Wednesday, May 6, 2020
The Doctrine Of Separate Legal Entity A Case Of Salomon Vs Salomon Co Ltd Free Essays
string(70) " legislatures and courts have followed the separate entity principle\." Abstract The doctrine of separate legal entity is a doctrine which has gained increasing importance in the analysis of company law. The importance of this doctrine and its relevance in the analysis of laws relating to companies is evident in the case of Salomon v A Salomon and Co Ltd [1897] AC22, the leading case which gave effect to the separate entity principle (Macintyre 2012). This case has formed the basis of company law and corporate theory. We will write a custom essay sample on The Doctrine Of Separate Legal Entity: A Case Of Salomon Vs Salomon Co Ltd or any similar topic only for you Order Now Not only is this case often quoted in textbooks and journal articles, but also, its principles have found their way to English courtrooms and law firms (Karasz 2012) Aligning with the above, this paper explains the following statement made by Lord Halsbury in Salomonââ¬â¢s case ââ¬Å"Either the limited company was a legal entity or it was not. If it was, the business belonged to it and not to Mr. C Salomon. If it was not, there was no person and nothing to be an agent at all; and it is impossible to say at the same time that there is a company and there is notâ⬠(Roach 2012). Attempts will be made in this paper to analyze courtsââ¬â¢ approach to the separate entity principle. Criticism against the decision made by the House of Lords in salomonââ¬â¢s case will also be examined. Statutory and judicial exceptions to Salomon shall also be explored on. Introduction Corporate theory has certain principles which practitioners and academics have struggled to define. Some of these principles seem somehow unsuitable for strict and permanent delineations given that their construction often change with time (Karasz 2012). The case of Salomon V. Salomon and Co. Ltd which has formed the basis of company law globally is one such example. Not only is this case often quoted in textbooks and journal articles, but also, its principles have found their way to English courtrooms and law firms (Karasz, 2012). The doctrine of ââ¬Ëseparate legal personalityââ¬â¢ laid down in Salomonââ¬â¢s case has received increased recognition and is often cited in court today. In this paper we explore on the following statement made by Lord Halsbury L.C. in Salomonââ¬â¢s case and analyze the courtsââ¬â¢ approach to the separate entity principle. ââ¬Å"Either the limited company was a legal entity or it was not. If it was, the business belonged to it and not to Mr. C Salomon. If it was not, there was no person and nothing to be an agent at all; and it is impossible to say at the same time that there is a company and there is notâ⬠(Roach 2012). We will also try to find the basis under which courts may decide to disregard the separate personality of a company. A delve on this topic will not be complete without exploring on Salomonââ¬â¢s case. Salomon v Salomon Co Ltd The case of Salomon v Salomon revolves around Mr. Salomon, a businessman who incorporated his business; and given the requirements put forth in the Companies Act 1862 which require the presence of at least seven shareholders, he made his family members as business partners issuing one share to each of them (Keenan Riches 2009). The business was bought at ?39,000. Mr. Salomon held some 20,000 shares and since ?10,000 was not paid for, he was paid the remaining amount by debentures and granted a floating charge on the companyââ¬â¢s assets as part payment (Keenan Riches 2009). Soon after the business had been incorporated, the shoe industry witnessed a series of strike which led to the governmentââ¬â¢s decision to split contracts with several other firms with the aim of diversifying and reducing the risk of its few suppliers, given the ongoing strikes (Keenan Riches 2009). Since the company was in need of more funds, they sought ?5,000 from Broderip. Salomonââ¬â¢s debenture was then assigned to Broderip and secured by a floating charge (Keenan Riches 2009). In the end, however, the business failed and Broderip sued to enforce his security. Given that, at the time, the company was indebted to unsecured creditors; an action against the appellant was brought by the companyââ¬â¢s liquidator and the case tried before Vaughan Williams, J. of the high court (Keenan Riches 2009). Vaughan Williams J declared Broderipââ¬â¢s claim to be valid arguing that the signatories were just but mere dummies and that Mr. Salomon was acting as an agent of the company (Keenan Riches 2009). Thus the company was entitled to indemnity from the principal who in this case was Mr. Salomon (Keenan Riches 2009). The ruling made by the Court of Appeal further confirmed the earlier decision made by Vaughan William. The Court of Appeal ruled that Broderipââ¬â¢s claim was valid on grounds that the Appellant had abused the privileges of incorporation (Macintyre 2012). According to the Court of Appeal, the incorporation of the company was improper as the Act only contemplated the incorporation of independent bona fide shareholders with the will and minds of their own and not mere puppets (Macintyre 2012) This decision was, however, unanimously overturned by the House of Lords and the arguments of fraud and agency rejected (Macintyre 2012). They held that the Act had to be the sole guide for determining whether a company had been validly constituted. According to the Companies Act 1862, just a share was enough for one to be named as a member. It was therefore not in order to label shareholders as dummies or mere puppets since the company had been duly constituted by law and thus had a separate legal entity (Macintyre 2012). The House of Lords remarked that it was improper for the judges to read into the statute limitations based on their personal opinion (Macintyre 2012). The House further noted that while the company remained precisely the same even after being incorporated with the same hands receiving profits; by law, the company was not an agent nor a trustee of the subscribers and the subscribers were also not liable for any of the companyââ¬â¢s liabilities (Macintyre 2012). Since then, legislatures and courts have followed the separate entity principle. You read "The Doctrine Of Separate Legal Entity: A Case Of Salomon Vs Salomon Co Ltd" in category "Essay examples" This principle which is enshrined in article 16 of the Companies Act 1997 have since been followed in company proceedings in court. Salomonââ¬â¢s case has become a landmark company case law in the UK and is often cited in most cases within the area of company law. The principle established in Salomon vs. Salomon Co Ltd has stood the test of time, given that this doctrine has formed the basis of company law (Puig 2000). As noted in Salomonââ¬â¢s case, a company is at law a legal entity separate from its members and can neither be an agent nor a trustee of the subscribers. The decision made by the House of Lords in Salomonââ¬â¢s case confirms Gooleyââ¬â¢s observations that the doctrine of separate legal personality was a ââ¬Ëdouble-edged swordââ¬â¢ (Puig 2000). While this decision was good as it promoted capitalism, the decision also extended the benefits of incorporation to private businesses thereby providing for fraud and evasion of legal obligations (Puig 2000). This criticism will be examined in detail in the next section. Criticism against Salomonââ¬â¢s case Despite having been cited in court, Salomonââ¬â¢s case has met considerable criticism. Much of the criticism has been based on the fact that corporate veil may at times lead to injustice. For example, in the article 7 Modern Law Review 54, Kahn-Freund described the decision made in Salomonââ¬â¢s case as ââ¬Å"calamitousâ⬠. Kahn-Freund further called for the abolition of private companies. Criticism is also mounted against Salomonââ¬â¢s case on the basis that priority is given to the separate identity principle over the economic reality of a one-person company. In the article, The Law Quarterly Review, Goulding explains that criticism laid against Salomonââ¬â¢s case is two-fold. First, the unanimous ruling made by the House of Lords in this case gives incorporators the benefit of limited liability even in situations where it may be deemed unnecessary. Second, this decision affords unscrupulous promoters opportunities to abuse the privileges provided for under the Corporations Act. Piercing of the corporate veil Despite the seemingly categorical statement made by Lord Halsbury in Salomonââ¬â¢s case, a few years later, the English court held that in certain situations it was permissible to disregard this principle and to ââ¬Ëpierce the corporate veilââ¬â¢ (Mugambwa 2007). In this context, ââ¬Ëpiercing of corporate veilââ¬â¢ describes situations wherein the separate entity principle may be deemed unfair and the courts may make decisions contrary to this principle on various grounds. The court often does this so as to reach the person behind the veil and to reveal the true nature of the company (Mugambwa 2007) It has however become a hard task for academics and practitioners to find a basis in which courts may lift the veil. This is an area which is said to be ill-defined, inconsistent and quite unpredictable. In Briggs v James Hardie Co Pty Ltd, Rogers AJA point out to the lack of a common and unifying principle underlying the courtââ¬â¢s decision to lift or ignore the corporate veil (Macintyre 2012). In determining when to disregard the separate entity principle, commentators have often divided their instances into several distinct categories and often there is no consensus as to the number or type of categories, with some similar cases being placed in different categories. The ultimate policy for lifting the veil also remains elusive with some arguing that it depends on ââ¬Ëpolicyââ¬â¢ while others arguing that it depends on ââ¬Ëjusticeââ¬â¢ (Mugambwa 2007). Attempts have been made by commentators to categorize cases with the view of predicting the outcome of future cases but this has proved difficult largely due to the fact that this is an area where case facts have significant influence on the outcome. It has also proved difficult to rationalize and categorize cases since this is an area in which the personal views of judges have a bearing on what justifies lifting the corporate veil (Karasz 2012). Statutory and judicial exceptions Despite being enshrined in the Companies Act 1997, significant exceptions have been made to the separate entity principle (Macintyre 2012). In other words, there are certain situations in which the courts can legitimately disregard the separate legal entity principle. According to Bourne (2001), there are two main exceptions to the separate entity principle. These are statutory and judicial exceptions. In this context, statutory exceptions include provisions that penalize office holders by imposing personal liability. Several statutory provisions have introduced exceptions to the separate legal entity principle. One such statute is the Insolvency Act 1986 which involves fraudulent or rather wrongful trading (Roach 2012). In pursuant to the ââ¬Ëfraudulent tradingââ¬â¢ provision, if it appears that fraud has been used in carrying out business transactions, the court may on application of the liquidator declare any of the parties to the business liable for making contributions as may be deemed necessary by the court (Roach 2012). Judicial exceptions, on the other hand, are concerned with the companyââ¬â¢s separate legal personality. These exceptions have, however, proven hard to define. Justification for making such exceptions also differs greatly. Sealy Worthington (2010) gave an example wherein court may make such exceptions. They argued that members can be declared by court liable where their acts constitute them as ââ¬Ëprincipalsââ¬â¢ and the company acting as merely an agent. This example, however, does not encompass all the judicial exceptions. One major group to this type of exception relates to fraud. In this respect, Linklater (2006) identifies three cases where fraud had significant influence on the courtââ¬â¢s decision to lift the corporate veil: Kensington International Ltd v Congo, R v K and Trustor v Smallbone. A common feature in all these cases is that they would all have passed Salomonââ¬â¢s test that ââ¬â ââ¬Ëeither the limited company was legal entity or it was notââ¬â¢ (Linklater 2006). There is, however, one element in all these cases which set them apart from Salomon: the fact that all the three cases were being used for fraud and to disguise the true state of affairs rather than being used for legitimate trading (Linklater 2006). Another group encompassing judicial exceptions relates to a group structure, wherein both the parent and subsidiary company are viewed as one. This can be seen in the case of Adams v Cape Industries Plc. The court of Appeal ruled that the subsidiary company acted as an agent to the parent company and thus had to be indemnified by the parent company. Another practical example wherein courts can disregard the doctrine of separate entity can be seen with certain court cases. In UK, courts may disregard Salamonââ¬â¢s precedent especially when public funds are at stake. In such cases, courts may decide to impose financial liability on the shareholders and directors of the company. While these exceptions have been viewed by many as undermining the doctrine of separate legal personality embodied in Salomonââ¬â¢s case, it should be noted that these exceptions serve to further define the doctrine by narrowing its scope and stipulating additional guidelines. Conclusion There is no doubt that the decision in Salomonââ¬â¢s case established the separate legal personality of a company, allowing shareholders to carry on trading with minimal exposure to the risk of personal insolvency in the event of a collapse. There are, however, exceptions to this principle wherein the court may justifiably disregard and make rulings contrary to this principle. It remains, however, a daunting task for academics and practitioners to find a basis in which the courts may be justified to lift the corporate veil. This is largely due to the fact that this is an area where case facts and personal views of judges have a bearing on the outcome. Nonetheless, the principle in Salomon case is widely recognized and followed in courts. This principle which is enshrined in article 16 of the Companies Act 1997 have since been followed in company proceedings in court. Salomonââ¬â¢s case has become a landmark company case law in the UK and is often cited in most cases within the area of company law Reference Bourne, N., 2001. Bourne on Company Law. 5th edition, Oxon, Routledge Gooley, J., 1995. Corporations and associations law: principles and issues. 3rd edition. Sydney: Butterworths Kahn-Freund, O., 1944. Some reflections on Company Law Reform. 7 Modern Law Review, page 54-66 Karasz, A., 2012, Corporate world today: courts respond to limited liability and boardââ¬â¢s decision making ââ¬â a fight for a justice or rather prosperity at stake Keenan, D. and S. Riches, 2009. Business law, 9th edition. Harlow, Pearson Longman. Linklater, L., 2006. ââ¬Ëâ⬠Piercing the corporate veilâ⬠ââ¬â the never ending story?ââ¬â¢ Comp. Law 27 (3), 65-66 Macintyre, E., 2012. Business law. 6th edition. Harlow: Pearson Longman. Mugambwa, J.T., 2007. Commercial and business organizations law in Papua New Guinea. Routledge-Cavendish Puig, G.V., 2000. A two-edged sword: Salomon and the separate legal entity doctrine. Corporation law. Vol.7 (3) Roach, L., 2012. Card Jamesââ¬â¢ Business Law for business, accounting and finance students. 2nd edition. OUP Oxford. Sealy, L. and S. Worthington, 2010. Sealyââ¬â¢s Cases and Materials in Company Law. 9th edn, Oxford, Oxford University Press. Stephen, J., 2008. Business organisations and the veil of incorporation. In: Q A: Company Law. Oxford university press. How to cite The Doctrine Of Separate Legal Entity: A Case Of Salomon Vs Salomon Co Ltd, Essay examples
Cloning Benefits Essay Research Paper Cloning Benefits free essay sample
Cloning Benefits Essay, Research Paper Cloning Benefits What if while walking down the street you encountered person who looked precisely like you? Would you gaze in astonishment or would your bosom be filled with fright? At first some people may look upon the thought of cloning with disgust and inquiry themselves if worlds should play God while others would be interested and study the many possibilities that cloning offers. This illustrates the way that cloning has taken over the latter portion of the 20th century. At first, when cloning was brought up in conversations, people tended to fearfully believe of an ground forces of indistinguishable individuals processing across the Earth in hopes of governing worlds. This and many other absurd impressions of ringers stem from scientific discipline fiction films and books where ringers are distorted into horrid, monstrous animals. In Ira Levin # 8217 ; s science fiction book, The Boys of Brazil, babe Adolf hitlers are cloned in order to take over Hitler # 8217 ; s dream of his race ruling the universe ( Harris 361 ) . This deformation was, and still is, a common misconception of the ends of cloning. In world, cloning, along with its opposite number cistron therapy, is non intended for the production of a to the full developed single. Alternatively, cloning and cistron therapy are about the medical promotion of the universe # 8217 ; s population through the control of diseases and replacing of losing endocrines and variety meats. Although there are statements against them, the possibilities of cloning and cistron therapy are of import for the production of variety meats and endocrines and as a means to command diseases, but both must besides be purely regulated in order to criminalize the production of fully-developed human ringers. Until 1997 the opportunity of mammalian cloning seemed merely approximately every bit improbable as happening a remedy for AIDS. However, 1997 marked the beginning of the fantastic engineering known as mammalian cloning. In that twelvemonth scientists in Scotland clon ed, for the first clip, a sheep ( # 8221 ; The Future # 8221 ; 46 ) . Since so people think that life scientists are cloning both human and other mammal # 8217 ; s embryos merely to see how far they can force the scientific envelope, but in fact there are many legitimate grounds for look intoing cloning. Embryologists believe that research into cloning could assist better the life of future coevalss. Cancer research is perchance the most of import ground for embryo cloning they argue. Oncologists believe that embryologic survey will progress apprehension of the rapid cell growing of malignant neoplastic disease. Cancer cells develop at about the same phenomenal velocity as embryologic cells do. By analyzing the embryologic cell growing, scientists may be able to find how to halt rapid cell division, and besides stop malignant neoplastic disease growing in bend ( Hyde 15 ) . Another of import country of embryo cloning research is embryologic root cell development. Stem cells are u niform cells that can develop into about any type of cell in the organic structure. These cells are non attacked by a individual # 8217 ; s immune system, because of their fast development and uniform position ( Wilmut 4 ) . Many physicians believe that these root cells could be used in interventions for encephalon and nervous system harm. Possibly a more questionable usage of cloned embryos is for trim parts and endocrines. Production of transgenic farm animate beings to do variety meats to transfer in worlds with organ failure has been to a great extent researched. Companies like Alexion Pharmaceutical have been working on the development of # 8220 ; hogs to turn Black Marias and kidneys that won # 8217 ; t be rejected in grafts # 8221 ; ( Reibstein 58 ) . For illustration, the cells used to bring forth tissues for organ transplant could include skin and blood cells for interventions of burn and other hurts, bone marrow grafts for leukaemia patients, and neurological tissues f or degenerative neurological diseases like Parkinson # 8217 ; s and Alzheimer # 8217 ; s ( Winston 913 ) . Obviously human embryo cloning is a great beginning for human promotion, and it is the engineering that will eventually do it possible to use familial technology to worlds. Familial technology involves splicing and recombining Deoxyribose Nucleic Acid ( DNA ) to make or repair a cistron on a chromosome. Many intervention drugs have been made through a process known as cistron splicing. Gene splice is a method in which whole cistrons or parts of cistrons are put into bacteriums where they are reproduced when the bacteriums divide. In 1982, two promotions in cistron splice were made ; Interferon, a drug used to handle malignant neoplastic disease, and Humulin, a man-made signifier of insulin used to handle diabetes, were produced through cistron splice ( Hyde 44 ) . Harmonizing to Hyde # 8217 ; s book, Cloning and the New Genetics, before cistron splice was used it took 20 tip and 80 pig pancreases to bring forth a twelvemonth # 8217 ; s supply of insulin for one individual. This may non sound like much, but when you consider the fact that about 60 million people have diabetes worldwide that is a batch of animate beings whose lives have been saved ( 61 ) . Another intervention greatly affected by familial technology is Human Growth Hormone ( HGH ) . Without HGH, kids # 8217 ; s growing is decreased so much they tend to look dwarfed. Alternatively of pull outing the pituitary secretory organs from 50 corpses per one kid, familial technology now allows scientists to utilize the common bacteriums E. Coli to bring forth HGH ( 62 ) . . Both cistron therapy and cloning are highly of import for the promotion of worlds. Harmonizing to D. J. Weatherall # 8217 ; s book, The New Genetics and Clinical Practice: # 8220 ; Finally, and possibly most importa nt[ly] in the long [run], these new analytical techniques will broaden the scope of the genetic analysis of human disease to encompass the cell and molecular biology of a variety of the major killers of western societies, in particular vascular disease, diabetes, cancer, rheumatic disease, and major psychiatric disorders.â⬠(2) Without these new technologies many people would die, and in order to continue with these technologies, we need to restrict only the parts that are harmful or unethical to society. Regulation and restriction must be established in order to outlaw the implantation of a cloned embryo into a womanââ¬â¢s womb. Because human embryo research is just in its infancy, there has been a rush to decide what guidelines are going to be instituted for governing cloning experiments. However, we must not make rash decisions to ban cloning because ââ¬Å"[w]hatââ¬â¢s at stake here are lifesaving technologies, the only hope for thousands afflicted with Parkinsonâ⠬â¢s disease, diabetes, cancer, and other deadly and disabling diseases (Carey 2).â⬠To assist the National Institutes of Health (NIH) in determining which cloning experiments to fund, a medical panel was set up to form a preliminary set of guidelines. Steven Muller, the head of the panel, set out with the help of several prominent biologists including, Brigid Hogan and embryology specialist Mark Hughes, to put together a set of guidelines that would satisfy the concerns of both the scientific and religious communities. The religious community vigorously opposes all human cloning procedures for fear that humans are attempting to play God and destroy the family. The scientific community sympathizes with the religious communities concerns, but does not want to lose the enormous amount of information that may be gained by human embryo cloning. Mullerââ¬â¢s panel announced a set of guidelines that they hope would be acceptable to both communities. They recommended research be p ermitted on embryos allowing them to develop up to and including the fourteenth day. Researchers would also be allowed to produce new embryos for what the NIH considers compelling research. Researchers would also be permitted to remove some of the embryonic cells from embryos that are destined for in vitro fertilization at a later time (Marshall 1024). The panel did not come to a decision in several other areas including research funding. The panel suggested that research might be permitted after the fourteenth day of development depending upon the circumstances, but definitely not after the eighteenth day, when neural tube closure begins to develop. The neural tube is the beginning of the nervous system, including the brain, in adult humans (Marshall 1024). Thus the scientific community seems to be giving more moral consideration to an embryo then a majority of society gives to a more developed fetus during abortion The experiments that the panel recommended be banned include impre gnating human embryos in other animal species, impregnating cloned embryos into humans, the use of embryos for sex selection, or the transfer of one nucleus from one embryo to another. These are but a few of the procedures that the panel felt were inappropriate for federal funding (Marshall 1024). However, the above limitations only apply to federally funded experiments. Currently there are no laws directly prohibiting any of the above procedures in private research settings. It should also be stated that all of the above procedures have or can be carried out with our current technology. Although the NIH does not have the ability to stop privately funded cloning clinics like the one Richard Seed plans to build, the Food and Drug Administration (FDA) does. ââ¬Å"The [FDA] already has the power to quash attempts to clone people. Eccentric scientistsâ⬠¦ can announce plans to open human-cloning clinics. But without FDA approval, theyââ¬â¢ll be committing a crime. And they wonâ⠬â¢t get FDA approvalâ⬠(Carey 1). Whenever a new idea is introduced into society, it is usually met with criticism and fear by some and with joy and hope by others. Just like criticism and fear arrived with the delivery of Louise Brown, the first In Vitro fertilization baby born in 1978 (Tudge 34), the same will hold true for cloning. However, there is hope. Not only is In Vitro fertilization accepted now, but it is used daily by hundreds of couples trying to conceive when it was impossible to even imagine a family before. The plain and simple truth is that both cloning and gene therapy provide many new and exciting possibilities such as the production of organs and hormones and the control of disease to ensure the future health of the human race. Like In Vitro fertilization, humans need to open their eyes and accept these new techniques that are creeping over the horizon which can not only save lives, but increase our longevity as a society. Many critics of cloning and gene therapy do not stop to think about the possibilities of these technologies or about the possibility that one of their offspring could need some genetically engineered or cloned substance to save their life in the future. They worry about one or two scientists trying to clone humans instead of the possibilities that will be available to the world to fight disease. If humans would just take a look at the bigger picture they would realize that cloning and gene therapy will not be the downfall of society, but will increase our longevity and health as a whole.
Saturday, April 25, 2020
Of Mice And Men Essays (904 words) - English-language Films
Of Mice And Men Of Mice and Men, by John Steinbeck, takes place on a ranch in the Salinas Valley of California, against the backdrop of the Great Depression. Steinbeck writes of two ordinary men trying to live the American Dream. Unfortunately they fail to fulfill those dreams. Steinbeck opens the book by vividly painting a picture of the Salinas River Valley. Two traveling laborers, George Milton and Lennie Small, are on their way to a job at a Californian ranch. George decides that they were to stay the night along the Salinas River's bank before reporting to work the next day. Over dinner George and Lennie discuss their plans. Through this conversation, Steinbeck reveals the contrasts between Lennie and George. Lennie is big and slow witted and George does the thinking for the pair. Lennie obeys George's every word like a dog to his master's commands. At this point in the book it becomes apparent that George and Lennie want to pursue the American Dream. Lennie asks George to tell him of their future home. It would be just George and him. They plan to have many orchards, pigs, cows, rabbits. They plan to live off the fat of the land. The next morning the two friends travel to the ranch to obtain their work assignments. As the arrive at the ranch they are greeted by a man name Candy. He tells them of the ranch and its inhabitants. When interviewed by the boss, George answers all the questions. He even answers for Lennie. Due to this, the boss becomes suspicious. While in the bunk the Boss' son Curly walks in looking for his father. Curly bullies Lennie, even though Curly is much smaller than him. George warns Lennie to stay away from him. At dinner, Slim introduces himself to George and is puzzled why they travel together. Later in the bunk George tells Slim about his life. He explains how Lennie likes to pet soft objects and how Lennie always gets them in trouble. George travels with Lennie because Lennie has nobody to look after him. George asks slim if Lennie could have one of his puppies. Lennie is ecstatic when Slim gives him a puppy. Curly's wife walks into the bunk looking for her husband. All of the men in the bunk drop their heads, but Lennie stares at her. The men told her that Curly isn't in the bunk. She leaves. George warns Lennie to stay away from her because she is trouble. Candy overhears George telling Lennie of their future farm and asks them about their future plans. At this point in the book it is apparent that Candy also wants to follow the American Dream. His dream is to live on their farm, hoe the garden, and wash the dishes for free. Curly enters the bunk again and spots Lennie smiling. He thinks that Lennie is making fun of him, so Curly begins taunting and hitting Lennie. Lennie refuses to fight back until George gives him permission. Lennie catches Curly's fist and begins to crush it. Lennie finally lets go of Curly's hand. The others threaten Curly that if he doesn't tell everyone that he got his hand caught in a machine that they would beat him up. They made this threat to prevent Lennie from being fired. The next day while the others are at a whorehouse, Lennie goes into the barn to pet his puppy. While in the barn he sees a light and goes towards it. Lennie enters the room of the black stable worker, named Crooks. At first Crooks objects to Lennie's invasion of privacy, but Lennie's good humor wins him over. Crooks explains the difficulties of being a black person on the ranch, and Lennie talks about his future farm. Candy enters the room and tells Lennie that he is going to put money towards the farm, Crooks asks to be included, too. At this point Crooks wants to be part of the American Dream. The next day while the boys are playing horse shoes, Lennie is in the barn playing with his puppy. He handled the puppy too much and he broke the puppy's neck. As he tries to hide the animal, Curly's wife enters the barn. She talks to Lennie about her life dreams. She tries to seduce him. She too wants to be part of an American dream. When she learns that Lennie likes to touch soft objects, she invites him to touch her hair. At first he hesitates, but
Saturday, April 18, 2020
The Biggest Myth About Once You Submit Your Common App Essay to One College Can You Chnge It Exposed
The Biggest Myth About Once You Submit Your Common App Essay to One College Can You Chnge It Exposed It will help to gather all the essential information in 1 place, guide applicants throughout the practice of applying, and you don't need to be concerned about repeating the exact same information ad nauseam. The application has to be complete before you may print preview. Make certain you print preview your whole application prior to submission. Just one form for your own personal details! The last tab provides you an opportunity to provide any extra details. It is possible to then review their info employing the Manage Recommenders button. Selecting this option does not permit you to see your recommendation via the application. You have to earn all of your green checks prior to a button will appear letting you generate the preview. The Fundamentals of Once You Submit Your Common App Essay to One College Can You Chnge It Revealed Your guidance counselor or a different school official might also be in a position to provide help. You will nonetheless add different recommenders and advisors utilizing the steps above. Every college may want to know where your home is, who your parents are, and the way you scored on the SAT. From that point, students will need to check with their counselors, who should verify eligibility. You may qualify when you have a financial hardship. It's possible you'll send the exact recommendations to each college you apply to, and sometimes even essay questions could possibly be similar from school to school. Correct it if you're able to, but don't forget that college admissions officers are in the work of evaluating 17-year-olds. The question-writers are giving you an enormous clue when they request that you describe what prompted your thinking they wish to know the way your mind works. Talk about the folks who share your passion, or the people who inspired it. Because everybody has a story to tell. Unfortunately, there's no way to view if you've been accepted or not, which means you will have to visit each college's website and make an account there. Before you get to the Common App essay, for instance, you'll be shown whether your college choices take a personal essay. Nevertheless, you most likely have lots of questions as yet unanswered. As soon as you have actually submitted an edition of the essay to any school, you just have two more opportunities to make changes to that bit of writing. Consider checking your ideas with family members and friends. Details of Once You Submit Your Common App Essay to One College Can You Chnge It In the end, under Additional Information, you can incorporate information on any special circumstances which may be related to your application and aren't addressed elsewhere in the Common App. Again, it's nice that you are able to conserve the application and walk away from it, since you may have to find minutia. Your application has done its work, but it doesn't signify you have to cease along your trip. It is now ready to be reviewed! Like the remainder of the Common Application, the major essay will come to be fully editable for all applicants at any moment. Rather than filling in precisely the same information on multiple college applications, you sometimes take the Common App's batch strategy. Before it is possible to submit your application, you will need to gather your materials. Your application is likely to make the glorious transition from incomplete to finish. Choosing Good Once You Submit Your Common App Essay to One College Can You Chnge It Some might want more than 1 letter from a teacher, while others might only need a counselor. 1 student made a mistake in his private essay which he wanted to repair. Both domestic and worldwide students may sign up, and it is possible to be living in any place in the world. A student who must babysit younger siblings while their parents work or who had to find a job to add to the family's finances are not going to have the very same extracurricular resume as other students. Observing the profile section, you will answer questions regarding your present education status. Since you can see in this screenshot, there's a Instructions and Help box on the correct side of the webpage. For each one of these sections, you are going to want to supply answers to a variety of particular questions. Visit my site for more info.
Wednesday, April 15, 2020
What Does Writing an Essay Say About Me?
What Does Writing an Essay Say About Me?I've been asking myself for years, 'What does college essay writing say about me?' You probably have a similar question; don't you?Some colleges have programs that will help you prepare your essay. It's quite a change from the traditional way of doing things and it can be a little stressful but it's worth it because it helps you stay away from common mistakes that make your essay so forgettable.One of the mistakes that people make is rewriting their college essay. They start at the beginning of the document, edit down the rough draft, then re-write the whole thing. There's nothing wrong with this approach, but you should try to stay away from this kind of strategies because it does not help you become a better writer.First of all, when you're rewriting your essay, it takes away from your actual point. You may be trying to move on from something that was difficult to write about. By moving on from your essay early, you are not making your audien ce feel as if they are learning something new, and you're also only leaving them wanting more because you are setting yourself up for the next essay in a row that they'll do much worse.Second, and probably most importantly, is that you need to leave your readers satisfied. You can't let them down by giving them an essay that doesn't belong to them.Finally, no matter how well you might be feeling about your writing, make sure that you continue to improve yourself. Nobody can think or write very well, so make sure that you learn from your mistakes.The best way to become a better writer is to practice writing every day and to actually have a plan for improving your own college essay. Some ways to do this is to plan out your essay a few weeks before you actually begin writing, and then read it out loud or just by yourself to figure out where you went wrong.Finally, make sure that you understand that one mistake is one too many, and you can never really catch up to someone else in that w ay. So keep an eye on what others are doing, and remember that you cannot get better until you learn from what others are doing.
Monday, April 13, 2020
How to Choose Persuasive Essay Topics
How to Choose Persuasive Essay TopicsPersuasive essay topics are a must for students in the sixth grade. Any student who wants to have a successful college career and choose a specific major should write persuasive essays, which is part of the curriculum for the sixth grade. It will give them an advantage, regardless of whether they want to go to college or not.Sixth grade teachers usually do not guide students when it comes to writing their essays. Sixth graders can't write college essays. For some reasons, but mainly because college professors are trained to recognize the problems in this and help students make the necessary changes. By the time students enter high school, they can write persuasive essays and university admissions essays.College admissions essays should be full of facts and figures. But when it comes to college application essays, students cannot apply facts and figures. They need to present their argument using a couple of examples and anecdotes.Students should kn ow the basics of persuasive essay topics before they start writing. They should be familiar with the format, how to compose a perfect sentence and learn about basic grammar rules. They should also read a lot of books on writing and visit college libraries and talk to professors on the subject.As the years pass by, college students become more proficient in writing persuasive essays. However, it is still a good idea to brush up on your skills if you want to write an essay that makes your reader stand up and take notice.Persuasive essay topics are created using an entire range of ideas and arguments. There are stories, statistics, essay topics and even applications. All are basic and can be used in every persuasive essay.The length of persuasive essay topics can vary depending on the importance of the topic. Just make sure that you take into account the essay topic, the grade the student wants to achieve and what he or she has to gain from the essay.By learning the fundamentals of per suasive essay topics, students will be able to write persuasive essays quickly and more effectively. They will also have a better grasp of what makes a persuasive essay.
Saturday, April 11, 2020
MMLA For Research Papers
MMLA For Research PapersMore often than not, students usually look for a good MMLA style for research papers. MMLA style is good for the researcher as it gives them an idea on how to get rid of all the paper for easy reference. But it can be better to understand that there are two kinds of paper; one being the heavy paper and the other the light one. So what is a 'heavy' paper?These papers are called heavy because it is meant for research purpose and not for everyday use. Usually, it is very long and the paper is in good order. It also has to be well composed and organized.A MMLA for research papers is often needed by students who cannot afford to buy their own copies. So if you are among them, then you should know that most of the times they are less expensive than the ones bought by libraries. The price also depends on the paper.There are some MMLA style for research papers. First, students normally prefer them when they are writing an undergraduate paper. They do not need this typ e for a thesis, but it is good to know that MMLA is not meant for high school seniors. It is usually recommended that they should write a college paper first.Another reason why students prefer MMLA style for research papers is that they know that this paper is not that difficult. Because of this, the student will get a more thorough result in terms of understanding the topic and the method used. This is not always the case in essay papers, but in MMLA papers, the student can expect this result.When you are choosing a MMLA paper for a student, ask him or her to make a rough draft. At that time, you can decide on the style you like and create it according to his or her choice.To summarize, MMLA style for research papers is good for research purposes. Students prefer it since it does not require a lot of writing and doesn't require a lot of research. However, for high school seniors, they usually write a thesis first.
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