Epic of Beowulf - Where Did the Christianity in Beowulf Come From? Essa

Where Did the Christianity in Beowulf Come From?   â The Christian impacts in Beowulf at last originated from the Christian/Catholic Church of Rome which changed over Romans, and along these lines the Roman armies and in this manner the involved areas. Likewise the Christian/Catholic Bishop of Rome sent evangelist ministers and priests to the British Isles to proselytze the populace. There are extra contemplations as well.  As a matter of first importance, let us get straight to the point about the way that the transformation of Britain to Christianity started very early. The Catholic cleric Venerable Bede, conceived in Bernicia, Northumbria, around 673, states in Bk 1, Ch 4 of his Ecclesiastical History of the English People that while Eleutherius was Bishop of Rome (175-189AD), a lord of Britain named Lucius mentioned of the Pope that the ruler be purified through water a Catholic by ecclesiastical pronouncement:  In the time of our Lord 156 Marcus Antoninus Verus was made head along with his sibling Aurelius Commodus. He was the fourteenth after Augustus. In their time, while a heavenly man called Eleutherius was cleric of the congregation at Rome, Lucius, a ruler of Britain, sent him a letter supplicating him that he may be made a Christian by a rescript from him. His devout solicitation was immediately allowed and the Britons protected the confidence which they had gotten, untouched and whole, in harmony and calm, until the hour of the Emperor Diocletian.  Bede’s last sentence in the entry suggests that Christianity had just been built up in Britain for quite a while before Eleutherius possessing Peter’s seat from 175-189. This appears to be sensible as indicated by what is composed by the antiquarian Eusebius Pamphilus, cleric of Caesarea, in His Ecclesiastical History written in the 300’s. The Ecclesiastical His... ...McClure, Judith, editors. Bede: The Ecclesiastical History of the English People; The Greater Chronicle; Bede’s Letter to Egbert. New York: Oxford University Press, 1969.  Eusebius’ Ecclesiastical History, deciphered by C.F. Cruse. Peabody, MS: Hendrickson Publishers, 2000.  Magoun, Frances P. â€Å"Oral-Formulaic Character of Anglo-Saxon Narrative Poetry.†Ã¢ In TheBeowulf Poet, altered by Donald K. Fry. Englewood Cliffs, NJ: Prentice-Hall, Inc., 1968.  â€Å"Nero.† The Columbia Encyclopedia, sixth ed. New York: Columbia University Press, 2000. www.bartleby.com/65/.  â€Å"St. Patrick.† The Columbia Encyclopedia, sixth ed. New York: Columbia University Press, 2000. www.bartleby.com/65/.  Ward and Trent, et al. The Cambridge History of English and American Literature. New York: G.P. Putnam’s Sons, 1907â€21; New York: Bartleby.com, 2000  Â

I am going to talk about how Shakespeare creates sympathy for Juliet in Act 3 Scene 5 Essay Example

I am going to discuss how Shakespeare makes compassion toward Juliet in Act 3 Scene 5 Essay Example I am going to discuss how Shakespeare makes compassion toward Juliet in Act 3 Scene 5 Essay I am going to discuss how Shakespeare makes compassion toward Juliet in Act 3 Scene 5 Essay Exposition Topic: Talk In Act 3 Scene 5, Romeo and Juliet have recently woken up from going through their night together, at the end of the day fulfilling the marriage. Juliets nurture at that point comes in and says that her mom needs to talk with her. Romeo says farewell to Juliet an, articulating that they will meet once more. At that point Juliets mother, Lady Capulet, rushes in and reports that Juliet should wed Paris next Thursday morning. Juliet is likely reasoning How would i be able to wed Paris, when I am hitched to Romeo?Then, in comes her dad, Lord Capulet, who whines about her despite everything crying. At that point he looks towards Lady Capulet, and asks her whether she has disclosed to Juliet the report about her wedding. Woman Capulet answers by saying she has told Juliet, however then reverse discharges by saying she wishes Juliet was dead and hitched to her grave. Juliet says she is glad at what her dad found for her, however she isn't appreciative of something she detests. Her dad at th at point goes on to obnoxiously mishandling her, and finishes up by saying on the off chance that she isn't at the congregation on Thursday morning, he will abandon her.The sort of language highlights Shakespeare utilizes in Act 3 Scene 5 of Romeo and Juliet are paradoxical expressions, twofold implications, comparisons and illustrations. A case of a confusing expression is when Romeo says O fighting affection! Here Romeo is portraying how out of adoration he is. Here Rosaline dismissed him and he significantly grieved over the misfortune. A case of a two sided connotation is when Juliet is conversing with her mom, after her mom says wed, I won't wed at this point. Also, when I do, I swear it will be Romeo, whom you realize I as of now detest, instead of Paris.These are news without a doubt! Juliet, cleverly, turns her words when she is around her mom. She says that she would prefer Romeo, however she is as of now wedded to him. In any case, her mom doesn't realize that Romeo and Ju liet are legitimately hitched. A case of an illustration is when Juliets father is manhandling her and saying spiting things like, Out you green infection, remains! Out you stuff! You fat face! Juliets father is calling her angry things like You nauseate me, you bug! He is letting his furious feelings out on Juliet by communicating how he feels about Juliets choice about the marriage he decided for her.One of the manners in which Shakespeare likewise makes compassion toward Juliet is by causing such a significant number of appalling occasions to occur simultaneously for Juliet. I feel that due to Tybalt biting the dust, Romeo leaving, quite possibly he may stay away forever and that Juliet is being constrained into an organized marriage with Paris, Juliet is upset. Furthermore, the way that Juliet lacks a mother figure, one that she can trust, has a major impact in how Shakespeare makes compassion toward Juliet.Juliet had the medical attendant as a mother figure for almost every las t bit of her life, the attendant even breastfed Juliet since she was pretty much nothing. Tis since the quake now eleven years; And she was weand,I never will overlook it,- Of the considerable number of days of the year, upon that day: For I had then laid wormwood to my burrowed, Sitting in the sun under the bird house divider; My master and you were then at Mantua: Nay, I do bear a brain:but, as I stated, When it tasted the wormwood on the areola Of my burrowed and felt it harsh, pretty nitwit, To see it touchy and drop out with the burrowed! Here the medical caretaker is sharing her experience of Juliet being breastfed.Even however the attendant resembles a mother to Juliet, when Juliet approaches the medical caretaker for comfort in time generally required; the attendant essentially answers back I think it best on the off chance that you wedded with the region. Gracious, hes a stunning man of honor. Romeos a dishclout to him. The medical caretaker is offering her input to Juliet, which is something Juliet wouldn't like to here, in light of the fact that she confided in the attendant and just in that quote, I imagine that the trust among Juliet and the medical attendant is broken.Additionally Juliet feels that she is left in complete dimness, when different situations occur simultaneously for Juliet; Romeo leaves her, she is compelled to wed Paris, Tybalt, her nearby cousin has as of late passed on, and when Juliet approaches the medical caretaker for comfort and exhort, the attendant double-crosses Juliet in the back by not saying what Juliet needs to hear. Here, we find the shortcoming of the medical attendant by her unexpected activities towards Juliet. Everybody leaving Juliet in a manner mirrors this in the arranging of the scene, her cousins demise, Romeo going to Mantua and afterward the medical attendant, who she trusts beyond a reasonable doubt, doesnt identify about what she is feeling.The subjects Shakespeare utilizes in Act 3 Scene 5 are many. A few topics remembered for the play are love. There are various kinds of affection in Romeo and Juliet. There is cultured love, loyal love and genuine romance. Dignified love is utilized when Romeo is discussing Rosaline and how she isn't hit with Cupids bolt, as is Romeo. Romeo will in general be extremely emotional when alluding to cherish. Another name for dignified love is petrarchan love. Loyal love is the affection among Paris and Juliet. Paris has consistently been faithful to Juliet all through the entire play. Toward the finish of the play, Paris loyal love picks up him a spot close to Juliet on her deathbed. Genuine romance is the adoration that is passed on. Romeo and Juliet.When Romeo says to Juliet, Farewell! I will overlook no open door that may pass on my welcome, love, to thee. Romeo is communicating his affection toward Juliet, in light of the fact that truth be told, Juliet is never going to see Romeo again, however the crowd and characters dont know this. Shakespea re generally makes compassion toward Juliet by utilizing loyal love and genuine affection. By utilizing genuine romance, Shakespeare is causing Juliet to feel very desolate in light of the fact that her significant other is leaving her, and perhaps, failing to come back. By utilizing obedient love, I think Shakespeare causes Juliet to feel blameworthy in a manner since Paris really cherishes her, yet she is being unfaithful to him since she is as of now wedded to another man.Furthermore, Shakespeare likewise makes compassion toward Juliet by making the crowd in Romeo and Juliet a man centric culture, causing the men to have greater need to lady over numerous things. For the situation where Juliet is compelled to wed Paris, she needs to wed since her dad was constraining her. Also, the way that Lord Capulet is a man, and thought about the leader of the house, each one in the house including Lady Capulet, Juliet, the attendant and the hirelings need to comply with the man of the house . This makes compassion toward Juliet, in light of the fact that her dad, in view of the man centric culture, drives her decisions in life upon her. On the off chance that Juliet doesn't hear her out dad, at that point he said he will repudiate her. Hang thee, youthful things! Defiant wretch!I tell thee what: get thee to chapel o Thursday, Or never after look me in the face: Speak not, answer not, don't answer me; My fingers tingle. He additionally needed to slap her since she was in effect so insubordinate and stubborn.In end, I think how Shakespeare makes compassion toward Juliet is important, in light of the manner in which he plays with the crowds sentiments towards Juliet. It likewise includes a considerable amount of contention to the play between the families toward the finish of the play. Romeo and Juliet didn't intend to begin to look all starry eyed at; they were bound to experience passionate feelings for and afterward bite the dust, since the beginning of the disaster. T hey are Star-crossed darlings from the beginning of the play; the proof is in the introduction. The manner in which Shakespeare made compassion toward Juliet, drove her to manage nothing else of the things she had to do, so it lead to two darlings from two angry families to end their lives, only for their voices to be heard to arrive at the family.

Florida electorate's buyer's remorse of governor Rick Scott and Essay

Florida electorate's purchaser's regret of representative Rick Scott and Florida's absence of a review procedure - Essay Example To be sure 68% of those met concurred held this perspective as appeared by the survey results (Brown 1). The State of Legislatures are likewise sharing same dissatisfaction from the Florida voters simply like the representative, and their rating is 56-27% as at may 2011, while in April it was 47-35 (Brown 2). Regardless of this low evaluating of Governor Rick Scott, voters have little choice since they can't send him back home until his term closes. This is on the grounds that Florida State needs gubernatorial review process. This paper in this manner inspects these twin issues confronting Florida State, the disappointment of the Florida electorate with Governor Rick Scott and Florida's absence of a gubernatorial review process. The disappointment of the Florida electorate with Governor Rick Scott Governor Rick Scott doesn't only appear to be progressively loathed, he is, in fact, progressively getting disliked. As called attention to by Marc Capato in his â€Å"Poll shows increment in Florida voters' aversion for Gov. Rick Scott† distributed by Times/Herald, this has been uncovered by latest review done by Quinnipiac University that included 1,499 enlisted voters in Florida. The survey results demonstrated that 48% of voters objected his work as a senator; this was twofold the figure in a survey done in February, 2011 by a similar college. The individuals who affirmed his work were simply 35%, indicating a decrease in the rate (Capato). Notwithstanding, the Governor in reacting to the survey results expressed that, he was not stressed over the survey results; rather he was worried about tackling issues (Capato). There are shifted reasons that have added to Scott’s prevalence decrease, there incorporate economy that isn't progressing nicely, with 60% expressing their disappointment on how he is running the economy, Power battles with different lawmaking bodies from his Republican gathering, An as of late revived left that profoundly detests him, a nd a hard-right administering approach he utilized that seems to irritate Democrats and free votes (Capato). Another significant purpose behind his declining notoriety is his proposed spending plan. In this spending Scott proposes profound cuts in financing and a cutback of 6,000 occupations of state laborers (Capato). In deed, the outcomes from the Quinnipiac University show that over 53% of voters contradict the proposed financial plan. This is on the grounds that they see it has unjustifiable to them, just 37% support the spending measures (Brown 2). 33% of voters affirm the way wherein the Governor has dealt with the spending issue, however 55% don't (Capato). The outcomes further show that more that half voters feel that the cuts are extremely intense, 29% feel the spending plan is â€Å"okay†, and just 16% feel more cuts ought to be taken (Capato). Notwithstanding, there is a general understanding that the state’s spending should be readdressed as 95% of voters s aid (Brown 2). As indicated by Brown (2) the numbers on apparent reasonableness of the spending plan proposed by the Governor is basic. He takes note of that, when voters by almost 2-1 express that his Scott’s way to deal with the spending plan is out of line to them, at that point that is a major political admonition pointer for the Governor (Brown 2). In deed Brown completely cautions that â€Å"when voters feel that they are being dealt with unreasonably, they appear to respond negatively† (Brown 2). Disregarding the new property protection law that was marked by Scott, voters attest that getting protection today is more trouble and all the more exorbitant. Appropriately, 63% of the surveyed voters

10 Tips on How to Write a Professional Email

10 Tips on How to Write a Professional Email Notwithstanding the fame of messaging and internet based life, email remains the most widely recognized type of composed correspondence in the business world-and the most normally abused. Too frequently, email messages snap, snarl, and bark-as though being brief implied that you needed to sound bossy. Not really. Consider this email message as of late sent to all staff individuals on an enormous college grounds: The time has come to restore your workforce/staff stopping decals. New decals are required by Nov. 1. Leaving Rules and Regulations necessitate that all vehicles driven nearby should show the present decal. Slapping a Hi! before this message doesnt take care of the issue. It just includes a bogus demeanor of friendliness. Rather, consider how much more pleasant and shorter-and most likely progressively powerful the email would be in the event that we just included a please and tended to the peruser legitimately: Kindly restore your personnel/staff stopping decals by November 1. Obviously, if the writer of the email had genuinely remembered perusers, they may have incorporated another valuable goody: an intimation with regards to how and where to restore the decals. Utilizing the email about the stopping decals for instance, take a stab at joining these tips into your own composition for better, more clear, increasingly viable messages: Continuously fill in the title with a point that implies something to your peruser. Not Decals or Important! yet, Deadline for New Parking Decals.Put your primary concern in the initial sentence. Most perusers wont stay for an astonishment ending.Never start a message with an ambiguous This-as in This should be finished by 5:00. Continuously determine what youre composing about.Dont utilize ALL CAPITALS (no yelling!), or every single lowercase letter either (except if youre the artist E. E. Cummings).As a general standard, PLZ maintain a strategic distance from textspeak (shortened forms and abbreviations): You might be ROFLOL (moving on the floor roaring with laughter), yet your peruser might be left pondering WUWT (whats up with that).Be brief and amenable. In the event that your message runs longer than a few short passages, consider (a) decreasing the message or (b) giving a connection. In any case, regardless, dont snap, snarl, or bark.Remember to state please and much obliged. What's more, would not joke about this. For instance, Thank you for understanding why evening breaks have been dispensed with is snobby and frivolous. Its not affable. Include a mark obstruct with proper contact data (much of the time, your name, place of work, and telephone number, alongside a legitimate disclaimer whenever required by your organization). Do you have to mess the mark obstruct with a smart citation and fine art? Likely not.Edit and edit before hitting send. You may think youre too occupied to even think about sweating the little stuff, however sadly, your peruser may think youre an indiscreet dolt.Finally, answer quickly to genuine messages. In the event that you need over 24 hours to gather data or settle on a choice, send a concise reaction clarifying the postponement.

B2B – Product Marketing Plan.rev1

The vison of the fleece fabricating segment of Australia is to grow its fare deals to developing markets in the ASEAN district. Developing markets are those of the creating nations with popularity on essential crude materials for dress assembling and different ventures identified with employments of fiber, in addition to the result items from a similar classification of industry. Developing markets possibly from creating nations, as opposed to exceptionally created ones. The mission is enter these developing markets, make a solid footing with the correct contact systems and get long haul contracts for fleece, fleece items and its ancillaries.The primary goal is to expand the fare incomes of the fleece fabricating segment, in this way adding to the GNP and GDP of Australia to improve per capita pay and to create greater work. The particular targets are: a. To discover the exchange channels of developing markets the ASEAN Region and infiltrate these business sectors. b. To build up the correct technique how to infiltrate these developing markets and set up long haul exchanging exercises with the equivalent. c. To inquire about more employments of the fleece fiber as crude material, regardless of whether in mass crude fleece or string fleece or texture wool.d. To include remote speculators as partners in the improvement of fleece fiber for new employments of fleece and its culmination items referenced in this. e. To make sure about a caught showcase in return for remote ventures. 1. 1 Sales Objectives The general deals objective is to build up a proceeding and developing interest for trade deals of fleece, wollen items, presumably new created items out of fleece, and culmination fleece items, e. g. sheep meat or lambchops and sheep calfskin. The expansion in deals may not really mean increment in profitablity in the short term.It is the drawn out target that is the primary concentration all together for deals projections to be drawn effortlessly and followed. Long haul projections must be done if venture promoting agreements can likewise be drawn with the plausible purchaser of the made items. It would be a speculation loaded task, with the end goal that the requirement for venture can be explicitly pinpointed regarding apparatus, work, working capital and undertaking costs or, so as to discover the particular employments of the capital investment.From there, the Return on Investment (ROI) or the Return to Equity (ROE) can be determined and esteemed to be practical or doable to Autralian inclinations. Along these lines, the business target considers the drawn out practicality of the undertaking and figures out what level of value the Australians ought to permit any outside financial specialist to come in and intercede in the fleece business. 1. 2 Product Positioning There is not a viable alternative for a great, ideal valued item and predictable flexibly and these variables must be the situation of the products.In request to expand further t he market position, it is ideal to identify the items that may originate from the fleece business, clarify the charecteristics of the items and dissect where it uses would be. Consequently, there could be innovative work (R&D) to improve the item so that there is esteem included when it is sold. a. Mass Raw Wool Fibers Bulk crude fleece filaments possibly characterized. The standard procedure begins with sheering, washing, dying, drying and bailing. At that point there can be characterizing, maybe, into which group originates from an increasingly develop or more youthful crowd of sheeps or known sheep varieties.Another way, which would require R&D, is to discover how to isolate the long filaments from the short strands. At that point the technique for grouping can be into long and short filaments. Hardware can be intended to seggregate which filaments are long or short. Both sort of filaments can be wooven into texture with various characterics and long strands can be an add ed substance in matress creation for vehicle seats. In Europe vehicle seats have natural strands an alternative for froth pads, and is now a guideline. Froth pads produce harmful exhaust when it consumes if there should be an occurrence of accidents.b. Fleece Thread If and when fleece can be seggregated into long and short strands, there can likewise be two sorts of strings delivered. Short strands will create string with short flexibility in light of the fact that the turning procedure delivers an all the more fine finished string. Long filaments will create string that is increasingly flexible, which is wool’s trademark and has been acknowledged by clients of this string. Fine string from fleece can turn into another item which can be contrasted with cotton string. c. Fleece Fabric When wooven into material, long strands make the material stretchable.The stretchable texture is generally utilized for protection, for example, sweaters and covers, the primary completed results of fleece. Albeit standard woolen texture is acceptable protection, it has a charcteristic extremely unmistakable from cotton fabric. The fleece filaments are somewhat abbrasive and may initiate hypersensitivity or irritation to human skin and is commonly heavier than cotton texture. Ought to there be fine string from short strands wooven into fleece texture, at that point the result would be fine and lighter fabric, which can turn into an adaptable material in sewing clothes.Definitely, this scope of item improvement needs R&D. d. Sheep Leather Sheep skin can be prepared into cowhide to make elastic shoes. China and Korea are turning out to be top makers of elastic shoes. Those nations could be the objective market of sheep calfskin in the event that it were tanned in Autralia. Along these lines, tanning sheep cowhide can turn into a side assembling worry of the fleece business. Dairy animals and kangaroo cowhide from Australia is as of now known on the planet showcase. It wou ld not hurt if the sheep calfskin market can be developed.Rather than arranging sheep skin as manure, it might be made into cowhide. e. Sheep Meat or Lamb Chops It is just intelligent that there is consistency in the flexibly of crude materials for fleece. Subsequently, in reverse joining to create fleece turns into an inescapable factor when there are plans to extend the fleece showcase. In this manner, sheep creation, which Australia is likewise known for, turns into a coordinated part of the fleece send out industry. Sheep are proliferous and duplicate like goats and there will be overflow of sheep regarding number of heads if the fleece business were to expand.Lamb meat can get one of the subordinate results of the fleece business and limit of handling plants for new or even canned sheep meat must be prepared when the market is created. 1. 3 Product Objectives It is ideal to identify again what are the plausible fare items got from the fleece business: short fiber crude fleece, long fiber crude fleece, fine fleece string, standard fleece string, sheep cleaves/sheepmeat, and sheep cowhide. The general item objective is to improve the advancement of items produced from the fleece area. This segment begins from the animals creation of sheep, an essential piece of agriculture.Wool must not be the main item that can got from this industry. Regarding short and long strands that need R&D, new hardware may must be gotten. This should be possible by requesting that outside financial specialists direct the examination, plan and create the hardware themselves. The machines required would relate to processing machines, weaving, and sewing machines. In the event that China were the decision of association, it has just built up its apparatuses for weaving and sewing. It might be the processing machine that ought to be planned so as to isolate the short and long filaments before processing into threads.The strings might be additionally prepared with the goal that the surface could be near or equivalent to silk, a notable Chinese texture. Regardless, development should come in with the goal that the finished results turns into another one and will most likely have its place in the design world, which is extremely enormous business. Should this occur, there will be curiousity from European purchasers, subsequently making a damand, as the capital of style is in Paris, France. This would extend the assembling segment in this manner producing greater work for the locales.In expressions of sheep meat, impact freezing and cold storerooms overhaul might be required for the extension of the business. Outside financial specialists may likewise be welcomed. A similar convention might be applied to sheep calfskin producing. The apparatuses securing can be haggled to such an extent that it might come as an advance, whereby, some portion of the installments would be as fabricated items the hardware would produce. When all is said in done, the heading of this worry is towards growing the assembling segment in preparing, increment business, create send out incomes and outside investments.1. 4 Pricing Objectives General market reemergence, much the same as estimating, is a craftsmanship. The general valuing objective is to hold ideal benefits that would profit the business in the long haul. The volume of business may repay the ideal overall revenues when the interest for the made items increment. The estimating ought to be by and large lower than rivalry. This would pull in remote makers to purchase the fleece and woolen items. With regards to calfskin, the estimating ought to be practically identical to hoard cowhide (e.. g. Quiet Puppies use hoard leather).Only when in the event that it turns into a prevailing fashion and is profoundly looked for, should sheep cowhide costs be expanded to a most extreme level. Shoes are a fundamental need as well. Cowhide packs and gear may not be a need and design patterns may direct the interest for t hese calfskin items. With regards to sheep meat, costs ought to go lower than that of pork or chicken costs as modest food is an indication of progress. By and large, item advancement ought to be perhaps the biggest factor in item targets. Wool has been a texture since the medieval ages and is outdated.Sheep meat has been a staple food to certain nations however has not been advanced as a low cholesterol meat. Sheep skin could have been utilized uniquely as protection or unpleasant garments during the medieval ages likewise, and not as cowhide for shoes and packs. Development is changing the item with the goal that when it is utilized or devoured, it is new and pull in

Watch out for random advice - UGA Undergraduate Admissions

Watch out for random advice - UGA Undergraduate Admissions Watch out for random advice I am back from my vacation and am well tanned and overfed. There is something wonderful about a long vacation that allows for time to relax, read, and think about things (usually it focused on food or napping, but occasionally it was about more serious issues). I was also able to do some reading, and I was finally able to finish Fooled by Randomness by Nassim Taleb. It was not an easy book to read, but it opened up my mind to a number of different ideas. One great quote from the book was about an idea from the philosopher Wittgenstein called Wittgensteins ruler. Unless you have confidence in the rulers reliability, if you use use a ruler to measure a table you may also be using the table to measure the ruler. Admissions counselors all over are always asked about a students chances of admission based upon limited data, such as a test score or a GPA, and at UGA, the usual answer is a non-answer. Without looking at both the individual student and the applicant pool as a whole, we have no idea what the chances would be for admission. But in PTO meetings, college discussion web sites, high schools and private counselor sessions across the nation, random individuals are more than happy to voice their thoughts on a students chances of admission. Look back at Wittgensteins ruler and tell me, are students learning more about themselves, or about the reliability (or lack of) of the person giving the advice. My suggestion, ignore the advice and work directly with the colleges to which you are considering applying. Colleges are generally very open as to what they look at for admissions, and the level of importance of different variables. For a good look at an example of some of the highs and lows of people getting and giving advice, take a look at a recent NY Times article about independent college counselors. It is a very revealing story! Please remember that when you hear advice, measure both the advice and (more importantly!) the advice-giver!

First Amendment Rights and Access to Opinions - Free Essay Example

In 1972, five burglars were arrested following the break-in of the Democratic National Convention (DNC) headquarters at the Watergate office complex in Washington D.C. Uncovered, was a plan concocted by members of the official organization of President Nixons campaign to photograph campaign documents and install listening devices in telephones. Taped recordings of President Nixons conversations revealed the President had clearly obstructed justice by directing members of the CIA to halt the FBI investigation into the DNC break-in. Facing certain impeachment and conviction, President Nixon resigned the Presidency and subsequently pardoned by his successor, Gerald Ford. The Watergate scandal created a growing concern in the American public and Congress about the ability of the government to spy on its own citizens. During the course of the Senate Watergate Committee investigation, past executive branch direction of national intelligence agencies to carry out constitutionally questionable domestic security operations came to light. Additionally, a New York Times article published by Seymour Hersh claimed that the CIA had been spying on anti-war activists for more than a decade, violating the agencies charter. In response to these revelations, Congress launched the Church Committee in the Senate and the Pike Committee in the House to conduct an investigation into the nations secret agencies and programs. The Church Committee investigated and identified a wide range of intelligence abuses by federal agencies, including the CIA, FBI, Internal Revenue Service, and National Security Agency. In the course of their work, investigators identified programs that had never before been known to the American public, including NSAs Projects SHAMROCK and MINARET, programs which monitored wire communications to and from the United States and shared some of that data with other intelligence agencies. Committee staff researched the FBIs long-running program of covert action designed to disrupt and discredit the activities of groups and individuals deemed a threat to the social order, known as COINTELPRO. The FBI included among the programs many targets organizations such as the Southern Christian Leadership Conference, the anti-Vietnam War movement, and individuals such as Martin Luther King, Jr., as well as local, state, and federal elected officials. Investigators determined that, beginning with P resident Franklin Roosevelts administration and continuing through the early 1970s, intelligence excesses, at home and abroad, were not the product of any single party, administration, or man, but had developed as America rose to a become a superpower during a global Cold War. The committee observed that there is no inherent constitutional authority for the President or any intelligence agency to violate the law, and recommended strengthening oversight of intelligence activities. The Church Committees investigative work led to reform efforts throughout the intelligence community. Congress approved legislation to provide for greater checks and balances of the intelligence community. In 1976 the Senate approvedSenate Resolution 400, establishing theSenate Select Committee on Intelligence, to provide vigilant legislative oversight over the intelligence activities of the United States to assure that such activities are in conformity with the Constitution and laws of the United States. I n 1978 Congress approved and President Jimmy Carter signed into law the Foreign Intelligence Surveillance Act (FISA), requiring the executive branch to request warrants for wiretapping and surveillance purposes from a newly formed FISA Court. The Foreign Intelligence Surveillance Act authorizes electronic and physical surveillance of foreign powers and agents of foreign powers for the purpose of collecting foreign intelligence information. FISA was originally enacted to regulate the collection of foreign intelligence information within the United States. The USA Patriot Act was passed by Congress as a response to the terrorist attacks of September 11, 2001 and allowed federal officials greater authority in tracking and intercepting communications, both for purposes of law enforcement and foreign intelligence gathering. Until 2001, FISA permitted electronic and physical surveillance of foreign powers and agents of foreign powers if foreign intelligence collection was the primary purpose of the activity. In 2001, the USA PATRIOT Act amended FISA to allow searches if foreign intelligence collection was a significant purpose. In 2005 the New York Times published an article revealing the Bush administrations warrantless domestic wiretapping surveillance program dating back to 2002. President Bush secretly authorized the National Security Agency to eavesdrop on Americans and others inside the United States to search for evidence of terrorist activity without the court-approved warrants ordinarily required for domestic spying . . . . Under a presidential order . . . the intelligence agency has monitored the international telephone calls and international e-mail messages of hundreds, perhaps thousands, of people inside the United States without warrants . . . . The agency . . . still seeks warrants to monitor entirely domestic communications. The President relied on his Article II authority to claim a basis for not following the FISA warrant requirements but following the Supreme Court Decision in Hamdan v. Rumsfeld the argument became shaky. In response to this, the Bush Administration introduced the Protect America Act of 2007 to amend the FISA. The act was passed in August 2007 with a 6-month sunset provision and a number of significant changes to the original law including warrant requirements for foreign communications. Shortly after the expiration of the Protect America Act, Congress passed the FISA Amendments Act of 2008 which was similar to but not the same as the Protect America Act of 2007. In 2013, NSA contractor Edward Snowden leaked an estimated 1.7 million classified intelligence files which revealed bulk data collection programs by the government. In response to the leaks, the government introduced the USA Freedom Act which restored in modified form several provisions of the Patriot Act and also imposed restrictions on bulk data collection under section 215 of the Patriot Act. Additionally, act mandates that theFISA courtrelease novel interpretations of the law, which thereby setsprecedentand thereby makes up the body of FISA courtcommon law, as both legal authority for deciding subsequent cases, and for guidance parameters for allowing or restricting surveillance conduct. However, the Act is not clear as to whether or not it mandates retroactive disclosure of decisions prior to passage of the Act in 2015. In January of 2018, President Trumped signed the FISA Amendments Reauthorization Act of 2017. The act extended FISA section 702 authorities until 2023 with some significant changes. The act includes a number of reporting requirements, the publication of minimization procedures that apply to the handling of U.S. person information collected under Section 702, and it addresses issues concerning upstream about collection†information gathered from Internet communications infrastructure based on the mention of a certain selector, such as an email address, within the communication itself (as distinguished from communications collected because they are to or from a selector). Finally, in the most recent development with respect to the FISA court is the widely discussed FISA warrant targeting former foreign-policy adviser to Donald Trumps presidential campaign, Carter Page. In February 2018, House intelligence committee Chairman Rep. Devin Nunes released a memo claiming that the FBI m isled the FISA Court about Christopher Steele, the former British secret agent who compiled the dossier on Trump-Russia ties and who was a source of information in the FISA applications on Page. The main complaint in the Nunes memo was that the FISA applications did not disclose or reference the role of the DNC, Clinton campaign, or any party/campaign in funding Steeles efforts, even though the political origins of the Steele dossier were then known to senior and FBI officials. In response to the Nunes memo, the Democrats on the committee released their own memo. That memo quoted from parts of the FISA applications, including a footnote in which the FBI explained that Steele was hired to conduct research regarding Candidate #1, Donald Trump, and Trumps ties to Russia, and that the man who hired him was likely looking for information that could be used to discredit [Trumps] campaign. On July 21, 2018 the FBI released a heavily redacted copy of the 412 page FISA application seeking a warrant against Carter Page. Regardless of whether the allegations of impropriety by the FBI are determined to be true, these documents raise serious concerns about the level of oversight the FISA courts work under. Structure of the Act and Court The Foreign Intelligence Surveillance Court sits in Washington D.C., and is composed of eleven federal district court judges who are designated by the Chief Justice of the United States. Each judge serves for a maximum of seven years and their terms are staggered to ensure continuity on the Court. By statute, the judges must be drawn from at least seven of the United States judicial circuits, and three of the judges must reside within 20 miles of the District of Columbia. Judges typically sit for one week at a time, on a rotating basis. Pursuant to FISA, the Court entertains applications submitted by the United States Government for approval of electronic surveillance, physical search, and other investigative actions for foreign intelligence purposes. Most of the Courts work is conducted ex parte as required by statute, and due to the need to protect classified national security information. The USA Freedom Act requires designation of at least five people who may serve asamicus curiae: individuals are appointed to inform the court about specific legal or technical issues in certain cases.In cases involving a novel or significant interpretation of the law, one of the designated amicus curiae shall be appointed to assist the court unless the court gives a reason that it would not be appropriate. In other cases, the court may appoint an individual or organization to serve as amicus curiae or file an amicus brief. Since the passage of USA Freedom Act,amicushave counseled the Court on questions such as the governments ability toretain call metadataafter the effective date of the Act and the governments authority touse pen registerswhen communications content may be collected. The FISC operations are classified by default due to the sensitive nature of the issues addressed, but the court has become increasingly visible to the public as the Director of National Intelligence has begun publicly releasing FISC opinions and Congress has issued transparency mandates in the USA FREEDOM Act. However, records from FISC hearings are still not typically made available, even to petitioners challenging surveillance orders under the court rules. FISC historically had discretion to publish its opinions, and in some cases it did so. However, Congress imposed new transparency requirements in the USA Freedom Act, seeking to make the court more publicly accountable. The Director of National Intelligence now must review each FISC order or opinion to determine whether it includes a significant construction or interpretation of any provision of law. Any orders that do must be made public to greatest extent practicable, although when necessary to protect national security it may be permissible for the ODNI to release a summary of the decision. Congress created the Foreign Intelligence Surveillance Court of Review (FISCR) in 1978 to hear appeals from applications denied by FISC. This court is made up of three judges, appointed by the Chief Justice, from U.S. district or appellate courts and serving for seven years. The FISCR has jurisdiction to review the denial of any application under FISA by the FISC. The FISCRs review of the FISCs denial of an application for surveillance is limited. After a motion of the United States to transmit the FISCs record, the FISCR may either affirm or reverse the FISC judges decision. If the FISCR determines that the application was properly denied, it must provide for the record a written statement of each reason for its decision. Under the USA Freedom Act, the FISC is required to certify for review by the FISCR questions of law in the orders it has issued that affect the need for uniformity or where consideration would serve the interests of justice. In response, the FISCR may give binding instructions to the FISC or require the FISC send the complete record to the FISCR for it to decide the entire matter itself. Finally, the FISCR can also review the FISCs decisions on third party challenges to orders under FISA (e.g. an order for an individual to produce tangible things or a connected gag order, and electronic service providers directed to assist the government). The Supreme Court has statutory jurisdiction to review FISC opinions under certain circumstances. The Court may review on a Writ of Certiorari filed by the United States any decision of the FISCR affirming the denial of a government application to the FISC. Additionally, the FISCR certify any question of law . . . as to which instructions are desired, and the Supreme Court may then give binding instructions to the FISCR or require the FISCR send the complete record up and decide the entire matter itself. The Court may also review FISCR decisions on a third party challenges. Foreign Intelligence Information (FII) is information that relates to U.S. ability to protect against possible hostile acts of a foreign power or an agent of a foreign power, sabotage or terrorism by a foreign power or agent, and clandestine intelligence activities by a foreign power or agent. FII includes information with respect to a foreign power or foreign territory that relates to the national defense, national security, or conduct of foreign affairs of the United States. If the intended surveillance target is a U.S. person, the information must instead be necessary to protect against hostile acts, sabotage, or terrorism, or U.S. national defense, national security, or foreign affairs. Under FISA, the Justice Department reviews applications for counterintelligence warrants by agencies before submitting them to the FISC. The Attorney General must personally approve each final FISA application. The application must contain, among other things: a statement of reasons to believe that the target of the surveillance is a foreign power or agent of a foreign power; a certification from a high-ranking executive branch official stating that the information sought is deemed to beforeign intelligence information, and that the information sought cannot reasonably be obtained by normal investigative techniques; statements regarding all previous applications involving the target; detailed description of the nature of the information sought and of the type of communication or activities to be subject to the surveillance; the length of time surveillance is required; whether physical entry into a premises is necessary, and proposed procedures tominimizethe acquisition, use, and rete ntion of information concerning nonconsenting U.S. persons. For U.S. persons, the FISC judge must find probable cause that one of four conditions has been met: (1) the target knowingly engages in clandestine intelligence activities on behalf of a foreign power which may involve a criminal law violation; (2) the target knowingly engages in other secret intelligence activities on behalf of a foreign power under the direction of an intelligence network and his activities involve or are about to involve criminal violations; (3) the target knowingly engages in sabotage or international terrorism or is preparing for such activities; or (4) the target knowingly aids or abets another who acts in one of the above ways. When the FISC grants applications for surveillance it issues a primary order finding that all the FISA requirements were met. The FISC also issues a secondary order providing that upon request of the applicant, a specified third party must furnish the applicant forthwith with all information, facilities, or technical assistance necessar y to accomplish the search in such a manner as will protect its secrecy and produce a minimum of interference. Assisting third parties, such as telephone and Internet service providers, are compensated for any assistance rendered, and can keep certain records under security procedures adopted by the government. Section 702 of Foreign Intelligence Surveillance Act was added as an amendment in 2008. It authorizesthe collection, use, and dissemination of electronic communications contentstored by U.S. internet service providers (such as Google, Facebook, and Microsoft) or traveling across the internets backbone (with the compelled assistance of U.S. telecom providers such as ATT and Verizon). It allows intelligence agencies to collect foreign intelligence from non-Americans located outside the United States. But under the surveillance authority set up under this section, many Americans also have their communications swept up by surveillance programs operated by the FBI and NSA. Unlike the four traditional FISA surveillance activities, the surveillance programs authorized under Section 702 of the FISA Amendments Act of 2008 do not involve FISC oversight of individual surveillance orders. The Attorney General and the Director of National Intelligence are allowed to jointly authorize the targetin g of persons reasonably believed to be located outside the United States to acquire foreign intelligence information without adhering to traditional FISA rules. Instead, the FISC reviews the targeting and minimization procedures adopted by the government and determines whether they comport with the statutory restrictions and the Fourth Amendment. The FISC also reviews the certification submitted by the government attesting that a significant purpose of the acquisition is to obtain foreign intelligence information, providing copies of the targeting and minimization procedures, and attesting that acquisition will comply with certain statutory limitations.The statutory limitations on acquisition are that it: (1) may not intentionally target any person known at the time of acquisition to be located in the United States; (2) may not intentionally target a person reasonably believed to be located outside the United States if the purpose of such acquisition is to target a particular, known person reasonably believed to be in the United States; (3) may not intentionally target a United States person reasonably believed to be located outside the Unit ed States; (4) may not intentionally acquire any communication as to which the sender and all intended recipients are known at the time of the acquisition to be located in the United States; and (5) shall be conducted in a manner consistent with the Fourth Amendment to the Constitution of