Monday, August 24, 2020

Pride and Prejudice Personal Response Essay

Jane Austen’s tale, Pride and Prejudice, is an incredible portrayal of how life during the 1800s would have been. Arrangement in the public eye assumed a significant job and the majority of her characters just did what society allowed them to do. The individuals what your identity was encircled around either broke you or made you an impact on the town. The ladies appeared to search just for somebody to wed them, not for somebody to cherish them. The ladies in this novel, scanned for men with riches and influence. They just looked on a superficial level and couldn't have cared less enough to look past. They appeared every other lady of their time, just searching for a man to call spouse, and to keep them as embellishments, as opposed to sweethearts. This book, as I would like to think, didn't show numerous profound emotions, or any adoration included, aside from Elizabeth. It demonstrated that most ladies were materialistic and accepted what you had made you as an individual. Marriage was not an indication of affection spoke to in the book, yet as only a prize to flaunt to other people. The book doesn't show the characters with much distinction, anticipating all the ladies searching for something very similar: an attractive spouse with cash. Taking a gander at this, I believe that Austen did it purposefully. The various characters were foils to make Elizabeth stick out. Austen may have particularly misrepresented the longing of ladies frantically needing marriage be that as it may, Elizabeth indicated that only one out of every odd choice depended on budgetary soundness, seeing that she dismissed two potential spouses. My preferred thing about this book is Elizabeth’s smart perceptions about different characters. She can see through all the garbage in her life. She had her very own brain and she realized how to utilize it, she was not going to be influenced by ladies like Lady Catherine, who never really judge the individuals who she felt were not equal to her. However, as I would see it, one character isn't sufficient to represent the various character’s characters as they are for the most part shallow.

Saturday, August 22, 2020

Babies Essays

Children Essays Children Essay Children Essay How is the baby’s due date determined and for what reason is it frequently difficult to compute? The baby’s due date is determined by specialists and birthing assistants from the earliest starting point of the mother’s last period. This marker is utilized in light of the fact that it is hard to decide precisely when the mother is ovulating and therefore when the sperm is treated the egg. 2) Briefly clarify the procedure of origination? Ovulation, Development of Corpus Luteum, Release of Egg, Menses, Fertilization, Implantation, Pregnancy Hormones. 3) What is DNA? DNA, or deoxyribonucleic corrosive, is the inherited material in people and practically all other organisms.Nearly every phone in a person’s body has a similar DNA. Most DNA is situated in the cell core yet a limited quantity of DNA can likewise be found in the mitochondria. 4) How long is the germinal stage? Clarify what occurs in this stage. The germinal stage endures just around fourteen days. Inside only a couple of hours after origination, the single-celled zygote starts making an excursion down the fallopian cylinder to the uterus where it will start the procedure of cell division and development. 5) How would pregnancy be able to be recognized? What hormones assume a critical job in this? You can distinguish pregnancy by specific indications. A pregnancy test can be detected.The hCG hormone assumes a job in this. 6) Describe the physical improvement that happens comparable to the ectoderm, mesoderm and endoderm. 7) What happens 18 days after origination? The undeveloped organism initiates development inside the uterus. It is isolated into three layers that will later shape organs and tissues. The neural cylinder creates in the top layer. A portion of these cells will additionally practice, growing outward to cover the body with skin, hair and nails. The heart and the circulatory framework start to show up in the center layer. The third layer begins to house the lungs, digestion tracts and beginnings of the urinary system.In the interim, the early division of the placenta, the chorionic villi, and the umbilical string, which conveys sustenance and oxygen to the undeveloped organism, are as of now working. Low on the sides of the head, two folds are obvious †tissue that will end up being the ears. 8) Why is the early stage thought about a basic period? Since the early stage time frame is the point at which the undeveloped organism experiences childhood in to hatchling by playing out a few procedures, these procedure are so much significant that on the off chance that these are not occur meanwhile, at that point the baby may get numerous distortions and anomolies . ) Briefly depict the fetal stage. The fetal phase of pre-birth improvement might be characterized as starting at the eleventh week in gestational age, which is the ninth week after treatment. In natural terms, be that as it may, pre-birth advancement is a continuum, with no reasonab le characterizing highlight recognizing an incipient organism from an embryo. The utilization of the term baby by and large suggests that a mammalian undeveloped organism has created to the point of being conspicuous as having a place with its own species, however where this happens is subjective.A embryo is likewise described by the nearness of all the significant body organs, however they may not yet be completely utilitarian, or arranged in their last anatomical area. 10) What is the placenta? Talk about its significance. The placenta is an organ connected to the covering of your belly during pregnancy. It keeps your unborn baby’s blood gracefully separate from your own blood flexibly, just as giving a connection between the two. The connection empowers the placenta to do capacities that your unborn infant can’t perform for itself. The placenta is connected to your child by the umbilical cord.Your infant is inside a pack of liquid called the amniotic sac, which is m ade of films. Oxygen and food go from your blood flexibly into the placenta. From that point, the umbilical rope conveys the oxygen and food to your unborn infant. Squander items from the infant, for example, carbon dioxide, go back along the umbilical rope to the placenta and afterward into your circulation system, for your body to discard them. The placenta produces hormones that help your infant to develop and create. The placenta likewise gives some assurance against disease for your child while its in the belly. It ensures your child against most bacteria.However, it doesn't secure your infant against infections. For instance, if you’re not invulnerable to the rubella infection (German measles), it can cross the placenta and cause unsuccessful labor, stillbirth or birth deformities, for example, deafness, mind harm, heart imperfections and waterfalls. Liquor, nicotine and different medications can likewise cross the placenta and can make harm your unborn child. Towards t he finish of your pregnancy, the placenta passes antibodies from you to your child, giving them insusceptibility for around a quarter of a year after birth. Notwithstanding, it just passes on antibodies that you as of now have.

Sunday, July 19, 2020

Signs of Pathological Gambling and Gambling Addiction

Signs of Pathological Gambling and Gambling Addiction Addiction Addictive Behaviors Print Signs of Pathological Gambling and Gambling Addiction By Elizabeth Hartney, BSc., MSc., MA, PhD Elizabeth Hartney, BSc, MSc, MA, PhD is a psychologist, professor, and Director of the Centre for Health Leadership and Research at Royal Roads University, Canada. Learn about our editorial policy Elizabeth Hartney, BSc., MSc., MA, PhD Medically reviewed by Medically reviewed by Steven Gans, MD on December 08, 2015 Steven Gans, MD is board-certified in psychiatry and is an active supervisor, teacher, and mentor at Massachusetts General Hospital. Learn about our Medical Review Board Steven Gans, MD Updated on July 10, 2019 Eric Raptosh Photography/Getty Images More in Addiction Addictive Behaviors Caffeine Internet Shopping Sex Alcohol Use Drug Use Nicotine Use Coping and Recovery Gambling addiction, also known as pathological gambling, compulsive gambling, problem gambling, or gambling disorder involves maladaptive patterns of gambling behavior that the individual persists with, despite negative consequences. This is consistent with behavior patterns observed in other addictions.   Gambling Disorder is currently the only behavioral addiction included in the Diagnostic and Statistical Manual of Mental Disorders (DSM 5). Previously, Pathological Gambling was classified as an Impulse Control Disorder, where the “essential feature is the failure to resist an impulse, drive or temptation to perform an act that is harmful to the person or to others” (p. 609, DSM-IV, American Psychiatric Association, 1994). Pathological Gambling has been renamed Gambling Disorder and moved to a new category, Addiction and Related Disorders in DSM 5. As problem gambling has been increasingly recognized, treatment of problem gambling has fallen within the realm of addiction services. Not All Gambling Is Harmful Not all excessive gamblers are pathological, compulsive or problem gamblers. There are several different types of a gambler. Pathological gambling is characterized by: Preoccupation with gamblingDifficulty controlling gambling behavior, and unsuccessful efforts to stopNegative consequences, such as family and job disruption, and lying about the extent of involvement with gamblingFinancial problems due to gambling, gambling with increasing amounts of money to achieve desired excitement and stealing money to fund gambling.Chasing losses Money is central to the experience of gambling. People with gambling addiction, as with other people, attach many different positive attributes to money, such as power, comfort, security and freedom. Unlike other people, they fail to recognize that gambling puts them at risk of losing all of these attributes and that gambling is a random process, where the odds are stacked against them, so they are more likely to lose than to win. Furthermore, when they do win, people with gambling addictions tend to gamble away their winnings quickly. Gambling Behaviors There are many different gambling behaviors, which can be engaged in either alone or in social settings. Some examples of gambling behaviors are: Card games, such as pokerBetting on games of skillSports bettingBingoLotteriesSlot machines, VLTsCasinosScratchcards, break open or pull tab ticketsRaffles Cognitive Distortions Gambling is an ineffective and unreliable way of acquiring money. For someone to become addicted to gambling, their cognitions or thought processes must become distorted to the point where this central truth eludes them. Many problem gamblers’ thoughts are distorted in the following ways: Attribution: Problem gamblers may believe their winnings occur as a result of their efforts and not randomly. Magical thinking: Problem gamblers may believe that thinking or hoping in a certain way will bring about a win or that random outcomes can be predicted. They may also believe they are special in some way and that their specialness will be rewarded with a win. Superstitions: Problem gamblers may believe that lucky charms, certain articles of clothing, ways of sitting, etc., may cause a win or a loss. Systems: Problem gamblers may believe that by learning or figuring out a certain system (a pattern of betting in a particular way), the house advantage can be overcome. Although professional gamblers were more able to predict payouts with earlier technologies, which relied on more predictable patterns of payouts, this required many hours of careful observation, and the machine always kept more than it paid out. The increased computerization of gambling machinery has ensured that wins are now truly random, so it is impossible to predict a payout, and, of course, it is still heavily stacked in favor of the “house.” Selective recall: Problem gamblers tend to remember their wins and forget or gloss over their losses. The personification of a gambling device: Problem gamblers sometimes attribute human characteristics to inanimate objects, which are part of the gambling process, thinking that a particular machine is punishing, rewarding or taunting them. Near miss beliefs: Problem gamblers reduce the number of losing experiences in their minds by thinking they “almost” won. This justifies further attempts to win. Near misses can be as stimulating, or even more stimulating, than actual wins. Chasing losses: Problem gamblers believe that they have not really lost money to gambling, but that it can be “won back” by further gambling. Many of these thought distortions lead to highly ritualized patterns of behavior, which are characteristic of addictions. The Controversy of Gambling Addiction Like other behavioral addictions, gambling addiction is a controversial idea. Many experts balk at the idea that gambling can constitute an addiction, believing that there has to be a psychoactive substance that produces symptoms, such as physical tolerance and withdrawal, for an activity to be a true addiction. Gambling, however, is by far the best represented behavioral addiction in research literature and treatment services; therefore, pathological gambling has the most credibility among the behavioral addictions. This is partly due to financial input from the gambling industry, whose contribution is tiny compared to the massive profits they make but greatly exceeds funding for research or treatment of any other behavioral addiction. Despite the fact that this funding has greatly increased public awareness of gambling problems and treatment services, the potential conflict of interest when funding comes from a source that makes a profit from gambling addiction is obvious. The 9 Best Online Therapy Programs

Thursday, May 21, 2020

Facts About Milk and Whats Wrong With Milk

It may be difficult to understand, at first, why vegans abstain from drinking milk. It’s supposedly wholesome and healthy, and if the advertising is to be believed, comes from â€Å"happy cows.† If you look beyond the image and examine the facts, you’ll find that the objections range from animal rights to the environment to health concerns. Animal Rights Because cows are sentient and capable of suffering and feeling pain, they have a right to be free of use and abuse by human. No matter how well the animal is cared for, taking breast milk from another animal violates that right to be free, even if cows were allowed to live out their lives on idyllic green pastures. Factory Farming Many believe that drinking milk is fine as long as the cows are treated humanely, but modern factory farming practices mean that cows do not live out their lives on idyllic green pastures. Gone are the days when farmhands just used their hands and a milk pail. Cows are now milked with milking machines, which cause mastitis. They are artificially inseminated as soon as they are old enough to become pregnant, give birth and produce milk. After two cycles of pregnancy and birth, when they are about four or five years old, they are slaughtered because they are considered â€Å"spent† and no longer profitable. When they are sent to slaughter, approximately 10% of them are so weak, they cannot stand on their own. These cows would normally live about 25 years. Cows today are also bred and raised to produce more milk than in past decades. PETA explains: On any given day, there are more than 8 million cows on U.S. dairy farms—about 14 million fewer than there were in 1950. Yet milk production has continued to increase, from 116 billion pounds of milk per year in 1950 to 170 billion pounds in 2004.(6,7) Normally, these animals would produce only enough milk to meet the needs of their calves (around 16 pounds per day), but genetic manipulation, antibiotics, and hormones are used to force each cow to produce more than 18,000 pounds of milk each year (an average of 50 pounds per day). Part of the increased milk production is due to breeding, and part of it is due to unnatural husbandry practices, such as feeding meat to the cows and giving rBGH to cows. Environment Animal agriculture is a very inefficient use of resources and is damaging to the environment. Water, fertilizer, pesticides and land are required to grow crops to feed to cows. Energy is needed to harvest the crops, turn the crops into feed, and then transport the feed to farms. The cows must also be given water to drink. The waste and methane from factory farms are also an environmental hazard. The US Environmental Protection Agency states, â€Å"In the U.S., cattle emit about 5.5 million metric tons of methane per year into the atmosphere, accounting for 20% of U.S. methane emissions.† Veal Another concern is veal. Approximately three quarters of the calves born in the dairy industry are turned into veal, because they are not needed or useful for milk production, and are the wrong breed of cattle for beef production. What About â€Å"Happy Cows†? Even on farms where the cows are not constantly confined, the female cows are slaughtered when their milk production drops and three-quarters of the calves are turned into veal. Don’t We Need Milk? Milk is not necessary for human health, and may be a health risk. Except for domesticated animals to whom we feed milk, humans are the only species that drinks the breast milk of another species, and the only species that continues to drink breast milk into adulthood. Furthermore, dairy consumption raises certain health concerns, such as cancer, heart disease, hormones and contaminants.

Wednesday, May 6, 2020

The Relationship Between Flexibility Benefits Used And...

The article by Cicei (2015) discusses one of the greatest challenges to families in today’s society, which is work family conflict. In the workforce today, and in numerous households people struggle with being able to balance family time and the responsibilities of their chosen career without creating disturbance within their home. As a way to lessen these disputes corporations have begun to provide certain benefits, organizations, and flexible work arrangements to their employees. However, in recent studies that examine the use of flexible work arrangements and reduced levels of work-family conflict no significant results of reduced disturbance has been reported (Cicei, 2015). Since there have been no significant results Cicei (2015) conducted a study in this article to examine the relationship between the flexibility benefits used and work-family conflict, focusing especially on the role flextime and telecommuting (Cicei, 2015). To validate whether flexible work arrangements have a negative effect on work and family conflict, the conducted study examined the relationship between the use of flexible work arrangements and three forms of work family conflict. The flexible work arrangements utilized in the study included flextime, compressed workweek, telecommuting, and part-time work (Cicei, 2015). The three forms of work conflict were time-based, strain-based, and behavior based (Cicei, 2015). The participants consisted of 102 individuals who worked in IT, education, andShow MoreRelatedSynthesis Of Text 12 And 31605 Words   |  7 Pagesparental leave policy: a change in impact factors across three articles from 2008-2014. Introduction Traditional family model changed a lot these years, women have their own jobs and cannot pay all their attention to their families as they used to. Therefore, parental leave policy is put forward for to decrease work-family conflict for both men and women. 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These include personal differences, Informal deficiencies’, role incompatibility, environment stress, perceptions, and expectations. Personal differences could be related to personal values, physiognomies, family bonds or ties, and material belongings. Moreover, job performance, education, knowledge, and training tend to mold each individualRead MoreThe Benefits and Challenges of Developing Play/Leisure Activities 997 Words   |  4 Pagesthat work with children experience the skilfulness to prompt or even contribute to a child’s play, which is a principle constituent to therapeutic alliance. However, for those children mentioned above, what happens when play becomes nonexistent or deprived, then how do these children engage in play? 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Unemployment and inflation Free Essays

The rise in energy prices reduces the productivity of capital per worker. This causes sf(k) to shift down from sfl(k) to sf2(k). The result is a decline in steady-state k. We will write a custom essay sample on Unemployment and inflation or any similar topic only for you Order Now Steady-state consumption per worker falls for two reasons: (1) Each unit of capital has a lower productivity, and (2) steady-state k is reduced. population growth rate permanently increased due to increased immigration Immigration raises n from nl to n2. The rise in n lowers steady-state k, leading toa lower steady-state consumption per worker. c. A temporary rise in s has no effect on the steady-state equilibrium. . The increase in the labor force participation rate does not affect the growth rate of the labor force, so there is no impact on the steady-state capital-labor ratio or on consumption per worker. However, because a larger fraction of the population is working, consumption per person increases. Question 4 How would each of the following affect the national saving, investment the current account balance and the real interest rate in the large economy (a) The home countrys saving curve shifts to the right, from Sl to S2. The real world interest rate falls, so that the current account surplus in the home country equals the current ccount deficit in the foreign country. National S rises, I rises, CA rises, rw falls. (b) The foreign countrys saving curve shifts to the right, from Sl For to S2For. The real world interest rate must fall, so the current account surplus in the foreign country equals the current account deficit in the home country. National S falls, I rises, CA falls, rw falls. C The foreign countrys saving curve shifts to the left, from Sl For to S2For. The real world interest rate must rise, so the current account deficit in the foreign country equals the current account surplus in the home country. National S rises, I falls, CA ises, rw rises. (c) If Ricardian equivalence holds, there is no effect. If Ricardian equivalence does not hold, then the result is the same as in part (b), as the toreign count saving curve shifts to the right. That is because all else equal, higher taxes increase government saving more than they reduce private saving. Question 3. Explain how each of the following transaction would enter the Bahamas Question 3 a Income receipt from abroad: credit entry in current account. b Import of assets: debit entry in capital and financial account. (c Import of services: debit entry in current account. (d Increase in foreign ownership of U. S. assets: credit entry in capital and financial account. Question2. Assume (a) Desired consumption declines as the real interest rate rises because the higher return to saving encourages higher saving; desired investment declines as the real interest rate rises becauses the user cost of capital is higher, reducing the desired capital stock, and thus investment. (b) Recall that Sd = Y -Cd – G, so Sd = 9000 -Cd – ld 2 6100 1 500 3 1400 1 ooo 4 5900 1300 1100 9200 5 1200 6 5700 equilibrium. Given Y 9000, the equili brium condition holds only at r = 5%. Atr = 5% it is also true that Sd = = 1200. Question 1 Keynesians and classicals differ sharply in their beliefs about how long it takes the economy to reach a long-run equilibrium. Classical economists believe that prices adjust rapidly (within a few months) to restore equilibrium in the face of a shock, while Keynesians believe that prices adjust slowly, taking perhaps several years. Because of the time it takes for the economy’s equilibrium to be restored, Keynesians see an important role for the government in fighting recessions. But because classicals believe that equilibrium is restored quickly, there’s no need for government policy to fght recessions. Since classicals think equilibrium is restored quickly in the face of shocks, aggregate demand shocks can’t cause recessions, since they can’t affect output for very long. So classical economists think recessions are caused by aggregate supply shocks. Keynesians, however, think that both aggregate demand and aggregate supply shocks are capable of causing recessions. Question 8 Growth that is â€Å"too rapid† most likely refers to a situation in which the aggregate demand curve has shifted to the right and, in the short run, intersects the SRAS curve at a level of output that’s greater than the full-employment level of output. This situation is associated with inflation because, in the long run, prices will rise, shifting the SRAS curve up to intersect with the LRAS and AD curves. The shock that is implicitly assumed to be hitting the economy is an aggregate demand shock, since that’s the only shock that increases output in the short run and inflation in the long run. Question 10 The temporary increase in government purchases causes an income effect that increases workers’ labor supply. This results in an increase in the full-employment level of output from FEI to FE2 in Figure 10. 10. The increase in government urchases also shifts the IS curve up and to the right from ISI to IS2, as it reduces national saving. Assuming that the shift up of the IS curve is so large that it intersects the LM curve to the right of the FE line, the price level must rise to get back to equilibrium at full employment, by shifting the LM curve up and to the left from LMI to LM2. The result is an increase in output and the real interest rate. figure 10. 11 shows the impact on the labor market. Labor supply shifts from NSI to NS2, leading to a decline in the real wage and a rise in employment. Average labor productivity declines, since employment rises while capita ixed. Investmentdeclines, since the real interest rate rises. To summarize, in response to a temporary increase in government purchases, output, the real interest rate, the price level, and employment rise, while average labor productivity and investment decline. (a) The business cycle fact is that employment is procyclical. The model is consistent with this fact, since employment rises when government purchases rise, causing output to rise. (b) The business cycle fact is that the real wage is mildly procyclical. The model is inconsistent with this fact, since it shows a decline in the real wage when government purchases rise and c) The business cycle fact is that average labor productivity is output rises. procyclical. The model is inconsistent with this fact, since it shows a decline in average labor productivity when government purchases rise and output rises. (d) The business cycle fact is that investment is procyclical. The model is not consistent with this fact, as investment falls when government purchases rise and output rises. (e) The business cycle fact is that the price level is procyclical. The model is consistent with this fact, as the price level rises when government purchases increase and output increases. Question 6 and 7 (a) An increase in government purchases reduces national saving, causing the real interest rate to rise for a fixed level of income. If the real interest rate is higher, then real money demand will be lower. The price level must rise. The result is that output is unchanged, the real interest rate increases, and the price level increases. 6 (b) 7aWhen expected inflation falls, real money demand increases. There is no effect on employment, saving or investment, so output and the real interest rate remain unchanged. With higher real money demand and an unchanged nominal money supply, the equilibrium price level must decline. b) When labor supply rises, full- employment output increases. Higher output means higher income, so saving will increase. More saving means the real interest rate will decline. Both higher output and a lower real interest rate increase real money demand. Higher money demand with a constant money supply means the price level must decline. 17 c When the interest rate paid on money increases, real money demand rises. That is because the cost of holding money falls. With no effect on employment or saving and investment, output and the real interest rate remain unchanged. With higher real money demand and an unchanged nominal money supply, the quilibrium price level must decline. Question 11 and 12 In Figures 11 . 17-11. 20, point A is the starting point, point B shows the short-run equilibrium after the change, and point C shows the long-run equilibrium after the change. (a) In Figure 11. 7, when banks pay a higher interest rate on checking accounts, the demand for money rises, shifting the LM curve up and to the left from LMI to LM2 in Figure 11 . 17(a). As a result, the AD curve shifts down and to the 2 in Figure ) The new snort-run equilibrium occurs at point B, where output is lower, the real interest rate is higher, employment is lower, and the price level is unchanged. In the long run, the price level decreases to shift the LM curve from LM2 to LM3, which is the same as LMI, to restore equilibrium at point C. As a result, the short-run aggregate supply curve shifts down from SRASI to SRAS2. At the new equilibrium, compared to the starting point, output is the same, the real interest rate is the same, employment is the same, and the price level is lower. Figure 11. 17 (b) In Figure 11. 18, the introduction of credit cards reduces the demand for money†shifting the LM curve down and to the right from LMI to LM2 in Figure 11 . 18(a). As a result, the AD curve shifts from ADI to AD2 in Figure 11. 8(b). The new short-run equilibrium occurs at point B, where output is higher, the real interest rate is lower, employment is higher, and the price level is unchanged. In the long run, the price level increases to shift the LM curve from LM2 to LM3, which is the same as LMI, to restore equilibrium at point C. As a result, the short-run aggregate supply curve shifts up from SRASI to SRAS2. At the new equilibrium, compared to the starting point, output is the same, the real interest rate is the same, employment is the same, and the price level is higher. Figure 11. 18 (c) In Figure 11. 9, the reduction in agricultural output shifts the FE curve to the left from FEI to FE2, and shifts the LRAS line from LRASI to LRAS2. The rise in agricultural prices increases the price level, so the short-run aggregate supply curve shifts up from SRASI to SRAS2. Also, the rise in the price level shifts the LM curve up and to the left from LMI to LM2. The short-run equilibrium is at point B, assuming that the LM curve shifts so much that it intersects the IS curve to the left of the FE line. At point B, compared to the starting point, output is lower, the real interest rate is higher, employment is lower, and the price level is higher. Figure 11. 19 If the water shortage persists, a new long-run equilibrium occurs at point C. To get to this equilibrium, the price level must decline, shifting the LM curve from LM2 to LM3, and the short-run aggregate supply curve from SRAS2 to SRAS3. Relative to point B, the new equilibrium has a higher output level, a lower real interest rate, higher employment, and a lower price level. (Relative to the initial equilibrium at point A, output and employment are lower, and the real interest rate and the price level are higher. How to cite Unemployment and inflation, Papers

Sunday, April 26, 2020

Nollan Vs. CCC Essays - Supreme Court Of The United States

Nollan vs. CCC Environmental Law Nollan vs. CCC Abstract of: 483 U.S. 825, 97 L. Ed.2d 677 James Patrick Nollan, et ux., Appellant v. California Coastal Commission. Case Definition: The case is Nollan versus the California Coastal Commission. The Nollans were the appellates against a decision made by the California Coastal Commission (CCC). The Nollans had been leasing a property on the California coast with which they had an option to buy. The property lies directly at the foot of the Pacific Ocean and is a prime piece of real estate on the California Coast. The property had been used by the Nollans to rent out during the summer months to vacationers. At the end of the Nollans' lease they took the option to purchase the land and began preparing for the terms of purchase by the previous land owner. Among those terms was the demolishing of the small deteriorating bungalow that the Nollans had been leasing. The Nollans had planned to expand the structure from the small bungalow that it was to a three bedroom house more complimentary to the surrounding homes and their needs. In order to begin destruction of the property and begin rebuilding the site the Nollans had to secure a permit from the California Coastal Commission. Upon submitting the permit application, the CCC found that the permit should be granted on the condition that the Nollans provide public access to the beach and to the local county park, which lay adjacent to the property. This provision called for the Nollans to use a portion of their land to be used as a public walkway to the beach and park. The Nollans protested to the condition, but the CCC overruled the objection and granted the permit with the condition intact. Case Decision: The Nollans filed a petition to the Ventura County Superior Court asking that the condition to supply easement be removed from their permit. The Nollans' argument was that there was not enough evidence to support the developments limiting of public access to the beach. The argument was agreed upon by the court and the case was remanded to the California Coastal Commission for a full evidentiary hearing on the issue of public access to the beach. The CCC held a public hearing which led to further factual findings which reaffirmed the need for the condition. The CCC's argument was that the building of the new structure would limit view of the ocean, and therefore limit access to the public who had full rights to use the beach. To compensate for the limitations on the public the Nollans would have to provide access to the beach from their property. The CCC also noted that all of the other developments on the same tract of land had been conditioned similarly in having to provide public access to the ocean. The Nollans filed a supplemental petition for a writ of administrative mandamus (a writ that would order a public official or body to comply with a specified duty issued by a superior court). The Nollans argument was that the permit condition violated the Takings Clause in the V Amendment, and also in the XIV Amendment of the Constitution. The court agreed that the administrative record did not provide for in showing the existence of adverse impact on the publics' access to the ocean. The court granted the writ of mandamus, and directed that the public access condition be removed from the permit. The CCC appealed the case in the California Court of Appeal and won the decision. The Court of Appeal found an error in the Supreme Courts interpretation of the Coastal Act which mandates public access to any category of developments on the coast. The Court of Appeal also found that the Takings claim was unsubstantiated by the Nollans. The permit condition did take from the value of the land, but did not restrict them of reasonable use of their property. The Nollans then appealed to the United States Supreme Court. The argument made by the Nollans continued to revolve around the Takings Clause in the V Amendment. The Supreme Court found that the requirement of the permit only put a restriction on the use of the property and not a ?taking? of the property. The Supreme Court also held the California State Constitution to have standing, and upheld the ruling made by the Court of Appeals. Reasoning for Decision: I believe that the reason the Supreme Court decided as it did was that its interpretation of the California State Constitution provided for the authority of the CCC's permit regulation. The part within the states constitution says that access to any