Wednesday, January 29, 2020
Simon Cowell Essay Example for Free
Simon Cowell Essay Simon Cowell was born on October 7, 1959, in London, England. Cowell started his career in the music industry working in the mailroom at EMI Music Publishing. He worked as a record producer, talent scout and consultant within the music industry before producing the hit British TV show Pop Idol and its U.S. counterpart, American Idol. Cowells scathing comments were famous during his 10 seasons as a judge on American Idol. He started judging The X Factor in 2011. QUICK FACTS: OCCUPATION: Music Producer, Reality Television Star BIRTH DATE: October 07, 1959 (Age: 53) EDUCATION: Dover College PLACE OF BIRTH: London, United Kingdom FULL NAME: Simon Phillip Cowell, ZODIAC SIGN: Libra Early Career: Simon Phillip Cowell was born on October 7, 1959 in London, England. His father, Eric Philip Cowell, was an estate agent developer and music industry executive. His mother, Julie Brett, was a former ballet dancer and socialite. Cowell attended school at Dover College, but dropped out at 16. He floated in and out of jobs, sabotaging several interviews for jobs set up by his father. He finally landed a job at his fathers company as a mailroom clerk at EMI Music Publishing. He managed to earn a position as an assistant to an AR executive at EMI in 1979, where he was promoted and given the job of talent scout. Cowell left EMI during the early 1980s to form ES Music with his boss at EMI, Ellis Rich. The company created several hits, but Cowell left by mutual agreement a few years later. In 1985, he and a partner formed the independent label Fanfare Records, which enjoyed short-lived success. The company folded in 1989. In financial straits, Cowell was forced to move back in with his family. Undeterred, Cowell signed on as a consultant with BMG Records later that same year. He moved back into his own place, and gradually climbed the corporate ladder at BMG. He managed to sign a string of successful acts for the company, selling more than 150 million records and 70 top-charting singles in the UK and United States. | Sign In | Register MOBILE â⬠¢ EMAIL UPDATES â⬠¢ PEOPLE â⬠¢ TV â⬠¢ VIDEO â⬠¢ PHOTOS â⬠¢ GAME â⬠¢ BLOG â⬠¢ ON THIS DAY â⬠¢ SHOP SEE WHATS ON TONIGHT! Mobsters Tune In Tuesdays @ 8/7c more sharing servicesshare Simon Cowell biography profile photos 1 photo QUICK FACTS NAME: Simon Cowell OCCUPATION: Music Producer, Reality Television Star BIRTH DATE: October 07, 1959 (Age: 53) EDUCATION: Dover College PLACE OF BIRTH: London, United Kingdom AKA: Simon Cowell FULL NAME: Simon Phillip Cowell ZODIAC SIGN: Libra BEST KNOWN FOR Simon Cowell is a record producer and television personality known for his scathing critical remarks as a judge on the television show, American Idol. QUIZ Think you know about Biography? Answer questions and see how you rank against other players. PLAY NOW Home â⬠¢ People â⬠¢ Simon Cowell Print Cite This Synopsis Simon Cowell was born on October 7, 1959, in London, England. Cowell started his career in the music industry working in the mailroom at EMI Music Publishing. He worked as a record producer, talent scout and consultant within the music industry before producing the hit British TV show Pop Idol and its U.S. counterpart, American Idol. Cowells scathing comments were famous during his 10 seasons as a judge on American Idol. He started judging The X Factor in 2011. CONTENTS Synopsis Early Career Pop Idol and American Idol The X Factor Industry Recognition Personal Life QUOTES In TV, film and music theres a lot of snobbery, and I dont like it. If I dont like French food, that doesnt make me a lesser person. ââ¬â Simon Cowell Early Career Simon Phillip Cowell was born on October 7, 1959 in London, England. His father, Eric Philip Cowell, was an estate agent developer and music industry executive. His mother, Julie Brett, was a former ballet dancer and socialite. Cowell attended school at Dover College, but dropped out at 16. He floated in and out of jobs, sabotaging several interviews for jobs set up by his father. He finally landed a job at his fathers company as a mailroom clerkà at EMI Music Publishing. He managed to earn a position as an assistant to an AR executive at EMI in 1979, where he was promoted and given the job of talent scout. Cowell left EMI during the early 1980s to form ES Music with his boss at EMI, Ellis Rich. The company created several hits, but Cowell left by mutual agreement a few years later. In 1985, he and a partner formed the independent label Fanfare Records, which enjoyed short-lived success. The company folded in 1989. In financial straits, Cowell was forced to move back in with his family. Undeterred, Cowell signed on as a consultant with BMG Records later that same year. He moved back into his own place, and gradually climbed the corporate ladder at BMG. He managed to sign a string of successful acts for the company, selling more than 150 million records and 70 top-charting singles in the UK and United States. Pop Idol and American Idol In 2001, Cowell teamed up with Simon Fuller to produce a show in which the public chooses Britains next big music performance star. The show, Pop Idol, debuted in the UK and promised a BMG record deal to the winner. With Cowell as a judge notorious for reducing contestants to tears, the show was an instant success, drawing more than 10,000 would-be stars to audition for the show. The American version, American Idol, debuted in 2002, with Cowell once again judging alongside singer Paula Abdul and producer Randy Jackson. The show drew in a record number of viewers for Fox, in addition to producing pop stars Kelly Clarkson (2002), Ruben Studdard (2003), Fantasia Barrino (2004), Jennifer Hudson (2004), Carrie Underwood (2005), Taylor Hicks (2006), Jordin Sparks (2007) and David Cook (2008), among others. Cowell has become known for combining his music and television interests. He set up another company, SYCOtv, in 2002. The company created the television shows American Inventor, Americas Got Talent and X-Factor. The group also produces records for many of the performers on Cowells shows including albums for Leona Lewis and Il Divo. New point: In 2011, Cowell helped import his hit British series The X Factor to America. The show is a talent search that awards a $5 million recording contract toà the winner. Cowell even gave up his judging duties on American Idol to sit front and center at The X Factor auditions. Television viewers loved this competition, which proved to be a success in the ratings. Cowells fellow judges included legendary recording executive L.A. Reid, former American Idol judge and singer Paula Abdul, and singer Nicole Scherzinger of Pussycat Dolls fame. The X Factor kicked off its second season in September 2012 with a few line-up changes. Pop star Britney Spears and actress-singer Demi Lovato joined the show as judges, replacing Abdul and Scherzinger. For the third season, the series made yet another change to the members of the judges panel, replacing Reid and Spears for Kelly Rowland and Paulina Rubio. Mario Lopez also stepped in as the primary host for the show after co-hosting with Khloe Kardashian during the second season. Industry Recognition In 2004, Entertainment Weekly named Simon Cowell as one of the Top Entertainers of the Year. In 2006, he renewed his contract with American Idol for five more seasons; the deal gave him a yearly salary of $40 million. That same year, he was named Varietys UK Personality of the Year. In 2007, Cowell earned the No. 3 slot on the Forbes TV Faces List, and No. 21 on Forbes Celebrity 100 Power List. He also created an American Idol spin-off, Idol Gives Back, a two-episode special that helped to provide aid to children in Africa and the American poor. The show raised $76 million for charity. Personal Life Since his time on American Idol, Cowell has been romantically linked to several women in public relationships. Rumors began to swirl after Cowell was seen flirting with his Idol co-host Paula Abdul that the two were an item. However, both celebrities confirmed that they were merely friends, despite their chemistry on camera. In early 2010, Cowell announced that he was engaged to Idol makeup artist Mezghan Hussainy. The couple broke off their engagement in 2012, with Cowell saying, We came to the conclusion that Im a hopeless boyfriend. He also reportedly gave Hussainy a à £5million mansion in Beverly Hills as a parting gift. In December of the same year, Cowell confirmed that he was dating actress and model Carmen Electra. The relationship only lasted a few months, with Cowell confirming that the twoà had separated in early 2013. In 2009, Cowell revealed that he had no intention of having children, stating, With kids, youve got a routine you cant escape from. Youve got to be up at a certain time, got to listen, when all you want to do is sit in a corner thinking. His position on kids softened three years later during an interview with AOL in 2012, during which he stated I do really, really like kids, because I can talk to them and listen toIve always dedicated all my life to work, and at 52, Ive probably missed the opportunity. Despite his views on parenthood, a source told US Weekly in July 2013 that Cowell was expecting his first child with Lauren Silverman, wife of his close friend Andrew Silverman. Although Andrew and Laura Silverman are technically still married, them. The problem has always been how much time you need to devote to bringing up kids. the source told Us Weekly that a divorce has been in the works for a while. Cowell has yet to comment on his alleged part in the high profile pregnancy.
Tuesday, January 21, 2020
Media, Appearance and Eating Disorders Essay -- Argumentative Persuasi
Media, Appearance and Eating Disorders à Many women are concerned with their appearance. Too many of them are caught up with the image of being skinny and pretty. By seeing all the beautiful, thin women in the media and in society, they may feel insecure about the way they look. Therefore, they try and do anything they can to acquire that appearance. Methods they use to try and achieve this are by self-starvation, known as Anorexia, or induced vomiting, known as Bulimia. Anorexia nervosa and bulimia nervosa are only two of the eating disorders that often result from their incessant desire to be thin and "beautiful." Eating disorders, such as these, also occur amongst men. However, it is less common. "Standards for males simply are not as extreme or as inimical to normal body builds as are women's standards" (Fallon, Katzman, and Wooley 8). It is not just the biological aspect, though, that makes this occur more often in women. Fallon, Katzman, and Wooley claim On even a practical level, women's self-image, their social and economic success and even their survival can still be determined largely by their beauty and by the men it allows them to attract, while for men these are based largely on how they act and what they accomplish. Looks simply are of secondary importance for male success. (9) Beauty and fashion are also in part with their desire for social acceptance and success. Women try to meet an unreasonable weight standard because fashion requires them to. Men are encouraged to be strong and powerful. As they work to develop their power in the gym and at work, they associate "thin" with "skinny" and "weak." Even though female models often look frail, (which men hate in themselves), fema... ...school, a majority of the guys would pine after the thin, pretty girls. The girls, "with meat on them," would often be jealous of, therefore, feeling they are not thin enough to be beautiful. Low self-esteem and eating disorders would then result from these feelings. I, personally, do not think that "thin is beautiful." Not only by your exterior, but what kind of a person you are and what you have inside, makes you beautiful. à à Works Cited Anorexia Nervosa and Related Eating Disorders, Inc. Updated September 2001. http://www.anred.com. November 27, 2001. Fallon, Patricia, Melanie A. Katzman, and Susan C. Wooley, eds. Feminist Perspectives on Eating Disorders. New York: Guilford Press, 1994. Wolf, Naomi. "The Beauty Myth." Signs of Life. 3rd edition. Comp. and ed. Sonia Maasik and Jack Solomon. New York: St. Martin's Press. 2000. 481-89.
Monday, January 13, 2020
Lab Report Essay
Lab Report: Exercise 2: Blood Purpose: Explain why you did this lab and what if any safety precautions needed to be followed. This lab was done to learn about blood on a micro and macroscopic level. There are safety concerns when using bodily fluids. Gloves were needed and caution with the use of the lancet was important, which included keeping it sterile. Activity 1: Observing Your Own Blood Observations: Sketch and describe what you saw on the prepared slide of human blood: White blood cells are a light pinkish color and clearer in the center. The doghnut shape was not easy to see but can be made out. The centers are clearer because there is less mass there. The white blood cells were dark and looked very similar to me. Sketch and describe what you saw on the blood smear slide using your own blood: There were a lot less white blood cells on my slide of my own blood. The red blood cells also seems to be more grouped into certain sections. Iââ¬â¢m curious if I cut my foot if that would increase the amount of white blood cells in circulatory rotation or would the increase in white blood cells only happen around the cut area of my foot. I think I may have to try this experiment next time a scrape something. Questions: A.What are the components of blood? The main components include three types of cells (leukocytes, erythrocytes and platelets) and plasma. B.List the five types of leukocytes and describe the function of each. Neutrophils comprise 60-70% of white blood cells. They are the first to respond to infection and move into tissues and phagocytize bacteria and foreign matter. They also secrete enzymes called lysozumes that destroy certain bacteria. Eosinophils comprise 2-4% of white blood cells. They enter tissues undergoing an allergic response. They reduce the inflammatory response by producing enzymes that destroy inflammatory chemicals, such as histamine. They also release toxic chemicals that attack certain work parasites. Basophils comprise .5-1% of white blood cells. They increase in number during allergic and inflammatory reactions. They release histamine to increase inflammation and heparin to inhibit blood clotting. Lymphocytes comprise 20-25% of white blood cells. They play an important role in immunity and produce antibodies. Monocytes comprise 3-8% of white blood cells. They leave the circulation and become macrophages and phagocytize bacteria, dead cells, cell fragments, and other debris. C.What did you learn making a blood smear slide? I learned that milking the incision site is not a good idea because it forces tissue fluid out as well as blood. This was not something I considered before. I also learned that you have to wait a while for the Wrightââ¬â¢s stain to take hold of the cells. Had I not read closely I may have rushed this step and not got cells that I could see easily. I also learned that in order to get a better look at the cells one needs to look at a thinner area because the thicker areas overlap cells which makes it difficult to observe them. Activity 2: Blood Typing Observations: What is your blood and Rh type? Type O+ Questions: A.Describe how the ABO blood typing system works. In the ABO blood type, there are two main anitgens or agglutinogens, A and B. A type has the A antigen, B type B antigen, O none, and AB both the A and B antigen. O is a universal donor due to its lack of antigens and AB is a univeral reciepient due to the fact that it has both antigens. If the A antibodies find A antigens on red blood cells we say the personââ¬â¢s blood is type A. B.Why is it important for everyone to know their own blood type? In an emergency situation a person may not have time to have their blood tested. There may not even be a way to test there blood when a situation that requires a blood tansfussion occurs. In this situation the person trying to administer the transfusion needs to know what type of blood the recipient has because transfusing the wrong type of blood is dangerous and will be rejected by receivers body. If I was ship wrecked I would want to know who had what type of blood so that in an emergency situation blood could be transfused. That is assuming that equipment for such a procedure was available. I have a catheter from my nursing classes bag in my car at all times. If natural disaster strikes, Iââ¬â¢m slightly prepared. C.Describe what would happen if type A blood were transfused into a person with type B blood. A transfusion reaction will occur, meaning that a reaction occurs when the antigens on the red blood cells of the donor blood react with the antibodies in the recipientââ¬â¢s plasma. This causes the red blood cells to clump together and plug up blood vessels. Then the cells are destroyed by the body (hemolysis), releasing hemoglobin from the red blood cells into the blood. Hemoglobin is then broken down into bilirubin, which can cause jaundice. D.What happens in the blood of an Rh-negative individual who is exposed to Rh-positive blood? The Rh negative person develops antibodies that attack Rh positive blood. This can be a serious problem for a pregnant mother with a Rh positive child. The disorder is called HDN. Activity 3: Review of Blood 1.Log onto the Hands-On Labs Website and click on exercise 2. 2.Click on the link ââ¬Å"Get Body Smartâ⬠. 3.Click on the ââ¬Å"Circulatory Systemâ⬠. 4.Review each of the following modules: Introduction to the blood, Red Blood Cells, White Blood Cells, and Coagulation. 5.Explain how the various elements found in blood work together to provide a unified function for the body. The main function of blood is to be a delivery system. It is like the highway of your body. Or actually more like the trucks of your body and the veins and arteries are the roads. The blood transports oxygen and nutrients to tissues. In order to do this many elements work together in the blood. The hemoglobin is responsible for oxygen transportation. Iron acts as a binding agent. White blood cells are the police of the road. They protect the cargo and destinations it is shipped to. They also clean up any messes that are left around (busted red blood cells, foreign bodies, bacteria). The albumin in the plasma regulates osmotic pressure so that the traffic flows appropriately, The different white blood cells control other problems by increasing macrophages and inflammation or decreasing inflammation. The body is a mini city with eveything working toward homeostasis, and the blood is no exception. Conclusion: Describe how leukemia affects the functional capacity of the blood. Leukemia results in an increase of blood cells that can clog bone marrow and blood vessels. The thrombosis result in an inability of blood cells to pass and blood count decreases. This result in a decreased ability of the blood to carry oxygen.
Sunday, January 5, 2020
Analysis Of The Poem My August Guest By Robert Frost...
Paper #1: Formalist Analysis The term ââ¬Å"formalismâ⬠refers to a critical approach that analyzes, interprets, or evaluates the features of a text. These features include not only grammar and syntax but also literary devices such as meter, and metaphor. The formalist approach does not pay attention to a text s historical, biographical, or geographical context. A formal analysis, is the formal analyzation of a text. This paper will delve into the formal analysis of two distinct poems, written by different authors. The emphasis will be on the physical elements, or structure of the poetry, less on the meaning. In the first poem ââ¬Å"My November Guestâ⬠by Robert Frost, we will discuss the formal analysis, which includes the style, metre, rhyme, figurative language, etc. In the second poem ââ¬Å"You Called Me Corazonâ⬠we will discuss the formal analysis as well. In Robert Frostââ¬â¢s ââ¬Å"My November Guestâ⬠, the first thing you will notice about the poem is that it consists of four stanzas, (a stanza is the proper name for a verse) with each stanza containing five lines, (the poem contains four lines per stanza, also known as a quatrain). A poem with five line stanzas is referred to as a quintet. Inside the lines of the poem, there is evidence of iambic tetrameter. Meaning, there are four iambic feet (refers to groups of unstressed, and stressed syllables constituting a metrical unit), per line in this poem. Tetrameter, is a verse of four measures. In iambic tetrameter, an unstressed syllable isShow MoreRelatedStephen P. Robbins Timothy A. Judge (2011) Organizational Behaviour 15th Edition New Jersey: Prentice Hall393164 Words à |à 1573 PagesDiversity Management Strategies 56 Attracting, Selecting, Developing, and Retaining Diverse Employees 56 â⬠¢ Diversity in Groups 58 â⬠¢ Effective Diversity Programs 58 Summary and Implications for Managers 60 S A L Self-Assessment Library Whatââ¬â¢s My Attitude Toward Older People? 40 Myth or Science? ââ¬Å"Dual-Career Couples Divorce Lessâ⬠47 An Ethical Choice Religious Tattoos 51 glOBalization! Images of Diversity from Around the Globe 54 Point/Counterpoint Men Have More Mathematical Ability Than WomenRead MoreOrganisational Theory230255 Words à |à 922 Pages. Organization Theory Challenges and Perspectives John McAuley, Joanne Duberley and Phil Johnson . This book is, to my knowledge, the most comprehensive and reliable guide to organisational theory currently available. What is needed is a text that will give a good idea of the breadth and complexity of this important subject, and this is precisely what McAuley, Duberley and Johnson have provided. They have done some sterling service in bringing together the very diverse strands of work
Saturday, December 28, 2019
Things I Learned about Myself as a College Student
The score I received on the study skill inventory that where high are textbooks, note taking, memory, and concentration. The study skill inventory that I scored low on is test prep and time management. The reason why I scored low in test prep was because I do not think I prepared well for test. I also believe that I scored low on this because I do not take proper notes that are full in details. I do not put enough time into studying like I should. The reason why I scored low on time management is because I donââ¬â¢t manage my time well. I also do not have a set schedule where I plan on doing school work. Which leads me to procrastinate so I decide to do everything the last minute right before it is due. One thing that I learned about myself as a college student this semester is that I need to push myself to study more and take better notes because it will pay off when exams come. Especially because college course are much more complicated than high school because you donââ¬â¢t have 9 months to learn everything in one textbook. The second thing that I learned about myself as a college student is that I am more independent and I donââ¬â¢t rely on my parent to pay for my college textbooks or tuition. I pay it on my own. I also have to push myself more to get things done on my own. My parents are not there to nag me to do something or help me. The third thing that I learned about myself as a college student is balancing my social life from work and school. I learned that my social life hasShow MoreRelatedImportance Of My Life Changing Experience In College1105 Words à |à 5 Pageschanged completely. I began my journey as a college student. I was extremely nervous, but excited at the same time. I waited for this moment for so long. 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Helping me to build effective ways to get good grades in my other classes by building effective study habits then ineffective study habits I have been using previously. Thus I have improved in many ways than one inRead MoreGraduation Speech On Academic Probation951 Words à |à 4 PagesNo college student heads to college planning to be on academic probation and possibly dismissal. But reality, it can happen to anyone. It happened to my classmates and I and I know each and every one of them did not want to receive that email. Academic probation is a warning that students get when their performance falls below the college or universityââ¬â¢s requirement for good academic standing. When I received my em ail, I was shocked and did not know what I was going to do next. I have never had a
Friday, December 20, 2019
The Impact of Ophelia on Shakespeares Hamlet Essay
The Impact of Ophelia on Hamlet Michael Pennington in ââ¬Å"Ophelia: Madness Her Only Safe Haven,â⬠elucidates the character of Ophelia in Shakespeareââ¬â¢s tragedy, Hamlet: This is the woman she might have become ââ¬â warm, tolerant and imaginative. Instead she becomes jagged, benighted and imaginative. . . .Ophelia is made mad not only by circumstance but by something in herself. A personality forced into such deep hiding that it has seemed almost vacant, has all the time been so painfully open to impressions that they now usurp her reflexes and take possession of her. She has loved, or been prepared to love, the wrong man; her father has brought disaster on himself, and she has no mother: she is terribly lonely. (73-74)â⬠¦show more contentâ⬠¦So poor Ophelia is again asked to conform her will to the wishes of another, this time her only living parent, her father. When the ghost talks privately to Hamlet, he learns not only about the murder of his father, but also about the unfaithfulness and adultery of his mother. Gertrude was seduced by ââ¬Å"that incestuous, that adulterate beast,/With witchcraft of his wit, with traitorous giftsâ⬠ââ¬â Claudius himself ââ¬â prior to his brotherââ¬â¢s passing. ââ¬Å"So lust, though to a radiant angel linkd,/Will sate itself in a celestial bed,/And prey on garbage.â⬠In the mind of Hamlet, this drastically reduces the goodness of womankind generally. Hamlet chooses to use an ââ¬Å"antic dispositionâ⬠to disguise his actions as he maneuvers to kill the one who poisoned his father in the garden. Wilkie and Hurt say that Shakespeare ââ¬Å"is particularly fond of double-plotting.â⬠(2156) Ophelia is shortly affected by the protagonistââ¬â¢s mad conduct. And immediately she goes to her father, Polonius, to explain how she is ââ¬Å"so affrightedâ⬠as a result of Hamletââ¬â¢s visit: My lord, as I was sewing in my closet, Lord Hamlet, with his doublet all unbraced; No hat upon his head; his stockings fould, Ungarterd, and down-gyved to his ancle; Pale as his shirt; his knees knocking each other; And with a look so piteous in purport As if he had beenShow MoreRelatedWilliam Shakespeare s Hamlet - Conversation Enabler1332 Words à |à 6 PagesConversation-Enabler In Shakespeareââ¬â¢s Hamlet, Ophelia is one of the most elusive characters of the play and her importance is very hard to pinpoint and has raised eyebrows for centuries. For example, the scene of her death is one that artists have depicted over and over, yet that iconic moment is merely alluded to and happens off stage. This reflects Opheliaââ¬â¢s character very well considering that she is often at the periphery of the action; more talked about then talked to. There are many questionsRead MoreSimilarities Between Hamlet And The Lion King1535 Words à |à 7 Pages Hamlet and The Lion King The Shakespeareââ¬â¢s critical analysis William Shakespeare Hamlet is a play that is written about tragedy in the late middle ages. On the other hand, Lion king is a todayââ¬â¢s compelling Disney movie that kids and adults both love to watch. In addition, both films partake a lot of similarities since Lion King was inspired by Hamlet. The lion king and the hamlet have the same plots but different outcomes. Hamlet can serve as a metaphor for lion king and the long-termRead MoreEssay on The Character of Ophelia in Shakespeares Hamlet1169 Words à |à 5 PagesThe Character of Ophelia in Hamlet à à à à In Shakespeares play, Hamlet, the character Ophelia plays an important role in the elaboration of the plot.à In the beginning, she is in a healthy state of mind, in love with Hamlet, yet controlled by her father.à During the play she has several troubling experiences involving Hamlet - causing her to become distressed.à The death of Ophelias father leaves her mentally unstable and in a state of madness that eventually leads to her own death. à à à à à à à à à à Read MoreHuman Nature In Hamlet737 Words à |à 3 PagesThroughout, Shakespeareââ¬â¢s play, Hamlet, Prince of Denmark (Hamlet), he exposes how relationships between characters influences their fates. 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Wednesday, December 11, 2019
Dangerous Recreational Activity and Materialisation
Question: Discuss about the Dangerous Recreational Activity and Materialisation. Answer: Introduction: The defendant that is Alexander Fallas shot his friend accidentally, who is the plaintiff, Con Mourlas in the leg. Both the plaintiff and the defendant were parts of four friends who had traveled all the way from Sydney to Bathurst in search of spotlighting kangaroos and before going for this mission; they had "a couple of beers" with dinner. In this case, the application of Section 5K and 5L of the Civil Liability (Personal Responsibility) Act, 2002 New South Wales has been taken under consideration (Austlii.edu, 2016). In Section 5L, it has been provided that the defendant will not be liable for negligence in any matter if there is the materialization of an obvious risk of any dangerous recreational activity in which the plaintiff also engages in irrespective of whether the plaintiff is aware of the matter or not. In the trial court, it was held that the defendant was liable for negligence, and he had no immunity under Section 5L of the Civil Liability Act. Two issues were taken into consideration in the decision of the Court of Appeal. Ipp and Tobias JJA determined whether spotlighting was a dangerous recreational activity and whether the risk that was materialized in the given instance was an obvious risk or not. The plaintiff contended that the risk that was being stated as a defense by the defendant was not an obvious risk in the given instance. It was agreed that the action was dangerous one in which the four of them were engaged in (Casenotes.curwoods.com.au, 2016). This is because they were not experienced kangaroo hunters and were amateurs in this field. Moreover, they drove for a long distance and had also consumed some amount of alcohol. On top of this, apart from the defendant, none of the other people had a license for owning a gun. In these circumstances, it was agreed that the recreational activity of kangaroo spotlighting was a dangerous one. However, the risk that was associated with the same and the risk that materialized were not one and the same thing. It was contended that Fallas re-entering the car and firing a shot at Mourlas while unjamming the gun was not an obvious risk that was associated with spotlighting kangaroos. From the definition of obvious risk in Section 5F, i t is clear that one should have regard to a particular circumstance in which the respondent suffers a relevant harm. A determination is given as to whether the risk that causes the suffering and those harms are obvious in the eyes of any other reasonable person who has been in his position. To determine whether the activity in which the respondent was engaged was a dangerous recreational activity or not, it is essential to make a note of all those things and circumstances that took place immediately before the suffering of the relevant harm of the respondent. Then a determination should be made as to whether the risk that in fact materialized was an obvious one or not (Hilson, 2008). In this incident, the activity with which Mourlas was engaged was that of sitting in a vehicle and holding the spotlight for his other three friends who were the shooters and were outside the vehicle in most of the times. In this situation, one or more of the shooters would have left or entered the vehicle with or without guns which could or could not have been loaded at any point in time when the activity was in action. This activity is solely carried on by the plaintiff, and it is limited and distinguishable from other activities that constitute and qualify within the description of shooting kangaroos by spotlight (Barristerdirect.com.au, 2015). Mourlas was sitting inside the car, and when Fallas entered the car, he repeatedly asked him not to do it and also warned him about the loaded gun. The other hand told him that the gun was not loaded and that he was careful enough and also said that he was sure that no harm would be caused to anyone because of his presence in the car. In si milar circumstances, it can be said that Mourlas was aware of the risk, and he was also sure about the fact that a loaded gun could have caused injury. However, this was not a part of the spotlighting of kangaroos and thus, with the recreational sport of spotlighting kangaroos, the entering of the vehicle with the loaded gun was not a part thereof (Fallas v Mourlas, [2006]). Thus, it is evident in the present matter that the risk which materialized was not a part of the sport, and hence immunity cannot be claimed by the defendant in the matter under Section 5L of the Civil Liability Act (Katsivela, 2014). The reasonability test is also not being satisfied in the given instance. No other reasonable person could have guessed that an unloaded gun could have caused an injury in similar circumstances. However, it was just the opposite that happened in the given instance and hence it can be said that the defendant was liable for negligence in the matter and cannot claim any immunity. Thus, it can be concluded saying that Mourlas is liable to be indemnified in the matter, and both the Trial Judge as well as the Court of Appeal were justified in upholding their decisions. References Austlii.edu. (2016).Austlii.edu. [online] Available at: https://www.austlii.edu.au/cgi-bin/sinodisp/au/cases/nsw/NSWCA/2006/32.html?stem=0synonyms=0query=title(Fallas%20and%20Mourlas%20)#disp86 [Accessed 14 Sep. 2016]. Barristerdirect.com.au. (2015).CLA: dangerous recreational activity not necessarily an obvious risk. [online] Available at: https://www.barristerdirect.com.au/cla-dangerous-recreational-activity-not-necessarily-an-obvious-risk/ [Accessed 14 Sep. 2016]. Casenotes.curwoods.com.au. (2016).Dangerous Recreational Activity and Materialisation of an Obvious Risk: Fallas -v- Mourlas [2006] NSWCA 32 | Curwoods Case Notes. [online] Available at: https://casenotes.curwoods.com.au/?p=1090 [Accessed 14 Sep. 2016]. Fallas v Mourlas[2006] NSWCA p.32. Hilson, C. (2008). Let's Get Physical: Civil Liability and the Perception of Risk.Journal of Environmental Law, 21(1), pp.33-57. Katsivela, M. (2014). The Assumption of Risk Defence in Torts (Common Law) and Extra-contractual Liability (Qubec Civil Law) in Canada.Comparative Law Review, 17, p.13.
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