Formalities †Perfect/Imperfect Trust Essay - Free Essay Example

Sample details Pages: 9 Words: 2612 Downloads: 8 Date added: 2017/06/26 Category Law Essay Type Case study Did you like this example? Formalities – Perfect/Imperfect Trust Introduction The question in this case refers to the creation of a trust, i.e. the formalities that are required. In the case of Serena, she has created a trust that holds the property in trust for Alice for life and then the remainder goes to Alices children. Don’t waste time! Our writers will create an original "Formalities – Perfect/Imperfect Trust Essay" essay for you Create order On the death of Serena, there is a valid will where Alice gets all of the property and there is no interest for Alices children. Therefore, the following advice is going to identify a trust is in place, which will ensure that the property transfers to the children. The Creation of a trust The case of Milroy v Lord identifies a perfect trust, which includes; 1) a deed of the trust; and 2) transfer of the property following all formalities . Therefore, in the case of the trust created by Serena, both the property Hillside and the Jane Austin books have the capability of being part of a perfect trust. However, in the case of the land there are additional formalities, which will be discussed later. At this point there is a perfect trust that related to the books, because this is a case of a perfect trust, because there is both declaration and transfer of the books to the trustees . The share certificate and cheque are not in the deed documents, but have been transferred to the trustee with the declaration to be added to the trust. This is not a full deed, but applying the case of Milroy v Lord it is a declaration plus transfer of the property, which means that it has a capability of being a trust under Neville v Wilson and Vandervell v IRC . The argument still rem ains on whether the formalities have been fulfilled in the case of the land, shares and cheque which can be a contentious subject. The need for formalities? The case of Neville v Wilson held that the formalities of a trust need not be in writing if it can be shown that intention is present; however, problems have arisen in showing this intention, which is why the Statute of Fraud 1677 introduced the need formalities A similar argument that there is no need for formalities was expressed in the case of Walsh v Lonsdale in 1882; however as it can be seen in 1925 the formalities were required for all property under a trust. However, it seems to be that the argument for these formalities is that they clarify the intention of the settlor. S. 53(1)(c) of the Law of Property Act 1925 (LPA 1925) is now the defining piece of legislation for where trust formalities can be identified. In the case of Timpsons Executers v Yerbury it was held that the formalities of a trust can be identified in the written disposition of the trust and the transferring of the property to the trustees. The interest in respect to Uncle Joes Trust is an equitable interest; therefore should comply with s. 53(1)(c). As this trust is in the original deed then it complies with the formalities of 53(1)(c) an like the Jane Austens novels form a perfect trust, as the deed identifies both the intention and the transfer of the equitable interest to the new trust. The shares are another example of an equitable interest; however as will be discussed later may not form a perfect trust due to deficiencies in formalities. In the case of Alice some of the property has been adequately transferred through deed and transfer to the trustees; however there remain questions if the whole trust can be properly administered. If one considers the case of Neville v Wilson the indication is that the requisite intention is enough. However, the problem is that Neville v Wilson is in direct contradiction with s. 53(1)(c) of the LPA 1925, which states that a disposition of an equitable interestà ¢Ã¢â€š ¬Ã‚ ¦ subsisting at the time of the disposition, must be in writing signed by the person disposing of the same, or by his agent thereunto lawfully authorised in writing or by his will. This would mean, the prima facie facts of the case, are that all of the property would have to be in the initial trust deed in order for it to be transferred on trust to Alice; whereby anything outside of it would return to the estate. However, it is not as simple as this. The case of Neville v Wilson needs to be reconciled and there are additional formalities required in respect to shares and land. The Transfer of the Land: In the case of the land s. 53(1)(b) states that a declaration of trust respecting any land or interest therein must be manifested and proved by writing signed by the person who is able to declare such trust or by his will. Therefore, the land must be transferred by deed to the trustees, which has been done in the case of Hillside; therefore it would indicate that as soon as the deeds to the property were transferred to the trustees the land has been moved into a trust. The exact route of transfer has been identified in the Law of Property (Miscellaneous Provisions) Act 1989 s. 2, which identifies that the deed needs to be properly signed by each party in the transfer . This means that the trustees must have signed for the exchange and the deeds in this case. The implication of this is not clear as the deed document has been transferred to the trustees, but the question is whether this deed shows the trustees as the legal owners, if not then the formalities have not been fulfi lled and the property has not passed, as per the case of Firstpost Homes v Johnson . The Shares: In the case of the shares, as an equitable interest, s, 53(1)(c) should be followed, which means that the shares should be deeded and in writing, as well as entered into the company books as registration of change . In the case of shares the formalities are important, because like land there are external legal formalities that must be complied with. Therefore, if the settlor had not begun the steps to transfer the shares, with the company, then regardless of whether there was an intention and the share certificates were placed in the hands of the trustees the constitution had not been fulfilled . This was the approach that has been taken in Grey v IRC and Oughtred v. IRC ; however Vandervell held that if the deeds and the shares had been transferred to the trustee then it will be implied that the trust is perfect. A similar approach was taken in Re Rose and Hunter v Moss where transferring the correct information to the company was enough, as it was in the hands of a third pa rty. The problem in this case is that there is no formal deed, even though the shares have been transferred. This means that the trust is not properly constituted in respect to the shares and would go back to the estate. The Cheque As this is a chattel the case of Neville v Wilson will apply, because the requirements of Milroy v Lord have been fulfilled and a perfect trust will be implied. Duty of the Trustee and Remedies: Introduction: The case of Alan relates to the duty of a trustee, a breach of trust and the equitable remedies that are available. Alan is a director of a company that holds a trust for the holidays that it sells on behalf of Go Ltd, which is separated from Buyit Nows accounts. The question that is raised is whether the actions of Alan, by; 1) failing to put the money into BuyIt now are accounts; and 2) taking money out of Go Ltds account to purchase a gift for his girlfriend, are a breach of trust. Then it will consider if it is a breach of trust what remedies are available to reclaim the lost money. The first part of this question will identify the duty of the trustee and the implications for the other directors of Buyit Now. Then it will consider what remedies are available to Go Ltd to retrieve the lost money. Duty of the Trustees: The administration of a trust is set out by the Trustees Act 2000 (TA 2000). Section 1 of the act defines the duty of case requirements that the trustee must adhere to, which is to exercise such skill and care as reasonable in all circumstances. The implication of this is that there is a minimum test for the private trustees as a reasonable trustee . However, s. 1 TA 2000 put the decision of Speight v Gaunt into statutes, highlighting that this is a higher duty of case for any trustee with special knowledge or experience should take all those precautions which an ordinary prudent man of business would take in managing similar affairs of his own . This means that in the case of Alan and the directors of the company they owe a standard of care of a company director . It is also important as this trust has been set up in the course of the companys business that s. 1(b) of the TA 2000 will apply, which means that the level of the duty of care will be that which is reasonable to e xpect of a person acting in the course of that kind of business . It is important to note that the Nestle Case identified that a trustee cannot be held in breach of trust for a mere error of judgement. It must also be identified that as this is a company/industry arrangement there may be an exclusion clause in place that limits liability. This is a perfectly valid approach and upheld in the case of Armitage v Nurse , which states [n]o trustees shall be liable for any loss of damage which may happen to a trust fundà ¢Ã¢â€š ¬Ã‚ ¦ at any time from any cause whatsoever unless such loss shall be caused by his own fraud. However, in the case of Alan there is more than a mere error of judgement and it is highly likely that his acts would be classed as: 1) Wilful deceit, in regards to the monies that were never transferred; and 2) Recklessness in regards to the monies that were taken from Go Ltd to pay for a yacht for his girlfriend This was confirmed in the case of Re City Equita ble Fire Insurance Co as either a consciousness of negligence or breach of duty, or a recklessness in the performance of a duty . Therefore, the acts of Alan could not be limited by an exclusion clause. Remedies: There is a problem with this case, which is that the company is the trustee and each of its directors are to act personally . To follow on from this each of the trustees, as BuyIt will be a corporation trust for Go Ltd, as it is an industry association it must be assumed that BuyIT has capability in its Articles of Association. This means that one trustee (Director) cannot be liable for the actions of another unless they facilitated, by act or omission, the breach . This means that the company cannot be held in breach, only Alan unless it can be shown that the other trustees were put on notice . However, the indication is that this is not the case. This raises a problem in regards to receiving the monies from the administrators of BuyIt, because as BuyIt as a whole was not in breach there is no claim against the company. As the company acts as a trustee the dishonesty of Alan cannot be imputed to the other directors in the company. This means that there is only a personal bre ach of Alan in the trust. Rather, it must be against Alan personally for breach of trust. Alan is personally wealth then it may be the case that if all of the losses can be reclaimed in an action for personal breach of trust . However, as his wealth has depleted it may be that not all the monies can be recovered this way. Therefore, the remedy of tracing is available, as per Re Diplock . The case of Foskett v McKeown identified that tracing is not a remedy, but a process to identify the lost property. In the case of Gos lost money the money transferred to buy the yacht is easy to trace , but as the yacht is destroyed then it is of no worth. This means that it may be the case that personal action against Alan is the only available option. However, according to Re Diplock it will be able to trace the money from Alans girlfriend as she benefited from the act, as well as she may have known of the act. If Fiona does know then she is as liable as Alan . It is possible that she di d not know of the act; however as she received the gift and it can be traced back to Fiona. It is possible that an innocent third party can be approached to claim the lost funds, but it may only be limited to estates . Even so the case of Butler v Broadland and Re J Leslie Engineers Co Ltd have indicated this act may be extended to other fiduciary relationships, which there are indications that in the case of insolvency there would be strong case. This is because the money to claim from the trustee that has breached the trust, just like in the case of a deceased settlor, is no longer available. In this case it would be fair to pursue the innocent third party. In the case of the monies it is mixed with that Buy Its, which means that it may not be possible to trace as a mixed, as opposed to an unmixed account . However, it is identified that if mixed or not it must continue to exist unless it has been used to pay a debt or completely depleted . Therefore, as the company is ba nkrupt it is more than likely that the funds are now untraceable from BuyIt, which means that personal action is only available. References: 1) Clemants and Abbass (2008) Complete Equity and Trusts: Texts Cases and Materials, OUP 2) Edwards N. Stockwell (2002) Trusts and Equity, Longman 3) Edwards N. Stockwell (2010) Equity and Trusts 9th Edition, Longman 4) Hayton Mitchell (2005) Commentary and Cases on the Law of Trusts and Equitable Remedies 12th Edition, Sweet Maxwell 5) Hudson, A (2009) Equity and Trusts 4th Ed, Routledge Cavendish 6) Burn and Virgo (2002) Maudsley Burns Trust and Trustee, Case Materials, 7th Ed, OUP 7) Law commission (1999) 7th Programme of reform No 259 8) Law Commission in Trustees Powers and Duties (Law Com, 1999, Report No. 260) 9) Moffat, G, Bean, Dewar (2005) Trusts Law: Texts and Materials 4th Ed. CUP 10) Pearce, Stevens Barr (2010) The Law of Trusts and Equitable Obligations5th edition, OUP 11) Watt, G (2010) Equity and Trusts Directions 2nd Ed, OUP 12) Watt, G (2010) Equity and Trusts 4th Ed, OUP Cases: 1) Milroy v Lord (1862) 4 De GF J 264 2) Neville v Wilson [1997] Ch 144; 14-15; 3) Vandervell v IRC [1967] 2 AC 291 4) Walsh v Lonsdale [1882] 21 Ch D 14 5) Timpsons Executers v Yerbury [1936] 1 KB 645 6) Firstpost Homes v Johnson [1995] 4 All ER 355 7) Grey v IRC [1960] AC 1 8) Grey v Oughtred [1960] AC 206 9) Re Rose [1952] 1 All ER 1217 10) Hunter v Moss [1994] 3 All ER 215 11) Speight v Gaunt (1883) 9 App Cas 1 12) Walker v Stones [2001] 2 WLR 623 13) Nestle v National Westminster Bank [2000] WTLR 795; cf 14) Armitage v Nurse (1998) Ch 241 15) Re City Equitable Fire Insurance Co [1925] Ch 40 16) Royal Brunei Airlines v Tan (1995 2 AC 378) 17) Brinks Ltd v Abu-Saleh (1995) WLR 1478 18) Styles v Guy (1849) 19 LT Ch 185 19) Target Holdings v Redfern [1995] UKHL 10; Jackson v Dickinson (1903) 1 Ch. 952 20) Re Diplock [1948] Ch. 465 21) Foskett v McKeown [2000] 3 All ER 97 22) Taylor v Plumer (1815) 3 M S 562 23) Ministry of Health v Simpson [1951] AC 251 24) Banque Belge po ur lEtranger v Hambrouk [1921] 1 KB 321 25) Agip(Africa) v Jackson [1992] 4 All ER 385 26) Lipkin Gorman v Karpnale [1992] 4 All ER 512

Report On The Distribution Of Values - 2903 Words

ASSIGNMENT # 5 AMAN VIJ ADEENA MIRZA AMIT KUMAR TRIPATHY SECTION A Questions 1. (a) Explore the data. Report on the distribution of values in the attributes and how they individually relate to the outcome of interest (dependent variable). All the attributes are combination of categorical and numeric values and cover varied ranges. Each attribute was studied along with analyzing histograms, scatterplots and log-scaled graphs. The findings are listed below with the graphs of each attribute distribution in Section B. (i) Borrower’s age (Bo_Age): Borrower’s age shows an overall right skewed distribution with a maximum at 36. The distribution for only defaulters shows a†¦show more content†¦(vi) Borrower’s total monthly debt expense (Tot_mthly_debt_exp): Total monthly debt expense of borrower’s has a range from 0 to 17225 with an average of about 1745. 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Why was the Cuban Missile Crisis a turning point in Cold War Relations Free Essays

The Cuban missile crisis had relieved the tensions and possibilities of a nuclear war between the two superpowers. The USA had attempted to destroy Castro’s regime, with the April 1961 Bay of Pigs invasion where 1,400 Cuban rebels attempted to invade the island. The USSR had come to the aid of Cuba, providing nuclear missiles aimed at major cities in USA. We will write a custom essay sample on Why was the Cuban Missile Crisis a turning point in Cold War Relations? or any similar topic only for you Order Now The USA ordered a naval blockade to prevent Soviet ships from transporting the missiles to Cuba. The threat of a nuclear war was apparent and eventually the two superpowers made an agreement stating the removal of the US missile sites in Turkey in exchange for the USSR missile sites in Cuba, aborting the possibility of nuclear annihilation. The two superpowers were at the brink of a nuclear holocaust but the crisis made them realise the policy of brinkmanship was dangerous so they abandoned it, which is why the crisis is viewed as a turning point. The crisis had also improved US-USSR relations. USA and the USSR were prepared to avoid a future crisis after they realised the policy of brinkmanship nearly caused a nuclear war. A telephone hotline was set up between the White House and the Kremlin to provide swift communication and in August 1963, a Test-Ban treaty was signed, outlawing the test of nuclear weapons. Therefore, the Cuban Missile Crisis was a turning point in Cold War relations because the two superpowers developed a friendship, putting the effort in to reduce risk of a recurrence. On the contrary, it could only be described as a turning point in this period because they were reducing the risk of a crisis but they did not preserve their relations later on. The crisis had also led to world peace. The superpowers had avoided a nuclear war and in doing so prevented the destruction of the world. The USA did not bother Cuba again and the Soviet missiles were removed from Cuba. The superpowers realised that peaceful negotiations can help solve predicaments and both leaders were credited for their part in maintaining world peace. The crisis is a turning point as before, the world wasn’t peaceful with USA trying to rid the world of communism and the relations between superpowers were negative. However, in this time period, they had restored world peace by negotiating terms. The Cuban Missile Crisis influenced Cold War relations strongly. The two superpowers had now realised the dangers of adopting the policy of brinkmanship and made an effort to avoid a recurrence of the crisis again by understanding the importance of swift communication. How to cite Why was the Cuban Missile Crisis a turning point in Cold War Relations?, Essays

Educational Theory in Clinical Environment-Samples for Students

Question: Discuss about the Educational Theory in Clinical Environment. Answer: Introduction Educations which can also be called learning is described as a process where one acquires knowledge and start having different thoughts and feeling about the new skill and develop an attitude towards it. It helps individuals to respond well to demands in clinical environment, that is, if for the sick and their families, they will be able to understand ways of improving their health and follow the prescriptions from a medical practitioner. For the learning students in the field of medicine, they are able to get information and all skills required in the medical field. Educational theory offers a different point of view on how learning takes place and what attracts people towards it (Emerson 2007). Learning theory is very crucial in education as it helps in creating a good environment for learning, improving education system and harmonizing it. It is also useful in psychology guidance. Medical professionals are therefore advised to use these theories often especially when dealing with the sick and other clients, during trainings and during other health programs. There are different types of learning theories which include behaviorism, cognitive, humanism, but in this paper, we will be discussing one of the theories, how learning theories is applied to clinical sector, principles to learning and ways that facilitate learning in clinical environment Behaviorism This is a type of learning is believed to be a change in behavior which is visible and this happens when there is a communication and response (Siemens 2014). There are two types of behaviorism; methodological which describes psychology as a science which helps predict and control ones behavior, (Slavin Davis 2006) while radical behaviorism which says that behaviors are inborn and is determined by genes of a particular organism This theory assumes that all change of behavior is achieved from the environment and that behavior is the final product of event response. Learning can be simple because by not considering what is happening in an individuals mind, observation and responses can tell you there is behavior change and therefore the final behavior is achieved by continuous learning (Ormrod,2011). This has a great impact on learners responses which can be positive or negative. The transition of behavior is achieved through practice and much of these are based on respondent conditioning and operant conditioning. Respondent conditioning deals with conditions of stimuli in that when a neutral stimulus is joined with a naturally occurring and unconditioned response, a new conditioned response occur and this happens without the knowledge of an individual. This creates a good clinical environment and improves the performance of the medical practitioners. This conditioning can also be used in eliminating a previously learned behavior, for example, fear/ anxiety or any other behavior and in this case psychologists have devised ways to help counter that by use of; Systematic desensitization is used by psychologists to minimize fear and anxiousness in patients/clients. This is done by teaching patients with anxiety or fear problems the need for relaxation. This technique is used in treating patients who are addicted to drugs. Stimulus generalization whereby first experiences are used to apply to other events, therefore mixture of different events helps people to learn. Spontaneous recovery is a technique used in respondent theory to help in dealing relapse cases whereby a person can go back to past habits when the current conditions seem alike with the past experiences Operant conditioning looks into behavior of an organism and effects that occur after response. There are different responses in this operant conditioning; neutral which comes from the environment and does not cause a change in behavior, rein forcers which increase the change in behavior and punishers which decreases the chance of change of behavior. The main point of doing this is to observe individual reactions and find ways to use to change the behavior. The methods of reinforcement used can be positive or negative (Deci Ryan 201); positive involve giving gifts to enhance action repetitions of a response. A negative method involves removing unwanted events. Different patterns can be used to achieve these reinforcements and they are as follows; Continuous method happens when behaviors occur in an individual or animal, fixed ration happens after occurrence of behavior for a specific number of times. Fixed interval happens when one thing is given priority to achieve one response, variable pattern whereby a behavior is determined after several trials. Variable interval pattern says that after one good behavior is achieved, the others can be tried at different unpredictable time. This theory has some disadvantages because it does not show all kinds of learning, does not explain some learning techniques. Key principles of learning Consequence role- behavior is strengthened by positive and exciting learning effects but it is weakened by unpleasant events. The positive events are called rein forcers while the negative ones are called punishers. Rein forcers are any events that strengthen behavior; it has two categories; primary and secondary. Experiences learning should acknowledge learners past events therefore educators should be able to guide the learners come out of past experiences and gain new skills (Hirsh, et.al 2007) Result- this is the immediate consequences after behavior change and this includes shaping which is a new skills or behavior impacted on learners to achieve the best. Extinction is also a result of change in behavior whereby when learning stops, behavior change declines and almost disappear. Learning in adults needs practical performance of what is being taught so that there is good understanding which helps in behavior change (OConnor 2015). Maintenance- this involves close monitoring and continuation of learning in learners especially the slow learners and those with bad behaviors. Learning should cover every learner including the poor learners so that no one is left behind. Antecedents role- events that follow behavior is important because they give a clear information whether the behavior change need reinforce or punishment. Educators should be able to do follow up in their students to allow better change. Learning should have goals, it should be able to solve a problem; a learner should have something in mind which he/she wants to achieve, a teacher therefore should guide them in setting the goals. Learning is not easy for both young and adults, it needs motivation and the teacher should always guide them and to some point giving them real life scenarios so that they can understand. Learning should have orientation, a sense of self direction and responsibility, a teacher is the one who understands the learners and for the concept to be understood, the teacher knows a way of passing that information to the students, teacher can engage the students in discussion groups to perform some tasks or discuss and share information about a certain idea and by so doing, the teacher will be able to know where to begin in guiding the students. Some ideas can be learned well the through the process. Learning process should be practical; the teacher should take the students through the clinical needs through practical, visiting wards to check on patients, allowing them to do some things and not just seeing or being told about them, this will build their confidence in the area of clinical profession. For a learner to understand an idea there should be continuous learning and practicing (Hirsh, et.al 2007). In learning process, there should be a show of respect to one another, learners should learn to appreciate one another and the ideas thy bring into the learning forum, by so doing it helps someone who might be having a problem or might have faced difficult experiences. In learning, somebodys idea should build someones life hence need for that virtue. Applications of behaviorism theory in clinical environment It helps in psychology guidance by providing the required infrastructure. It should also be used by health professionals during interactions with patients/clients, in health programs. Nurses being the ones to launch and implement processes of training, they should embrace the approach of this learning theory for education to the patients (Emerson 2007). Behaviorism theory applications influence learners reactions in that it can be positive or negative reaction. Bad response can lead to fear. Can be used in treating psychology disorders, finding ways of improvement and changing behavior conflicts. Techniques of change of behavior are used in teaching learners about education and social behaviors in teaching environments. Behavioral objectives are crucial in nursing especially when dealing with mental because it helps the educators in teaching and also in analyzing the performance of the learners as it forms the basic foundation in learning. It has been used to find ways of dealing with chronic illnesses like diabetes, hypertension, and using effective diet programs as per the theory and health procedures. Following up correct diet during treatment is a hard task specially to aged adults; therefore, health professionals should always guide the patient on this so as to comply with the required food procedures. Ways to facilitate learning. Learning in work place help in improving the spirit of learning in clinical environment as it offers great opportunities making learners acquire skills and knowledge in medical field (Bastable 2014). Nursing is one of the essential parts in clinical environment and nurses play a very crucial part in the health sector. They are therefore required to be professionally and academically qualified to perform their duties well.th following methods help in facilitating learning of nurses in the clinical environment; Setting participants and baseline assessments this involve training the nurses as they come in and depending on their qualifications and age so that they are not overtake by time. Study design involves a procedure where individuals who have the same qualifications are tested on some ideas to determine their level of knowledge and skill on the question asked, the outcome will determine who needs further training than the other and by so doing improve learning. Nurses need more knowledge on clinical teachings, skills about critical thinking and ways of communicating so as to deliver their work well and pass clear and legit information to the people they are dealing with. There is need for knowledge in communication so as to handle questions from the students well. There is need for learning in clinical environment to allow easy coaching of learners in the field too because they should be taught and assessed well so that they get the correct content as required in the medical field. Incorporation of developed ideas of professional self has also created a room for learning of nurses (educators and learners) hence improving the relationship between others. In as much as nurses need learning for the sake of coaching the learners, they should also get knowledge on how to handle their own fears and anxiety and also be able to handle students while training them. Learning by participation is a way of improving learning of nurses in a medical field, learning as acquisition involves going back to class hence shortage of workers to attend to patients, but through participation it opens ways to learn while working. Learning through talking has also improved learning in clinical environment in that learners should learn to talk for them to become experts in their field of medicine other than listening to a talk from experts. There are ways in which learning by talking has improved learning and it includes trainee talk, self-talking/thinking aloud, discussions. Conclusion In health education, research which was once done in psychology, nursing and medicine, is used in finding learning experiences from patients, clients, families and at the same time developing teaching and learning experiences to learning students and workers. Despite many explanations of theories and principles in learning, each concept/theory has important direction in learning process. Educators in the clinical environment cannot be able to know everything at once but through learning on day- to- day basis. Psychology and nursing work hand in hand in hand psychology has helped much in health sector and nursing uses its principles, ideas and theories Reference list BASTABLE, SB 2014,Nurse as educator: principles of teaching and learning for nursing practice. Burlington, MA, Jones Bartlett Learning. Deci, EL and Ryan, RM 2010,Self?determination. John Wiley Sons, Inc. Top of Form EMERSON, RJ 2007,Nursing education in the clinical setting. St. Louis, Miss, Mosby, Elsevier. Bottom of Form Hirsh, DA Ogur, B Thibault, GE and Cox, M 2007, " Continuity" as an Organizing Principle for Clinical Education Reform Medical Education.The New England journal of medicine,356(8), p.858. 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