Private Express Trust Essay Example | Topics and Well Written Essays - 1250 words

Dealing with a Disability in the Hospitality Industry Free Essays

Managing Disability This report focuses on the impacts of managing an inability in the Hospitality and Tourism Industry. There are numerous ways how incapacitated individuals can be influenced here, for example, separation in work, segregation in being the client, bogus promotion and absence of help and offices in the business. Regardless of whether it’s a psychological inability, for example, dyslexic or a physical incapacity, for example, in part located it can affect both. We will compose a custom exposition test on Managing a Disability in the Hospitality Industry or on the other hand any comparable point just for you Request Now For some in the travel industry and cordiality world impaired individuals implies wheelchair clients, it’s worth calling attention to that the Disability Rights Commission gauges that wheelchair clients speak to under five percent of incapacitated individuals (around 450,000). The business ought to likewise know that handicap incorporates facial distortion, the individuals who have hypersensitivities and the evaluated one of every seven individuals who have a psychological wellness issue every year. Statics appear: Current appraisals recommend that there are more than 9,000,000 impaired individuals in the UK, some 15% of the populace or to more than the joined populaces of Scotland and Wales. Related paper: Relationship Between Tourism and Hospitality This figure incorporates 6. 5 million individuals of working age who have a current long haul handicap or medical issue, 8. 7 million individuals who are hard of hearing or in need of a hearing aide, an expected 1. 8 million visually impaired or incompletely located individuals, 18,000 individuals who are customary Braille clients and 400,000 individuals who have a learning inability. In one sense, the travel industry and cordiality divisions are now providing food for clients with a wide assortment of inabilities yet they frequently do this accidentally, given the way that numerous handicaps are not quickly self-evident. There are numerous acclaimed individuals that endure with a type of handicap, for example, Ludwig Van Beethoven that experiences deafness. Beethoven is broadly viewed as probably the best writer ever. Christy Brown an Irish Author, Painter and Poet is another celebrated handicapped individual. He was incapacitated by cerebral paralysis and was unfit for quite a long time of conscious development or discourse. Many debilitated individuals don’t have as much certainty as a non-crippled individuals and this is the place they disregard celebrated individuals who made it far throughout everyday life. Many incapacitated individuals think that its elusive the correct convenience to suit their requirements and discover a settlement with the correct offices for them. Numerous instances of the correct offices could incorporate wheelchair inclines, wheelchair openness in the inns open region (e. g. pool and eating zone), verbal declarations on the lift, Handrails in restrooms and width of entryways and so forth. A few organizations in the accommodation business that are inadequate in this lose visitors/clients without taking note. Bogus notice is likewise utilized here for instance when inns express that they have impaired or constrained versatility offices in pamphlets and on the web yet they really don’t have these offices in the lodging. ‘DisabledGo’ is an honor winning incapacity association that gives online access guides. Its site is intended to assist impaired with peopling find what they are searching for e. g. lodgings, cafés, films, vacation spots and some more. Destinations like these can be an extraordinary assistance. Reference index: http://listverse. com/2010/01/18/top-10-unprecedented individuals with-handicaps/http://www. disabledgo. com/ Instructions to refer to Dealing with a Disability in the Hospitality Industry, Essay models

Things to Do On Your Birthday Alone

Things to Do On Your Birthday Alone Social Anxiety Disorder Coping Print 10 Things to Do on Your Birthday Alone By Arlin Cuncic Arlin Cuncic, MA, is the author of Therapy in Focus: What to Expect from CBT for Social Anxiety Disorder and 7 Weeks to Reduce Anxiety. Learn about our editorial policy Arlin Cuncic Reviewed by Reviewed by Amy Morin, LCSW on July 01, 2019 facebook twitter instagram Amy Morin, LCSW, is a psychotherapist, author of the bestselling book 13 Things Mentally Strong People Dont Do, and a highly sought-after speaker. Learn about our Wellness Board Amy Morin, LCSW Updated on October 10, 2019 More in Social Anxiety Disorder Coping Symptoms Diagnosis Treatment and Therapy Work and School Related Conditions Finding things to do on your birthday alone might leave you feeling lonely. Birthdays are generally fun when you are a child. As you grow older, birthdays become a nuisance for some in that they are a reminder that you are getting older. For people who live  with social anxiety disorder (SAD), they can also be a reminder of the difficulty that you have with social situations.?? On the other hand, if youve never enjoyed birthdays, this day of the year may bring back bad memories. As a way of starting a new tradition, even if you find yourself alone on your birthday this year, try to make a special day for you?. If you start planning now, you will find it is not that hard. Verywell /  Nusha Ashjaee 1. Start Fresh Use this opportunity to start fresh in some area of your life. Go the traditional route and do a makeover on your outside: that might mean a new haircut, new outfit, or even something a little riskier like a tattoo. Choose styles that give you confidence and a new outlook. Or, go the less traditional route, and treat yourself to an internal makeover: read a self-improvement book, take a workshop, or start writing in a journal. Read books to work on coping with social anxiety so that you will not be alone on future birthdays. 2. Create Something Even if no one is coming over, you can still have a birthday cake. If youre not into baking, buy a store-made version. However, if you really want to enjoy your day, dont take this shortcut. Take your time and enjoy the process of baking a cake. Feel proud of what you have accomplished. Share leftovers with a neighbor and consider it an opportunity to make a new friend. 3. Be Generous Toward Yourself If you arent expecting anyone to give you gifts, treat yourself to something new. Choose a gift that might help you with your social anxiety such as chamomile tea, or buy an item for your home/dorm/bedroom to spruce it up. 4. Exercise Outdoors Exercise helps to clear your mind and hiking outdoors gives you a chance to connect with nature. Get outside and go for a hike, walk around your neighborhood, or a stroll along the beach (if you are so lucky to live near one). Feel proud about spending your birthday out of the house and being proactive about your physical and mental health. Bring your dog, if you have one, and let his natural joy and curiosity lead the way. 5. Take in a Movie Treat yourself to a night out at the movies even if you will be going alone. Lift your spirits with a comedy. Go at a time when you know the theater is likely to be full. Laugh out loud and dont worry what others think. Consider it a behavioral experiment to see whether people are really paying as much attention to you as you think that they are. 6. Volunteer Your Time Consider offering your services as a volunteer. Spend time chatting with people at a retirement or nursing home or offer to walk dogs at an animal shelter. You might even make new friends and become a regular volunteer. This is a perfect way to challenge your social anxiety and build your social skills. Be sure to call in advance to learn about any requirements prior to helping out. 7. Read a Book Your birthday is the perfect time to sit down with a book youve been dying to read. Start that novel or non-fiction book you have had on your list. Curl up with a good book and you might be surprised how quickly the day passes. You could even take this a step further and read a self-help book to work on overcoming your social anxiety. 8. Go About Your Routine Make your birthday just like any other day. Go about your usual routine. Dont mention to anyone that it is your birthday. This strategy works best if you are not much into birthday celebrations anyway. 9. Plan a Party for Next Year Start thinking about next year if you dont want to be alone on your birthday again. Are there relatives you could visit or friends that you could invite over for dinner? Take the year to make new connections so that you dont find yourself alone again this time next year. 10. Be Appreciative Birthdays are a reminder of how much time has passed and potentially how much time we have left. Take the time to appreciate the positive things in your life, even if you are alone on your birthday. If you have a roof over your head, food on the table, access to education, and running water, you are actually ahead of a good portion of the worlds population. Over time, this type of gratitude will become a habit and will serve you well in improving all aspects of your life. How to Cultivate Gratitude A Word From Verywell Occasionally finding yourself alone on your birthday should not be cause for concern. However, if this pattern repeats every year, and it is distressing for you, consider whether reaching out for help might be a better option. If severe social anxiety prevents you from making and keeping friends, treatments such as cognitive-behavioral therapy (CBT) and medication may help.??

Ib Hl History Ia - 1632 Words

HL History Internal Assessment Was President Ronald Reagan the reason for the Cold War’s conclusion? Word Count: 1,634 Was President Ronald Reagan the reason for the Cold War’s conclusion? A. Plan of Investigation This investigation focuses on the impact that President Ronald Reagan had on ending the Cold War between the United States of America and the Soviet Union during the 1980’s. The use of historian argumentation, primary sources, such as Ronald Reagan’s Address to the Nation on Defense and National Security, and analytical essays by well known professors, such as John Gaddis’s excerpt from Major Problems in American History Since 1945 – titled â€Å"Ronald Reagan’s Cold War Victory† – will be utilized. The origins, purposes, values,†¦show more content†¦Evaluation of Sources â€Å"Ronald Reagan’s Cold War Victory†, written by John Lewis Gaddis in 1989, is an analytical essay from Major Problems in American History Since 1945, an educational book meant to introduce those interested in history to primary sources as well as essays written by noted historians. Gaddis wrote this essay with the purpose of educating individuals on the role that President Ronald Reagan played in the Cold War. The essay’s value is due to the fact that it was written by an individual who experienced these historical occurrences firsthand. Furthermore, Gaddis has become a noted historian with multiple publications on the topic of the Cold War. The limitation of the essay is that the information contained within it is based on facts known to the public as of 1989 – a date which does not necessarily come after the conclusion of the Cold War; ergo, the amount of declassified documents and available information to historians and the public would have been m inimal. Another valuable source to this investigation was â€Å"Ronald Reagan’s Address to the Nation on Defense and National Security.† The address took place on March 23, 1983. TheShow MoreRelatedIb Business Management 2013 Ia Guildline Booklet16033 Words   |  65 PagesIB Business Management 2013 Internal Assessment Standard Level Guidelines booklet Mark Lewis Jan 2013 Page 1 of 77 IB Business Management Internal Assessment Guidelines Standard Level – 2013 Index Page †¢ Templates †¢ IB Commentary on report structure †¢ IB SL IA criteria and mark bands from syllabus †¢ IB general commentary on SL IA from syllabus †¢ Sample IA’s with marks (IB sourced) †¢ General guide comments (IB Sourced) †¢ Recent IA questions at Carey †¢ General guide comments (IB Sourced) †¢ SubjectRead MoreIB EE GUIDE9051 Words   |  37 PagesCandidate performance against each criterion 26 Introduction The extended essay is an in-depth study of a focused topic chosen from the list of approved Diploma Programme subjects—normally one of the student’s six chosen subjects for the IB diploma. It is intended to promote high-level research and writing skills, intellectual discovery and creativity. It provides students with an opportunity to engage in personal research in a topic of their own choice, under the guidance of a supervisor

Ancient Civilizations Of Mesopotamia And Mesopotamia

Sumerian (3500-2300BC)Babylonian (1792-1750 BC) both belong to civilizations of Mesopotamia, but they existed different period. The ancient civilizations of Mesopotamia are the source of the earliest surviving art; these civilizations were situated between the Tigris and the Euphrates Rivers. Dating back to 3500 B.C.E., Mesopotamian art was intended to serve as a way to glorify powerful rulers and their connection to divinity. Art was made from natural resources such as stone, shells, alabaster and marble, and was often created as didactic pieces. No artist signatures can be found on most of the work, because the pieces were meant to embody the subject matter, rather than the creator. Popular items that typify this time period include cylindrical seals, steles, narrative relief sculptures, and lavishly decorated tombs. More than 4,000 years ago the valleys of the Tigris and Euphrates rivers began to teem with life--first the Sumerian, then the Babylonian, Assyrian, Chaldean, and Per sian empires. Here too excavations have unearthed evidence of great skill and artistry. Examples of fine works in marble, diorite, hammered gold, and lapis lazuliahve been found. Stone, wood, and metal was imported. Sumerian art and architecture was ornate and complex - primarily used for religious purposes - painting and sculpture the main median used. Of the many portraits produced in this area, some of the best are those of Gudea, ruler of Lagash. Some of the portraits are in marble,Show MoreRelatedAncient Mesopotamia And Ancient Civilizations896 Words   |  4 Pages Throughout many cultures in ancient civilizations, humans have held a belief in superior beings to which they called gods. The gods, in the eyes of many of the ancient people, were responsible for many things such as crop growth, storms, fertility, and even creation of life. The Mesopotamians, Egyptians, and the Hebrews all had gods that they interacted with. Understanding the likenesses and differences in how these people interacted with their gods might give us an insight to how similar or differentRead MoreMesopotamia And Its Impact On Ancient Civilization994 Words   |  4 PagesMesopotamia, or â€Å"land between the rivers† as the name translates to in Greek, is exactly as it states; in the region of southwestern Asia, the land itself is named for it s initial position between the Tigris and Euphrates rivers. However, Mesopotamia can be defined as having a reach into what is now Syria, Turkey and most of Iraq (History of Mesopotamia, 2016). This ancient civilization hou ses one of the earliest cities throughout human history, appearing around 3500 BC, though human settlementRead MoreEssay on Egypt, Mesopotamia and Ancient Greek Civilizations1810 Words   |  8 PagesMichael Jones 10/5/2012 Cabrera Egypt, Mesopotamia and Ancient Greek Civilizations The Ancient Egyptians, Mesopotamia, and Greeks were some of the oldest complex societies, although similar in many aspects. Mesopotamia is located in the Fertile Crescent, land in and between the Tigris and Euphrates rivers usually known as modern day Iraq and Eastern Syria.(24) In Egypt, the Nile River creates a fertile valley which is rich in nutrients and essential to their survival. The Nile flows fromRead MoreSimilarities And Differences Between Civilizations, Mesopotamia And Ancient China868 Words   |  4 PagesMany of the early world civilizations had similar experiences when evolving to become the influential societies that affected other societies. They were called the first civilizations because they were able to form the first functional communities, successful systems of organized laws over people, the distinction of social classes, economic income, and development of arts and educations. Two of histories well-known civilizations, Mesopotamia and Ancient China had similar experiences in the beginningsRead More Exploring The Four Ancient Civilizations- Mesopotamia, Egypt, Greece and Israel1009 Words   |  5 Pagesnumerous cultures, each unique in some ways while the same time having features in common. Mesopotamia, Egypt, Greece and Israel are all important to the history of the world because of religious, social, political and economic development. In the first civilization, both Mesopotamia and Egypt relied on a hunter-gatherer economic system, during that time, every country in the world strived on it. Mesopotamia had rich soil for agriculture, but experiences floods. For the Mesopotamians, theseRead MoreHow Did the Geographic Features of Ancient Egypt and Mesopotamia Impact Civilization Development?1786 Words   |  8 Pagesimpacted a civilizations development in great measures. Depending on the resources available or the detriments present due to certain topographical characteristics like rivers or deserts, a civilization could flourish or collapse. By studying the geographic features of growing societies like the Nile, Euphrates, and Tigris Rivers as well as the Mediterranean Sea of Egypt and Mesopotamia, the link between developing cultures and geography will be examined through sources, including Egypt: Ancient CultureRead MoreRelevance Of Mesopotamia Essay1566 Words   |  7 Pagesâ€Å"The relevance of ancient Mesopotamia can be simply stated: Mesopotamia produced the world’s first humanists - studying ancient Mesopotamia enables students to explore what it is to be human,† (Jamieson Ancient Mesopotamia: Discovering Civilisation 23). The Fertile Crescent is where the start of civilization occurred, and it is often called the ‘cradle of civilization,’ (Jamieson Ancient Mesopotamia: Discovering Civilisation 23). Understanding the development, the of civilization in the Fertile CrescentRead MoreMesopotamia, Egypt and China Essay871 Words   |  4 PagesThe civilizations of ancient Egypt, Mesopotamia and China were all different but were also developed similar ways of doing things. The political, economic and intellectual outlooks of these ancient peoples say a lot about their ways of life. The religious views of Egypt and Mesopotamia were rather different. II. Politics The political thinking of these ancient civilizations definitely had their differences and also their similarities. A. Mesopotamia Mesopotamia was divided into city-statesRead MoreTrends in Ancient Civilizations1234 Words   |  5 Pagesï » ¿Trends in Ancient Civilizations Over the course of human history, humans and our ancestors have made tremendous strides. From Homo habilis making the first stone tools to the Egyptians building The Pyramids of Giza, human history is nothing short of intriguing. If it wouldn’t have been for each stride made by our ancestors we probably wouldn’t live in the world that we live in today. When the Neolithic Era began in 9600 BCE, human civilizations gradually started to spring up all over the worldRead MoreEssay on Compare and Contrast Egypt and Mesopotamia901 Words   |  4 Pagesdeveloped around the Nile River, while Mesopotamia developed between the Tigris and Euphrates rivers. Egypt and Mesopotamia grew into complex civilizations. Politically, both Egypt and Mesopotamia had a government with one main ruler, but Egypt had a centralized government with a pharaoh, while Mesopotamia had a decentralized government with a king. Socially, both civilizations were patriarchal, but Egypt was more lenient tow ards women while Mesopotamia was stricter. The political and social

Who Else Wants to Learn About Argumentative Essay about Social Issues?

Who Else Wants to Learn About Argumentative Essay about Social Issues? Young writers may try simple on-line citation generators which are ordinarily at no cost. Individuals are more mindful of today since they are better educated. Social networking encourages the false images of how everything ought to be in an ideal world. The Upside to Argumentative Essay about Social Issues While you might have a specific interest like immigration or poverty it's important to select a more specialized topic within that subject. For a social issue to be classified as an issue, it has to be getting attention from the general public. It is imperative to choose from any 1 issue for those essays on immigration to sound focussed. There's no quick fix to the immigration issue. Quite simply, as soon as a woman is raped, it's not unusual that a few of the blame and responsibility for the rape is set on her. In the story, there are those who are rich, middle class and working simply to get by. S ince you may see, students will definitely face many challenges should they need to turn into a member of the buy essay club. The majority of the teacher did not need to posting in rural area since they think that it will bring difficulty to them. The cost of an essay depends upon the total amount of effort the writer has to exert. The topic must be based on trending news and issues which exist only recently. You don't have to be fancy, only an overview. Lots of people are using social media to find employment by developing a web resume' and other techniques. It is preferable to use templates since they include all necessary formatting elements. Aside from business, there are different difficulties that may be addressed more effectively through social networking. Argumentative Essay about Social Issues - What Is It? Social problems aren't universal to each society and have a tendency to change rapidly. Poverty also impacts the environment. It is one of the main social problems in the world. Poverty in the society is the primary source of a number of other social difficulties. The effect of vandalism can be negative also. At the rural locations, family is just one of the elements that determine their child performance. A good example is the current worldwide warming crisis. There are several social issues that teenagers go through. Rape is not only a women's problem--it's a community issue. Urban students have greater access to a lot of resources and so have opportunities that aren't easily accessible to rural students. The shortage of fantastic support sources will end in a decrease grade. As stated by the structural perspective, society is seen as a complicated system of structures that interact as a way to execute various necessary functions. Caste system is an important social problem in India. The Argumentative Essay about Social Issues Chronicles Moral argumentative essay topics are a few of the simplest to get carried away with. The means of writing about social problems that you will encounter most often at an essay ought to be based on argumentation, ie on reasoned discussion. It's important to select debatable argumentative essay topics as you need opposing points you can counter to your own points. Recent argumentative essay topics that are related to society is going to do. Inspiration to make your own advertising or media argumentative essay topics isn't difficult to discover. The majority of the folks have a tendency to run away from politics and thus the politics essays also, therefore it is quite important to grab the eye of the readers till the conclusion of the essay and that would be much difficult I know. Thus, the skills required to compose a social media argumentative essay has to be capitalized here. They can be viewed in various approaches therefore can be a great topic for a college essay. Odds are, all you have to do is relax and locate a topic you're passionate about and, obviously, one that's debatable. Deciding on your topic isn't that easy. Therefore, the topic ought to be debatable! Researching the topic permits you to find out more about what fascinates you, and should you pick something you truly like, writing the essay will be more enjoyable.

Mt302 Organizational Behavior Unit One Case Incident 1 Essay Example

Mt302 Organizational Behavior Unit One: Case Incident 1 Essay John G. Watson MT302 Organizational Behavior Unit Four: Case Incident 1 Frustrated at Age 30 July 4, 2009 Frustrated at Age 30 1. Analyze Bob using the Maslow need hierarchy? This weeks case covering Bob is a great example of the many people who are experiencing the very same lifestyle changes he has gone through. For example, here we will be discussing how bob after graduating from college in 1996 resided in a great career earning $80,000 per year and due to how the many changes that are taking place in the workforce throughout America now earns $44,000 per year. In addition, how the changes Bob experienced is in relations with Maslows hierarchy needs. The meaning of hierarchy of needs theory says that a hierarchy of five needs exist such that as each need is substantially satisfied, the next need becomes dominant (Robbins Judge, 2007 p. 187). In the case with Bob, he started out great in life fulfilling his college needs, finding a great job and being in a great career and fulfilling his security needs thinking he was going to retire by the age of forty. Through this, he reached what Maslow calls self-actualization in which he achieved the drive to become what he was capable of, growing, achieving his potential, and having self-fulfillment (Robbins Judge, 2007 p. 217). Like late bloomers in life who graduated in their late thirties and early forties, I myself unlike Bob have sustained the lower order of Maslows hierarchy of physiological needs throughout my early part in life learning how to appreciate and be gratified within with the small things in life that really matters. Due to the timing in life of fulfilling each of Bobs hierarchy needs in which he did ot have to struggle and learn the survival to skills to make end meet, I feel it is what caused Bob to feel frustrated. This may have lessened his self-esteem when societies economic and job loss security vanished in which he now earns $44,000 per year and have debts to pay off and is pressured to buy a home, settle down and get married. 2. Analyze Bob’s lack of motivati on using organizational justice and expectancy theory. By looking at Bob’s lack of motivation from his career turning events we may analyze where it may have stem from-from an organizational justice and the expectancy theory standpoint. We will write a custom essay sample on Mt302 Organizational Behavior Unit One: Case Incident 1 specifically for you for only $16.38 $13.9/page Order now We will write a custom essay sample on Mt302 Organizational Behavior Unit One: Case Incident 1 specifically for you FOR ONLY $16.38 $13.9/page Hire Writer We will write a custom essay sample on Mt302 Organizational Behavior Unit One: Case Incident 1 specifically for you FOR ONLY $16.38 $13.9/page Hire Writer There are three justices in organizational justice and they are multidimensional. They are distributive, procedural, and interactional. As we proceed to understand the meaning of organizational justice, which is what is fair in the workplace and resides in the perception of the person. We are able to connect Bob’s perception from a distributive justice standpoint residing in the fact that he went from earning $80,000 per year to $44,000 and as he claims, â€Å"He may never earn $80,000 again until 20 years from now (Robbins Judge, 2007 p. 217). To Bob or for anyone else for that matter this situation is an inequity in which their being under rewarded for their qualifications and skills. Bob’s inequity also comes from comparing himself to the 40 million American whose peak earning are behind them and his father. As the case claims Bob states, â€Å"The rules have changed and the generation Xer’s is getting hit hard (Robbins Judge, 2007 p. 217). † If we a re to proceed to understand the second element of justice â€Å"procedural† in which is to understand the process used to determine an outcome-Bob explains, â€Å"I’m frustrated. I feel like my generation got a bad deal. We initially got great jobs with unrealistically high pay. I admit; we were spoiled (Robbins Judge, 2007 p. 217). † Since, there are no specifics in the case as to why Bob withdrew from his job of why he earns half of his usual income. I can only assume it is due to downsizing and the current restructuring of our workforce in America and this is a factor of Bob’s lack of motivation. Although there are, less evidence of interactional justice Bob goes on to claim, â€Å"We have no job security, the competition for jobs combined with ressures by business to keep cost down mean a future with minimum raises (Robbins Judge, 2007 p. 217). † Bob is more unmotivated because he perceives his situation such that the companies he works for treats him with no dignity, concern or respect. He feels as the case sounds that whether the blame is externally or internally it is unfair because he graduated at a good time, had a great job tit le, drives a European sports car, and was very optimistic about his future. Now his lack of motivation is causing him to worry about paying his bills, to settle down and marry, and to buy a home. On the other hand, if Bob accepted and embraced Victor Vroom’s expectancy theory he would be able to change the outcome of all of his situations and events that are occurring in his career as well as his personal life. Expectancy theory much like self prophesy which one receives an outcome through the belief that they are already receiving it, relies on the strength of ones effort performance in which say Bob for example, may exert some amount of effort with the probability that will lead to performance. This in return leads to a reward relationship in which say Bob would believe that performing at a certain level would lead to a desired outcome. In the end, this reward leads to a personal goal relationship that satisfies say Bob’s personal goals or needs (Robbins Judge, 2007 p. 208). Through the application of goal setting, using expectancy theory, and self prophesy, Bob can life himself up and be optimistic once again and begin to attract and create the lifestyle he once had or better. 3. If you were Bob’s boss, what could you do to positively influence his motivation? If I were Bob’s boss I would get to know him more personally to find out any goals he has in the company, a little about his personal life like his family life. I would observe his potential and skills more closely that can benefit the company. I would have to make sure that I implement the expectancy theory and follow through with all the employees I manage so they can continue to excel and feel appreciated for the work that they do. This can motivate him to do excellent work because if there are openings for advancements he could be a good candidate if he is motivated, the drive to succeed, the qualification, and the skills. I would reassure Bob as well as other employees by having brief meetings during the week on how the company is doing and how important their participation in the companies programs are contributing to the great success/disappointments of the company as to motivate him to continue to do great or better. As a manager, I would provide Bob with customer feedback so he may know how the work he does each day is benefiting the customers. I would implement procedure justice by providing process control, explanations, and provide him clear reasons as to why he is receiving the reward. If the company cannot provide Bob a raise or a substantial one, I would use creative rewards for performance like create contests, give out tickets, as they may be earn unlimitedly when I acknowledge him for his good performance. 4. What are the implications of this case for employers hiring Generation Xers? The implication this case suggest of hiring Generation Xers, is that even though they have a college degree employers would have to let them know they are in competition for their jobs and that they may only get paid half of what they were paid years ago (Robbins Judge, 2007 p. 217). It has to be out in the open to the Generation Xers that there is no job security due to businesses trying to keep costs down and they will probably receive only minimum future raises in salaries (Robbins Judge, 2007 p. 217). References 590Robbins, S. P. , Judge, T. A. (2007). Organizational Behavior(12th. ed. ). Prentice Hall.

Biography of Elizabeth of York, Queen of England

Biography of Elizabeth of York, Queen of England Elizabeth of York (February 11, 1466–February 11, 1503) was a key figure in Tudor history and in the Wars of the Roses. She was the daughter of Edward IV and Elizabeth Woodville; Queen of England and Queen Consort of Henry VII; and the mother of Henry VIII, Mary  Tudor, and Margaret Tudor, the only woman in history to have been daughter, sister, niece, wife, and mother to English kings. Fast Facts: Elizabeth of York Known For: Queen of England, mother of Henry VIIIBorn: February 11, 1466 in London, EnglandParents: Edward IV and Elizabeth WoodvilleDied:  February 11, 1503 in London, EnglandEducation: Trained in the palace as a future QueenSpouse: Henry VII  (m. January 18, 1486)Children: Arthur, Prince of Wales (September 20, 1486–April 2, 1502); Margaret Tudor (November 28, 1489–October 18, 1541) who married King James IV of Scotland); Henry VIII, King of England (June 18, 1491–January 28, 1547); Elizabeth (July 2, 1492–September 14, 1495); Mary Tudor (March 18, 1496–June 25, 1533) married King Louis XII of France; Edmund, Duke of Somerset (February 21, 1499–June 19, 1500); and Katherine (February 2, 1503) Early Life Elizabeth of York, known alternatively as Elizabeth Plantagenet, was born on February 11, 1466, at Westminster Palace in London, England. She was the eldest of the nine children of Edward IV, king of England (ruled 1461–1483) and his wife Elizabeth Woodville (sometimes spelled Wydeville). Her parents marriage had created trouble, and her father was briefly deposed in 1470. By 1471, likely challengers to her fathers throne had been defeated and killed. Elizabeths early years were spent in comparative calm, despite the disagreements and battles going on around her. She likely began her formal education in the palace by age 5 or 6, and learned history and alchemy from her father and his library. She and her sisters were taught by ladies-in-waiting, and by observing Elizabeth Woodville in action, the skills and accomplishments considered appropriate for future queens. That included reading and writing in English, mathematics, and household management, as well as needlework, horsemanship, music, and dancing. She spoke some French, but not fluently. In 1469, at the age of 3, Elizabeth was betrothed to George Neville, but it was called off when his father supported Edward VIIs rival, the Earl of Warwick. In August 29, 1475, Elizabeth was 11 and, as part of the Treaty of Picquigny, she became betrothed to Louis XIs son, the Dauphin Charles, who at the time was 5 years old. Louis reneged on the treaty in 1482.   Death of Edward IV In 1483, with the sudden death of her father Edward IV, Elizabeth of York was at the center of the storm, as the eldest child of King Edward IV. Her younger brother was declared Edward V, but because he was 13, his fathers brother Richard Plantagenet was named regent protector. Before Edward V could be crowned, Richard imprisoned him and his younger brother Richard in the Tower of London. Richard Plantagenet took the English crown as Richard III, and had the marriage of Elizabeth of Yorks parents declared invalid, claiming Edward IV had been betrothed before the marriage had occurred. Though Elizabeth of York was by that declaration made illegitimate, Richard III was rumored to have had plans to marry her. Elizabeths mother, Elizabeth Woodville, and Margaret Beaufort, mother of Henry Tudor, a Lancastrian claiming to be heir to the throne, planned another future for Elizabeth of York: marriage to Henry Tudor when he overthrew Richard III. The two princes, the only surviving male heirs of Edward IV, disappeared. Some have assumed that Elizabeth Woodville must have known, or at least guessed, that her sons, the Princes in the Tower, were already dead because she put her efforts into her daughters marriage to Henry Tudor. Henry Tudor Richard III was killed on the battlefield in 1485, and Henry Tudor (Henry VII) succeeded him, declared himself King of England by right of conquest. He delayed some months in marrying the Yorkist heiress, Elizabeth of York, until after his own coronation. They were married in January 1486, gave birth to their first child, Arthur, in September, and she was crowned Queen of England in November 25, 1487. Their marriage established the Tudor dynasty of the British crown. Her marriage to Henry VII brought together the House of Lancaster which Henry VII represented (though he grounded his claim to the crown of England in conquest, not birth), and the House of York, which Elizabeth represented. The symbolism of a Lancastrian king marrying a Yorkist queen brought together the red rose of Lancaster and the white rose of York, ending the Wars of the Roses. Henry adopted the Tudor Rose as his symbol, colored both red and white. Children Elizabeth of York apparently lived peacefully in her marriage. She and Henry had seven children, four surviving to adulthood- a fairly decent percentage for the time. Three of the four became kings or queens in their own right: Margaret Tudor (November 28, 1489–October 18, 1541) who married King James IV of Scotland); Henry VIII, King of England (June 18, 1491–January 28, 1547); Elizabeth (July 2, 1492–September 14, 1495); Mary Tudor (March 18, 1496–June 25, 1533) married King Louis XII of France; Edmund, Duke of Somerset (February 21, 1499–June 19, 1500); and Katherine (February 2, 1503). Their oldest son, Arthur, Prince of Wales (September 20, 1486–April 2, 1502) married Catherine of Aragon, a third cousin of both Henry VII and Elizabeth of York, in 1501. Catherine and Arthur became ill with sweating sickness soon after, and Arthur died in 1502. Death and Legacy Its been surmised that Elizabeth became pregnant again to try to have another male heir for the throne after Arthurs death, in case the surviving son, Henry died. Bearing heirs was, after all, one of the most crucial responsibilities of a queen consort, especially to the hopeful founder of a new dynasty, the Tudors. If so, it was a mistake. Elizabeth of York died in the Tower of London on February 11, 1503, at the age 37, of complications of the birth of her seventh child, a girl named Katherine, who died at birth on February 2. Only three of Elizabeths children survived at her death: Margaret, Henry, and Mary. Elizabeth of York is buried at the Henry VII Lady Chapel, Westminster Abbey. The relationship of Henry VII and Elizabeth of York is not well-documented, but there are several surviving documents which suggest a tender and loving relationship. Henry was said to have withdrawn in sorrow at her death; he never remarried, though it might have been advantageous diplomatically to do so; and he spent lavishly for her funeral, though he was usually quite tight with money. Fictional Representations Elizabeth of York is a character in Shakespeares Richard III. She has little to say there; she is merely a pawn to be married to either Richard III or Henry VII. Because she is the last Yorkist heir (assuming her brothers, the Princes in the Tower, have been killed), her childrens claim to the crown of England will be more secure. Elizabeth of York is also one of the major characters in the 2013 series  The White Queen  and is the key character in 2017 series The White Princess. Elizabeth of Yorks picture is the usual depiction of a queen in card decks. Sources License, Amy. Elizabeth of York: The Forgotten Tudor Queen. Gloucestershire, Amberley Publishing, 2013.Naylor Okerlund, Arlene. Elizabeth of York. New York: St. Martins Press, 2009.Weir, Alison. Elizabeth of York: A Tudor Queen and Her World. New York: Ballantine Books, 2013.

Venerate

Venerate Venerate Venerate By Maeve Maddox This odd use of the verb venerate occurs on a funeral home website: Prior to the age of photography, death masks were used to venerate the death. The use is odd because the transitive verb venerate means â€Å"to regard with feelings of respect and reverence.† The taking of a death mask may be seen as a way of venerating a deceased person, but not a death. The Latin verb venerare gives us the verb venerate and the adjective venerable. The words are used in both religious and secular contexts: While far from universal, ancestor veneration occurs in societies with every degree of social, political, and technological complexity. While Horus was venerated throughout Egypt, his primary cult centers were in the south.   Kissing the Black Stone–Veneration or an Idolatrous Practice? Why Do We Venerate the Holy Cross? Upon Gary Smith’s retirement: The venerated Sports Illustrated writer on long-form immersion and intimacy The book discusses the extreme veneration of technology. Generation gap: Older folks venerate patriotic symbols, while younger folks extol principles. The adjective venerable (worthy of respect or worship) may be applied to people or things. The respect may be seen to stem from character, position, age, or antiquity. Author of Stupid Men Jokes Nancy Gray calls Washington DC â€Å"that venerable bastion of maledom.† Anti-equality advocates, like Princeton professor  Robert George and his co-authors, are attempting to cast this movement as an attack on the venerable institution of marriage.   The doctrine of re-birth - that is, the repeated embodiment of the inner essence of man - is the oldest and most venerable belief of the human race. It was also great to see such venerable actors as Dick Van Dyke, Mickey Rooney, and Bill Cobbs, as the three elderly security guards, strut their stuff. In some religions, Venerable is an honorific prefixed to the names of especially respected leaders: Buddhist Ethics by Venerable K. Sri Dhammananda Maha Thera The Venerable Dr. Jean Fritz Bazin, [Episcopal] Archdeacon for Immigration and Social Justice In the Roman Catholic process of canonization, Venerable is a title bestowed on a candidate for sainthood before the approval of the first miracle. The person most associated with the title Venerable in English is a medieval monk named Bede (672-735 CE). Bede is venerated as the father of English history. Because of his dedication to scholarship and religious observance, he was honored with the title Venerable even in his lifetime. He doesn’t seem to have undergone the official canonization process, but in 1899, Pope Leo XIII declared him a Doctor of the Church. He is often referred to as â€Å"Saint Bede,† but more commonly as â€Å"the Venerable Bede.† Bottom line: People and things are venerated. Respected people and things are venerable. The transitive verb venerate takes a direct object–human or inanimate–that is felt by someone to be worthy of respect. The funeral home writer may have been reaching for the word commemorate (to mark by ceremony): Prior to the age of photography, death masks were used to commemorate the death. Note: Although the word worship is often given as a synonym for venerate, many speakers distinguish between the two words, using venerate to denote deep respect for non-divine things or personages and reserving worship to describe the adoration of a divinity. Want to improve your English in five minutes a day? Get a subscription and start receiving our writing tips and exercises daily! Keep learning! Browse the Vocabulary category, check our popular posts, or choose a related post below:What Is Irony? (With Examples)Between vs. In BetweenShore It Up

Tourism Marketing Research Proposal Example | Topics and Well Written Essays - 1000 words

Tourism Marketing - Research Proposal Example The research is thus undertaken to understand the different dimensions of tourism marketing and ho this elates to marketing of tourist spots and what are the approaches involved in marketing such tourist places or locations. The concepts of brands and creativity or innovation are also highlighted in the discussion. There are several research questions in this study and based on these research questions, some of the research articles and analysis published in journals will be examined and a comparison of the research approach with the already published research viewpoints will be sought. The main research question is whether or how the approach to tourism marketing and management should change or differ in case of architectural landmark as against tourism marketing of regular destination or location. Are there special approaches to promoting a particular tourist spot and how is it possible to differentiate between destination and location and tourist sites such as architectural landmarks in tourism marketing and management Considering the approaches to tourism marketing in promoting destinations and tourist or architectural sites as brands, several research studies and published papers could be used to substantiate the background of the study. The research study is to be focused on destination marketing and tourist destination as brands as it is important to develop branding approaches for any successful marketing venture. As Kerr (2006) has indicated, destination marketing organizations with government support have been responsible for promoting certain locations and tourist spots and there is suggestion to review such responsibilities and approaches. However there are downsides to destination marketing as this sort of marketing is solely tourism focused and tend to overlook stakeholder prospects or investments in these locations so may not be completely productive for the overall development of a location. Brand management of any particular location deals with the holistic approach of actually changing the potential of a location from an ordinary location to a tourist friendly destination. However according to Kerr there is a need to reform destination marketing practices as it is important to address brand management of locations. Kerr draws out a distinction between destination brand and location brand with the potentially relevant research areas as in the study of brand management of locations. In another related paper, Perivoliotis and Margaret (2007) studied local tourist producers and businesses involved in artifacts and textiles. The paper focuses on how tourism marketing could bank in on the strengths of the local markets and cultural heritage of any product and also brings out the importance of creativity, innovation, productivity, education in any tourism marketing and management initiative. New technology is primarily important in tourism marketing as it could be used to select participating tourist producers and marketers or managers and basic design education and computer training as also basic management and marketing

THE COTSWOLDS AREA OF OUTSTANDING NATURAL BEAUTY Essay

THE COTSWOLDS AREA OF OUTSTANDING NATURAL BEAUTY - Essay Example ple and Hall (1992) opines that the heritage based tourism aims at letting the tourists experience the past traditional, social and religious aspects of a destination. In order to give tourists an unforgettable experience in heritage tourism, the management of a tourist destination selected must be perfect. One area that can be used to perfect the management of destinations is through an audit of the destination. An audit of the destination will involve an intensive examination of the destinations available tourism resources (Cooper, 2003). These resources include the amenities, major attractions, activities and other internal aspects of the destination with respect to the targeted market. It also includes the external factors such as threats emerging from competition and economic environment (Woodside 2008). This paper uses the case of Cotswolds Area of Outstanding National Beauty to perform a tourist destination audit. First, an overview of the destination is given. It then proceeds to analyse the internal and internal factors that affect the performance of the destination with recommendations of appropriate actions in the end. The Cotswold area is the largest heritage based destinations of tourism in England and Wales. The geographical area covers an expansive region with different tourist attractions. These include heritage cities, serene and attractive country side, cultural cuisines, and local limestone along with heritage events. Because of its expansive nature, the Cotswold area of outstanding natural beauty has a complex destination management organization. A destination management organization is the hierarchy of groups of persons and bodies that are in charge running tourism affairs in a given tourist destination (Wang & Pizam 2011). Their main task is to constantly examine and improve tourism attraction features and strategically position the destination in the tourism market (Klimerk 2013, p. 1). This study also indicates that the destination

Baldwins Stepfather in Notes to a Native Son Essay -- James Baldwin

The Effects on a Narrative Son From His Stepfather In order to effectively analyze something, it is necessary to thoroughly examine and discuss the subject. James Baldwin does this in his essay â€Å"Notes of a Native Son† by describing his experiences growing up with his stepfather while weaving in discussion. Baldwin’s comments during these breaks in his stories draw conclusions and generalizations about himself, his relationship with his father, and its influence on James Baldwin. He uses this analysis to discover and help the audience understand how he was and is affected by his stepfather. Baldwin’s stepfather was very quiet and remote in his relationships with his children. In his essay, Baldwin presents many stories portraying examples of this which all appear early on in the essay. One of the most important stories about his childhood with his stepfather is when they walk back home from church and have their only meaningful conversation together. Baldwin writes that the opportunities in America are â€Å"thicker† than any other place and as a result of this â€Å"the generation has no time to talk to the first†(63). Unlike this observation by Baldwin, his stepfather didn’t avoid contact with the world because of the available opportunities. Instead, Baldwin’s stepfather kept himself away from his children and the world because of his immense anger and hatred. Baldwin remembers his father â€Å"sitting at the window, locked up in his terrors; hating and fearing every living soul including his children who had betrayed him, to o, by reaching towards the world which had despised him†(66). James Baldwin’s stepfather feels extremely rejected by the world and as a result hates everything in it and in contact with it. He feels betra... ...s to be hatred, as described in earlier passages but in this case Baldwin shows that they are ultimately caused by pride. Baldwin uses his narration and analysis to realize that although he ignored his father during his childhood, he could have benefitted by learning something from his warnings. In the final sentence of the essay Baldwin writes, â€Å"I wished that he had been beside me so that I could have searched his face for the answers which only the future would give me now† (84). Baldwin realizes that through similar experiences he and his stepfather have learned much about the world. He wishes that he could still learn from his stepfather but knows that he must now rely on his future experiences. Works Cited Baldwin, James. â€Å"Notes of a Native Son.† 1955. James Baldwin: Collected Essays. Ed. Toni Morrison. New York: Library of America, 1998. 63-84.

Puma’s Ag Case

PUMA’s AG Case Adalbert and Rudolf Dassler founded puma in 1924 in Germany. The company was called Gebruder Dassler OHG, and was internationally well known. However, the two brothers separated creating Adidas and Puma, respectively. Puma had sponsored some of the worlds most famous soccer players, positioning itself as one of the most important company in soccer shoes and accessories. In spite of that, the son of the founder, Armin Dassler, take Puma to a point where all product were sold â€Å"dirt-cheap†, ruining the brand image. The high society was not willing to wear the brand.In 1993, Jochen Zeitz, became the CEO of the company, and together with Martin Gaensler, the supply chain management chief, applied 3 significant phases into the Comeback of Puma: * Aimed at making Puma profitable in order to build a strong financial foundation. * Restructuring the whole company * Focusing in core competencies: marketing, brand management, and product management. * Transform Puma into an attractive sports brand. (High- value brand in sport and lifestyle sales categories). * Sponsoring and advertisement. Puma’s major competitors 1. Adidas –Salomon AG * Headquarters in Bavaria, Germany. Production was in every continent, except in Australia, with administration, design, and marketing in Germany and France. * Production outsourced in Asia. * Only supplier covered all sports. * Main strength soccer line, sky and tennis market. * Known as a brand for the family, satisfying customer’s needs. * Sponsoring activities on huge sports events, famous teams, and athletes like FIFA World Cup and UEFA Champions League. 2. Nike * American company founded by Bill Bowerman and Phil Knight in 1964. * Outsourced part of the production to China and concentrated its skills on product design, marketing, and distribution. Located in Oregon. * Administrative activities concentrated in United States. * Europe, Africa, and Asia worked only in sales strategies . * Target group young people with the slogan â€Å"Just do it† * Marketing strategy: sponsoring events, popular teams, and athletes. * Introduction to specialized brands * Web-based Nike ID (customizing Nike products) 3. Reebok * Founded in 1895 in USA by Joseph William. * Key market: footwear industry (aerobics industry, women’s sportswear, and design street & casual footwear). * Located in 140 countries. R & D in China, Korea, and Taiwan. Distribution finished goods via traditional retailers. * Sales in Gym club trainers. * Reebok female sports shoes were the most famous. * 1992, change of strategy to American football, basketball, and soccer. * Sponsoring sport events and popular athletes. * Nevertheless, Reebok was often regarded as a fitness and exercise equipment manufacturer. 4. Fila * 1911, Italy. * Distribution in 50 countries. * Portfolio of sportswear and athletic footwear. * Focus on running, basketball, and fitness. 5. Prada * Italian brand focused on lux ury leather goods. * Founded by Mario Prada. 2003 Sportive line called Prada Sport. 6. Diesel * 1970. Casualwear or sportswear company that became a luxury brand. PUMA’s Value Chain * R&D: sourcing, production, and logistics * 80% of all production move to Asia due to raw materials and MOD * Manufactured in Turkey and Mexico * It reduces its working capital and inventory to 21% * The raw material sourcing allowing shortening the production and enabling full quality control of input factors. (Inditex’s Zara strategy) * Production partners according to quality, price, and environmental/social factors. Logistics was not a core competence. * Brand management * Turnaround new positioning of the brand itself. * 1980’s unpopular image due to heavy price decline. * Jochen Zeitz (CEO), repositioned the brand * Making PUMA desirable again * 2003, the brand was already positioned and well-known and considered as a luxury * Ensuring success, PUMA hired charismatic personali ties who could represent and understand the desired brand perception, recognition, and awareness even further. * Sponsoring several teams such as the Jamaican running team, Cameroon soccer team, and Italian national soccer team. Sponsoring Formula One, entering by the official supply of sportswear for the FIA World Rally Championship, the Ford Rally division, and freestyle motocross champion Travis Pastrana. * Quality over quantity and rely on innovation. * Following upcoming trends quickly and creating trends. * The Puma classic King was reintroduced creating a new market segment of lifestyle sportswear, having in consequence to it a significant competitive advantage over competitors from the fashion industry. * CEO understood the fashion as â€Å"the new combination of elements of the past†. * Right time for launching a new product line. Puma entered in the cricket market in Australia and Africa. * Advertising in MTV and in Hollywood movies. * Puma was perceived as rebellio us and stylish. * Distribution * Outsourcing 70% in distribution logistics. * Building up a system to develop its own network in Europe. * Retail activities * Selected partners according to the corporate message of Puma. * Sport retailer did not operated globally; only foot Locker and Intersport, Decathlon, and JJB Sports. * There was no price discrimination due to low transportation costs in Europe. * Collaboration with strategic partners and allies Acquired the Swedish company Tretorn (manufacturer of tennis balls), because of the sophisticated and broad distribution system in the Scandinavian market and a very skilled management team. Corporative Strategy: R&D and design (functionality and stylish appearance products). Launching the New Collection: sport, lifestyle, and fashion. * Trying to be innovative in every part of the process * Marketing strategy Innovation * Modernizing latest collections and re-launch them Bibliography. Kaufmann, Lutz. â€Å"Puma AG†. The WHU Otto Beisheim Graduate School of Management.

The Most Important Bankruptcy Supreme Court Cases - Free Essay Example

Sample details Pages: 4 Words: 1336 Downloads: 5 Date added: 2019/08/08 Category Law Essay Level High school Tags: Supreme Court Cases Essay Did you like this example? The Most Important Bankruptcy Supreme Court Cases Issue Whether debtor’s retained counsel could be compensated for the fees and expenses incurred in the defense of its bankruptcy fee application. Facts The Southern District of Texas Bankruptcy Court awarded Baker Botts, LLP, along with Jordan, Hyden, Womber, Culbreth Holzer, PC, approximately $120 million in fees for representing ASARCO, LLC, one of the leading copper producers in the U.S., who filed for Chapter 11. As the bankruptcy court noted in its initial fee award order, the DOJ described the ASARCO case as â€Å"the largest environmental bankruptcy in U.S. history.† In 2009 ASARCO emerged with a reorganization plan that would pay its creditors in full, $1.4 billion in cash and resolution of its environmental liabilities. Don’t waste time! Our writers will create an original "The Most Important Bankruptcy Supreme Court Cases" essay for you Create order Baker Botts filed for a final fee request, which ASARCO contested. After extensive discovery and a 6-day trial, the Bankruptcy Court overruled the objections and awarded $120 million in compensation, $4.1 million as an â€Å"enhancement for exceptional performance,† and $5 million in fees for defending the applications. The district court affirmed. The U.S. Court of Appeals for the Fifth Circuit held that the Bankruptcy Code did not allow the firms to recover $5 million spent defending the fee request against Asarcos opposition. The Fifth Circuit held that (i) the American Rule (discussed below) controls absent explicit statutory authority providing reimbursement of defense fees and (ii) defense fees fall outside of  §330(a)(1)’s requirement that services are only compensable â€Å"if they are likely to benefit a debtor’s estate or are necessary to case administration† because the professional, not the estate, is the â€Å"primary beneficiary of a profe ssional fee application.† The Supreme Court then granted certiorari and heard oral argument on February 25, 2015. Holding On June 15, 2015, the Supreme Court affirmed the judgment of the Fifth Circuit in finding that fee defense costs were not recoverable. Justice Thomas wrote the opinion for a six Justice majority (Justice Sotomayor concurring for purposes of the outcome). Justice Breyer dissented, joined by Justices Kagan and Ginsburg. The Supreme Court’s review of the language of Bankruptcy Code  §330(a)(1) led the Court to conclude that it did not provide the sort of â€Å"explicit statutory authority† necessary to override the American Rule and therefore bankruptcy professionals employed under  §327(a) of the Bankruptcy Code may not, under  §330(a)(1) of the Bankruptcy Code, recover as compensation fees incurred in defending their bankruptcy fee applications. The Court’s majority stated, â€Å"[t]he word ‘services’ ordinarily refers to ‘labor performed for another.’† Since Baker Botts was litigating to defend its own fees, the Court reason ed that it was not providing an â€Å"actual, necessary service† to the bankruptcy estate and therefore was not entitled to compensation for such time. Baker Botts’ Significance and Aftermath Following the issuance of the Baker Botts opinion, bankruptcy professionals have raised concerns that the ruling will lead to litigants tactically using fee objections to pressure debtors and their retained professionals. However, since the Baker Botts decision questions have been raised whether there is a possible workaround. That question has been tested in cases since Baker Botts. For example, in the Delaware cases In re Boomerang Tube, LLC, et al. Case No. 15-11247 (MFW) and In re Northshore Mainland Services, Inc., et al. (15-11402-KJC) (a/k/a the Baha Mar case), the bankruptcy court declined to allow Baker Botts ruling to be avoided by contract.   In the Boomerang case, the law firm for the official committee of unsecured creditors asked for the fee approval order to include a provision that would entitle it to be compensated from the bankruptcy estate for fees incurred in defending its fees against any challenges. The law firm relied upon  §328 of the Bankruptcy Code, which allows for the retention of estate professionals â€Å"on any reasonable terms and conditions† arguing that the Supreme Court in Baker Botts recognized that parties could and regularly did contract around the American Rule. The Boomerang Court denied the request and held that  §328 does not create a statutory exception to the American Rule, because it does not mention awarding fees or costs in the context of an adversarial proceeding. In support of the court’s ruling, the Boomerang Court rejected the law firm’s argument that  §328 permitted a contractual agreement for the payment of defense fees because the retention agreement was between the law firm and the official creditors’ committee, but it would be Boomerang Tube’s bankruptcy estate, a non-party to such agreement, that would bear the costs.   Finally, the Boomerang Court determined that the proposed fee shifting provisions were not â€Å"reasonable† terms of employment of professionals with the meaning of  §328. However, decisions in two other cases, In re Nortel Networks, 2017 Bankr. LEXIS 674 (Bankr. D. Del. Mar. 8, 2017) and in a New Mexico case, In re Hungry Horse LLC, Case No. 16-11222, distinguished Boomerang Tube and permitted contractual provisions that allow payment for the defense of fees.   Nortel Networks that Baker Botts and Boomerang Tube did not apply to a fee dispute between an indenture trustee and certain bondholders, and permitted the trustee to recover its attorneys’ fees for defending against the challenge.   Although this case is not directly on point as it did not involve an estate professional, and Judge Gross was not opining on whether Section 328 would permit such an agreement, he held that the bond indenture qualified as a contractual exception to the American Rule, noting that, unlike the retention agreement in Boomerang Tube, it was an agreement directly between the debtor and the trustee. In Hungry Horse New Mexico Bankruptcy Judge David Thuma looked to Nortel Networks for support in holding that a retention agreement in a chapter 11 case between proposed debtor’s counsel and the debtor could pass muster under Section 328, thereby permitting a contractual work-around to Baker Botts.   Judge Thuma first determined that nothing in Baker Botts prevented a bankruptcy court from finding a fee defense provision in a retention agreement to be â€Å"reasonable† within the meaning of Section 328.   In his reading of Baker Botts, the Court simply limited the compensation an estate professional could receive under Section 330 to fees for services to the client, rather than on its own behalf, and noted that Section 328 had no applicability to that issue. He then considered various other provisions typical of retention agreements, and observed that several were â€Å"reasonable† under Section 328 even if they were intended to favor the professional, rather than the client. He pointed to provisions, among other things, setting out retainer requirements, permitting an attorney to withdraw under certain conditions, and granting a lien on certain recoveries.   â€Å"A typical employment agreement between a lawyer and a client has many terms; some benefit the client, while others benefit the lawyer.   Considered together, they may be reasonable.†Ã‚   The overall effect, he noted, is that â€Å"the client obtains the services of needed, able professionals.† Judge Thuma concluded that Section 328 therefore can permit contractual exceptions to the American Rule, and outlined the terms of a fee defense provision in a retention agreement that he believed was â€Å"reasonable† and â€Å"violat[ed] neither the letter nor spirit of [Baker Botts].†Ã‚   He stated that, among other things, it needed to be agreed to by the bankruptcy estate, in order to avoid the issue highlighted by Judge Walrath in Boomerang Tube, and provided also that it extended to the creditors’ committee’s professionals, in order to â€Å"level the playing field.†Ã‚   He suggested sample language that he believed could be acceptable under Section 328: Fee Defense. The Client agrees to pay all reasonable legal fees and expenses incurred by the Firm, and also by any counsel retained by the unsecured creditors’ committee (if one is formed in the Client’s bankruptcy case) for successfully defending their respective fee applications. The bankruptcy court must approve all of such fees as reasonable. The Client will have no obligation to pay for any fees or expenses the Firm incurs defending fees that are not allowed. The pragmatic approach taken in Hungry Horse in particular offers a template that other courts will likely be urged to adopt. https://www.abi.org/feed-item/delaware-takes-on-baker-botts-v-asarco-fee-defense-costs