Law for International Trade free essay sample

Because no terms in the contract or surrounding documents explicitly stated which governing law would be used it will be decided by the objective test. The most real and substantial connection is based on factors including the country in which the majority of the obligations under the contract are performed, e. g. manufacture, packaging, delivery; where the contract was formed, and what the currency of payment is. In this case the manufacture and packing is conducted in Australia, and the payment is in dollars and not yen, which would indicate the governing law is that of Australia. Under Australian law the rights and obligations of the parties are based on the contract, the Convention on International Contracts for Sale of Goods (CISG), and because Punked Jeans is based in Melbourne, the Goods Act 1958 (Vic) also applies. The CISG is an international sales code which attempts to balance the interests of the buyers and sellers. We will write a custom essay sample on Law for International Trade or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page Countries can choose to become a signatory to the convention, which then acts as a net to hold terms not expressly covered by the contract. Both Australia and Japan are signatories to the CISG and so under CISG Article 1(1)(a) the CISG will apply to the contract. However there are exceptions where even if both parties have signed the CISG it still won’t apply. These exclusions are contained in CISG Article 2. In this case the exceptions aren’t applicable, and the parties haven’t explicitly excluded it (CISG Article 6), so the terms of the CISG will be enforced. Under CISG Articles 14-24 it can be shown that SurfLife and Punked Jeans entered into a legally binding contract. This contract contains the express terms, which is this case include the cost of the goods, the inclusion of CPT Incoterms 2010, the port of delivery (Osaka), the order amount and type, the due date, and the buyer and seller. The implied terms of this contract include the CISG provisions and the Goods Act (Vic) provisions. The CPT Incoterms which were set out as express terms in the contract detail the obligations surrounding the delivery and transportation of the goods that the buyer and seller have. Issue 1 – Lateness of Delivery: The first issue to be discussed is that of the late delivery, with the goods ordered to be delivered no later than the 1st of April, and arriving in Osaka on the 17th of April. If the goods were found to be delivered late it would be considered a breach of CISG Article 33. The time at which goods are considered to be delivered is determined by the CPT (Carriage Paid To) Incoterms. Under these Incoterms delivery is considered complete when the seller delivers the goods to the first carrier at the named place of shipment. As the goods were loaded onto the carrier on March 30th, delivery (which only required the goods to be unloaded at the place of shipment), was done before April 1st, therefore Punked jeans is not in breach of CISG Article 33. Issue 2 – Mouldy and Stained Jeans: The second issue in this case is that the delivered jeans were spoiled and mouldy. Prima facie the relevant laws are CISG Article 35, which specifies the seller’s obligations in providing conforming goods, and CISG Article 36, which specifies the seller’s liability for non conformity and the time risk passes, or occurs later as a result of a breach of obligations. Earlier it was shown that Punked Jeans did deliver the jeans, and therefore transferred the risk to SurfLife, at the point of delivery to the carrier, Feilong Transportation Company (Feilong). This means Punked Jeans has not breached Article 35 and 36 because the damage was caused after the goods had been delivered. Therefore Punked Jeans has no obligations to provide remedies for the mouldy and stained jeans and it would be up to SurfLife to make a claim against the carrier. Issue 3 – Incorrect Number of Jeans: The final issue between Punked Jeans and SurfLife is the incorrect number of jeans delivered. Punked jeans delivered only 14,000 pairs of jeans total, including 2,000 XXL size, which is double the amount that was ordered. Prima facie and incorrect number of jeans breaches CISG article 35, to provide conforming goods. As the goods were nonconforming when they were delivered to the carrier it would appear that Punked Jeans would be in breach. Feilong did provide a clean Bill of Lading, which indicates that they received the items in the correct condition, but since the Bill of Lading condition report only has to indicate the outward appearance of the items (i. e. the outside of the container the jeans were carried in), Punked would not be able to use this as evidence that the correct amount of jeans had been delivered, merely it would represent the correct amount of containers had been delivered and loaded. This means that Punked Jeans has indeed breached CISG Article 35(1), by delivering the incorrect quantity of jeans. This breach is likely to be considered a fundamental breach according to CISG Article 25 as SurfLife jeans has been substantially deprived of they were entitled to, receiving only 13,000 of the 15,000 pairs of jeans ordered. The extra 1,000 XXL jeans won’t be considered as making up some of the numbers as they are not useable by the company. Remedies: Under CISG Article 45 the buyer has a series of remedies available if the seller fails to perform any of his obligations. These include rights in Articles 46-52, and damages from 74-77. Remedies for the incorrect number of jeans that may be sought by SurfLife against Punked Jeans, in accordance with Article 25 (Fundamental Breach) and Article 51, include: delivery of substitute goods (Article 46), additional time period for delivery (Article 47), providing a self-correction remedy at Punked Jeans’ own expense (Article 48), declare the contract avoided (Article 49), or reduce the price paid for the goods (Article 50). The best course of action in order to remedy matter is to reduce the price the Punked Jeans charges for the goods by the amount of the missing jeans. This is because the demand for the jeans has passed, which makes Articles 46 and 47 ineffective; only part of the package hadn’t been delivered, making Article 49 ineffective; and a self-correcting remedy adds additional expense to Punked Jeans, as opposed (Article 48), as opposed to Article 50 which simply results in a lower income to Punked Jeans. However, SurfLife can still claim damages under CISG Articles 74-76. SurfLife can claim damages including loss of profits (Article 74), and the costs of purchasing replacement goods (Article 75). Unfortunately for Punked Jeans, SurfLife were smart enough to preserve the goods rejected for non-conformity (the extra XXL jeans), as under Article 86 if they hadn’t have kept them then they would not have a claim for the extra jeans. Conclusion: The result for Punked Jeans is that they are likely to have to reduce the price paid for the goods by 2,000 pairs of jeans, as well as providing damages for the loss of profit the SurfLife would have received from selling those jeans. In regards to the late delivery and mouldy and stained jeans SurfLife will have no claim against Punked Jeans. Part B: The main issues in the case are the late delivery, the incorrect number of jeans, and the mouldy and stained jeans. In order to determine the rights and obligations of Feilong Transportation Company (Feilong), and any resolutions available, there are a number of steps to be taken. What are the governing laws of the case? The governing laws in this case are the Carriage of Goods by Sea Act (COGSA) Section 11(a) which states that all carriage of goods from an Australian port to an overseas port select Australian law as the governing law. Section 10(1)(b)(i) states that the Modified Hague-Visby Rules (MHVR) apply in accordance with Article 10 of the MHVR. Under Article 10(1) of the MHVR the rules of the MHVR apply to outbound carriage of goods from Australia. The other laws applicable in this case are the CPT Incoterms, which were expressly defined in the contract. Can the buyer sue the carrier? In Australia law there is a general principle called the privity of contract. This means that the contract is enforceable as between parties in a contract only. This impacts the rights and obligations of Feilong to SurfLife and the carriage of the goods to Osaka was organised by a contract between Punked Jeans and Feilong (based on the CPT Incoterms) not between SurfLife and Feilong. Under the privity of contract principle it would then not be possible for SurfLife to sue Feilong. As seen in Part A the only claim SurfLife can have against Punked Jeans is for the incorrect number of jeans delivered. Section 8 of the Sea-Carriage Documents Act 1998 (Vic) allows for the transfer of rights under a contract of carriage to the successive holders of the Bill of Lading. Under section 10 the liabilities are also transferred in the process. This allows for SurfLife to sue Feilong as the holder of the Bill of Lading whilst the carriage was being made. A second important factor in the ability for SurfLife to sue Feilong is based on the MHVR. Under the Hague or Hague-Visby regulations a carrier would only be responsible under the rules from tackle to tackle, meaning from the loading to the unloading of the goods and no further. As the damage in the case occurred when loading the container on a truck to be delivered to the ship this damage would not have come under the carrier’s responsibility. Since the goods had been delivered it would not have come under the seller’s responsibility either and so SurfLife would have to cover the damages themselves. Under the MHVR Article 1(3) the responsibilities of the carrier extend port to port, meaning from delivery to the port until they are picked up from the port. This means the SurfLife is able to sue Feilong for any breaches that occurred after the goods had been delivered. A third important factor in who SurfLife sues is that they correctly identify he carrier, else the case will not succeed and they may lose the right to sue under MHVR Article 3(6) (discussed later). To find this out SurfLife should consult the Bill of Lading. Issue 1 – Late Delivery: In Part A it was established that delivery, according to the contract between SurfLife and Punked Jeans, was within the legal time period. However, MHVR Article 4A(2)(b) states that if the carriage contract (the contract between Punked Jeans and Feilong) does not spe cify a delivery date to the port of destination then a reasonable time period based what a diligent carrier would perform. This would result in Feilong being liable for the loss caused by the delay, which could include SurfLife’s costs of hiring trucks and getting employees to work overtime, as well as lost profits. Feilong’s defence would to argue MHVR Article 4A(3)(e) in which the carrier is excused from liability if it is for the purposes of saving human life or aiding a ship in distress. As well as this MHVR Article 4(4) states that any deviation as a result of saving or attempting to save life at sea will not be considered a breach of the rules, and the carrier will not be liable for any damages as a result therefrom. The end result would be that Feilong would not be responsible for any losses caused by the delay. Issue 2 – The Incorrect Number of Jeans: The second issue for Feilong is the incorrect number of jeans delivered. In Part A it was found that a clean Bill of Lading is indicative of the goods being received in correct condition, but as was pointed out this only applies to the external appearance of the goods, i. e. the outside of the container. As this was indeed in good condition Feilong has fulfilled its duty to receive and deliver the correct amount of packages, and therefore in his case would not be found liable for the missing pairs of jeans. Issue 3 – The Mouldy and Stained Jeans: The final issue is that of 5,000 pairs of jeans (100 boxes each containing 50 pairs of jeans) were delivered mouldy and stained. Prima facie Feilong is in breach of MHVR Article 3(2), which requires the carrier to take proper care of the cargo. As discussed earlier under the MHVR Article 1(3 ) the goods were considered to be in Feilong’s possession at the time they fell on the ground in the rain. Under MHVR Article 4 carriers aren’t liable when damage results from a list of exemptions. In this case it is possible that Feilong could argue MHVR Article 4(2)(n), insufficiency of packing. Feilong could argue that Punked Jeans hadn’t packed the product properly and that the plastic packaging burst when it shouldn’t have. There is evidence in the case that the goods were properly packaged and so this exemption would not be applicable. Feilong may be able to make the claim that the jeans would have been in a reasonable condition had they not had to deviate, due to there being less time for them to go mouldy. This would come under MHVR Article 4(4) or MHVR Article 4(2)(l) as the extra time was the result of saving life at sea. However, the damages are unlikely to be considered ‘arising’ or ‘resulting’ from this action, as the rules require, and so would not apply. Even if one of these exemptions were to be found applicable Feilong can still be found liable if the underlying cause of the damage is Feilong’s failure to exercise proper care in carrying out its fundamental duties in MHVR Article 3(2). It is therefore likely the Feilong will be found in breach of MHVR Article 3(2) for failing to take proper care of the goods. Damages: In the Bill of Lading there is a clause for the carrier not to be liable for any loss or damage arising from delay, and limiting liability to US$100 to a single shipper, however caused. Under MHVR Article 3(8) any clause or agreement in the contract of carriage that limits the liability of the carrier for failure in the duties and obligations in the MHVR is considered null and void. This means that these clauses aren’t applicable, even though they are expressly stated in the contract. The maximum damages Feilong will be responsible for is declared in MHVR Article 4(5)(a). If the value of the jeans was declared on the Bill of Lading then that value could be used, else the maximum amount the carrier would be liable for is 666. 67 units of account per package, or 2 units of account per kilogram. A unit of account is defined by MHVR Article 4(5)(d) as a Special Drawing Right as defined by the IMF. The rate as of 21/09/11 is US$1. 57. The definition of a package was determined in El Greco (Australia) Pty Ltd v Mediterranean Shipping co SA [2004] FCAFC 202 (PM3. 84) as being the amount stated on the Bill of Lading. In this case the Bill of Lading stated 1 container of jeans, which would means that the maximum damages, based on the number of packages, is 666. 67 * 1. 57 * 1 which is US$1,046. 67. The weight of the jeans is not mentioned, so unless this was contained on the Bill of Lading it couldn’t be used. Feilong may have a claim under MHVR Article 3(6) which requires notice to be given to the carrier of any damage within 3 days of removal of goods. If SurfLife did not provide notice then they would not be able to make a claim against Feilong. In conclusion Feilong is unlikely to be found liable for the delay in shipping, and the inadequate number of jeans. They are likely to be found liable under the MHVR to be in breach of Article 3(2) to take proper care of the goods. The exemptions listed in Article 4(2) will not be applicable, and so they will have to pay damages according to Article 4(5). The result is that Feilong will have to pay US$1,046. 67 in damages to SurfLife. Part C: The relevant laws would be much different if the goods were shipped from a manufacturing complex in Singapore. Although the cases would not be the same as determining the governing law in Australia, Singapore is based on the English common law system, and so would have a similar method. This would likely result in the governing law of Singapore being used. Singapore is a signatory to the CISG, however they did opt out of Article 1(1)(b), whereby the use of international private law could not lead to the application of the CISG. As both Japan and Singapore are signatories than Article 1(1)(a) applies, which still results in the CISG being applied. Punked Jeans would therefore still be liable for the missing jeans. Under FCA Incoterms the seller is responsible for the carriage, risk, and costs of the goods up until the goods are unloaded at the port where they are to be shipped from. This means the carriage would have been organised by SurfLife, and so SurfLife would have the contract with Feilong. SurfLife would not have to get around the privity of contract laws to sue Feilong for the damaged goods. The final difference is that Singapore has ratified the Hague-Visby Rules (HVR), not the MHVR that Australia has. The HVR states that the carrier is only responsible from tackle to tackle, from the loading to the unloading of the goods.

buy custom Personal Statement essay

buy custom Personal Statement essay I am applying for an opportunity to enrol in the PhD. in Management program at the University of Florida because I wish to progress my career in the research of management. I have an interest in understanding the different aspects of businesses and the factors influencing their performance. In addition, I am interested in researching the managements competencies, and what is needed in every form of business. Development of technology has had an impact on businesses at the international level. It is necessary to understand the impact on the management of organisations, which I am looking forward to doing by furthering my level of studies to the Ph.D level. In order to be approved on these and other related issues, it is vital to have a firm foundation in international management, financial analysis, business strategy, as well as personal and professional development. I believe that the Ph.D program in Management will offer priceless assistance towards the attainment of these objectives. It will make it possible for me to channel my theoretical and quantitative skills in business analysis. It will also create and open new directions for research. In addition, I am interested in applying for a position as a faculty member and study issues related to technological development and its impact on business management. I trust that my background in business management has provided adequate preparation for the career. During my undergraduate where I pursued BA (Hons) Business Management (HRM), and Masters Level where I pursued MBA (Human Resource Management), I have found conducting research an interesting adventure. My Masters Level dissertation involved researching about competency development at the workplace, and it was judged as one of the best presentations. It involved checking the development of competency at different small enterprises in the UK. It offered an opportnity to understand the approach taken by organisations to develop the competency of their employees. I also develop my skills as a researcher by consulting relevant authorities to get the best results from the research. Therefore, I am looking forward to using the experience in research and details learned in research methods to continue conducting relevant research in the field of management. I have always had an interest in business management, and it prompted me to join a course on business management in my undergraduate. I found the subject of technology and its impact on management interesting. It was mainly due to the dynamic nature of technology, and interest to understand how businesses are embracing it. In the Masters Level, I was interested in studying the research methods, which I have been applying while conducting research on various aspects of management and businesses. I have also developed numerous skills to work both independently and as part of a team. Additionally, due to the temperament of the studies at both undergraduate and Masters Level, I have developed the skill of time management. I have also worked as a leader, which is essential in understanding how to deal with different members of a team and develop skills to ensure the teams success. In line with my interest competency development in organisations, I have worked as the HR consultant at www.healthmagkw.com. I had the responsibility of addressing the competency of the staff members in each department. It involved researching the skills required to undertake various tasks, the competency of employees, and recommend approaches that can be used to enhance and develop their competencies. The job has prompted me to conduct massive independent research in the field of competency development in order to offer the best consultations to the company. The nature of the assignment requires prompt response to problems relatedd to competency development. It should be done within the limited period in order to have an impact on the performance in the departments, and an organisation at large. It has also offered insight into the organisational environment; how it affects the organisation, as well as how the organisation influences it. I wish to pursue a Ph.D at the University of Florida due to various reasons. The university has one of the best Ph.D in Management program globally. My graduate professors also stressed on the universitys performance, and the emphasis on its general orientation of management, technical and analytical skills, as well as its rigorous research methodology has impressed me. Profound knowledge given on management courses is also appropriate for my research interests. Its reputation for testing coursework, excellent approach to teaching and high-quality facilities are attractions to the University of Florida. After completing the course, it will promote my interests in research. While studying and conducting research on different issues is my prime interest, I also have interests in football, archery, fitness, running, and visiting the cinema. They are activities that assist me in the maintenance of a perspective sense in life. I use these activities to relax and have a rest. I have also organised and participated in various extra-curricular activities related to writing competitions during my school years. I am also passionate about humanitarian activities, and I have been a volunteer in Dublin. It is an aspect of giving back to the community, which, I believe, is the responsibility of every human being. I still participate in different activities aimed at promoting the welfare of the society. I hope that the admissions committee will find the strengths, skills and background commensurate with the University of Floridas Ph.D program in Management. Buy custom Personal Statement essay

Case study Essay Example | Topics and Well Written Essays - 1750 words - 17

Case study - Essay Example Globalization in the film industry can be approached from four main categories as discussed by Lorenzen (2008). He enumerates these approaches as being globalization of involvement in film-making, film consumption, film production and organization of film making. Globalization involvement in film-making is characterized by a rapid growth in the number of feature films that hit the market, either for TV, cinema or exhibition. For instance, Lorenzen observes that India and China have considerably experienced steady growth in the film industry, a situation backed by their respective growth in purchasing power and investment in the industry. The rise of global consumer taste the world over characterizes globalization in consumption. Lorenzen notes that apart from continuous expansion of the global market, the ease with which producers can reach the prospective market has also improved. The advantage that comes with this phenomenon is that products can be released simultaneously to global audiences on a good number of national markets. This consumption globalization is immensely boosted by such quick distribution and exhibition platforms as internet, Satellite TV and DVDs. India and Japan have been noted to be more aggressive in adopting new technological distribution means compared to Hollywood. Cross-border co-production of films is what marks production globalization. Even though this practice has been around for some time, it has recently witnessed a great surge, with most films from US, Canada, Asia, and Europe involving cross-border production. India, due to is conservative nature, is yet adopt cross-border co-production, hence the relatively low external market share for its films. The final aspect of globalization is global organization, characterized by the advent of global corporations. With the onset of internalization, Lorenzen observes that most Hollywood

Literary Response to Passage from The Story of My Life by Helen Keller Essay

Literary Response to Passage from The Story of My Life by Helen Keller - Essay Example In literary works, however, where different perceptions, feelings and moods are to be conveyed alongside pure facts, analogies can be used to make the text more interesting, memorable and evocative for the reader. In this case the analogy of the ship is a good example of how the author uses language to represent emotional as well as factual elements in her life story. The passage occurs on the first page of Chapter IV in the book, and relates the child Helen Keller’s anticipation of meeting her teacher Anne Sullivan. It starts with a direct question to the reader: â€Å"Have you ever been at sea in a dense fog†¦Ã¢â‚¬  and it aims to represent the loss of human senses and the feeling of helplessness that this brings. In English the term â€Å"at sea† can be used literally, to mean undergoing a voyage on water, or figuratively, meaning that someone has lost his or her bearings, and is drifting far from land. Since it is difficult to imagine being blind and deaf as an actual experience, the analogy of standing on a ship in fog serves to illustrate what it feels like. Inanimate objects like the ship, take on human characteristics: â€Å"the great ship, tense and anxious, groped her way†¦Ã¢â‚¬  Just as the ship has â€Å"no way of knowing how near the harbor was† so Helen Keller had no idea what was about to happen to her. The ship is personified here, and this encourages the reader to step into the role of a ship heading for harbor. It is clear that Helen Keller’s imagination is doing its best to make up for the lack of sights and sounds to give clues to what is happening all around her. In the middle of the passage the author explains what the analogy of the ship means: â€Å"I was like that ship before my education began.† By using this statement as a key to the text, the reader can figure out that the ship is Helen Keller, the harbor is the safety and security that she found in the teachings and loving care that h er teacher brought her. A very interesting part of the analogy is found in the expression â€Å"a tangible white darkness shut you in.† This is an unusual expression because it makes reference to the human senses in an apparently contradictory way. Darkness is not normally something that you can touch, and so the word â€Å"tangible† is out of place, and furthermore, the adjective â€Å"white† is not usually used to describe darkness. This collocation sounds wrong, because the whole point about darkness is that it is precisely not white. Helen Keller deliberately places these contradictory words together because she is trying to find a way of describing the phenomenon of being deaf and blind. By mixing the sense of touch with an unusual use of color, she is emphasizing the way that a deaf and blind person uses other senses to imagine the way that the world is. This is a very inventive usage, and shows the author’s literary skill. The point is further expa nded when she links the word â€Å"light† with the word â€Å"love† in the phrase â€Å"the light of love.† The darkness she suffered as a child was also a spiritual one, and the analogy of a ship sailing into a harbour full of light conveys a sense of arrival to safety after a long spell of being afraid of the unknown. By addressing the reader directly, and using the ship analogy, Helen Keller depersonalizes her own suffering, but at the same time conveys the emotions she felt, and this is a very skilful use of the technique of analogy.

Septic Shock: Acute Generalised Exanthematous Pustulosis

Septic Shock: Acute Generalised Exanthematous Pustulosis An illusion of Septic Shock: Acute Generalised Exanthematous Pustulosis with Multi organ Dysfunction Acute Generalised Exanthematous Pustulosis (AGEP) is a rare cutaneous eruption, most often caused by commonly used antibiotics. It is characterized by an acute onset of non-follicular sterile pustular rash and erythema within hours or days of drug exposure and usually resolves spontaneously within 1-2 weeks once the drug is discontinued. Hemodynamic involvement in the form of shock is rare. Here, we present a severe case of AGEP, manifesting with systemic involvement and hemodynamic instability resulting into shock with multi-organ dysfunction. The associated drugs were Erythromycin and Fluconazole with a possible combined effect of these two drugs that resulted in systemic involvement. Our patient improved markedly, both his hemodynamically and dermatologically, after discontinuation of the drugs and with systemic steroid therapy. BACKGROUND Why you think this case is important why did you write it up? Acute Generalised Exanthematous Pustulosis (AGEP) is a rare condition which presents with rapid onset of several non-follicular sterile pustules occurring diffusely on an edematous and erythematous background (1) (2). Systemic manifestations are typically restricted to fever and leukocytosis. Reversible mild hepatic and kidney injury have been reported in some cases (1) (3). AGEP is caused by drugs in 90% of the cases (3) and spontaneously resolves rapidly after the offending agent has been discontinued. Topical steroids are used for symptom relief and systemic steroids have been used in atypical severe presentations with systemic involvement (4) (5). Here we describe a unique case of Erythromycin and Fluconazole induced severe form of AGEP presenting with shock requiring vasopressors and multi-organ dysfunction requiring CVVHD. Despite prompt discontinuation of the offending agent, patients condition continued to deteriorate until systemic steroids were initiated. CASE PRESENTATION Presenting features, medical/social/family history A 61-year-old man with morbid obesity, COPD, hypertension, and Type 2 diabetes mellitus was admitted to the hospital for acute onset rapidly progressive diffusely erythematous rash within the deep folds of his pannus and scrotum, which was refractory to over-the-counter topical therapy. There was concern for erythrasma so he was started on erythromycin and fluconazole. Within three days, the patients rash spread diffusely across his trunk and extremities to form erythematous morbilliform papules which coalesced to form plaques. Within 12 hours of noticeably worsening rash, the patient acutely decompensated, became short of breath and developed metabolic and respiratory acidosis, requiring transfer to the Intensive Care Unit. He was initially started on BiPAP, however due to increasing somnolence he was intubated. He was noted to be hypotensive with blood pressure of 66/42 mmHg, not responsive to intravenous fluid resuscitation. Patient was started on vasopressor support with norepine phrine. On laboratory analysis, he was found to have leukocytosis (WBC 31.10 10^3/uL), a mixed metabolic and respiratory acidosis, lactic acidosis, as well as hepatic injury with AST of 4902 units/ml and an ALT of 3073 units/ml. He subsequently developed acute renal failure with a creatinine of 3.06 mg/dL, hyperkalemia of 6.3 mmol/L and phosphorus of 7.0 mg/dL and was started on CVVHD. INVESTIGATIONS If relevant More detailed The patient was thoroughly evaluated for an infectious source with radiographic studies and blood and urine cultures, however all work up was negative. Skin biopsy was performed which showed diffuse spongiosis, as well as numerous subcorneal pustules filled with a mixed inflammatory infiltrate, predominately consisting of neutrophils, with some associated lymphocytes consistent with AGEP. DIFFERENTIAL DIAGNOSIS If relevant Other differentials included septic shock, pustular psoriasis, Toxic epidermal necrolysis, Stevens- Johnson syndrome TREATMENT If relevant Erythromycin and Fluconazole were immediately discontinued upon acute decompensation. Due to concern for septic shock initially, he was started on broad spectrum antibiotics, with Vancomycin, Meropenem and Micafungin. However, when the infectious work up was negative, antibiotics were discontinued. With suspicion of AGEP, he was treated with methylprednisolone 80 mg every 8 hours for three days and eventual slow taper on oral steroids. OUTCOME AND FOLLOW-UP The patient had marked improvement in both hemodynamics and rash once started on steroids. He no longer required vasopressor agents and was extubated on Day 3 of methylprednisolone. He required four days of CVVHD and had complete recovery of both kidney and liver function. He was maintained on oral prednisone with slow taper for 2 weeks. DISCUSSION Include a very brief review of similar published cases Acute Generalised Exanthematous Pustulosis (AGEP) is a relatively rare cutaneous condition provoked by drugs- mainly by anti-infective agents, less commonly by infections (3)(4) and sometimes the cause remains unclear. It is believed to be a T-cell mediated neutrophilic inflammation and the histological hallmark is a spongiform subcorneal/intraepidermal pustule. The rash typically starts in the intertriginous area, as seen in our patient, or the face and rapidly spreads to involve the rest of the body. Systemic manifestations are typically just limited to include fever and neutrophilic leucocytosis and organ involvement is rare. In a few patients, mild hepatic and kidney dysfunction has been reported (1)(6)(3). Our case of AGEP was an atypical presentation with severe systemic involvement leading to hemodynamic instability and multi-organ dysfunction, thereby giving an illusion of septic shock. To the best of our knowledge,ÂÂ   there have been only a few reported cases of AGEP w ith such severe presentation and none of these cases were associated with the use of Erythromycin and Fluconazole (7)(8)(9).ÂÂ   In most of the severe presentations, Vancomycin was the culprit medication (7)(8)(9). It is possible that the combined effect of Erythromycin and Fluconazole which are both hepatically metabolized and alter each others metabolism leading to increased drug levels resulted in the drug reaction being severe with systemic involvement as an affect. Other differentials to consider would be pustular psoriasis, Stevens-Johnson syndrome and Toxic epidermal necrolysis. The patient had no history of psoriasis and the concern for SJS and TEN was low based on the history, lack of mucosal involvement and the timing of the drug eruption within a few days of the antibiotics was more in favour of AGEP which was later confirmed by the biopsy results. Treatment of AGEP involves prompt removal of the offending agent which typically leads to improvement in symptoms within a few days. Topical steroids can be used for symptom relief. Systemic steroids are not indicated , but have been used in rare cases with severe presentations such as in our case, but currently there is not enough data to support the use of systemic steroids to reduce the duration of the symptoms and early recovery (11)(5)(4)(10). LEARNING POINTS/TAKE HOME MESSAGES 3 to 5 bullet points this is a required field AGEP is a rare cutaneous drug eruption which can be severe and mimic septic shock. It should be suspected in patients being managed as septic shock with negative infectious work up and the patients condition continues to deteriorate while on anti-infective agents. Several medications have been known to cause AGEP, but it is unclear as to which factors contribute to its severity. Discontinuation of the culprit agent might not always result in clinical improvement , especially in severe cases and there might be a role for systemic steroids to promote early clinical recovery.

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Public/ Private Parents these days try to find the best school for their child’s needs. Some parents can’t choose between public and public schools, because of their differences. Public and private schools have a lot of difference like cost, admissions, teachers, students, and special needs. Public schools don’t have tuition as all people know. State, Federal, and local taxes fund public schools. So when you pay taxes, you are paying for child’s education. Also you are paying for the other kids in your community. Unlike public schools, private schools have tuition. The National Association of Independent Schools says that the median tuition in the United States is $12,000 for first to third, $13,000 for grades sixth to eighth, and $15,000 for grades nine to twelve. For boarding schools it’s like another $8,000 for each group (Education World). Another difference is the admission. Public schools admit all children. This includes students with special needs. You can enroll your child in public schools by just filling out the necessary paperwork. Some private schools on the other hand are selective. Private schools are not forced to accept every child. In many schools admission is very cutthroat. The teachers are another difference in public and private schools. The teachers in public schools are usually state certified. That just means that the teacher has gone through training required by the state. In private schools teachers may not be required to have to train. Instead they have subject area expertise and an undergraduate or graduate degree in the subject they teach. Also teachers in private schools often report better working condctions. The students in public schools are usually the kids from the neighboring community. Also public schools usually have more racially and ethnically diverse populations. On the other hand a process determines students that go to private schools. All students must apply and be accepted in order to attend. Some people may say that this can create a fairly homogenous student body. Another difference is the special needs. Public schools by law must educate all children. They also have to provide the necessary programs to meet the child’s special needs. Public schools have teachers who are trained to work with students who have specific needs, because of this law. However, private schools don’t have to accept kids with specific needs. As a result most private schools do not have special education programs. Also in private schools extra resources to help children with special needs may come at an additional cost (Greatschools).

Pork Barrel

Pork barrel literally takes the meaning of setting apart budgets, which initially were taken from the people's money, for the realization of the proposed development projects of the members of the Congress of the Philippines. It usually is intended to benefit a group of citizens of a certain politician in return of their political support, which were either in the form of campaigning or in the voting process. To have these purposes be done neatly is a challenge for every politician.The temptation gets the otter of them at times, and this heads into the downside of having a pork barrel. Normally, in the English language, either addition or omission of words or letters always brings about another meaning into a word/group of words. Just like when pork barrel and scam meets halfway, its result you would never want to hear. But if every politician Just works with conscience, then we won't have any fear in mind regarding the collision of the words. But if otherwise, then it would not prod uce good feedbacks from the people.The Idea of whether or not to abolish the pork barrel is too hard to decide. But if I were to, I would have chosen not to take it away from the system of government. Yes, I may have stated downfalls In some parts of this essay, but I have a larger picture captured in mind. The outcome of abolishing this system I would always fear. What would happen to the Filipino people if the pork barrel for the betterment of the nation Is abolished? Every people must remember this system had its ups In terms of building roads and bridges, program for farmers, scholarships or deserving people, among others.Now, if the pork barrel Is to be scrapped, then It should be a challenge to the government to ensure that those who benefit from the program will not be affected. And that Is exactly what would happen If It Is abolished, there will be no guarantee that these people will continue their education and receive other significant assistance. Thus, the solution for It shall not be termination, but to have a greater commitment and accountability In Its utilization. Pork Barrel A cure, a treat, an alliance, a devastation or just a play. What do we really know about that so called Pork Barrel? All nation introduce to there governance the power of pork barrel stating that it’s a program serving righteous benefits for the society that concentrates on the people’s cost. But as a result of what they said Pork Barrel, I, you, we can’t see a single glimpse of faith brought by them. How can we say were free when we know that our hands and feet are tightly chained, how can we say were free when we know that were controlled by our very own governance who have no pardon for any citizens that relives faith in there own way.Why do Australia, Germany, United Kingdom, Eastern and Central Europe stated that they walk in on the path of righteousness, do that show that we have a bunch of prod, foolish and culprits in our public officials. It’s stated that the government is our government so how the government is working to help people over come co mplex problem if there the one who giving them and courses them in the path of lies and faults. A very good example is The Intriguing Controversy of the Year, The Pork Barrel Scam of Mrs.Janet Lim Napoles whom to be the brains of the lost of more than 10 Billion pesos in the funding of the Nation. And not only she is involve there’s still senators and congressman involve, how can they hold on trough this even then there are peoples supporting and trusting them all the way. Upon all happenings, evidence and controversies Mrs. Janet Lim Napoles can be voted not guilty, what is this happenings do our government just playing and fooling around to this crisis.Majority of the people is grieving for the lost wealth and opportunities just imagine all that money can do, it can feed million of people, can give hundred of thousand opportunities, can build off thousands of houses, can heal hundreds of illnesses, and help our only one nation from devastation. Now knowing these possibiliti es that can do so much, who can upholds this kind of cruel and unjustified act. After they say it’s for our own good how come they manage to control everything? How can we make an act if they have all the choices in life?But then I manage to conquer that after all that mischief I still need to thanks Mrs. Janet Lim Napoles not because of her cruelty and unjustified act people in the world won’t know the alliance and power of the whole Filipino people by means of the abuse of one. Now this day we should do what we know is right and stand on our two very own feet, we should know the path of what is fair and what is not because in the end were still humans and we can’t do every thing. So now a question will be leaven â€Å"Should you fight for what is right or stay on what you know is vogue? †