STRUCTURED SETTLEMENT

A structured settlement is a financial or insurance arrangement, including periodic payments, that a claimant accepts to resolve a personal injury tort claim or to compromise a statutory periodic payment obligation. Structured settlements were first utilized in Canada and the United States during the 1970s as an alternative to lump sum settlements. Structured settlements are now part of the statutory tort law of several common law countries including Australia, Canada, England and the United States. Although some uniformity exists, each of these countries has its own definitions, rules and standards for structured settlements. Structured settlements may include income tax and spendthrift requirements as well as benefits. Structured settlement payments are sometimes called “periodic payments.” A structured settlement incorporated into a trial judgment is called a “periodic payment judgment."

Structured Settlements in the United States

The United States has enacted structured settlement laws and regulations at both the federal and state levels. Federal structured settlement laws include sections of the (federal) Internal Revenue Code^[1]. State structured settlement laws include structured settlement protection statutes and periodic payment of judgment statutes. Medicaid and Medicare laws and regulations affect structured settlements. To preserve a claimant’s Medicare and Medicaid benefits, structured settlement payments may be incorporated into “Medicare Set Aside Arrangements” “Special Needs Trusts."

Structured settlements have been endorsed by many of the nation's largest disability rights organizations, including the American Association of People with Disabilities ^[2] and the National Organization on Disability ^[3].

Definitions

The United States definition of “structured settlement” for federal income taxation purposes, found in Internal Revenue Code Section 5891(c)(1) (26 U.S.C. § 5891(c)(1)), is an "arrangement" that meets the following requirements:

• A structured settlement must be established by:
  • A suit or agreement for periodic payment of damages excludable from gross income under Internal Revenue Code Section 104(a)(2) (26 U.S.C. § 104(a)(2)); or
  • An agreement for the periodic payment of compensation under any workers’ compensation law excludable under Internal Revenue Code Section 104(a)(1) (26 U.S.C. § 104(a)(1)); and
• The periodic payments must be of the character described in subparagraphs (A) and (B) of Internal Revenue Code Section 130(c)(2) (26 U.S.C. § 130(c)(2))) and must be payable by a person who:
  • Is a party to the suit or agreement or to a workers' compensation claim; or
  • By a person who has assumed the liability for such periodic payments under a qualified assignment in accordance with Internal Revenue Code Section 130 (26 U.S.C. § 130).

Legal Structure

The typical structured settlement arises and is structured as follows: An injured party (the claimant) settles a tort suit with the defendant (or its insurance carrier) pursuant to a settlement agreement that provides that, in exchange for the claimant's securing the dismissal of the lawsuit, the defendant (or, more commonly, its insurer) agrees to make a series of periodic payments over time. The insurer, a property/casualty insurance company, thus finds itself with a long-term payment obligation to the claimant. To fund this obligation, the property/casualty insurer generally takes one of two typical approaches: It either purchases an annuity from a life insurance company (an arrangement called a "buy and hold" case) or it assigns (or, more properly, delegates) its periodic payment obligation to a third party which in turn purchases an annuity (which arrangement is called an "assigned case").

In an unassigned case, the property/casualty insurer retains the periodic payment obligation and funds it by purchasing an annuity from a life insurance company, thereby offsetting its obligation with a matching asset. The payment stream purchased under the annuity matches exactly, in timing and amounts, the periodic payments agreed to in the settlement agreement. The property/casualty company owns the annuity and names the claimant as the payee under the annuity, thereby directing the annuity issuer to send payments directly to the claimant. If any of the periodic payments are life-contingent (i.e., the obligation to make a payment is contingent on someone continuing to be alive), then the claimant (or whoever is determined to be the measuring life) is named as the annuitant or measuring life under the annuity.

In an assigned case, the property/casualty company does not wish to retain the long-term periodic payment obligation on its books. Accordingly, the property/casualty insurer transfers the obligation, through a legal device called a qualified assignment, to a third party. The third party, called an assignment company, will require the property/casualty company to pay it an amount sufficient to enable it to buy an annuity that will fund its newly accepted periodic payment obligation. If the claimant consents to the transfer of the periodic payment obligation (either in the settlement agreement or, failing that, in a special form of qualified assignment known as a qualified assignment and release), the defendant and/or its property/casualty company has no further liability to make the periodic payments. This method of substituting the obligor is desirable for property/casualty companies that do not want to retain the periodic payment obligation on their books. Typically, an assignment company is an affiliate of the life insurance company from which the annuity is purchased.

An assignment is said to be "qualified" if it satisfies the criteria set forth in Internal Revenue Code Section 130 [1]. Qualification of the assignment is important to assignment companies because without it the amount they receive to induce them to accept periodic payment obligations would be considered income for federal income tax purposes. If an assignment qualifies under Section 130, however, the amount received is excluded from the income of the assignment company. This provision of the tax code was enacted to encourage assigned cases; without it, assignment companies would owe federal income taxes but would typically have no source from which to make the payments.

MESOTHELIOMA

Mesothelioma is a form of cancer that is almost always caused by previous exposure to asbestos. In this disease, malignant cells develop in the mesothelium, a protective lining that covers most of the body's internal organs. Its most common site is the pleura (outer lining of the lungs and internal chest wall), but it may also occur in the peritoneum (the lining of the abdominal cavity), the heart,^[1] the pericardium (a sac that surrounds the heart) or tunica vaginalis.

Most people who develop mesothelioma have worked on jobs where they inhaled asbestos particles, or they have been exposed to asbestos dust and fiber in other ways. Washing the clothes of a family member who worked with asbestos can also put a person at risk for developing mesothelioma.^[2] Unlike lung cancer, there is no association between mesothelioma and smoking.^[3] Compensation via asbestos funds or lawsuits is an important issue in mesothelioma (see asbestos and the law).

The symptoms of mesothelioma include shortness of breath due to pleural effusion (fluid between the lung and the chest wall) or chest wall pain, and general symptoms such as weight loss. The diagnosis may be suspected with chest X-ray and CT scan, and is confirmed with a biopsy (tissue sample) and microscopic examination. A thoracoscopy (inserting a tube with a camera into the chest) can be used to take biopsies. It allows the introduction of substances such as talc to obliterate the pleural space (called pleurodesis), which prevents more fluid from accumulating and pressing on the lung. Despite treatment with chemotherapy, radiation therapy or sometimes surgery, the disease carries a poor prognosis. Research about screening tests for the early detection of mesothelioma is ongoing.

Signs and symptoms

Symptoms of mesothelioma may not appear until 20 to 50 years after exposure to asbestos. Shortness of breath, cough, and pain in the chest due to an accumulation of fluid in the pleural space are often symptoms of pleural mesothelioma.

Symptoms of peritoneal mesothelioma include weight loss and cachexia, abdominal swelling and pain due to ascites (a buildup of fluid in the abdominal cavity). Other symptoms of peritoneal mesothelioma may include bowel obstruction, blood clotting abnormalities, anemia, and fever. If the cancer has spread beyond the mesothelium to other parts of the body, symptoms may include pain, trouble swallowing, or swelling of the neck or face.

These symptoms may be caused by mesothelioma or by other, less serious conditions.

Mesothelioma that affects the pleura can cause these signs and symptoms:

• chest wall pain
• pleural effusion, or fluid surrounding the lung
• shortness of breath
• fatigue or anemia
• wheezing, hoarseness, or cough
• blood in the sputum (fluid) coughed up (hemoptysis)

In severe cases, the person may have many tumor masses. The individual may develop a pneumothorax, or collapse of the lung. The disease may metastasize, or spread, to other parts of the body.

Tumors that affect the abdominal cavity often do not cause symptoms until they are at a late stage. Symptoms include:

• abdominal pain
• ascites, or an abnormal buildup of fluid in the abdomen
• a mass in the abdomen
• problems with bowel function
• weight loss

In severe cases of the disease, the following signs and symptoms may be present:

• blood clots in the veins, which may cause thrombophlebitis
• disseminated intravascular coagulation, a disorder causing severe bleeding in many body organs
• jaundice, or yellowing of the eyes and skin
• low blood sugar level
• pleural effusion
• pulmonary emboli, or blood clots in the arteries of the lungs
• severe ascites

A mesothelioma does not usually spread to the bone, brain, or adrenal glands. Pleural tumors are usually found only on one side of the lungs.

Diagnosis

CT scan of a patient with mesothelioma, coronal section (the section follows the plane that divides the body in a front and a back half). The mesothelioma is indicated by yellow arrows, the central pleural effusion (fluid collection) is marked with a yellow star. Red numbers: (1) right lung, (2) spine, (3) left lung, (4) ribs, (5) descending part of the aorta, (6) spleen, (7) left kidney, (8) right kidney, (9) liver.

Diagnosing mesothelioma is often difficult, because the symptoms are similar to those of a number of other conditions. Diagnosis begins with a review of the patient's medical history. A history of exposure to asbestos may increase clinical suspicion for mesothelioma. A physical examination is performed, followed by chest X-ray and often lung function tests. The X-ray may reveal pleural thickening commonly seen after asbestos exposure and increases suspicion of mesothelioma. A CT (or CAT) scan or an MRI is usually performed. If a large amount of fluid is present, abnormal cells may be detected by cytology if this fluid is aspirated with a syringe. For pleural fluid this is done by a pleural tap or chest drain, in ascites with an paracentesis or ascitic drain and in a pericardial effusion with pericardiocentesis. While absence of malignant cells on cytology does not completely exclude mesothelioma, it makes it much more unlikely, especially if an alternative diagnosis can be made (e.g. tuberculosis, heart failure).

If cytology is positive or a plaque is regarded as suspicious, a biopsy is needed to confirm a diagnosis of mesothelioma. A doctor removes a sample of tissue for examination under a microscope by a pathologist. A biopsy may be done in different ways, depending on where the abnormal area is located. If the cancer is in the chest, the doctor may perform a thoracoscopy. In this procedure, the doctor makes a small cut through the chest wall and puts a thin, lighted tube called a thoracoscope into the chest between two ribs. Thoracoscopy allows the doctor to look inside the chest and obtain tissue samples.

If the cancer is in the abdomen, the doctor may perform a laparoscopy. To obtain tissue for examination, the doctor makes a small incision in the abdomen and inserts a special instrument into the abdominal cavity. If these procedures do not yield enough tissue, more extensive diagnostic surgery may be necessary.

Typical immunohistochemistry results

Positive	Negative
EMA (epithelial membrane antigen) in a membranous distribution	CEA (carcinoembryonic antigen)
WT1 (Wilms' tumour 1)	B72.3
Calretinin	MOC-3 1
Mesothelin-1	CD15
Cytokeratin 5/6	Ber-EP4
HBME-1 (human mesothelial cell 1)	TTF-1 (thyroid transcription factor-1)

Screening

There is no universally agreed protocol for screening people who have been exposed to asbestos. Screening tests might diagnose mesothelioma earlier than conventional methods thus improving the survival prospects for patients. The serum osteopontin level might be useful in screening asbestos-exposed people for mesothelioma. The level of soluble mesothelin-related protein is elevated in the serum of about 75% of patients at diagnosis and it has been suggested that it may be useful for screening.^[4] Doctors have begun testing the Mesomark assay which measures levels of soluble mesothelin-related proteins (SMRPs) released by diseased mesothelioma cells.^[5]

Staging

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Mesothelioma is described as localized if the cancer is found only on the membrane surface where it originated. It is classified as advanced if it has spread beyond the original membrane surface to other parts of the body, such as the lymph nodes, lungs, chest wall, or abdominal organs.

Pathophysiology

The mesothelium consists of a single layer of flattened to cuboidal cells forming the epithelial lining of the serous cavities of the body including the peritoneal, pericardial and pleural cavities. Deposition of asbestos fibres in the parenchyma of the lung may result in the penetration of the visceral pleura from where the fibre can then be carried to the pleural surface, thus leading to the development of malignant mesothelial plaques. The processes leading to the development of peritoneal mesothelioma remain unresolved, although it has been proposed that asbestos fibres from the lung are transported to the abdomen and associated organs via the lymphatic system. Additionally, asbestos fibres may be deposited in the gut after ingestion of sputum contaminated with asbestos fibres.

Pleural contamination with asbestos or other mineral fibres has been shown to cause cancer. Long thin asbestos fibers (blue asbestos, amphibole fibers) are more potent carcinogens than "feathery fibers" (chrysotile or white asbestos fibers).^[6] However, there is now evidence that smaller particles may be more dangerous than the larger fibers.[1][2] They remain suspended in the air where they can be inhaled, and may penetrate more easily and deeper into the lungs. "We probably will find out a lot more about the health aspects of asbestos from [the World Trade Center attack], unfortunately," said Dr. Alan Fein, chief of pulmonary and critical-care medicine at North Shore-Long Island Jewish Health System. Dr. Fein has treated several patients for "World Trade Center syndrome" or respiratory ailments from brief exposures of only a day or two near the collapsed buildings.[3]

Mesothelioma development in rats has been demonstrated following intra-pleural inoculation of phosphorylated chrysotile fibres. It has been suggested that in humans, transport of fibres to the pleura is critical to the pathogenesis of mesothelioma. This is supported by the observed recruitment of significant numbers of macrophages and other cells of the immune system to localised lesions of accumulated asbestos fibres in the pleural and peritoneal cavities of rats. These lesions continued to attract and accumulate macrophages as the disease progressed, and cellular changes within the lesion culminated in a morphologically malignant tumour.

Experimental evidence suggests that asbestos acts as a complete carcinogen with the development of mesothelioma occurring in sequential stages of initiation and promotion. The molecular mechanisms underlying the malignant transformation of normal mesothelial cells by asbestos fibres remain unclear despite the demonstration of its oncogenic capabilities. However, complete in vitro transformation of normal human mesothelial cells to malignant phenotype following exposure to asbestos fibres has not yet been achieved. In general, asbestos fibres are thought to act through direct physical interactions with the cells of the mesothelium in conjunction with indirect effects following interaction with inflammatory cells such as macrophages.

INTEREST

Interest is a fee paid on borrowed assets. Assets that are sometimes lent with interest include money, shares, consumer goods through hire purchase, major assets such as aircraft, and even entire factories in finance lease arrangements. The interest is calculated upon the value of the assets in the same manner as upon money. Interest can be thought of as "rent on money". For example, if you want to borrow money from the bank, there is a certain rate you have to pay according to how much you want loaned to you.

Interest is compensation to the lender for foregoing other useful investments that could have been made with the loaned asset. These foregone investments are known as the opportunity cost. Instead of the lender using the assets directly, they are advanced to the borrower. The borrower then enjoys the benefit of using the assets ahead of the effort required to obtain them, while the lender enjoys the benefit of the fee paid by the borrower for the privilege. The amount lent, or the value of the assets lent, is called the principal. This principal value is held by the borrower on credit. Interest is therefore the price of credit, not the price of money as it is commonly believed to be.^{[citation needed]} The percentage of the principal that is paid as a fee (the interest), over a certain period of time, is called the interest rate.

History of interest

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Interest is the price paid for the use of savings over a given period of time. In ancient biblical Israel, it was against the Law of Moses to charge interest on private loans.^{[citation needed]}During the Middle Ages, time was considered to be property of God. Therefore, to charge interest was considered to be commerce with God's property. Also, St. Thomas Aquinas, the leading theologian of the Catholic Church, argued that the charging of interest is wrong because it amounts to "double charging", charging for both the thing and the use of the thing. The church regarded this as a sin of usury; nevertheless, this rule was never strictly obeyed and eroded gradually until it disappeared during the industrial revolution.^{[citation needed]}

Usury has always been viewed negatively by the Roman Catholic Church. The Second Lateran Council condemned any repayment of a debt with more money than was originally loaned, the Council of Vienna explicitly prohibited usury and declared any legislation tolerant of usury to be heretical, and the first scholastics reproved the charging of interest. In the medieval economy, loans were entirely a consequence of necessity (bad harvests, fire in a workplace) and, under those conditions, it was considered morally reproachable to charge interest.^{[citation needed]}

Interest has often been looked down upon in Islamic civilization as well for the same reason for which usury was forbidden by the Catholic Church, with most scholars agreeing that the Qur'an explicitly forbids charging interest. Medieval jurists therefore developed several financial instruments to encourage responsible lending. These instruments sometimes closely resemble interest, leading some to wonder whether they truly satisfy the letter and spirit of the rule.^{[citation needed]}

In the Renaissance era, greater mobility of people facilitated an increase in commerce and the appearance of appropriate conditions for entrepreneurs to start new, lucrative businesses. Given that borrowed money was no longer strictly for consumption but for production as well, interest was no longer viewed in the same manner. The School of Salamanca elaborated on various reasons that justified the charging of interest: the person who received a loan benefited, and one could consider interest as a premium paid for the risk taken by the loaning party. There was also the question of opportunity cost, in that the loaning party lost other possibilities of using the loaned money. Finally and perhaps most originally was the consideration of money itself as merchandise, and the use of one's money as something for which one should receive a benefit in the form of interest. Martín de Azpilcueta also considered the effect of time. Other things being equal, one would prefer to receive a given good now rather than in the future. This preference indicates greater value. Interest, under this theory, is the payment for the time the loaning individual is deprived of the money.

Economically, the interest rate is the cost of capital and is subject to the laws of supply and demand of the money supply. The first attempt to control interest rates through manipulation of the money supply was made by the French Central Bank in 1847.

The first formal studies of interest rates and their impact on society were conducted by Adam Smith, Jeremy Bentham and Mirabeau during the birth of classic economic thought.^{[citation needed]} In the early 20th century, Irving Fisher made a major breakthrough in the economic analysis of interest rates by distinguishing nominal interest from real interest. Several perspectives on the nature and impact of interest rates have arisen since then. Among academics, the more modern views of John Maynard Keynes and Milton Friedman are widely accepted.^{[citation needed]}

The latter half of the 20th century saw the rise of interest-free Islamic banking and finance, a movement which attempts to apply religious law developed in the medieval period to the modern economy. Some entire countries, including Iran, Sudan, and Pakistan, have taken steps to eradicate interest from their financial systems entirely.^{[citation needed]} Interest is the fee to use the money.

Types of interest

Simple interest

Simple interest is calculated only on the principal amount, or on that portion of the principal amount which remains unpaid.

The amount of simple interest is calculated according to the following formula:

where r is the period interest rate (I/m), B₀ the initial balance and m the number of time periods elapsed.

To calculate the period interest rate r, one divides the interest rate I by the number of periods m.

For example, imagine that a credit card holder has an outstanding balance of $2500 and that the simple interest rate is 12.99% per annum. The interest added at the end of 3 months would be,

and he would have to pay $2581.19 to pay off the balance at this point.

If instead he makes interest-only payments for each of those 3 months at the period rate r, the amount of interest paid would be,

His balance at the end of 3 months would still be $2500.

In this case, the time value of money is not factored in. The steady payments have an additional cost that needs to be considered when comparing loans. For example, given a $100 principal:

• Credit card debt where $1/day is charged: 1/100 = 1%/day = 7%/week = 365%/year.
• Corporate bond where the first $3 are due after six months, and the second $3 are due at the year's end: (3+3)/100 = 6%/year.
• Certificate of deposit (GIC) where $6 is paid at the year's end: 6/100 = 6%/year.

There are two complications involved when comparing different simple interest bearing offers.

1. When rates are the same but the periods are different a direct comparison is inaccurate because of the time value of money. Paying $3 every six months costs more than $6 paid at year end so, the 6% bond cannot be 'equated' to the 6% GIC.
2. When interest is due, but not paid, does it remain 'interest payable', like the bond's $3 payment after six months or, will it be added to the balance due? In the latter case it is no longer simple interest, but compound interest.

A bank account offering only simple interest and from which money can freely be withdrawn is unlikely, since withdrawing money and immediately depositing it again would be advantageous.

Compound interest

Main article: Compound interest

Compound interest is very similar to simple interest; however, with time, the difference becomes considerably larger. This difference is because unpaid interest is added to the balance due. Put another way, the borrower is charged interest on previous interest. Assuming that no part of the principal or subsequent interest has been paid, the debt is calculated by the following formulas:

where I_comp is the compound interest, B₀ the initial balance, B_n the balance after n periods (where n is not necessarily an integer) and r the period rate.

For example, if the credit card holder above chose not to make any payments, the interest would accumulate

So, at the end of 3 months the credit card holder's balance would be $2582.07 and he would now have to pay $82.07 to get it down to the initial balance. Simple interest is approximately the same as compound interest over short periods of time, so frequent payments are the best (least expensive) payment strategy.

A problem with compound interest is that the resulting obligation can be difficult to interpret. To simplify this problem, a common convention in economics is to disclose the interest rate as though the term were one year, with annual compounding, yielding the effective interest rate. However, interest rates in lending are often quoted as nominal interest rates (i.e., compounding interest uncorrected for the frequency of compounding).^{[citation needed]}

Loans often include various non-interest charges and fees. One example are points on a mortgage loan in the United States. When such fees are present, lenders are regularly required to provide information on the 'true' cost of finance, often expressed as an annual percentage rate (APR). The APR attempts to express the total cost of a loan as an interest rate after including the additional fees and expenses, although details may vary by jurisdiction.

In economics, continuous compounding is often used due to its particular mathematical properties.^{[citation needed]}

Fixed and floating rates

Commercial loans generally use simple interest, but they may not always have a single interest rate over the life of the loan. Loans for which the interest rate does not change are referred to as fixed rate loans. Loans may also have a changeable rate over the life of the loan based on some reference rate (such as LIBOR and EURIBOR), usually plus (or minus) a fixed margin. These are known as floating rate, variable rate or adjustable rate loans.

Combinations of fixed-rate and floating-rate loans are possible and frequently used. Loans may also have different interest rates applied over the life of the loan, where the changes to the interest rate are governed by specific criteria other than an underlying interest rate. An example would be a loan that uses specific periods of time to dictate specific changes in the rate, such as a rate of 5% in the first year, 6% in the second, and 7% in the third.^{[citation needed]}

Composition of interest rates

In economics, interest is considered the price of credit, therefore, it is also subject to distortions due to inflation. The nominal interest rate, which refers to the price before adjustment to inflation, is the one visible to the consumer (i.e., the interest tagged in a loan contract, credit card statement, etc). Nominal interest is composed of the real interest rate plus inflation, among other factors. A simple formula for the nominal interest is:

i = r + π

Where i is the nominal interest, r is the real interest and π is inflation.

This formula attempts to measure the value of the interest in units of stable purchasing power. However, if this statement was true, it would imply at least two misconceptions. First, that all interest rates within an area that shares the same inflation (i.e. the same country) should be the same. Second, that the lender knows the inflation for the period of time that he/she is going to lend the money.

One reason behind the difference between the interest that yields a Treasury bond and the interest that yields a Mortgage loan is the risk that the lender takes from lending money to an economic agent. In this particular case, a government is more likely to pay than a private citizen. Therefore, the interest rate charged to a private citizen is larger than the rate charged to the government.

To take into account the information asymmetry aforementioned, both the value of inflation and the real price of money is changed to their expected values resulting in the following equation:

i_t = r_{(t + 1)} + π_{(t + 1)} + σ

Where i_t is the nominal interest at the time of the loan, r_{(t + 1)} is the real interest expected over the period of the loan, π_{(t + 1)} is the inflation expected over the period of the loan and σ is the representative value for the risk engaged in the operation.

BIOGRAPHY

A biography (from the Greek words bíos (βίος) meaning "life", and gráphein (γράφειν) meaning "to write") is a description of someone's life, usually published in the form of a book or essay, or in some other form, such as a film. An autobiography (auto, meaning "self", giving self-biography) is a biography by the same person it is about. A biography is more than a list of impersonal facts (education, work, relationships and death), it also portrays the subject's experience of those events. Unlike a profile or curriculum vitae (resume), a biography presents the subject's story, highlighting various aspects of his or her life, including intimate details of experiences, and may include an analysis of the subject's personality.

A work is biographical if it covers all of a person's life. As such, biographical works are usually non-fiction, but fiction can also be used to portray a person's life. One in-depth form of biographical coverage is called legacy writing. Together, all biographical works form the genre known as biography, in literature, film, and other forms of media.

Biography portal

Early forms

The first known biographies were written by scribes commissioned by the various rulers of antiquity: ancient Assyria, ancient Babylonia, ancient Egypt, ancient Mesopotamia, among others. Such biographies tended to be chiseled into stone or clay tablets.

Classical forms

Ancient Greeks developed the biographical tradition which we have inherited, although until the 5th century AD, when the word 'biographia' first appears, in Damascius' Life of Isodorus, biographical pieces were called simply "lives" (βιοι: "bioi"). It is quite likely that the Greeks were drawing on a pre-existing eastern tradition; certainly Herodotus' Histories contains more detailed biographical information on Persian kings and subjects than on anyone else, implying he had a Persian source for it.

The earliest surviving pieces which we would identify as biographical are Isocrates' Life of Evagoras and Xenophon's Life of Agesilaos, both from the fifth century BC. Both identified themselves as encomia, or works of praise, and that biography was regarded as a discrete entity from historiography is evidenced by the fact that Xenophon treated King Agesilaos of Sparta twice in his works, once in the above-mentioned encomium and once in his Greek History; evidently the two genres were conceived as making different demands of authors who enrolled in them. Xenophon could present his Cyropaedia, an account of the childhood of the Persian King Cyrus the Great now regarded as so fabulous that it falls rather into a novelistic tradition than a biographical one, as a serious work, without any disclaimers or caveats.

Whereas Thucydides set the benchmark for a historiographical tradition comprising 'conclusions ... drawn from proofs quoted ... [which] may safely be relied upon' (Thuc. 1.21), and offering little explicit judgement on the people with whom he dealt, biographers were quite often more concerned with drawing a moral point from their investigations of their subjects. Parallel Lives by Plutarch, a Greek writing under the Roman empire, is a series of short biographies of eminent men, ancient and contemporary, arranged in pairs comprising one Greek, one Roman, in order that a broad educative point might be extraced from the comparison (for example Mark Antony and Demetrius were paradigms of tyranny, Lysander and Sulla examples of great men degenerating into blood-thirsty corruption).

However, although their moralising approach is not in fashion in the current intellectual climate, Greek biographies still have much to offer the modern reader, and for the most part it is reasonable to assume that while authors may have suppressed details which did not fall in with the general theme which they wished to convey, they are unlikely to have fabricated much. Not least, they were instrumental in developing the modern idea of the person. The traditional Greek attitude to individuals was to 'reduce them to types'; the Peripatetic tradition records various categories into which men might fall: the flatterer, the superstitious man and so on. Greek rhetorical handbooks give advice on 'ethopoia', that is creating a character, one of a recognised type, to win favour in the law courts.

The biographical tradition does draw on these types, but it also gives explicit recognition to the importance of individual idiosyncrasies in defining a man, and places the emphasis firmly on a man's personality rather than merely listing his accomplishments. As Plutarch says in the introduction to his Life of Alexander the Great, 'in the most illustrious deeds there is not always a manifestation of virtue and vice, but a slight thing like a phrase or a jest often makes a greater revelation than battles where thousands fall, or the greatest armaments, or sieges of cities'. Thus the individual is recognised as having some value and interest irrespective of the impact of his actions on the broader sweep of history.

Under the Roman Empire, the biographical and historiographical traditions converged somewhat, likely due to the nature of government, whereby the state was dominated by a single emperor with totalitarian power and whose character and actions set the tone for the period; Tacitus's History and his Annals, as well as Dio's History contain much of the same material as the biographer Suetonius's Lives of the Twelve Caesars. However, although Tacitus in particular was extremely critical of the regime, his disapproval emerges in subtle characterisation and arrangement of his material, in contrast with Suetonius' vicious authorial comment.

Middle Ages and Renaissance

The Early Middle Ages (AD 400 to 1450) saw a decline in awareness of classical culture. During this time, the only repositories of knowledge and records of early history in Europe was the Roman Catholic Church. Hermits, monks and priests used this historic period to write the first modern biographies. Their subjects were usually restricted to church fathers, martyrs, popes and saints. Their works were meant to be inspirational to people, vehicles for conversion to Christianity. See hagiography. One significant example of biography from this period which does not exactly fit into that mold is the life of Charlemagne as written by his courtier Einhard.

By the late Middle Ages, biographies became less church-oriented as biographies of kings, knights and tyrants began to appear. The most famous of these such biographies was 'Le Morte d'Arthur' by Sir Thomas Malory. The book was an account of the life of the fabled King Arthur and his Knights of the Round Table.

Following Malory, the new emphasis on humanism during the Renaissance promoted a focus on secular subjects such as artists and poets, and encouraged writing in the vernacular. Giorgio Vasari's Lives of the Artists (1550) was a landmark biography focusing on secular lives. Vasari created celebrities of his subjects, as the Lives became an early "best seller." Two other developments are noteworthy: the development of the printing press in the fifteenth century and the gradual increase in literacy.

Biographies in the English language began appearing during the reign of Henry VIII. John Foxe’s Acts and Monuments (1563), better known as Foxe's Book of Martyrs, essentially was the first dictionary of biography, followed by Thomas Fuller’s The History of the Worthies of England (1662), with a distinct focus on public life.

Modern biography

The "Golden Age" of English biography emerged in the late eighteenth century, the century in which the terms "biography" and "autobiography" entered the English lexicon. The classic works of the period were Samuel Johnson's Critic material and letting the subject "speak for itself." While Boswell compiled, Samuel Johnson composed. Johnson did not follow a chronological narration of the subject's life but used anecdotes and incidents selectively. Johnson rejected the notion that facts revealed truth. He suggested that biographers should seek their subject in "domestic privacies", to find little known facts or anecdotes which revealed character. (Casper, 1999)

The romantic biographers disputed many of Johnson's judgments. Jean Jacques Rousseau's Confessions (1781-88) exploited the romantic point of view and the confessional mode. The tradition of testimony and confession was brought to the New World by Puritan and Quaker memoirists and journal-keepers where the form continued to be influential. Benjamin Franklin's autobiography (1791) would provide the archetype for the American success story. (Stone, 1982) Autobiography would remain an influential form of biographical writing.

Generally American biography followed the English model, while incorporating Thomas Carlyle's view that biography was a part of history. Carlyle asserted that the lives of great human beings were essential to understanding society and its institutions. While the historical impulse would remain a strong element in early American biography, American writers carved out their own distinct approach. What emerged was a rather didactic form of biography which sought to shape individual character of the reader in the process of defining national character. (Casper, 1999)

The distinction between mass biography and literary biography which had formed by the middle of the nineteenth century reflected a breach between high culture and middle-class culture. This division would endure for the remainder of the century. Biography began to flower thanks to new publishing technologies and an expanding reading public. This revolution in publishing made books available to a larger audience of readers. Almost ten times as many American biographies appeared from 1840 to 1860 than had appeared in the first two decades of the century. In addition, affordable paperback editions of popular biographies were published for the first time. Also, American periodicals began publishing series of biographical sketches. (Casper, 1999) The topical emphasis shifted from republican heroes to self-made men and women.

Much of late 19th-century biography remained formulaic. Notably, few autobiographies had been written in the 19th century. The following century witnessed a renaissance of autobiography beginning with Booker T. Washington's, Up From Slavery (1901) and followed by Henry Adams' Education (1907), a chronicle of self-defined failure which ran counter to the predominant American success story. The publication of socially significant autobiographies by both men and women began to flourish. (Stone, 1982)

The authority of psychology and sociology was ascendant and would make its mark on the new century’s biographies. (Stone, 1982) The demise of the "great man" theory of history was indicative of the emerging mindset. Human behavior would be explained through Darwinian theories. "Sociological" biographies conceived of their subjects' actions as the result of the environment, and tended to downplay individuality. The development of psychoanalysis led to a more penetrating and comprehensive understanding of the biographical subject, and induced biographers to give more emphasis to childhood and adolescence. Clearly, psychological ideas were changing the way Americans read and wrote biographies, as a culture of autobiography developed in which the telling of one's own story became a form of therapy. (Casper, 1999)

The conventional concept of national heroes and narratives of success disappeared in the obsession with psychological explorations of personality. The new school of biography featured iconoclasts, scientific analysts, and fictional biographers. This wave included Lytton Strachey, André Maurois, and Emil Ludwig among others. Strachey's biographies had an influence similar to that which Samuel Johnson had enjoyed earlier. In the 1920s and '30s, biographical writers sought to capitalize on Strachey's popularity and imitate his style. Robert Graves (I, Claudius, 1934) stood out among those following Strachey's model of "debunking biographies." The trend in literary biography was accompanied in popular biography by a sort of "celebrity voyeurism." in the early decades of the century. This latter form's appeal to readers was based on curiosity more than morality or patriotism.

By World War I, cheap hard-cover reprints had become popular. The decades of the 1920s witnessed a biographical "boom." In 1929, nearly 700 biographies were published in the United States, and the first dictionary of American biography appeared. In the decade that followed, numerous biographies continued to be published despite the economic depression. They reached a growing audience through inexpensive formats and via public libraries.

According to the scholar Caroyln Heilbrun, women's biographies were revolutionized during the second wave of feminist activism in the 1970s. At this time women began to be portrayed more accurately, even if it downplayed the achievements or integrity of a man (Heilbrun 12).

FOREST

FOREST (an acronym for "Freedom Organisation for the Right to Enjoy Smoking Tobacco") is a United Kingdom political pressure group that campaigns for the right of people to smoke tobacco and opposes attempts to ban or reduce tobacco consumption. FOREST also disputes the health risks of smoking.

While FOREST describes itself as the "voice and friend of the smoker",^[1] the organization has been characterized as a front group, as it is organized and funded by the tobacco industry and has generated little grassroots interest.^[2] According to internal memos, the tobacco industry designed FOREST to be controlled "through a third party, so that there would be no direct contact between tobacco company personnel or TAC and the director."^[2]

History

FOREST was officially founded in 1979 by former Air Chief Marshal Sir Christopher Foxley-Norris.

In 1987 Lord Harris of High Cross, general director of the Institute of Economic Affairs (1957-1989), was appointed chairman, a position he held until his death in October 2006. A long-term pipesmoker and an outspoken critic of public smoking bans, Harris wrote numerous articles and essays on the subject of passive smoking.^[3]

FOREST spokesmen appear regularly on television and radio in the United Kingdom and are frequently quoted by British newspapers as representatives of a pro-tobacco viewpoint.^[4][5][6] Despite this media visibility, FOREST's internal communications to the tobacco industry argued that its real successes "cannot be publicised":

Measuring FOREST purely in terms of media coverage denies the existence of other work in which it is engaged but which cannot be publicised. In short, if others can be persuaded to "sing the same tune" this is of more value than anything that might be said by the tobacco industry itself, or FOREST.^[7]

Funding and membership

FOREST has been described as an astroturf group created and primarily funded by the tobacco industry.^[8] Its establishent was planned by the Tobacco Advisory Committee, the British tobacco industry trade association. At a 1979 meeting, the Tobacco Advisory Committee discussed the launch of FOREST as well as ways to maintain its appearance of independence.^[9]

After its founding, grassroots interest in FOREST was meager and failed to make the organization self-financing, despite aggressive membership campaigns.^[2] In one instance, 10,000 cigarette retailers were solicited to join FOREST, but only 4 joined.^[10] Thus, financial support from the tobacco industry remained the major source of funding for FOREST, while funding from outside the industry was minimal.^[2]

Notwithstanding efforts to create the appearance of independence, the Tobacco Advisory Council controlled leadership at FOREST. Internal industry memos stipulated: "If money invested [in FOREST] is to be properly effective then control and management are essential." Contact between the Executive Director of FOREST and the Tobacco Advisory Council was envisaged "on an almost daily basis."^[11]

Recent developments

In recent years FOREST has attracted the support of several high profile smokers including artist David Hockney, inventor Trevor Baylis, musician Joe Jackson, restaurateur and TV chef Antony Worrall Thompson, and Claire Fox, director of the Institute of Ideas. In September 2005 Hockney, Jackson and Fox all spoke at a fringe meeting organised by FOREST at the Labour Party conference in Brighton.

In February 2006, FOREST lost its fight against a total ban on smoking in enclosed public places in England from Summer 2007. This includes all pubs, bars, cafés and restaurants, as well as workplaces and private members clubs. Similar bans have come into force in Northern Ireland (Spring 2007) and Wales (April 2007). Scotland introduced its own public smoking ban in March 2006. Despite this, FOREST says it will continue to fight for freedom of choice. Current slogans include "Smokers are voters, too", "Enough is enough" and "Nanny state? No thanks".

GREENHOUSE

A greenhouse is a structure with a glass or plastic roof and frequently glass or plastic walls; it heats up because incoming solar radiation from the sun warms plants, soil, and other things inside the building. Air warmed by the heat from hot interior surfaces is retained in the building by the roof and wall. These structures range in size from small sheds to very large buildings.

Greenhouses can be divided into glass greenhouses and plastic greenhouses. Plastics mostly used are PEfilm and multiwall sheet in PC or PMMA. Commercial glass greenhouses are often high tech production facilities for vegetables or flowers. The glass greenhouses are filled with equipment like screening installations, heating, cooling, lighting and may be automatically controlled by a computer.

The glass used for a greenhouse works as a selective transmission medium for different spectral frequencies, and its effect is to trap energy within the greenhouse, which heats both the plants and the ground inside it. This warms the air near the ground, and this air is prevented from rising and flowing away. This can be demonstrated by opening a small window near the roof of a greenhouse: the temperature drops considerably. This principle is the basis of the autovent automatic cooling system. Greenhouses thus work by trapping electromagnetic radiation and preventing convection. A miniature greenhouse is known as a cold frame.

Uses

Greenhouses are often used for growing flowers, vegetables, fruits, and tobacco plants. Bumblebees are the pollinators of choice for most greenhouse pollination, although other types of bees have been used, as well as artificial pollination. This helps the plants to produce more offspring for future plantations.

Besides tobacco, many vegetables and flowers are grown in greenhouses in late winter and early spring, and then transplanted outside as the weather warms. Started plants are usually available for gardeners in farmers' markets at transplanting time.

The closed environment of a greenhouse has its own unique requirements, compared with outdoor production. Pests and diseases, and extremes of heat and humidity, have to be controlled, and irrigation is necessary to provide water. Significant inputs of heat and light may be required, particularly with winter production of warm-weather vegetables. Special greenhouse varieties of certain crops, like tomatoes, are generally used for commercial production.

Greenhouses are increasingly important in the food supply of high latitude countries. One of the largest greenhouse complexes in the world is in Almeria, Spain where Greenhouses cover almost 50,000 acres (200 km²) and where almost 5% of Spain's salad vegetables are grown.[1]

Greenhouses protect crops from too much heat or cold, shield plants from dust storms and blizzards, and help to keep out pests. Light and temperature control allows greenhouses to turn inarable land into arable land. Greenhouses can feed starving nations where crops can't survive in the harsh deserts and Arctic wastes. Hydroponics can be used in greenhouses as well to make the most use of the interior space.

Biologist John Todd invented a greenhouse that turns sewage into water, through the natural processes of bacteria, plants, and animals.

History

Cucumbers reached to the ceiling in a greenhouse in Richfield, Minnesota, where market gardeners grew a wide variety of produce for sale in Minneapolis. ca. 1910

19th Century Orangerie in Weilburg, Germany

The idea of growing plants in environmentally controlled areas has existed since Roman times. The Roman emperor Tiberius ate a cucumber-like^[2] vegetable daily. The Roman gardeners used artificial methods (similar to the greenhouse system) of growing to have it available for his table every day of the year. Cucumbers were planted in wheeled carts which were put in the sun daily, then taken inside to keep them warm at night.^[3] The cucumbers were stored under frames or in cucumber houses glazed with either oiled cloth known as "specularia" or with sheets of mica, according to the description by Pliny the Elder.^[4]

The first modern greenhouses were built in Italy in the thirteenth century^[5] to house the exotic plants that explorers brought back from the tropics. They were originally called giardini botanici (botanical gardens). The concept of greenhouses soon spread to the Netherlands and then England, along with the plants. Some of these early attempts required enormous amounts of work to close up at night or to winterize. There were serious problems with providing adequate and balanced heat in these early greenhouses.

Jules Charles, a French botanist, is often credited^[who?] with building the first practical modern greenhouse in Leiden, Holland to grow medicinal tropical plants.^{[citation needed]}

Originally on the estates of the rich, with the growth of the science of botany greenhouses spread to the universities. The French called their first greenhouses orangeries, since they were used to protect orange trees from freezing. As pineapples became popular pineries, or pineapple pits, were built. Experimentation with the design of greenhouses continued during the Seventeenth Century in Europe as technology produced better glass and construction techniques improved. The greenhouse at the Palace of Versailles was an example of their size and elaborateness; it was more than 500 feet long, 42 feet wide, and 45 feet high.

In the nineteenth Century the largest greenhouses were built. The conservatory at Kew Gardens in England is a prime example of the Victorian greenhouse. Although intended for both horticultural and non-horticultural exhibition these included London's Crystal Palace, the New York Crystal Palace and Munich’s Glaspalast. Joseph Paxton, who had experimented with glass and iron in the creation of large greenhouses as the head gardener at Chatsworth, in Derbyshire, working for the Duke of Devonshire, designed and built the first, London's Crystal Palace. A major architectural achievement in monumental greenhouse building were the Royal Greenhouses of Laeken (1874-1895) for King Leopold II of Belgium.

In Japan, the first greenhouse was built in 1880 by Samuel Cocking, a British merchant who exported herbs.

In the Twentieth Century the geodesic dome was added to the many types of greenhouses.

Shadehouse

A shadehouse serves the opposite purpose of a greenhouse; it is used to protect cultivated plants from excessive heat, light or dryness.

Gallery

Victorian conservatory, Kew Gardens

A modern glasshouse in RHS Wisley

A greenhouse in Saint Paul, Minnesota.

Greenhouses lighted at night near Amsterdam (seen from an airplane)