Sunday, January 26, 2020

The Game Of Volleyball Physical Education Essay

The Game Of Volleyball Physical Education Essay Volleyball is a team sport that has earned his place in every competitive level, based on very quick and explosive movements, such as jumping, hitting, diving and blocking (Mario. C Marques, Roland Van Den Tillaar, Tim J. Gabbett, Victor M. Reis, and Juan J. Gonzalez-Badillo, 2009). The squad consists of 12 players with team positioning depending on the attributes the player has, the positions are broadly defined as setters, hitters, opposite and outside hitters (left and right), middle blockers and liberos, each of the positions have a specific role within a match (Mario C. Marques et al. 2009). The left and right outside hitters positioning is at the net, and the priority for these players is to spike the ball and block opponent attacks. The percentages of attack and block jumps performed according to the position played in the court were 33 and 67 % for Position 2(right side outside hitter), 29 and 71 % for Position 3 (middle blocker), and 59 and 41 for position 3 (left side outsi de hitter). The left outside hitter focuses more in spike jumps than blocking because the right outside hitter is the one that helps more the middle blocker, focusing mostly in block jumps (Black, 1995). Every spike is made approximately at 100MPH, the player with the greater strength blocking or spiking will be the one that wins the joust (Scates et al.,2003). The athletes in volleyball generate a great deal of force when landing after performing an approach jump, blocking a spike, during a spike and while diving (Gadeken, 1999). Data gathered within the past competition seasons tells us that the athletes that are involved in volleyball sport do short run distances, vertical jumps and change directions frequently in a matter of seconds during the games. The trainings made by coaches should be based on this data to increase the attributes needed for a maximal performance but keeping a minimum reduction in performance due to fatigue (Black, 1995). According to Gadeken (1999) players must have a solid strength, plyometric and conditioning foundation in order to be able to absorb the forces generated while performing jumps and sudden movements. Certain abilities must be developed during training activities such as the high jumps, hand-eye coordination, fast response to change positions rapidly maintaining body balance, short distance running amongst others. Volleyball is a high speed sport in which anaerobic training is needed to gain energy; the source is the phosphagen system which provides ATP (adenosine triphosphate) (Scates, et al. 2003). Athletes according to Scates, et al. (2003) do not only have to be in good physical condition to play volleyball, an athlete has to be in volleyball condition in order to be able to perform as expected, this involves the capability of the athlete to perform high jumps at the same height during a match, and must have the energy to maintain the physical feats while sustaining their levels of strength, power and agility. Timothy J. Piper tells us that in womenà ¢Ã¢â€š ¬Ã¢â€ž ¢s intercollegiate volleyball the most important factor for success is the upper-body strength and for spiking velocity the main factor is the shoulder extension strength at high speeds. The major muscle groups utilized while hitting, blocking, passing, setting and moving at a volleyball game or training drill were studied to determine the movement patterns. Balance and coordination are required in order to comply with the demands of body movement while the athletes are on their feet (Gadken, 1999). In order to produce a greater force while jumping the glutes, hamstrings, quadriceps, and calves work together to produce the power necessary to impulse the body up (Scates, et al. 2003). According to Marques et al. (2009) there are differences in anthropometric, muscular strength and power characteristics of volleyball athletes according to the position they are playing. The outside hitters have a significant difference in maximal bench press strength, parallel squat and throwing distances than the setters and liberos, demonstrating to have greater lower-body strength. Outside hitter skills and drills are different from a setter or libero, while the setter focuses in well set passes, an outside hitter will focuse on block jumps, backpedaling for 4 m, rapid spike approaches and spike jumps, every exercise done within a short period of time (Allen Hendrick, 2007). Volleyball training is in need of anaerobic conditioning due to the short and explosive movments and high power outputs, games may last a long period of time but the game plays are not continuous with many breaks during the game (Scates, et al., 2003). Specificity and overload are necessary to increase the body efforts and improvement, according to Black (1995) the overload training must be stimulus; this means that the weights, speed, height and duration must be greater than usual in order to have a direct impact in body resistance, strength and conditioning. Increasing the speed, power and overall coordination is important and it can be achieved by doing Olympic-style lifts and Power cleans to develop the hip and back power (Timothy J. Piper, 1997). The volume of strength training varies depending on the exercise. Olympic style lifts never exceed 6 repetitions in some programs due to the fact that performing more than 6 repetitions may place the athlete at risk for injury (Gadeken, 1999). The use of free weights and of upper and lower body ballistic training is important in developing strength and power (Gadeken, 1999). Like basketball players, volleyball athletes need to be able to leap with agility and power but also be able to hit the ball with an enormous force while suspended in mid-air (Scates et al., 2003). Importance made on movements in which the athletes are on their feet, the exercise is similar to the demands of volleyball, and balance and coordination are required (Gadeken, 1999). It is necessary for the volleyball player to have a great upper-body strength, stability of the shoulder socket, and functional trunk strength to allow the athlete to swing faster and more powerfully (Scates et al., 2003). The shoulder joint musculature and rotator cuff muscles are of major concern because of their roll in stabilization of the shoulder and because of the high forces produced while spiking and blocking (Gadeken, 1999).

Saturday, January 18, 2020

Gross Negligence Manslaughter Essay

â€Å"In our judgement the law is clear. The ingredients of the offence have been clearly defined, and the principles decided in the House of Lords in Adomako . They involve no uncertainty. The hypothetical citizen, seeking to know his his position, would be advised that, assuming he owed a duty of care to the deceased which he had negligently broken, and that death resulted, he would be liable to conviction for manslaughter if, on the available evidence, the jury was satisfied that his negligence was gross. â€Å" Per Judge LJ R. v. Misra and Srivastava [2004] EWCA Crim 2375 para 64 (in the Court of Appeal Criminal Division) In light of the above comments, consider the elements of the offence of Gross Negligence Manslaughter and, referring to relevant authority, critically assess whether the current law in this area is certain and satisfactory. This paper is going to consider elements of the offence of Gross Negligence Manslaughter and will assess, whether the current law in this area is certain and satisfactory. In order to discuss whether the law governing Gross Negligence Manslaughter is in a certain and satisfactory state, I need to first consider its elements and then look at the current law, outlining the problems, and lastly discuss the proposed changes. Gross negligence manslaughter is a form of involuntary manslaughter where the defendant is apparently acting lawfully. Involuntary manslaughter may arise where the defendant has caused death but neither intended to cause it nor intended to cause serious bodily harm and therefore lacks the mens rea of murder. Whereas constructive manslaughter happens where the defendant commits an unlawful act which results in death, gross negligence manslaughter does not depend on representing an unlawful act has been committed. It can be said to apply where the defendant commits a lawful act in such a way as to render the actions criminal. Gross negligence manslaughter also differs from constructive manslaughter in that it can be committed by omission. The leading authority for gross negligence manslaughter is decision of the House of Lords in Adomako (1994) , where doctor Adomako’s actions of negligence caused his patient’s death. It was decided by Lord Mackay, that liability for this type of manslaughter arises where the jury decides that â€Å"Having regard to the risk of death involved, the conduct of the defendant was as bad in all the circumstances as to amount in their judgement to a criminal act or omission† In Adomako, House of Lords decided that gross negligence test is correct to use in all cases where duty of care has been broken. According to Adomako case, the following elements are considered to be a form of this involuntary manslaughter: the existence of a duty of care, breach of that duty resulting in death and gross negligence which the jury consider justifies criminal conviction. I will now study the first element of the gross negligence manslaughter offence which is duty of care. The criminal law recognise certain duty situations, Adomako itself involved a breach of duty owed by a hospital anaesthetic towards a patient (under a contract of employment). The requirement of a duty of care is fundamentally a civil law concept found in the law of tort. (Wacker [2003]). D owes a duty of care not to injure anyone whom he or she could reasonably foreseeably injure. Applying that to this context, there is a duty of care if there was a risk that an act or omission of the defendant might kill the victim. As it is a legal concept, it is for the judge to decide whether a set of facts gave rise to a duty of care. When bearing in mind the Adomako, the House of Lords approved the case of Stone v Dobinson (1977), in which D had undertaken a duty of care. The Miller principle, in turn, was used as the basis of the duty in the recent gross negligence manslaughter of Evans (2009), which decided that a duty may be imposed on those who ‘create or contribute to â€Å"life threatening situation†.. Alan Lidbury, in his book Criminal Law, asks the following question ‘so is the ambit of the offence limited to those who, for whatever reason, have either undertaken or had a duty imposed upon them or should it be wider ’’? Lord Mackay LC, when considering the case of Adomako, said that ‘’the ordinary principles of law of negligence apply to ascertain whether or not D has been in breach of a duty of care towards the victim’’. By looking at the above statement, it is clear that those same principles should apply in determining these people to whom a duty of care is owed. These principles can be found in the leading negligence case of Donoghue v Stevenson (1932). In this case, Lord Atkin in the House of Lords said you must take reasonable care to avoid acts or omissions which you can reasonably foresee would be likely to injure your neighbour (†¦) persons who are closely and directly affected by my act that I ought reasonably to have them in contemplation as being so affected when I am directing my mind to the acts or omissions which are called into question’’. It can be argued that this goes much further than the traditional duty situations. If this examination is correct, then this form of manslaughter has certainly a very wide scope. Nevertheless, the principles of criminal and civil law do not always go well together. This is demonstrated by the case of Wacker (2003), which involved the bodies of 58 illegal immigrants and two survivors which were found in a lorry at Dover. The D was convicted of 58 counts of manslaughter by gross negligence and appealed. He argued that because the illegal immigrants had shared the same purpose as him (gain access to the UK), he did not owe them a duty of care. This argument was rejected by Court of Appeal on the grounds that the public policy issues relating to civil law were different to criminal law and even where there was an fundamental unlawful purpose, he did not prevent criminal responsibility arising. The above case was followed by Willoughby (2004), where the court decided that D, as participant in a joint enterprise, owed the other participant a duty of care. The next element of gross negligence manslaughter which needs to be examined is a breach of duty of care. The ordinary law of negligence applies to these cases, in that those with an established duty of care, must act as a â€Å"reasonable person would do in their position†. If they fail to do so they breach that duty. This is called an objective test and will be grounded upon defendant’s situation at the time of the breach. Thus, if the defendant’s actions were within the range of what was commonly accepted as being the standard practice, it will be problematic to describe such behaviour as falling far below the standard of a reasonable person in his position. An unqualified person is not to be judged at a lower standard than a qualified person. Hence the absence of skill will not be a defence if the conduct is considered negligent. If however, the defendant has precise skills and knowledge of a danger that the reasonable person would not have, his actions should be judged in the light of those skills or knowledge. This test is an objective test. In the case of R v DPP ex parte Jones (2000) it was decided that no matter whether the defendant did not escalate the risk (the predictable risk of death) only that the risk would have been obvious to a reasonable person in the defendant’s position. The third and last element to consider is gross negligence. Just demonstrating that D has been in breach of a duty to another person and caused that person’s death will certainly not lead to liability for gross negligence manslaughter. There is something more necessary. In Adomako, the House of Lords confirmed that the correct test for this additional component was ‘‘gross negligence’’. This established a line of case law dating back to Bateman (1925), which as well as Adomako, involved negligent treatment by a doctor which caused patient to die. In this cases, it was explained by Lord Hewart LCJ that in order to establish criminal liability for gross negligence ‘the negligence of the accused went beyond a mere matter of compensation between subjects and showed such disregard for the life and safety of others as to amount to a crime against the state and conduct deserving punishment’’. This passage may be criticised for being somewhat imprecise, it tells the jury to convict if they think that D’s negligence was bad enough to amount to the misconduct. Nevertheless, the Bateman test received approval from the House of Lords in Andrews v DPP (1937), which involved death by extremely negligent driving. The Bateman case has also been approved in Adomako, where Lord Mackay LC stated that it was for the jury to ‘’consider whether the extent to which D’s conduct departed from the proper standard of care incumbent on him (†¦) was such that it should be judged criminal â€Å". Lord Mackay acknowledged that the test â€Å"involves an element of circularity† but was adamant that the matter had to be left to the jury. In Andrews, Lord Atkins at least offered some direction on exactly how ‘bad’ D’s negligence has to be. He said that ‘a very high degree of negligence is required to be proved’. Mere inattention by D would never suffice for criminal liability, D must have had a ‘criminal disregard’ for ‘others’ safety or the grossest unawareness or the most criminal inattention. In Mistra v Srivastava (2004), Court of Appeal held that the components of gross negligence manslaughter involved no vagueness which offended against Article 7 of the European Convention of Human Rights, which provides that â€Å"no one shall be guilty of any criminal offence on the basis of any act or omission which did not constitute a criminal offence under national or international law at the time when it was committed (†¦)† It had been argued that the application of the ECHR into British law via Human Rights Act 1998 meant that the principles set in Adomako were no longer a good law. The disagreement was put for the appellants that condition leaves it to the jury to decide a query of law, specifically whether the negligence initiating death amounted to gross negligence and so created a crime. To leave this assessment to be accomplished by different juries at each individual trial affords too little direction to those who owe duties of care. This absence of precision is compounded by indirectness: gross negligence manslaughter is any killing in breach of duty found to be grossly negligent. The disagreement failed. The court did not reflect that the jury had a law-making role when determining, on the facts demonstrated, whether D was guilty of manslaughter on the basis of a negligent breach of burden owed to victim. Whether the negligence was effectively bad as to be â€Å"gross† negligence was a matter of fact. If the jury made a conclusion to this effect, a decision of guilty would follow inevitably on the basis of the conclusion; the verdict of guilt was not something complementary to the outcome. The jury were merely finding facts within the boundaries of a legal standard, and the legal standard was reasonably clear to please the necessities of Article 7. On the face of it, the Article 7 dispute had particular strength. If someone remained to request, say, in what situations would D be said to have â€Å"murdered† V, we could tell our inquirer that, all other things comparable, D murders V if he causes V’s death with intent to kill or to cause really serious bodily harm. If there is time and patience, we could go on and tell him about the history of the courts and the sense of intent, the notions of the law of provocation, etc. But if, sensibly, we restrain ourselves to a simple explanation of the offence, we have specified sufficient proof to allow any person of ordinary personality to stay clear of the rules of the law of homicide. So far if we were enquired by D, a young medic at the beginning of her profession, what she must do if she is not to be sentenced for manslaughter, the discussion would unavoidably be longer. For instance, she might ask what would be her situation if, throughout the path of a widespread of infection, she misdiagnosed V’s meningitis as a case of flu, a fault which leads to the decease of victim. She might additionally ask whether her inexperience and any fatigue from overtask would be factors in her support, or whether it would be applicable if she was seeing many cases of flu at the period which presented signs comparable to those experienced by victim. Undoubtedly we could offer support implied in general terms, but to offer anything impending adequate direction we would need to talk to an experienced and qualified medical consultant to catch some logic of how bad a fault it is to cloud flu with meningitis. Coming to conclusion, the fact of the matter is that if a legal system in the common law practise is to avoid unnecessary particularity in criminal guideline, for many offences it must use, as definitional features, evaluative principles of substantial generality. Regularly, the most the law will say are things like, â€Å"if you drive a car, drive with due care and attention, if you take and retain someone else’s property, and make sure you are acting honestly. Numerous of additional samples could be specified. Wherever the jury is given the concluding say on whether D has failed to encounter such a standard, its task is observed, juridical, as concerning an outcome of fact rather than a judgment of law. Much would be vanished if violations reliant on on such outcomes were to be eliminated from the law. Regrettably, one price to be paid is that individuals matter to laws drafted in this way can only be assumed with comprehensive, â€Å"ball park† advice as to the conditions where they can misbehave against such laws. That seems to be satisfactory to please the necessities of Article 7.

Thursday, January 9, 2020

Details of Easy College Essay Topics

Details of Easy College Essay Topics Easy College Essay Topics: No Longer a Mystery Now you know how to write a college essay, we've got a good deal more specific resources for you to excel. If you wish to create a college essay which works, you will need to provide importance on the content which you will offer the admissions officer of your intended university with. Just because you've already written a college essay for a single university doesn't mean that it may also apply on your next applications. Developing a wonderful college essay may lose its purpose in the event the content of what you've written is not what the university is asking for. You are able to also get the reader's attention by starting your college admission essay with a rather intriguing story line that may produce the reader really curious to find out more about your college admission essay. When you have addressed, answered and explained your introduction within the body, you need to know how to correctly end your college admission essay. Now you've caught the interest of the reader via your introduction, you ought to be in a position to sustain the reader's interest and curiosity by inventing a great body for your college admission essay. To make it simpler for you, you only have to remember specific parts of the college essay format college that you may use in writing your college admission essay. There's nobody approach to compose an essay, and there are not any fixed rules. Besides the things you should always bear in mind, in addition, there are some things which you shouldn't do when creating the content of your college essay. Now you have the format right, it's time to learn some suggestions that will assist you in making a killer impact by means of your essay. The Appeal of Easy College Essay Topics Let's go through the crucial measures which will help you turn an outstanding topic into an outstanding essay. Bridget's essay is extremely strong, but there continue to be a couple little things that could be made better. Stephen's essay is quite effective. When you begin writing, don't be concerned about your essay's length. Essays are a lot shorter than books. If, on the flip side, you have more than 1 idea you love, consider whether any of them may be used for different essays you must write. Well, now you have to return to that list and determine which essays you still will need to write. To develop an incredible introduction for your college essay format, it is going to be simpler if you make a draft of how you would like your college admission essay to be. Prior to starting editing, set your essay aside for an about a week. Essay format doesn't have anything to do with the true content of the essay, it is the way you organize and present it. Stick to the same since it is an essential format for college essays. The secret to writing your very first draft isn't to be concerned about whether it's any good just get something on paper and go from that point. One of the absolute most troublesome things in writing essays is finding a very good title. You shouldn't write about the exact topic you used for your private statement, though it's fine to chat about something similar, provided that you adopt a clearly various angle. Nowadays you own a list of prospective topics, but probably no clue where to begin. What Everybody Dislikes About Easy College Essay Topics a nd Why The reader should observe relationships between different points. Be aware you do not need to have solved the issue, and a few of the greatest essays will explore problems which need to be solved later on. Regardless of the ample quantity of substantial research materials and intelligent ideas, the essay may wind up flawed in the event the student doesn't have effective writing skills. Application essays about challenges reveal how you respond to difficulty to folks who are quite interested in how you'll manage the subsequent four years by yourself. The Supreme Strategy for Easy College Essay Topics Now, employing a sample college essay isn't the exact same as plagiarism. The duration of your essay is not what universities start looking for. If you neglect to adhere to the easy MLA (Modern Language Association) instructions on the best way to format your essays, the examiners will believe you don't even have the capacity to follow simple instructions properly. In some instances the author might be an organization or department, therefore the stating of their name will finish the APA essay format.

Wednesday, January 1, 2020

Comparing Margaret Cavendish’s The Description of a New...

Comparing Margaret Cavendish’s The Description of a New World, Called the Blazing World and Sir Thomas More’s Utopia The so-called Utopia – the quasi-perfect society – flourishes in Margaret Cavendish’s â€Å"The Description of a New World, Called a Blazing World† and Sir Thomas More’s Utopia. While the former is a dreamlike account of fantasy rule and the latter a pseudo-realistic travelogue, both works paint a picture of worlds that are not so perfect after all. These imperfections glitter like false gemstones in the paths of these Utopians’ religious beliefs, political systems, and philosophical viewpoints. Religion and spirituality reach into the depths of the human psyche and strongly influence a nation’s way of life.†¦show more content†¦In More’s Utopia, everyone does indeed worship different gods, yet they must all believe in one single eternal power. This allows Hythloday the narrator and his comrades to convert some of the Utopians into Christians, for the citizens readily accept the one-god notion and the practice of sharing communal goods (More 517). No one is condemned due to his or her religious beliefs in Utopia. A fanatic who begins condemning other religions is tried on a charge, â€Å"not of despising their religion, but of creating a public disorder† and is sent into exile (More 518). Does this reflect a society with utopian religious ideals? In Utopia, there are two sects of religious people – the ascetic sect whose members do not marry or eat meat, and the sect that allows its members to marry and eat meat. The Utopi ans regard the second as more sensible, but the first holier. They believe that â€Å"anyone [who] chose celibacy over marriage and a hard life over a comfortable one on grounds of reason alone† is insane; but â€Å"as these men say they are motivated by religion, the Utopians respect and revere them† (More 520). Truly, religion shapes a nation’s identity and beliefs, and in the cases of the Blazing World and Utopia, some aspects of their religion mars their perfect societies. Closely linked to religion is marriage, a celebration governed by the government of Utopia. Marriage is a