By Markella M. I know it's sometimes hard and even pointless but when it comes to dating, you need to play the game of love and follow certain rules. These dating rules are in fact well known secrets man has developed through the years. Women surely know most of these secrets, but not all of them. Although there are countless ways to approach women, some basic dating rules must be followed in order to succeed. Dating Rule 1: Return her calls a couple of days later. This way you are in control of the situation. But be careful, do not over do it. Two days later is fine but no later than that. She may lose her interest in you completely. The idea behind this dating rule is that you must never let her think you are desperate about her. There are more important things in your life. Dating Rule 2: Don't spend a fortune on early dates. This is a great way to find out if a woman likes you or is after your wallet. On your first dates, do not spend much money on her. Take her to places like a cafeteria for example where you don't have to spend much. Again do not over do it or she will think you are cheap. Dating Rule 3: Do not sleep with her on early dates. Resist the temptation. Slow down the process. Kiss her or touch her a few times but don't go for sex. This will really turn her on and it will increase the passion and sexual tension. Patience is a virtue but hey, don't wait too long before making love. Dating Rule 4: Don't open your heart and soul early on. Be mysterious. Do not give any financial information or clues about your ex-lover or your job. Play the game of seek and hide for a while. She will do the same. Let her think she's in control but be careful not to scare her with too much mystery. Dating Rule 5: Don't introduce her to your friends. At least not yet. Keep her away from your good friends at the beginning. Mistakes could happen. For example a friend of yours might reveal something you are still trying to hide. This is very common. And for god's sake do not let her even think about flirting with your friends to make you jealous. Because she will probably try that evil technique. Dating Rule 6: Try to stay away from her friends. At least at the start. It's a fact that if you meet her friends you will eventually start exposing yourself to the wrong people and give the impression that she can invite her friends to go out with the two of you. She may even ask for a double date! What could be worse than that? Keep her friends away until you are confident enough to meet them. Alright these are just six golden dating rules. There are thousands of dating rules you can practise and test for yourself. Now it's time to go out hunt some women. Start playing the game of love. In case you need some extra help I have this women attraction guide written by a woman. Yes. An experienced woman decided to help us with our dating skills! Check it out. I wish you good luck. Article Source: http://EzineArticles.com/?expert=Markella_M. http://EzineArticles.com/?6-Golden-Dating-Rules-To-Attract-Women&id=388004 drugstore ambien
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Friday, 29 February 2008
Wednesday, 27 February 2008
Marketing's Nuclear Weapon
By Harry Hoover Three seconds. That's what you have to convey your message. Creativity is the strategic weapon that allows us to capture those few precious moments of attention from busy consumers in our increasingly competitive, time-crunched environment. Focus groups tell us that time is a precious, yet dwindling resource. Attention spans are dwindling, as well. Many forces condition people: competing messages, special effects, quick cuts, pop-up videos, too much media. We should not totally surrender to these trends but instead look at the yearnings they reveal: a desire for simplicity, efficiency, truth, and quality of presentation. When we design and write marketing communication material we must recognize a very fundamental fact: we are interrupting someone's day. The fact that they chose to read, hear or view our message places a great responsibility on us to present this work as best we can. All the elements should contribute to a single point. A single reason for being there. Add something and it is excess baggage. Take something away and it's thin soup. The balance is critical. And, we can't underestimate today's consumers. They are smart and we must not fall prey to communicating to the lowest common denominator. Consumers demand creativity, and ultimately they are who we work for. Do The Math It adds up to this: the increasing need for creativity. Thinking beyond the rote. Asking why and why again. Researching. Feeding the mind. Looking at the situation from a different angle. Parking your biases at the door. Once you've done the research and asked all the questions, it's time to let ideas flow, not just on concepts, but also on content, medium, style. Quick example. A small New York lingerie store with virtually no budget wanted to boost business. Its ad agency had an idea: paint messages on the sidewalk within eight blocks of the store. The messages read, "From down here, it looks like you could use some new underwear." Business exploded. Creativity isn't just a flash of lightning. It is a deliberate, disciplined process that anyone can follow. Now, go be creative. Harry Hoover is a partner in My Creative Team. He has 30 years of experience in crafting and delivering bottom line messages that ensure success for serious businesses like Bank of Commerce, The Bray Law Firm, Brent Dees Financial Planning, CruisingTheICW.com, Duke Energy, Focus Four, Levolor, North Carolina Tourism, TeamHeidi, Ty Boyd Executive Learning Systems, VELUX, and Verbatim. Article Source: http://EzineArticles.com/?expert=Harry_Hoover http://EzineArticles.com/?Marketings-Nuclear-Weapon&id=38367 ambien ultram
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Sunday, 24 February 2008
Add Wings to your Business with a Secured Business Loan
By [http://ezinearticles.com/?expert=Pranav_Das]Pranav Das A business always needs continuous cash flow be it an established business or a new one. A businessman faces ups and downs in his business as a business depends on market forces to a large extent. Given the facts most of the businessmen are forced to take loans to run their business uninterrupted. And when it comes to procuring loans the best option available to a businessman is to go for a secured business loan. A secured business loan is one that is specially crafted to cater to the monetary requirements of a business. This loan is granted against collateral be it your house or any other movable or immovable asset. Some of the major benefits of a secured business loans are that you will be charged with a very low interest rate. Your monthly installments are fixed as small amount. The repayment period is also longer and stretchable depending on your suitability to pay back the loan. You can get a large some of money as loan because the lender is secured with your collateral. However, there are some disadvantages also attached with [http://www.loans-park.co.uk/SecuredLoans_businessloans.html]secured business loans. Since this kind of loan requires collateral you may have to involve yourself with a lot of paper work. And the biggest risk is that you may lose your property which you had kept as collateral in case you fail to repay the installments. A secured business loan can be used for a number of purposes such as your initial expenses to establish a business, financing ongoing operations, or major investments in equipment. You are in the hospitality business and need to make improvements to make people feel at home. You want to purchase a building or refinance an existing commercial mortgage. You want to expand your business or buy out your partner. Consolidate your debt. Increase your inventory. Whatever is the reason you can avail a secured business loan. About the Author: The author is a business writer specializing in finance and credit products and has written authoritative articles on the finance industry. He has done his masters in Business Administration and is currently assisting Loans Park as a finance specialist. For More information please visit us:- [http://www.loans-park.co.uk/]http://www.loans-park.co.uk Article Source: http://EzineArticles.com/?expert=Pranav_Das http://EzineArticles.com/?Add-Wings-to-your-Business-with-a-Secured-Business-Loan&id=150026 ativan addiction theraputic use overdose
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Sunday, 17 February 2008
If You Want to Lose Weight, Stop Dieting!
By Sue Roberts Lose weight without dieting...how is that possible? It seems like a contradiction, doesn't it? If you have tried unsuccessfully to lose weight in the past, chances are you tried a special diet. And you probably lost weight. The important question of course being, did you keep it off permanently? For many the answer is no. In fact a recent study conducted at UCLA showed that short term dieting (up to about 6 months) can be achieved, but 2/3's of all dieters regain the weight within 4 - 5 years. The reason that these diets ultimately fail is that the underlying causes of overeating aren't usually addressed. The focus is all on counting calories, restricting fats, cutting out carbs, not eating after 7pm, or other such tactics. Take a look at the reasons why you overeat...is it what you turn to when under stress? do you refrain from expressing your feelings, stuffing them down with french fries and milkshakes instead? Examine these questions, too...how do I eat? fast or slow? alone or with others? am I persuaded by advertisements to eat something? if someone offers me something to eat that I don't really want, do I eat it anyway to avoid hurting their feelings? Dieting is expensive. In fact, Forbes.com in 2005 reported the following: "Last year Americans spent an estimated $46 billion on diet products and self-help books....a government review found that two-thirds of U.S. dieters regained all the weight they had lost within a year, and 97% had gained it all back within five years." Pretty depressing. But there's more! Ten of the most popular diets were examined to see how much a dieter spent on their weekly food to follow one of these diets. Here's how they compare: Jenny Craig.............$137.65
NutriSystem..............113.52
Atkins.......................100.52
Weight Watchers........96.64
Zone...........................92.84
Ornish.........................78.74
South Beach................78.61
Slim Fast.....................77.73
Sugar Busters!............69.62
Subway.......................68.60 Pretty amazing, huh? Granted, dealing with the root issues may take longer, but you'll be much farther ahead (and both your pocketbook and your body will be lighter, too) if you do. As a certified nutritionist and registered dietitan for over 20 years, Sue is passionate about helping you become your healthiest ever! She provides completely confidential online nutrition counseling, wellness coaching and education services at www.YourOnlineNutritionist.com Just think... right from the comfort of your own home you can get all the help you need to lose weight, gain weight, deal with compulsive overeating, or simply learn how to have a nutritionally-healthy lifestyle. Sue provides all the compassionate support and education necessary! Sign up for her monthly ezine and receive a free ebook, "Losing Weight with Dietary Supplements: Fact or Fiction?" Article Source: http://EzineArticles.com/?expert=Sue_Roberts http://EzineArticles.com/?If-You-Want-to-Lose-Weight,-Stop-Dieting!&id=538437 phentermine online physicians and pharmacy
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NutriSystem..............113.52
Atkins.......................100.52
Weight Watchers........96.64
Zone...........................92.84
Ornish.........................78.74
South Beach................78.61
Slim Fast.....................77.73
Sugar Busters!............69.62
Subway.......................68.60 Pretty amazing, huh? Granted, dealing with the root issues may take longer, but you'll be much farther ahead (and both your pocketbook and your body will be lighter, too) if you do. As a certified nutritionist and registered dietitan for over 20 years, Sue is passionate about helping you become your healthiest ever! She provides completely confidential online nutrition counseling, wellness coaching and education services at www.YourOnlineNutritionist.com Just think... right from the comfort of your own home you can get all the help you need to lose weight, gain weight, deal with compulsive overeating, or simply learn how to have a nutritionally-healthy lifestyle. Sue provides all the compassionate support and education necessary! Sign up for her monthly ezine and receive a free ebook, "Losing Weight with Dietary Supplements: Fact or Fiction?" Article Source: http://EzineArticles.com/?expert=Sue_Roberts http://EzineArticles.com/?If-You-Want-to-Lose-Weight,-Stop-Dieting!&id=538437 phentermine online physicians and pharmacy
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Saturday, 16 February 2008
Tuscan Garden Design
By Hans Dekker If youre looking for a beautiful, old world garden style, then you should look into designing a Tuscan garden design. There are several different things that you can do with a Tuscan garden design, but there are a few things that you should keep in mind if youre planning on a Tuscan garden design. First of all, if youre aiming for a Tuscan garden design, then youll definitely want to aim for a Mediterranean feel. This is easy to do if youre planning to design your own garden, and there are just a few important tips that you should try to follow if you want a Tuscan garden design. One thing that is very helpful is if you can design or add a wall fountain to the garden. The wall fountain (as opposed to a free-standing fountain) adds an air of older elegance, and definitely gives the impression that youre in a Mediterranean garden. Iron wrought benches can also help you achieve a Tuscan garden design, as well as a lot of terra cotta planters. In fact, one of the cheapest and easiest ways to get a Tuscan garden design is to use terra cotta plant containers instead of containers made out of other materials. If the shape is like older vases, then that is even better. Garden design landscaping can also go a long way toward helping you make a Tuscan garden design. One important thing to remember is that a lot of Tuscan gardens have flagstone pathways leading in between patches of different flowers. If at all possible, you should try to design your garden so that you can put in pathways. The final, and most important part of any Tuscan garden design is that you use the right types of plants. By using plants, herbs and flowers that grow primarily in the Mediterranean, you can make your garden appear to be a real Tuscan garden. Hans is author of the
Garden
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Thursday, 14 February 2008
'Tis The Season For Cold & Flu
By [http://ezinearticles.com/?expert=Theresa_Ramsey,_N.M.D.] Theresa Ramsey, N.M.D. The U.S. Centers for Disease Control (CDC) estimates that more than 20,000 people die from the flu and its complications each year. Even though this is only half the number of people that die from car accidents annually, this number can be significantly reduced with a little bit of information from medical experts and a little bit more effort from patients. When you are exposed to the flu, your immune system responds by making antibodies that attack the flu like Pac-man and although you feel like you got hit by a Mac Truck, you slowly recover your strength once the battle has been won. Since so many people lose the battle to the flu each year, the CDC recommends that healthy children, adolescents and adults receive the flu shot with extreme variations in effectiveness outcomes. There are two forms, an injectable form (dead virus) and an intranasal form (live virus). The vaccines are made up of three viral strains from the previous year. I believe the World Health Organization (WHO) and the U.S. and Canadian Public Health Services do their best to try to identify which strains may be the ones that we will be exposed to however there is no guarantee which is one reason that effectiveness outcomes vary so much year to year. The question that vibrates the walls of my office is, should I get the flu shot? To that I ask, do you typically get the flu shot and do you typically get the flu? and then listen for which of the four possible answers will follow before I respond. If the answer is yes, and I never get the flu, I support their decision to continue this ritual. If the answer is yes, and I always get the flu, I suggest they skip it this year since it hasnt worked and teach them how to strengthen their immune system. If the answer is no, but I always get the flu, I ask them not to start getting the flu vaccine but to support their immune system instead. If the answer is no, and I never get the flu, the answer is obviously that they should not start getting the vaccine. Supporting your immune system is important regardless of whether you get the vaccine or not. The goal, therefore, is to ascertain your immune system is making abundant, healthy antibodies and that you have enough reserve, or energy stores, to get back on your feet as quickly as possible. Here is a checklist for you to see how well you are protected: Make sure your body is getting plenty of rest. Sleep is the time our body makes its antibodies among many other restorative actions. Sleep is the time our bodies recover from the day of thinking, digesting, moving and doing. Sleeping at least eight hours, uninterrupted is one of your best protections. If you are not sleeping, it takes more energy for every cell to do all of their jobs. Try to decrease your stress by making healthy choices that support more peace and ease. Simply put, ease is the opposite of dis-ease. Minimizing stress is most often easier said than done. Regardless, recognizing if stress is affecting your health is essential. The next step is to make sure that your body is well fed. Your cells need energy to do their jobs well. Making antibodies is only one job. The nutrition you give your body dictates the type of energy you will have. If you eat highly processed foods from fast food stores or from packages and cans, you are getting calorie dense, nutrient deficient foods. Your repair and protection mechanisms will be deficient without proper nourishment for your cells have to do their work. There are a few guidelines to enhance your nourishment. 1. Become aware of what you are putting into your mouth. Sometimes writing a simple food log at the end of the day allows you to look in the mirror and reflect on your food and beverage choices. 2. Educate yourself about what a nutritious meal looks like. A good snapshot of a healthy plate is one that contains fifty to seventy-five percent of vegetables and fruit. The remaining twenty-five percent is divided between your protein and your starch. Protein comes from animal, fish, dairy and legumes. Starch is either your grain or root vegetables like sweet potatoes. 3. Stay hydrated with lots of water (half of your body weight in ounces of water per day), limit or avoid caffeine from coffee, soda, and tea as caffeine not only dehydrates you but also creates a false sense of energy that your body may become dependent upon. Limit or avoid alcohol as well as it dehydrates you and is a fermented sugar that is rapidly absorbed creating rapid blood sugar shifts while at the same time adding stress to your liver which is responsible for cleaning your body like your vacuum cleans your house. You might also consider supplements to boost your immune system, assist with sleep and to help your body best deal with stress. Think of supplements as just that something that will add to your bodys resources to do its job. Supplements help the body by nourishing it. Basic supplements like vitamin C, selenium, zinc, and the B-vitamins are safe as they are water soluble and wont build up in your tissues or imbalance your other nutrients. Vitamins like A, D and E are also beneficial, however they are fat soluble and can cause toxicity if you take too much. Although I am not a strong proponent of the flu vaccine, I do at times have to prescribe antihistamines or antibiotics when the body is unable to protect itself. We must be mindful to not overuse prescription drugs and to respect them for short periods of time and to also protect the body against their potential side effects. Antihistamines dry up body secretions and therefore can cause electrolyte imbalances and cause dehydration. Antibiotics destroy the acidophilus in our digestive tracts which weakens our immune system. Prescriptions for insomnia make your body sleep but they interrupt the natural sleep cycles which is when healing occurs. For these reasons, these medications must be utilized with respect and for the shortest amount of time necessary. In closing, I hope that you are getting excited about making your body stronger and that you are building your confidence as you enter the season of colds and flus. On that note, if you do get the sniffles or body pain, give yourself some downtime and read a good book with a cup of warm tea. If you push too hard when you are worn down, you will end up needing more time off in the long-run. Dr. Theresa Ramsey is co-owner of the Center for Natural Healing in Paradise Valley, Arizona, where she has had a family practice for 10 years. She specializes in lifestyle counseling, nutritional supplementation, homeopathy, botanical medicine, subconscious reprogramming, nutritional IV therapy, hyperbaric oxygen therapy, detoxification programs, specialty testing for food allergies, hormone panels, and amino acid & oxidative stress testing. Author of Healing 101, Dr. Ramsey bridges the gap between Conventional and Natural Medicine and teaches the language of healing. Through her Coming Home Retreats, she emphasizes individualized nutrition programs, stress management and hormonally balanced exercise plans. Dr. Ramsey is also Medical Director of Bella Vita Journeys, an Assoc. Clinical Professor & preceptor at SCNM and a member of the American Association of Naturopathic Physicians and the Arizona Naturopathic Medical Association. 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Wednesday, 13 February 2008
Free Dating Web Site - How To Find The Best Free Dating Web Site!
By Jarod Hunter How many free dating web sites are there online any way? It is terrible they shoot out of the ground like weed. And that is what most of them are pure, overgrown weed. However, I like visiting a free dating web site for a reason. This reason is very simple: They allow me to get more hot chicks then any other way you can think of! These free dating web sites are like a chick magnet for my primal animal instincts. And I got some really primal animal instincts dude! But I was talking about a good free dating web site. You know the only difficulty in a free dating web site is the following: They let you jump through hoops to make you get what you want. That is really terrible. But on the other side you have to see the positives on a free dating web site youll be able to pick up horny girls for sure. Seriously, girls are like menthey dont wanna pay money to satisfy their dirty needs. Theres just one thing that I cant help you with. No matter how good of a free dating web site you find youll NEVER get busy with any chick on there if you lack the skills man. SO you definitely need to amp up your skills. How? One tip Be real and be creative. Thats right if you wanna get hot chicks from a free dating web site, this is a golden tip. I cant give you any more in this short article so stay tuned man. And give those free dating web sites a chance. Stay tuned. Wait! Discover sly schemes to manifest your wettest dreams. You know you want it. No more goofing around. Now its time for action! Click here right now for more information about online flirting Saves a lot of aggravation too Article Source: http://EzineArticles.com/?expert=Jarod_Hunter http://EzineArticles.com/?Free-Dating-Web-Site---How-To-Find-The-Best-Free-Dating-Web-Site!&id=485382 buy phentermine us
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Monday, 11 February 2008
Employment Law - Majrowski And Employers' Liability For Psychiatric Illness
By Ian Mann The Protection from Harassment Act 1997 makes harassment both a criminal and civil offence, it was intended to deal with the problem of stalking. Section 1 - Prohibition of Harassment A person must not pursue a course of conduct which:- i) Amounts to harassment of another; and
ii) which he knows or ought to know amounts to harassment of another. For the purposes of this section the person whose course of conduct is in question ought to know that it amounts to harassment of another if a reasonable person in possession of the same information would think the course of conduct amounted to harassment of the other. Majrowski v Guy's & St Thomas's NHS Trust [2006] UKHL 34 This case was a claim brought by an employee under the 1997 Act against his employer in respect of alleged harassment at work. The employee argued that his manager had breached a duty placed upon her by the Act and that the employer should be held vicariously liable for that breach. This was not a case which the employee could bring under any of the discrimination legislation. The allegations were of general bullying intimidation and harassment. The Act clearly established a statutory tort and the Court of Appeal had to carefully consider whether an employer could be held vicariously liable for a statutory tort committed by one of its employees where the legislation in question does not specifically provide for such liability. On the basis that unless the statute in question directs otherwise or there is a good policy reason why the principle of vicarious liability should not apply, the Court of Appeal believed that there was no reason to reject the argument of the employee. The Court of Appeal was prepared to accept that although it was generally understood that the 1997 Act had been introduced to deal with the problem of stalking, it was nevertheless an Act which dealt with the prohibition of harassment in a range of different situations, not just stalking. The appellant NHS trust appealed against the decision ((2005) EWCA Civ 251, (2005) QB 848) that it was vicariously liable in damages to the respondent (M) under the Protection from Harassment Act 1997 s.3 for harassment committed by one of its employees in breach of s.1 of the Act. M, who had been employed by the trust, had alleged that his manager had harassed, bullied and intimidated him while acting in the course of her employment. An investigation by the trust had resulted in a finding that harassment had occurred. M had claimed against the trust for damages under s.3 of the Act based exclusively on the trust's vicarious liability for its employee's alleged breach of the statutory prohibition of harassment. The trust, relying on the phrase "damages may be awarded" in s.3 of the Act, submitted that the award of damages under that section was discretionary, and therefore harassment could not be equated with a common law tort. The trust also submitted that the Act was not aimed at the workplace but was a legislative response to the public order problem of stalking. The House of Lords held that: (1) The principle of vicarious liability was not confined to common law torts, but was also applicable to equitable wrongs and breaches of statutory obligations. Unless statute expressly or impliedly indicated otherwise, vicarious liability was applicable where an employee committed a breach of a statutory obligation sounding in damages while acting in the course of his employment, Dubai Aluminium Co Ltd v Salaam (2002) UKHL 48 , (2003) 2 AC 366, Nicol v National Coal Board (1952) 102 LJ 357 and National Coal Board v England (1954) AC 403 applied, Harrison v National Coal Board (1951) AC 639 considered. An employer could be vicariously liable if the employee's conduct was closely connected with the acts the employee was authorised to do and the conduct might fairly and properly be regarded as done by the employee in the course of her employment, Lister v Hesley Hall Ltd (2001) UKHL 22 , (2001) 2 WLR 1311 applied.
(2) The effect of s.3(1) was to render a breach of s.1 a wrong giving rise to the ordinary remedies the law provided for civil wrongs. The enabling language "may be awarded" was apt simply to extend or clarify the heads of damage or loss for which damages were recoverable.
(3) Neither the terms nor the practical effect of the Act indicated that Parliament intended to exclude the ordinary principle of vicarious liability. By s.3 Parliament had created a new cause of action, a new civil wrong, and damages were one of the remedies for that wrong. Parliament had added harassment to the list of civil wrongs because it considered the existing law provided insufficient protection for victims of harassment. The prospect of abuse in cases of alleged workplace harassment was not a good reason for excluding vicarious liability.
(4) Section 10 of the Act inserted a new section, s.18B, into the Prescription and Limitation (Scotland) Act 1973, which assumed that in Scotland an employer might be vicariously liable in damages to the victim of a course of conduct amounting to harassment in breach of the relevant provision of the 1997 Act. Parliament could not have intended that the position should be different in England. Problems The Act however presents an employee with hurdles to overcome if a claim is to be brought in this way. Firstly the 1997 Act prohibits only a "course of conduct" amounting to harassment, meaning that a single incident of harassment by an employee will not be sufficient to lead to liability. Secondly, in order to succeed, a claimant must establish that harassment within the meaning of the Act has taken place. This means "alarming" the person or causing the person "distress" amongst other things. Thirdly, vicarious liability will only be established where there is a sufficiently close connection between the harasser's conduct and the nature of his or her duties, and where it is just and reasonable to hold the employer liable for the harasser's actions. This is obviously an area of law which is very much in its infancy. However there is possible cause for concern. An employee who brings a claim for damages in the Civil Court has two significant hurdles to clear. The first is that any injury was "foreseeable" and the second is that if the claim is based upon a mental injury that that must be a "recognised psychiatric disorder" requiring significant medical evidence. Ian Mann - Employment Barrister
http://www.employment-barrister-uk.com http://www.13kbw.co.uk 13 Kings Bench Walk
Ian Mann was called to the Bar in 2000. He practices in employment disputes representing both employers and employees. His employment practice embraces the full spectrum of Employment Tribunal, High Court and appellate work and covers all areas of employment law, especially discrimination. Article Source: http://EzineArticles.com/?expert=Ian_Mann http://EzineArticles.com/?Employment-Law---Majrowski-And-Employers-Liability-For-Psychiatric-Illness&id=514806 buy phentermine
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ii) which he knows or ought to know amounts to harassment of another. For the purposes of this section the person whose course of conduct is in question ought to know that it amounts to harassment of another if a reasonable person in possession of the same information would think the course of conduct amounted to harassment of the other. Majrowski v Guy's & St Thomas's NHS Trust [2006] UKHL 34 This case was a claim brought by an employee under the 1997 Act against his employer in respect of alleged harassment at work. The employee argued that his manager had breached a duty placed upon her by the Act and that the employer should be held vicariously liable for that breach. This was not a case which the employee could bring under any of the discrimination legislation. The allegations were of general bullying intimidation and harassment. The Act clearly established a statutory tort and the Court of Appeal had to carefully consider whether an employer could be held vicariously liable for a statutory tort committed by one of its employees where the legislation in question does not specifically provide for such liability. On the basis that unless the statute in question directs otherwise or there is a good policy reason why the principle of vicarious liability should not apply, the Court of Appeal believed that there was no reason to reject the argument of the employee. The Court of Appeal was prepared to accept that although it was generally understood that the 1997 Act had been introduced to deal with the problem of stalking, it was nevertheless an Act which dealt with the prohibition of harassment in a range of different situations, not just stalking. The appellant NHS trust appealed against the decision ((2005) EWCA Civ 251, (2005) QB 848) that it was vicariously liable in damages to the respondent (M) under the Protection from Harassment Act 1997 s.3 for harassment committed by one of its employees in breach of s.1 of the Act. M, who had been employed by the trust, had alleged that his manager had harassed, bullied and intimidated him while acting in the course of her employment. An investigation by the trust had resulted in a finding that harassment had occurred. M had claimed against the trust for damages under s.3 of the Act based exclusively on the trust's vicarious liability for its employee's alleged breach of the statutory prohibition of harassment. The trust, relying on the phrase "damages may be awarded" in s.3 of the Act, submitted that the award of damages under that section was discretionary, and therefore harassment could not be equated with a common law tort. The trust also submitted that the Act was not aimed at the workplace but was a legislative response to the public order problem of stalking. The House of Lords held that: (1) The principle of vicarious liability was not confined to common law torts, but was also applicable to equitable wrongs and breaches of statutory obligations. Unless statute expressly or impliedly indicated otherwise, vicarious liability was applicable where an employee committed a breach of a statutory obligation sounding in damages while acting in the course of his employment, Dubai Aluminium Co Ltd v Salaam (2002) UKHL 48 , (2003) 2 AC 366, Nicol v National Coal Board (1952) 102 LJ 357 and National Coal Board v England (1954) AC 403 applied, Harrison v National Coal Board (1951) AC 639 considered. An employer could be vicariously liable if the employee's conduct was closely connected with the acts the employee was authorised to do and the conduct might fairly and properly be regarded as done by the employee in the course of her employment, Lister v Hesley Hall Ltd (2001) UKHL 22 , (2001) 2 WLR 1311 applied.
(2) The effect of s.3(1) was to render a breach of s.1 a wrong giving rise to the ordinary remedies the law provided for civil wrongs. The enabling language "may be awarded" was apt simply to extend or clarify the heads of damage or loss for which damages were recoverable.
(3) Neither the terms nor the practical effect of the Act indicated that Parliament intended to exclude the ordinary principle of vicarious liability. By s.3 Parliament had created a new cause of action, a new civil wrong, and damages were one of the remedies for that wrong. Parliament had added harassment to the list of civil wrongs because it considered the existing law provided insufficient protection for victims of harassment. The prospect of abuse in cases of alleged workplace harassment was not a good reason for excluding vicarious liability.
(4) Section 10 of the Act inserted a new section, s.18B, into the Prescription and Limitation (Scotland) Act 1973, which assumed that in Scotland an employer might be vicariously liable in damages to the victim of a course of conduct amounting to harassment in breach of the relevant provision of the 1997 Act. Parliament could not have intended that the position should be different in England. Problems The Act however presents an employee with hurdles to overcome if a claim is to be brought in this way. Firstly the 1997 Act prohibits only a "course of conduct" amounting to harassment, meaning that a single incident of harassment by an employee will not be sufficient to lead to liability. Secondly, in order to succeed, a claimant must establish that harassment within the meaning of the Act has taken place. This means "alarming" the person or causing the person "distress" amongst other things. Thirdly, vicarious liability will only be established where there is a sufficiently close connection between the harasser's conduct and the nature of his or her duties, and where it is just and reasonable to hold the employer liable for the harasser's actions. This is obviously an area of law which is very much in its infancy. However there is possible cause for concern. An employee who brings a claim for damages in the Civil Court has two significant hurdles to clear. The first is that any injury was "foreseeable" and the second is that if the claim is based upon a mental injury that that must be a "recognised psychiatric disorder" requiring significant medical evidence. Ian Mann - Employment Barrister
http://www.employment-barrister-uk.com http://www.13kbw.co.uk 13 Kings Bench Walk
Ian Mann was called to the Bar in 2000. He practices in employment disputes representing both employers and employees. His employment practice embraces the full spectrum of Employment Tribunal, High Court and appellate work and covers all areas of employment law, especially discrimination. Article Source: http://EzineArticles.com/?expert=Ian_Mann http://EzineArticles.com/?Employment-Law---Majrowski-And-Employers-Liability-For-Psychiatric-Illness&id=514806 buy phentermine
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Sunday, 10 February 2008
How to Get Rid of Puffy Eyes
By Brenda Murphy Its six oclock in the morning and you have to get ready for work. One look in the mirror makes you want to cringe. Your eyes look like youve just gone a couple of rounds with Mike Tyson. Yes, you have puffy eyes. The question is what do you do about it? Here are a few suggestions to help you deal with this early morning horror. 1. Know the causes. Investigate why your eyes are puffy in the first place. There are several reasons why your eye area could be retaining fluid. Allergies are a common cause of puffy eyes. Dust or other irritants could cause flare-ups that swell the eyes. Stress can also cause problems with your eyes. Physical manifestations are common among individuals experiencing high levels of stress in their lives. Crying is a cause of puffy eye syndrome, too. Fluid is also retained when the intake of sodium (salt) is higher than normal. 2. Try caffeine. After your morning tea, save those tea bags. Caffeine is a natural diuretic, meaning that it pulls fluid out of your system. Caffeinated tea bags can be used to help alleviate the puffy eye syndrome. First, cool down the tea bags by placing them in a cup of cold water. Warm tea bags will increase the flow of blood to the area which may increase the swelling, instead of decreasing it. Once the bags are sufficiently cooled, place them over each closed eye. Relax for about five to ten minutes. Remove the tea bags and examine your eyes. The puffiness should diminish. If the result is not to your liking, re-cool the tea bags and apply to your eyes again. 3. Cool as a cucumber. Cucumbers are not just for salads anymore. They make good cold compresses for the eyes. Take a chilled cucumber from the fridge and slice it into thin circles. If the slices are too thick they will not lay properly over the eyes. Let the cool slices rest on your eyes for about five minutes. Re-apply new slices as needed. 4. Drink more water. If puffy eye syndrome is more than an occasional occurrence, maybe your body is trying to tell you something. The body retains water when there is precious little available in your system. Increasing your water intake will give the body ample fluid for cellular function and it will not need to store extra water. Drinking lots of water will keep the incidence of puffy eyes to a minimum. Puffy morning eyes are annoying, but they can be treated. To avoid them in the long run, lower your salt intake, drink plenty of water, and use allergy eye drops if irritants are the cause of eye puffiness. Visit http://www.LearnHowToRemove.com for a growing library of tips to remove those annoying messes in your life. Article Source: http://EzineArticles.com/?expert=Brenda_Murphy http://EzineArticles.com/?How-to-Get-Rid-of-Puffy-Eyes&id=449752 phentermine without a dr prescription
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