Un-Answered Issues With Toefl Essay Samples Free Revealed

<h1> Un-Answered Issues With Toefl Essay Samples Free Revealed </h1> <p>Some individuals would prefer to stay in a little town. Different people want to remain in a tremendous city. At the point when people succeed, this is a direct result of difficult work. They ought to now and then do things that they hate doing. </p> <p>You will likewise need to offer certain reasons and guides to fortify your position. It is conceivable to likewise work on conceptualizing or arranging reasons regardless of whether the case you don't form a far reaching response. You should give reasons that help your decision. Like the absolute first activity, in the wake of settling on your decision you should bolster that choice with explicit models. </p> <p>The subject will be an extensive astonishment. You can find the total rundown on the IELTS official site. Recollect that anybody can make a site. Have a go at all that you can to expound on the exact subject gave to you. </p> <p>If you wish to discover confirmation in abroad you have to qualify in the TOEFL test. All of the test segments has a period breaking point, and you have to benefit from the time you're given. Obviously, numerous TOEFL takers feel this is unquestionably the most scary segment of the test. Besides, you would need to get ready and study difficult for your tests to accomplish a high score. </p> <p>Our totally free language structure activities will permit you to gain proficiency with the propelled punctuation that you require for the test. Our iBT free data page and iBT test themes will uncover to you that our online tests contain the indistinguishable sort of scholastic points which you will experience on the genuine assessment. Utilizing an exposition sentence structure checker online free is one specific methodology that will assist you with increasing your evaluations. Our totally free exposition check supplies you with the perfect device to practice and clean yo ur composition. </p> <p>For this exposition, you will be evaluated fair and square of your writing notwithstanding how well your reaction speaks to the chief purposes of the sound clasp and composed entry and the manner by which they identify with each other. Having great exposition models gives the peruser a top to bottom and on-the-court thought regarding what a very much organized and sound paper seems like. For you need to comprehend about its inquiry designs you should prepare for the assessment in such a way, that you think that its conceivable to score well. For the most part, a viable reaction will be 150 to 225 words. </p> <p>You shouldn't use measurements as you won't be in a situation to look into during the test. A wonderful prep book can be completely the most significant investigation instrument you use, and we have data on all the absolute best TOEFL prep books you should consider. Gain proficiency with all the proposals you have to comprehend as an approach to expert TOEFL Speaking! The composing test for the most part requires an hour to finish. </p> <p>The cost of an exposition rides on the aggregate sum of exertion the essayist needs to apply. The Integrated Writing task was created to assess the limit of understudies to get data, which originated from different sources. Expounding on an alternate point is a straightforward way to get a negligible score. Don't quickly start writing.</p> <p>Being mindful of what graders need and evaluating TOEFL Writing tests can go far towards helping you to get a high score on this segment. 168 TOEFL Essay Writing is endeavoring to fix these challenges. Numerous understudies experience difficulty thinking about specific models, however it's a huge piece of generally excellent composition. Study the example paper, and look at the instructor's remarks inside the following area. </p> <p>When you surf our site for suggestions that may assist you with composing your own paper, you will run over numerous supportive tips. Be allowed to utilize various books if my recommendation doesn't work for you. The inquiry will demand that you sum up a particular region of the talk, and you will regularly should incorporate certain models the speaker referenced. The key to responding to these inquiries well is to give certain models and subtleties to help your essential thought. </p>

Examining an Internship Reflection Essay Sample

Examining an Internship Reflection Essay SampleInternship reflection essay samples are easy to find and all you need to do is to type a search term into your favorite search engine. There are many sites out there which offer such sample essays and they can help you write your own masterpiece on what the main point of this exercise should be. The work is made easier for you, as you will know that you are not alone in writing this kind of essay.The best thing about this kind of essay is that the essay is freely available for everyone. This means that anyone can use your essay and make changes so that it may be different from the original one. On the other hand, it also means that your essay will be publicly available so people will be able to see how you are writing.Another thing that you should be careful about when writing a good reflection essay is that you will be able to link the above situation to your job application. When the piece is already complete, you will have to make sur e that the interviewer reads your piece before sending it. The best way to make the essay popular is to include some personal touch in the essay.This will make it more effective because the interviewer is able to check the writer's skills through the Internet. When you have finished the essay, the best thing to do after is to find an editor who can rewrite it to give it a more professional look. As a matter of fact, many editors may be able to fix the issues that you are facing.Before choosing an editor, you should always do some research on their past and how they have done things. You should also check on their services and price. However, if you do not have the money for it, you can try to get the help of your friends or relatives.On the other hand, when you are just starting to write your reflection essay, there are some basic rules that you should follow. One of the most important things to remember is that you should be objective in writing the essay. You will be able to convi nce the interviewer if you are able to write from your heart.It is also important to add the small things that you experienced during the internship. It would be a waste of time if you include the big things without mentioning the little things. There is no need to be shy; just be yourself and do not be afraid to share your thoughts about your internship.These small things will help you make your essay better. If you think that it will be too much for you, you can just find a professional editor who will be able to guide you on this matter.

What Are the Proper Font and Spacing For a College Essay?

What Are the Proper Font and Spacing For a College Essay?What are the proper font and spacing for a college essay? It's a question that will only be answered if you understand how to properly format your papers. Properly designed papers will impress judges and give you a great chance at being awarded with a scholarship.Proper formatting makes the paper stand out from others and when you go to an exam you want to impress and this is done by the manner in which you cover all the important points in your papers. There are a number of tips and hints you need to understand before you actually make the changes to your documents.The first tip is to ensure that the font is of good quality and that it is not too small or too big for the paper. You should have a white color space between the letters and in addition to that, you should avoid using any lines that are longer than a few inches. This is so the color spaces you need to place on the white spaces of the paper can be clearly seen.The n ext tip is to place all the important information in the proper areas. When you have information that is spread all over the paper, it will look like your doing a disorganized job. When you have information spread throughout the page, it will look like you are trying to cram the information in there. When you organize the information, it will help people see it better and they will also get the feeling that the paper is organized properly.Proper spacing is also an important factor to be considered. If you have a lot of information to write down, it is recommended that you place them in smaller lines to save space and allow them to be easier to read.The next tip is to use something called Texas Hold-Hider paper and this will help you look professional on an exam and impress the judges. You should be using this type of paper because it will help protect the paper from spillage and also keeps all the papers dry. Remember to have extra paper handy so you do not run out during the test.Y ou should also use colored pens instead of ink for the student papers so it can become more professional looking. It is recommended that you use your extra and colored pens and this will help you to maximize the use of the space.Proper font and spacing are something that will help you look good on a test and impress the judges. It is also important that you avoid all the marks from getting smudged and the idea is to prevent this from happening. Most importantly, you have to be careful with the tips and tricks that you use for a test.

Why Everybody Is Talking About 6th Grade Essay Samples Essay...The Simple Truth Revealed

Why Everybody Is Talking About 6th Grade Essay Samples Essay...The Simple Truth Revealed As stated by The Educator, Students who take part in co-curricular activities have an awareness of commitment to whatever they're involved in. Writing about the reason and effect essay topics related to the school's popularity or surviving the initial year in college could possibly be fine to grab the interest of your peers. Essay writing provides a great deal of benefits to students in the academe. We've provided very distinctive and general topics essay which are usually assigned to students in the school. Effectively completing assignments require students to be very attentive. Students will locate some excellent points and ideas essential for the evolution of a superior school or college comparative essay. They will find it easier to write about topics that they are interested in, and it will make the researching process much simpler. They lead busy lives and often forget about an upcoming deadline. While describing a health problem such as some type of disease, it's possible to include numerous outcomes. The capacity to share something from your head is absolutely a plausible act. When you pick a cause and effect topic, it ought to be something that you either know well or are interested in knowing more about. Additionally, there are times when you really feel like you don't need to write anything. The Basic Facts of 6th Grade Essay Samples Essay The conclusion of essay, that is the previous part, should become your opportunity to earn your readers understand the entire po int of your topic. There are several methods about how to compose an expository essay. Writing a literary essay in the sixth grade is a rather straightforward process which should take just a few hours to finish. While writing an essay for an english class may appear overwhelming it does not need to be. You may continue to keep your argumentative essays for your upcoming job portfolio in case they're highly graded. An excellent thesis statement is one which stays within a particular scope. There are a few great topics to look at when deciding on a topic for your argumentative essay. If you're looking for assistance with your essay then we provide a comprehensive writing service given by fully qualified academics in your area of study. Since 6th grade students will need to compose essays more frequently, they ought to look up some topics ahead of time. Reviewing argumentative essay topics 6th grade could act as a good source of inspiration for those students that are tired of standard themes and would like to express their creativity in a new method. In reality, the only step you will need to complete is filling out the purchase form, where you give out the facts of the purchase. Despite the fact that you pay for homework, we provide those options free of charge. Another alternative is to list all the qualities of the subject A and after that describe the features of the subject B. As a result of this, there'll be more writing assignments and a closer attention to the caliber of the writing. Who Else Wants to Learn About 6th Grade Essay Samples Essay? There are things which are the exact same and various other things which are really different. You've invited your two best friends to devote the afternoon a t your house. It would be helpful if it's something you are most passionate about so that you can write in great particulars. Compare and contrast your family's house and the house of your dreams. The very first sentence of each paragraph should play off the previous sentence of the former paragraph to provide a smooth transition. The very first paragraph should contain the most crucial point that you intend to make about the literary work and ought to give details to support the claim. Your very first paragraph should begin with an interesting and attention-grabbing sentence which is known as a hook. Make your strongest claim to back up your thesis statement in the very first body paragraph. Keeping a consistent voice within the body paragraphs, together with the remainder of the essay, is also an additional ability that sixth-grade teachers are likely to be on the lookout for when grading. Each paragraph needs to be limited to a single point of argument. A conclusion is, without a doubt, the most significant portion of the argumentative essay as possible either support the excellent impression or destroy it entirely. The previous sentence ought to be persuasive to the major point and ought to suggest that the essay is coming to a finish. The 6th Grade Essay Samples Essay Cover Up Thus, it can be concluded that homework plays an important function in facilitating education throughout the world. For such as student, obtaining a math problem solver with steps ensures he or she doesn't lag behind when it comes to performance. The help provided by tutors is also limited since they may not operate on the assignment for your benefit. For example, getting assistance from a fellow student is complicated by the simple fact you could be facing similar challenges.

The Scarlet Letter, By Nathanial Hawthorne - 2079 Words

Envisage living in a community where one could only be intimate with their husband. Sounds insane, right? Though being sexually active with more than one partner in a lifetime is moderately common in today’s society, it was severely looked down upon in the 1800s. In The Scarlet Letter, Nathanial Hawthorne communicates the story of Hester Prynne, an adulteress. Hester Prynne lived in a Puritan Society in which women were held to high, difficult, and unjust standards by men. Evidently, she undergoes unusual punishments for her infidelities against her estranged husband. She forcibly wears an embroidered, scarlet letter A on her breast for the remainder of her life. Though physically benign, its call of attention to Hester’s transgression is emotionally straining. As a man or woman, adultery must always be perceived as improper and unlawful. However, the author exhibits transcendentalist values when one can conclude that Hawthorne’s words were not demeaning Hester, but more so commending her. His execution of rhetorical devices applauds Hester’s individuality in a conforming society. Through the author’s implementation of diction to illuminate Hester and debase the rest of society, manipulation of symbolism to compliment Hester’s individuality, and application of irony to manifest Hester’s gained dignity from rebelling, Hawthorne illustrates Hester’s journey in a culture against change as one of dauntlessness, and conveys his purpose that individuality is precious. NathanielShow MoreRelatedThe Scarlet Letter By Nathanial Hawthorne1074 Words   |  5 Pagesa young woman found guilty of adultery. She is required to wear a scarlet A on her dress to shame her. She must stand on the scaffold for three hours, to be exposed to public humiliation. As Hester approaches the scaffold, many of the women in the crowd are angered by her beauty and quiet dignity.† The Scarlet Letter written by Nathanial Hawthorne centers on sin, identity and society. The meaning of the A in the Scarlet Letter is meant to mean â€Å"Adulterer†. The meaning is not definite, the A meaningRead MoreScarlet Letter by Nathanial Hawthorne890 Words   |  4 Pagesfloating around letting you see others sin. Finally, you are a product of sin, your life is full of evil, and torture. Until your sin is revealed by your unknown father. These events happened to the character in Nathaniel Hawthorns The Scarlett Letter. Their sin affects the way that these characters live. The Nature of sin can bring the worst and best out of people. Whether it is hidden or know, the sin can bring good and bad things to the people who have sinned. Dimmsdale’s sin was locked insideRead MoreSymbolism Of The Scarlet Letter By Nathanial Hawthorne881 Words   |  4 Pagesmany symbols throughout Nathanial Hawthorne’s novel The Scarlet Letter. The characters and many differe nt things throughout the book are all symbolic, but the main symbol in the novel is the letter â€Å"A† on Hester Prynne’s gown. Not only are there many symbols throughout the novel, but the letter â€Å"A† has many different representations of itself such as, adultery, which is the main symbol for the â€Å"A,† her ability to do things, and she is even referred to as an angel. The letter is meant to be a symbolRead MoreThe Influences of the Main Characters in The Scarlet Letter by Nathanial Hawthorne961 Words   |  4 PagesWho is Arthur Dimmsdale? Do we, as readers, ever fully understand the extent of Dimmsdale’s character provided to us by Nathaniel Hawthorne? In the novel, The Scarlet Letter, the on-the-surface themes of sin and suffering are very clear, but the development of the different characters and their own personal challenges plays a big factor (and maybe even the biggest factor) to the moral of the story rather than what is shown in plain sight. There are three main characters that reflect the differentRead MoreAntifeminist and Feminism within The Scarlet Letter1388 Words   |  6 PagesAntifeminist and Feminism within The Scarlet Letter In Nathaniel Hawthorne’s â€Å"The Scarlet Letter† Hester Prynne is accused and convicted of adultery. During the puritan era women in this society had specific obligations and rights they had to maintain. By Hester having an affair and acting unladylike the community disapproved of her actions causing everyone to isolate her in her town. Due to Hester Prynne’s Isolation and the harsh judgment she received from everyone in her town, she goes throughRead MoreThe Novel The Scarlet Letter 893 Words   |  4 PagesThe Weight of a Name The Scarlet Letter is a timeless novel because of the timeless characters depicted in the piece. Each character was carefully constructed by Nathanial Hawthorne to represent a specific aspect of sin. He used these characters to tell a story that would translate how distorted the Puritans’ view of sin was. Not only did he thoughtfully plan the characters’ personalities, backgrounds, and beliefs out in order to convey this distortion of sin, but their names were carefully consideredRead MoreThe Scarlet Letter By Hugues Merle1580 Words   |  7 PagesThe Scarlet Letter (Figure 1) painted by Hugues Merle in 1861 depicts the novel The Scarlet Letter by Nathanial Hawthorne. Hester Prynne, an adulteress forced to wear the letter â€Å"A† upon her bosom forever, becomes an outcast from the community with her daughter, Pearl. Merle was often known for painting scenes of mothers and children. He illustrates the scene of Hester and Pearl sitting in the town square as part of her punishment. The townspeople walk by, pointing fingers and making shrewd remarksRead MoreSins inThe Scarlet Letter by Nathaniel Hawthorne Essay1517 Words   |  7 Pagesâ€Å"Be true! Be true! Be true! Show freely to the world, if not your worst, yet some trait whereby the worst may be inferred† (Hawthorne). As this sentence is read in the The Scarlet Letter, the reader will realize that the main theme of the book is the sentence above. Throughout the book, secret sin damages the lives, soul, and the integrity of the main characters. However, it could have easily been evaded through open confession of their sins. Nathaniel Hawthorne’s purpose in writing this novel isRead MoreEssay about Nathaniel Hawthornes Use of Symbolism482 Words   |  2 PagesNathaniel Hawthorne is a prominent writer who uses many different elements in his works. He uses elements such as symbolism, figurative language, metaphor, irony and etc. to make his work prominent. In the works by N athaniel Hawthorne, he uses symbols for secret sin in The Scarlet Letter, â€Å"The Minister’s Black Veil,† and â€Å"Dr. Heidegger’s Experiment.† As seen in The Scarlet letter, the symbol for secret sin is the Scarlet letter â€Å"A.† The â€Å"A† represents the sin in which Hester commits adultery withRead More Exposed Sin vs. Hidden Sin in the Scarlet Letter Essay633 Words   |  3 Pageshidden sin as related to The Scarlet Letter, and the effects it has on people. In Nathanial HawthorneÂ’s The Scarlet Letter, Hester Prynne represents the exposed sin while Reverend Arthur Dimmesdale and Roger Chillingworth represent the hidden sin. Hester PrynneÂ’s sin is exposed on the scaffold in front of the townspeople. For punishment she is made to wear the letter “A”, for adulteress, on her bosom. HesterÂ’s daughter, Pearl, is herself a symbol of the scarlet letter. Pearl is always seen with

Search Seizure, Open Fields Doctrine Free Essays

string(38) " he saw the blood on Tobias’ pants\." MEMORANDUM ON DEFENDANT’S MOTION TO SUPPRESS STATEMENT OF FACTS Owyhee County is located in the south west corner of Idaho. The Owyhee Mountains fill the west portion of Owyhee County. Mud Flat Field and Marmaduke Spring are located in the Owyhee Mountains, in the west central portion of Owyhee County, south of South Mountain and north of Juniper Mountain. We will write a custom essay sample on Search Seizure, Open Fields Doctrine or any similar topic only for you Order Now The Mud Flat Field is approximately two miles long from North to South. The south end of the Mud Flat Field borders the Mud Flat road. Over this road one can travel to Jordan Valley, Oregon, from Grandview, Idaho. From the Mud Flat road, a person enters the Mud Flat through the locked gate or through another, unlocked, gate. The unlocked gate is approximately 25 yards east of the locked gate. In July 1995, a number of persons, including *** Bennett, had keys to the locked gate. Near the south end of the field is a set of corrals. Defendant *** Tobias’ cabin is approximately a quarter mile east of the corrals. The cabin is not visible from the corrals. In the summer of 1995 the defendants Tobias and *** Black, were running cattle in the Mud Flat field and adjoining fields. Marmaduke Spring is located about a quarter mile west of the northwest end of the Mud Flat Field, over a saddle from the field. On July 21, 1995, an Idaho Air National Guard helicopter pilot, *** Brummett, flew a mission over the Owyhee Mountains. While flying over Marmaduke Spring, Brummett saw a number of dead cows. Brummett initially observed the cows from the air; he then landed his helicopter and inspected the cows on foot. Brummett found *** Bennett’s truck parked near the north end of the Mud Flat Field. The truck was approximately a quarter mile east and over a ridge from the dead cows and the spring. Bennett was not at his truck. Brummett left a note on *** Bennett’s truck after he inspected the cows. The note identified the location of the massacred cows. When Bennett came back to his truck and read the note he walked over the hill to examine the cows. Because Bennett ran cattle on the ranch adjacent to and west of the Mud Flat Field, and had cattle in the area, he was afraid that the cows might have been his own. He found a number of swollen dead cows. What he saw caused him to leave and contact the Owyhee County Sheriff’s Office (OCSO). At approximately 6:00 p. m. on July 21, 1995 Bennett returned to the Mud Flat Field and Marmaduke Spring. He brought the Owyhee County Sheriff, Tim Nettleton, Owyhee County Sheriff’s Deputy Jim Bish and an Idaho Deputy Brand Inspector, Chuck Hall, with him. They got onto the Mud Flat field through the locked gate using Bennett’s key. They inspected the dead cows. The cattle had been shot through the head and were lying on their left sides or were on their bellies. Each had at least one ear removed and each had an 11 inch by 11 inch (approximate) patch of hide missing from the right shoulder; The significance of the removal of the ear is that a numbered (â€Å"Bangs†) tag is attached to the ear. The owner of cattle can be determined by the tag even if the brand is destroyed Some of the cows had bled. The cows were tentatively identified as *** King’s. Gordon King’s brand is a â€Å"Heart-K† on the right shoulder; exactly where the hide had been cut from the cows. The cows appeared to have had calves nurse them after they had been killed. After inspecting the cows, Bennett, Nettleton and Hall went to the Mud Flat Corral and found Tobias. They told him what they were doing and asked him whether he had seen anyone in the area during the past few days. He denied that he had. The following day, July 22, 1995, law enforcement officers, lab technicians and citizens returned to the Marmaduke Spring area to try to figure out what happened. During that day *** King found a Charolais cross calf in the Mud Flat Field. This calf had an open wound on its right shoulder from where a â€Å"Heart-K† brand had been skinned. The calf had a new â€Å"T-cross† brand on its left hip. Officers and cowboys found 12 skinned and rebranded calves during the next few days. Two calves were found in Tobias’ and Black’s Mud Flat Field. The remainder of the calves were found in an allotment Tobias and Black shared with their neighbors, the Colletts. Each calf had a chunk of hide missing from its right shoulder, some had new ear marks, and each had a new â€Å"T-cross† brand. Skin, hair and blood samples were taken from the skinned calves and the dead cows. The samples were sent to the Stormont Laboratory for DNA testing. The tests established that at least eight of the calves came from eight of the dead cows. An Idaho brand officer, Chuck Hall, was near the corrals and saw saddles in the back of Tobias’ pickup. On one saddle’s horn wrap Hall saw what appeared to be a fairly fresh spot of blood pressed into the wrap. Hall is an experienced cowboy and his opinion was that blood may have come from one of the cows or calves. Hall cut a small piece of leather containing the spot of blood off the saddlehorn wrap. Later, *** Black claimed that saddle. When asked at the preliminary hearing why he took the piece of leather, Hall said, â€Å"I saw it as evidence, and if I hadn’t taken it at that time I may not have ever seen it again. † (PH, p. 572. ) The leather and blood were sent to the Stormont lab. The lab determined that the spot was blood and that it came from one of the stolen calves. On July 21, when Nettleton first saw the dead cows and told Tobias about them, he saw the blood on Tobias’ pants. You read "Search Seizure, Open Fields Doctrine" in category "Essay examples" The following day Tobias was wearing the same pants. Nettleton decided, based on his experience as a cowboy and a hunter, that the blood pattern on the pants was unusual. It was not the pattern of blood as it usually appears on the pants of a cowboy, or a hunter. Blood on the pants of a hunter or cowboy will be wiped on from wiping off either hands or knives or as specks from the spray of cut small arteries. The blood in this instance was smeared and soaked onto the thigh area of the pants and had dripped down onto the cuff area. Nettleton believed that the blood may have come from the cows and calves. He believed that the blood pattern came from Tobias’ having laid the skinned patches of cow and/or calf hide on his pants. The patches of hide from the cows and calves were never recovered. Near the end of the day of July 22, Nettleton approached Tobias and told him that he had probable cause, but did not want, to arrest him. Nettleton asked Tobias for his pants. Tobias asked Sheriff Nettleton what would happen if he did not give Sheriff Nettleton the pants and Nettleton replied that he would have to arrest him. Tobias consented to give up the pants. The pants were sent to the Stormont lab and DNA tests were performed on them. The tests showed that blood on the pants matched that from one of the dead cows. DEFENSE ARGUMENTS The arguments are set out in Tobias’ â€Å"Memorandum in Support of Defendant’s Pretrial Motions. † I. THE THRESHOLD MATTER BECAUSE TOBIAS HAS MADE NO SHOWING THAT HIS UNITED STATES CONSTITUTIONAL FOURTH AMENDMENT RIGHTS HAVE BEEN VIOLATED, THIS COURT SHOULD NOT CONSIDER HIS ARGUMENTS. As a threshold matter, this court must determine whether Tobias has standing to assert a violation of the 4th Amendment to the United States Constitution. In order to show standing Tobias must show that the search or seizure violated his own privacy, liberty or possessor interests. Rakas v. Illinois 439 U. S. 128, nt. 1, (1978); Smith v. Maryland, 442 U. S. 736, 740, 99 S. Ct. 2577, 2580, 61 L. Ed. 2d 220 (1979). Tobias has an obligation to demonstrate, by affidavit or testimony, that any of his privacy, liberty or possessor interests have been violated. Tobias has not shown either a subjective or objective expectation of privacy. The facts demonstrate that Tobias and Black had little, if any, expectation of privacy in the Marmaduke Spring kill site, in the Mud Flat field, in the Mud Flat field corrals, in the open back of Tobias’ pickup truck, in the federal allotment that Tobias and Black shared with the Colletts, in the dead cows found near Marmaduke Spring, in King’s calf found in the Mud Flat field, in the running irons found at the Mud Flat field corrals, in the running irons and blood spot found on the saddle which was located in the open back of Tobias’ pickup truck at the Mud Flat field corrals, in the bloody pants that Tobias was wearing, in the calves found on the federal allotment that Tobias and Black shared with the Colletts, the Marmaduke Spring, the Mud Flat corral, the Mud Flat Field, or his pickup. Tobias has shown no ownership interest Marmaduke Spring. He has shown no violated privacy interest in the Mud Flat Field, or the Collett/Tobias/Black allotment. Tobias has not claimed an ownership interest in the evidence seized from the deceased cows, the calves or the saddle leather. Therefore, the court should not consider his arguments nor grant his motion to suppress regarding this evidence. II. THE MUD FLAT CORRAL SEARCH ARGUMENT THE MUD FLAT CORRALS WERE OUTSIDE THE AREA OF FOURTH AMENDMENT PROTECTION BECAUSE TOBIAS HAD NO REASONABLE EXPECTATION OF PRIVACY IN THEM. The state will first analyze Tobias’ reasonable expectation of privacy in the corral area. The analysis of his interest in the Mud Flat field, the federal allotment that Tobias shared with the Colletts, and the Marmaduke Spring kill site, will be substantially the same. If the court finds that Tobias had no reasonable expectation of privacy in the corral area, then it should find that he had no reasonable expectation of privacy in the other areas. In order to determine if the Fourth Amendment applies, the court has to determine if the person objecting to the search or seizure has a reasonable expectation of privacy in the place searched or the thing seized (because if there is no reasonable expectation of privacy violated there is no search or seizure), if there was a search or seizure, if the state was involved, and, finally, if an exception applies. Should this court consider Tobias’ search and seizure claims it should consider that the facts show diminished and missing subjective and objective expectations of privacy. The Fourth Amendment prohibits only those searches and seizures that are â€Å"unreasonable. While the appellate courts presume that warrantless searches are unreasonable, the state rebuts this presumption when it demonstrates, by a preponderance of the evidence based on the totality of the circumstances, that the search was reasonable. The state can also rebut the presumption when it shows that the se arch came under one of the exceptions to the warrant requirement. In other words Tobias must show that he had a reasonable expectation of privacy which was violated. A. Open Fields The Fourth Amendment â€Å"protects people, not places. What a person knowingly exposes to the public, even in his home or office, is not a subject of Fourth Amendment protection. † Katz, 389 U. S. at 351. The person must have an actual, or subjective, expectation of privacy, and the expectation must be one that society will recognize as reasonable. Katz, 389 U. S. at 361. Federal courts have consistently held that there is no constitutionally protected privacy interest in the area outside of the curtilage a home. In Hester v. United States, 265 U. S. 57 (1924), federal agents entered onto Hester’s lands looking for, and finding, his illegal still. The court held that the Fourth Amendment did not protect open fields. The Court reiterated that holding in Oliver v. United States, 466 U. S. 170 (1984), and United States v. Dunn, 480 U. S. 294 (1987). In Oliver, the officers acted on anonymous tips, ignored â€Å"no trespassing† signs, and found secluded marijuana fields on private land. The Supreme Court again held that open fields do not provide the setting for those intimate activities that the Fourth Amendment is intended to shelter from government interference or surveillance. Therefore, there is no reasonable expectation of privacy, even though the police are trespassers in the unprotected areas. In Dunn narcotics officers trespassed onto Dunn’s farm. They climbed over fences and crossed open fields. They avoided the house but went to the barn and other outlying structures. They crossed over more fences and looked inside, but did not go inside, the barn. The Supreme Court said there was no Fourth Amendment protection in the area where the trespass occurred. The Court discussed curtilage concepts and factors such as distance from the residence, enclosures surrounding the residence, the uses to which the area was being put, and owner’s efforts at concealment. It then ruled that the open fields doctrine applied. Although the Idaho appellate courts have found the federal definition of curtilage unduly restrictive, they nevertheless analyze curtilage similarly. In State v. Kelly, 106 Idaho 268 (Ct. App. 1984) and State v. Young, 107 Idaho 671 (Ct. App. 1984), the appellants asked the court to examine Oliver‘s effect on Katz and Hester. The court of appeals declined to do so. The court did not agree with the appellants that the evidence should have been suppressed. The court also examined the federal cases in relation to Idaho’s constitutional law. It decided the cases by determining that the defendants had exhibited no reasonable expectation of privacy. In Kelly, the court commented that the officers seized the marijuana after going over the defendant’s insubstantial barbed wire fence. The court also noted there was no evidence of â€Å"no trespassing† signs. In Young, the court said that while the officers had initially encountered a gate, a fence and â€Å"no trespassing† signs, they had walked around them to an area where there were no signs, gates or fences. The officers then entered Young’s land and saw the marijuana. Tobias, in his brief, implies that under no â€Å"stretch of the imagination† can the search at the Mud Flat corrals be justified. He suggests that the Mud Flat corrals are within the curtilage of his cabin and are immediately adjacent to his cabin. (Deft’s Mem. , p. 7. ) To support the argument, he cites a number of other state courts as having held that corrals â€Å"are within the constitutionally protected ‘curtilage’ of a farmhouse. † (Deft’s Mem. , p. 8. ) To suggest that corrals are by definition within the curtilege of a house is to expand the definition of curtilage beyond Idaho law. Curtilage: encompasses the area, including domestic buildings, immediately adjacent to a home which a reasonable person may expect to remain private even though it is accessible to the public. State v. Cada, supra; State v. Clark, 124 Idaho 308 (Ct. App. 1993); State v. Rigoulot, 123 Idaho 267 (Ct. App. 1992), emphasis added. It is clear from the photographs and from the preliminary hearing testimony that the corrals are not †immediately adjacent to a home. † Clearly, the corrals are not located within â€Å"a small piece of land† around the cabin. (See attached photograph. ) Tobias’ cabin is concealed from the corrals. There is a tree-covered ridge isolating the cabin from the corrals. Tobias’ cabin sits below the ridge. His cabin is approximately a quarter mile from the corrals. The corrals are not part of a barnyard immediately adjacent to a home. Their association with the cabin is that they are along the road leading to the cabin. The road ends and the path to the cabin begins, near the corrals. While the corrals are not clearly visible from the Mud Flat Road, they are easily seen from the road that goes through the Mud Flat field and on to Bennett’s ranch. There are no special fences that set the corrals and the cabin apart from the rest of the Mud Flat field. The corrals are within sight of, and on the edge of, the Mud Flat field. The corrals are presumably used for the livestock within the Mud Flat field. As can be seen in the attached photograph, many paths lead to the corrals. Both in use and location, the corrals are more closely associated with the Mud Flat field than with Tobias’ cabin. It is fair to characterize the corrals as outside the area that â€Å"a reasonable person may expect to remain private,† therefore outside the area included in the cabin’s curtilage, and therefore outside the area of Fourth Amendment protection. B. Plain View However, if the court includes the Mud Flat corrals within the curtilage of Tobias’ cabin, that does not mean that the corrals are protected by the Fourth Amendment. In Rigoulot the court concluded that observations made by persons â€Å"restricting their movements to places ordinary visitors could be expected to go were not protected by the Fourth Amendment. † Rigoulot at 272. The Mud Flat corrals are located near the south end of the Mud Flat Field. They are approximately one-half mile north of the Mud Flat Road, out of sight, to the west, and over a ridge (or around a draw) from Tobias’ cabin. A person driving along Mud Flat Road cannot see either the Mud Flat Corrals or Tobias’ cabin. A person who enters the main gate at the Mud Flat Field follows a dirt road north to where it splits. One fork continues in a north, north-west direction. This fork continues off Tobias’ property and onto Bennett’s property. The other fork continues north for a way then t curves east around a hill toward the corrals. This fork ends just beyond the corrals. In order to get to Tobias’ cabin, a person has to travel along the road to the corrals, then the remainder of the way on foot. The state’s position is that if the corrals are included within the cabin’s curtilage , then they are in an area that visitors would normally go. These visitors include police officers coming onto the property to â€Å"conduct an investigation or for some other legitimate purpose. † Id. In summary, because the officers were not in a place protected by the Fourth Amendment, their search was not improper. III. THE MUD FLAT FIELD SEARCH ARGUMENT TOBIAS HAD NO REASONABLE EXPECTATION OF PRIVACY IN THE MUD FLAT FIELD BECAUSE THE FIELD IS OUTSIDE THE AREA OF FOURTH AMENDMENT PROTECTION. The governing law is set out above under the argument regarding Tobias’ expectation of privacy in the Mud Flat Field corrals. On July 22, after the officers were finished or nearly finished gathering evidence from King’s dead cows, Gil King was heading away from the Marmaduke Spring area. He was going to load his motorcycle into a truck and leave. As he was leaving and while near Bennett’s truck near the Johnson Reservoir, he saw the Charolais calf that â€Å"had a big ol’ patch of hide missing off its side. † (PH, p. 389. The calf was herded to the Mud Flat Field corrals and examined. This calf had skin removed off its right shoulder, where a â€Å"Heart-K† brand had been, and a new â€Å"T-cross† brand on its left hip. Tobias claimed the calf. Based on the above law and arguments regarding Tobias ’ expectation of privacy in the Mud Flat Field corrals, and the fact there should be a progressively decreasing reasonable expectation of privacy as one gets further away from the cabin, the state respectfully requests that this court deny the defendant’s motion to suppress the evidence gathered in the Mud Flat Field (the Charolais calf). IV. THE MARMADUKE SPRING KILL SITE SEARCH ARGUMENT TOBIAS HAD NO REASONABLE EXPECTATION OF PRIVACY IN THE MARMADUKE SPRING BECAUSE IT IS OUTSIDE THE AREA OF FOURTH AMENDMENT PROTECTION. The governing law is set out above under the argument regarding Tobias’ expectation of privacy in the Mud Flat Field corrals. Considering the facts, and the above stated law and argument, the state respectfully requests that this court deny the defendant’s motion to suppress the evidence gathered at the Marmaduke Spring. V. THE COLLETT/TOBIAS BLACK ALLOTMENT SEARCH ARGUMENT TOBIAS HAD NO REASONABLE EXPECTATION OF PRIVACY IN THE COLLETT/TOBIAS ALLOTMENT BECAUSE THE ALLOTMENT IS OUTSIDE THE AREA OF FOURTH AMENDMENT PROTECTION. The law governing this area of search and seizure is set out above in the argument regarding the Mud Flat corrals search. On July 23rd, a number of cowboys and officers road through the Collett/Tobias allotment and found 11 calves. The calves were found in the area of the allotment furthest from Tobias’ cabin. The calves had new â€Å"T cross† brands, new ear marks and had a chunk of hide skinned off their right shoulders. Subsequent DNA tests showed that most of the calves came from the dead cows. The Collett/Tobias allotment is a section of land lying adjacent to and east of the Mud Flat field. The allotment is also adjacent to and east of Collett’s private land. It is adjacent to and south of land on which the Kings ran cattle. In July 1995 two ranchers (Tobias and the Collett family) leased the grazing rights from the Bureau of Land Management; on July 22nd both had cattle on the land. Each would ride the allotment to check their cattle. There were fences to keep the cattle in, there were no â€Å"no trespassing† signs. There is no indication that intimate family activities such as those protected by curtilage concepts occurred on the land. Because Tobias had no reasonable expectation of privacy in the Collett/Tobias allotment, the state respectfully requests that this court deny the defendant’s motion to suppress the evidence regarding the calves found in the allotment. VI. THE CONSENT TO SEARCH ARGUMENT TOBIAS HAD NO REASONABLE EXPECTATION OF PRIVACY IN THE MUD FLAT CORRAL, THE MUD FLAT FIELD, MARMADUKE SPRING OR THE FEDERAL ALLOTMENT BECAUSE THE OFFICERS HAD EITHER REAL OR APPARENT PERMISSION TO BE ON THE PROPERTIES. The officers had reason to believe that either Bennett or Tobias had consented to their presence at the Mud Flat corrals search and that either Bennett or Tobias had the authority to consent to their presence. Consent must be shown to be free and voluntary and not a result of duress or coercion, either direct or implied. State v. Aitken, 121 Idaho 783 (Ct. App. 1992), citing Schneckloth v. Bustamonte, 412 U. S. 18 (1973): As long as the police officer reasonably believes that the person giving consent to a warrantless search has the authority to consent, the search is valid and the defendant’s right against unreasonable searches and seizures pursuant to the Fourth Amendment to the United States Constitution and art. 1,  § 17 of t he Idaho Constitution is not violated, even though the consenter has no actual authority to consent. State v. McCaughey, 127 Idaho 669, 904 P. 2d 939, (1995). The state must show the voluntariness of consent by a preponderance of the evidence; and the voluntariness of consent is to be determined in light of all of the circumstances. State v. Aitken, supra; State v. Rusho, 110 Idaho 556 (Ct. App. 1986). A number of people had access to the Mud Flat field and the Mud Flat corrals. Tobias allowed local people access to his fields. Tobias provided an access key to Bennett. Bennett notified OCSO of the dead cows and brought officers to look at the cows. Bennett used his key to unlock the gate on July 21st when he brought officers to look at the cows. Bennett gave the officers his key so that they could return to the field the following day. Tobias talked to state officers at his corrals and made no objection to their presence on July 21st. He knew on July 21st that state officers were going to return July 22nd and made no objection. Tobias was present at the Marmaduke Spring when officers returned July 22nd and he watched the work that they were doing and he did not object to their presence. Tobias watched them while they gathered evidence from the cows. He was present when the Charolais calf was found in the Mud Flat field and knew that the calf was going to be driven to the Mud Flat field corrals. He was present at the corrals when the officers were looking at the Charolais calf and when they seized the piece of leather from the saddle in his pickup. Officers talked to Tobias at Marmaduke Spring and at the Mud Flat corrals. Tobias only questioned the officers about their authority to seize his pants. Officers only seized his pants after gathering evidence from the dead cows, after finding the Charolais calf with a patch of hide missing from its shoulder and with new ear marks and a new â€Å"T cross† brand, which Tobias claimed as his own. Tobias Black may not have been present when the calves were found in the Collett/Tobias Black allotment. Tobias and Black had a diminished expectation of privacy as they shared the allotment with the Colletts and the Colletts allowed cowboys and state officers to search the allotment. At no time did Tobias, the alleged owner of the property, object to the officers’ presence and the only time he questioned their actions was when they seized his pants. Considering all of the circumstances, including custom in the area, it is fair to say that the officers thought they had Tobias’ permission to be at the corrals when he knew that they were going to be there, he accompanied them, and expressed absolutely no disapproval to their presence. The law of consent is clear that, â€Å"[w}here two persons have equal rights to the use or occupation of premises, either may give consent to a search, and the evidence thus disclosed can be used against either. † State v. Huskey, 106 Idaho 91 (Ct. App. 1984), citing United States v. Sferas, 210 F. 2d 69, 74 (7th Cir. ). The co-tenants, the Colletts, could give the officers permission to search the allotment for King’s calves. The officers searched the allotment with the permission of the co-tenants, the Colletts. The state respectfully requests that this court deny the defendant’s motion to suppress the evidence regarding the calves found in the allotment. VII. THE MUD FLAT CORRAL SEIZURES ARGUMENT IT WAS PERMISSIBLE FOR HALL TO SEIZE THE LEATHER CONTAINING THE BLOOD SPOT AND THE CINCH RINGS (RUNNING IRONS) THAT HE SAW ON BLACK’S SADDLE IN THE OPEN BACK OF TOBIAS’ PICKUP TRUCK Assuming, without conceding, that Tobias has standing to challenge the seizure from Tobias’ pickup truck, the state’s position is that Hall could seize the thumbnail sized piece of leather and the running irons under either the plain view doctrine or the moving target doctrine. Hall seized the cinch rings and piece of leather because he was investigating the killing of the cows and rebranding of the calf and believed that both items were evidence. On Saturday, July 22, 1995, while the officers were at the Mud Flat corrals trying to figure out the situation with the Charolais calf, Hall observed a saddle in the uncovered back of Tobias’ pickup truck. The saddle belonged to *** Black. Black was not present at the corrals. On the saddle there were two blackened cinch rings and a spot of blood on a piece of leather. Anyone present could have looked into the back of the pickup and seen the saddle, the cinch rings and the blood spot. The overall circumstances indicated that large chunks of hide were cut from cows and at least one calf. The calves were alive when their hide was cut off their shoulders. It is reasonable to infer that the calf would have bled. Chuck Hall, from the state Brand Inspector’s office and an experienced cowboy, observed Black’s saddle and saw the blood spot on the saddle horn wrap. It was apparent to Hall that the blood spot was unusual both in the location and how it was pressed into the wrap. Hall cut the thumbnail sized piece of leather off the saddle horn wrap. Hall seized the rings. It was apparent to Hall that the cinch rings had illegally been used as running irons. A. The Plain View Doctrine. Hall’s seizure of evidence from the pickup truck was permissible under the plain view doctrine. The court in State v. Clark, 124, Idaho 308, 311 (Ct. App. 1993), (citing Horton v. California, 496 U. S. 28 (1990)), set out the standard: (1)The officer must lawfully make an initial intrusion or otherwise properly be in a position to observe a particular area, and (2) it must be immediately apparent that the items observed are evidence of a crime or otherwise subject to seizure. The â€Å"immediate ly apparent† requirement is â€Å"met when an officer has probable cause to believe that the item in question is associated with criminal activity. † State v. Claiborne, 120 Idaho 581 (1991), citing Texas v. Brown, 460 U. S. 730 (1983). An officer is allowed to â€Å"draw reasonable inferences based on his training and experience. † State v. Tamez, 116 Idaho 945 (Ct. App. 1989). Multiple officers at a scene may make reasonable inferences based on their collective knowledge. United States v. Newton, 788 F. 2d 1392 (8th Cir. 1986). Here, Hall was properly on the property either because of actual or implied consent, or because he was in an â€Å"open view† area at the corrals. When Hall saw the blood spot on the saddle horn he recognized it to be evidence. (PH, p. 572. ) He then seized a small section by cutting it off the saddle horn. Because the cinch rings and the blood spot were open to public view and because Hall had probable cause to believe that they were contraband and prima facie evidence of a crime, the state respectfully requests that this court deny the defendant’s motion to suppress these items. B. The Moving Target Doctrine Further supporting Hall’s decision to seize the cinch rings and the leather piece is the fact that they were located in a motor vehicle: The guaranty of freedom from unreasonable searches and seizures by the Fourth Amendment [recognizes] a necessary difference between a search of a store, dwelling house or other structure†¦ and a search of a ship, motor boat, wagon or automobile†¦ [since] it is not practicable to secure a warrant because the vehicle can be quickly moved out of the locality or jurisdiction in which the warrant must be sought. Carroll v. United States, 267 U. S. 132, 152 (1925). The United States Supreme Court explained this doctrine in Chambers v. Maroney, 399 U. S. 2, 52 (1970): For constitutional purposes, we see no difference between, on the one hand, seizing and holding a car before presenting the probable cause issue to a magistrate and on the other hand carrying out the immediate search without a warrant. Given probable cause to search, either c ourse is reasonable under the Fourth Amendment. When Hall seized the running irons, he believed they had been used as running irons to draw on brands. He knew that it was illegal to possess running irons and, as such, they were contraband. It appeared that someone had drawn the â€Å"T-cross† brand on the Charolais calf with a running iron. He also knew that someone had killed 11 cows and that someone had cut a patch of hide off their right shoulders. He knew that someone had cut a patch of hide off the Charolais calf’s right shoulder and that someone had changed its ear mark by cutting the ear. From his experiences as a cowboy he knew that the cows and calf would have bled. He knew from his experience as a cowboy that the blood on the saddle wrap was unusual in the location and in the manner that it was pressed into the wrap. He recognized the blood as evidence and was afraid that he would not see it again if he did not seize it then. The seizure of the blood spot from the saddle horn wrap is similar to the seizure that occurred in Cardwell v. Lewis, 417 U. S. 583 (1974). In Cardwell, officers investigating a murder examined a tire and took paint scrapings from the defendant’s car. The car was located in a public parking lot. In the court’s opinion the officers did not infringe on any reasonable expectation of privacy. A similar case is New York v. Class, where an officer reached into a motor vehicle to move papers on the dashboard. The papers were covering a VIN. When the officer moved the papers he saw and seized a gun. The court upheld the search as the defendant did not have a reasonable expectation of privacy in the VIN, the officer had a right to see the VIN, therefore, he had a right to move the papers. In United States v. Ferri, 778 F. 2d 985 (3rd Cir. 1985), the court held that a person had no reasonable expectation of privacy in his shoes (and their soles). The above cases are based on the Katz reasoning that the Fourth Amendment does not apply to the exteriors or interiors of items open to the public view. Because the cinch rings and the blood spot were located within a mobile vehicle and because Hall had probable cause to believe that they were contraband and evidence of a crime, the state respectfully requests that this court deny the defendant’s motion to suppress these items. CONCLUSION For the above stated reasons the state respectfully requests that this court deny Tobias’ motion to suppress. ——————————————– [ 1 ]. The access to *** Bennett’s ranch is by a road that goes through the Mud Flat Field. The Bennett family has used the road through the Mud Flat Field to get to their property to the north and west since at least 1948 when Mud Flat was owned by Elmer Johnston. Since then the property has been owned by *** Steiner, *** Steiner and *** Tobias. (see Preliminary Hearing (PH) Tr. , p. 12. ) [ 2 ]. Near a water hole, *** King’s son, *** King, had fed potato chips to one of the cows on July 13, 1995. [ 3 ]. The â€Å"T-cross† brand was the registered brand of Tobias’ partner, *** Black. Tobias has two brands registered in Idaho, one is a â€Å"46,† the other is an â€Å"‘F’ hanging ‘J. ’† [ 4 ]. Other Tobias and Black cow/calf pairs were in the fields where the newly branded â€Å"T-cross† calves with the chunks of hide missing were found. The cows were branded with Tobias’ â€Å"46,† their calves were branded with Black’s â€Å"T-cross. † [ 5 ]. The cows’ ears were never found. [ 6 ]. The court in State v. Cada, 129 Idaho 224 (Ct. App. 1996), established that Idaho will not follow the Dunn analysis regarding enclosure and visibility to passersby. [ 7 ]. â€Å"Curtilage† refers to a small piece of land not necessarily enclosed, around a dwelling house, generally including buildings used for domestic purposes in the conduct of family affairs. Ferrel v. Allstate Insurance Co. , 106 Idaho 696 (Ct. App. 1984). [ 8 ]. Approximately one quarter mile. [ 9 ]. Approximately 2 miles from Tobias’ cabin. [ 10 ]. The brand was actually registered to his partner, *** Black. [ 11 ]. This point does not even examine the question of whether one can have a reasonable expectation of privacy in someone else’s cows. [ 12 ]. The Collett/Tobias allotment is approximately five miles long and varies from approximately one mile wide to over two miles wide, so it cannot equate to a premises. [ 13 ]. Also known as the Carroll Doctrine. [ 14 ]. Idaho Code sec. 25-1903 states that, â€Å"any person who uses, or has, or keeps in his possession, any running branding iron, tool, or instrument used by him for running a brand on any livestock†¦ is guilty of grand larceny†¦. [T]he possession of such iron or instrument is prima facie evidence of guilt. † [ 15 ]. The seizure of the pants is also similar, as both were items held out to public view. How to cite Search Seizure, Open Fields Doctrine, Essay examples

PeaceKeeping In Iraq Comparing Traditional Vs. U.S. Essay Sample free essay sample

Abstractions: America is confronting its biggest challenge in Iraq in the signifier of peacekeeping. There is turning distrust and sectarian force in a state that has no political or societal system left and with no economic agencies to prolong itself. The lifting instability in the Iraq is taking to stableness and security issues in the Middle East and Central Asia as good. America is now looking at two options. either to transport out peace maintaining missions itself. or to take the aid of UN and seek to set up peace in the part. Which of the two options remains to be decided? Introduction: Iraq in the past few old ages has undergone a major transmutation with the remotion of Saddam Hussein and the debut of the U. S military in topographic point. From remotion of absolutism to Restoration of democracy. and the incidences of assurgency with Sunni Shiite force. this is merely the tip of the ice berg that the current Iraq constitutes. We will write a custom essay sample on PeaceKeeping In Iraq: Comparing Traditional Vs. U.S. Essay Sample or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page Iraq now faces jobs with its economic. every bit good as industrial and societal apparatus. basic necessities of life. jobs at the boundary lines with the Kurds. Iran instability. continued addition in hatred for the American ground forces and the uninterrupted discontent about the electoral procedures and the hereafter of the state. and these jobs show no opportunities of decelerating down. Iraq presently hangs by a yarn with respects to stableness. But even more of import is the possible destabilization that will result should Iraq neglect. Iraq is presently the 2nd largest oil manufacturer. and its resources are under menace. With its stultifying economic system. Iraq faces menaces from its neighbours Iran and Syria every bit good. The new moving ridge of force among the Sunni and Shiite Muslims has made the part one of the most volatile in the universe. and presently there is perfectly no 1 point where the whole Iraqi state is standing united. The loss of cultural heritage. economic position. and any sort of societal model is making individuality crises. which Iraqis feel has been defaced by American propaganda. The immediate loss of one of the most controversial yet powerful leaders of Iraq. which is Saddam Hussein. has led to a new set of jobs sing administration and political control. The American invasion and invasion and so active engagement in the electoral procedure has increased misgiving among Iraqis about current authorities every bit good. peculiarly since it has been unable to supply any conclusive aid to the people confronting jobs due to war. The late and really meagre human-centered services in the part are another ground why Iraq is hostile and angry at the minute. For this. Iraq sees merely one to fault and that is the United States. Among the most urgent current jobs that are faced by America is peacekeeping in Iraq. This simple term includes a really broad assortment of issues that are needed to be established and maintained in a tense country to make favourable conditions. Such peacekeeping intercessions may change from carry oning election processes to diversion of the constabulary and defence systems. nevertheless. all aim to make a societal every bit good as a political state of affairs that ensures peace and stableness in the part. Most of the peace maintaining missions take topographic point in war afflicted countries. and hence. the peace maintaining missions have added duty to supply human-centered services every bit good. Therefore a peace maintaining mission is steering every bit good as keeping system that may be required to be present until the country is stabilized and regional turbulency is dealt with. ( Serafina. 2004 ) With a negative image of America in Iraq. it is confronting huge troubles in deriving any support for any peace maintaining operations. Iraq views these operations as extensions of American programs for deriving control and domination in the part. and as such there is no peculiar shaping characteristic that can assist define it apart from verbal confidences from the Pentagon. Therefore. America stands in between a moral and ethical quandary about supplying peace and order in a part that itself was responsible for destructing. Initially against any sort of peace maintaining operations where America would tie in itself. America is now looking at assorted possibilities that can assist in work outing current Iraq peace issue. With really small support within and outside Iraq. America faces enormous challenge. for which it will non derive any recognition even if it succeeds. THE PEACE PROBLEMS OF IRAQ: BACKGROUND AND CONTRIBUTING FACTORS In order to understand the true jobs of peace maintaining in Iraq. one must derive position about both sides and how they influence the response of the part every bit good as the Earth. American policy was neer limited to Afghanistan or Iraq. and alternatively was intended for cardinal Asia. There were three security issues in cardinal Asia that USA wished to accomplish. First was security itself. where concerns were about regulation and extinguishing terrorist act. drug trafficking and accomplishing non proliferation. This issue came to attending instantly after the 9/11 onslaughts. when the security of American state came under menace. America’s 2nd most of import program in cardinal Asia is related to energy and resources. and making economical planetary conditions that guarantee sustained development of the part. every bit good as protection and saving of these. The 3rd purpose was democratisation every bit good as market oriented alterations ; in other words. internal ref orm of the part conductive of U. S involvements. While these programs were present for a long clip. the 9/11 incidence increased the urgency of accomplishing these ends. Cardinal Asia is a really of import country for America’s antiterrorist programs. and hence America has been working in assorted ways to derive support of the part. America did win in deriving support in the initial phases. Through assorted support such as the Freedom Support Act financess. America gave aid to the assorted states to assist in its antiterrorism plans. Such plans nevertheless. required the aid of local countries where preparation could be provided to the American military personnels deployed in the assorted parts. America besides wanted assorted bases for its air discourtesies. and hence needed to construct itself strategically in the part. America hence. decided on the policy â€Å"the best defence is a good offense† . which may hold cost its neighbours and the mark states significantly high in the long tally. America explained itself by saying that certain countries in Middle East every bit good as Northeast Asia are parts of instability which must be taken attention of in order to guarantee safety of Asia and forestall any future menace to America. Therefore. for the most portion. America has been transporting out onslaughts on presumed menaces to the American state. while disregarding that these were possible menaces merely. and did non necessitate such barbarous tactics. These and many such intercessions of the American ground forces have created many complications and destabilization in the part itself. and many states are now confronting difference and confusion every bit good as deficiency of safety due to American steps. Kyrgyzstan. Afghanistan. Iraq. Iran. Pakistan and Uzbekistan now face some of the most disruptive times sing their hereafter every bit good as their security. and the changeless but unproductive presence of American military personnels continue to destabilise the harmoniousness of the part. Many personal grounds are besides cited for the war on Iraq. One of the chief grounds why America wished to command Iraq has been its oil militias. which comprise of one of the biggest oil beginnings in the universe. The control of this trade good particularly in the clip when oil monetary values are high is the chief ground why the super powers in the part every bit good as America are seeking to command Iraq. ( Lipinski. 2007 ) with the uninterrupted presence of Saddam Hussein. America was unable to command this really big influencer of the universe economic system with respects to oil. In order to accomplish this control. America had to transport out some kind of military action in the part. Since the war in Iraq. the alterations in the Middle East have been really disruptive and full of assorted reactions. While in the yesteryear. the Central Asia cooperation was something the USA could number on. Iraq was raised inquiries about whether America plans to stabilise or destabilise the part. The Afghanistan war was the initial point where America established its support with the Middle East and the cardinal Asia. but turning concern is taking topographic point as America still struggles to accomplish some balance in the helter-skelter hereafter of Iraq. ( Wishnick. 2004 ) Iraq war has led to increase in competition among the neighbour giants every bit good such as Russia. China and India. who do non wish external influence of USA in the part. Russia since the Iraq war is in tense dealingss with America. and inquiries the true purpose of the USA about the Iraq war. ( Wishnick. 2004 ) Many analysts believe that the measure taken in the signifier of war is really USA seeking to set up control in an country that was one time really hard to accomplish. The jobs on the US believe armored combat vehicle are lifting. for in the yesteryear America was focused merely on the political facet of Iraq. it now has to manage its complex human-centered issues produced straight as a consequence of war. and understand the regional political relations and spiritual tensenesss that are portion of the Iraqi civilization. America still faces tough opposition from Iraqis about their presence in their dirt. and America hence. now has to give human-centered aid along side in o rder to trust any improved dealingss with the locals. ( Wishnick. 2004 ) Russia continues to play against America in this war of panic. and the distressing influence and constitution that the USA is seeking to accomplish in the part. While Russia believes in battling terrorist organisations of all sorts. it is besides asseverating its military presence by bettering its bilateral dealingss in the part through cooperation. Russia in assorted times offered to move as a peacekeeping mission in Commonwealth of Independent States. every bit good as in assorted countries of cardinal Asia. However. Russia can non be called an ally to America. This is because Russia and Chinas have the same involvement in set uping their regional high quality and in this respect do non wish to hold any American presence in the part that can act upon their high quality. Russia’s policies remain to be really of import in the yesteryear every bit good as in the future waies in stableness of Asia. ( Wishnick. 2004 ) America itself changed its schemes with respects to the location of the footing. which it aims to exchange from Saudi Arabia to Qatar. ( Wishnick. 2004 ) This in portion has been done as a consequence of increased tensenesss between Meleagris gallopavo and USA. where Meleagris gallopavo had refused to supply its military footing for USA operations in Iraq. More and more states are now defying America’s invasion in their military parturiencies. and most of them are against usage of their bases on any of the adjacent states. ( Wishnick. 2004 ) Almost all the states in the cardinal every bit good as the remainder of the Asiatic part review America’s onslaught on Iraq and how it has led to destabilization of the part. While ab initio Kazakhstan was some what supportive and even concerted to the operations of America. recent polls have revealed that they Kazakhstan populace besides are against war on Iraq. ( Wishnick. 2004 ) Current SITUATION IN IRAQ The war on Iraq did non accomplish the coveted consequence that America wished. America thought by pulverizing Iraq and Afghanistan. there would be a decrease in the so called terrorist activities that were being carried out by assorted radical Islamic groups. However. the studies have shown other wise. and these activities are now prevailing in many parts of Asia. The atrociousnesss of war in Iraq and Afghanistan possibly are the ground of renewed insurgency and opposition against American invasion in the country. While the states of the part do non back up such radical activities. they surely do non wish America’s presence in the part. and the potency of farther destabilization of the part. which has taken topographic point since the Afghanistan and the Iraq wars. ( Wishnick. 2004 ) The harm to the American resources has besides been high. There has been loss of more than 3000 American soldiers with infinite others who have been injured during the war. The costs of the war on Iraq have been really high. and the sum to be spent on rehabilitation of the country is even higher. With complete destruction of the societal model. the undertaking in front of America to reconstruct Iraq is really immense. ( Lipinski. 2007 ) America at this phase can non retreat from Iraq chiefly due to the disruptive conditions that it has created in the part. Iran and Syria are really likely to fall into contending if Iraq fails. and Saudi Arabia is besides sing military action in the part if the mass violent death of Sunni Muslims is non stopped in the Iraqi part. Along side the issue of Kurds and their battle for the development of a separate state continues. Therefore. America has now become cause for a multi state war. which will hold really annihilating effects on the universe. due to the cardinal presence of oil in the part. ( Lipinski. 2007 ) THE HUMANITARIAN AND HUMAN RIGHTS OF THE REGION. AND THE ROLE OF VARIOUS NATIONS IN THIS REGARD For the most portion. the war in Iraq and Afghanistan failed to concentrate on the human-centered issues that took topographic point. While these attempts were no uncertainty nowadays. it is merely late that they are get downing to be felt and considered for assorted arguments and attempts. America’s believing form about certain states has been akin to the ideas in the Cold War epoch. Back so America was focused against the Communist governments. and today. it is moving on the same thought form against â€Å"rogue states† which need alteration of administration. ( Wishnick. 2004 ) With the transition of clip. the hatred of Iraqi people towards American military personnels is increasing. which raises the inquiry about peacekeeping missions. ( Lipinski. 2007 ) In the yesteryear. America was sing deploying the US peacekeeping military personnels in to the part. However. the current targeted deceases of American military personnels are coercing America to see international aid for peace maintaining missions. Problem here is that many of the states have merely refused to flip in. merely because they feel America should unclutter the muss up itself. Therefore. America’s many enterprises to make international peacekeeping forces are neglecting wholly. It is now hoped that the aid of UN can salvage Iraq and supply the necessary forces required to finish the peace maintaining procedure in Iraq. ( Lipinski. 2007 ) THE PROBLEMS WITH PEACEKEEPING Current military operations around the universe are now largely concentrated towards peacekeeping missions. With the war in Iraq and Afghanistan. the current environment of the Middle East and cardinal Asia is extremely disruptive. and inquiries sing the type of peacekeeping are increasing. ( Serafina. 2004 ) Sustainable peace in a part requires a secure and stable environment. Stability and peace devising are really slow procedures. which may necessitate the military or the ground forces in the initial phases. but can non win unless there is some strategic policy doing which ensures cooperation and understanding from two parties at difference. Military presence is possibly one of the exacerbating factors in the creative activity of tenseness in the part. Therefore. alternate signifiers of peace keepers are now besides being considered. International civilian constabulary is now among the new line of peacekeeping mission that are hoped non to make tensenesss or aggression in any part that they are deployed into. Such establishments are now deriving attending for their apprehension of the demand of assorted United Nations peacekeeping operations and the ends that united state attempts to accomplish while carry oning such operations. ( Serafina. 2004 ) The argument arises here as to who gets to supply peacekeeping in Iraq. While the UN system of peace maintaining has been working since its origin. there are many who think there is demand for new systems of peacekeeping. This is surely the subject of argument in the US Congress. which is contemplating on whether to advance UN peacekeeping plans by giving it support. or by making a new US peacekeeping system exposing CivPol capablenesss. ( Serafina. 2004 ) The US peacekeeping proposals are aimed at bettering the quality and capablenesss of the CivPol. Many enterprises have been proposed in the past. of which Clinton’s Administration February 2000 Presidential Decision Directive 71. focused on the jurisprudence enforcement facets of peace maintaining. ( Serafina. 2004 ) This in many ways is a really different base from one that Bush disposal took at the beginning of their term. The US authorities had been wholly against the inclusion of the US ground forces into assorted peacekeeping missions of any sort. Now it is suggesting the formation of a new peacekeeping force. which would be trained by the US authorities. Such an docket is non being received to the full by other states. which believe that there should be no individual state ordering the peacekeeping mission or its assorted facets of preparation and dispatching. There are many challenges the US ground forces has to get the better of in order to win at this. The peacekeepin g missions will necessitate a major part of the US ground forces to be abroad. and this will well stretch the bounds of the ground forces. The US chiefly got interested in this plan because it wants a speedy issue scheme from Iraq. which is a state of affairs beyond America’s control. Now it aims to take such plans by giving preparation to the participants around the universe. Again. while in the yesteryear. the UN and other international states acknowledged the high support it got from the US. it was non under any duty for America to take the assorted peace missions. The current proposal given by the US authorities could good present this impression. and hence. there is hesitance from many circles related to it. ( Schrader. 2003 ) THE UN PEACEKEEPING MISSIONS United Nations can be called one of the first of the assorted peacekeeping missionaries on international graduated table. It has been working continuously since its constitution in to supplying peace in assorted countries of struggle. However. many alterations have taken topographic point since its constitution. and UN is now germinating itself and its authorizations. ( Serafina. 2004 ) There are many grounds for these alterations. For some clip now. the UN peacekeeping missions have been acquiring hapless recommendations with the transition of clip. The Brahimi Panel study in 2000 pointed out assorted jobs in the current UN peacekeeping missions and besides provided some really of import recommendations with respects to bettering it. These recommendations were chiefly affecting the enlisting and preparation. and the deployment of civilian constabulary forces. Such recommendations propose that the CivPol of the UN be a separate force. showing constabulary with military accomplishment s in order to manage efficaciously assorted state of affairss in the tenseness zones. Most of these recommendations besides propose a lessening in the trust of US military forces and creative activity of separate force that is able to transport out international peacekeeping missions. ( Serafina. 2004 ) Among these authorizations is included monitoring of the authorizations. add-on of preparation constituents. the development of authorizations that include significant reform and reconstituting capacities of the current systems. the add-on of constabulary units. and enlargement of the authorizations that provide them with executive authorization about commanding assorted peace state of affairss. Many of these recommendations are brooding of the proposals given by the Brahimi panel. and besides reflect the current tendencies of security. ( Serafina. 2004 ) There are nevertheless. some grounds why UN can lose its liability in Iraq. UN ab initio was wholly against the invasion of Iraq and even refused to back up the invasion. However. when America and its Alliess continued in this program and did occupy Iraq. the UN started to back up the act to avoid any tensenesss from Washington. This badly decreased the credibleness of the UN in many parts of the Earth. and particularly in the Arab states. Subsequently on in 2003. the UN once more caused a terrible bad luck. when it gave an official authorization to the business. claiming that the UK and the US had authorization over the assorted legal procedures of Iraq. UN hence. lost its credibleness as an active force. but became a weak inactive force that was under the monopoly of the USA. and following harmonizing to the caprices of it. ( War and Occupation in Iraq. 2007 ) However. on the positive side. the demand for the UN peacekeepers has neer been higher. In 2007 entirely. the demand was increased to 37. 000 military forces. which was twice the sum of the entire figure of peacekeeping agents deployed globally. The UN is presently being given more undertakings so it can manage. Already it is working in countries such as Lebanon. East Timor. and Darfur. It is now proposed to be deployed in Iraq. which may be excessively much for the UN to manage. The handing over of part such as Iraq to the UN could intend important jobs to the American foreign policy. ( Goldberg. 2007 ) America besides loses its credibleness because of its funding to the UN missions. Although it enjoys the claim of giving 27 % of the budget of peacekeeping to the UN. this sum is non sent. Most of these sums have been cut off by the senator Helms and Henry Hyde. who in fact reduced US parts to the UN by 25 % . This is once more puting to oppugn USA’s involvement in accomplishi ng universe order and peace. and once more puts America in negative visible radiation about its programs for peace and peacekeeping in the universe. Lack of UN support is non merely traveling to impact the quality of UN peacekeeping. but besides American involvements. This contradictory function of America. where it continues to back up assorted peace doing missions across the Earth with out supplying any support. is diminishing its credibleness among the states globally. ( Goldberg. 2007 ) Of the current enterprises taken to better the current peace maintaining forces of UN. there is increased involvement in rectifying the many highlighted mistakes and rectifying them consequently. Much of these intend a complete upgrading of the mission itself. and regenerating the Department of Peacekeeping Operations. ( Johnson. 1997 ) Among the assorted intercessions were included field disposal and logistics division to better working. The forces have been increased well so as to guarantee proper operation and turning away of understaffing. There has been work done to set up a 24 hr contact with all countries where peace maintaining missions are being carried out. so as to stay up to day of the month at changeless gait. There are attempts to better the degree of counsel and way of operations in this country. and the debut of assorted manuals have been introduced to assist in steering the assorted missions. These and other such enterprises are hoped to better the results of the UN peacekeeping forces. which in bend may assist in deciding differences in countries such as Iraq. ( Johnson. 1997 ) Introduction TO CIV POL IN PEACE KEEPING OPERATIONS CivPol or the civilian constabulary construct is a comparatively new one in the peacekeeping and international focal point. CivPol has been working in one signifier or the other since the late 19Thursdaycentury. While ab initio working at low profile in assorted international peacekeeping missions. CivPol started to derive attending station 1994. of all time since its debut into the United Nations. the CivPol profile has increased well. and now CivPol is fast going an of import constituent in the assorted peace missions around the universe. ( Serafina. 2004 ) Many states provide preparation and aid to the CivPol. and America is included among these. The primary map of the CivPol can be summarized by saying that it â€Å"monitors and supervises local forces. behaviors articulations patrol with them. trains and advises them. and aids in restructuring and reformation. including designation and ejection of unwanted members† ( Serafina. 2004 ) . CivPol’s maps can be summarized by their acronym SMART. which stands for support for human rights. monitoring. reding. coverage and preparation. Civilian constabulary has been an of import portion of the UN peacekeeping missions. Most of the forces that are included in such squads belong to Jordon. followed by America. Other states which are actively supplying members in the CivPol include India. Germany. Turkey. Ukraine. Nepal. Malaysia. Romania and Pakistan. While many states take portion in the preparation of these forces. there is an option of preparation of one state forces by a state under UN supervising. ( Serafina. 2004 ) With increased efficaciousness of these plans in commanding struggle state of affairss. the CivPol are now going the new force of peace maintaining mission around the universe. THE US CIVILIAN POLICE PROGRAM: AN ALTERNATIVE TO TRADITIONAL PEACEKEEPERS? USA is among the really few states which are working towards the creative activity of the US CivPol plan. This plan is involved in developing of the policy of the CivPol. and supplying assorted preparations that may be required for effectual operation of the recruits on assorted international missions. ( Serafina. 2004 ) These plans involved contractual employees from assorted local and municipal jurisprudence enforcement bureaus. Two companies have been main providers of the forces in this plan and include the DynCorp International and the Civilian Police International. Most of its support comes from channels such as the regional agency of the province sections and the peacekeeping histories. ( Serafina. 2004 ) This preparation plan nevertheless is non inexpensive. Annual costs of each US CivPol can run from $ 100. 000 to $ 175. 000 per caput harmonizing to the location of the struggle. These costs are presently the highest in the part of Iraq. which is raising inquiries about the entire costs and the budget deductions. ( Serafina. 2004 ) Among the two current issues sing the US ground forces and the peacekeeping issues is the whether the US ground forces be placed in UN control for peacekeeping intents. and whether the president should confer with with the Congress before any deployment of US military. The demand for inclusion of US military in the UN is the pressing demand due to the reducition in the figure of UN forces. However. the support of UN peacekeeping missions is dearly-won for the US. Many policies are being considered for the decrease of the figure of US soldiers in foreign peace maintaining operations. In Bosnia. the figure of US soldiers is being reduced. where as America has refused to supply any military support for Afghanistan peace maintaining missions. America presently is confronting many jobs with respects to its peace maintaining mission in Iraq. There are many hurdlings that America has to get the better of in order to let the Iraqi people to allow them transport out such operations. The Iraqis do non swear the Americans and believe that they are after the resources of Iraq and are in Iraq to avail the economic advantages of the part. America will hold a really tough clip in turn outing this. since many of the actions done by the US authorities in Iraq boulder clay now have non respected any of the cultural or economic values of the part. Another ground why the US military will hold jobs making so is due to the type of developing that they undergo as a soldier. The peacekeeping companies are fundamentally involved in deciding struggle. while the military forces are chiefly involved in combat and contending accomplishments. The usage restraint is required in peacekeeping missions instead than offense. which is non a common tacti c taught in the armed forces. It is in this mentality that the American authorities is sing the option of a separate peacekeeping force. ( Serafino. 2003 ) Reversion TO TRADITIONAL METHOD OF Peacekeeping: Turn TO UNwith the addition in the list of failures of the US authorities about the assorted facets of war. the planetary do-gooder and justness system supports that the UN should be handed over the disposal of Iraq. This. they claim is the lone possible manner to continue Iraq and forestall any catastrophe in the country. The protagonists of the UN mission put frontward four statements in favour over America’s peace maintaining mission. One restriction to the use of UN in Iraq is that UN has non been involved in any peacekeeping missions that may necessitate the usage of force to command the affairs. UN has shown more success in non violent peace missions. ( Johnson. 1997 ) The grounds cited for such is the deficiency of resources and the deficiency of sufficient will by the international community to transport out such intercessions. Time has besides revealed assorted operational and organisational mistakes in the UN peacekeeping steps. and assorted geopolitical state of affairss and countries mean that non all can be handled in the same manner as earlier. UN besides faces changeless deficiency of peace keepers as it means a voluntary proviso on behalf of the member states. Another concern is that it is neer confirmed whether the national troop contingents will transport out the orders given by the UN force commanding officer. These two issues really much undermine the degree of assertiveness that the UN can take. but is non allowed to. In this respect. with less authorization and expertness about carry oning forceful peace doing operations. the UN loses credibleness as the best possible option. ( Johnson. 1997 ) Decision Under the present conditions the continued stay of American ground forces in the Iraqi part can take to more force and negative results. American war on Iraq has caused important harm to the country that will take old ages to mend. The cultural loss of old heritage edifices is a important job that America has created in the part. With many atrociousnesss that have been carried out by the Americans in the Iraqi dirt. their staying will merely increase the degree of hatred among the Iraqis. Any effort to accommodate with this state will neglect bitterly. due to the utmost negative behaviour of the American authorities and the ground forces from the start. With this in head and the sort of harm that has demolished the whole societal cloth of Iraqi life. it is no admiration that America remains the most despised state in the Iraqi list. In this respect. the lone possible solution to the current Iraqi state of affairs is the deployment of forces that are impersonal and 1s to which the Iraqi people will react to in a more positive mode. Such a force should be wholly barren of any American influence. In this respect. the function of the UN peace maintaining mission or the traditional peacekeeping missions may be the lone manner any consequences can be achieved in the country. While UN is non used to managing highly sensitive and volatile countries. and it has led Iraq down in the yesteryear. the Iraqis are more likely to put their trust on the UN than on America. With the inclusion of international support and the voicing of international recommendations. there is more hope that Iraq will react quicker to UN than to US. However. there are many factors involved in the current state of affairs in Iraq and if the UN does non understand and react to them consequently. even the UN can neglect. The inquiry hence. should be. is at that place any hope for the hereafter of Iraq? Mentions Mark Leon Goldberg. 2007. the Coming Peacekeeping Crunch. The American Prospect. May 22. 2007. site last accessed on February 17Thursday. 2008 from Harold J Johnson. 1997. UN Peacekeeping. Issues Related to Effectiveness. Cost and Reform. Statement of Harold J Johnson. Associate Director. International Relations and Trade Issues. National Security and International Affairs Division Daniel Lipinski. 2007. A New Path for America’s Iraq Policy. January 9Thursday. 2007. site last accessed on February 16Thursday. 2008 from file hypertext transfer protocol: //www. lipinski. house. gov/index2. php? option=com_content A ; do_pdf=1 A ; id= Esther Schrader. 2003. US Looks at Forming Global Peace Keeping Force. Global Policy Forum. Site last accessed on February 18Thursday. 2008 from hypertext transfer protocol: //www. globalpolicy. org/security/issues/irqindx. htm Nina M Serafino. 2004. Patroling in Peacekeeping and Related Stability Operations: Problems and Proposed Solutions. Congressional Research Service. The Library of Congress. Nina M Serafino. 2003. Peacekeeping: Issues of US Military Involvement. Issue brief for Congress. Site last accesed on February 13Thursday. 2008 from hypertext transfer protocol: //digital. library. unt. edu/govdocs/crs/permalink/meta-crs-4254:1. War and Occupation in Iraq. 2007. site last accessed on February 13Thursday. 2008 from hypertext transfer protocol: //www. globalpolicy. org/security/issues/iraq/occupation/report/1introduction. htm Elizabeth Wishnick. 2004. Strategic Consequences of the Iraq War: US Security Interestsin in Central Asia Reassessed. The Strategic Studies Institute Stephen Zunes. 2003. Transfer the Administration of Iraq to the UN. Foreign Policy in Focus. Site last accessed on February 10Thursday. 2008 fromhypertext transfer protocol: //www. presentdanger. org/commentary/2003/0307untrans. hypertext markup language