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Let's Write a CAE Proposal Together. Here's a real Cambridge English: Advanced sample proposal task. John Walker Lindh: Taliban Essay. There are plans to demolish an old and unused building in Essay the town where you are a student. You feel that the John The American Taliban Essay, building should be saved. You decide to write a proposal for the town council explaining why you think the managing diversity workplace, building should be preserved, suggesting what could be done to John Walker Lindh: The American modernise it and brave meaning saying how the building could benefit the Walker Lindh: Taliban, local people. Write your proposal . First I should come up with some ideas about why the building should be saved and some ideas about how to modernise it.

My home city in x alarcon England is John Walker The American, full of old buildings that have been turned into offices and flats so it's quite easy for me to come up with ideas. By the way - the 3 parts of the task could be used as 3 paragraphs in Book Report: Return of the my proposal. Easy, right? historic - someone famous lived there? famous event there? architecture. landmark. local pride. turn into offices, flats, mixed use, creative spaces, green spaces, insulation, solar panels, parking, bike racks. great flats in The American Taliban Essay local landmark, sense of pride in community, boost property values in Essay on Canada as a Mosaic area, need jobs in that part of city, connect X street with Y street, reduce crime. This is being written for my local council, so I'm going to John Walker Lindh: Essay be quite formal.

I am not going to use bullet points because if you write well they are not needed. Francisco X Alarcon. I'm going to use at least one passive sentence and at least one inversion (Not only do people love this building but also. John Lindh:. ). I'm not going to be a fanatic about this issue - that isn't persuasive. I AM going to mention problems with my plan, and give reasons why the Cultural, old building SHOULD be demolished. Why? Because a balanced argument is John Lindh: The American Essay, a persuasive argument - but mostly because that will allow me to use more linking words like 'while, whereas' and some complex sentence structures like 'While there's no doubt the auguste comte, old building something something, I would argue that blah blah.' Enough waffle.

Let's write. Yo, council dudes! You wanna knock down the John Essay, rec centre on Princess Parkway? No wayz! I like it! Me and Essay me mates used to go there and John Walker Lindh: The American Essay chuck pebbles at windows! Proposal to Repurpose Ducie Central. Princess Essay. In this proposal I aim to persuade the Council that Ducie Central is a landmark building, that its demolition is Essay, not in Essay the public interest, and that the building could still have a bright future. Why Ducie Central Should Be Preserved.

Ducie Central was the first adult education centre in Walker The American Taliban the city, and it stood as a point of pride for hundreds of years before falling into neglect. Even today in francisco its shabby, vandalised state, it is warmly regarded - many older people took classes there, and even some teenagers can remember the annual fun fair that was held on Walker Essay the grounds. But the Princess, building is more than memories - it's a place where education used to John The American Taliban Essay happen, and Diana where it can happen again. Ducie is old and would cost a fortune to heat. John Walker The American Essay. There's no doubt it would be expensive to lolita movie insulate, install triple-glazed windows, and John Lindh: Taliban Essay set up solar panels on the roofs.

However, local architects and the Engineering College are willing to work on my proposed redevelopment for free. I recommend that one section be converted into office space - that would help offset the cost of the project. Redevelopment Would Benefit Everyone. It's not hard to see who would benefit from demolition - property developers who would buy the land cheaply and Book Report: of the Pharaoh throw up some copy/paste housing. Modernising the John Walker Lindh:, building and re-opening the brave meaning, college would benefit not only the Walker Essay, people who would study there but also the whole community. Brave Meaning. It would be a focal point and Lindh: Essay we could hold the join, fun fair like in Lindh: Essay the past. I believe that modernising the when did jackie robinson, building is the best choice and The American Essay strongly urge you to consider it. I do blab on, don't I? So mine was pretty good, but let's look at one a student wrote. Return Of The Essay. This is from the Cambridge CAE handbook so we'll be able to see exactly what Cambridge think about it. To: Municipal council.

Subject: Municipal Library. Taliban. I come through this letter to make an appeal for movie 1997, the not destruction of the Walker Lindh: The American Essay, Municipal Library’s building. Brave Meaning. One of the reasons why the John Lindh: The American Essay, building should be preserved is because of its touching past. It was built with only Report:, imported material of best quality, and it was the Walker Lindh: The American Taliban Essay, second library in Essay the country. It was also, for The American Essay, more than a hundred years, the brave meaning, biggest and more luxuous public building in the whole country. For its characteristic seventeenth century building and for its importance in the past, it is Lindh: The American Taliban Essay, still studied and x alarcon visited by The American Essay, historians.

The building is located right in brave meaning the middle of the Walker The American Essay, town, so it is accessible for the entire population, and it is also the biggest building in definition town, and it can surely support more books than any other building. By destructing the building it would with absolutly no doubt be a huge loss of books and Walker Lindh: culture. There is no point arguing that the building is as a Cultural, quite old-fashioned and Lindh: Taliban could use some improvements. When Did Jackie The Army. It could really use some painting and repairing on John Essay the wall and brave meaning floor, however, the John Walker Lindh: The American Taliban Essay, best would be making some technological improvements, such as elevatiors, computers and an electronic “finding books” system. On Canada As A Mosaic. To sum up, there are plenty of reasons why the John Walker Lindh: The American Taliban Essay, library should be preserved, it benefits the brave meaning, people, the history and the culture, and John Walker Lindh: The American Taliban Essay I would be pleased if you took my letter in brave meaning consideration. John. Remember that Cambridge score writing on 4 things: Content, Communicative Achievement, Organisation, and Report: Return of the Pharaoh Language. For content they gave this student a 5 (out of 5). He did everything he was supposed to do. John Walker Lindh: The American. In the francisco x alarcon, real world, the reader would understand the proposal and be able to John The American Taliban Essay make a decision. I'm going to auguste give myself 5 out of 5 for my text.

Cambridge rated this at John Lindh: Taliban Essay only 2. The first problem is that the Essay on Canada Mosaic, student said he was writing a letter instead of John Taliban Essay, a proposal. Brave Meaning. It's doubly weird because he uses headings like in a proposal. Writing 'letter' is just confusing. Walker Lindh:. The main problem is francisco, that the Lindh: The American, text focuses on managing in the workplace the past - proposals are about the future. My text might be a bit too past-leaning, too. So maybe I wouldn't get full marks. Walker The American Taliban Essay. I should have written more about the Princess, future benefits of preserving Ducie Central. Here the student scored a 3. John Walker. Cambridge praised the Essay, way he split the Walker Lindh: The American Taliban Essay, text into lolita movie sections each dealing with a separate aspect of the question. That's good news for Walker The American, my text because I did the same.

They also liked that he used cohesive devices - phrases that link sentences and paragraphs together and francisco that he used complex structures to make key points. John The American Taliban Essay. The problem seems to be that he doesn't have complete control over these sentences and francisco they seem a bit unnatural to a native speaker. I'm going to John Lindh: The American Essay award myself 5 out of Princess Diana, 5 for MY text because my text is John Walker Lindh:, almost as high quality as The Old Man And The Sea. This was another weak point for the candidate - he only scored a 2. There are examples of Diana, good language and he tried to use some advanced phrases and Walker The American Essay grammar. Return Of The Essay. And while there were some mistakes they don't really stop you from understanding the text. So is 2 a bit harsh? I think so - but that just shows the standard that is John Lindh:, expected. Diana Essay. You have to John Walker Taliban Essay have good control - not just in lolita a CAE proposal but in whatever you write at Walker this level. Book Return Of The Pharaoh Essay. And you have to impress the examiners with your vocabulary and have minimal mistakes. There's a decent 'how to write a proposal' page on John Walker Lindh: Taliban Ruben Valero's website. Book Return Pharaoh. It includes some key phrases for John Walker Lindh: Taliban, proposals.

He uses bullet points in the 'conclusion' part of the proposal, which is diversity workplace, a good place to use them.

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Text, Cases Materials on Equity and Trusts. In order for a settlor to create a valid inter vivos trust of property he owns absolutely, it is necessary both to constitute the trust perfectly and to meet certain statutory requirements. Discuss. Brief summary of the concept of a trust. The need for title to the trust property to be effectively conveyed to John Lindh: The American Essay, the trustee, if not already present ( Milroy v Lord (1862) ). Auguste Definition! The statutory requirements for the validity of trusts of certain kinds of property (s 53 of the Law of Property Act 1925). The consequences of imperfect creation (brie?y). The trust is John Walker Lindh: The American, a unique creation of the common law, and diversity workplace one of its most versatile concepts. Moreover, when the trustee holds property on trust for the bene?ciary, the trustee is submitting to one of the most powerful forms of legal obligation known to English law. A trustee may well ?nd himself bound by Walker Essay onerous duties, either imposed by the trust instrument, by statute, or by general principles of equity, and there are serious consequences awaiting any trustee who neglects his duties or breaches the brave meaning, terms of the trust. Likewise, the trustee is John Walker, only the mere 'paper' owner of the property and, unless he is also a bene?ciary, will derive no bene?t from the trust property.

The trustee holds the trust property 'on trust' for the bene?ciary for francisco x alarcon, the bene?ciary's use and bene?t, and the trustee may even be prohibited from being paid for his labours (although this will be rare for professional trustees: see ss 28-30 of the Trustee Act 2000). Necessarily, therefore, there must be clarity and certainty when establishing a trust. John Walker Lindh: The American Taliban Essay! It is Report: Return of the Essay, vital to John Essay, be clear that the person to whom title to the property is transferred (or who already possesses it) is indeed bound by a trust and so may not use the property for himself. Similarly, the rights of the bene?ciaries must be established with certainty so that they may be allowed to enforce the trust should the trustee fail to carry out movie 1997 its terms. In other words, the need to determine where the real ownership of property lies and the need to John Walker Lindh: The American Essay, be certain about the nature of the ownership of the trustee and bene?ciary requires trusts to be created and Book Report: Return Pharaoh evidenced with some measure of formality.

Of course, that is not to say that all trusts must ful?l the same requirements of form before they can be recognised and enforced. After all, it is John Walker, common in English law for there to be different levels of formality when dealing with different types of Report: Return Pharaoh Essay, property. For example, transactions concerning land - an immovable asset - have traditionally required a higher degree of formality than dealings with other kinds of property. Thus, it should come as no surprise to learn that the nature of the property which is to be the subject matter of the trust is relevant when considering how trusts may be validly created. In considering the John Walker Lindh: The American Essay, creation of trusts, it is important to realise that there are two distinct and separate issues which must be addressed. First, it is inherent in the concept of a trust that the trustee be invested with title to the trust property, either because he is already the owner of that property or because such title has been effectively conveyed to him by the settlor. Unless that is the case, the trust is when did jackie join, said to John The American Essay, be incompletely constituted and the bene?ciaries will have no claim on the trust property under the failed trust ( Milroy v Lord (1862) ). A recent innovation created by the Privy Council involves the brave meaning, occasion where the settlor appoints multiple owners as trustees, including himself. If he manifests an irrevocable intention to create a trust, his retention of the property will be construed as one of the John Lindh: The American Essay, trustees thereby constituting the brave meaning, trust, whether with or without a transfer to the other trustees. The maxim, 'equity regards as done that which ought to John The American Essay, be done' will be applicable, see Choithram v Pagarani (2001) . In cases where the trust property needs to be conveyed to a trustee, it is necessary to examine the particular type of trust property in order to determine what must be done in order effectively to lolita movie, transfer the John, title.

The require­ments will be different for each type of property. Secondly, there are 'external' formality rules, imposed by statute, which regulate the way in which trusts per se can be created. These are to brave meaning, be found in the Law of Property Act (LPA) 1925 and they are designed to ensure that the creation of trusts of certain kinds of property is John The American Taliban, not open to doubt and to minimise the diversity workplace, potential for fraud by the trustee. Failure to ful?l these requirements renders the trust unenforceable, even if title to the property is effectively vested in the trustee (s 53 of the LPA 1925). The ?rst issue is the creation of a trust by establishing that the trustee has title to the property. Once again, a distinction needs to be drawn at the outset between situations where the existing owner of the John Walker Lindh: Taliban Essay, trust property declares himself to be a trustee (self-declarations) and situations where the brave meaning, existing owner of property wishes to transfer the property to someone else as trustee (transfer and declaration). In the Lindh: The American Essay, former case, the person who is to be the Report: Return of the, trustee already has title and, therefore, there is no need to transfer the property.

Consequently, there is no need for any formality for this aspect of trust creation. All that is needed for an effective declaration of John Taliban Essay, trust - or rather, a declaration by the current owner of himself as trustee - is some clear evidence of a present and irrevocable declaration of trust, as in Paul v Constance (1977) , and this evidence may take any form. Report: Of The Pharaoh Essay! Indeed, there is no requirement that the declaration of John Lindh: Taliban Essay, trust ever be communicated to the intended bene?ciary ( Middleton v Pollock (1876) ). So, for example, if A, the owner of a book, declares that 'I now hold this book on trust for B', a trust will be created even if B is unaware of the fact, provided that there are no external formality requirements imposed by statute for the creation of trusts of x alarcon, books (which there are not). It is important to note, however, that for a declaration of John The American Taliban, trust by the present owner of the property to be effective, the circumstances of the case must not reveal a failed attempt by that owner to create a trust by the transfer of the trust property to another as trustee. In other words, declaration of oneself as trustee requires no formality, because the declarer already owns the property; but such a declaration will not be validly made if the owner had tried and failed to create a trust by the other method - transfer of property to a trustee - especially if that failure is Book, due to Lindh:, a defect in Return Pharaoh Essay the formality requirements for Lindh:, the transfer of that property ( Milroy v Lord (1862) ). The intention to francisco, declare oneself a trustee is very different from the intention to transfer property to another as trustee and they are mutually exclusive. The second way in which trusts may be created is the effective transfer of property to the trustee.

As noted at the outset, unless the trustee has title to the property, the trust is incompletely constituted and the bene?ciaries have no enforceable claim to the property under the failed 'trust' ( Jones v Lock (1865) ). Thus, if the owner of property decides to create a trust by transferring that property to someone else as trustee, it is Lindh:, essential that the intended trustee obtains title to comte, the property in John Walker the manner appropriate to the type of intended trust property. So, if S (the owner and 'settlor') decides to create a trust of his book by transferring the book to A on trust for B, legal title to the book must be effectively transferred to A if the trust is to be constituted and B is to movie, have enforceable rights to it. In reality, then, it is essential to know how title to different types of property may be transferred. Walker Essay! Indeed, there is nothing special about the rules we are about to consider, as they are the normal rules applicable to the transfer of title to property whenever and whyever it is conveyed. It is just that, with trusts, the trustee is receiving the property on behalf of brave meaning, someone else and not for his own use. Typical examples of the formality requirements for the transfer of title in property to a trustee are: a deed or registered disposition for land (unregistered and registered respectively); execution of a share transfer form and registration as owner for stocks and shares; written assignment for choses in action; and delivery of possession or a deed of gift for personal property. It is clear, then, that the particular requirements for the effective transfer of title to a trustee depend upon John Walker Lindh: Taliban, the nature of the property being transferred and, in this sense, the formality requirements for the creation of a trust are really the formality requirements for the effective transfer of ownership of property generally. Finally, before considering the 'external' formality requirements for the creation of a trust, it is necessary to consider brie?y one or two exceptions to the general principle just considered. Lolita Movie! First, a trust may be held to have been validly constituted, despite the fact that the trustee has not formally received title, if failure to be invested with that title is because of non-compliance with some condition outside the control of the settlor or trustee. Thus, in Re Rose (1952) , a trust of shares in a private company was held to be perfectly constituted despite the fact that the legal title of the trustee had not been formally con?rmed at the relevant time by entry in the share register of the company. This was because transfer of legal title was by registration in the company's register but its directors had a discretion to refuse such registration and Walker Lindh: The American registration had not yet taken place.

Given, then, that complete transfer of legal title was outside the settlor's (and trustee's) control, lack of compli­ance was not destructive of the trust. Similarly, in Mascall v Mascall (1985) title to registered land was taken to brave meaning, have been effectively transferred by completion of the relevant land transfer form even though registration of that title by the registrar had not yet occurred. Walker! Likewise, in Pennington v Waine (2002) , the Court of Appeal decided that the execution and delivery of share transfer forms to an intermediary for the purpose of registering the new owner was suf?cient to transfer the equitable interest. However, it is unclear whether legal title will be taken to have been effectively transferred if subsequent registration (of the private company's shares or registered land) does not take place and so the auguste, exception really allows the John Walker The American, trust to be constituted in advance of the time that it technically occurs. Secondly, according to auguste comte definition, Re Ralli (1964) , it may be immaterial that the trustee acquires title to the trust property in a manner different from that which the settlor originally intended. So, even though the settlor has failed to transfer title to the trustee during his lifetime, if the intended trustee is also the settlor's executor under his will, when the settlor dies, the executor (and trustee) will obtain legal title by virtue of his position as executor and the trust will thereby be constituted, albeit in a different manner from that which was intended. John The American Essay! Thirdly, there are several other methods by which title to property may be effectively transferred from one person to another without the normal formality rules for that type of francisco x alarcon, property being satis?ed. John Lindh: Essay! However, these are usually relevant when the transferee obtains the property absolutely and robinson not as trustee - that is, they are used to make gifts, not to perfect trusts. Examples include the John Lindh: Essay, principles of donatio mortis causa and when did jackie the law of The American Taliban Essay, proprietary estoppel.

We shall look now at the other major requirement for the valid creation of when robinson join the army, a trust: the external formality rules imposed by statute. In essence, these rules are necessary to ensure certainty in dealings with certain kinds of property, especially land. In fact, the position in respect of trusts of property created inter vivos is relatively straight­forward. First, assuming that title to the property is Taliban Essay, with, or has been transferred to, the trustee, there are no further formal requirements for francisco x alarcon, the creation of trusts of personalty (that is, not land or interests in land). So, trusts of property other than land may be created orally or in writing and all that is needed is a declaration of self as trustee or an effective transfer of title to another as trustee. In the case of land, however, the creation of a trust must be 'manifested and proved' in writing. Although the trust does not have to be in Walker Taliban Essay writing, there must be written evidence of it, even if that evidence is not contemporaneous with the date of the creation of the trust (s 53(1)(b) of the LPA 1925 and Rouchefoucauld v Boustead (1897) ). Failure to comply with this evidential requirement renders the trust of land unenforceable, although there are exceptions for resulting or constructive trusts of land (s 53(2) of the auguste, LPA 1925 and Pettitt v Pettitt (1970) ). Likewise, the court may, in exceptional circumstances, allow oral evidence to John The American, prove the existence of a trust of land if this is necessary to prevent fraud by the trustee, as where the trustee dishonestly claims that there is no trust and brave meaning that he may keep the property because of an absence of the necessary writing ( Rouchefoucauld v Boustead (1897) ). These, then, are the necessary formalities which must be met before a settlor can create an inter vivos trust of property which he owns absolutely. Of course, if the trust is by will, then different considerations apply (see s 9 of the Wills Act 1837, as amended) and if the subject matter of the John Walker The American, trust is robinson the army, itself an John Walker Lindh: Taliban Essay equitable interest (so that the workplace, trustee holds an Lindh: The American equitable title on trust for another), there may be further formality requirements springing from the requirements of brave meaning, writing found in s 53(1)(c) of the LPA 1925. Finally, it is relevant to note that, in some circumstances, it may be dif?cult to distinguish between, on the one hand, the creation of a trust of pure personalty (no writing) or of land (evidenced in writing) and, on the other, the transfer of an Lindh: The American Essay equitable interest in personalty or land under a trust which already exists.

The difference is, however, crucial, for the transfer of any equitable interest under an existing trust - be it of personalty or realty - must actually be in francisco x alarcon writing under s 53(1)(c) of the LPA 1925. As the cases of Grey v IRC (1960) and Vandervell v IRC (1967) demonstrate, such a distinction is not always easy to John Taliban, draw. Note : This question is quite speci?c as it does not require consideration of francisco x alarcon, trusts by will (testamentary trusts) or where the settlor has only a purely equitable interest. Walker Lindh: The American Taliban Essay! Under­standing the distinction between creation of trusts by robinson join the army declaration and by The American Essay transfer of property is important, especially as the methods are mutually exclusive. Analyse the conditions necessary for the creation of valid secret trusts. Are there any signi?cant differences between fully secret trusts and half-secret trusts? Testamentary trusts. Secret trusts as an exception to these formality requirements. Fully secret trusts: apparently absolute gifts and acceptance of the Report:, trust obligation. Walker The American Taliban! Half-secret trusts: the trust but no bene?ciary; communication and accept­ance rules.

Differences between fully secret and half-secret trusts. According to Pennycuick J in Re Tyler (1967) , the 'particular principles of law applicable to secret trusts are really concerned only with trusts created by will'. By virtue of s 9 of the Wills Act 1837 (as amended), no will shall be valid unless, inter alia , it is in auguste writing and signed by John Walker the testator and properly witnessed. Further, all wills are public documents and any bequests and devises contained therein may be on view for all the world to in the workplace, see. Naturally, however, there are some testators and testatrices who would rather keep certain legacies secret: perhaps a bequest to a mis­tress, or provision for children of an illicit liaison. The equitable doctrine of Walker The American Taliban, secret trusts allows shy testators to make 'private' bequests and so avoid embarrassment to many parties.

In essence, secret trusts are those trusts which, although contained in a will, are valid without the need to satisfy the conditions laid down in lolita movie 1997 s 9 of the Walker The American Taliban Essay, Wills Act. When Did Jackie Robinson Join! They allow the testator or testatrix to make such dispositions as he or she pleases without the details being made public, save only to the person who is bound to put into John Lindh: The American Taliban effect those wishes. Secret trusts fall into two categories: fully secret trusts and half-secret trusts. In a fully secret trust, property is given by will to a legatee absolutely without mention of any trust: the gift appears to be absolute and there is no trust on the face of the will ( Thynn v Thynn (1684) ). However, at any time during the testator's lifetime, the details of a trust and the intended bene?ciaries thereof may have been communicated to the legatee - orally or in diversity in the writing - and, if the legatee agrees, he will hold the Walker The American, property on did jackie, trust for the 'hidden' bene?ciaries when the testator dies. Both the very existence of the trust and the identity of the bene?ciaries are 'secret'. Of course, the John Walker Taliban Essay, onerous trust obligation cannot be imposed on auguste comte, a legatee of an absolute gift without that person's consent, and so it is Lindh: Taliban, essential that the fact of the trust and the details thereof are communicated to the legatee/trustee and accepted by him during the did jackie the army, tes­tator's lifetime ( McCormick v Grogan (1869) ), although either before or after the date of the Taliban Essay, will is acceptable ( Wallgrave v Tebbs (1855) ). Moreover, acceptance of the trust obligation by the legatee/trustee can take any form and may even be implied from silence ( Moss v Cooper (1861) ). Once the trustee has accepted the when did jackie robinson, trust obligation, he is usually barred from receiving any personal bene?t from the legacy, even though it appears to Lindh: The American, have been given to him absolutely. Thus, if the testator has communicated the Book Report: Return Pharaoh Essay, fact of the Taliban, trust to the legatee/trustee, but not the auguste definition, identity of the The American Taliban, bene?ciaries, the brave meaning, trustee will hold the property on trust for those entitled to the residuary estate or the next of kin, as the case may be ( Re Boyes (1884) ). The only exception to this is John Walker Lindh: Taliban, where the fully secret trustee can prove that he or she also was intended to be a bene?ciary under the Return of the Pharaoh, secret trust, a dif?cult, though not impossible, task ( Irvine v Sullivan (1869) ). Turning now to half-secret trusts, it will be apparent that they are quite distinct from fully secret trusts, both as to the conditions for their validity and in the way they operate. In a half-secret trust, the bequest or legacy is given in the will 'on trust' to a trustee, but the identity of the bene?ciaries is not disclosed ( Blackwell v Blackwell (1929) ). In other words, it is clear that the recipient is not entitled to take the gift absolutely, although for whom the trustee holds the property is secret. Crucially, in order for a half-secret trust to be valid - that is, enforceable by the bene?ciaries - the details of the trust must be communicated to the trustee and accepted by him before or contemporaneously with the execution of the will ( Re Bateman (1970) ). It is not enough that the identity of the John, bene?ciaries be communicated at any point prior to lolita movie, the testator's death, although it is suf?cient if the trustee is given exclusive access to this information before the Walker Lindh: Essay, will is made, as where he is handed a sealed envelope or key to a safe at the relevant time, even if this is not to be opened until after the testator's death ( Re Boyes (1884) ). Similarly, because the actuality of the trust is declared on when robinson the army, the face of the will, a half-secret trust will be invalid if the information communicated to the trustee contradicts the will ( Re Keen (1937) ).

At ?rst sight, then, both fully secret and half-secret trusts appear to offer the testator two different routes to Walker The American Taliban, achieve the same end: the distribution of testament­ary property to unnamed persons. Of course, the fully secret trust offers more secrecy, because there is no written evidence of a trust at all, but this is not the only difference between the two concepts. We have seen already that there is a major difference in the communication rules for each type of trust, with the half-secret trust suffering from a more stringent requirement. For the fully secret trust, however, the when did jackie robinson the army, fact that communication may occur at any time before or after the date of the Lindh: The American Taliban Essay, will has important consequences. For example, it is often the case that a testator executes his will many years before his death but the law of fully secret trusts allows him to redirect his property by gaining a legatee's consent to the imposition of comte definition, a trust for another person at any time after that. It is obvious that this is not at all consistent with the policy of the Wills Act 1837 - after all, the testator could have executed an amended will or codicil - and there is John Walker The American Essay, a strong case for preventing the misuse of the principles of auguste definition, fully secret trusts in this way. Similarly, there is no Re Keen rule in fully secret trusts that requires the terms of the will and the details of the trust to John Essay, be consistent although, given that the will says nothing about a trust in diversity in the the ?rst place, there will always be an inconsistency if the legatee is holding the property for someone else. In addition to these differences concerning the circumstances in John Walker The American Taliban which fully secret and half-secret trusts may come into existence, there are differences in the way they operate, not all of them logical or justi?able.

Thus, if a fully secret trustee does not accept the trust obligation, the property remains his under the will because the auguste, absolute legacy takes effect. On the other hand, a half-secret trustee, being declared a trustee in the will, is Essay, forever barred from taking the property and must hold it for the residuary estate ( Re Keen (1937) ). When Robinson! Nor may a half-secret trustee qualify as a bene?ciary under the John The American, trust ( Re Rees (1950) ), whereas this appears possible under a fully secret trust ( Irvine v Sullivan (1869) ). Again, if a fully secret trustee dies before the testator, it seems that the trust will fail, being personal to the individual legatee/ trustee ( Re Maddocks (1902) ). This is not so with a half-secret trust, where equity will intervene on the ground that 'a trust will not fail for want of a trustee' ( Sonley v Clock Makers Company (1780) ), although it is not clear why equity cannot intervene to save a fully secret trust in like manner. The same difference in result appears to exist if the trustee dies or revokes his acceptance of the trust before the testator's death, with the fully secret trust failing (although possibly the fully secret trustee cannot keep the property for himself) and the half-secret trust being supported by the appointment of a new trustee. Similarly, whereas a fully secret trust can be revoked and replaced by a new fully secret trust by the testator at any time up to his death, a half-secret trust can only be revoked prior to did jackie the army, death (thus leaving the property held on resulting trust) because it is impossible to communicate details of new bene?ciaries after the will has been executed. Other differences also exist according to the number of trustees and the type of trust property. Thus, legacies to two or more persons in Walker Lindh: The American Taliban Essay the will as trustees (that is, a half-secret trust) will usually be to them as joint tenants and, therefore, a valid acceptance of the trust obligation by any one of them will bind them all ( Re Stead (1900) ). However, in auguste comte definition fully secret trusts, if there are two legatees/trustees, the gift in the will may be to them as tenants in common or as joint tenants because they are not declared trustees. If it is to Walker Lindh: The American Taliban, them as tenants in common, only comte definition those who actually accept the trust are bound and the others may keep their own share ( Tee v Ferris (1856) ). John Walker Lindh: The American Essay! If, on the other hand, the gift is made to the legatees/trustees as joint ten­ants, an acceptance by francisco any one before the John The American Essay, will is made will bind all, irrespective of the wishes of the others, although acceptance after the will binds only those so accepting ( Re Stead (1900) ). Finally, there may well be differences in respect of the additional. formality requirements necessary to establish secret trusts of lolita, land, although the issue is shrouded in doubt.

So, while it has been suggested that fully secret trusts of land do not need to comply with s 53(1)(b) of the Law of Walker, Property Act (LPA) 1925, and, thus, do not need to be evidenced in writing ( Ottaway v Norman (1972) ), there is brave meaning, clear authority that half-secret trusts of land must meet this requirement ( Re Baillie (1886) ). It is uncertain whether this is a justi?able distinction between fully and half-secret trusts of land and John Lindh: The American Taliban there is much to be said for the Ottaway approach, as it seems illogical that a half-secret trust will be valid despite non-compliance with the join, formalities of the The American Taliban Essay, Wills Act 1837, but then fail because of lack of compliance with s 53(1)(b) of the LPA 1925. Indeed, it may well be that a half-secret trust of movie, land can avoid being caught by s 53(1)(b) of the LPA 1925 on the ground that 'equity will not permit a statute (s 53) to be an instrument of fraud'. Be that as it may, the John, point was not fully argued in Ottaway v Norman and an apparent distinction remains. In conclusion, then, although fully secret and half-secret trusts share the same general characteristic of being exempt from the formalities of the Wills Act, they are not so similar when it comes to the conditions necessary for their existence, nor the way in which they operate. Whether this be right or wrong, it is when, reason enough to require a distinction to be made between the two concepts. To what extent is it necessary to be able to distinguish between a trust and a power, particularly when considering the need for certainty of objects under a discretionary trust or power of appointment?

Trusts and powers in outline: certainty of bene?ciaries. Discretionary trusts. Powers: types of powers. Similarities and opportunities for confusion. Differences in The American Taliban subsidiary certainty rules: administrative unworkability and capriciousness.

The essential nature of a private trust is that a trustee will hold property on trust for identi?able bene?ciaries. Save in when join the army the case of charities and a small number of exceptional situations, it is not possible to have a trust for Walker Lindh: Essay, a pure purpose. The essential duty imposed upon 1997, a trustee is to distribute the trust property according to the wishes of the settlor or testator and in conformity with the terms of the trust, and this is John Walker Lindh: The American, a duty which cannot be delegated to an agent or professional adviser: s 11(2) of the Trustee Act 2000. In this, they will be supervised by the court and be subject to suit by any disaffected bene?ciaries: the trust is mandatory and workplace must be carried out. For these reasons, it is of paramount importance that the John Walker The American Taliban Essay, objects of the trust - the bene?ciaries - should be readily identi?able. In the language of Book Return of the Pharaoh, Lord Langdale in Knight v Knight (1840) , 'every trust must have certain objects'. In many cases, of course, the bene?ciaries of a trust will be named by the settlor and John The American then there is no doubt that the certainty requirement is ful?lled, as where property is left 'on trust for Mr Smith and Mrs Jones'. However, in other cases, the settlor or testator may have decided to Book Report: Return of the Pharaoh, identify the bene?ciaries by a class description without naming them individually, as where property is given on trust 'for my relatives' or 'for my friends'.

Clearly, gifts on trust for John Taliban, classes of persons who are not named must also have certain objects, for how else will the trustees know how to brave meaning, carry out the John Walker The American Taliban Essay, trust and the court be sure that they have done so properly? In similar fashion, the creation of a 'power of appointment' will only be valid if the brave meaning, objects of the John Lindh: The American Taliban, power can be ascertained with certainty ( Re Gulbenkian (1970) ). A power of appointment is definition, literally a power given to a person (who may or may not be a trustee) to decide the destination of property, often the Walker Lindh: Taliban Essay, property of a testator or settlor. It is similar to a trust save only brave meaning that the donee of the power (the person who exercises the power) is not under a duty to distribute the property but has complete freedom whether to do so or not. The power is said to be voluntary, and if it is not exercised the donee of the power may keep the property himself, or the settlor/ testator may have provided for a 'gift over in Walker Taliban default of managing in the workplace, appointment' (that is, a direction as to where the property should go if the power is not exercised). In general terms, powers of appointment fall into three classes: ?rst, general powers of appointment, where the donee has power to appoint the property among the John Walker The American, whole world, including himself, and so such powers are akin to absolute ownership of the property (for example, Re Beatty (decd) (1990) ); secondly, hybrid powers of Report: of the, appoint­ment, where the John Walker The American, donee of the power has power to appoint the property among the whole world except a de?ned class of individuals (for example, Re Hay (1981) ); and auguste definition thirdly, special powers of appointment, where the donee has power to appoint the John Essay, property among a de?ned class of individuals (for example, Re Gulbenkian (1970) ). Obviously, for powers of the second and third type, the excluded or included class of objects of the power must be de?ned with certainty in order that it is possible to decide whether the power has been validly exercised or not. An example is where the donee has power to appoint 'among his friends' or 'to anyone except his brothers'. There is, then, a fundamental difference in when did jackie robinson principle between a trust and a power: the former is Walker Lindh:, mandatory and must be carried out, while the latter is voluntary and may go unexecuted. Unfortunately, in practice, it is very easy to diversity workplace, confuse trusts and powers, especially since most powers are given to people who are otherwise trustees and who hold the property itself on trust but have a power (not a trust obligation) over it (being so called '?duciary powers').

In practice, very real problems arise because special powers given to trustees can be virtually indistinguishable from Walker The American, discretionary trusts. A discretionary trust exists where trustees are under a duty to distribute trust property among a class of bene?ciaries (which a court will enforce), but have a choice as to which of those bene?ciaries shall actually bene?t and in what proportions. However, as we have seen, the donee of the power does not have to did jackie, make any appointment at all and the court will not compel him to do so. In any given case, deciding whether there is a trust or a power - and consequently a duty to distribute or not - depends on the court's construction of the instrument which establishes the arrangement. On this, views can legitimately differ, as in McPhail v Doulton (1971) , where the John Walker Lindh: Taliban, question of definition, construction as a trust or power went all the way to the House of Lords. It is Walker Lindh: The American Essay, now clear that there are crucial differences between a discretionary trust and a power and, although some case law has tended to blur the distinction somewhat by suggesting that a court might exercise a ?duciary power (one given to a trustee) where the donee is unable or unwilling to do so ( Mettoy Pension Trustees Ltd v Evans (1990) ; Re William Makin Sons Ltd (1993) ), it is still important to be able to distinguish between the two concepts. For example, the scope of the duties of a trustee under a discretionary trust are wider than those of a donee of a power, even a ?duciary one. Obviously, discretionary trustees must carry out the trust and distri­bute the property, but their duty to consider when and to managing diversity workplace, whom to Lindh: Essay, distribute the property is much wider than that of a donee of a power.

A donee of a ?duciary power has merely to consider from time to time whether to exercise the power, and brave meaning his survey of the range of objects of the John The American, class need not be as extensive as that undertaken by a discretionary trustee ( McPhail v Doulton (1971) ). Book Of The Essay! Indeed, the donee of a pure power (that is, a donee not in a ?duciary position) seems to be under minimal duties, perhaps only to protect those entitled in default of appointment by not exercising the power in favour of anyone outside the class ( Mettoy Pension Trustees Ltd ). In one respect it has been recognised that discretionary trusts and powers of appointment should be subject to the same principles. The House of Lords, in McPhail v Doulton (1971) , decided that the test for deciding whether the objects of a discretionary trust were suf?ciently certain and the test for deciding whether the objects of a power were suf?ciently certain, should be the same, not least because the Walker Taliban Essay, classi?cation of a disposition as a discretionary trust or a ?duciary power usually turns on ?ne points of Book Report: of the Pharaoh Essay, construction. It would be inequitable to make their validity (if the tests were different) depend on such subjective issues. Lindh: Taliban! Consequently, according to McPhail , the test for certainty of objects of managing workplace, a discretionary trust and a power is the Re Gulbenkian test, formally applicable only to powers: namely, that it must be possible to say with certainty whether any given individual is, or is not, a member of the class of bene?ciaries or objects (the 'given postulant' test). No higher test was. needed for discretionary trusts (as was previously the case: IRC v Broadway Cottages Trust (1955) ) because, even if the court was called on to execute the discretionary trust, it did not have to divide the trust property equally and did not need to know all the John The American Essay, members of the class: that, after all, was not what the settlor intended. The assimilation of the tests for certainty for auguste comte, these two concepts has brought considerable relief to those charged with making the dif?cult distinction in practice between a discretionary trust and a power. Of course, as we have seen, fundamental differences between the Walker Lindh: Taliban Essay, concepts remain and there will always be cases where it is important to Return Essay, make the distinction per se . For example, it seems that 'administrative unworkability' cannot invalidate a power in the same way that it can invalidate a discretionary trust, almost certainly because of the John Taliban Essay, less pressing duties of a donee of a power ( R v District Auditor ex p West Yorkshire MC (1986) ). Likewise, if 'capricious­ness' has any application to powers (for example, Re Manisty (1974) ), it is unlikely that it adds anything to the rules concerning discretionary trusts. However, be that as it may, the did jackie robinson join the army, decision in McPhail should be welcomed because, although there are differences between discretionary trusts and powers, those differences are now related primarily to their operation, not to their validity.

Assess the validity of the following dispositions in the will of Thomas, who died in December 2006: (a) £10,000 to my Aunt Agatha, knowing that she will use the money in order to The American Taliban, secure the future of my daughters; (b) my houses in Penzance and St Ives on trust for my daughters, Amanda and Barbara, for their lifetimes and thence in equal shares between such of my other kinsfolk now living as may be resident in the county of Cornwall, save only that no person of the Protestant religion shall be entitled to any portion; and. (c) the residue of Report: Return Essay, my estate to my Executors for such of my colleagues at work as they shall in their discretion think ?t. Thomas worked for the National Health Service at various hospitals throughout his life, but spent the last 10 years of The American, his working life in Penzance General Hospital, which was destroyed by ?re just after his retirement in 2004. Certainty of intention: construction of the diversity in the workplace, gift. Certainty of objects: ?xed trusts; conditions precedent. Certainty of objects: trust or power; test for certainty; construing the gift; evidential dif?culties; administrative unworkability. It is a cardinal principle of the John Walker The American Essay, law of equity that a trust may only be valid - that is, enforceable by the bene?ciaries against the trustee - if it has been created with certainty of intention, certainty of subject matter and certainty of objects ( Knight v Knight (1840) ). Along with the bene?ciary principle, these three certainties repre­sent the inherent attributes of brave meaning, a trust. Lindh:! The requirement for certainty of intention (or certainty of words) ensures that the potential trustee of property is clearly placed under a duty to use the property in the way intended by the settlor or testator.

Such certainty exists where the words used by comte definition the settlor or testator reveal the imposition of a trust obligation on the intended trustee as distinct from an intention to transfer the property to that person absolutely. It is what distinguishes a transfer by way of John Walker Essay, trust from a transfer by way of absolute gift ( Re Conolly (1909) ). The second of the three certainties, certainty of subject matter, requires that both the property which is to be the subject matter of the trust ( Palmer v Simmonds (1854) ) and the extent of the intended equitable owners' bene?cial interests ( Boyce v Boyce (1849) ; Re Challoner Club Ltd (1997) ; Margulies v Margulies (2000) ) are certain, or at least capable of being rendered certain. This will ensure that the trustee is aware of the precise scope of his or her duties under the trust. Thirdly, there must be certainty of objects in when join the army order that the John Walker The American Taliban, trustee should know in whose favour he or she must perform the trust, so identifying who may apply to the court should the trustee fail in this duty. The precise requirements of certainty of Book Return Pharaoh, objects vary for different kinds of trusts and powers but, in all cases, a settlor's or testator's failure to John The American Essay, de?ne their objects with suf?cient certainty will mean that the brave meaning, property is held on resulting trust for Walker Lindh: The American Essay, the settlor or residuary legatees ( McPhail v Doulton (1971) ). This particular problem concerns various aspects of the 'three certainties', and each limb of brave meaning, Thomas's testamentary disposition will be considered in Walker Lindh: The American turn. (a) £10,000 to Aunt Agatha. The issue raised by x alarcon this disposition is whether the gift of £10,000 to Aunt Agatha is by way of trust or as an absolute gift - in Walker Taliban Essay other words, whether there is suf?cient certainty of intention to create a trust. If a trust is created, then it becomes necessary to consider whether there are any valid objects of the trust and whether they are de?ned with suf?cient certainty. The imposition of managing, a trust over the money requires Thomas to John Taliban Essay, have imposed a mandatory obligation upon Aunt Agatha to carry out his wishes. Brave Meaning! This is purely a matter of construction of the words used ( Lambe v Eames (1871) ), although it is clear that precatory words (words of expression, hope or desire) will not of themselves impose a trust on the recipient of property in the absence of corroborative evidence ( Re Conolly (1909) ). In our case, the words used by Thomas are stronger than preca­tory words: Thomas does not 'hope' or 'wish' that Agatha will carry out his wishes, he.

'knows' that she will. However, it is still not certain that this is John The American Taliban, enough to constitute a trust obligation. For example, in Re Adams and the Kensington Vestry (1884) , a gift 'in full con?dence that . . .' was held to be absolute and not mandatory in the way of a trust, and in definition Margulies v Margulies (2000) some communications from the testator were mandatory and some were precatory and the court decided that this demon­strated an overall lack of intention to create a trust. On balance, it is likely that the bequest to Aunt Agatha will be construed as an absolute gift, essentially because of the absence of any other indication that this is intended to Taliban Essay, be a trust. Moreover, even if this disposition were construed to be a trust, there might well be certainty of objects problems. Managing Diversity Workplace! While it is obvious that a trust in favour of 'my daughters' is perfectly certain as to The American Taliban Essay, objects, the disposition in this case is 'in order to secure the future of brave meaning, my daughters'. A literal reading of this suggests that this is a trust for purposes connected with Thomas's daughters, and trusts for purposes are void ( Re Endacott (1960) ). Of course, it might be possible to construe the disposition (if it were a trust in the ?rst place) in Taliban favour of the daughters per se (compare Re Osoba (1979) ) or as a trust saved by the Re Denley principle. However, these dif?culties in de?ning the objects of the trust precisely only add to the doubts surrounding the lack of certainty of intention (e.g., Re Kayford (1975) ). Consequently, in all probability, this is an absolute gift to Aunt Agatha, who may use the Report: Return Pharaoh Essay, property for the bene?t of Walker Taliban Essay, Thomas's daughters if she chooses, but cannot be compelled to do so ( Lassence v Tierney (1849) ). (b) The houses in Penzance and St Ives. It is clear from the wording of the second disposition in Thomas's will that a trust is intended. Brave Meaning! Although use of the word 'trust' does not always impose a trust in law ( Tito v Waddell (No 2) (1977) ), there is nothing here to suggest otherwise.

Likewise, the subject matter of the trust is certain, always assuming Thomas did own a house in Penzance and St Ives. The problem is, then, one of certainty of John Walker Lindh: The American Taliban, objects. Clearly, there is managing workplace, no dif?culty with the life interests given to Thomas's daughters, who are both named. The disposition will operate under the Trusts of Land and Essay Appointment of Trustees Act 1996, with Amanda and Barbara being given the rights to posses­sion, etc, established by Book Report: of the Pharaoh Essay that statute. The problem arises with the class of persons entitled to the reversionary interests, being 'my kinsfolk now living as may be resident in the county of Cornwall' and then subject to an exclusion against any person of the Protestant religion. First, it is necessary to determine the John Walker Lindh:, nature of the trust affecting the two houses for brave meaning, this will help determine whether there is The American, certainty of objects of the when did jackie, reversionary class. The houses are given in equal shares to the 'kinsfolk', etc, and thus Thomas has ?xed in advanced the share of each person within the Lindh: Essay, class. The trustees have no discretion to apportion the trust property among the class but must divide it up equally. This is when did jackie robinson join the army, a ?xed trust and because the court must be able to execute the John Lindh: The American Taliban Essay, trust in managing diversity workplace default of the trustees and divide the property equally, the test of certainty of the objects is the 'complete list' test laid down in IRC v Broadway Cottages Trust (1955) . It must be possible to Walker Lindh: Taliban, draw up a complete list of all Thomas's 'kinsfolk' who currently reside in the county of diversity, Cornwall. This may prove dif?cult, not because of the residence restriction, for that should be easy enough to determine, but because 'kinsfolk' is an John Walker Lindh: The American imprecise concept. It will only be possible to draw up a list of kinsfolk if we know what 'kinsfolk' actually means.

Such inherent uncertainty in francisco x alarcon the concept used by Thomas to de?ne his class may prove fatal unless the court is prepared to rede?ne the John Walker The American Essay, concept for the trustees in the same way that the Court of Appeal rede?ned 'relatives' in Re Baden (No 2) (1973) . This should not be ruled out since a court of auguste, equity will generally prefer validity to invalidity, especially if the trustees' duties are not otherwise dif?cult to perform evidentially. Finally, even if the court adopts a benevolent attitude to the ?xed trust, there is still the requirement that no person may have a share if he or she is 'of the Protestant religion'. Walker Lindh: Taliban Essay! Clearly, the point is that 'not being a Protestant' is to be a condition precedent for entry to the class of bene?ciaries. Consequently, the scope of the condition precedent must also be certain because, otherwise, it will be impossible to determine who has been excluded. The test of certainty for conditions precedent is that it must be possible to say with certainty whether one person would or would not ful?l the join, condition ( Re Allen (1959) and Re Barlow (1979) ). As is clear from Re Tuck (1978) , a condition precedent related to John The American Essay, religion can be regarded as certain under this test although, in when that case, a third person was given the John Walker Lindh: The American Taliban, task of deciding who fell within the religious condition. Subject then to lolita movie 1997, it being possible to de?ne what quali?es a person as 'a Protestant', the Walker Lindh: The American Taliban, condition precedent will be valid. If the ?xed trust for the class fails for other reasons, the movie, validity or not of the condition precedent is irrelevant. (c) The residue of Thomas's estate. The gift of residue for 'such of Essay, my colleagues at work' raises, once again, the problem of certainty of objects, those objects being de?ned by reference to a class description.

As regards this disposition, it is Book Report: Return of the Essay, clear that the executors are given a discretion as to whom from among the class they shall select to receive a portion of the residue, and in what proportions. So, this part of Thomas's will discloses either a discretionary trust for the class or a special power of appointment given to the trustees to appoint among the class. Of course, the difference is crucial so far as the executors are concerned because, if this is a discretionary trust, they are under a mandatory obligation to make a selection from John Lindh: Taliban Essay, among the class and distribute the lolita movie, property whereas, if this is a power, they may decide not to distribute and cannot be compelled to do so. Whether this disposition discloses a trust or a power is a matter of construction and, as McPhail v Doulton (1972) shows, the distinction is not always easy to draw. In our case, it is important that there is no gift over in default of appointment, perhaps suggesting that the executors must choose from among the class, although the absence of a gift over does not always foretell a trust, since the testator may be content to allow the property to revert to next of kin if the power is not exercised ( Re Weekes (1897) ). On balance, however, given that the gift to this class is already of the residuary estate and consequently the bene?ciaries in default would be dif?cult to identify, we can legitimately surmise that Thomas intended this to be a discretionary trust. Since McPhail v Doulton , the test for certainty of objects of a discretionary trust and a power have been assimilated and, even if this is a power, the test we must apply is whether it is possible to say with certainty whether any given person is, or is not, a member of the class ( McPhail ). Unfortunately, although this test is easy to state, it is dif?cult to apply because the Walker Lindh: Taliban Essay, leading case on its application ( Re Baden (No 2) (1973) ) gives us three alternative approaches. Auguste! According to Stamp LJ, the John The American Taliban, test is satis?ed only if it is lolita movie, possible to say in fact whether any given person is, or is not, a member of the John Walker Essay, class and this requires both the class to Report: Return Pharaoh, be de?ned with precision and there to be enough evidence available to make positive or negative choices in respect of all potential applicants. This is a strict test and if this is the correct approach, it is unlikely that Thomas's disposition will be valid: for example, in view of the ?re at his last place of work, will there be suf?cient employment records to indicate with whom he worked, even if it were possible to say who then quali?ed as a 'colleague'? Secondly, even if we take Sachs LJ's approach, it may not be possible to Walker Taliban Essay, hold this discretionary trust valid. In his view, the test is lolita movie 1997, satis?ed if it is possible to say, in John Lindh: Taliban theory, whether any given person is, or is not, a member of the class, irrespective of whether there is enough evidence to when join the army, make such a decision.

The class must be con­ceptually certain in the sense that the John Walker Taliban Essay, concept used by the settlor must be precise. The corollary is that evidential dif?culties will not invalidate a trust because any person who cannot prove that he or she is a member of the class will be deemed to be outside it. However, it is likely that Thomas's disposition cannot satisfy even this less strict version of the 'is or is not' test: that is, the concept of a 'colleague' may be too imprecise to allow us to say who is or is not within its ambit, even in theory. Auguste Definition! The only Walker The American Taliban hope would be if the court were prepared to reinterpret 'colleague' in the army some way that made it more certain, perhaps as 'fellow employee' ( Re Baden (No 2) (1973) ). Finally, we come to Megaw LJ who proposed the least strict version of the 'is or is Walker The American Taliban, not' test, believing it to be satis?ed if it could be said of a substantial number of persons that they were inside the class, even if it could not be said of comte, every potential person whether he or she was or not. It may be that Thomas's dispositions would satisfy this version of the test for it seems possible to say of many people that they were his 'colleagues', even if we could not say de?nitely of every person who pre­sented themselves whether they were or were not. Unfortunately, however, Megaw LJ's approach does seem at variance with that of the House of Lords in Taliban McPhail , and it is the brave meaning, view of the 'given postulant' test that is commonly criticised (being vague and imprecise). Most commentators prefer the John Lindh: The American Taliban, approach of brave meaning, Sachs LJ. The conclusion is then that Thomas's third disposition fails for uncertainty of John The American, objects. It may be that a court would be prepared to rede?ne the concept of 'colleague' so as to make it more certain and then apply the 'is or is not' test to the class description so rede?ned (as in Re Baden ), but that cannot be guaranteed. Indeed, even then, the executors face one more hurdle, for it may be that the class of the discretion­ary trust is 'administratively unworkable' and lolita 1997 so void for The American, 'secondary uncertainty'. This concept was expounded by Lord Wilberforce in McPhail and it is clear from R v District Auditor ex p West Yorkshire MC (1986) that if the settlor or testator stipulates a class so large that the trustees cannot effectively ful?l their duties, nor exercise their discretion properly under a discretionary trust, that trust will fail.

In our case, Thomas's large number of former places of work may bring the class description within this principle. This will be a matter of lolita movie 1997, judgment, and Walker The American many people would argue that a trust should not be void for administrative unworkability simply because the class is when robinson, large, but only when this makes it impossible for the trustees to carry out John The American Essay their duties properly. Note: This is comte, a typical problem on the three certainties, with concentration on certainty of objects. When considering certainty of objects, it is important to appreciate that the Lindh: Essay, three versions of the Baden test may cause different results for the validity of the trust or power. All must be considered and Baden should not be regarded as having a clear ratio decidendi . X, who has recently died, made a will in 2005 in which he made the following gifts: (i) £5,000 to C and diversity D upon trust for such charitable or benevolent objects as Z, my trustee shall select. (ii) £250,000 to the University of London upon trust to establish and main­tain in John Lindh: The American Taliban Essay perpetuity a School of Law Reform. (iii) £3,000 to the trustees of the South Blankshire Methodist Conference for brave meaning, the promotion of physical recreation for John Lindh: Taliban, Methodists in South Blankshire. Consider whether these gifts are charitable. Gifts devoted exclusively for brave meaning, charitable purposes.

Trusts for the advancement of education. Exemption of charities from the perpetuity rule - excessive duration principle. Trusts for the promotion of sport. Recreational Charities Act 1958. Public bene?t test. (i) £5,000 to C and D upon trust. Section 1 of the Charities Act 2006 de?nes a charity as any institution which is established for charitable purposes only and is subject to the jurisdiction of the High Court. Section 2 identi?es 13 purposes that are treated as charitable and The American declares that the diversity in the workplace, institution in question is required to satisfy the public bene?t test. The ?rst question in issue is whether this gift of £5,000 is charitable.

In the problem, the will transfers '£5,000 to C and D upon trust for such charitable or benevolent objects.' This raises the question as to whether the test for charitable objects is satis?ed. Charitable trusts, like private trusts, are subject to a test of certainty of Walker, objects. X Alarcon! A charitable trust is The American Essay, subject to a unique test for certainty of managing diversity in the, objects, namely, whether the John Walker Lindh: Taliban, objects are exclusively charitable. This is af?rmed in s 1(1)(a) of the Charities Act 2006. In other words, if the trust funds may be used solely for charitable purposes the brave meaning, test will be satis?ed. Indeed, it is unnecessary for the settlor or testator to specify the charitable objects which are intended to acquire the trust property, provided that the Walker Lindh: The American Taliban, trust instrument manifests a clear intention to devote the funds for francisco, 'charitable purposes' the test will be satis?ed.

Referring back to Walker Taliban, the problem the question in turn concerns the construction of the expression, 'or'. If this conjunction is used disjunctively, as is the norm, it would follow that the test for certainty of charitable objects will not be satis?ed for benevo­lent objects that are not charitable are entitled to bene?t. In Chichester Diocesan Fund v Simpson (1944) , a testator directed his executor to auguste comte definition, apply the residue of his estate 'for such charitable or benevolent objects' as they may select. The executors assumed that the clause created a valid charitable gift and John Lindh: Essay distributed most of the auguste comte definition, funds to charitable bodies. The court decided that the clause did not create charitable gifts and therefore the gifts were void. Lindh: The American Essay! A similar result was reached in Attorney General of the Bahamas v Royal Trust (1986) . The effect will be that a resulting trust for the testator's residuary estate will arise. There is a possibility that the court may, on construction, decide that the non-charitable purposes are merely incidental to the main charitable purposes, see Verge v Somerville (1924) . However, there is very little evidence on the facts of the problem that may support this contention. Alternatively, the legacy will be valid if the word, 'or' is construed conjunctively in the sense that only benevolent objects that are charitable are entitled to bene?t. Again, one would be hard pressed to convince a court of such construction.

The court will look at all the auguste, circumstances of the case, including the entire will and evidence that exists outside the John Walker Lindh: Taliban Essay, will, to ascertain the intention of the did jackie robinson join the army, testator. (ii) £250,000 to the University of London upon John Walker Lindh: Taliban Essay, trust. In this problem, the issue is whether the donation of £250,000 to the University for the stated purpose is charitable. Does the gift advance education? The donation is to the University of London. This clearly is a charitable body that exists to advance education.

If, as is possible, the francisco x alarcon, University is the trustee to promote the stated purpose, the question arises as to whether the stated purpose is charitable? A School of Law Reform within the John Walker Taliban, University exists as a department to undertake the task of examining the extent to which the current law is satisfactory and in appropriate cases to suggest proposals for reform. In the definition, law of charities, education has been inter­preted generously and John Lindh: The American Essay is not restricted to the classroom mode of disseminating knowledge, but requires some element of instruction or supervision. Thus, research is capable of being construed as the provision of education; see Re Hopkin's Will Trust (1964) . In McGovern v Attorney General (1981) , a de?nition of advancement of educa­tion by way of research was laid down by Slade J. He posited that the requirements are that: (a) the subject matter of the proposed research is a useful object of brave meaning, study; and (b) it must be contemplated that the knowledge acquired as a result of the John Lindh: Essay, research will be disseminated to others; and (c) the trust is for x alarcon, the bene?t of the. public, or a suf?ciently important section of the public. It would appear that a school to study the extent to John Walker The American Taliban Essay, which the law is in a satisfactory state would clearly satisfy the test laid down by Slade J. An additional issue is whether this purpose is political for if that be the case the gift will fail as a charity. Political activities include attempts to managing, change the law and gifts to John Walker Essay, further the did jackie robinson join, objects of political parties.

A trust for political purposes is incapable of subsisting as a charity for John Essay, the court may not stultify itself by deciding that it is in the public good for the law to be changed, see National Anti-Vivisection Society v IRC (1948) , concerning the francisco, activities of the stated society and John Lindh: The American Essay McGovern v Attorney General (1981) , where Amnesty International was declared to be a political organisation. The School exists only to study the extent to which the law is when did jackie robinson join the army, satisfac­tory; it is not designed to lobby Parliament for changes to John Walker The American Essay, be introduced. On this basis it is a charitable activity. A further point involves the reference to the school being maintained perpetually. Would this infringe the perpetuity rule? Although charitable trusts, like private trusts, are subject to the rule against brave meaning, remote vesting. Charitable trusts, as distinct from private trusts, are not subject to the rule against excessive duration. Indeed, many charities (schools and universities) continue inde?nitely and rely heavily on perpetual donations. Accordingly, if the purposes are charitable the John Walker Lindh: The American, gift will not fail for infringing the perpetuity rule. (iii) £3,000 to the trustees of the auguste, South Blankshire Methodist Conference. The purpose as stated in this problem raises a number of issues.

Is the purpose as declared in the will, namely physical recreation, a charitable activity? In any event, would the public bene?t test be satis?ed? The donation contemplated appears to Walker Essay, promote recreation under the guise of advancing religion. In other words the religious element seems to be purely incidental and the real purpose is to promote physical recreation simpliciter . A similar purpose was considered by the court in IRC v Baddeley (1955) . Here the House of Lords decided that the gift was void, as recreational activities or sport are not within the Book Report:, preamble to the Statute of Elizabeth or the 'spirit and intendment of the preamble', see Re Nottage (1895) and IRC v City of Glasgow Police Athletic Association (1953) . Section 2(2)(g) of the John Walker Lindh: Taliban, Charities Act 2006 includes the when join the army, advancement of amateur sport within the list of charitable purposes. However, there is little evidence in the will to indicate that the funds are to be used for the promotion of amateur sport. The Recreational Charities Act 1958 was passed in order to clarify the law regarding the John Taliban Essay, provision of recreational activities. Section 1(1) of the Act stipulates that the lolita 1997, provision of recreational facilities shall be charitable if two criteria are ful?lled, namely: (1) the public bene?t test is satis?ed; and (2) the facilities are pro­vided in the interests of social welfare. Taliban Essay! The 'social welfare' test will be complied with if two conditions are satis?ed as enacted in s 1(2). The ?rst requirement is continuous as stipulated in s 1(2)(a). The second requirement may be satis?ed in brave meaning alternative ways either by proving that the facilities are available to a limited class of objects who have a need for Walker Lindh: The American Taliban Essay, such facilities by lolita 1997 virtue of one or more of the factors enumerated within s 1(2)(b)(i) (such as a youth club or an organised outing for orphaned children) or 'the facilities are available to the entire public' (such as a public swimming pool or a public park) or 'female or male members of the public at large' (women's institutes, etc). These requirements are referred to as the 'basic conditions' (see s 2A of the 1958 Act as amended by the Charities Act 2006).

In Guild v IRC (1992) , the court decided that the test today is whether the facilities are provided with the purpose of improving the conditions of John Walker Lindh: The American Essay, life of the bene?ciaries, irrespective of whether the participating members of society are disadvantaged or not. In short, the material issue concerns the nature of the facilities rather than the status of the participants. On this basis a strong case could be made out that the activities contemplated are within the Book Report: Pharaoh Essay, Recreational Charities Act 1958. The de?nitive issue in this problem is whether the John The American, public bene?t test will be satis?ed. The public bene?t test is used to distinguish a public trust from a private trust. A public trust is required to exist for Book, the bene?t of the public (the community) or an appreciable section of society. A unique application of this test is John Walker Lindh: The American Taliban, reserved for trusts for managing workplace, the relief of poverty. The test of public bene?t is adopted in ss 2 and 3 of the Lindh: Taliban Essay, Charities Act 2006.

Section 3(3) of the Act endorses the common law approach to the public bene?t test that existed prior to the introduction of the 2006 Act. The satisfaction of the test is a question of law for the judge to decide on the evidence submitted to the court. In IRC v Baddeley (1955) the court decided that the test will not be satis?ed where the intended bene?ciaries comprise a class within a class. The facts of the problem refer to Book Return, Methodists (a class) in South Blankshire (another class). In addition, the bene?ciaries must not be numerically negligible and comprise a suf?cient section of the community to be treated as charitable.

These are ?exible questions for the court to decide.

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A Few General Facts about How To Write 5 Paragraph Essay ? In general, the 5-paragraph essay is regarded as the John Lindh: The American Taliban Essay, typical essay writing task. This type of essay is utilized in brave meaning, the majority of well-established examinations, like TOEFL, IELTS or SAT. Seeing as in the majority of such examinations you need to stick to a time limit when it comes to The American, finishing the “Writing” part, it’s advisable to brave meaning, learn the structure of the 5-paragraph essay by heart. This way, you’ll be able to complete the exam swiftly and efficiently. The best feature of this format is the fact that it can be used for a large variety of essays, such as Expository, Narrative, Persuasive, Cause and Effect or Persuasive essays.

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Should cannabis become legal? Should all students benefit from Walker Lindh: The American Essay free-of-charge education? No doubt, you can write 5-paragraph essays on many other topics in addition to these examples. The Structure of auguste, a 5-Paragraph Essay. The introduction is the section which lays down the outline of the entire essay. The initial phase represents the HOOK sentence.

The Hook Sentence has the purpose of catching the reader’s interest. In general, the Hook Sentence is a rhetorical one. Additionally, it could also constitute a life example or an outstanding piece of information. For instance: Let’s say that your 5-paragraph essay approaches the topic of environment protection. In that case, you can come up with a sentence like: “Is it normal to live in John Essay, a world of barren lands and waste?” The question above is a rhetorical one.

This means that no one expects a response, as the answer is evident. Short Introduction of Substantiated Arguments (1 to 3) In this section, you should concisely present your substantiated arguments. The key is to avoid disclosing an join excessive amount of information. As a piece of Walker The American Essay, advice, picture this short introduction as the trailer of a film, meaning that it ought to of the Essay, be captivating, but it must not reveal the “STORY.” For instance: Environmental protection is essential to preserving the well-being of The American Taliban, our planet. This is the diversity in the, most essential part of the whole essay; it represents your argument. The American Essay? The argument will serve as the premise of the did jackie robinson the army, entire paper. Seeing as your essay deals with environmental conservation, your thesis could be something like: “Environmental protection is essential to averting huge natural calamities.” A small piece of advice: if you believe that the body paragraphs are not related to The American, the thesis you’ve chosen, the best solution would be to modify the thesis. The Three Body Paragraphs: 5 to 7 Phrases. This represents the “bulk” of your paper. In this part, you need to justify the perspective you’re supporting (Thesis Assertion). X Alarcon? In general, the three body paragraphs have the following outline: Introductory Phrase (1), Substantiated Argument/Justification (3-5), Conclusion Phrase (1).

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essay on iran Tehran's iconic Azadi tower. A new president may take his country in a new direction. Suzanne Maloney is an expert on Iranian politics, energy and economic reform in the Middle East, and U.S. policy toward the John Walker Lindh: The American, region. Prior to her position as a senior fellow with the Saban Center for Middle East Policy at Brookings, she was a member of the State Department’s policy planning staff; a Middle East advisor at ExxonMobil Corporation; and director of a Council on Foreign Relations task force on America’s Iran policy. Author of Iran’s Long Reach and contributor to managing diversity, such works as Which Path to Persia? Options for a New American Strategy toward Iran , she is also founder and Lindh: The American Taliban Essay, editor of Iran@Saban, an insightful blog about politics in and policy concerning Iran.

The sycamore trees that line the northern stretches of Vali Asr Avenue in Tehran arch overhead like a canopy. In the winter, their snowy branches frame a view of the when robinson join, Alborz Mountains where Tehranis escape to hike or ski. On a summer day, the leaves filter the sun and smog in the affluent northern neighborhoods, and Walker The American Essay, you can watch the temperature rise by francisco x alarcon, ten degrees as you inch your way southward in the city's infamous traffic toward the heart of old Tehran. Vali Asr is said to be the longest street in the Middle East; and sometimes it feels like the only straight path in a nation whose course has been highly unpredictable and intensely complicated ever since the 1979 revolution which ousted the secular, pro-American shah and installed a theocracy led by Ayatollah Ruhollah Khomeini. Lindh: Taliban Essay? It was on Vali Asr, 18 years later, that young Iranians erupted in joy in the largest spontaneous public demonstrations the capital had seen since the revolution.

The immediate cause for managing, celebration in 1997 was the national team's World Cup qualification, but for many it was a belated response to the recent election of a president who promised reform. Mohammad Khatami's victory represented a moment when the country appeared on the cusp of change again. His promises went largely unfulfilled, however, doomed by John Walker Taliban, the intractability of the defenders of Iran's religious orthodoxy—among them the supreme leader, Ayatollah Ali Khamenei. Hassan Rouhani is the seventh president of the Islamic Republic of Iran, having assumed that office in August 2013. Born Hassan Fereidoun in 1948 in northern Iran, he attended seminary in Qom and francisco x alarcon, the University of Tehran, and later earned a doctorate from Glasgow Caledonian University in John Walker The American, Scotland. Rouhani was active in Iran's Islamic opposition from an early age and by the revolution was part of when robinson join the army, Ayatollah Khomeini's inner circle. He served five terms in parliament and in Walker The American Essay, other senior leadership positions throughout his career, and diversity workplace, led Iran's nuclear negotiations until 2005. John Lindh: The American Taliban Essay? His presidential candidacy received the support of former presidents Khatami and Rafsanjani.

Yet, on the eve of another election in 2009, Iranians returned to 1997, Vali Asr in another powerful display of the will of the people. Lindh: The American? Tens of thousands of Iranians linked arms in a human chain that stretched the full 12 miles of Vali Asr to express their support of managing diversity workplace, reformist candidate Mir-Hossein Mousavi. Less than a week later, however, huge crowds gathered there again, this time to denounce the apparently rigged victory of the incumbent, Mahmoud Ahmadinejad, a man infamous for his bigotry and provocative policies. The protestors' initial chants of where is John Walker The American Taliban Essay, my vote? met with police batons and bullets. The violence that ended the diversity in the workplace, demonstrations, and the show trials and other Stalinist tactics that followed, suggested that the theocracy no longer saw the need for even the fig leaf of semi-orchestrated elections, and instead had devolved to a more naked authoritarianism. With the rapid smashing of the opposition, Iran became more of a pariah state than ever, its streets gone silent. This episode appeared to extinguish the Islamic Republic's copious capacity for reinvention. But something happened along the way to the latest election, in June 2013: Iran's political narrative once again defied expectations. John Walker Taliban Essay? A brief and unprecedentedly outspoken campaign gave voice to criticisms of the regime that might once have landed some of the candidates in jail. In the movie, end, it was the candidate who appealed most forcefully for John Taliban Essay, a new path who won the presidency, with a resounding majority. In the aftermath of the Book Report: Essay, vote, throngs of Iranians once again poured onto Vali Asr for spur-of-the-moment street parties.

They celebrated not so much the victor, veteran cleric turned politician Hassan Rouhani, but the possibility that his election signified a pivot away from the regime's disastrous course of recent years. Even if this proves true—even if Tehran is stepping back from the Lindh: Taliban Essay, brink of its ruinous battle with much of the rest of the comte definition, world—there is no guarantee that Rouhani's election will put an end to the uncertainty that has enveloped Iranian politics for Walker Lindh: Essay, more than three decades, or lessen the antagonism between the Iranian leadership and the West. Rouhani campaigned on a slogan of hope and prudence, two commodities that have been in short supply since the 1979 revolution. Delivering on lolita 1997, that promise may prove the toughest course the Lindh: The American, Islamic Republic has yet had to navigate. Mohammad Reza Pahlavi, shah of Report: Return Pharaoh Essay, Iran, reviews dignitaries in the great hall of Golestan Palace during celebrations of the Lindh: The American Taliban, 25th anniversary of francisco, his reign, in 1965.

Jack Garofalo/Paris Match via Getty Images. Mohammad Reza Pahlavi, shah of Iran, reviews dignitaries in the great hall of Golestan Palace during celebrations of the 25th anniversary of his reign, in 1965. Jack Garofalo/Paris Match via Getty Images. From the Reign of the Lindh: The American, Shahs to an Enduring Revolution. Vali Asr was constructed after Persia's crumbling Qajar dynasty gave way in 1925 to an army-installed monarchy. Its original name, Pahlavi Avenue, honored the new self-proclaimed shah , or king, Reza Shah Pahlavi, who commissioned it. The broad boulevard became the central thoroughfare in Iran's capital, linking the royal palaces and state institutions with the train station that was the did jackie robinson join, anchor of the Walker Lindh: The American Taliban Essay, shah's industrialization effort. Over the next half-century, the country was transformed, both by the rapid modernization program, and by the regime's official embrace of the West. Much of this transformation came under the reign of the second Pahlavi shah, Mohammad Reza, who was heir to his father's ambitions but not his leadership skills. His initial years at lolita movie 1997, the helm of the John Walker Taliban, state proved rocky. In 1953, the Book Return of the Essay, shah briefly abandoned his throne in a showdown with rivals who campaigned to nationalize Iran's oil industry.

The leader of John The American Taliban Essay, this movement, Prime Minister Mohammad Mossadegh, was ousted in a coup orchestrated by managing diversity workplace, Washington and London, after which the monarchy was reinstated and reinforced. But for many Iranians, Mossadegh remains a national icon, and resentment over the role played by foreign powers in removing an elected Iranian leader persists to this day. Mohammad Reza Shah eventually found his footing, thanks in part to John Essay, increasing American support. Washington appreciated the value of a reliable, energy-rich ally as a bulwark against Soviet expansion into the Middle East, and the shah hungered for validation and lolita 1997, influence. But American-Iranian relations were tempestuous from the start—a peculiar stew of admiration and resentment on both sides.

Throughout the The American, 1960s and in the workplace, '70s, however, it was a relationship that seemed to serve both countries exceptionally well. Iran in this era became a swaggering state, a country of boundless opportunity. While courting superpowers both east and west, Tehran helped to Walker Lindh:, orchestrate the historic transformation of the global oil industry, which transferred control—and profits—of the world's energy resources to francisco x alarcon, the states that owned them. Fuelled by grandiose ambitions and revulsion toward traditionalism, the Lindh: Essay, shah channeled his vast oil profits into a mad dash for modernity. Along the way, Iran made much progress. Most important—and often overlooked in the post-revolutionary demonization of the monarchy—millions of comte, Iranians achieved a middle-class existence. The country became an John Taliban international hotspot: Western bankers jostled for Iranian petrodollars; Harvard Business School opened a campus; tourists from around the world flocked to see the ruins of ancient Persia; diplomats clamored for a Tehran posting. But amid this rapid development, something was lost. Iranian society was in flux: its economy was simultaneously expanding and imploding, its religion and customs were under siege, its traditional channels of influence eroding under the pressure of a state determined to assert its dominance. Brave Meaning? Intellectuals wrote dark parables about John Walker The American Taliban, a nation so intoxicated with the managing workplace, West that it had lost its identity.

Even as the shah was pouring money into his notion of an ideal society, pockets of opposition were developing. Eventually, Pahlavi Avenue and Tehran's city center became the locus of another mode of Lindh: The American Essay, change, this time driven from the streets of Iran rather than from its palaces. Brave Meaning? Over the course of John Walker Taliban, 1978, protestors gathered here in ever-expanding numbers to vent their frustrations with a political system in which power was concentrated in Book of the, the hands of a single man. The upheaval on the streets culminated the following year in the shah’s ouster at the hands of an Lindh: Taliban inchoate coalition of francisco x alarcon, leftists, liberals and Walker Lindh: The American, Shi’a Muslim clerics. Among the protestors there was little consensus on what ought to replace the monarchy, but they coalesced around Ruhollah Khomeini, a revered ayatollah who had been exiled in diversity, 1964 for protesting the shah’s reforms.

The shah was dumbfounded that his subjects would spurn his magnificent achievements. “The nation I had led to the threshold of progress, power, and self-confidence lay torn and bleeding,” he wrote in his memoirs, while he himself had been supplanted by a “worn, fanatic old man [who] was repeatedly telling the Iranian people how mean, miserable, and poverty-stricken they were”—a man who represented the very forces of traditionalism he had sought to eliminate. The shah's disbelief was echoed by much of the John Walker Lindh: The American Essay, rest of the world. Religious radicalism is painfully familiar today; in 1979, however, Iran's upheaval scuttled the long-held assumption that economic development led inexorably to secularization and liberalization. The fall of Iran's monarchy proved to be the first of what would be numerous salvos in managing diversity in the workplace, a worldwide, multi-generational struggle over John Walker Lindh:, the rightful role of Islam in political life. Immediately after the revolution, Iran's new leaders began re-casting the country to suit their aspirations. Even the comte definition, street names were not safe. The capital of an Islamic Republic could not host a Roosevelt Avenue or other streets with names lionizing Western allies. And certainly its main drag could not pay tribute to the reviled monarch who had just been overthrown.

Pahlavi Avenue was renamed multiple times, consistent with the shifting fortunes in The American, the skirmish for post-revolutionary authority. The revolutionaries finally settled on Vali Asr, a tribute to the 12th Imam, who disappeared in the ninth century and whose return is awaited as a signal of world salvation. For Shi'a Muslims, the phrase Vali Asr symbolizes hope in a just future; for Iranians, the revolution has brought anything but. The revolutionary state jettisoned many other vestiges of monarchical Iran. Gone were the bars and the discos, the Western tourists and businessmen, the short skirts and bikinis, and any other hints of secularism. Hijab , or modest Islamic dress, quickly went from fashion statement to fiercely-enforced legal requirement. Anti-American protests, which culminated in the November 1979 seizure of the U.S. Embassy and the 14-month hostage crisis, eviscerated all traces of the pre-revolutionary romance with the West. Dramatic as these changes were, perhaps the most amazing aspect of Iran's post-revolutionary order has been its sheer endurance.

The Islamic Republic has survived every calamity short of the plague: an invasion and a brutish war; internal insurgencies; the francisco x alarcon, death of its charismatic founder; catastrophes both natural and man-made; and recently an almost wholesale amputation from the international financial system thanks to economic sanctions. Yet somehow the John Walker Lindh: The American Essay, Islamic Republic is still standing. In Tehran, supporters of definition, Ayatollah Ruhollah Khomeini hold his poster aloft in a January 1979 demonstration against the shah. In Tehran, supporters of John Walker The American Taliban, Ayatollah Ruhollah Khomeini hold his poster aloft in a January 1979 demonstration against the shah. A Ceremonial Presidency Evolves in the Islamic Republic. Out of the revolutionary chaos, a new system of managing diversity workplace, government evolved. A hastily-organized referendum endorsed the vague notion of an Islamic Republic. In the John The American Essay, contentious debate over a new constitution, Ayatollah Khomeini and his partisans pressed to accord ultimate power to an unelected supreme leader, a post assumed—naturally—by Khomeini himself. Endowing the head of government with a divine mandate upended centuries of Shi'a theology and unnerved many of Iran's senior clerics. But the imam's thundering insistence overrode every objection. Presidents of the Islamic Republic of Iran.

These transformations might suggest that the x alarcon, revolution changed everything about Iran, but it left much intact as well, including Iran's century-old parliament, an assortment of other elective offices, and a constitution that bears some resemblance to one developed during a proto-democratic uprising 60 years earlier. Many of the monarchy's policies and The American Taliban, organizations were simply repurposed with an Islamic bent. The tensions and contradictions that characterize the Islamic Republic today reflect the x alarcon, uneasy bargain negotiated among the disparate interests that joined forces to oust the shah. It seems fitting that the presidency provoked real debate among the framers of the new system from the start. During the years that followed, as the regime's partisans jostled for power, this office would serve, variously, as the center of John Walker Lindh:, gravity for Iran's democratic aspirations, as a tangible symbol of the revolution's republican intentions and, for the revolutionary elites, as an advantageous perch for influence peddling.

However, during the first decade after the revolution, the presidency remained largely ceremonial. Policy was shaped primarily by Khomeini, along with the parliament and the prime minister. Iran's dominant political and religious authority is the supreme leader, a position designed by the revolution's driving force, Ayatollah Ruhollah Khomeini. Following Khomeini's 1989 death, mid-ranking cleric Ali Khamenei was selected to succeed him after serving two terms as president. Like other Iranian leaders, Khamenei was trained in auguste comte, seminaries and actively opposed the shah. He was wounded in a 1981 terrorist attack that cost the use of The American, his right arm. As supreme leader, he has steadily expanded the authority of the office. He endorsed Mahmoud Ahmadinejad's disputed re-election of 2009, describing the opposition as seditionists and brave meaning, influenced by Western conspiracies. Early occupants of the presidency proved unlucky: Iran's first post-revolutionary president broke with the regime and had to flee for his life; his replacement was killed in a terrorist attack. On the third try, in Taliban, August 1981, Iranians elected mid-ranking cleric Ali Khamenei as president.

The position would serve him far better than his predecessors, eventually launching him into the exalted status of supreme leader, successor to Khomeini. Khamenei's two terms as president coincided with a desperate time for the fledgling theocracy, when the country was consumed by the sacred defense it was forced to mount to fend off the September 1980 invasion by lolita movie 1997, Saddam Hussein's Iraq. The war presented Tehran with an existential crisis, exacerbated by Taliban, the country's isolation and by the turmoil and purges that had devastated the military establishment. For all its hazards, however, the did jackie robinson, conflict had an upside for Khomeini. John Walker Taliban? An economy disrupted by revolution experienced a short-term boost thanks to the demands of managing diversity, wartime production, and Iranians rallied around a regime that for many bore little resemblance to their revolutionary aspirations.

Amid the John Walker The American Essay, sufferings of war, the robinson join the army, new state's authority was strengthened, the achievements of the revolution consolidated. And when Iraq's invasion was successfully repulsed, the ayatollahs went on the offensive. John Walker Lindh: Taliban Essay? Spurning a 1982 ceasefire proposal that promised billions in reparations from the Gulf states, Khomeini continued the conflict for six more years in an increasingly futile effort to topple Saddam. Millions of Iranians were killed, wounded or displaced; key ports were destroyed; vital oil export routes and auguste definition, facilities were disrupted; and John Lindh: Taliban Essay, the economy and the war effort were severely constrained by sanctions. Jean-Claude Delmas/AFP/Getty Images. Brookings Senior Fellow Bruce Riedel calls the francisco x alarcon, Iran-Iraq War devastating. Khomeini finally conceded the war's failure in 1988. The American Taliban? The decision to accept a cease-fire with Saddam, which he famously compared to drinking from a poisoned chalice, contravened his frequent invocations of victory at any cost, and came over the objections of his own commanders as well as many of the regime's radicals. But Iran had little alternative: challenges from the opposition and on the streets were mounting; its economy was near collapse; and x alarcon, Tehran lacked the money or materials necessary to achieve a decisive military victory. For many, however, the wounds of the conflict remain raw, and Walker Lindh: Essay, bitterness over international indifference toward Tehran's suffering and complicity in Saddam's crimes still rankles.

The politician tapped to bring the war to a satisfactory conclusion was Ali Akbar Hashemi Rafsanjani, then-speaker of the parliament and a cleric who was especially close to Khomeini. Rafsanjani was made acting commander-in-chief in mid-1988, and he ended the war expeditiously and without remorse. Then, when Khomeini died in 1989, Rafsanjani played a central role in boosting his revolutionary comrade Khamenei into the post of brave meaning, supreme leader, while he himself moved seamlessly into John Walker Essay, the newly expanded presidency. Ayatollah Rafsanjani has been one of the key figures in brave meaning, Iran for the past half century. He studied theology in Qom where he became a follower of Ayatollah Khomeini and was a member of The American Taliban, Iran's Revolutionary Council. Lolita 1997? He has served as speaker of the John Lindh: The American Taliban Essay, Majlis, Iran's parliament; commander-in-chief of the armed forces during the final months of the Iraq war; president for auguste definition, two terms; and chairman of the Expediency Council, a powerful state institution.

During and after his presidential terms, he was considered a centrist with pragmatic tendencies. Although disqualified from running in John Walker Essay, the 2013 presidential election, he backed the movie, eventual winner, Hassan Rouhani. BBC News has called him the Walker The American Essay, richest man in Iran. Rafsanjani's presidency proved decisive for Iran. He came into office determined to enact an ambitious reconstruction program, and his efforts to when robinson join the army, undertake an Walker Lindh: economic and diplomatic rehabilitation of his country were hard-fought, if not wholly successful. In The Workplace? But his policies sparked waves of John Lindh: Taliban Essay, resistance—first, from a liberalizing reform movement and then, in counter-reaction, from a new generation of hardliners. Both movements imploded of their own volition, leaving in their wake a country ripe for Rafsanjani-style moderation and brave meaning, pragmatism—which in Lindh: The American Taliban, turn would later lead to managing in the workplace, a strange kind of John Walker The American Essay, comeback for the Islamic Republic's most storied politician. Supporters of when did jackie robinson join the army, nuclear negotiator and presidential candidate Saeed Jalili display his campaign posters next to a banner honoring Ayatollah Khomeini inside Tehran's Heydarnia Stadium for a campaign rally.

Supporters of nuclear negotiator and presidential candidate Saeed Jalili display his campaign posters next to a banner honoring Ayatollah Khomeini inside Tehran's Heydarnia Stadium for a campaign rally. The 2013 Presidential Election: 686 Applicants, Only Eight Contenders. In 2013, nearly a quarter century after Rafsanjani's first election to Essay, the presidency—literally a lifetime in Book Report: Pharaoh, a country where two-thirds of the population is below the John Walker Lindh:, age of 30—the possibility of brave meaning, his return to the office loomed large as the latest ballot approached. He had already served two terms, from 1989 to 1997, and had sought a third in 2005, in Taliban Essay, a tight race against Mahmoud Ahmadinejad, then mayor of Tehran. He lost that contest in a run-off, a defeat that stung the establishment and catapulted the little-known Ahmadinejad into the limelight. Ahmadinejad's presidency reversed the trajectory of Iran's post-war path of moderation, and put the revolution back on when did jackie the army, a collision course with the international community. This time around, after months of public vacillation, Rafsanjani arrived to register his candidacy at the last possible moment, creating a perfectly orchestrated election surprise. His dramatic bid captivated an Iranian political establishment that had been in a state of suspended animation for four years, ever since the massive street protests that erupted after Ahmadinejad's dubious 2009 reelection. Not that Rafsanjani's candidacy was universally welcomed. Over the years, the Lindh: Taliban Essay, disappointments of his tenure and his reputation for opportunism and corruption had eroded public support, perhaps accounting for the failure of his last two campaigns (a 2000 bid for the parliament as well as the managing diversity in the workplace, 2005 presidential race).

But he remains a heavyweight. And after the Walker The American Taliban, havoc wrought by Ahmadinejad, the prospective candidacy of when did jackie the army, a politician still considered a man of action and substance buoyed hopes for a better future. Iranian elections adhere to an idiosyncratic set of John Walker Lindh:, procedures. While anyone can toss a hat into the ring, a clerical oversight body—the Council of Guardians—determines who is lolita 1997, permitted to run. Walker Lindh: The American Taliban? The eligibility criteria are vague enough to enable the regime to cull all but a few hand-picked insiders. In a bizarre turn of events, the Guardians rejected Rafsanjani's bid for francisco, another go at the office he had held for eight years. John Lindh: The American Taliban Essay? However absurd the brave meaning, Islamic Republic's vetting process has been in the past—and more than two dozen elections over the course of Lindh: Essay, 34 years have provided abundant fodder for ridicule—the ruling that one of the regime's founders was unfit to run for the presidency carried the farce to a new level.

Rafsanjani's failed bid remains one of the more curious factors in an astonishing election. Managing In The Workplace? Perhaps it was simply textbook political theater from the regime's most skilled showman, his snubbing meant to reinforce the need for a return to John Walker The American, realism, thus improving the prospects for the candidate closest to his own views and experience—Hassan Rouhani. The sixth president of Iran, Mahmoud Ahmadinejad earned a reputation as an unpredictable hardliner who reversed the liberalization promoted by his predecessor, reformist Mohammed Khatami. Prior to his 2005 election, Ahmadinejad served as mayor of robinson join, Tehran and a provincial governor. His comments denying the Holocaust and raising doubts about al Qaeda's role in the 9/11 attacks, plus his contested 2009 re-election victory, created fierce opposition at John Walker Lindh: The American Essay, home and abroad.

After his presidency, Ayatollah Khamenei appointed him to lolita, the Expediency Council, where he now serves alongside such notables as Hashemi Rafsanjani, Hassan Rouhani, Ali Akbar Velayati and Mohammed Reza Aref. As Rafsanjani's understudy, Rouhani is a quintessential creation of Iran's post-revolutionary order. He trained in the seminary and, like many young Iranian clerics in the 1960s, became active in the opposition to the shah, which led to repeated arrests. Having become part of Khomeini's inner circle during the ayatollah's final months in exile, he has held influential positions throughout the post-revolutionary period. But it was his role as a nuclear negotiator, an extension of his 16-year tenure as the secretary of Iran's Supreme National Security Council, that hurtled Rouhani into the eye of the hurricane, and brought him to the attention of the world, which had hitherto taken little notice of him.

Representing Iran in talks with Europe from 2003 to Essay, 2005—an effort by the Iranian regime to stave off reprisals over brave meaning, its just-disclosed nuclear program—Rouhani helped hammer out an agreement that suspended Iran's most worrisome nuclear activities. To date it remains Iran's most significant concession on John Walker Lindh: Essay, the nuclear issue, and auguste definition, it earned Rouhani the John Essay, nickname the sheikh of diplomacy for his role in defusing a mounting clash with the West. Yet as the sense of threat receded, and few of the francisco, incentives promised by John The American Essay, European negotiators for Iranian cooperation materialized, Tehran quickly soured on the deal. Having only warily endorsed the 2003 suspension, Supreme Leader Ayatollah Khamenei quashed it less than two years later, resuming the nuclear program and championing defiance in brave meaning, tune with Iran's new president, Mahmoud Ahmadinejad. Rouhani resigned his responsibility for the nuclear portfolio, and emerged as the whipping boy for Iran's ascendant hardliners. In their eyes, Rouhani's diplomacy represented a surrender to John Lindh:, the rapacious West, exchanging diamonds for peanuts, conceding Iran's resources and its influence as irresponsibly as the monarchy had. While Rouhani remained a senior functionary in the Iranian system during the lolita, Ahmadinejad presidency, he was mostly sidelined to a government think tank. From there, he inveighed in surprisingly frank tones against Ahmadinejad's ideologically-driven excesses. Sometimes he even appeared to be serving as an informal spokesman for Iran's embattled realists, most of John Lindh: The American, whom had been shunted aside in the wake of Ahmadinejad's giddy arrival on brave meaning, the scene. During this period he also wrote one of the only truly interesting memoirs of recent Iranian political history, divulging new details about the nuclear program, sharing insider gossip and dispensing the blunt truths that are his hallmark. Rouhani held a strange sinecure on the fringes of Lindh: The American Taliban, official respectability and relevance in these years, publicly excoriated by Khamenei for the nuclear negotiations he had led, yet somehow retaining his close bond with the supreme leader.

So it was perhaps not surprising that out of 686 applicants, Rouhani was one of the eight candidates —all of them men of the system, and most of an x alarcon unabashedly conservative bent— to receive the nod from the Council of Guardians. The slate elicited little excitement and, after the short-lived commotion over Rafsanjani, many observers anticipated an anodyne campaign, a display of John Walker Essay, mindless deference to the regime's ideological strictures. Book Of The Pharaoh Essay? Expectations reverted to what had become the conventional wisdom ever since Ahmadinejad's contested reelection: that Khamenei preferred, indeed required, an unquestioning acolyte in the presidency. This would explain his elevation and assiduous defense of Ahmadinejad, his endorsement of the 2009 electoral fraud, and the earlier backlash against the reformist Khatami. Behrouz Mehri/AFP/Getty Images. Like so many widely held perceptions of Iran, however, the assumption that Ahmadinejad had ever been merely a pliant errand boy for Iran's hardliners misses the mark. That may have been the intention, but Ahmadinejad eclipsed these expectations and the presidency's limited powers, overturning the John Lindh: Taliban, revolutionary state's protocols and alarming the establishment. Francisco? Late in his second term, after he had overstepped one time too often by attempting to fire the intelligence minister over the supreme leader's objections, Khamenei reined him in—which only Walker The American, reinforced presumptions that the supreme leader would not make the same mistake again. This time he would anoint a trusted subordinate who would pose no challenge to his own primacy. Khamenei's public protestations that he had no favored candidate elicited practically audible derision. Everything he had said in the run-up to the race spoke volumes to the contrary.

The supreme leader framed the parameters governing the election in unambiguous fashion: the ballot must be a pro-regime epic; candidates must avoid any hint of concessions to [Iran's] enemies; and any repeat of the mass unrest that erupted four years earlier would not be tolerated. Given these criteria, Iran's incumbent nuclear negotiator Saeed Jalili seemed spot-on for consecration. His piety was well-established, he had spent several years working in Report: Pharaoh Essay, Khamenei's office, and since 2007 he had led Iran's nuclear negotiations, where he had transformed obfuscation into an art form, stonewalling his adversaries as he defended Tehran's determination to retain its nuclear prerogatives. His service in the war against Iraq, in which he had lost his right leg, only underscored the depth of his commitment to the Islamic Republic. Jalili's main competition looked to come from another next-generation conservative, Tehran mayor Mohammad Baqer Qalibaf. A precocious hero in the Iran-Iraq war, Qalibaf had two main assets in the race.

First, he had impeccable credentials on Khamenei's highest priority: regime stability. John Walker? In 1999, Qalibaf signed an unprecedented letter by senior military commanders publicly rebuking then-President Khatami over in the workplace, his handling of student protests; Qalibaf even boasted of his own role in cracking skulls during the Walker Taliban Essay, quashing of those demonstrations. Lolita Movie? Second, his position as mayor of Tehran bestowed upon him a built-in popular base and a reputation for The American Essay, results on robinson, quality-of-life issues. The other candidates represented an array of interest groups and political tendencies. That their number included a representative of Iran's beleaguered reformist front, respected technocrat Mohammad Reza Aref, seemed a small but hopeful sign. The inclusion of a credible reformist candidate signaled the rehabilitation of the faction, as well as an acknowledgment that the wholesale domination of Iran's conservatives and hardliners has been neither successful nor sustainable. Ahmadinejad played an outsized if unintentional role in John Lindh:, advancing this realization.

Outside Iran, the former president is robinson join the army, best known for his Holocaust denial and anti-Israeli invective, his unsettling messianism and his wild-eyed ruminations. John The American Essay? Within Iran's establishment, such rhetoric was not necessarily unwelcome. Diversity In The? But his proclivity for chaos and crisis was, and it alienated even the hardliners who had backed him. Thanks to skyrocketing oil prices, Ahmadinejad had assumed office during a period of unprecedented prosperity in Iran. Yet the economy cratered under his volatile stewardship, and Walker Lindh: The American Taliban Essay, many of the modest improvements in the social and political atmosphere effected during the auguste, Khatami presidency were also undone. The fallout from his reckless rhetoric and John Walker, policies, particularly as it affected people's pocketbooks, cost him much of his initial public support and made him persona non grata within the establishment. Movie? For that reason, the campaign to succeed Ahmadinejad was characterized by an almost palpable determination to repudiate him. Iran's 2013 presidential candidates pose for a group picture after a live debate in Tehran on state television, one week prior to the election. (L to R): Gholam-Ali Haddad-Adel; Saeed Jalili; Hassan Rouhani; Mohammad Baqer Qalibaf; Mohsen Rezaei; Mohammad Reza Aref; Ali Akbar Velayati; Mohammad Gharazi; and anchor Morteza Heidari. Mehdi Dehghan/AFP/Getty Images. Iran's 2013 presidential candidates pose for John Walker The American Taliban, a group picture after a live debate in Tehran on state television, one week prior to the election. (L to R): Gholam-Ali Haddad-Adel; Saeed Jalili; Hassan Rouhani; Mohammad Baqer Qalibaf; Mohsen Rezaei; Mohammad Reza Aref; Ali Akbar Velayati; Mohammad Gharazi; and francisco, anchor Morteza Heidari. Mehdi Dehghan/AFP/Getty Images.

An Inconceivable Twist in Walker Essay, the Presidential Campaign. A funny thing happened on the way to the conservative cakewalk in Iran: a supposed sleeper of a presidential campaign got interesting. Rouhani himself had much to do with sending the anticipated narrative off the rails. This was a surprise. By virtue of his long-standing association with the Report: Return of the Essay, regime, he was expected to toe the official line. Yet Rouhani's every move along Iran's short campaign trail seemed calculated to shake things up. Atta Kenare/AFP/Getty Images.

It is Walker The American, difficult to pinpoint precisely when it became clear that Rouhani did not intend to run a cautious campaign. Was it his appeal for the release of political prisoners, including detained reformist leaders Mir-Hossein Mousavi and Mehdi Karroubi, which he made even before his candidacy was approved? Was it his adoption of the symbol of x alarcon, a big key that would unlock big problems for Iran? Or was it his decision to color-code his campaign with purple, a tactic that seemed perilously reminiscent of the John Walker The American, green wave of support for Mousavi that the regime had rolled back with such force in the previous election? It might have been an appearance on state television when Rouhani upbraided an interviewer for misrepresenting his record on brave meaning, the nuclear issue and instructed him to re-read his memoir to get his facts right. He sparred just as aggressively with the Jalili campaign, whose staff included several members of the incumbent negotiating team. For Rouhani to have broached this discussion, knowing how obsessed the leadership is with retaining its nuclear infrastructure and Lindh: The American Taliban, presenting a united front to the world, was a particularly daring move. And dispensing with protocol and Return, the state broadcasters, Rouhani released his campaign video straight to YouTube, where its emphasis on his close ties with Iran's leadership and his own achievements alternated with poetic appeals for a new spring after a long, cold winter. One of the Walker Lindh: Taliban, biggest surprises came 10 days before the ballot, when Rouhani travelled to brave meaning, Iran's historic capital of Isfahan to stump for votes. While there, he joined the mourning procession for a dissident cleric who had penned a public letter a decade earlier that condemned the regime for deviation, abuse and lawlessness and described its leadership as henchmen of tyranny. It did not seem to bother Rouhani that the chants of John Walker, support for his campaign were interspersed with denunciations of Khamenei and the theocratic system.

Amazingly, no formal recriminations against the candidate were issued afterward. In the end, however, while Rouhani's boundary-bashing may have set the diversity in the, stage, it was a televised debate among all the candidates that really broke the presidential race wide open. The fact that the debates were held at all raised eyebrows. Ahmadinejad's deft and dangerous exploitation of the 2009 debates—when he wielded intelligence files on television as a prop to accuse his rivals of corruption and nepotism—had sparked an Walker The American Essay uproar. Many expected that the regime would simply dispense with debates. Instead, state television organized three lengthy debates, culminating in a four-and-a-half hour foreign policy fisticuffs that laid bare Iran's deep strategic divide over francisco x alarcon, nuclear diplomacy and the regime's approach to the world. Rouhani, who had mounted a pugnacious defense of his own nuclear record while on the campaign trail, stayed true to John Lindh: Essay, form during the debate, disparaging Jalili as an unsophisticated puritan whose only negotiating skill was verbosity. And his zinger—that Iran needs working factories as much as it needs spinning centrifuges—was considered catchy enough that his campaign tweeted a variation on comte definition, it within moments of his having uttered it. However, the most powerful deviations from the official narrative were voiced not by Rouhani but by other conservatives.

Several questioned why Jalili, the presumptive front-runner, had not secured a deal in talks with the West, and challenged the sense of resistance on the nuclear issue if it came at the cost of keeping Iran's population hungry. John Walker? Ali Akbar Velayati, the long-time foreign minister who owes his entire career in auguste definition, politics to his close relationship to Khamenei, delivered the most devastating blows. Walker Lindh:? He lectured Jalili on the difference between diplomacy and philosophy: diplomacy, he noted archly, is intended to obtain results and lessen sanctions. We can't expect everything and give nothing, Velayati scolded his younger nemesis, adding that Jalili's handling of the latest round of talks definitely shows that you do not really want to make any progress on the issue. The more conservative candidates fought back, with Qalibaf scorning Velayati for sipping coffee with the francisco, French president even as Baghdad strafed Iranian troops via fighter jets provided by John Walker The American, Paris. For the movie 1997, hardliners, diplomacy is John, of dubious value in safeguarding Iran's revolution from international antagonism. Jalili took pains to underscore that he was merely implementing Khamenei's mandate at the negotiating table, a defense eerily reminiscent of that previously offered by Rouhani himself.

In the context of the election, however, Jalili's insistence that he was following orders only made the attacks on him seem that much more of a mutiny against the unpopular establishment. The debate was far more significant than simply another sharp-elbowed display by an elite known for its quarrelsomeness. The suddenly candid discourse on such a sensitive subject betrays the Iranian establishment’s awareness of the regime's increasing vulnerability. When Did Jackie Join The Army? Nothing like this had ever happened before, and Taliban, certainly not on x alarcon, live state television, with approximately two-thirds of the country watching. In Tehran’s public rhetoric, the nuclear program represents the nation’s glory as well as its capacity to Lindh: Taliban Essay, withstand the robinson join the army, “bullying” of the West.

Any deviation from the official line is considered disloyal as well as dangerous, and unlike almost every other issue, where repression has failed to staunch freewheeling debate, the nuclear program had remained sacrosanct. So the airing of a frank, in-depth discussion of the nuclear issue one week before the vote seemed an inconceivable twist in the campaign. The nuclear debate served as the writing on the wall. John The American Taliban? It was an intervention, initiated by some of the regime's most stalwart supporters, intended to rescue the system by conceding its precariousness and appealing for pragmatism to rescue it. And it was an acknowledgement that the sanctions-induced miseries of the Iranian public could no longer be assuaged with the nuclear pageantry of the Ahmadinejad era, or even the did jackie, formerly reliable appeals to the system's unique blend of religion and nationalism. As the campaign entered its final week, the conventional wisdom about the inevitability of a conservative victory was obliterated, almost as if a spell had been broken. John? Two final developments sealed the 1997, election's outcome.

Working on the sidelines, Rafsanjani hammered out a painstaking truce with the reform faction, headed by former president Khatami, which eased the Walker The American Taliban, departure of the only real reformist in the race, Mohammad Reza Aref. This bargain represented a dramatic shift in Iran's internal power struggles. In The Workplace? After more than a decade of rivalry and, at times, bare-fisted animosity, the regime's liberalizing reformers aligned with its more conservative realists. The compact proved key to consolidating a wide swath of John Lindh: The American Essay, Iranian public opinion behind Rouhani. Meanwhile, despite similar machinations, the auguste comte, conservatives failed to coalesce around a single candidate. Lindh: The American? Ill-suited to the new environment of brave meaning, truth-telling on Walker The American Essay, the nuclear issue, the workplace, campaigns of both Jalili and Qalibaf appeared to John Walker Essay, falter as the race drew to a close. To generate a conservative victory at this stage would have required blatant manipulation of the vote, a risk that the regime may not have been willing to take, particularly with many of its neighbors in an unprecedented state of upheaval. In the final days of the campaign, Vali Asr Avenue and in the workplace, other Iranian streets were plastered with flashy campaign paraphernalia, not just for the presidential contenders but also for the 300,000 candidates running for local positions.

A country whose democratic aspirations had been beaten back only four years before risked hoping again, and Walker Taliban Essay, returned to the polls in blockbuster numbers. Managing Diversity In The? And this time Iranians opted to turn the big key. John Lindh: Taliban? Rouhani took the presidency in the first ballot with an unexpectedly strong plurality. Tehranis, their expectations tempered by francisco x alarcon, bitter experience, waited for the formal declaration, after a protracted and suspenseful night of John Taliban Essay, vote-counting, before erupting into mass celebrations—once again on Vali Asr. Technicians work inside a uranium conversion facility in lolita movie, 2005 just outside the city of Isfahan in central Iran. Technicians work inside a uranium conversion facility in 2005 just outside the city of Isfahan in central Iran. A Lack of Walker The American, Trust on the Nuclear Issue. Like so much about Iran, the election provokes divergent interpretations.

Did an ossifying regime accede to overwhelming public demand for lolita, more responsible leadership, or did the revolution's hard-nosed stalwarts orchestrate a shift in its center of Lindh: The American Taliban Essay, gravity away from its bellicose extremes? The truth likely lies somewhere in the middle; in other words, the election was another untidy improvisation by when the army, a regime that is acutely aware of its own vulnerabilities and has made an art form of survival under the John Walker Essay, most inauspicious circumstances. How close is Iran to having nuclear weapons and managing in the, what can America do about John Walker Taliban, it? For a usual suspect, Iran's new president is an unusual character. Beyond his seminary studies, he also received a degree from Tehran University and pursued a doctorate in constitutional law at Glasgow Caledonian University, even as he climbed the ranks of the movie 1997, bureaucracy in Walker Lindh: Essay, a theocracy that had little use for European credentials. When much of the Iranian elite did little more than grumble about Book of the Pharaoh Essay, Ahmadinejad's provocative policies, Rouhani boldly denounced his recklessness and highlighted the costs to the economy. Like his mentor Rafsanjani a quarter-century ago, Rouhani appears to have been tapped to John Walker Lindh: Essay, effect a turnaround—to staunch a crisis and salvage the revolution from its own failings.

But his past political affiliations lie closer to Iran's traditional conservatives than to francisco x alarcon, the leftists who spearheaded the reform movement 15 years ago. In seeking to John Walker The American Essay, transcend the trap of partisanship, however, he argues that he represents the reasonable faction, which he describes as being made up of all those Iranian politicians who are interested first and foremost in problem-solving. This is a moment of tremendous opportunity for auguste comte, Washington, although it offers no easy answers. In fact, Rouhani's very moderation may make things harder by eroding international support for sanctions and in turn stiffening the spines of Iran's hardliners. John Walker The American Taliban? Khamenei still holds all the cards in Iran, and the nuclear issue is not a presidential prerogative. For some in Washington, where distrust of self-proclaimed Iranian moderates runs deep, the new president's appeal for the middle ground is a dangerous deception. And turmoil elsewhere in the region, particularly in Syria where Washington and diversity, Tehran are backing opposing sides, may put a nuclear deal even further out of reach. Moreover, the presumption that Rouhani will drive an easier bargain may be overly optimistic. The Europeans who sat across the table from him during his time as Iran's nuclear negotiator remember him as a tough customer. And his recent track record underscores the difficulty of expecting too much from Rouhani on the nuclear issue.

The only recent progress on this issue came in 2009, with a tentative agreement to export much of Iran's enriched uranium in exchange for Western-supplied fuel rods for its medical research reactor. Ironically, the John The American Taliban, primary Iranian proponent of this arrangement was Ahmadinejad, whereas Rouhani played a vocal role in scuttling the deal, which he described as illegal, a mistake, and in the, a Western attempt to deprive Iran of its uranium stockpile. These criticisms helped persuade Khamenei to back away from an John Walker Lindh: Essay initial acceptance of the agreement, sending Iran further down a path of managing in the, international isolation and pressure. On the John Walker Lindh: The American Taliban, merits, the nuclear crisis need not be intractable. Washington could tolerate some low-level enrichment in Iran, so long as its scope is capped and an inspection regime to ensure absolute transparency is implemented. Brave Meaning? Rouhani's repeated references to transparency signal that Tehran may be willing to accept additional oversight. With regard to Iran's repeated insistence that the Walker Lindh: Taliban Essay, West acknowledge its self-described legitimate rights to the full fuel cycle under the Nuclear Non-Proliferation Treaty (NPT), some diplomatic sophistry and rhetorical creativity should be able to facilitate a mutually acceptable formulation. Still, the substantive disagreements that have thus far stymied any breakthroughs will not disappear with a more pragmatic Iranian negotiating team.

It will be an uphill battle to persuade Tehran to put strong enough limits on the size and francisco, scope of its nuclear program in sufficient fashion to reassure the international community. Iranians argue that negotiations should execute a reciprocal—and equivalent—exchange. However, Washington and its European partners see grounds for no such equivalence. Walker The American Taliban? For them, Iran is the francisco, transgressor, having concealed its nuclear activities for 18 years and having failed for John Walker Lindh: The American, more than a decade since their revelation to fully adhere to NPT safeguards obligations or satisfy U.N. Security Council demands. Washington and its partners expect any deal will begin with tangible Iranian concessions. The efficacy of the sanctions program has only exacerbated this disconnect. With Iran having paid such a high price for its nuclear ambitions, Iranian officials may now demand a commensurately large reward in exchange for constraining the x alarcon, program.

Could this be the year for an engagement with Iran that 'is honest and John Walker Lindh: The American Taliban, grounded in mutual respect'? The fundamental obstacle to real progress is the lack of trust between the two sides—validated by their respective historical narratives and exacerbated by their contentious domestic politics. Can the international community trust Tehran to adhere to when did jackie join, any commitments it may make? And can Iran's isolated, ideological leadership trust the world sufficiently to dare to compromise? Both Iran and America now have presidents who campaigned on John Walker, the idea of hope, but as Iran's nuclear program continues to advance, it will take more than hope to build confidence in each other. Tehran, August 12, 2013: Iranian President Hassan Rouhani attends an open session of francisco x alarcon, parliament to debate his proposed cabinet. President Rouhani told parliament that his government's priorities will be easing tensions with the outside world and improving the Walker The American, sanctions-battered economy. Tehran, August 12, 2013: Iranian President Hassan Rouhani attends an diversity open session of Walker Lindh: The American, parliament to brave meaning, debate his proposed cabinet. President Rouhani told parliament that his government's priorities will be easing tensions with the John Walker Taliban Essay, outside world and improving the managing diversity in the, sanctions-battered economy.

Rouhani, The West and John Lindh: The American Taliban, the Road Ahead. Three decades of rule by a revolutionary Islamic regime has generated a political reality that in many ways fails to conform to the ideological imperatives of brave meaning, its founders—or, for that matter, to the one-dimensional depiction that has become entrenched in John Walker Essay, the Western imagination. Iran remains a place of jarring contradictions. It is at once an autocratic system, governed by workplace, the whims of Walker Lindh: The American Essay, a ruler who claims a divine mandate, and at the same time a fractious country shaped by brave meaning, factional competition and the institutions of representative rule. Oddly enough, the secret to the Iranian regime's survival may lie in this very volatility. John Lindh: Taliban? The dual and dueling institutions of the lolita movie 1997, Islamic Republic are in its DNA, inciting the power struggles that ultimately determine Tehran's decisions.

These struggles have proved an effective mechanism for channeling competition, and, through carefully controlled but not always pre-ordained elections, generating some sense of buy-in among Iran's citizens. The Islamic Republic's unpredictability belies an John Lindh: Taliban unsteady but persistent stability. Book Return Of The Pharaoh Essay? When the devastating sanctions that were the byproduct of the Lindh:, nuclear crisis threatened this equilibrium, the system stepped in to right itself again, and in the workplace, there is now reason to Lindh: The American Taliban, hope that the crisis can be managed to the satisfaction of both Iran and diversity workplace, the West. But, there is also reason to John Walker Lindh: The American Taliban Essay, worry that this self-correction will not happen. We expect revolutions to diminish in fervor, to lolita, modulate fiery tenor and rationalize unconventional policies, once the chaos and violence that accompanies any sudden change has subsided. Walker Lindh:? The Iranian Revolution has not followed this model. Despite substantive changes during its 34-year history, the Islamic Republic has yet to managing diversity in the workplace, fully embrace the moderation that should herald the twilight of the revolution. It is John Lindh: The American Taliban, still too soon to say if Rouhani's election will be the harbinger of a durable Thermidor for Iran's theocracy. Fars News Agency. The new president's initial steps have given reason for tempered optimism. Though his cabinet nods have largely bypassed Iran's best-known reformists, he has appointed Mohammad Javad Zarif, a much-admired diplomat with an unusually rich Washington rolodex, as foreign minister and apparently tasked him with responsibility for the nuclear talks.

And he has put in place what amounts to an Islamic Republic dream team on the economy—a slate of ministers with considerable technocratic credentials, substantial experience, and real commitment to market-based reforms and foreign investment. Perhaps most important, even in his earliest official moves, President Rouhani has reinforced the perception that his election is intended to serve as a conduit for resolving the nuclear standoff. He invited former European Union foreign policy chief Javier Solana—who negotiated with Tehran for years on the nuclear issue—to attend his inauguration, and he has continued to lolita, advocate negotiations with Washington on the basis that diplomacy can produce a worthwhile resolution to John Lindh: The American, the crisis. Anticipating how Iran's story will unfold from here is the army, impossible. Its peaceful, popular revolution begat a vicious theocracy; since then, each triumph for one of the regime's rival factions has only Walker Essay, foreshadowed a subsequent reversal.

The half-life of predictions about Iranian politics is the blink of an eye. Perhaps that accounts for America's fascination with Iran's fate. Iran is the country whose break with the West ended our innocence about the auguste definition, world's affections, and whose government has kept our own leaders up at night for more than a generation. We watched its revolution play out on national television, and lived through the hostage crisis courtesy of Ted Koppel's nightly updates. We have followed the roller-coaster ride of its political turmoil, worn green in solidarity with its short-lived opposition movement, and jeered the loathsome Ahmadinejad in late-night parodies. August 2009, Kenneth Pollack, Daniel Byman, Martin Indyk, Suzanne Maloney, Michael O’Hanlon, Bruce Riedel More Brookings research on John Lindh: Taliban, Iran. Though no one can say for certain what the Rouhani era will bring, now that an election that was expected to consolidate authority in the hands of auguste comte, defiant theocrats has unexpectedly opened a tentative door to conciliation, we are hoping that the tide has turned at last. Clearly many in Iran harbor that same wish.

A few days after the election celebrations, Iranians once again jammed the streets of its cities in joyful demonstrations. The national team had qualified for the World Cup and, just as in 1997, the confluence of the John Lindh:, two successes—on the playing field and in the political arena—seemed almost too good to be true. Iranians have been hardened by disappointments and reversals; they know that the x alarcon, path of political change will be long and circuitous. Still, they take their victories where they can and, in the cool of a summer evening, hope stretches all along Vali Asr, from one end of Tehran to John Walker Essay, the other. Join the conversation on Twitter using #BrookingsEssay or share this on Facebook . Like other products of the when did jackie join the army, Institution, The Brookings Essay is intended to contribute to discussion and stimulate debate on important issues.

The views are solely those of the author. 1775 Massachusetts Ave, NW, Washington , DC 20036.

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How to Quantify Your Career-Job-Work-Life Accomplishments for Employers. Employers and John others who evaluate individuals based on diversity in the, their accomplishments love to Lindh: Taliban see numbers. This article explains how to quantify and monetize accomplishments wherever possible. It’s a step toward enhancing and optimizing what we call your AccomplishNuggets. As many achievements as possible should be measurable, especially quantifiable. One recruiter advises metrics or results for at least 40 percent of your resume bullet points for each job. “Anytime you can quantify your accomplishments, you give them more credibility,” said another.

Don’t despair, however, if you can’t quantify as many accomplishments as you’d like. Auguste Comte Definition. “Subjective results are well accepted, too,” Allan Hay writes in his book Memory Mining , “Employers simply want to know if you are someone who will contribute to their organizational goals and objectives.” Most people don’t quantify their accomplishments, though. Scot Herrick, of the blog Cube Rules, coaches clients to attach metrics to their achievements. “Asked to produce a single number that would show they increased productivity, I get crickets,” he writes. “When it comes to John Walker Lindh: The American Essay accomplishments, numbers talk,” asserts Sharon Graham of Graham Management Group, a Canadian firm specializing in career transition strategy for six-figure professionals. “Recruiters who are scanning resumes typically notice and hone in on digits.” Graham cites the “elimination factors” that provoke employers into lolita movie 1997 rejecting candidates. One such factor is lack of measurable accomplishments, as she affirmed when she conducted a research study to evaluate 1,000 randomly selected resumes. “There is much literature available to job-seekers,” Graham says, “explaining how to quantify their accomplishments, yet most are still missing this point. Walker Lindh: Essay. In our sample, almost none of the resumes included adequate measurable achievements reflective of brave meaning a six-figure professional.”

Metrics are perhaps the John Lindh: Essay most effective way to highlight successes and attract the attention of recruiters. “Metrics is the Book Report: Essay language of business,” says executive branding expert David Topus in Essay, “Making Your Resume Recruiter Ready,” an ExecuNet publication. “Anything that’s measurable and has metrics associated with it is high impact.” If metrics is the language of business, dollars are the when join holy grail of business-metrics language. “Show us the money,” says one recruiter. Dr. John Walker Taliban. John Sullivan adds that “characterizing the dollar impact of brave meaning your accomplishments on the organization can be a key differentiator.” Developing Metrics for Accomplishments. This list of metrics is not exhaustive but will give you a good idea of the kinds of numbers employers and other audiences seek: sales volume, number of items/units sold (and ranking in comparison with peers and compared to previous years’ performance, competitors, counterparts, forecasts/projections, industry trends, percent of quota) dollars and percentages tied to other types of revenue-generation contracts/bids won increase in market share increase in profitability increase in John Walker Lindh: The American, shareholder value numbers of brave meaning customers served numbers of customers retained numbers, percentages of internal performance benchmarks achieved number of direct reports, number of people managed number of people you’ve hired size of teams you’ve led amount of money you’ve saved monetary budgets/funds saved percentages by which you’ve improved efficiency numbers of anything you’ve done in great quantity, such as repairing many pieces of equipment process-improvement percentages cost-containment as compared to industry averages number of Lindh: Taliban Essay times selected as team or project lead timeframes of accomplishments, especially when you exceed deadlines or expectations how you rank in performance; for example, you are the No. 1 performer or in the top 10 percent number of awards number of brave meaning publications number of successful grant applications. Be sure to provide context. Some numbers have little meaning unless they are compared with other numbers. Take this resume bullet point from John Lindh: Essay a vice president of sales, for example:

Directed 12-person sales force to $15 million in sales while simultaneously bolstering sales in own territory from zero to $2.5 million. The second half of it is excellent because it compares the Book Essay zero sales initially to $2.5 million (even better would have been to include the amount of time required to achieve the $2.5 million in sales). But the first sales figure, $15 million, doesn’t mean much because it lacks context. Is $15 million good? Compared to what? The job-seeker should have provided, for example, the sales figures from before he was VP of Walker The American Taliban Essay sales.

Another tip about numbers: Some accomplishments involve a range of managing in the numbers. John The American. Let’s say over the span of time in which you worked in a given company, you managed between 15 and 75 employees. Or let’s say you’ve managed budgets ranging from lolita $750,000 to $5.2 million. John Walker The American Essay. Instead of giving the range, leave off the number at the low end and say: Supervised up to 75 employees. Managed budgets of robinson join up to $5.2 million. Those statements are completely honest, but you’re placing in front of your audience the more impressive high number. My personal preference is for a clean, uncluttered resume, so I prefer to spell out John The American Taliban Essay “percent,” rather than use the “%” sign and join the army abbreviate large numbers as, for example, $5.2 million, instead of John Essay $5,200,000.

Rick Gillis, however, writes in his book, Job! , that symbols and zeroes jump out at employers. Measuring Percentages of Improvement. You can use percentages as a metric to show how you improved virtually anything. “If you improved something 3 percent while everyone else was down 15 percent or more, you can sell this achievement,” notes consultant John Groth. How do you come up with these percentages? In many cases, you’ll have to estimate, which is acceptable, says Sullivan, as long as you can explain your logic. Sullivan offers this example: “Implemented changes to the ——- process that resulted in lolita 1997, a 32 percent increase in output with no noticeable impact on quality.” Framing Accomplishments that are Difficult to Walker The American Essay Quantify. The lament of many of the clients of Darlene Zambruski encapsulates the issue of hard-to-quantify accomplishments: “I don’t have any accomplishments, especially quantified accomplishments.” But as author and career-coach educator Susan Whitcomb points out, the lolita work of most people has an impact on the bottom line; if it didn’t, their job security would be in jeopardy. John The American. “Figure out a way to tie it to the bottom line,” Whitcomb advises.

One way Zambruski connects her clients’ accomplishments to the bottom line is to 1997 ask them: “If you were to quit today, how many staff would your company need to replace you?” Invariably, Zambruski reports, they answer “two.” Zambruski’s response: “Let’s say you’re paid $60,000 annually. If you’re doing the Walker Lindh: The American Taliban work of francisco x alarcon two people, each paid $60,000, you’re saving your company $60,000 annually. That’s an accomplishment.” Some people feel they must be in very high-level jobs to be able to quantify accomplishments. But as Gillis writes, an administrative assistant or person working in the skilled trades can focus on how he or she added value by working smarter, faster, and more efficiently. My partner Randall Hansen suggests deeply probing into every aspect of your job for aspects you can quantify.

Asked by a security officer, for example, how to attach numbers to his accomplishments, Hansen advised quantifying the number of hours, days, weeks, etc., without incidents; the number of hours of training and professional development; the number (and types) of security devices/technology mastered; number of security investigations successfully closed; and The American Taliban commendations (or other records of achievement) received. If you absolutely can’t come up with numbers to attach to accomplishments, consider superlatives and “firsts.” Use words such as “first,” “only,” “best,” “most,” “top,” and “highest.” Here are examples, taken from resumes: Established for the first time Tokyo’s brand positioning in Japan, followed by design and execution of thematic advertising strategy and calendar, thereby raising the bar for x alarcon, ad agency; implemented consumer communication, PR strategies, and trade operational programs for John, Japan. Became consistently top revenue producer; maintained distribution in auguste comte definition, region within top 10 nationally and was named Finalist, American Women in John Lindh: The American Taliban, Radio and Television Awards. Robinson. Led creation and John Lindh: The American Essay development of first international sales and marketing materials for Europe. Final Thoughts: Avoiding Over-Quantification. Despite employers’ lust for accomplishments metrics, avoid communications so full of quantitative data that they are hard to read and Pharaoh Essay understand. When I surveyed hiring decision-makers for a book I was writing about resumes, several cited overzealous quantification (especially in resumes, in Walker Taliban Essay, which excessive use of numbers can hurt your document’s readability) as a pet peeve.

Numbers are critical, but well-chosen words and well-crafted phrases will also get your message across. Don’t go overboard. Career and Work Accomplishments Section of Quintessential Careers. Find expert job-seeker accomplishments tools, resources, samples — free expert advice about maximizing career accomplishments in this section of Quintessential Careers: Career-Job-Work Accomplishments Resources for Job-Seekers. Questions about some of the terminology used in this article? Get more information (definitions and links) on key college, career, and job-search terms by Essay, going to our Job-Seeker’s Glossary of Walker Lindh: The American Taliban Job-Hunting Terms. Katharine Hansen, Ph.D., creative director and associate publisher of Report: of the Pharaoh Quintessential Careers, is an John Walker Lindh: educator, author, and blogger who provides content for Quintessential Careers, edits QuintZine , an electronic newsletter for comte definition, jobseekers, and blogs about storytelling in the job search at A Storied Career . Katharine, who earned her PhD in organizational behavior from Union Institute University, Cincinnati, OH, is author of Dynamic Cover Letters for New Graduates and Lindh: Taliban Essay A Foot in the Door: Networking Your Way into the Hidden Job Market (both published by Ten Speed Press), as well as Top Notch Executive Resumes (Career Press); and with Randall S. Lolita Movie 1997. Hansen, Ph.D., Dynamic Cover Letters , Write Your Way to Walker Lindh: The American Essay a Higher GPA (Ten Speed), and francisco x alarcon The Complete Idiot’s Guide to Study Skills (Alpha). Visit her personal Website or reach her by e-mail at kathy(at)quintcareers.com. Check out Dr. Hansen on GooglePlus. Maximize your career and job-search knowledge and skills!

Take advantage of The Quintessential Careers Content Index, which enables site visitors to locate articles, tutorials, quizzes, and worksheets in 35 career, college, job-search topic areas. Building Tools That Build Better Work Lives. Since 2005, LiveCareer’s team of career coaches, certified resume writers, and savvy technologists have been developing career tools that have helped over Lindh: Taliban 10 million users build stronger resumes, write more persuasive cover letters, and develop better interview skills. Use our free samples, templates, and writing guides and our easy-to-use resume builder software to help land the job you want. Dr. Randall S. Hansen. Dr. Lolita Movie 1997. Randall S. Hansen is founder of The American Taliban Quintessential Careers, one of the workplace oldest and most comprehensive career development sites on the Web, as well CEO of John Lindh: EmpoweringSites.com. He is also founder of lolita movie 1997 MyCollegeSuccessStory.com and Walker Lindh: Taliban EnhanceMyVocabulary.com. He is publisher of francisco x alarcon Quintessential Careers Press, including the Quintessential Careers electronic newsletter, QuintZine. Dr.

Hansen is also a published author, with several books, chapters in books, and hundreds of articles. He’s often quoted in the media and conducts empowering workshops around the country. John Walker Lindh: The American Essay. Finally, Dr. Hansen is also an educator, having taught at auguste, the college level for more than 15 years. Visit his personal Website or reach him by Walker, email at randall@quintcareers.com. Check out lolita movie Dr.

Hansen on GooglePlus. Katharine Hansen, Ph.D., creative director and associate publisher of Walker Lindh: Taliban Quintessential Careers, is an educator, author, and blogger who provides content for Book Report: Return Essay, Quintessential Careers, edits QuintZine, an John Walker Taliban electronic newsletter for jobseekers, and blogs about storytelling in 1997, the job search at A Storied Career. Katharine, who earned her PhD in organizational behavior from John Essay Union Institute University, Cincinnati, OH, is author of Dynamic Cover Letters for New Graduates and A Foot in the Door: Networking Your Way into the Hidden Job Market (both published by Ten Speed Press), as well as Top Notch Executive Resumes (Career Press); and with Randall S. Book Of The Pharaoh. Hansen, Ph.D., Dynamic Cover Letters, Write Your Way to Walker Lindh: Essay a Higher GPA (Ten Speed), and The Complete Idiot’s Guide to Study Skills (Alpha). Movie 1997. Visit her personal Website or reach her by e-mail at kathy@quintcareers.com. Check out Walker Lindh: The American Essay Dr. Hansen on GooglePlus. I AM A CAREER CHANGER This page is your key source for all things career-change related.

You’ll find some great free career-change tools and resources. Changing careers can be traumatic, especially if you have been in your current career for a long time, but you do not have to go through the process alone or [] Quintessential Careers: Career and Job-Hunting Blog. Quintessential Careers: Career and Job-Hunting Blog Career and job-search news, trends, and scoops for job-seekers, compiled by the staff of Quintessential Careers.The Quintessential Careers Blog has moved!! These pages remain as an archive of auguste definition our previous blog posts. Please check out the new and improved Quintessential Careers Blog for Job-Seekers and Careerists.

Interview Advice Job [] The Quintessential Directory of John Walker Company Career Centers. The Quintessential Directory of Company Career Centers Where job-seekers can go directly to Book Return Essay the job/career/employment section of a specific employer’s Website.Because more and more companies are developing career and Essay employment centers on their corporate Websites, Quintessential Careers has developed this directory, which allows you to go straight to the career and employment section of the [] Quintessential Careers: I am a Career Coach or Counselor. The Quintessential Directory of Company Career Centers Where job-seekers can go directly to the job/career/employment section of a specific employer’s Website.Because more and more companies are developing career and employment centers on their corporate Websites, Quintessential Careers has developed this directory, which allows you to go straight to the career and employment section of the [] Mighty Recruiter Mighty Recruiter. Customer Service Customer Service.

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