13,594 research outputs found

    Employment and Wage Changes in Oil-Producing Counties in the Bakken Formation, 2007-2011

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    The Bakken Formation is an oil-producing shale formation underneath North Dakota, Montana, and parts of Canada. In recent years, horizontal drilling and hydraulic fracturing techniques, combined with higher prices for crude oil, have led to rapid increases in oil extraction from shale formations like the Bakken Formation. As of late 2011, North Dakota was the fourth largest oil-producing state, after Texas, Alaska, and California. The large increase in oil production has led to growth in employment and wages and has changed the industry profile of employment in the region

    Civil Procedure and the Ministerial Exception

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    In Hosanna-Tabor Evangelical Lutheran Church & School v. EEOC, the U.S. Supreme Court recognized a ministerial exception to the ordinary rules of employer liability. The Court also concluded that the exception operates as an affirmative defense rather than a jurisdictional bar. This conclusion raises quite significant questions about how courts should address the exception in the course of litigation. This Article posits that courts should approach these procedural questions in light of the underlying justification for the ministerial exception. The exception reflects a longstanding constitutional limitation on the competence of courts to resolve “strictly and purely ecclesiastical” questions. To conclude that the exception operates as an affirmative defense does not alter this fundamental limitation on the authority of secular courts. As a practical matter, this means that in litigation between religious institutions and their employees, courts may be required to manage discovery to resolve threshold questions about the application of the ministerial exception before permitting broader discovery. Similarly, courts should consider permitting interlocutory appeals of trial court decisions that deny motions for summary judgment based on the exception. And courts not only should conclude that religious institutions do not waive the defense by failing to raise it but also ought to raise it sua sponte when the facts indicate that the exception may apply. These departures from the ordinary treatment of affirmative defenses are necessary to respect the constitutional principles that the Court articulated in Hosanna-Tabor

    Orbitofrontal epilepsy: Electroclinical analysis of surgical cases and literature review

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    Clinical and electrographic data were reviewed on 2 of our patients with orbitofrontal epilepsy who were seizure free at 5-year follow-up, and on 2 similar patients from the literature. One of our patients was lesional, and the other was nonlesional. Interictal EEG discharges were lateralized to the side of invasively recorded orbitofrontal seizures in the nonlesional case. In this case, no clinical manifestations occurred until the orbitofrontal discharge had spread to the opposite orbitofrontal and both mesial temporal areas. Unresponsiveness or arrest of activity were the initial manifestations of complex partial seizures in both cases. The 2 cases from the literature with long-term seizure-free follow-up had little impairment of awareness and displayed vigorous motor automatisms. Interictal epileptiform activity was bifrontally synchronous in 1 case. Ipsilateral frontotemporal discharges were seen in both. Invasive ictal epileptiform activity appeared maximal in the ipsilateral orbitofrontal region in both patients. No consistent electrographic or clinical pattern characterized these 4 cases. Seizures of orbitofrontal origin may be characterized by either unresponsiveness associated with oroalimentary automatisms or limited alteration of awareness and associated with vigorous motor automatisms. Invasive monitoring of the orbitofrontal cortex should be considered in nonlesional cases with complex partial seizures that show nonlocalizing ictal patterns and interictal frontal or frontotemporal epileptiform discharges. Copyright (C) 2004 S. Karger AG, Basel

    Seasonal variation of the three-dimensional mean circulation over the Scotian Shelf

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    The seasonal-mean circulation over the Scotian Shelf is studied numerically by computing mean and tidal current fields for winter, spring, and summer using a three-dimensional nonlinear diagnostic model. The mean current fields are forced by seasonal-mean baroclinic pressure gradients, tidal rectification, uniform wind stresses, and associated barotropic pressure gradients. A historical hydrographic database is used to determine the climatological mean baroclinic forcing. Upstream open boundary conditions are estimated from the density fields to give no normal geostrophic bottom flow and are specified as either along-boundary elevation gradients or depth-integrated normal velocities. The numerical solutions for nominal bimonthly periods (January–February, April–May, and July–August) reveal the dominant southwestward nearshore and shelf-break flows of relatively cool and fresh shelf water from the Gulf of St. Lawrence and Newfoundland Shelf, with speeds up to about 20 cm/s. The seasonal intensification of the southwestward flows is reproduced by the model, with the transport increasing from 0.3 Sv in summer to 0.9 Sv in winter on the inner Halifax section. There are also pronounced topographic-scale influences of submarine banks, basins, and cross-shelf channels on the circulation, such as anticyclonic gyres over banks and cyclonic gyres over basins. Baroclinicity is the dominant forcing throughout the domain, but tidal rectification is comparable on the southwestern Scotian Shelf (e.g., about 0.2 Sv recirculating transport around Browns Bank for all the periods). The mean wind stress generates offshore surface drift in winter. The solutions are in approximate agreement with observed currents and transports over the Scotian Shelf, although there are local discrepancies

    Simulating interventions in graphical chain models for longitudinal data

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    Simulating the outcome of an intervention is a central problem in many fields as this allows decision-makers to quantify the effect of any given strategy and, hence, to evaluate different schemes of actions. Simulation is particularly relevant in very large systems where the statistical model involves many variables that, possibly, interact with each other. In this case one usually has a large number of parameters whose interpretation becomes extremely difficult. Furthermore, in a real system, although one may have a unique target variable, there may be a number of variables which might, and often should, be logically considered predictors of the target outcome and, at the same time, responses of other variables of the system. An intervention taking place on a given variable, therefore, may affect the outcome either directly and indirectly though the way in which it affects other variables within the system. Graphical chain models are particularly helpful in depicting all of the paths through which an intervention may affect the final outcome. Furthermore, they identify all of the relevant conditional distributions and therefore they are particularly useful in driving the simulation process. Focussing on binary variables, we propose a method to simulate the effect of an intervention. Our approach, however, can be easily extended to continuous and mixed responses variables. We apply the proposed methodology to assess the effect that a policy intervention may have on poorer health in early adulthood using prospective data provided by the 1970 British Birth Cohort Study (BCS70).chain graph, conditional approach, Gibbs Sampling, Simulation of interventions, age at motherhood, mental health

    Manual of Criminal Law and Procedure

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    Intended to aid to Alaska law enforcement officers in the performance of their duties in the field, this manual was designed to provide brief, quick access to major points of substantive and procedural criminal law. The manual contained discussion and procedural guidelines for investigatory stops, identification procedures including line-ups, arrest, search and seizure, interrogation, as well as discussion of justification for the use of nondeadly and deadly force whether by peace officers or civilians, culpability, entrapment, trial preparation, and media relations. The section on substantive criminal law deals with a selection of crimes most likely to be encountered by "street" officers as defined with the recently enacted Revised Alaska Criminal Code (effective January 1, 1980), desribing elements of each crime, investigative hints, and differences with previous provisions of the criminal code, where relevant.Alaska Department of Law Grant No. 78-A-014Introduction / Criminal Procedures / Substantive Criminal Law / Justification / Culpability / Entrapment / Trial Preparation / Media Relations / Appendice

    Anisotropic focusing characteristics of micro-domain structures within crystalline Sr<sub>0.61</sub>Ba<sub>0.39</sub>Nb<sub>2</sub>O<sub>6</sub> : the crystal ball

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    We report the anisotropic focusing characteristics of a spherically configured region of micro-domains that have been induced within a cubic shaped crystal of Ce:doped Sr0.61Ba0.39Nb2O6. The internal spherical structure focuses extraordinary polarised light, but not ordinary polarised. The spherical region, which is easily observed via scattering, is formed as the crystal cools down, after a repoling cycle through the Curie temperature, with an applied field. Analytic modelling of the thermal gradients that exist within the crystal during cooling reveals a small (&lt; 1°) temperature difference between the central and outside regions. The similarity in shape between these temperature profiles and the observed scattering region suggests a possible mechanism for the growth of this spherical micro-domained structure

    Ongoing astrometric microlensing events from VVV and Gaia

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    6 pages, 2 figures, accepted MNRAS LettersWe extend predictive microlensing event searches using the Vista Variables in the Via Lactea survey and the second Gaia data release. We identify two events with maxima in 2019 that require urgent follow-up. First, we predict that the nearby M2 dwarf L 338-152 will align with a background source with a closest approach of 35−23+3535^{+35}_{-23} mas on 2019 November 16−27+2816^{+28}_{-27} d. This will cause a peak astrometric shift and photometric amplification of the background source of 2.7−1.5+3.52.7^{+3.5}_{-1.5} mas and 5.6−5.2+143.25.6^{+143.2}_{-5.2} mmag respectively. This event should be astrometrically detectable by both the Hubble Space Telescope (HST) and the Spectro-Polarimetric High-contrast Exoplanet Research instrument on the Very Large Telescope. Secondly, we predict the likely K dwarf NLTT 45128 will lens a background source with a closest approach of 105.3−11.7+12.2105.3^{+12.2}_{-11.7} mas on 2019 September 26−15+1526^{+15}_{-15} d. This will produce a peak astrometric shift of 0.329−0.059+0.0650.329^{+0.065}_{-0.059} mas. NLTT 45128 is only 3.6 magnitudes brighter than the background source which makes it an excellent candidate for follow-up with HST. Characterisation of these signals will allow direct gravitational masses to be inferred for both L 338-152 and NLTT 45128 with an estimated precision of ∼9\sim9 and ∼13\sim13 per cent respectively.Peer reviewedFinal Published versio
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