Colonization and domestic violence: Strategies

Colonization and domestic violence: Strategies The correlation between colonization and domestic violence is undeniable given the plethora of scholarly and historical data. The main misconception that exists in this area relates to the belief that the violent aspects of colonization and its associated abuse lay directly at the feet of Westerners or other outside cultures and influences. Domestic violence, in its many forms, is forced upon men, women and children from many sources including people in their own society. In addition to the definitions and correlations of colonization and domestic violence, this paper also discusses the colonization, social structure and abuse of Aboriginal Peoples including the Maori tribe of New Zealand, Native Americans, and the First Nation communities of Canada as well as the diseases thrust upon the colonists by the colonizers. Also examined are the relationships between modern abuse related to colonised cultures and its possible prevention. Domestic Violence The United States Justice Department’s Office on Violence Against Women provides a definition of the various types of domestic violence: We define domestic violence as a pattern of abusive behavior in any relationship that is used by one partner to gain or maintain power and control over another intimate partner. Domestic violence can be physical, sexual, emotional, economic, or psychological actions or threats of actions that influence another person. This includes any behaviors that intimidate, manipulate, humiliate, isolate, frighten, terrorize, coerce, threaten, blame, hurt, injure, or wound someone. (2014) The types of domestic abuse include physical, sexual, emotional, economic and psychological abuse. Domestic violence is not limited to any particular race, religion, gender, age, educational or socio-economic factors. For the purpose of this paper, domestic violence is categorized as violent behavior that has been inflicted on one culture by another since colonization took place. Oftentimes the victims are the colonists who are subjected to abuse in its various forms by the colonizers but eventually that abuse transfers into abuse between members of the oppressed culture. The reasons for the abuse may disappear but the behavior can last and even accelerate through future generations. Colonization The term colonization comes from the Latin for â€Å"to inhabit†. Colonisation most often refers to an outside group moving into a previously inhabited area. Ever since man learned to travel, he has desired to conquer new lands either by developing a profitable relationship with the indigenous peoples or, more commonly, by taking over the land and other resources through a threat of force or through direct violence. Colonisation can be beneficial if it is done with respect and cooperation of the inhabitants. Some regions, especially underdeveloped regions, may benefit significantly from colonization by an outside culture. These regions may experience in an increase in world knowledge, medical care, economic growth and more. There are instances however, that show the dark side of colonization and the domestic violence with which it has often been associated. History is filled with tales of forceful colonization despite the language used to describe it – exploration, emin ent domain, settlements. More often than not when a territory is colonised without the express permission of the colonists, violence ensues. The violence may come in the form of a direct attack or through cultural oppression. The colonists may be imprisoned, raped or beaten into submission. This form of abuse lasts much longer than the life span of the abuser and abused. It is carried into future generations through culture, belief systems and trauma, often causing particular cultures to be more prone to the violence committed against their ancestors or, worse, become the abusers. Correlation between Colonisation and Domestic Violence People intent on colonizing new lands or infiltrating existing cultures typically held the strict belief that their religion, politics, education and culture were far superior to that of the indigenous people therefore it was common practice for the new settlers to impart, often forcibly, their culture and belief systems on the indigenous peoples. As a result of this effort, the indigenous peoples were required to take on the characteristics and culture of the invaders, usually due to the threat of violence. Because indigenous people were often less educated than the invading population, they were seen – and treated – as an inferior society. This is not to say that the indigenous cultures were perfect before they were infiltrated by the colonizers. Each culture has its own unique set of beliefs and circumstances. The difference may be that there is limited, if any, knowledge or documentation on the culture of these peoples before they were colonised. Colonization and Patriarchy Patriarchy, the cultural practice of revering the male gender as the head of society, including the family structure, can be directly linked to colonization and the mistreatment of the female gender. Historically speaking, cultures with a patriarchal view held little regard for the female gender which often permitted substandard treatment of females. This treatment often led to various forms of domestic violence. A patriarchal belief system is common even in the modern world although great strides have been made to protect women and children from violent males often taught to be dominant by colonizing cultures. While the majority of the invading people held a patriarchal view, that is not without exception. Many indigenous cultures are matriarchal in nature, particularly the Native American and First Nation communities of Canada. The shift in leadership from matriarchal to patriarchal often caused women to be viewed as inferior as men were taught not to respect women as they once had. As a result, women in many cultures were viewed as little more than property allowing the male population to treat the women in any way they saw fit, including a cycle of domestic violence that would remain in place for generations. According to Kanuha (2002), there are several strategies for claiming superiority over another gender or culture. The first is to convince the colonists that their ways are superior. The second strategy is to create a delineation between the colonizers and the indigenous peoples through segregation including the separation of men and women. The third strategy of colonization is to use domestic violence to control the colonists. This may include any and all forms of physical, emotional, spiritual and psychological abuse. The fourth strategy is to take control of the colonists’ economic resources including natural resources. The fifth strategy is controlling the culture and limiting outside resources of knowledge and information. In some cultures they are permitted to see only media images of women that were created by men; images that often objectified women. Another form of control is to prohibit the use of native language and education as well as to deny the colonists the opportunity to decide or vote on their own futures. While patriarchy is undeniably tied to colonization, it must be mentioned that men also suffered from these same issues. While men may have been seen as dominant, the colonists were second to the colonizers and therefore often suffered from the same abuses as women. Colonisation and Disease One form of domestic violence is to deny one appropriate health care. During the colonization of many regions of the world, indigenous peoples were exposed to and infected to new diseases brought by the colonists yet were denied adequate care. In fact, many of the colonizers were often quarantined from the recently exposed natives to protect them from diseases they brought to the region. The belief was that the natives, unable to withstand any number of exotic pathogens, were biologically inferior. It was the development of world trade routes as well as the desire to conquer new lands that encouraged Europeans to cross borders into previously unexplored territories. As a result, they infected entire cultures with disease, namely tuberculosis and small pox, two diseases responsible for killing the majority of Americans and Europeans in the 18th and 19th centuries. Additionally, the colonizers tended to bring with them newly domesticated animals which added another level of potential disease to the natives. As the mortality rate of the colonists rose, the colonizers were able to increase their presence and domination over the remaining people and their lands. Colonisation of the Maori, Native Americans and the First Communities of Canada The Aboriginal tribes of the South Pacific, particularly the Maori, have a long and violent history of being colonised by Western Europeans. The Maori were once the colonisers of New Zealand, taking over the island through force and causing the genocide of the island’s indigenous peoples. The Maori began to trade with Europe in the 1700s, bartering fish and land for beads, cloth and other items. When potential invaders attempted to invade New Zealand, the Maori embraced violence and beheaded the infiltrators. They often participated in cannibalism rituals which led to a reputation of the Maori as being brutal savages. The shift toward colonisation began when missionaries arrived in New Zealand with the hope of converting the Maori to Christianity. The missionaries traded goods for land and built New Zealand’s first church. The Maori began to trade in muskets which created an arms race between New Zealand and its neighbors. Violence escalated. Although the Maori and the missionaries tended to remain separate, many Maori began to convert to Christianity. Relationships between Britain and the Maori strengthened. Britain wanted the Maori to pledge its allegiance to the throne in exchange for a guarantee that no one would attempt to rob the Maori of their lands. While many Maori refused to link themselves to the Queen, 46 chiefs signed the Treaty of Waitangi, hoping to end the violence. While the Maori as a whole did not willingly shift to British rule, the region began to thrive from the relationship. Eventually, the British established a new capital in Aukland and the country continued to thrive. The history of the Native American tribes is well documented in most school texts. Christopher Columbus believed he had discovered a shorter route to China when he landed in the Bahamas. Columbus, eager to prove that he was a superior explorer sought only three things in his travels – to educate people about God, to gain glory for his explorations, and to gain fame and fortune from the gold, spices and other resources the trip would provide. Due to these factors, Columbus’ arrival in the Bahamas was ill fated for its people. Columbus and his crew pillaged the land and were, in essence, responsible for the deaths of nearly 60,000 inhabitants of the islands over a period of the next 30 years. Upon arriving in America, Columbus discovered that there were people living on this new land. This contact encouraged other people to travel to the New World. The infiltration of Europeans was not welcome by many of the 160 native tribes. While some tribes were friendly with each other and with the Europeans, many were not. Wars ensued. A large percentage of Native Americans were wiped out by the arrival of small pox, diminishing its population by as much as 70%. As the colonisation of the Americas continued, the Europeans began to outnumber the â€Å"savages†, forcing them into more remote areas of the country. Violence continued to escalate between the Europeans and Native Americans. Although it was the Europeans that began the barbaric practice of scalping, the act was solely attributed to the Native Americans who often retaliated in kind. The reputation of the Native Americans as uncivilized savages grew and along with it, any respect for their culture all but vanished. The legacy of the First Nation of communities mirrors that of the Native Americans and, in fact, they are in some way of the same family as their lands were stolen in the name of capitalism and racism. Throughout 100 years of violence between the Europeans and native cultures, the natives continued to be pushed back until eventually the majority of tribes were relegated to reservations. The segregation and loss of their culture created a wider gap between the cultures. Missionaries continued to attempt to colonise the natives by preaching and introducing modern ways into their culture. Domestic violence between factions continued as women were abused, men were beaten and killed. Women and children were also sold into the slave trade as sexual objects. Prevention of Domestic Violence in Colonised Territories It has been stated that the abuse and objectification of indigenous peoples carries with it a dark stain that has permeated generations. In addition to carrying that sense of shame and continued chain of abuse, each individual in the culture also carries with him a sense of being inferior. This sense of inferiority and the legacy of abuse are two of the reasons that indigenous peoples tend to have a higher rate of abuse as well as suicide. The prevention of domestic violence in colonised territories, despite the location, begins with education. In modern society it is known that abuse in any form is morally and ethically wrong as well as being illegal. Still, incidents of abuse occur every day and perpetrators are often allowed to wander free while the abused suffer. Some domestic violence treatment programmes may give special consideration to the history of trauma suffered by a particular culture, particularly those that have been colonised and show a marked increase of substance abuse or number of psychological issues. One such programme, popular in the United States is the Duluth Model in which the abuser is treated based on his history of trauma, beliefs in victimization and power over the abused as well as the shame factor. The programme has been used in the education and court systems to decrease the percentage of abuse, particularly by men. Smith (2006) states: Researchers are beginning to confirm what common sense dictates: that violence between individuals, while influenced by social and cultural variables, is more parsimoniously explained by an examination of individual characteristics, contexts, and functions of behavior. Not surprisingly, empirical research is beginning to identify shame, individual stressors such as substance abuse and trauma history, and personality characteristics as main contributors to violent behavior in intimate relationships. Smith also intimates that while there are many programmes and models that claim to have the best recipe for preventing abuse, it is not clear if one has any superior efficacy. Smith asserts that domestic violence activists and agencies will see the most success when treating the individual ascribed to the abuse. Conclusion The correlation between colonisation and domestic violence has been proven through myriad scholarly articles, texts and studies. Research has shown that the oppression of the colonists by colonisers creates deep inner turmoil that must be expressed. Since the anger, indignation and shame usually cannot be expressed directly at the abuser, the victim may turn those feelings inward which may result in depression, substance abuse, and even suicide. However, some victims will take out those feelings on others that may be weaker than they. In this case, it is often women and children that may suffer from physical, emotional, psychological, financial and verbal abuse. While many social programmes exist to combat domestic violence, they are often not designed to address the underlying trauma of the victim or the abuser. When one culture has been oppressed by another, a sense of inferiority is instilled. The oppressor intends to take what it wants from the oppressed whether it is land, money or even its own women and children. The oppressor often uses whatever means necessary to achieve his goals and will subject the oppressed to various types of violence and abuse. The oppressor may begin to believe that the violence is justified and that belief, that victim or abusive mentality may remain and perhaps even escalate throughout future generations. As women are objectified due to their cultures and perhaps beaten or raped, they tend to believe that the behavior is â€Å"normal† or perhaps even earned. Combatting those emotions and putting an end to domestic violence among the colonised cultures goes much deeper than the formulation of any law or social programme, no matter how valid. The issue must be addressed at the deepest level – the level of one’s belief system. While many pro grammes may treat only the victim or the abuser, it is imperative that both sides of the conflict be dissected and examined. The history of one’s culture can shed light on personal behavior even if the history seems far removed. Learning one’s history as well as becoming educated on healthy forms of communication and interaction are the only ways in which domestic violence can be effectively addressed. Only then is it possible to perhaps not eradicate but at least lessen the occurrences of domestic violence in these and other cultures.

Pride And Prejudice: First Impressions Essay -- essays research papers

First Impressions First impressions are very important. In the Victorian age, people based their whole opinion of someone on first impressions. Most times the first impression of someone is not the way they truly are. Sometimes a first impression can cause you to think negative of someone but later you find out that they are very nice and a very positive person. One example is when Mr. Darcy meets Elizabeth in the book ,Pride and Prejudice. Elizabeth thinks Mr.darcy is a cruel and arrogant person, but she later finds out that he is not. Also in, Pride and Prejudice when Elizabeth meets Mr. Wickham she gets the impression that he is very nice and gentlemen like, but she finds different with him too. In the story " The Importance of being Ernest" Lady Bracknell does not like Jack because he does not have any money and does not live up to her standards, but little does she know. In "Pride and Prejudice" by Jane Austen, Elizabeth thinks Mr. Darcy is a very rude and self centered person based on what she saw the first time they met or actually the first time they saw each other. Elizabeth over heard Mr. Darcy talking to Mr. Bingley at a ball and didn't really like what she heard. "She is tolerable; but not handsome enough to tempt me." ( Austen 12) Mr. Darcy thinks he is much to good for some people and has very high expectations. at one point n Beck 2 the story Mr. Darcy starts to fall in love with Elizabeth. Elizabeth knows he has changed but...

Indian dance Essay

Kathak is the one of eight forms of Indian classical dances perform by men and women, originated from northern indian, known as kathakars or storytellers. The styles of dance have its unique character from the rhythmic footwork with rhythms that he or she stomps out barefoot on the floor, accented with many bells worn around the ankles ( and from seeing the guest artist I can say there were more than 100 bells around her ankles making lots of noise to go with the beats of the drum), spectacular spins, and also every dance piece has a story behind it. A traditional kathak performance features a solo dancer on a stage, surrounded on all sides by the audience. The repertoire includes amad ,the dramatic entrance of the dancer on stage. Male dancers perform in Persian costume of wide skirts and round caps, while female dancers wear a traditional Indian garment called a sari. Back in the day women are the one who preserved this traditional dance more than the men. Kathak are typically performs by one dancer surrounded by a group of musicians. The solo dancer performs the parts of all the characters in the story. For example the guest artist were going back and forth rapidly from one of her dance piece between two characters. She did it without changing her positions on stage, changes in gestures and facial expressions signal instantly which character they take on at that moment. Before the guest artist started her dance so did a pronom giving thanks to all five elements or also known as the god, space, wind, fire, water and earth. Dance is on the earth, the eyes wherever the eyes are the mind, where the mind there are feelings. The way Antara gave thank to the god were a little different from what we normally did in class, with more steps and she also added some singing and harmony into the rituals. Based on what Antara told us, kathak is a very intimate dance where it is a three ways conversation, between dancers with musicians and dancers with the audience. The tempo for kathak consist of 16 beats. Dancers sometime precise the beats while dancing. With kathak you can play with the rhythms, there is no set rhythms. Kathak consisted of a lot of feet movement and with that the bells around Antara added a more prominent movements. Even though the focused on her foot because of all the bells, we can still see that she’s using her upper body. The arms movement were very smooth and elegant, her eyes moved according to her hands gestures. Antara played the Theka which looked and sound like the accordion, along with singing and dancing. The Theka did not stop Antara from doing her incredible spins and keeping the tempo while doing all these things at once. Stomping her foot very fast and loud on the floor seems to be away for her to keep her tempo. Even when she was stomping her foot her hands and head was still doing a lot of movement to help tell the story. During her performance she uses a lot of phrases in Indian and it was hard for me to understand or catch what she was saying. But she later on explained that it is just like how we counts beats in america instead of using numbers, in Indian dance they used the language of the drums. Her right foot always ended in the front to help her keep up with the beat and also so that her body can face the audience and interacted with them. Her dance move was not all fast but it was very precise and very professional. Antara dances very elegant and somehow I can see her personality throw the way she moved the way she carry herself on all the dance pieces. She is a great dancer and a great guest artist for the style, she makes me want to learn more about the style and actually go see her performance in San Francisco.

Beauty Defined

What is beauty? How can an abstract concept such as beauty be defined? That question has been pondered for ages. An anonymous person once said â€Å"Beauty is in the eye of the beholder†. Beauty means something different to everyone but there is a general agreed-upon standard of beauty in our society. As defined by Merriam-Webster’s dictionary, beauty is â€Å"the quality or aggregate of qualities in a person or thing that gives pleasure to the senses or pleasurably exalts the mind or spirit : LOVELINESS †.It has also been defined as â€Å"the phenomenon of the experience of pleasure, through the perception of balance and proportion of stimulus. It involves the cognition of a balanced form and structure that elicits attraction and appeal towards a person, animal, object, scene, music, idea, etc†¦Ã¢â‚¬  The philosophical discipline of aesthetics aims to understand the nature and meaning of beauty. Two kinds of beauty were distinguished by composer and criti c Robert Schumann ; natural beauty and poetic beauty.Natural beauty is found in the examination of nature and poetic beauty in man’s cognizance. According to Schumann, in music or other art forms, both types of beauty exist. A familiar theory holds that beauty is the appearance of things and people that are good. Our society judges the physically attractive as â€Å"good†. The popular quote â€Å"beauty is in the eye of the beholder, â€Å" maintains that beauty is entirely personal. Beauty can be found in nature as well where â€Å"beauty as goodness† holds true.An Alaskan glacier, a ruggedly dry mountain range, or a field of wildflowers can all be said to be beautiful. Most people find beauty in nature, from a newly fallen leaf in autumn, a tadpole metamorphosing to a frog, or a butterfly fluttering in a field. Formal studies done in the United States have discovered that facial symmetry is a key factor in determining the beauty of human appearance. To have facial symmetry suggests that a person has no apparent inherited flaws. Other studies suggest that a specific height and length of cheekbones is a strong indicator of physical beauty.These studies were conducted by scientists who asked volunteers to rate a series of photographs on the basis of beauty. The attributes common to all images rated beautiful were then picked out. Dr. Devendra Singh, of the University of Texas at Austin, discovered the waist-to-hip ratio, which is considered an indication of beauty in women of most cultures. This holds that a woman whose waist circumference is 70% of her hip circumference is considered beautiful and is also an indicator of her fertility. Greek philosophers were the earliest to theorize beauty.Pythagorus saw a strong connection between mathematics and beauty. The Pythagorean School maintained that objects proportioned to the â€Å"golden ratio† seemed more attractive. People whose facial features are symmetric and proportioned are ra nked as more attractive than those who are not, according to the golden ratio. The ancient Indians believed that anything that is always new is beautiful. A survey conducted by London Guildhall University of 11,000 people showed that (subjectively) good-looking people earn more.Less attractive people earned, on average, 13% less than more attractive people, while the penalty for overweight was around 5%. The term â€Å"beautiful people† is used to refer to those who closely follow trends in fashion, physical appearance, food, dining, wine, cars, and real estate, often at a considerable financial cost. Such people often mirror in appearance and consumer choices of the characteristics and purchases of rich Hollywood characters. Beauty is truly a subjective concept that is difficult to prove or define.

Strategies for Acing a Multiple Choice Test

Strategies for Acing a Multiple Choice Test We all have to study and take a multiple choice test at some point in our lives. Since these tests are so prevalent, its important to have a few strategies under our belts when we sit for the exams. Read below, because these multiple choice test tips are sure to help you get the score you need on whatever exam youre taking next. Multiple Choice Strategies Read the question while covering up the answer choices. Come up with an answer in your head, and then check to see if it’s one of the choices listed. Use a process of elimination to get rid of as many wrong choices as you can before answering a question. Wrong answers are often easier to find. Look for extremes like never only or â€Å"always. Look for opposites like a substitution of –1 for 1. Look for similarities like conjunctive for subjunctive. Those could be distractors.Physically cross off wrong answer choices so you are not tempted to go back at the end of the test and change your answer. Why? You will read more about trusting your gut in a minute.Read ALL the choices. The right answer may be the one you keep skipping. Many students, in an attempt to move quickly through the test, tend to skim answer choices instead of reading them thoroughly. Do not make that mistake!Cross off any answer that does not fit grammatically with the question on your multiple choice test. If the test blank is looking for a singular noun, for instance, then any question choice displaying a plural noun will be incorrect. If you struggle t o figure it out, then plug the answer choices into the problem to see if it works.   Take an educated guess if there is no guessing penalty like there used to be on the SAT. You will always get the answer wrong by skipping it. You at least have a shot if you answer the question.Look for wordy answers. Unless you’re taking a standardized test, the correct answer is often the choice with the most information. Teachers often have to put as much info down as possible to make sure the answer choice can’t be disputed.Remember that you’re looking for the best answer. Often, more than one answer choice will be technically correct on a  multiple choice test. So, you have to choose which one fits best  with the stem and in the context of the reading passage or test.Use your test booklet or scratch paper. It often helps to write as your work, so write down formulas and equations, solve math problems, outline, paraphrase and underline to help you read. Use the scratch paper to help you work things out logically.Pace yourself. If you get stuck on a questi on, circle it and move on. Come back at the end of the test so you don’t waste precious time on something you may not get right anyway. Trust your gut. Definitely go back through your test to make sure you’ve answered everything, but keep your answers the same unless you’ve discovered new information in a later part of the test to disprove your answer. Click the link for more details about this strategy!

Pygmalion in Management Discussion Board Assignment

Pygmalion in Management Discussion Board - Assignment Example The employees are motivated will thus work very hard to achieve the high expectations set in order to get an increased salary. How else could salary increment motivate them? Many organizations and institution succeed mainly because of the type management system. The managers set high expectations to be achieved by the subordinates. Some of the managers set expectations based on how they believed in themselves. I disagree with the fact that managers should set unrealistic goals which wills discourage the subordinates. In order to motivate the employees to increase their productivity, there is a need to set to realistic goals. The unrealistic expectations will demoralize the employee and only work to achieve low expectations. I agree that managers should always motivate their employees whenever they set out the expectations. When the managers set higher expectations for the employees they should encourage them that they have the skills and capability of reaching the expectations. The employees should be treated equally rather than some of the employees being seen as super staff and some as low performers. In conclusion, there is a need for institutions to have well skilled and qualified managers who are able to treat subordinates in ways that lead to high performance and career satisfaction. The managers can influence the attitudes of employees towards their jobs which will affect their  productivity.

E-business models Essay Example | Topics and Well Written Essays - 3500 words

E-business models - Essay Example HTML code is the underpinning of every button that one clicks, every link one sees, how every link works, how every link leads to other pages, and how graphics and text are displayed on a page. Using a complex structure based upon how a page is organized and read, HTML code basically has several different elements which make it a valuable and widely-read and widely-accessible computer language, even for people who are not advanced coders by any means. HTML helps one distinguish where the header of a page is, where the footer of a page is, and other elements such as where paragraphs, graphics, and any buttons should be put on the page. Any kind of features that would be displayed on a website’s pages must be written into the HTML code, otherwise they won’t show up on the pages themselves. HTML code, therefore, is the bread and butter with which the Internet is composed. For, if we didn’t have HTML, there would be no ways to code in and allow for certain new elemen ts to be present on the web pages. Now, what if certain things had to be added onto the web page that had never been added before? In this case, we would have to build in some type of elements into the code that would allow for new features to be added onto the web pages. ... E-Payment ? -Online Credit Card Hosts Online credit card hosts basically take credit card numbers for clients or customers that are utilizing their services. â€Å"In general there is no obligation on hosts to take formal identification of their subscribers. Where the host charges for Internet access, it is probable that credit card details will have been taken and checked† (Reed, 2004, pp. 142). Basically, online credit card hosts have to have a number of detailed security checks that ensure that the people who are accessing these hosts are legitimate individuals and not people who have some type of skullduggery up their sleeves. Identity thieves will stop at nothing in order to fleece people of their hard-earned money, and, in short—separate them from it, ultimately. So, what online credit card hosts have to do is ensure that there are multiple security checks and code words entered—in some cases—in order to verify the identity of the person who is tryi ng to access the account. Of course, it only makes sense that online credit card hosts with more prestige probably have access to more online resources in order to make their systems safer. Therefore, the highest-quality card will probably offer the best protection, without a doubt. - Debit Card Consumer Protection ? Debit card consumer protection—in the past—has not been very good, but it is slowly improving. â€Å"In spite of the fact that there are difficulties involved in the use of debit cards, it is heartening to note that two big institutions in the USA have voluntarily extended some amount of credit card protection to [debit card owners]† (Gurusamy, 2009, pp. 58). In fact, debit card fraud is prosecuted more harshly even than credit card debt that is accrued fraudulently. This