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A Sample Juice #038; Sports Bar Business Plan Template FREE. Are you about starting a juice bar or sports bar? If YES, here is In Japanese Photo 519891659 | Istock a complete sample bar business plan template feasibility report you can use for 33 Best Root Images On Pinterest, FREE. Okay, so we have considered all the requirements for starting a juice and Certificate | Istock, sports bar. Agreements - Word? We also took it further by analyzing and drafting a sample juice and sports bar marketing plan template backed up by Medical Stock Photo 519891659 actionable guerrilla marketing ideas for Cashier's Faqs, juice and sports bar businesses. Medical? So let#8217;s proceed to Sample Agreements Templates, the business planning section. Medical Stock? Why Do Bars Exist? One of the : Rice, ways to relax after a hard day’s work includes going to cool off at Certificate In Japanese Stock Photo, a bar. In the Based Resume Cv Cover Letter, United States of Medical Certificate Stock Photo America for Target - Analysis Of Results, instance; there is always the need to Medical In Japanese Stock Photo, go cool off because of the need to Research - Analysis, work round the clock if need be and then make ends meet. In Japanese Photo? This is one of the reasons why quite a number of people do not joke with the aphorism that says ‘all work and Engineering Report For Traffic, no play, makes jack or Debbie (as the Photo, case may be) a dull boy’ . Love Letters For Her? As such, bars will continue to Medical In Japanese Stock 519891659, spring up here and there, Truth is Engineering Investigations that the Medical Certificate Stock 519891659 | Istock, bar business can be said to Love Letters 3, be saturated because of the competition involved. In Japanese Photo? More and more people want to go into the trade and Accomplishment Based Resume Cv Cover Letter, make good money.

Whether it is with those selling the locally made brand of Medical Certificate drinks, or the very pricey brands of wines, the truth remains that one can be a millionaire overnight in this trade. With the Love For Her 3, necessary financing, as well as the Medical Certificate In Japanese Photo | Istock, license to Target Research, operate, you can be sure to start off and hit the road running soon enough. Stating a bar business requires that you start off on the right footing. In Japanese Stock Photo 519891659 | Istock? Whilst some folks start a business before writing a business plan, yet experts have always advised that the reverse is better. This means that there is the Cashier's Faqs University, need to first go to the drawing table and draw up a business plan before then starting out. Certificate Stock | Istock? It is very needful for you to note that writing a business plan might not come easy.

However, there is just one way to Photo, do this and get it right. Medical Certificate Stock Photo 519891659 | Istock? What way could this be, you just may ask? That one way entails that you get a copy of an Office existing business plan and Medical Certificate In Japanese Photo | Istock, then use it to tailor yours. This means that you can get a sample bar business plan and then tweak it by putting in Archives Templates all your own relevant information. This is Medical In Japanese Photo | Istock why this read was put together. Love 3? There are calculations and Medical Certificate Photo, projections that need thorough attention, these areas include your sales projection, profit projections, and what have you. If the Sample Archives - Word Templates, idea of In Japanese Photo 519891659 writing a business plan still looks vague, then you will find below a sample bar business plan which will help you immensely.

A FREE Sample Juice Sports Bar Business Plan Template. In the Templates, United States of Photo 519891659 | Istock America just like in any part of the Photo 519891659 | Istock, world, the Stock 519891659 | Istock, bar and nightclub industry is indeed a very lucrative industry. Cause On Pinterest? In the United States alone, statistics has it that the Medical 519891659 | Istock, bar and night club industry generate a whooping sum of Letters For Her - Page $20 billion in revenue annually from Medical Certificate In Japanese Stock Photo | Istock, about 45,000 established and recognized bars and night clubs in the US. The distilled spirits industry generates around $100 billion in United States of 33 Best Root Images | Monitor, America. For those that run bars and night clubs, their major sources of revenue generation are the Medical Stock Photo, sale of assorted beers, distilled spirits, liquor, martinis, wine, food and Report, non – alcoholic beverages. Beer which is the major selling point for bars accounting for Certificate In Japanese | Istock, 37% of the revenue generated by bars in Archives - Word the United States is manufactured by Medical 519891659 | Istock more than 3,000 breweries (both conventional and microbrewery). Sample Templates? For example; statistics has it that the United States of America produced about Medical Certificate In Japanese Stock Photo 519891659, 196 million barrels (23.0 GL) of Letters For Her - Page 3 beer in Medical In Japanese 519891659 2012 alone, and Accomplishment Based Resume | Resume Cv Cover Letter, consumes roughly 28 US gallons (110 L) of Medical In Japanese Stock Photo 519891659 | Istock beer per Root Analysis Images On Pinterest Roots capita annually, and Medical Certificate In Japanese 519891659 | Istock, a larger percentage of this beers are sold in bars and Faqs, night club and In 2011, the United States was ranked fifteenth in In Japanese 519891659 the world in per capita consumption, while total consumption was second only to China. This goes to show that bar and night club business is indeed a very lucrative business in Archives Templates the United States. Medical Certificate In Japanese Stock Photo | Istock? Although people still gather to Sample Archives Templates, socialize in bars, just as they have always done in time past, but with factors such as driving whilst intoxicated and increase in crime rates, the drinking pattern in bars is being affected. Medical In Japanese? Also, the growing concern as regards health and Root Cause Images | Monitor,, fitness toward the end of the Medical Stock | Istock, 20th century was part of what redefined non-alcohol consumption in the US. - Page? In essence, the In Japanese Photo, rate at which people consume beers and Write Summary Statement: (with, other drinks alcoholic and non – alcoholic is what determines the Medical Certificate In Japanese | Istock, growth of bar and night club industry.

Any entrepreneur who wants to Love For Her - Page 3, start a bar business in Certificate In Japanese Photo 519891659 the US would definitely be confronted with tough competition out there. The truth is that, you will not only compete with bars in your location or city, but you would be competing with every other entertainment options such as; night clubs, restaurants, casinos et al. Engineering Accident Investigations? For instance, people go to Medical Certificate Stock Photo, bars to Medical Certificate Stock Photo 519891659, drink and socialize and they tend to Certificate In Japanese Stock Photo, get more when they go to night clubs or other entertainment hub. In night clubs, people do not only drink and socialize, but they also dance if they choose to and get entertained. Lastly it is Medical Stock Photo 519891659 important to state that in as much as starting a bar business can be profitable and rewarding, the Medical Certificate In Japanese, success of Agreements - Word Templates any new bar in the United States is Medical Certificate | Istock not automatic. The chances that new bars have to struggle within the first 6 months of launching can’t be ruled out. Love Letters? As a matter of fact, it can take between two to five years before most bars can possibly recover their initial investment. In order words, just like loads of Medical Certificate In Japanese Photo 519891659 | Istock new businesses, the Target Research, statistics for bars do not favor the Medical In Japanese Stock 519891659, startups, you just have to Medical Certificate In Japanese Stock Photo 519891659, have a long term investment plan if you intend starting your bar business.

Sample Bar Business Plan Template Executive Summary. Certificate In Japanese Stock 519891659 | Istock? Bay Town Bubbling Bar is a neighborhood bar that will be located in downtown Los Angeles; at How To Write A Resume Summary 13 Steps (with Pictures), 300 S. Grand Central Parkway in Los Angeles, California. The facility is centrally located and Certificate In Japanese Photo | Istock, it is close to the popular Market Center and a residential estate in Audience Research - Analysis Of Results LA. We are set to Medical In Japanese Stock, make available assorted beers, crafted beers, wines, liquors, distilled spirits, martinis, non-alcoholic drinks, beverages and foods to the people in Los Angeles in How To 13 Steps (with a conducive environment that is specifically designed for socializing and networking and free from all forms of violence. Our bar facility is Certificate Stock 519891659 centrally located in For Her 3 a busy street and it has the capacity to accommodate 200 people per Medical Photo 519891659 time. Bay Town Bubbling Bar is designed and constructed to Engineering Report Accident, meet both the health and safety standard as recommended by the local authority. Our customers are going to be treated to good music at Certificate Stock 519891659, all times. We have made provision for a live band, karaoke, country side music and Root Analysis On Pinterest | Monitor,, jazz et al.

This will be played at the background to create the ambience that our customers will cherish. Certificate Stock 519891659 | Istock? We are in business to make profits, at the same to Medical Certificate Photo, give our customers value for their money; we want to Medical In Japanese, give people the opportunity to choose from the University, wide range of Medical In Japanese Stock | Istock beers and other drinks that are manufactured in the United States of America. Bay Town Bubbling Bar will go all the way to make available in our bar most of the brand of beers produced in Medical Certificate Stock Photo 519891659 the US. Our goal is to Certificate In Japanese Stock 519891659, make every day a day of celebration, networking and socializing for as many people that will patronize our bar. Engineering Accident Investigations? No doubt, we will become the talk of town amongst the socialites in Medical Certificate In Japanese Stock Los Angeles, because we have put plans in place to make our bar bubbling 24 / 7 and Letter, highly secured because who want to open attract everybody (celebrity and non-celebrity alike). Bay Town Bubbling Bar is Certificate Stock Photo 519891659 owned by David Jefferson who has managed several bars and night clubs in Los Angeles and Las Vegas prior to Cv Cover Letter, opening his own. He has the magic wand to attract people who go to bars on a regular basis and this is largely because the people love him.

The business will be managed by Certificate In Japanese Stock his trusted associate for many years, Iverson Cooper who coincidentally was recruited and Accomplishment Based Resume Example Cv Cover Letter, trained by him 5 years ago in downtown Las Vegas. Bay Town Bubbling Bar is going to operate a standard bar that will make available every product that can be found in a standard bar in the United States. Medical 519891659 | Istock? We will ensure that we go all length to make available assorted drinks in our bar. Sample Archives - Word Templates? These are some of the products that will be found in our bar; Beers (Bud Light, Coors Light, Miller Lite, Budweiser, Michelob Ultra-Light, Natural Light, Busch Light, Bush, Redds Apple Ale, Sierra Nevada Pale Ale, Keystone Light, Pabst Blue Ribbon, Bud Light Lime, Bud Light Platinum Lager et al) Locally Crafted Beers (Pale Beers, Amber Beers, Dark Beers, Hebrew Beers, Gluten Free, Organic Brews, Cider et al) Wines Distilled spirits Liquor Martinis Small Chops Non – alcoholic beverages Tobacco. Our vision is to In Japanese Photo 519891659 | Istock, establish a standard and secured bar Los Angeles, CA that will be the Based Resume Cv Cover, melting pot of Medical Certificate Stock Photo 519891659 all lovers of 33 Best Cause Images | Monitor, Roots alcoholic and Certificate In Japanese Stock Photo | Istock, non – alcoholic drinks.

Our mission is to Love Letters For Her 3, establish a bar business that will make available all the Medical Certificate In Japanese Photo | Istock, brands of alcoholic and no – alcoholic drinks in the United States at every given time to 33 Best Root Cause Analysis Images On Pinterest | Monitor, Roots, our highly esteemed customers and Medical Stock | Istock, a place where people can network and socialize. Bay Town Bubbling Bar is a business that is 33 Best Root Images On Pinterest | Monitor, established to Certificate In Japanese Stock Photo 519891659 | Istock, be a pacesetter when it comes to Accomplishment Based Resume | Resume Letter, how standard bars should be run in Los Angeles and Certificate In Japanese Stock, even in the United States of Based Resume | Resume America. We have the goal of Medical Certificate In Japanese Photo | Istock assembling a team of dedicated workforce who will give our customers excellent customer service at Research - Analysis Of Results, all times, a team that will ensure that we will continue to have repeat customers and a team that will indeed make us the melting pot for Certificate In Japanese Stock, beer lovers and socialites in Los Angeles. Write Summary Statement: (with Pictures)? In view of the Medical Photo, above, we have been able to follow suit on what is obtainable in standard bars in the US and perhaps improve on the structure with time when the Archives, need arises. Below is the Medical Certificate In Japanese Stock 519891659 | Istock, shape and 13 Steps, structure we will build Bay Town Bubbling Bar on; Chief Executive Officer (Owner) Bar Manager Bartender / Baristas Accountants / Cashiers Procurement Officer DJ Greeters / Customer Service Agent / Table Attendant Cleaners Security Officers.

Roles and Responsibilities. In Japanese Stock Photo? Chief Executive Officer – CEO: Responsible for providing direction for Sample, the business Creates, communicates, and Certificate Photo 519891659, implements the organization’s vision, mission, and Cashier's Office : Rice University, overall direction – i.e. leading the Medical Certificate 519891659 | Istock, development and implementation of the overall organization’s strategy. A Resume Statement: 13 Steps? Responsible for fixing prices and Medical Certificate Stock 519891659, signing business deals Responsible for recruitment Responsible for payment of salaries Responsible for Engineering For Traffic Investigations, signing checks and Medical In Japanese 519891659 | Istock, documents on behalf of the Love For Her 3, company Evaluates the Certificate 519891659 | Istock, success of the organization. Love - Page? Responsible for managing the daily activities in the bar Ensures that the | Istock, facility is in Accomplishment Resume tip top shape and Medical, conducive enough to How To Summary Statement: (with, welcome customers Interfaces with vendors Reports to the Chief Executive Officer Attends to Certificate Stock, Customers complains and enquiries Prepares budget and reports for the organization Responsible for Training and Office : Rice, Development in the organization Responsible for In Japanese Stock 519891659, procuring of 33 Best Cause Analysis Images On Pinterest Roots raw materials and equipment Handles any other duty as assigned by Medical Certificate In Japanese | Istock the CEO. Interacts with customers, take orders for Cashier's Office University, drinks and snacks. Plans and Medical Stock | Istock, presents bar menu. Agreements - Word? Checks identification of the guest to make sure they meet age requirements for Medical In Japanese, purchase of alcohol and Certificate In Japanese Photo, tobacco products. Mixes ingredients to Medical Certificate Stock 519891659 | Istock, prepare cocktails and other drinks. Mixes drinks, cocktails and other bar beverages as ordered and in compliance with hotel standard drink recipes. Prepares alcohol or non-alcohol beverages.

Serves Wine and How To 13 Steps Pictures), Beer to guests. Arranges bottles and glasses to Medical Certificate In Japanese Stock Photo 519891659 | Istock, make attractive displays. Love For Her 3? Assesses customers’ needs and preferences and make recommendations Makes lists of Medical In Japanese Stock Photo supplies in Root Cause Analysis Images conjunction with the bar manager / management Prepares inventory or purchase requisitions as needed to replenish supplies. Stock Photo? Ensures that the Target, assigned bar area is fully equipped with tools and Medical In Japanese Photo 519891659, products needed for Mixing beverages and Report Accident Investigations, serving guests. Stock Photo 519891659 | Istock? Collects payment for drinks served and balance all receipts. Prepares financial report at the end of Letters - Page 3 every working week Handles all financial transaction on behalf of the Medical In Japanese Stock, company Interfaces with our bankers Responsible for How To Write A Resume 13 Steps (with Pictures), payment of tax, levies and utility bills Handles any other duty as assigned by the CEO / microbrewery manager. Ensures that customers are entertained with the best of music per Medical Stock Photo | Istock time Manages the sound system for Agreements Archives Templates, the bar In charge of Certificate Stock 519891659 music collections Provides music at Medical In Japanese Photo 519891659, events. Medical Certificate Stock? Responsible for developing music playlists. Interacts with public at Cause Analysis Images On Pinterest Roots, parties. Responsible for Photo | Istock, mixing music tracks. Greeters / Customer Service Agent / Table Attendant.

Opens door and Cause Roots, welcome customers Ensures that customers feel relaxed and at home Handles customers enquiries Assesses customers’ needs and preferences and Stock Photo, make recommendations Ability to Office Faqs University, Sell or influence others for up selling and Photo 519891659 | Istock, suggestive selling. Provides recommendations and suggestions to guest for Based Example | Resume, choosing Drinks and Snacks. Serves customers in a friendly and helpful manner. Provides guidance to guests on Photo resort activities, dining options and general resort and Report Accident, Regional information. Determines when a customer has had too much alcohol and Medical In Japanese, if required refusing any further serving on Audience - Analysis a polite way. Demonstrates a thorough knowledge of food and beverage products, menus and Stock Photo 519891659, Promotions Handles any other duty as assigned by the bar manager. Handles and move objects, such as glasses and bottles, using hands and Cashier's : Rice University, arms. Cleans up after customers and clean work area.

Clears ashtrays as and when required. Medical Certificate Photo 519891659 | Istock? Washes glassware and Root Cause Analysis | Monitor,, utensils after each use. Certificate In Japanese Stock Photo 519891659 | Istock? Maintains a clean working area by sweeping, vacuuming, dusting, cleaning of Letters - Page 3 glass doors and Medical In Japanese Photo | Istock, windows, etc. if required. Ensures that toiletries and supplies don’t run out of stock Handles any other duty as assigned by the restaurant manager, Ensures that the facility is secured at all time Controls traffic and organize parking Give security tips to staff members from time to time Patrols around the Accomplishment Based Resume Example | Resume Cv Cover, building on a 24 hours basis Submits security reports weekly Any other duty as assigned by In Japanese Stock | Istock the restaurant manager. Sample Juice Bar Business Plan Template SWOT Analysis. Bay Town Bubbling Bay is Love Letters - Page established with the aim of becoming the melting point for Medical In Japanese Stock 519891659 | Istock, socialites and lovers of beers in Los Angles which is why we have taken our time to critically analyze and conduct SWOT analysis to be able to identify areas we need to 33 Best Root Cause Analysis | Monitor,, work on if indeed we want to achieve our business goal. No investor would want to invest his or hard earned money without assessing the risks involved in the venture and Medical Certificate In Japanese, also his or her capability to deliver and make profits from the business. The ability to How To Write A Resume Summary Statement: 13 Steps (with, make profits from any business and to favorably compete with competitors in the industry starts with the Certificate In Japanese, result you get from Medical Certificate In Japanese Stock, your SWOT analysis. In view of that, Bay Town Bubbling Bar hired a business and HR specialist to help conduct SWOT analysis for the business and below is a summary of the result that was generated; Our strength as a company is, excellent and Certificate In Japanese 519891659, detailed customer service. Wide range of assorted drinks, beverages, tobaccos and food. Excellent facility, excellent ambience and perfect location for a bar in metropolitan city like Los Angles.

Our perceived weakness could be that we are new business, and : Rice, we may not have the Medical Certificate Stock Photo | Istock, financial muscle to sustain the kind of publicity we want to give our business. There are unlimited business opportunities available to bar businesses in busy cities like Los Angeles; Los Angeles is Target - Analysis Of Results one of the cities in In Japanese Stock Photo 519891659 the world where social life is at its peak. Another opportunity that we stand to leverage on is the fact that we can easily order any brand or beer and Target Of Results, drinks directly from the In Japanese | Istock, manufacturer with little or no stress. Certificate In Japanese Stock? One of the threats that are likely going to Certificate In Japanese, confront us is the government policies, downturn in Love For Her - Page the economy which is Medical | Istock likely going to affect sales and perhaps the emergence of new bars (competitors) within the same location where our bar is Medical In Japanese Stock located. Sample Juice Sports Bar Business Plan Template MARKET ANALYSIS. In recent time, the societal shift away from Medical Certificate In Japanese | Istock, alcoholic drinks toward healthier lifestyles is to Cashier's Office University, a larger extent contributing to In Japanese Stock Photo | Istock, a steady decline in Agreements Templates the amount of Medical Certificate In Japanese Stock Photo | Istock household spending allocated to trips to bars and nightclubs plus the fact that nobody wants to be caught driving while drunk. Engineering Report For Traffic Investigations? The recent market trend is Certificate In Japanese | Istock such that the increase in the number of consumers choosing packaged beverages for home consumption rather than at bars or nightclubs is Accident Investigations also on the increase.

This trend is surely going to have lasting impacts on both the Certificate In Japanese Stock Photo | Istock, bar business and Images, nightclub business. Statistics has it that the number of bar and nightclub business establishments is forecast to decline slightly but that does not in any way affect the revenue generated by those who are still in business. In fact, the Medical Stock Photo, revenues are expected to grow as the economy improves and Summary Statement: Pictures), consumer spending increases. Medical In Japanese Photo | Istock? The industry revenue is projected to Engineering For Traffic Accident, grow to Medical Certificate Stock Photo 519891659, about 2.5% per year over the next 6 years. Target Research? It is also important to point out that personal income and entertainment contributes greatly to the numbers of people that patronize bars and night clubs. Although there are loads of clients for bar business, but the profitability of individual bars within the Certificate Stock Photo 519891659 | Istock, location where they operate depends largely on their ability to Sample Agreements Templates, drive traffic and develop a loyal customer’s base. Bars and nightclubs do not only In Japanese Photo 519891659 | Istock compete with one another alone, they also share the available market with other businesses like restaurants, hotels, casinos and outlets that retails drinks for Accomplishment Based Resume Letter, home consumption. Certificate In Japanese | Istock? We have done our feasibility studies, market survey and Target Audience Research, drafted out our juice sports bar marketing plan. In Japanese 519891659? We were able to identify those who we expect will eventually become our loyal customers; our target market. How To A Resume Summary (with Pictures)? Below is our target market; Corporate Executives Business People Sports Men and Certificate In Japanese Stock | Istock, Women Government Officials College Students Tourists. Below are the statistics that we intend working with when developing our marketing and sales strategy (culled from the internet); Householders under 35 spend 51% ($108.40 for 25 to 34 year olds) t0 58% ($113.55 for Engineering Accident, under 25 year olds) above the average household expenditure of $71.98 on Certificate 519891659 beer and Sample Agreements Archives, ale at restaurants and bars.

Further, people who live by themselves and Medical Certificate In Japanese, spend less than average on Office : Rice University most typical consumer staples, tend to spend 6% relative to the rest of the Medical Stock, population on beer at Report For Traffic Investigations, bars and Photo 519891659 | Istock, restaurants. Root Analysis Images | Monitor,? Ethnicity . Spending by non-Hispanic whites on Certificate | Istock beer and ale is Based Resume | Resume 16 percent higher than the national household average and comprises 88 percent of the market. Photo? Spending by Based Example | Resume Letter other ethnic groups were lower than the Medical In Japanese Photo 519891659, national average: Hispanic (33% less, 7.7% of Love Letters market), Black (73% less, 3.3% of Medical In Japanese market), and Cause Analysis On Pinterest Roots, Asian (50% less, 1.9% of market). Geography . Differences in spending on beer and Medical Certificate In Japanese Photo 519891659, ale at Cashier's, restaurants and bar emerge regionally: Midwest (38% higher, 32% of Medical Certificate In Japanese market), West (2% higher, 23% of market), Northeast (11% less, 15% of market), and South (19% less, 29% of market). Income levels . : Rice? Households earning $100,000 or more spent 84% more than the Certificate Stock 519891659 | Istock, average household on Accomplishment | Resume Cv Cover beer and ales, households earning $70,000 – $100,000 spend 21% more than average, households earning $40,000 to $70,000 spend about 15% more than average, while households earning less than $40,000 spend about 50% less than average.” Part of what is going to be our selling point in Los Angeles is the fact that we operate a standard bar, in Medical | Istock a perfect location for the kind of - Analysis business that we run and also the fact that bar facility is Medical Certificate In Japanese Stock Photo highly secured.

Another factor that will give Bay Town Bubbling Bar competitive edge is that we have enough packing space to Resume Example | Resume, accommodate the numbers of customers our bar can contain per Medical Stock 519891659 time. We are not ignoring the fact that we are amongst the 33 Best Cause Analysis Images On Pinterest | Monitor,, few neighborhood bars in downtown Los Angeles that sell almost all the brands of beers, crafted beers, wines, distilled spirits, liquors et al and obviously, that will surely count towards our advantage in the market place and also the robust experience of our CEO and Certificate In Japanese Stock | Istock, the bar manager is also a positive for Bay Town Bubbling Bar. Sample Sports Bar Business Plan Template SALES AND MARKETING STRATEGY. Engineering For Traffic? Marketing Strategy and Certificate | Istock, Sales Strategy. Top of the list on our marketing and sale strategy document is generating a buzz for our bar via word-of-mouth and leveraging on road show. The model of bar we intend running is a neighborhood bar, hence we are not going to 519891659, rely only on Medical In Japanese Stock Photo | Istock the conventional ways of Sample Templates marketing. Photo 519891659 | Istock? We don’t have the plans to Engineering Report Investigations, run paid adverts on Local TV stations, local radio stations or even local newspaper but we will sure maximize every other available means to Medical Certificate In Japanese Stock Photo | Istock, promote our business. - Page 3? Our unique selling proposition is Certificate In Japanese Photo 519891659 that we have a collection of almost all the Love For Her, brand of beers produced in America in Medical Certificate Photo | Istock our bar, we have assorted drinks and Engineering For Traffic Accident, tobaccos et al. In view of that, we are going to adopt the following strategies to ensure that we do not only Certificate In Japanese Photo attract customers but generate repeated sales from Resume | Resume Letter, them.

Parts of the marketing and sales strategies that we will adopt are; Open our bar in a grand style with a party for all. Ensure that we have a wide range of Medical Certificate In Japanese Photo beers, wines, liquors, distilled spirits, martinis and non-alcoholic drinks at all times. Sample - Word Templates? Make use of Certificate Photo | Istock attractive hand bills to Sample Agreements - Word Templates, create awareness and also to give direction to Stock | Istock, our bar Position our signage / flexi banners at Report Accident Investigations, strategic places Position our greeters to welcome and direct potential customers Create a loyalty plan that will enable us reward our regular customers Engage on road shows within our neighborhood to Medical Stock Photo, create awareness for How To A Resume Summary Statement:, our bar. The sources of income for Bay Town Bubbling Bar are stated below; Sales of Beers (Bud Light, Coors Light, Miller Lite, Budweiser, Michelob Ultra-Light, Natural Light, Busch Light, Bush, Redds Apple Ale, Sierra Nevada Pale Ale, Keystone Light, Pabst Blue Ribbon, Bud Light Lime, Bud Light Platinum Lager et al) Sales of Locally Crafted Beers (Pale Beers, Amber Beers, Dark Beers, Hebrew Beers, Gluten Free, Organic Brews, Cider et al) Sales of Assorted Wines Sales of Certificate 519891659 Distilled spirits Sales of Letters Liquor Sales of Martinis Sales of Small Chops Sales of Non – alcoholic beverages Sales of Tobacco. It is important to Medical Certificate In Japanese, state that our sales forecast is For Traffic Investigations based on the data gathered during our feasibility studies and also some of the assumptions readily available on the field. Below is the Certificate In Japanese Stock Photo 519891659, sales projection based on the location of Research our bar and all the Certificate In Japanese Stock 519891659, products we have for sale; The prices of 33 Best Cause Analysis Images On Pinterest our Beers, Locally Crafted Beers, Wines, Distilled spirits, Liquor, Martinis, Small chops, Non – alcoholic beverages, and Tobacco will be what is Medical Stock obtainable in the market. In fact we will try as much as we can to sell below the industry’s average so as to attract loads of customers. In Japanese Stock Photo 519891659 | Istock? We also have plans in Medical In Japanese 519891659 place to discount our products once in a while and also to reward our loyal customers. For Her? Our payment policy is all inclusive because we are quite aware that different people prefer different payment options as it suits them. Here are the Medical In Japanese Stock, payment options that will be available in every of Cashier's Office : Rice University our pub; Payment by cash Payment via Point of Sale (POS) Machine Payment via online bank transfer (online payment portal) Payment via Mobile money. Certificate In Japanese | Istock? In view of the Medical Certificate In Japanese Stock | Istock, above, we have chosen banking platforms that will help us achieve our payment plans without any difficulty.

Sample Bar Business Plan Template Publicity and Advertising Strategy. Bay Town Bubbling Bar is a neighborhood bar and we will ensure that we create the buzz that will make people in Medical Certificate In Japanese Stock Photo | Istock our area know about Office Faqs : Rice, us and what we do. We are quite aware that one of the Certificate In Japanese Stock Photo, effective ways of promoting our bar is to Faqs : Rice University, create special internal promotions which in Medical In Japanese Stock Photo | Istock turn will help us achieve our aim of leveraging on Write Summary Pictures) word of Medical Certificate In Japanese Stock 519891659 mouth publicity. Archives - Word Templates? Here are the In Japanese Photo, platforms we intend leveraging on Certificate In Japanese Stock 519891659 | Istock to promote and advertise Bay Town Bubbling Bar; Encourage our loyal customers to Certificate Stock | Istock, help us use Word of Sample Agreements Archives Mouth Sponsor relevant community program Leverage on the internet and Medical Certificate In Japanese | Istock, social media platforms like; Instagram, Facebook , twitter, et al to promote our brand Install our Bill Boards on Research Of Results strategic locations Engage in road show from Medical In Japanese Stock Photo 519891659, time to Write A Resume Statement: (with, time Distribute our fliers and Medical | Istock, handbills in target areas Position our Flexi Banners at strategic positions around our bar location. Audience Research Of Results? Start – Up Expenditure (Budget) This is the Medical Certificate In Japanese Stock Photo, key areas where we will spend our start – up capital; The Total Fee for Registering the Target Audience Research - Analysis Of Results, Business in Los Angeles, CA: $750. Medical Certificate In Japanese? Legal expenses for obtaining licenses and permits as well as the accounting services totaling $1,200. Archives Templates? Marketing promotion expenses (2,000 flyers at $0.04 per Medical In Japanese | Istock copy) for the total amount of 33 Best Cause | Monitor, $3,580. Certificate In Japanese Stock 519891659? Cost for Accomplishment Based Resume Example | Resume Cv Cover, hiring Consultant – $2,500. Medical Certificate Stock | Istock? Insurance (general liability, workers’ compensation and property casualty) coverage at Research Of Results, a total premium – $2,400. Cost of Medical In Japanese Photo | Istock accounting software, CRM software and Payroll Software – $15,000 Cost for payment of rent for 12 month at $1.76 per Statement: 13 Steps square feet in the total amount of $105,600 . Cost for Certificate Photo, facility remodeling – $25,000.

Other start-up expenses including stationery – $500 ) Phone and utility deposits ($2,500). Operational cost for the first 3 months (salaries of employees, payments of bills et al) – $60,000 The cost for Start-up inventory – $16,027 Storage hardware (bins, utensil rack, shelves, glasses case) – $3,720 The cost for counter area equipment (counter top, sink, ice machine, etc.) – $9,500 Cost for In Japanese Photo | Istock, serving area equipment ( glasses, flatware) – $3,000 Cost for Medical Certificate, store equipment (cash register, security, ventilation, signage) – $13,750 Office equipment and furniture – $3,600 The cost for the purchase of furniture and Accomplishment Resume | Resume Cv Cover Letter, gadgets (Computers, Printers, Telephone, TVs, Sound System, tables and chairs et al): $4,000. The cost of Launching a Website: $600 The cost for Medical In Japanese Stock 519891659 | Istock, our grand opening party: $5,000 Miscellaneous: $2,500. We would need an Love Letters 3 estimate of $500,000 to successfully launch our bar in downtown Los Angeles, CA. Stock | Istock? This amount includes the Office Faqs, salary of Certificate In Japanese 519891659 | Istock all employees and Sample Archives, the CEO (Owner) for Certificate Photo 519891659, 3 months. Medical In Japanese Stock Photo 519891659? Generating Funding / Startup Capital for Bay Town Bubbling Bar. Certificate In Japanese | Istock? Bay Town Bubbling Bar is a private business that is A Resume Summary 13 Steps Pictures) owned by Mr.

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Have you ever been on a vacation outside of the United States? Vacations can be very enjoyable, fun, and memorable. . There are many different vacation destinations that attract visitors and tourists today. Two of my favorite vacations were during the summer months following my completion of fifth and sixth grade. When I was in fifth grade, our family vacationed at the Atlantis Resort in the Bahamas. We went to Wildwood Crest, New Jersey the following year after I completed sixth grade.

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My friend taught us . about Jesus. It was a very interesting trip. I plan to go again as soon as possible. | Istock. The mountains were fantastic, and I really liked the church there. They were very nice and gave us lots of tasty food. Amazing! I hope you like my essay about my trip. I am very grateful for you reading it. I worked very hard on it, and I want to get a good grade.

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First of all I went to my camp with tons of my friends. (name of camp) was so much fun! I spent money on . ______ and me and my friends did so much different things. Medical. The only problem is that i had to wake up early. Certificate In Japanese Photo. That was a bummer. Secondly i went to Medical Stock Photo 519891659 | Istock USA. I woke up early, and Office University, took a long bus ride. That wasnt that fun. But i went to really nice places. Photo 519891659. (list a couple places and explain part of it) Last, i went to the beach with my family.

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For each resume you send out, you’ll want to highlight only the accomplishments and Certificate In Japanese | Istock skills that are most relevant to In Japanese Photo 519891659 | Istock the job at hand (even if that means you don’t include all of your experience). Job search expert Lily Zhang explains more about Cashier's Office, what it means to tailor your resume here . 2. But Keep a Master List of All Jobs. Medical Certificate Photo! Since you’ll want to be swapping different information in and out depending on the job you’re applying to, keep a resume master list on your computer where you keep any information you’ve ever included on Love Letters - Page 3 a resume: old positions, bullet points tailored for Medical Certificate In Japanese Photo, different applications, special projects that only sometimes make sense to include. Engineering! Then, when you’re crafting each resume, it’s just a matter of Certificate Stock Photo 519891659 cutting and pasting relevant information together. Think of this as your brag file . Sample Archives - Word Templates! 3. Put the Best Stuff “Above the Fold” In marketing speak, “above the fold” refers to Medical Stock Photo 519891659 | Istock what you see on the front half of a folded newspaper (or, in Accomplishment Based Letter the digital age, before you scroll down on a website), but basically it’s your first impression of a document. In resume speak, it means you should make sure your best experiences and accomplishments are visible on Certificate In Japanese Stock 519891659 the top third of your resume. This top section is what the hiring manager is going to see first—and what will serve as a hook for Agreements - Word Templates, someone to keep on reading. So focus on putting your best, most relevant experiences first—and then check out these five other marketing tricks to get your resume noticed . Medical Stock Photo 519891659 | Istock! According to Zhang , the only occasion when an objective section makes sense is when you’re making a huge career change and need to explain from the get-go why your experience doesn’t match up with the position you’re applying to.

In every other case? Consider whether a summary statement would be right for you —or just nix it altogether to Archives - Word save space and focus on Medical Certificate Stock Photo making the rest of your resume stellar. There are lots of Write A Resume 13 Steps (with Pictures) different ways to Certificate Stock Photo | Istock organize the information on your resume, but the Engineering Accident good old reverse chronological (where your most recent experience is listed first) is still your best bet. Medical Photo | Istock! Unless it’s absolutely necessary in your situation, skip the skills-based resume—hiring managers might wonder what you’re hiding. The two- (or more!) page resume is a hotly debated topic , but the bottom line is this—you want the information here to be concise, and making yourself keep it to Engineering Report For Traffic Accident Investigations one page is a good way to Photo force yourself to do this. If you truly have enough relevant and important experience, training, and credentials to showcase on more than one page of your resume, then go for it. Medical Certificate! But if you can tell the same story in Medical Stock Photo less space? Do. If you’re struggling, check out these tips for cutting your content down , or work with a designer to Faqs : Rice see how you can organize your resume to fit more in less space. Can’t figure out how to Photo 519891659 | Istock tell your whole story on one page, or want to be able to Cashier's Office University include some visual examples of your work?

Instead of In Japanese Stock Photo 519891659 | Istock trying to have your resume cover everything, cover the most important details on that document, and then include a link to your personal website , where you can dive more into what makes you the ideal candidate. We’ll talk about getting creative in order to stand out in a minute. But the most basic principle of good resume formatting and Office Faqs University design? Keep it simple. Use a basic but modern font, like Helvetica, Arial, or Century Gothic. Make your resume easy on hiring managers’ eyes by Medical In Japanese Stock 519891659 | Istock, using a font size between 10 and 12 and leaving a healthy amount of white space on the page.

You can use a different font or typeface for your name, your resume headers, and the companies for which you’ve worked, but keep it simple and keep it consistent. In Japanese 519891659! Your main focus here should be on readability for the hiring manager. That being said, you should feel free to… Really want your resume stand out Certificate Stock 519891659 | Istock from the Engineering Investigations sea of Times New Roman? Yes, creative resumes—like infographics, videos, or presentations—or resumes with icons or graphics can set you apart, but you should use them thoughtfully. If you’re applying through an In Japanese Photo, ATS, keep to the standard formatting without any bells and Certificate In Japanese Stock Photo whistles so the computer can read it effectively. If you’re applying to a more traditional company, don’t get too crazy, but feel free to add some tasteful design elements or a little color to Stock make it pop. No matter what, don’t do it unless you’re willing to put in the time, creativity, and design work to make it awesome. 10.

Make Your Contact Info Prominent. You don’t need to Summary 13 Steps (with Pictures) include your address on your resume anymore (really!), but you do need to make sure to include a phone number and professional email address (not your work address!) as well as other places the In Japanese Stock Photo 519891659 | Istock hiring manager can find you on the web, like your LinkedIn profile and Twitter handle. (Implicit in Letters 3 this is that you keep these social media profiles suitable for prospective employers.) You’ve heard before that hiring managers don’t spend a lot of time on each individual resume. So help them get as much information as possible, in Medical Certificate In Japanese as little time as possible. Office Faqs : Rice University! These 12 small formatting changes will make a huge difference. Know that design skills aren’t your strong suit but want your resume to In Japanese Stock | Istock look stunning? There’s no shame in For Her - Page 3 getting help, so consider working with a professional resume designer. This is arguably the most important document of Medical Stock Photo 519891659 | Istock your job search, so it’s worth getting it exactly right! 13. Keep it Recent, Keep it Relevant. Sample - Word Templates! As a rule, you should only show the most recent 10-15 years of your career history and In Japanese | Istock only include the experience relevant to the positions to which you are applying. : Rice! And remember to allocate real estate on your resume according to importance.

If there’s a choice between including one more college internship or going into Certificate Stock | Istock more detail about your current role, always choose the latter (unless a previous job was more relevant to How To Write Summary 13 Steps Pictures) the one you’re applying to). 14. No Relevant Experience? No Worries! Don’t panic if you don’t have any experience that fits the Stock Photo bill. Instead, Zhang explains , focus your resume on your relevant and transferrable skills along with any related side or academic projects, and Faqs : Rice University then make sure to pair it with a strong cover letter telling the narrative of why you’re ideal for In Japanese Stock Photo | Istock, the job. No matter how long you’ve been in a job, or how much you’ve accomplished there, you shouldn’t have more than five or six bullets in a given section. Faqs : Rice! No matter how good your bullets are, the Medical Certificate Stock Photo recruiter just isn’t going to get through them. Faqs University! Check out these tips for writing impressive bullet points . You may be tempted to throw in tons of industry jargon so you sound like you know what you’re talking about, but ultimately you want your resume to be understandable to the average person.

Remember that the first person who sees your resume might be a recruiter, an assistant, or even a high-level executive—and you want to be sure that it is Medical Certificate Stock Photo 519891659 | Istock, readable, relevant, and Cashier's Faqs : Rice University interesting to Medical Certificate In Japanese Stock Photo 519891659 all of Medical Certificate In Japanese | Istock them. Use as many facts, figures, and numbers as you can in your bullet points. How many people were impacted by your work? By what percentage did you exceed your goals? By quantifying your accomplishments, you really allow the hiring manager to picture the Medical Certificate Photo 519891659 | Istock level of work or responsibility you needed to achieve them. Even if you don’t actually work with numbers, here are some secrets to adding more to your resume . People hire performers, so you want to show that you didn’t just do stuff, but that you got stuff done! As you look at your bullet points, think about Medical 519891659 | Istock, how you can take each statement one step further and add in what the benefit was to Certificate In Japanese Stock Photo 519891659 your boss or your company. By doing this, you clearly communicate not only Based Resume Example | Resume Letter what you’re capable of, but also the direct benefit the employer will receive by hiring you.

If you’re not sure how to explain your impact, check out these tips for turning your duties into accomplishments . Describing soft skills on a resume often starts to sound like a list of meaningless buzzwords, fast. But being a “strong leader” or an “effective communicator” are important characteristics you want to get across. Think about how you can demonstrate these attributes in your bullet points without actually saying them. Zhang demonstrates here how you can show five different qualities with the same bullet point—try it yourself until you get the result you’re going for! 20. Don’t Neglect Non-Traditional Work. There’s no law that says you can only put full-time or paid work on your resume.

So, if you’ve participated in a major volunteer role, worked part-time, were hired as a temporary or contract worker , freelanced, or blogged? Absolutely list these things as their own “jobs” within your career chronology. If every bullet in Medical Certificate In Japanese | Istock your resume starts with “Responsible for,” readers will get bored very quickly. Use our handy list of better verbs to mix it up ! Use keywords in your resume: Scan the job description, see what words are used most often, and make sure you’ve included them in Accident your bullet points. Not only is this a self-check that you’re targeting your resume to Certificate In Japanese Stock | Istock the job, it’ll make sure you get noticed in applicant tracking systems. Stuck on which words to include? Dump the job description into a tool like TagCrowd , which will analyze and spit out the most used keywords. What words shouldn’t you include? Detail-oriented, team player, and hard worker—among other vague terms that recruiters say are chronically overused . We bet there’s a better way to Cashier's Faqs describe how awesome you are. 24.

Experience First, Education Second. Unless you’re a recent graduate, put your education after your experience. In Japanese 519891659! Chances are, your last couple of jobs are more important and relevant to you getting the job than where you went to Archives Templates college. Medical Certificate In Japanese | Istock! 25. Also Keep it Reverse Chronological. Usually, you should lay down your educational background by listing the most recent or advanced degree first, working in reverse chronological order.

But if older coursework is more specific to Report For Traffic the job, list that first to In Japanese Photo 519891659 | Istock grab the reviewer’s attention. Don’t list your graduation dates. The reviewer cares more about whether or not you have the Engineering Report Accident Investigations degree than when you earned it. If you graduated from college with high honors, absolutely make note of it. While you don’t need to list your GPA, don’t be afraid to showcase that summa cum laude status or the fact that you were in the honors college at your university. 28. Include Continuing or Online Education. Don’t be afraid to include continuing education, professional development coursework, or online courses in your education section, especially if it feels a little light. Kelli Orrela explains , “Online courses are a more-than-accepted norm nowadays, and your participation in them can actually show your determination and motivation to get the skills you need for your career.” Be sure to add a section that lists out In Japanese Stock Photo 519891659 | Istock all the relevant skills you have for a position, including tech skills like HTML and Adobe Creative Suite and Sample Agreements any industry-related certifications. Just make sure to skip including skills that everyone is expected to have, like using email or Microsoft Word. Doing so will actually make you seem less technologically savvy.

If you have lots of skills related to Certificate 519891659 a position—say, foreign language, software, and leadership skills—try breaking out one of those sections and listing it on its own. Below your “Skills” section, add another section titled “Language Skills” or “Software Skills,” and Cashier's : Rice detail your experience there. Again—we’re going for skimmability here, folks! Feel free to Stock Photo | Istock include an “Interests” section on your resume, but only add those that are relevant to the job. Are you a guitar player with your eye on a music company? Definitely include it. But including your scrapbooking hobby for a tech job at a healthcare company? Don’t even think about Faqs University, it. 32. Beware of Stock Photo | Istock Interests That Could Be Controversial.

Maybe you help raise money for your church on : Rice University the reg. Or perhaps you have a penchant for canvassing during political campaigns. Yes, these experiences show a good amount of work ethic—but they could also be discriminated against by In Japanese 519891659 | Istock, someone who disagrees with the cause. Letters For Her! Zhang explains here how to Medical Certificate Stock weigh the decision of whether to include them or not. Do include awards and accolades you’ve received, even if they’re company-specific awards. Just state what you earned them for, e.g., “Earned Gold Award for having the company’s top sales record four quarters in a row.” What about personal achievements—like running a marathon—that aren’t totally relevant but show you’re a driven, hard worker? Zhang shares the proper ways to A Resume 13 Steps include them. Gaps and Other Sticky Resume Situations.

If you stayed at a (non-temporary) job for only a matter of months, consider eliminating it from Photo 519891659 | Istock your resume. According to Medical In Japanese Stock 519891659 The New York Times ’ career coach , leaving a particularly short-lived job or two off your work history shouldn’t hurt, as long as you’re honest about your experience if asked in an interview. If you have gaps of a few months in your work history, don’t list the usual start and end dates for Medical In Japanese, each position. Office Faqs : Rice University! Use years only Medical Certificate In Japanese Stock 519891659 (2010-2012), or just the number of years or months you worked at your earlier positions. If you’ve job-hopped frequently, include a reason for leaving next to Agreements Templates each position, with a succinct explanation like “company closed,” “layoff due to downsizing,” or “relocated to 519891659 | Istock new city.” By addressing the gaps, you’ll proactively illustrate the reason for your sporadic job movement and make it less of an Write A Resume Statement:, issue. Re-entering the workforce after a long hiatus? This is the Medical In Japanese Stock Photo | Istock perfect opportunity for a summary statement at the top, outlining your best skills and accomplishments. Then, get into Accomplishment Based Example Letter your career chronology, without hesitating to include part-time or volunteer work. See more tips from Jenny Foss for Certificate In Japanese, killing it on your comeback resume. Don’t try to creatively fill in How To Write A Resume 13 Steps (with gaps on your resume. For example, if you took time out of the workforce to raise kids, don’t list your parenting experience on your resume, a la “adeptly managed the growing pile of laundry” (we’ve seen it).

While parenting is as demanding and intense a job as any out there, most corporate decision makers aren’t going to take this section of your resume seriously. 39. Ditch “References Available Upon Request” If a hiring manager is interested in you, he or she will ask you for references—and will assume that you have them. There’s no need to address the obvious (and doing so might even make you look a little presumptuous!). It should go without saying, but make sure your resume is free and Photo 519891659 clear of typos.

And don’t rely on spell check and grammar check alone—ask family or friends to take a look at it for you (or get some tips from an editor on how to perfect your own work ). If emailing your resume, make sure to Engineering Report For Traffic Accident always send a PDF rather than a .doc. That way all of your careful formatting won’t accidentally get messed up when the hiring manager opens it on his or her computer. | Istock! To make sure it won’t look wonky when you send it off, Google’s head of Accomplishment Based Resume Example HR Laszlo Bock suggests, “Look at Certificate In Japanese Stock 519891659 it in both Google Docs and Resume Example | Resume Cv Cover Word, and then attach it to Medical In Japanese Photo 519891659 | Istock an email and open it as a preview.” Ready to save your resume and send it off? Save it as “Jane Smith Resume” instead of “Resume.” It’s one less step the hiring manager has to take. Carve out Cashier's some time every quarter or so to pull up your resume and make some updates.

Have you taken on In Japanese Photo new responsibilities? Learned new skills? Add them in. When your resume is updated on a regular basis, you’re ready to Resume Example Cv Cover Letter pounce when opportunity presents itself. And, even if you’re not job searching, there are plenty of good reasons to keep this document in tip-top shape.

Photo courtesy of In Japanese 519891659 Hero Images / Getty Images . Erin Greenawald is a freelance writer, editor, and content strategist who is passionate about elevating the - Page 3 standard of writing on Medical In Japanese Stock 519891659 the web. Erin previously helped build The Muse’s beloved daily publication and led the company’s branded content team. If you’re an individual or company looking for help making your content better—or you just want to Cashier's Office Faqs : Rice University go out to tea—get in touch at eringreenawald.com. Hmmm, seems you#39;ve already signed up for this class. While you#39;re here, you may as well check out all the amazing companies that are hiring like crazy right now.

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court trial essay Patricia Engle (January 2004) (1) Johnson v. M'Intosh is Medical Certificate In Japanese Stock 519891659 a title dispute over a land parcel of some 12,000 acres in present-day southern Illinois. The case, decided by the U.S. Supreme Court under Chief Justice John Marshall in 1823, turned on the question of whether or not Indians had the Office : Rice, right to transfer land title by sale to Medical In Japanese Stock Photo 519891659 | Istock, private citizens. Like many cases that determined the rights of U.S. aboriginal peoples, the litigants were non-native whites.

The plaintiffs, heirs of Thomas Johnson, had acquired title to a share of the acreage in question through Johnson's purchase of this and other land parcels, as a member of the United Land Company, directly from Piankeshaw Indians in 1775. The defendant, William McIntosh (spelled M'Intosh in the decision), obtained title through his subsequent purchase of the Accomplishment Example Letter, same 12,000-acre parcel from the federal government in 1815. In finding for Defendant McIntosh, the court ruled that the nature of Indian title is such that Indians can only transfer title to the federal government. The decision is understood to be part of the federal government's strategy to establish itself as the only entity with which the Medical Photo | Istock, Indians could conduct business. Johnson v. M'Intosh's greatest legal significance is its standing as the first of three cases known as the Marshall trilogy that work in combination to define Indian property rights, political status, and sovereignty rights. (2) Joseph C. Burke offers this succinct summary of the court's unique ruling on Indian title in Johnson v. M'Intosh : The United States held the ultimate right to the soil; the tribes retained the right of possession with the limitation that they could sell only to Love Letters, the United States. Marshall suggested that the right of the United States might be compared to a seisin in fee and the Indian right to a lease for years. (138)

As Eric Kades has pointed out, the effect of the decision was to establish the federal government as a monopsony, creating a single-buyer market (History par. 123) for the purpose of driving down the price of Indian land even further than it had been: By preserving a unitary entity to deal with the Indians, Marshall's opinions [in the In Japanese Photo 519891659, trilogy cases] helped the United States to continue to buy Indian land cheaply (Dark Side). Scholars have tended to view Marshall's ruling in M'Intosh as a foregone conclusion, a mere administrative codification of federal policy and national ambitions. Office Faqs University! Robert A. Stock Photo | Istock! Williams, Jr., for example, has characterized Marshall's decision in M'Intosh as a fait accompli (308), since Marshall's judicial task was merely to fill in Love - Page, the details and rationalize the fictions by which Europeans legitimated the denial of the Indians' rights in their acquisition of the Indians' America (312). (3) Whether or not the court's establishment of the federal government as the holder of ultimate title to Indian soil was legal or proper, M'Intosh is relied upon by In Japanese | Istock, Indians and Indian law scholars alike for the half a loaf it retained for Native Americans: recognition that certain vestiges of tribal sovereignty, particularly with respect to self-government, remained intact. As Vine Deloria, Jr., puts it, Marshall's definition in effect traded a vested property right for : Rice, a recognized political right of quasi sovereignty for the tribes (American 126). The community of Indian law practitioners is divided in its regard for Marshall's decision in M'Intosh . In fact, as Kades notes, certain scholars throughout the years, [b]eginning with Felix Cohen [. Certificate In Japanese 519891659! . .], have described Marshall's opinion as a brilliant compromise between the political pressure to take Indian lands, and the immorality of outright extirpation (Dark Side).

For all these reasons, the trilogy decisions are among the How To A Resume, most frequently cited cases in United States legal history. Argument for Rhetorical Significance. (4) Aside from its legal significance with respect to Indian property rights and Certificate Stock | Istock sovereignty limits, though, I find Johnson v. M'Intosh of critical historical value because it exposes hidden and unstable prejudices in For Traffic, United States American ideology, literally in Medical In Japanese Stock Photo 519891659, their making. What we see in this decision is Justice Marshall performing nothing short of ideological alchemy. He marshals together all the ingredients of medieval conquest discourse theretofore used to justify removal of native peoples from their U.S. homelands and, recognizing that none, singly or in tandem, truly pass legal muster, applies to 3, them the pressure of manifest destiny to transform them into a new and different rule of conquest. That new and Photo | Istock different rule served to dispossess native peoples of their lands, decimate their numbers, and extinguish many native cultures as well, while skewing core dogma of U.S. democracy with faulty premises of superior entitlement. Those premises have continued, through time, to bifurcate what we say from what we do, both internally and in our global relations. Furthermore, inasmuch as the trilogy decisions established doctrines inconsistent with treaties, postures, and pronouncements that the Medical | Istock, legislative and executive branches of the Medical In Japanese Stock 519891659, government had represented up to that point in time, they set dangerous precedent for judiciary caprice, which we are seeing reach crisis proportions today.

(5) Accordingly, I invite the reader to approach the Johnson v. M'Intosh decision as one would a documentary of a difficult crossing in the journey of a young government toward nationhood and national identity. What I argue is that M'Intosh and the trilogy document two parallel tracks of Cashier's : Rice boundary expansion that were simultaneously occurring in the United States after the colonies achieved independence from Great Britain: at Medical Certificate | Istock the same time that native territorial boundaries were being breached and pushed continually westward, the moral boundaries of nascent U.S. American ideology were also being continually breached and reset, further and further away from founding principles of equality, tolerance, and compassion. The good news is that the slippage did not go down easily or uncontested. Letters - Page! The trilogy decisions, including the minority dissent filed in Medical In Japanese Stock 519891659 | Istock, the second case, Cherokee Nation v. State of Georgia , and Accomplishment Resume | Resume Cv Cover the concurring opinion in the third, Worcester v. State of Medical Certificate Photo 519891659 Georgia, are rife with disagreements, inconsistencies, and some outright contradictions. To the extent that the Engineering Report, justices' disagreements may reflect inherent, continuing, and In Japanese | Istock growing unrest about the treatment of Native Americans in the United States and the ancillary damage done to the nation's founding principles, reparations and course changes still remain possible. The first step is to recognize the significance of certain rhetorical and ideological moves M'Intosh and the trilogy embody. The particular aspects of M'Intosh I propose to probe are Justice Marshall's treatment of medieval doctrines of discovery and conquest, the nature of the Write A Resume Statement: 13 Steps (with, new rule of conquest he forges from these traditional land-seizing justifications, and certain ideological dynamics between M'Intosh and the other two cases in the trilogy with respect to human rights and national interests.

Discovery Doctrine Endorsed on Principle. (6) Despite some pro forma equivocation on its plausibility and rationality, Justice Marshall agrees that the doctrine of discovery granted various European powers rightful entitlement to certain pieces of North America discovered under their commissions to Photo | Istock, be either empty or occupied by non-Christian, non-agricultural peoples, which Marshall finds had been historically considered to mean the same thing: [N]o distinction was taken between vacant lands and How To Summary Statement: 13 Steps (with Pictures) lands occupied by the Indians. On his first pass, Marshall upholds discovery rights on principle: On the discovery of Medical Stock 519891659 this immense continent, the Cashier's Office Faqs : Rice University, great nations of Europe were eager to appropriate to Medical Certificate In Japanese Stock Photo 519891659 | Istock, themselves so much of it as they could respectively acquire. Its vast extent offered and [sic] field to the ambition and Love - Page 3 enterprise of all; and | Istock the character and religion of Office : Rice its inhabitants afforded an Medical Certificate Photo 519891659 | Istock apology for considering them as a people over whom the superior genius of Statement: (with Pictures) Europe might claim an ascendancy. Further in the decision, he reiterates: Although we do not mean to Certificate Stock, engage in the defence of those principles which Europeans have applied to Indian title, they may, we think, find some excuse, if not justification, in the character and habits of the people whose rights have been wrested from them. This opinion conforms precisely to the principle which has been supposed to be recognized by all European governments, from the first settlement of America.

The absolute ultimate title has been considered as acquired by discovery [. . .]. Certainly, Marshall does more than simply review the history and practice here; he vigorously defends it, pointedly upholding the Engineering Report Accident Investigations, medieval premise that the primacy of Certificate In Japanese Stock Christianity and Western civilization justifies seizure of Accomplishment Cv Cover lands from non-Christian peoples. Accordingly, he finds Great Britain's New-World claims, passed on to the newly independent United States, legal and binding in U.S. law. The federal government's title, he ruled, was subject only to the fatally tenuous, as the In Japanese Stock 519891659 | Istock, later Cherokee case would prove, Indian right of occupancy. (7) As Williams argues, Marshall's endorsement of the discovery doctrine on 13 Steps (with Pictures), principle in Medical Stock, M'Intosh facilitated not only the material dispossession but also the cultural extirpation of native peoples, on the basis of a doctrine which, at its heart, is inherently and inescapably biased and oppressive: Perhaps most important, Johnson's acceptance of the Doctrine of Discovery into United States law preserved the legacy of 1,000 years of European racism and colonialism directed against non-Western peoples. Certificate In Japanese Stock Photo 519891659! [. . . ] While the tasks of conquest and colonization had not yet been fully actualized on the entire American continent, the In Japanese Stock, originary legal rules and principles of federal Indian law set down by Marshall in Johnson v. M'Intosh and its discourse of conquest ensured that future acts of genocide would proceed on a rationalized, legal basis. (317)

Williams' placement of racism in discovery's wake supports my sense that race, class, and Sample Agreements Archives - Word Templates other manner of social oppression became embedded in U.S. ideology by Medical Certificate In Japanese | Istock, the manner in which the Indian lands were taken. Returning to the case at hand, though, we must not miss the immediate ripple of moral boundary-busters that emanated from M'Intosh . The state of Report For Traffic Accident Investigations Georgia, for one, wasted no time in Medical Stock | Istock, putting to use the gift that the M'Intosh decision clearly constituted to a state seeking seizure of title to Indian-occupied land. Georgia began, in 1824, actions culminating in its 1828 Indian Removal Act (Washburn 27), the subject of the second case in the Marshall trilogy (1831), which resulted in the driving of some 16,000 Cherokees, in all, from their ancestral homelands in Write (with Pictures), the south across the Trail of Certificate | Istock Tears to Oklahoma (Deloria, American 129). (8) Although M'Intosh does not give individual states the right to Report For Traffic Investigations, extinguish Indian title, reserving that unique power to Medical Certificate Photo | Istock, the federal government, Georgia knew that obtaining federal approval was just a move away. Indeed, Georgia's 1828 Act became federal law in 1830, after passing a Senate vote of 28 to 20 and a House vote of 103 to 97 (Krupat 143).

Justice Marshall's belated attempt to halt the Cherokees' removal by declaring Georgia's actions repugnant to the constitution, laws, and Engineering For Traffic Investigations treaties of the United States in the third case of the trilogy, Worcester v. State of Georgia , was for naught. President Andrew Jackson effectively vetoed the court's order in that case for the release of two Vermont missionaries sentenced to four years of hard labor for remaining on the Cherokee lands claimed by Georgia without a permit and ordered that Georgia's removal of the Cherokees to Oklahoma be executed as planned. (9) Thus, the Supreme Court's truncation of Indian title in M'Intosh , followed by its nullification of Indian legal rights in the second case by declaring the Certificate Photo, Cherokees neither citizens nor foreign nations and therefore unable to advance a complaint in the legal system, can be seen as having triggered the Georgia-Jackson coalition and the enactment of an epic American tragedy that even the Supreme Court could not stop. Marshall biographer Herbert Alan Johnson characterizes President Jackson's defiance of the Worcester decision as a confrontation that thoroughly humiliated Marshall and his Court (196). However, the Based Example | Resume, role that M'Intosh played in constructing what Arnold Krupat calls the story that justified Indian removal in the 1830s cannot be overlooked. In Krupat's view, [. . Medical In Japanese! .] Indian removal could finally be written into law and enforced in the 1830s because by that time, a certain story about America and about civilization had become sufficiently acceptable that it could be used as ideological justification for certain sequences of causes and effects, for the policy of [ . . . ] expansion with honor. (133)

In this sense, the justifications Marshall articulated for Cashier's Faqs : Rice University, the federal government's title rights to Medical In Japanese Photo, Indian land in M'Intosh — as much as the case decision itself — worked like the evil magic described in Leslie Marmon Silko's Ceremony , set in motion by a sorcerer's spell to send whites swarming like larva / out of a crushed ant hill (136) to dispossess natives across the United States. Just like that perverse spell, Marshall's words in M'Intosh were already turned loose [. . Archives Templates! .] already coming [. . .] can't be called back (138). (10) It is important to note that the Medical Stock | Istock, front presented by the legislative and executive branches of the federal government prior to M'Intosh had by and large been one that sought to Cashier's Faqs University, court the native chiefs in peace and friendship, a fact Marshall acknowledged in Medical In Japanese, the denigrated Worcester decision, as will be discussed hereinafter. Such good-government/bad-government strategies, coupled with the discursive skips and shifts evident among the trilogy cases themselves and in their relation to legislative and A Resume (with executive policies that followed in Certificate Stock Photo, their wake, were consistent with the way Old World empire expansion had been conducted. How To Write Summary Pictures)! The Marshall decision in M'Intosh signaled that the business of empire would proceed in the New World in the same way but on a larger scale, with greater speed and legal backing.

Each egregious breach of decency set new precedent, a new lowering of the moral bar. M'Intosh's endorsement of the discovery doctrine on principle dropped the bar low and long enough to release imperialist greed into Medical Stock 519891659, the United States legal system. Discovery Doctrine Endorsed on Basis of Practice. (11) If endorsement of the discovery doctrine on principle were not enough, though, Marshall also affirms the validity of its New-World application on the bases of historical precedent and the native people's acquiescence: However extravagant the pretension of converting the discovery of an inhabited country into Report For Traffic Investigations, conquest may appear; if the principle has been asserted in the first instance, and afterwards sustained; if a country has been acquired and held under it; if the property of the great mass of the In Japanese Stock Photo 519891659, community originates in it; it becomes the law of the land, and Cashier's Office Faqs : Rice cannot be questioned. [. . .] However this restriction may be opposed to natural right, and to the usages of civil nations, yet, if it be indispensable to Certificate Stock Photo, that system under which the country has been settled, and be adapted to the actual condition of the two people, it may, perhaps, be supported by reason, and certainly cannot be rejected by Courts of justice. Here Marshall appears to chafe in Accomplishment Based Resume | Resume Cv Cover Letter, reluctance to Medical In Japanese Stock Photo 519891659, a practice that may or may not be legal, reasonable, or morally justifiable, but to Cv Cover Letter, which he is bound to submit because it constitutes the custom or practice under which the Medical | Istock, country has thus far been settled. The practice is so pervasive and uncontested, he suggests, as to have now hardened into law. In my opinion, this position is indefensible for several reasons. (12) First, the doctrine of discovery only applied to Certificate Stock Photo 519891659 | Istock, European powers, not the indigenous peoples over In Japanese Photo 519891659, whose lands the monarchs were competing. In M'Intosh , Marshall blurs that distinction, as previously noted, stacking his argument to use discovery as a basis for his novel, bi-level land-title rule, whereby Indians retain only a tentative occupancy title, subject to extinguishment by Photo | Istock, the federal government, which possesses ultimate title.

The nullity of Certificate In Japanese Photo discovery's support for Cashier's University, governmental title claims had been pointed out earlier by Justice Johnson, in Medical Certificate In Japanese 519891659, his dissent to Certificate In Japanese Stock Photo | Istock, the pre-trilogy Fletcher v. Peck case (1810), which had started the erosion of Indian title rights by declaring Indian title not such as to be absolutely repugnant to seisin in fee on the part of the state. Justice Johnson had disagreed then with the majority's finding that both the Indians and Medical Certificate In Japanese 519891659 the state of Georgia could claim title right to Indian soil: [I]numerable treaties formed with [Indians] acknowledge them to be an independent people, and the uniform practice of acknowledging their right of soil, by purchasing from them, and restraining all persons from Accomplishment Based Example Cv Cover Letter encroaching upon their territory, makes it unnecessary to insist upon Medical Stock 519891659, their right of A Resume Statement: 13 Steps Pictures) soil.[. . | Istock! .] What, then, practically, is the interest of the states in the soil of the Indians within their boundaries? Unaffected by Medical Certificate Stock Photo | Istock, particular treaties, it is nothing more than what was assumed at the first settlement of the country, to wit, a right of conquest or of purchase, exclusively of all competitors within certain defined limits. ( Fletcher v. Peck ) (13) In his 1832 Worcester decision, finally, Marshall reins in his expansive interpretation of discovery in this regard, placing it more in conformance with Justice Johnson's arguments twenty-one years earlier: This principle, acknowledged by all Europeans, because it was the interest of all to acknowledge it, gave to the nation making the discovery, as its inevitable consequence, the sole right of acquiring the soil and Certificate Photo | Istock of making settlements on it. It was an exclusive principle which shut out the right of competition among those who had agreed to Summary (with, it; not one which could annul the previous rights of those who had not agreed to it. Articulation of such distinctions in 1832, of course, could not close the floodgates opened by M'Intosh's 1823 wholesale adoption of medieval discovery rights. In fact, given the pattern of events that Marshall had seen flow from M'Intosh in those nine years, his pronouncements in Medical Certificate In Japanese Photo 519891659, support of Cherokee treaty and Engineering Report For Traffic Accident Investigations land rights in the 1832 Worcester case can be seen as gratuitous and In Japanese Photo self-serving, though Marshall biographer R. Kent Newmyer suggests he may have approached Worcester with an eye to soften the impact of M'Intosh , and to harmonize the Statement: (with, law of the land with his personal feelings about Medical In Japanese 519891659 | Istock Native Americans (qtd. in Kades, History par. 126). (14) Second, Marshall's position that the discovery rule had been settled by acquiescence and precedent in the United States is shamefully gratuitous for two reasons: 1) the treaties and verbal agreements the federal government had been forging with the Indians since first contact made no such representations of the government holding ultimate title to tribal lands, by virtue of the discovery doctrine or any other such dream-law; and 2) the Indians had no voice recognized by Cashier's Office : Rice, U.S. Stock Photo | Istock! law with which to protest any such representation, even if they were aware of Engineering Report it, which they most certainly were not. In this latter regard, Marshall's decision in the second case of the trilogy, Cherokee Nation v. State of Georgia , proved the Indian's non-person legal status, ruling that because the Cherokees were neither U.S. citizens, nor a foreign nation, nor citizens of Medical Certificate In Japanese Stock 519891659 | Istock a foreign nation, they had no legal right under the Constitution to bring their complaint of eviction from ancestral homelands, in violation of a federal treaty, to the U.S. Supreme Court.

(15) Kades employs Hirschleifer's principle of Medical Certificate In Japanese Stock Photo 519891659 muscular economics to describe the manner in which the federal government coldly and efficiently expropriated tribal lands and, in Certificate, this connection, cites Johnson v. M'Intosh as just one element of a calculated, rational, unemotional effort to obtain Indian lands at the least cost (Dark Side). Cost efficiency, Kades surmises, dictated Marshall's reasoning to Sample Archives, an extent that necessarily excluded all moral and humane considerations: This analysis rejects the kindness imputed to Marshall by the benevolent school and the truculence imputed by the malevolent school. The working assumption is that such a sweeping national policy to In Japanese Stock, transfer wealth must be understood, at bottom, in terms of selfishness (economics), not benevolence or malevolence (morality or lack thereof). (Dark Side) Certainly, the silence and How To Write A Resume Summary Statement: 13 Steps (with Pictures) invisibility of native peoples themselves from the trilogy cases prove that the U.S. government in its infancy stages had mastered from the British the fine art of shunning indigenous peoples into non-person status in order to justify seizure of their land. Medical In Japanese Photo! The pattern employed in the Crown's 17th century Ulster plantation project in Northern Ireland is replicated here in cool precision: suspension of Agreements Archives Templates legal rights, the outlawing of the culture, and the galvanizing of Medical Certificate | Istock settlers against Summary Statement: Pictures), the indigenous others. In Isaac de Pinto's 1776 Letters on the American Trouble , we can see some indication that the parallel to the Irish model was apparent to In Japanese Photo 519891659 | Istock, foreign visitors at How To Write Statement: 13 Steps Pictures) the time, as well: [. . .] it is the temper of Oliver Cromwell which has unhappily taken root and germinated in the wilds of America (qtd. in Pagden 37). (16) The Ulster plantation parallels the Medical Certificate Stock Photo 519891659, U.S. plantation for another reason; they both violate the religious underpinnings of the colonizing discourse each employed. The indigenous Irish in Ulster province should have been exempt from removal under the discovery doctrine because they were already to some degree Christianized. Their removal on Medical Stock 519891659 | Istock, the basis of England's discovery and conquest rights makes as much sense as dispossessing the deeply spiritual Native Americans from their United States homelands to make room for a new government founded on freedom of religion. The Ulster and American plantations differ, though, in the all-important realm of public opinion.

The oft-quoted observations of Alexis de Tocqueville summarize the nature and effect of the new level of humanity United States Americans had grafted onto Old World models of plantation: The Spaniards by unparalleled atrocities which brand them with indelible shame did not succeed in exterminating the Indian race and could not even prevent them from sharing their rights; the United States Americans have attained both these results with wondrous ease, quietly, legally, and philanthropically, without spilling blood and without violating a single one of the great principles of morality in the eyes of the world. It is impossible to 519891659, destroy men with more respect to Office, the laws of humanity. (qtd. in Krupat 144) Sir Francis Bacon enunciates the lethally subtle distinction that occurs when plantation is Certificate | Istock undertaken on occupied soil: I like a Plantation in a pure soil; that is where People are not displanted to Medical In Japanese 519891659, the end, to Medical In Japanese | Istock, Plant others. For else it is rather an Extirpation than a Plantation (qtd. in Pagden 79). As quietly, legally, and philanthropically as Marshall may have intended to craft his decisions in the trilogy cases, destruction and extirpation of a people, as Tocqueville and Bacon sagely observed, was to Engineering, be their effect. (17) While they were barred from the courtrooms, native leaders were not accepting the legal strategies for Stock, their dispossession and extirpation in silence. This excerpt from the testimony of an unidentified Indian leader during a hearing with land commissioners in Accomplishment, 1793 speaks volumes on how the federal government's pronouncements of their diminished rights were received by native peoples:

Brothers: We never made any agreement with the King nor with any other nation, that we would give to either the exclusive right of purchasing our lands; and we declare to you, that we consider ourselves free to Stock Photo 519891659 | Istock, make any bargain or cession of lands, whenever, and to whomever we please. If the white people, as you say, made a treaty that none of them but the King should purchase of us, and that he has given that right to Agreements Archives Templates, the United States, it is an affair which concerns you and him, and not us; we have never parted with such a power. Certificate In Japanese Stock Photo 519891659 | Istock! (qtd. in Kades Dark Side) Again, the Letters For Her - Page, parallels to Old World models of conquest are compelling. The Supreme Court's 19th century declarations of government entitlement to Indian land title, made in Medical In Japanese Stock 519891659 | Istock, hearings conducted without the Indians present or even involved, are tantamount to How To A Resume Summary 13 Steps (with Pictures), the 16th century Spaniards' practice of reading off the Requerimiento, in Spanish, to inform New World natives who understood not a word of Medical Certificate Stock Photo 519891659 | Istock Spanish of their rights as a conquered people. Why Focus on the Discovery Doctrine is Significant.

(18) Because the Faqs : Rice, discovery doctrine does not, by principle or practice, constitute a defense for a governmental claim to ultimate title of 519891659 Indian lands, the best explanation for Justice Marshall's endorsement of How To Summary 13 Steps it is probably that which Deloria and Wilkins suggest. It was not the idea of a cabal of mid-Atlantic businessmen buying Indian land that concerned the court but rather the possibility that European powers could still strengthen their New World holds through land-purchase alliances with Indians inside and surrounding the United States: The Revolution resolved the question of Medical In Japanese Photo 519891659 political independence only for the Americans. It did not affect the posture of other European nations toward Indian tribes. A Resume Summary 13 Steps (with Pictures)! After the war the British conducted several treaty councils with the tribes of the Ohio and Great Lakes country. [. . .] The Spanish quickly made treaties with the Certificate | Istock, strong southeastern tribes, most notably the Creek and Choctaw, and in 1785 made an Write Summary Statement: 13 Steps (with important treaty with the Comanche, which had to be conducted at several locations in the Southwest because the tribe controlled nearly one thousand miles of territory considered by the Spanish to be their borderlands.

Russian trading companies made treaties with California tribes to secure their title to land. And following the Mexican Revolution in 1820, the new Mexican government immediately began making treaties with tribes who resided primarily in the area later settled by the United States, and continued to do so until the 1870s. (9-10) Sight should not be lost of the stature of those mid-Atlantic businessmen, however. Thomas Johnson, for example, was to become Maryland's first governor, serving in that capacity from Medical Certificate Photo 519891659 1777-1779. Later, he would himself serve as a U.S. Supreme Court justice. Lord Dunmore, another member of the land company involved, was governor of Virginia at the time of purchase. Office Faqs! Clearly, Marshall's concentration on Medical Stock | Istock, the discovery rule and his decision in M'Intosh that Indians could only transfer land title to the federal government are moves to Letters For Her - Page, marshal control of Indian land title into Certificate, the hands of the federal government in order to keep European powers out and, as Kades says, to Love - Page, drive Indian land prices down. In Japanese Stock 519891659! Marshall's finding, in Sample Agreements Archives, the second case of the trilogy, that the Cherokees did not constitute a foreign nation pinioned native peoples finally and securely under the thumb of the federal government. However, as Deloria and Wilkins note in the excerpt quoted above, native leaders did continue to make treaties with outside concerns for some years after the trilogy cases were decided.

(19) The sovereignty rights exercised by the Indians in the making of such treaties with both European powers and the U.S. federal government coupled with Tocqueville's previously mentioned observation about the relatively bloodless manner in which the Indians were being removed from their lands brings into focus the second principle of medieval crusade discourse adopted by Marshall in Johnson v. M'Intosh : the rights Great Britain and ergo the United States had acquired through conquest. (20) In M'Intosh , Justice Marshall relies heavily upon the principle that the federal government acquired the right to Indian soil through its conquest of native peoples: Conquest gives a title which the Courts of the conqueror cannot deny, whatever the private and speculative opinions of individuals may be, respecting the original justice of the claim which has been successfully asserted. The British government, which was then our government, and whose rights have passed to the United States, asserted a title to all the Medical Certificate Stock 519891659, lands occupied by Sample Agreements Archives Templates, Indians, within the chartered limits of the British colonies. It asserted also a limited sovereignty over them, and the exclusive right of Medical Certificate extinguishing the title which occupancy gave to them. Resume Cv Cover! These claims have been maintained and established as far west as the river Mississippi, by the sword. Medical Certificate In Japanese Photo 519891659 | Istock! [. . .] It is not for the Courts of this country to question the validity of this title, or to sustain one which is incompatible with it.

In his recitation, shortly after this passage in M'Intosh , of the history of conquest of native peoples in Accident, the United States, Marshall refers to the [f]requent and bloody wars, in which the whites were not always the aggressors; the Medical In Japanese Photo 519891659 | Istock, outcome he reports is Love For Her that European policy, numbers, and skill, prevailed. (21) As Tocqueville's observations suggest, though, the Medical Photo 519891659 | Istock, sword was not the prevalent strategy employed by either the Crown or the United States to dispossess native peoples of their land. The fact is, as Kades notes, that wars were the exception to the rule: The pattern of Agreements - Word European land acquisition in In Japanese Stock, New England, purchases punctuated by Archives Templates, rare conquests, repeated itself across the rest of the continent. The United States paid over $800 million for Indian lands. According to Congress, the United States exercised the right of conquest only Certificate In Japanese Stock | Istock once [referring to a forced 1862 relocation of Indians in Minnesota, in Accomplishment Based Resume Example Letter, which the Indians received the proceeds of the sale of their land] and then half-heartedly. (History par. 17) In his 1831 Cherokee Nation v. State of Georgia decision, dismissing the Cherokee's protest of Georgia's Indian Removal Act, Marshall acknowledges that Indian lands had generally been acquired through voluntary cession:

Though the Indians are acknowledged to have an unquestionable, and unquestioned right to the lands they occupy, until that right shall be extinguished by Certificate Stock Photo | Istock, a voluntary cession to our government [. . Sample - Word Templates! .]. Granted, the term voluntary cession is a euphemism for the extremely aggressive campaign of coercion through which Indian land cessions had been obtained. Certificate In Japanese Stock! As Burke explains, In theory, the Cashier's University, Government treated with the tribes as sovereign nations, purchasing only the lands they chose to sell and guaranteeing forever their title to Photo | Istock, the land they chose to Engineering Report For Traffic, keep. In practice, the constant encroachment of white settlers, which the state government would not and the federal government could not prevent, made a mockery of Indian sovereignty by forcing tribes to sell lands they wanted but could not peacefully keep. [. . .] Because the Indians, under pressure, usually sold the lands that the settlers demanded, the Medical Certificate In Japanese Stock, President, the Congress, and Sample Agreements - Word Templates the Supreme Court could maintain the formal position that cession had been voluntary. (150) The slippage from the conquest defense is significant, however, in that it reveals Marshall's struggles, through the course of the trilogy cases, to construct a spin about past land title acquisitions capable of Certificate Stock 519891659 | Istock supporting future encroachments at an even more vigorous pace. (22) By the third decision, the 1832 about-face Worcester , Marshall seems to have relinquished M'Intosh's defense of war-based conquest rights completely, as he observes that defensive war alone seems to have been contemplated and [t]he power of war is given only for defence, not for conquest. The stress cracks from Office straddling legal and world-opinion forums were now beginning to show. (23) Perhaps the most compelling testimony, however, to the fact that land title had historically been transferred through purchases and treaties, not conquest, comes from the Cherokee Nation itself, in its December 18, 1829, written memorial to Congress, prior to Medical Certificate In Japanese Photo 519891659, the Cherokees' fruitless appeal to the Supreme Court: In addition to 519891659 | Istock, that first of all rights, the right of inheritance and peaceable possession, we have the faith and pledge of the United States, repeated over and over again, in treaties made at various times. [. . .] If we were but tenants at will, why was it necessary that our consent must first be obtained, before these Governments could take lawful possession of our lands? The answer is obvious.

These Governments perfectly understood our rights—our right to the country, and our right to self Government. Medical In Japanese Stock Photo! [. . .] The undersigned memorialists humbly represent, that if their interpretation of the treaties has been different from that of the Government, then they have ever been deceived as to how the Letters For Her - Page, Government regarded them, and what she has asked and promised. Moreover, they have uniformly misunderstood their own acts. (rpt. in Krupat 170-72) Likewise, this passage from their November 5, 1829, memorial establishes that the Cherokees' relationship with Great Britain prior to the colonies' independence had most certainly not been within the constraints of In Japanese 519891659 conquest: It is Accomplishment Based Resume Example | Resume Cv Cover evident from facts deducible from known history, that the Indians were found here by the white man, in the enjoyment of plenty and peace, and all the rights of soil and domain, inherited from their ancestors from time immemorial, well furnished with kings, chiefs, and warriors, the bulwarks of Medical Certificate In Japanese Stock 519891659 | Istock liberty, and How To Summary Statement: 13 Steps Pictures) the pride of Medical Certificate Photo their race. Great Britain established with them relationships of friendship and alliance, and at no time did she treat them as subjects, and Letters as tenants at will, to her power. In war she fought them as a separate people, and they resisted her as a nation. In peace, she spoke the language of friendship, and they replied in the voice of independence, and frequently assisted her as allies, at Photo | Istock their choice to fight her enemies in their own way and discipline, subject to the control of their own chiefs, and unaccountable to European officers and military law. Such was the Engineering Investigations, connexion of this nation to Medical Certificate Stock Photo, Great Britain, to wit, that of friendship, and not allegiance, to Archives Templates, the period of the declaration of Independence by the United States [. . .]. Certificate In Japanese | Istock! (rpt. in Krupat 164-69) Accordingly, the doctrine of conquest, to the victor go the Resume | Resume Letter, spoils, did not quite match the history of Euro-Indian relations in the United States. Conquerors do not buy the land from the conquered nor engage them as allies in war. Marshall rose to the challenge of Medical Photo | Istock converting purchase into conquest by bumping out a new and How To A Resume Statement: Pictures) different rule of conquest to justify the federal government's claims on Indian land title.

Justification for the New and Different Rule of Certificate Stock Photo 519891659 | Istock Conquest. (24) Marshall justifies the United States Americans' new and different rule of conquest in M'Intosh essentially by paying native peoples the back-handed compliment of being too brave [. . .] high spirited [and] fierce to conquer by any legitimate means. The way conquest is supposed to work, he says, is that, The old and new members of the society mingle with each other; the distinction between them is gradually lost, and they make one people. Where this incorporation is practicable, humanity demands, and a wise policy requires, that the rights of the conquered to property should remain unimpaired; that the new subjects should be governed as equitably as the old, and that confidence in their security should gradually banish the painful sense of Accomplishment Resume Example | Resume Letter being separated from their ancient connexions, and united by force to strangers. Marshall's reference to traditional conquest leaving the Medical Certificate In Japanese Stock Photo | Istock, conquered peoples' rights [. . .] to property [. . .] unimpaired seems inconsistent with reasoning purporting to justify seizure of property title claim on the basis of conquest. Nonetheless, note that the manner in which Marshall supports his new rule of conquest launches him back into the discovery-rule defense: But the tribes of Indians inhabiting this country were fierce savages, whose occupation was war, and whose subsistence was drawn chiefly from the Medical In Japanese Stock 519891659 | Istock, forest. To leave them in possession of their country, was to leave the country a wilderness; to govern them as a distinct people, was impossible, because they were as brave and high spirited as they were fierce, and were ready to repel by arms every attempt on their independence. Again, Marshall is relying on the Western, medieval principle that non-Christian, non-agricultural peoples could legally and should morally be removed from | Istock their land and Stock Photo 519891659 spiritually rehabilitated. The Europeans, he finds, had no choice but to forge a new, albeit cowardly, way of conquest that the new United States government was bound to follow:

The law which regulates, and ought to In Japanese Stock 519891659, regulate in general, the relations between the conqueror and conquered, was incapable of : Rice University application to a people under such circumstances. The resort to some new and different rule, better adapted to the actual state of things, was unavoidable. Here is where the truly virulent damage of M'Intosh was injected into the United States legal system — and hence, our national ideology — for Medical In Japanese Stock Photo 519891659 | Istock, here, Marshall is codifying a new rule of justifiable deceit. (25) Unlike the valued and time-honored words that Justice Marshall enshrines in M'Intosh to support extinguishment of the Indians' human rights — words like discovery, conquest, and civilization — the words framed in those innumerable treaties negotiated with the native peoples assuring them security and sovereignty within their territories forever, along with the allied friendship of the federal government, were cheap, disposable, and temporary. For example, Justice Thompson's dissent to the Cherokee Nation v. State of Georgia decision cites a provision of the Hopewell Treaty of 1785 that assured signatory tribes there was no truth to allegations made by enemies of the United States [. Accomplishment Based Resume Example | Resume Cv Cover Letter! . .] that it is the design of the states to extirpate the Certificate In Japanese Photo, Indians, and take possession of Photo 519891659 | Istock their country. The peace medals, the treaties, the solemn meetings with presidents — Marshall is acknowledging and tacitly approving the fact that none of these meant what they were portrayed to mean. (26) In Worcester , Marshall gives greater recognition to the strategy of subterfuge through which native peoples were now being determined by the highest court of the country to have been conquered: Fierce and warlike in their character, they [the Indians] might be formidable enemies, or effective friends. Instead of In Japanese 519891659 | Istock rousing their resentments, by asserting claims to their lands, or to dominion over their persons, their alliance was sought by Accomplishment Resume Example, flattering professions, and purchased by rich presents. [. . .] Not well acquainted with the exact meaning of words, nor supposing it to Medical Photo | Istock, be material whether they were called the subjects, or the children of their father in Love Letters, Europe; lavish in professions of Medical Photo 519891659 | Istock duty and affection, in return for the rich presents they received; so long as their actual independence was untouched, and their right to self government acknowledged, they were willing to profess dependence on the powers which furnished them supplies of which they were in Cashier's Faqs : Rice, absolute need, and restrained dangerous intruders from entering their country: and this was probably the sense in which the term was understood by them. At this point, Marshall's history of Euro-Indian relations conforms more precisely to what the Cherokees describe in their Memorials, but, of course, the damage is Certificate done.

The Legacy and Significance of the New and Different Rule (27) The legacy of M'Intosh , on its own and in the context of the trilogy cases, is of the veritable forked tongue. The new and different rule Marshall approves is that saying one thing and doing another is a sanctioned expedient for Agreements Archives - Word, furthering national interests. With the new rule come ancillary principles of exclusion and oppression, and a model for a privileged, bi-level application of In Japanese | Istock law. Under Marshall's new rule, agreements securing any rights of marginalized peoples are temporary markers on the next boundaries to be surreptitiously seized and reset by imperialistic or nationalistic bulldozers. Evidence of this fact can be seen in the continuing struggles of Native Americans to Office Faqs University, retain and utilize even their most fundamental rights to In Japanese Photo 519891659, self-government left to them by the Marshall trilogy. Continued judiciary erosion of those rights prompted hearings before the Senate Committee on Indian Affairs in February 2002. Professor David Getches of the University of Colorado was among the legal scholars who testified to petition congressional intervention:

Indian rights and Indian sovereignty are essential in a government-to-government relationship that goes all the way back to the founding of the nation. If the For Traffic Accident, Court understood this and appreciated this grounding in original intent, Indian laws could be put back on track by the Court itself, but this seems unlikely. The Court's primary mission has little to do with Indian law. It will be up to Congress to reverse this trend. Medical Certificate In Japanese Stock! (Hearing) As Committee Vice-Chairman Ben Nighthorse Campbell said at the close of those hearings, in response to Getches' testimony, with a succinctness that can only come from aged exasperation, [. . .] when I hear comments like yours [. . .] I do get mad [. . .] at For Traffic Accident [. Stock Photo! . .] the way we have treated Indians in the history of Cashier's University this country. It seems to me that they should have two sets of rights: that of being Native Americans as given in the treaties and that they inherit being an American, like any other American. Stock Photo | Istock! Yet, we see a constant erosion of their rights on both sides of that equation. (28) Thus it seems that the Report, cultural bias of white, Christian supremacy embedded in U.S. ideology with Marshall's endorsement of discovery and conquest principles continues its active destruction of native people's human rights. It must be noted that any implied characterization of the Indians' demise as inevitable due to some perception of Medical Certificate Stock Photo 519891659 inferiority on their part is How To A Resume Pictures) belied by the events of record in the trilogy cases. Medical Certificate! Krupat's analysis of the tenor of the Cherokee Memorials is compelling here:

The Cherokee memorialists will not allow their dispossession to be seen as savagist ideology would have it, as inevitable or necessary, neither God's will, nor Nature's law. Rather, should they be translated west of the Mississippi, such an outcome would be the result of no more than the force of American imperial power. (161) Indeed, the political savvy and eloquence of the Cherokee leaders, apparent in those excerpts from Photo | Istock their Memorials previously quoted, deeply affected Justice Joseph Story, who co-signed Justice Thompson's dissent to the majority opinion authored by Marshall in the Cherokee case. Some measure of Story's regret regarding the government's treatment of the Cherokees can be seen in this excerpt from a January 13, 1832, letter to his wife: At Philadelphia, I was introduced to two of the chiefs of the Cherokee Nation so sadly dealt with by the State of Georgia. They are both educated men, and conversed with a singular force and propriety of language upon their own case, the law of which they perfectly understood and reasoned upon. I never in my whole life was more affected by the consideration that they and all their race are destined to destruction. And I feel, as an Medical Stock Photo American, disgraced by our gross violation of the public faith towards them. I fear, and greatly fear, that in the course of Providence there will be dealt to us a heavy retributive justice. Medical Certificate In Japanese Stock! (qtd. in In Japanese Stock, Lubbers 65) Examination of this passage shows Story falling prey to the all-too-human tendency to at first shift culpability (to the State of Georgia), only to be crushed, within the same breath, by | Resume, the recoil of such suppression, since the Medical, gross violation of the public faith towards them rests, as he says, with all Americans.

(29) Greed wrote the new rule of conquest Marshall endorsed in Johnson v. M'Intosh . He could not come out and say it, but others before and after him have duly noted the emperor's nakedness in this regard. As Pagden suggests, our national origins lie in our European ancestors' melding of Christianly avaricious desires: [The American colonies] had been created out of a seemingly insatiable European need for precious metals, and an ambition, which the Ancients could scarcely have understood, to change the religious beliefs of their autochthonous inhabitants. (11) Certainly, the blurring of gold and God in medieval discovery and conquest discourse was not overlooked by all people of the times, though. In his In Defense of the Indians , for Love Letters, example, the 16th century Dominican friar Bartolome de las Casas excoriates Spain's use of forced conversion of native peoples to Christianity, pursuant to the discovery rule, as a means to seize their lands: All this drags innumerable souls to ruin and blocks the service of spreading the Christian religion by closing the Certificate, eyes of those who, crazed by blind ambition, bend all their energies of mind and Write A Resume Summary Statement: (with Pictures) body to In Japanese, the one purpose of gaining wealth, power, honors, and dignities. For the sake of these things they kill and destroy with inhuman cruelty people who are completely innocent, meek, harmless, temperate, and quite ready and How To A Resume (with willing to receive and embrace the word of God. (26)

Long before the Medical In Japanese Stock Photo 519891659, trilogy cases, greed had become sacralized in the foundations of United States American ideology. In this respect, Williams is right; M'Intosh is a fait accompli formality. Kades makes the very good point, in support of his cost-efficiency view of M'Intosh , that, If it were cheaper to be more brutal, then Europeans would have been more brutal (Dark Side). However, from the history of Euro-Indian relations Marshall uses to justify his new and different rule, we can see that Marshall, at least, had concluded the Love Letters For Her 3, native peoples could not have been defeated, at least when their numbers were strong, on brute force alone. (29) Marshall's new rule mythologized a false and schizophrenic memory of Euro-Indian relations in the United States that continues to twist and shift through our popular culture today. One of the new, 2004 United States nickel designs, for example, incorporates the 1801 Thomas Jefferson peace medal image of. [. . .] two hands clasped in friendship — one with a military uniform cuff, symbolizing the American government, and the other with a silver band adorned with beads and 519891659 | Istock a stylized American eagle, representing the Based Resume | Resume, Native American community with whom the United States sought good relations. (New Nickels)

That handshake, the international symbol of partnership and good will between respected equals, was interpreted by Certificate In Japanese Stock 519891659 | Istock, Marshall as a justifiably deceptive measure toward New World conquest and land seizure. The seeding of our collective memory with such contradictions hampers our ability to recognize, as Justice Story did, the gross violation of the public faith committed toward Native Americans. If we cannot see the treatment of Love Letters Native Americans for what it is and has been, we surely cannot see how their degradation degraded all of us, or how the U.S. government's endorsement of deceit and treachery in Certificate In Japanese Stock Photo 519891659, furtherance of national interests set in motion, along the lines that Silko's Ceremony suggests, an almost hypnotic suggestion of Certificate In Japanese Stock Photo 519891659 self-perpetuating avarice in our national ideology. (30) Pagden sees the United States' ambitions for Medical Stock Photo, global democracy as the third wave of the : Rice, Imperium Romanum-turned-Imperium Christianum ideology (24) that fed our originary colonizing discourse: The modern United States still pursues very much the same political ideology with respect to their relationship with the In Japanese 519891659, rest of the world. If the European settlers exported to America one notion of Letters - Page 3 a civitas, sustained and enforced by a corresponding vision of a Christian imperium, their descendents have created a universal order based upon another, but no less encompassing, conception of civility: democracy, an ideology which is quite as pervasive, and certainly as demanding as its ancient (and its Christian) ancestors. (199)

The internal manifestations of Certificate In Japanese Stock 519891659 our present-day Imperium Democraticum, as it were, are no less pervasive, demanding, or exclusionary. As Pagden says, the model for Love For Her, U.S. democracy relies for its civilizing machinery upon an exalted vision of commerce (199-200). Satisfaction of this vision's demands currently forces stratifications across race, class, and culture lines that limit many United States Americans' abilities to achieve economic progress and, in some cases, survival. Medical Certificate In Japanese Stock 519891659! Greed is an ancient, primitive impulse that only truly became dangerous when it masked itself in the guise of civilization and Christianity. The decisions in Based Example | Resume Cv Cover Letter, the Marshall trilogy adopted the guise into United States democratic ideology. Until we can see and begin to rectify the guise's first harm to the Native Americans, we cannot begin to arrest its continuing damage to our culture and restore our founding, democratic principles toward fulfillment of their original promise. Burke, Joseph C. The Cherokee Cases: A Study in Medical In Japanese Stock Photo 519891659 | Istock, Law, Politics, and Morality.

Native American Law and Colonialism, Before 1776-1903 . Ed. John R. Wunder. New York: Garland, 1996. 136-67. Casas, Bartolome de las. In Defense of the Indians . Ed. Trans. Stafford Poole. DeKalb: Northern Illinois UP, 1974. Cherokee Nation v. State of Georgia.

30 U.S. 1. For Traffic Accident! U.S. Supr. Ct. 1831. Lexis-Nexis. 23 Sep. 03. Deloria, Vine, Jr. American Indians in Stock 519891659 | Istock, Historical Perspective. Native American Law and Accomplishment Based Example | Resume Letter Colonialism, Before 1776-1903 . Ed. John R. Wunder.

New York: Garland, 1996. 123-34. Deloria, Vine, Jr., and David E. Wilkins. Tribes, Treaties, and Constitutional Tribulations . Austin: U of In Japanese Stock Photo Texas P, 1999. Fletcher v. Peck. 10 U.S. 87. U.S. Supr. Ct. 1810.

Lexis-Nexis. 11 Sep. 03. Hearing Before the Committee on Indian Affairs. United States Senate, One Hundred Seventh Congress, Second Session on Concerns of Recent Decisions of the U.S. Supreme Court and the Indian Tribal Governments in America. 27 Feb. 02. U.S.

Government Printing Office. 24 Oct. 03. http://purl.access.gpo.gov/GPO/LPS20968. Johnson, Herbert Alan. John Marshall. - Word! The Justices of the United States Supreme Court: Their Lives and Major Opinions . Vol. 1. Eds. Leon Friedman and Fred L. Israel.

New York: Chelsea, 1997. 181-99. Johnson v. M'Intosh. Medical Certificate In Japanese Stock 519891659! 21 U.S. Report For Traffic Accident! 543. U.S. Supr. Ct. 1823. Certificate In Japanese Stock Photo! Lexis-Nexis. How To Write (with Pictures)! 21 Oct. 03. Kades, Eric. The Dark Side of In Japanese Photo 519891659 | Istock Efficiency: Johnson v. M'Intosh and the Expropriation of American Indian Lands. U of Pa. Law Review 148 (Apr.

2000):1065-1190. Lexis-Nexis. 23 Sep. 03. ---. History and Interpretation of the Love For Her - Page, Great Case of Johnson v. M'Intosh . Law and Photo 519891659 | Istock History Review 19.1(Spring 2001): 67+. 11 Sep. 03. http://www.historycooperative.org/journals/lhr/19.1/kades.html. Krupat, Arnold.

Ethnocriticism: Ethnography, History, and 519891659 | Istock Literature . Certificate Stock Photo 519891659 | Istock! Berkeley: U of California P, 1992. Lubbers, Klaus. Born for the Shade: Stereotypes of the Native Americans in United States Literature and the Visual Arts, 1776-1894 . Amsterdam: Rodopi, 1994. Pagden, Anthony. Lords of All the Accomplishment Based Example | Resume, World: Ideologies of Empire in In Japanese Stock 519891659, Spain, Britain, and France c. 1500 – c. 1800 . New Haven: Yale UP, 1995. Silko, Leslie Marmon. Ceremony . New York: Penguin, 1977. Washburn, Wilcomb E. The Moral and Legal Justifications for Faqs : Rice, Dispossessing the Indians. Medical Stock 519891659 | Istock! Seventeenth Century America: Essays in Colonial History . Ed. James Morton Smith.

New York: Norton, 1972. 15-32. Williams, Robert A., Jr. The American Indian in Western Legal Thought: The Discourses of Conquest . New York: Oxford UP, 1990.