IN THE MORNING - Nicole Reynolds - index-art.info
well, i can describe so many wrong thing and bad days in my life, but i think the . song traducida When We Meet Again by Nicole Reynolds. family and friends and travel a little bit, but I, once again, had the opportunity to see our students in some Riner and Kelly Carlie, and CSE Chair Nicole Kohlstaedt for their tireless . and meet their teacher!! Alexander Reynolds .. Para solicitar por comidas gratuitas o precios reducidos para sus niños. Los Amparito – por medio de la lectura (taken from the Nicole Reynolds – when we meet again (taken from their release Con Law) 2.
In Reynolds, the Court recognized that a relationship and cohabitation equates with influence, so that if one proves intent and a means of carrying out that intent, causation can be presumed. Following Reynolds, the lower courts have also recognized the importance of the relationship between the defendant and the declarant in assessing forfeiture.
We will see how child sexual abuse perpetrators use positive inducements to take advantage of their victims and deter them from disclosing abuse.
Third, the actions that give rise to forfeiture may occur before the charged crime. It is not necessary that the crime be completed or charges filed. The lower courts have not gone as far, but they have recognized that the actions giving rise to forfeiture need not occur post-arrest or post-indictment. Fourth, forfeiture can apply even if the declarant had other reasons to avoid testifying.
Fifth, forfeiture can apply even if the defendant had other reasons to commit the wrongdoing. Our argument for forfeiture will not be that perpetrators abuse children in order to silence them.
Rather, we will show that the way in which they abuse children is designed to maintain their cooperation and silence. Finally, forfeiture is not limited to cases in which the hearsay statements were themselves under oath and subject to cross-examination. Historical analysis and Reynolds suggested that this was so, but none of the Justices in Giles expressed this view.
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The prototypical hearsay statements in child sexual abuse cases are structured, videotaped interviews. The child may have been given a child-friendly version of an oath, but cross-examination is obviously lacking. Reynolds and Giles are complementary. One might read Reynolds to suggest that direct evidence of intent must be provided, but, given Giles, it is more consistent to assume that the Court in Reynolds believed that the strong facts of intent before it were sufficient rather than necessary.
Giles illustrates how the dynamics of the charged acts can inform an analysis of what the defendant intended, even when direct evidence is lacking. Similarly, one might read Giles to suggest that clear evidence of causation must be provided murdering a declarant clearly renders her unavailable ; but, given Reynolds, it is more consistent to assume that Giles found the evidence of causation sufficient rather than necessary.
Reynolds presumed causation merely based on cohabitation. Read together, the opinions suggest a flexible approach for considering whether a defendant forfeited his right to cross-examine an unavailable declarant. Flexibility with respect to applying forfeiture is justifiable for two reasons. If the defendant keeps the declarant off the stand altogether, then she cannot explain her absence. If the defendant successfully threatens the victim, she will be deterred from explaining to the court the reasons for her uncooperativeness.
Second, it is important to reiterate that forfeiture is an equitable principle: From the perspective of fairness, intent is more important than causation. If the defendant desired that the declarant fail to testify and took actions to fulfill that desire, then the defendant should not be heard to complain if the declarant does not testify.
A focus on intent admittedly conflicts with the forfeiture-by-wrongdoing hearsay exception in the Federal Rules of Evidence, which requires both intent and causation. Proof of intent should presumptively satisfy a constitutional forfeiture claim, but need not suffice as an exception to the hearsay rule.
Perpetrators choose vulnerable victims, escalate the abuse over time, and cajole and threaten children into continued silence. One can either take advantage of preexisting vulnerabilities or create them.
Practically, defendants will usually take actions to guarantee that vulnerable victims remain so.
When they take those steps, they have clearly both taken advantage of and caused unavailability. The statutes currently require that, in order to admit this hearsay, courts find indicia of reliability and, when the child is unavailable, corroborative evidence of abuse. Parents and adult household members enjoy authority and private access, as do professionals who care for and interact with children.
In extrafamilial abuse, it is important to consider the extent and kinds of interaction between the child and the perpetrator. The Dynamics of Child Abuse Understanding the dynamics of child sexual abuse is helpful in applying the principles of forfeiture by wrongdoing to child witnesses. The dynamics of abuse speak to both intent and causation.
LIKE THE OCEAN - Nicole Reynolds - index-art.info
Although the focus here is on sexual abuse, many of the factors discussed here also keep child witnesses to other crimes off the stand. He might threaten the child not to tell, but such a threat may carry little weight because the child has no desire to protect the perpetrator. The perpetrator is unlikely to have continuing contact with the child, and by virtue of the violent abduction, the child does not feel complicit in the crime.
The child may fail to disclose the abuse because of her immaturity or her inherent sense that she was somehow to blame, but from an intent perspective, the stranger perpetrator has acted more out of impulse than cunning.
In contrast, in the typical case of child abuse, the perpetrator is a parent, a parent figure, or a familiar and authoritative adult. The perpetrator selects his victim on the basis of immaturity, vulnerability, and private access. Once abuse has begun, the perpetrator maintains secrecy through admonishments and occasional threats. Most child molestation typically includes attempts to obtain the assent and cooperation of victims.
The first step for the sex perpetrator is to befriend the child, typically before any kind of physical contact is attempted. Alienation from siblings occurs because of the privileges and special favors potential victims receive. In part because of careful victim selection and preparation, this need not involve violent force. When perpetrators do endorse strategies for inducing compliance, they mention a mixture of bribes and threats, and the strategies are similar for both intrafamilial and extrafamilial perpetrators.
Nevertheless, in criminal samples, abuse without the use of force also predominates. Indeed, perpetrators typically admit having had a number of victims whose abuse was never brought to the attention of the authorities. Clinical samples confirm that delays are common. If the child fails to report the abuse when it first occurs, it is likely to occur again.
The most common factor that predicts delay in reporting abuse is the relationship between the perpetrator and the child: This is true in population surveys, clinical samples, and criminal samples. Hence, the child looks up to the perpetrator and holds him in high esteem. The child also has reason to doubt that others will believe his report because they will have difficulty believing the perpetrator is a child molester.
The gradual introduction of sexual acts will increase the likelihood that the child feels complicit in the abuse and will thus feel guilt, shame, and embarrassment, further deterring disclosure. If the child fails to resist, she is more likely to believe that she consented.
If she delays in reporting, she is more likely to believe that subsequent acts of abuse were consensual, or at least that her failure to disclose is responsible for their reoccurrence.
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In order of frequency, their responses were: A successful perpetrator does not need to make any overt threats because the child will be sufficiently motivated to keep the abuse a secret.
Perhaps more than any other factor, this distinguishes nondisclosure in sexual abuse cases from the classic forfeiture situation, in which the perpetrator threatens the victim in order to enforce secrecy. The percentage of perpetrators who report specifically warning the child not to tell varies widely across the studies.
Perpetrators often refer to serious consequences from disclosure. Sixty-one percent of the perpetrators in Smallbone and Wortley told children that the perpetrators would go to jail or get in trouble. Kaufman and colleagues reported that perpetrators most often endorsed strategies that involved giving or withdrawing benefits for nondisclosure, such as giving children special rewards or privileges, and telling children that the perpetrator or caretaker s would no longer love them if they disclosed.
Smith and colleagues found that: In her large clinical sample, Hershkowitz found that threats increased the likelihood that disclosure was delayed. Gray did not find a relation between threats and nondisclosure, although she failed to look at delays, which is a more sensitive measure.
Second, as noted above, threats are only one of many means by which perpetrators silence children, and it is likely that perpetrators use threats less often when other forces are effective in maintaining secrecy. It is notable that the subtler methods of exploiting and inducing compliance are more consistently found to deter or delay disclosure. Perpetrators who do not have to threaten their victims are most likely to enjoy continued secrecy.
His purpose is to molest without the danger that the child will disclose the abuse. This both ensures continued access to the child and avoids discovery of the abuse. The perpetrator reasonably anticipates that the means by which he accomplishes abuse ensures that the child will not speak out against him.
We will address each of these concerns in turn. False allegations Studies in which victims are asked about their experiences are subject to the concern that some of the allegations are false.
However, the child may be lying, may have been coached, or may have formed false beliefs due to adult suggestion. The induction of a state of depression in animal models is accomplished by protocols applying acute physical stressors such as restraint, food or water restriction, continuous light exposure, physical or chemical lesions or genetic knockout 14 — 16 or social stressor paradigms such as social defeat 17 and early social separation 18whereas in humans, chronic psychosocial stress is typically the agent of onset of this disease In addition, the protocols used in rodents to investigate depressive state sometimes do not have etiological validity, i.
Therefore, the etiologic criteria are not addressed in various studies, and this is a cause for concern, because the face aspects observed are not likely an evolutionary trace. Moreover, investigations with molecular biomarkers such as hormones, neurotransmitters, or cytokines associated with behaviors are scarce in animal models of depression 22 ; therefore, the content criteria are also not addressed in most studies 1522 — More recently, to improve studies conducted in animal models, other criteria have been considered to validate translational models in psychiatry: Inter-relational criteria propose to investigate a model in various and interacting disordered domains such as behaviors, molecular biomarkers, and cognition Evolutionary criteria reflect the ability of the proposed model to investigate determinate disordered domains in a similar manner across various species.
In depression disorders, feeding, somnolence, motor alteration, and anhedonic behaviors, as well as cortisol levels and body weight, are altered in humans, non-human primates, rodents, and other species and can be used to investigate evolutionary criteria.
Therefore, these indicate conserved phenomena in this pathology along with evolution with great importance placed on its understanding, mainly because it can be associated with subjective states that cannot be measured directly in animals 1225 The population validity criterion is the capacity of the proposed model to reflect the natural variance in phenotypes observed in the general population.
The use of inbred or knockout strains to reduce random noise in studies also reduces the variability and does not reflect the heterogeneity of the human population. In this context, it is better to use outbred or wild-type populations The brain morphology, neural functional organization, social organization, and evolutionary history of non-human primates are more closely related to those of humans than are those of other species commonly used as animal models of depression, such as rodents and fish 27 Consequently, the use of non-human primates as animal models in studies of depression addresses both traditional and newly proposed validation criteria.
Moreover, it was recently observed that macaques exhibit naturally occurring depression attributed to chronic psychosocial stress, similar to that observed in humans. Consequently, in non-human primates, depending on their social organization, the stress protocols involving changes in social rank or chronic social isolation can induce similar physiological and behavioral symptoms to those observed in depressive disorders in humans 1128 — The majority of studies of mood disorders are developed in adult or infant animals and only a small proportion are conducted in juveniles.
It is well known that juvenile age is an important ontogenetic phase because it is a biological window of plasticity of the nervous system, showing considerable susceptibility to environmental influences that might induce permanent changes in cognition and in the stress response system.
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If these changes are maladaptive, they can induce serious and permanent damage in cognitive, behavioral, and physiological parameters in adulthood, increasing the probability of the emergence of mood disorders such as depression 31 — In this context, the present study investigated the effects of chronic social isolation and the potential antidepressant effect of nortriptyline on physiological parameters fecal cortisol and body weightas well as on the behavioral repertoire, in juvenile male and female common marmosets Callithrix jacchus to characterize biomarkers that respond to an etiological protocol for the study of depression in non-human primates.
Thus, our intention is to validate this animal model and protocol with respect to distinct criteria including etiologic, face, functional, predictive, inter-relational, evolutionary, and population, in order to provide evidence for the utility of this species as a translational juvenile animal model of depression. The common marmoset, C. This species exhibits a range of changes at the physiological and behavioral levels that resemble those observed in humans when facing stress 1138 — Materials and Methods Study Design This study includes two experimental procedures to validate the use of the common marmoset as an animal model of juvenile depression.
The first protocol was performed to validate chronic social isolation as a protocol for induction of depression state IDS and to provide evidence validating the etiologic, face, and functional criteria of this depression animal model.