Creditors, Keepers: Passive Retention of Estate Property and the Automatic Stay

The automatic stay provision is one of the most important provisions in the Bankruptcy Code. Until recently, however, it has remained unclear if passive retention of property of the bankruptcy estate must be immediately turned over to the debtor under the automatic stay provision. The Supreme Court decided in City of Chicago v. Fulton that passive retention does not violate the automatic stay, saving creditors from the consequences of retaining estate property. The debate about the stay, however, is far from over. Many circuit courts were already concerned about the policy issues deriving from the City of Chicago maintaining possession over debtors’ vehicles, rendering debtors unable to get to work or pay off their debts during the bankruptcy plan. Justice Sotomayor remains frustrated about these policy concerns and called on Congress to change the Code and enable debtors to be more successful in their payment plans. This Note suggests Congress make language and cross-reference changes to the Bankruptcy Code to satisfy both textual and policy issues associated with the current Code

An evaluation of exercises for the development of word recognition and word meaning in grade five

Thesis (Ed.M.)--Boston Universit

An evaluation of exercises for the development of word recognition and word meaning in grade five

Thesis (Ed.M.)--Boston Universit

Antenatal self-hypnosis for labour and childbirth: A pilot study

Publisher's copy made available with the permission of the publisher © Australian Society of AnaesthetistsIn our institution we have used antenatal training in self-hypnosis for over three years as a tool to provide relaxation, anxiolysis and analgesia for women in labour. To assess the effects of hypnotherapy, we prospectively collected data related to the use of hypnosis in preparation for childbirth, and compared the birth outcomes of women experiencing antenatal hypnosis with parity and gestational age matched controls. Methods: Prospective data about women taught self-hypnosis in preparation for childbirth were collected between August 2002 and August 2004. Birth outcome data of women using hypnosis were compared with routinely collected retrospective data from parity and gestational age matched women delivering after 37 weeks gestation during 2003. Results: Seventy-seven antenatal women consecutively taught self-hypnosis in preparation for childbirth were compared with 3,249 parity and gestational age matched controls. Of the women taught antenatal self-hypnosis, nulliparous parturients used fewer epidurals: 36% (18/50) compared with 53% (765/1436) of controls (RR 0.68 [95% CI 0.47-0.98]); and required less augmentation: 18% (9/50) vs 36% (523/1436) (RR 0.48 [95%CI 0.27-0.90]). Conclusions: Our clinical findings are consistent with recent meta-analyses showing beneficial outcomes associated with the use of hypnosis in childbirth. Adequately powered, randomized trials are required to further elucidate the effects of hypnosis preparation for childbirth.A. M. Cyna, M. I. Andrew, G. L. McAuliff

Evaluation and nonsurgical management of rotator cuff calcific tendinopathy.

Rotator cuff calcific tendinopathy is a common finding that accounts for about 7% of patients with shoulder pain. There are numerous theories on the pathogenesis of rotator cuff calcific tendinopathy. The diagnosis is confirmed with radiography, MRI or ultrasound. There are numerous conservative treatment options available and most patients can be managed successfully without surgical intervention. Nonsteroidal anti-inflammatory drugs and multiple modalities are often used to manage pain and inflammation; physical therapy can help improve scapular mechanics and decrease dynamic impingement; ultrasound-guided needle aspiration and lavage techniques can provide long-term improvement in pain and function in these patients

CV20017

This report provides the main results and findings of the fifteenth annual underwater television survey on the ‘Smalls grounds’ ICES assessment area; Functional Unit 22. The survey was multi-disciplinary in nature collecting UWTV and other ecosystem data. A total of 40 UWTV stations were surveyed successfully (high quality image data), carried out over an isometric grid at 4.5nmi or 8.3km intervals. The precision, with a CV of 8%, was well below the upper limit of 20% recommended by SGNEPS (ICES, 2012). The 2020 abundance estimate was 33% lower than in 2019 and at 750 million is below the MSY Btrigger reference point (990 million). Using the 2020 estimate of abundance and updated stock data implies catch in 2021 that correspond to the F ranges in the EU multi annual plan for Western Waters are between 1238 and 1560 tonnes (assuming that discard rates and fishery selection patterns do not change from the average of 2017–2019). One species of sea pens was recorded as present at the stations surveyed: Virgularia mirabilis. Trawl marks were observed at 48% of the stations surveyed

Punishment is strongly motivated by revenge and weakly motivated by inequity aversion

There are two broad functional explanations for second-party punishment: fitness-leveling and deterrence. The former suggests that people punish to reduce fitness differences, while the latter suggests that people punish in order to reciprocate losses and deter others from inflicting losses on them in the future. We explore the relative roles of these motivations using a pre-registered, two-player experiment with 2426 US participants from Amazon Mechanical Turk. Participants played as the “responder” and were assigned to either a Take or Augment condition. In the Take condition, the “partner” could steal money from the responder's bonus or do nothing. In the Augment condition, the partner could augment the responder's bonus by giving them money at no cost to themselves or do nothing. We also manipulated the responders' starting endowments, such that after the partner's decision, responders experienced different payoff outcomes: advantageous inequity, equality, or varying degrees of disadvantageous inequity. Responders then decided whether to pay a cost to punish the partner. Punishment was clearly influenced by theft and was most frequent when theft resulted in disadvantageous inequity. However, people also punished in the absence of theft, particularly when confronted with disadvantageous inequity. While the effect of inequity on punishment was small, our results suggest that punishment is motivated by more than just the desire to reciprocate losses. These findings highlight the multiple motivations undergirding punishment and bear directly on functional explanations for the existence of punishment in human societies