Honest Services Fraud after Skilling.

The United States Supreme Court ruling in Skilling v. United States limits honest services fraud prosecutions of both public officials and private individuals to schemes involving bribes or kickbacks. Over the past two decades, federal prosecutors have used the federal mail and wire fraud statutes to reach schemes which deprive citizens of their money or property and of the intangible right to honest services. The Court’s ruling in Skilling removes a category of deceptive, fraudulent, and corrupt conduct from the scope of the honest services law. By limiting honest services fraud under the statute to bribes and kickbacks, the Court fashioned elements to provide clearer notice as to criminal conduct. The assessment of the need for new legislation to fill the void created may be guided by thoughtful consideration of the development of honest services fraud prosecutions and the difficulties in fashioning defining principles. Under the honest services theory of mail and wire fraud, the focus is on the corruption rather than the victim or the offender. Under this theory the Government must prove the victim was deprived of the right to honest services. The United States Supreme Court’s decision in Skilling resolved the inconsistencies and conflicts in the interpretation of honest services fraud under 18 U.S.C. § 1346. Skilling restored §§ 1346, 1341, and 1343 to their traditional focus on schemes to defraud or deprive victims of money or property. The statutes further provide clear notice to citizens as to what conduct is prohibited, but Skilling also removed undisclosed self-dealing from the scope of federal honest services law. It is likely Congress will be called upon to restore the ability of federal prosecutors to address this significant category of fraudulent and corrupt conduct

Honest Services Fraud after Skilling.

The United States Supreme Court ruling in Skilling v. United States limits honest services fraud prosecutions of both public officials and private individuals to schemes involving bribes or kickbacks. Over the past two decades, federal prosecutors have used the federal mail and wire fraud statutes to reach schemes which deprive citizens of their money or property and of the intangible right to honest services. The Court’s ruling in Skilling removes a category of deceptive, fraudulent, and corrupt conduct from the scope of the honest services law. By limiting honest services fraud under the statute to bribes and kickbacks, the Court fashioned elements to provide clearer notice as to criminal conduct. The assessment of the need for new legislation to fill the void created may be guided by thoughtful consideration of the development of honest services fraud prosecutions and the difficulties in fashioning defining principles. Under the honest services theory of mail and wire fraud, the focus is on the corruption rather than the victim or the offender. Under this theory the Government must prove the victim was deprived of the right to honest services. The United States Supreme Court’s decision in Skilling resolved the inconsistencies and conflicts in the interpretation of honest services fraud under 18 U.S.C. § 1346. Skilling restored §§ 1346, 1341, and 1343 to their traditional focus on schemes to defraud or deprive victims of money or property. The statutes further provide clear notice to citizens as to what conduct is prohibited, but Skilling also removed undisclosed self-dealing from the scope of federal honest services law. It is likely Congress will be called upon to restore the ability of federal prosecutors to address this significant category of fraudulent and corrupt conduct

A 3-Month interdisciplinary Process Drama Program to Build Social Skills in Pre-Schoolers with ASD: A Feasibility Study

Objectives: To test the feasibility and effect of an interdisciplinary process drama program targeting social skill development in 3-5 year-old children with Autism Spectrum Disorder (ASD) characteristics To develop a paradigm for testing brain-behavior relationships related to social skills in these children using EEG and testing its ability to detect intervention-related changes. Background: Social skill deficits are a hallmark cause of disability in ASD. Such disability is of critical concern given the rising prevalence (1 in 54 Utah children) of ASD. [1] As children learn through social experiences, difficulty in social interactions can limit development and ability to succeed in school and eventually employment. One possible contributor to social interaction difficulties in ASD is a deficit in theory of mind (ToM), the ability to understand others\u27 perspectives, proposed to rely on memories of cognitive and emotional events that allow one to experience others\u27 situations as if they were one\u27s own. [2.3] Children with ASD have deficits in ToM [2,3] and show aberrant neural activation patterns in areas most typically activated during ToM tasks in healthy children. [4,5] An effective intervention fostering generalizable social skill development in children with ASD remains elusive. We propose to address this need with an interdisciplinary process drama intervention involving collaboration among occupational therapists (OT), theatre faculty/teachers, and speech language pathologists (SLP) to improve social interactions in preschoolers with ASD. Process drama may be an excellent medium for fostering social skill development due to the ability to create specific learning experiences in an autotelic manner [6] in which people experience the embodied cognition and emotions without conscious commitment to abstract social skill improvement goals. The scenes can emphasize social and emotional cues and explicit identification of scene-related feelings for the formation of social cognitive and emotional memories that can be recalled as the basis for later social functioning.[3] Process drama programs foster communication development in typically developing children [7] and a few studies have shown such programs enhance social skills of children aged 8-17 with ASD [8,9] However, targeting process drama intervention in preschool children may have the greatest potential for effect on ToM and subsequent social skill development. The overpruning hypothesis [10] proposes that ASD results from abnormal neural pruning in widespread neural networks, with weaker long-range connections being more vulnerable to major disruption. As neural connections strengthen through experience,[11] providing interventions targeting desired processing will strengthen associated connections making them less susceptible to pruning and resulting in preserved function. Peak synaptic density for auditory and prefrontal cortices, both involved in social skills, occurs between age 3-5 years [11], suggesting an optimal period for strengthening connections through intervention. Impact: The deficits in social skills of people with ASD significantly affect their ability to function in society. These deficits take a large toll on families and on independence and employability of the individual. Finding effective interventions to facilitate social skills would have a large impact on society by reducing disability in this prevalent population. Results: The primary goal of the proposed study is to gather preliminary data on potential utility of an interdisciplinary process drama intervention to improve social skills in children with ASD. We will address the following specific aims: 1) determine the feasibility of: a) the protocol for collecting neural activation data via EEG on preschoolers with ASD characteristics; b) conducting a 3 month, 3x/week process drama intervention program led by a collaborative team of theatre teachers, OTs and SLPs aimed at improving social skills. 2) Determine preliminary effects of this interdisciplinary intervention on: a) increasing positive social behaviors; b) changes in neural activation during social tasks

Arabidopsis thaliana XRN2 is required for primary cleavage in the pre-ribosomal RNA

Three Rat1/Xrn2 homologues exist in Arabidopsis thaliana: nuclear AtXRN2 and AtXRN3, and cytoplasmic AtXRN4. The latter has a role in degrading 3′ products of miRNA-mediated mRNA cleavage, whereas all three proteins act as endogenous post-transcriptional gene silencing suppressors. Here we show that, similar to yeast nuclear Rat1, AtXRN2 has a role in ribosomal RNA processing. The lack of AtXRN2, however, does not result in defective formation of rRNA 5′-ends but inhibits endonucleolytic cleavage at the primary site P in the pre-rRNA resulting in the accumulation of the 35S* precursor. This does not lead to a decrease in mature rRNAs, as additional cleavages occur downstream of site P. Supplementing a P-site cleavage-deficient xrn2 plant extract with the recombinant protein restores processing activity, indicating direct participation of AtXRN2 in this process. Our data suggest that the 5′ external transcribed spacer is shortened by AtXRN2 prior to cleavage at site P and that this initial exonucleolytic trimming is required to expose site P for subsequent endonucleolytic processing by the U3 snoRNP complex. We also show that some rRNA precursors and excised spacer fragments that accumulate in the absence of AtXRN2 and AtXRN3 are polyadenylated, indicating that these nucleases contribute to polyadenylation-dependent nuclear RNA surveillance

Niveau d’empathie des étudiants en kinésithérapie

peer reviewe

Communication Interventions for Minimally Verbal Children With Autism: A Sequential Multiple Assignment Randomized Trial

ObjectiveThis study tested the effect of beginning treatment with a speech-generating device (SGD) in the context of a blended, adaptive treatment design for improving spontaneous, communicative utterances in school-aged, minimally verbal children with autism.MethodA total of 61 minimally verbal children with autism, aged 5 to 8 years, were randomized to a blended developmental/behavioral intervention (JASP+EMT) with or without the augmentation of a SGD for 6 months with a 3-month follow-up. The intervention consisted of 2 stages. In stage 1, all children received 2 sessions per week for 3 months. Stage 2 intervention was adapted (by increased sessions or adding the SGD) based on the child's early response. The primary outcome was the total number of spontaneous communicative utterances; secondary measures were the total number of novel words and total comments from a natural language sample.ResultsPrimary aim results found improvements in spontaneous communicative utterances, novel words, and comments that all favored the blended behavioral intervention that began by including an SGD (JASP+EMT+SGD) as opposed to spoken words alone (JASP+EMT). Secondary aim results suggest that the adaptive intervention beginning with JASP+EMT+SGD and intensifying JASP+EMT+SGD for children who were slow responders led to better posttreatment outcomes.ConclusionMinimally verbal school-aged children can make significant and rapid gains in spoken spontaneous language with a novel, blended intervention that focuses on joint engagement and play skills and incorporates an SGD. Future studies should further explore the tailoring design used in this study to better understand children's response to treatment. Clinical trial registration information-Developmental and Augmented Intervention for Facilitating Expressive Language (CCNIA); http://clinicaltrials.gov/; NCT01013545