The Connection between Management and Leadership Essay

The Connection between Management and Leadership - Essay Example The researcher states that being a leader is easy. Gaining followers is the easiest part of being a leader, but it is still tough for most people. Leading one’s followers is a different prospect though; it demands the maximum one can offer. A well-structured organization should have a pool of leaders and managers in order to be successful. In fact, what they actually need is a few first-class leaders and many brilliant managers. This shows the connection between management and leadership. It is far more difficult to be a leader than a manager. One can go to school and become an excellent manager, but there is no guarantee that reading motivational books and attending workshops can make one a leader. Managers are the persons tasked with the job of management (planning, budgeting, staffing, organizing, controlling and problem-solving). On the other hand, leaders create a path, guide people, inspire, and motivate. In this regard, it is easy to see that leaders interact with peopl e much more than managers do. A leader usually has to go out there and put his skills to the test because the followers always want to see them. On the other hand, a manager can perform his duties in absentia and still achieve a decent degree of success. A manager can sit in his office the whole day and employees will still recognize that he is around. This is possible but difficult in leadership. A leader has the heart, drive, and creativity while a manager has the determination, the logic and the mind. A leader is inspiring, innovative, courageous, flexible and independent, while a manager is analytical, authoritative, direct, consulting and stabilizing. Management and leadership play an important role in service delivery in organizations. Although they are similar in many aspects, they may involve different types of behaviors, skills, and perspectives.

The Awful Rowing Toward God Assignment Example | Topics and Well Written Essays - 1000 words

The Awful Rowing Toward God - Assignment Example It seems something that causes ruin, injury or pain would be pretty clear-cut, but what if it is to destroy a cruel dictatorship, to cause injury as a means of repairing an internal injury or to create pain as a means of setting a broken bone? In many ways, evil must be considered to be a changing concept depending on the dominant cultural beliefs at a given time and considered along with the greater context of events. By looking at some relatively recent depictions of evil in today's culture, it is possible to see that evil is usually considered to be an outside force characterized by its creation of unearned pain and destruction.  It seems something that causes ruin, injury or pain would be pretty clear-cut, but what if it is to destroy a cruel dictatorship, to cause injury as a means of repairing an internal injury or to create pain as a means of setting a broken bone? In many ways, evil must be considered to be a changing concept depending on the dominant cultural beliefs at a given time and considered along with the greater context of events. By looking at some relatively recent depictions of evil in today's culture, it is possible to see that evil is usually considered to be an outside force characterized by its creation of unearned pain and destruction.   In the novel The Shining, for example, evil is a bodiless force that is confined for some reason within the area of a remote Colorado resort called Overlook. Within the novel, there is no clear sense of where the evil comes from or why it is attached to that particular location, only that it has likely been in place since the hotel's beginning. There are several instances where people who have died at the hotel are mentioned somewhat offhandedly as if it is too regular to make anyone upset. The Torrence's arrival at the hotel is marked by an angry woman speaking about the time her second husband died out on the roque court (Ch. 9) and they continue to hear about other deaths, increasingly more viole nt in nature, as the book continues. Even early in the story, some of these deaths seem odd, such as the death of the hotel's first owner, working as a caretaker after he'd lost his fortune. "He plugged his finger into a light socket by mistake and that was the end of him" (Ch. 10) or that of his son, who was killed in a riding accident on the property. The evil of the hotel is a disembodied thing, but it has a clear objective - to destroy life by causing extreme pain and mental anguish and to acquire power. The violence of the hotel is introduced in Chapter 12 as the little family is getting a tour of the Presidential Suite on the third floor: "Great splashes of dried blood, flecked with tiny bits of grayish-white tissue, clotted the wallpaper.  

Developments In Cold Environments Sustainable Essay Example for Free

Developments In Cold Environments Sustainable Essay To what extent are more recent developments in cold environments sustainable ? Fishing can disrupt food chains. For example krill fishing in the southern ocean is depleting food supplies for whales and penguins. Overfishing of a species can severely deplete its population, sometimes beyond recovery. Overfishing of the patagonian toothfish in the Antarctic is currently a concern. Bottom trawling catches fish by dragging nets along the sea-bed. This disrupts the eco system by reducing light levels thought increasing turbidity and catches other species as well as the target one. Its carried out in the gull of Alaska, the greenland sea and the barents sea. Fishing quotes have been introduced to limit the number of fish caught and prevent overexploitation of the resource. Large cruise ships increase pollution in the areas from the ships and from the tourist. Tourists and tourism developments disrupt wildlife and damage habitats leading to reduced biodiversity. National parks have been set up to allow tourism whilst protecting the environment e.g. denali national park in Alaska was set up in 1917 and then expanded in 1980 to induce a greater area of land. Cars and private vehicles are banned from the park so visitor’s have to travel in park buses on approved routes. The most vulnerable parts of the park don’t have any roads at all. So the ground is protected from the damaging effects of vehicles. Oil spills can occur during transport of oil from the area. For example in 1989 there was a huge oil spill off the coast of Alaska when the exxon valdez oil tanker crashed. Over 40 million litres of oil spilled into the ocean and over 250 000 birds and fish were killed. Oil spills can occur if the pipelines leak between 1977 and 1994 there were on average 30 to 40 spills a year from the trans-alaska pipeline. Some of these were caused by intentional attacks and forest fires. Oil pipes have automatic shut off valves in order to minimis e oil spills if the pipelines are damaged.

A Clean Well-Lighted Place Essay -- A Clean Well Lighted Place Ernest

A Clean Well-Lighted Place A Clean, Well-Lighted Place by Ernest Hemingway looks at age from the viewpoint of an inexperienced and experienced individual, with the aid of an old man to emphasize the difference between the two. This story takes place late one night in a caf. The caf is clean, pleasant, and well lighted, which brings some kind of comfort to the atmosphere. Here in the caf sits a deaf, lonely, older man, who although is deaf can feel the difference that the night brings to the caf, a younger waiter, who believes people stay around the caf to make his life miserable, and a waiter who is a bit older and seems to understand that this place, the caf, is comforting. The older man spends his late nights in the caf, because at his home there is nobody, he is widowed. All he has is the comfort that the light inside the caf brings to him at night, and the appearance and thought of other human beings may bring him. The old man is under the care of his niece, who last week had to cut him down from his attem pting to commit suicide. Why did he attempt to kill himself? He was in despair. Stated one waiter, and I am assuming it is the younger waiter because he goes on to state that he was in despair over nothing because he has plenty money. Money would be the answer to any problem to an individual of youth because when one is younger he/she has not yet come to realize the importance of relationships. The older waiter shows us the importance of relationships by stating, Each night I am reluctant to close up because there may be some one who needs the caf. This appearing to mean that he knows that there are many lonely people in the world without relationships and no one to turn to in time of need or having some one to just be ... ...per meanings. Looking at my critical approach New historicism and comparing it with my piece A Clean Well-Lighted Place, only from the point of view of a new historicist without doing any additional research into the ties or times of the author I believe I have a well understanding of what it means to be a new historicist and how it applies to my piece that I have chose. I tend to think that knowing more about Hemingway and the life he led might give me a better understanding of his reasons for writing A Clean Well-Lighted Place. The meaning of Hemingways piece also will differ greatly across cultures and how it is a particular society looks at the differences in age and communication factors. . Work Cited Hemingway, Ernest. A Clean Well-Lighted Place Literature Reading and Writing The human Experience. Donna Erickson. New York: St. Martins press, 1998. 115

Caltron Inc

Over the past ten years the importance of accounting cannot be overemphasized, as we've seen our share of national scandals. In today's society accounting principles and standards are severely important in driving the formation of financial statements. Without principles and standards, financial reporting would not fairly present the financial position of a company. Accounting has changed and evolved vastly over time and continues to change.Because of this I am going to breakdown the way your financial reporting team has been recognizing revenue for the fourth quarter of the current year and assess the implications it may have on your financial statements. I will also take you through the process of how the accounting standards are created to give you a better understanding of what my conclusion is. Revenue Recognition Implications As you know Caltron Computers, Inc. s a publicly held company with a total market capitalization in excess of $450 million, and you have a proposed second ary public stock offering coming in early February 20X2. Therefore the auditors are concerned about the impact of these transactions and want to bring it to your attention before it misrepresents the reported earnings. Caltron reported net revenues from four transactions equal to $1,710,000 in Q4, while cash received only totaled $495,000.The quality of earnings issue surfaces and gives the auditors reasons to question the accounting methods and possibly their honesty and ethics. The company policy for recognizing revenue is when the products are shipped, and because of this, a potential issue has come about relating to some of the transactions. Typically revenues are earned when the earning process is complete and an exchange has taken place. Once this happens the risks of ownership are transferred to the buyer, unless an arrangement for the sale states otherwise.Collectibility of the sales price is questionable for three of these transactions. According to FASB, revenue generally is realized or realizable and earned when all of the following criteria are met: persuasive evidence of an arrangement exists, delivery has occurred or services have been rendered, the seller's price to the buyer is fixed or determinable, and collectibility is reasonably assured. (FASB, 2008) Now I will follow this with a breakdown of all the

My Internship At Future Perfect Ventures - 768 Words

My internship at FuturePerfect Ventures has been an incredible learning experience and a stepping-stone for a fulfilling career path. I have known that I wanted to pursue a career in financial communications before I even started the internship search process. My experience at FuturePerfect Ventures not only solidified my desire to work in this specific industry but also gave me the opportunity to build on my existing skills and allowed me to have first-hand experience in this area. Thus, my internship at FuturePerfect Ventures has been, in many ways, more than a learning experience but also what Nathaniel Kolac, the author of the Harvard Business Review article, â€Å"Build a Career Worth Having, refers as a valuable stepping stone, one of the many experiences that help create the path to a successful, fulfilling career. All of my previous internship experiences have allowed me to hone in on and strengthen different skills. In his article, Kolac stresses the importance of treating one’s career like a â€Å"grand experiment† in order to develop a valuable career. My internship at FuturePerfect Ventures was certainly a â€Å"grand experiment† for me. While I was able to learn a lot about the financial industry, investing, and startups, I also I had to rely on the communications-related skills that I learned in my graduate classes and from previous internship experiences to help me because I was not interning for a communications team. Now that I’ve interned at FuturePerfect Ventures forShow MoreRelatedMy Experience At This Internship1561 Words   |  7 PagesAt this internship, I was able to learn many lessons. Those lessons can be applied to any field, but also give me a competitive edge when applying for jobs in the Venture Capital industry. 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Similar Fact Evidence - Free Essay Example

Sample details Pages: 9 Words: 2835 Downloads: 1 Date added: 2017/06/26 Category Law Essay Type Research paper Did you like this example? The law of evidence is a system under which facts are used to determine the rights and liabilities of the parties. Evidence proves the existence of facts in issue or infers them from related facts. One of the fundamental considerations of criminal evidence law is the balance of justice to the accused against wrongful convictions, ensuring a fair trial and fairness to the victim. Don’t waste time! Our writers will create an original "Similar Fact Evidence" essay for you Create order Since stakes in criminal trials are generally high, prosecution would have to prove the accuseds guilt beyond a reasonable doubt. Since similar fact evidence as evinced in s  11(b), 14 and 15 of the Evidence Act(EA) can be highly prejudicial to the accused, and yet play an important role in proving culpability, it should be reformed to clarify its scope of application under the EA and reflect the common laws prejudicial propensity balancing test. 2. Similar Fact Evidence A. Background Similar fact evidence is not directly connected to the case but is admitted to prove the existence of facts in issue due to its general similitude.The worry that the trier of facts would convict the accused based solely on evidence of prior conduct has generally led to the inadmissibility of such evidence in the trial as this is severely prejudicial. This concern is amplified in bench trials. Studies have suggested that judges were as influenced as laypersons when exposed to inadmissible evidence, such as prior convictions, even when they held that these evidences were inadmissible.  [6]  This is despite strong confidence in the judges ability to remain neutral to the inadmissible facts.  [7] Hence, the accuseds past similar offence or behaviour is inadmissible as similar fact evidence based on pure propensity reasoning would colour the courts ability to assess the evidence [objectively].  [8] Nonetheless, the mere prejudicial effect of such evidence does not render it inadmissible. It may be highly relevant, especially when such evidence is used to determine whether the acts in question were deliberate or to rebut a defence that could have been available.  [9] B. EA Under s  5 of the EA, a fact is only relevant if it falls within one of the relevancy provisions  [10]  stated in s  6 to s  10 of the EA. These provisions govern specifically the facts in issue, i.e. determinant facts that would decide whether the accused is guilty according to the substantive law governing that offence.In addition, s  11(b) was enacted to be the residuary category for the relevancy provisions. In contrast, similar fact evidence is primarily administrated by s  14 and s  15 as it is concerned with conduct that is merely similar in nature to those facts in issue  [13]  . s  14 is applicable only when the state of mind of the accused is in issue. Similar fact evidence is admissibl e to prove mens rea or to rebut the defence of good faith.  [14] s  15 deals with similar fact evidence that forms a series of similar occurrences to prove the mens rea of the accused,  [15]  and enables the prosecution to produce evidence to rebut a potential defence otherwise open to the accused.  [16] Admission of similar fact evidence under the EA is based on a categorization approach  [17]  , where such evidence is admissible pursuant to the exceptions stated in the EA  [18]  . Hence, similar fact evidence should only be admissible to prove the mens rea of the accused under s  14 and 15.  [19] Significantly, Singapore, India, Malaysia and Sri Lanka have identical s  11, 14 and 15 provisions in their respective Evidence enactments. With the exception of the Indian Evidence Act  [20]  , the three sections have not been amended since the 19th century.  [21] C. Case Law Interpretation of Similar Fact Evidence in EA Singapo re courts have not strictly adhered to the draftmans intention in recent cases.  [22]  The court has incorporated common laws balancing test  [23]  where the judge would balance between the probative and prejudicial effect of the similar fact evidence.  [24] In Lee Kwang Peng v PP  [25]  , scope of similar fact evidence was extended to prove actus reus. Pursuant to s  11(b), the court was of the view that the section embodied  [26]  the balancing test. Hence, similar fact evidence is admissible to prove both mens reas and actus reus.  [27]  Although readily admitting that this would be contrary to the draftsmans intention, then Chief Justice Yong held that the EA should be a facilitative statute rather than a mere codification of Stephens statement of the law of evidence  [28]  . The courts, until Law Society of Singapore v Tan Guat Neo Phyllis  [29]  (Phyllis Tan), were generally of the opinion that they had the discretion to exclude evide nce substantially unfair to the accused.  [30] D. Under the Criminal Procedure Code Act (2010)  [31]  (CPC) s  266 of CPC, dealing specifically with stolen goods, allows previous convictions of the accused to be admitted to rebut his defence of good faith and/or prove mens rea. However, notice would have to be given to the accused before adducing such evidence  [32]  . E. In Comparison to Common Law Unlike the EA, admissibility of criminal evidence at common law is exclusionary. As long as the evidence is logically probative, it is admissible unless it contravenes clear public policy or other laws.  [33] In Makin v A-G for NSW  [34]  , Lord Herschell formulated the two-limbed rule governing the admissibility of similar fact evidence. Under the first limb, the prosecution is not allowed to adduce similar fact evidence for pure propensity reasoning. However, under the second limb, evidence of the accuseds past conduct is admissible if relevant to the facts in issue via the categorization approach.  [35] Boardman v PP  [36]  reformulated these rules by incorporating the balancing test. Under this test, the probative force of the similar fact evidence must outweigh the prejudicial effect. Furthermore, such evidence should be strikingly similar, such that it would offend common sense if the evidence is excluded.  [37] However, the requirement of striking similarity was deemed to be too narrow in DPP v PP  [38]  . Instead, sufficient probative force could be gleaned from other circumstances  [39]  . Nonetheless, similar fact evidence used to prove identity must be sufficiently special to portray a signature or other special feature that would reasonably point to the accused as the perpetuator of the crime.  [40]  Hence, similar fact evidence is admissible to establish actus reus  [41]  . F. Defects of EA Singapore courts have incorporated common law principles and extended the applicability of similar fact evidence to prove actus reus. This has resulted in inconsistencies between the draftsmans intention and the courts approach. Further, there are some ambiguities that require clarification. First, there are difficulties superimposing the Boardmans balancing test into s  11, 14 and 15  [42]  as the EA was drafted to suit the categorization approach. The court would have to admit evidence falling under either section even if it may not be very probative or is highly prejudicial. Hence, s  14 and s  15 address only the probative part of the balancing test and leave no room for prejudicial effect considerations.  [43]  As a result, judicial discretion to exclude very detrimental evidence was developed.  [44] Second, although allowing similar fact evidence to prove actus reus would require the judge to evoke an additional step of inference  [45]  , limiting the use of this evidence to prove mens rea would allow extremely probati ve evidence to be excluded  [46]  . Third, admissibility rules under the EA do not distinguish situations where the accused adduced similar fact evidence unintentionally. An injurious consequence would result if the prosecution is entitled to use such evidence.  [47] Fourth, under s 15, a single act, no matter how probative, is inadmissible.  [48]  However, this does not take into account the consideration that an act may be capable of supporting the argument based on the rarity of circumstances  [49]  . Fifth, the courts have admitted similar fact evidence pursuant to s  11  (b) although it may not be pertinent to the facts in issue. Hence, EA should be amended to provide safeguards against such usage of s  11(b). Lastly, in light of Phyllis Tan  [50]  , more protection against admissibility of similar fact evidence should be incorporated into the EA. 3. Possible Options A. Survey of the other Jurisdiction (1) Australia Uniform Evidence Acts  [51]  (UEA) Under UEA, propensity evidence and similar fact evidence are governed by the tendency rule in s 97 and the coincidence rule in s  98. (a) Tendency Rule Evidence pertaining to the character, reputation, conduct or a tendency that the accused possessed is inadmissible unless (a) notice is given to the accused and (b) the evidence has significant probative value. Although UEA does not state how probative the evidence has to be, probative value of the evidence is defined the extent to which the evidence could rationally affect the assessment of the probability of the existence of a fact in issue.  [52]  Operation of s  97 would be invoked when the evidence is adduced for the purpose of proving the accuseds inherent tendency to act in a particular way.  [53] (b) Coincidence Rule As a general rule, evidence of related events which must be substantially and rele vantly similar  [54]   would be inadmissible unless notice is given and the court is convinced that it possesses significant probative value  [55]  . (c) Criminal Proceedings A safeguard was inserted in relation to criminal proceedings under s  101 where the probative value of either the tendency or coincidence evidence would have to substantially outweigh any prejudicial effect. However, the degree of probativeness need not  [56]  be of such a degree that only one conclusion, i.e. culpability of the accused, could be drawn  [57]  . (No rationale explanation test) (d) Analysis UEA clearly adopts the balancing test approach, where the probative effect of the evidence must substantially outweigh the prejudicial effect on the accused. Furthermore, the introduction of the notice system would reduce the prejudicial effect as the accused not be unduly surprised. However, as pointed out by the Australian Law Reform Commission, there is much ambiguity i n what constitutes significantly probative and when the probative effect will substantially outweigh the prejudicial effect. Significantly, in Australia, the trier of fact and law are different. Heavy reliance on the judges discretions, added with the ambiguity and wide application of the balancing test, would increase the risk of prejudice in bench trials. (2) India Statutory Amendments Some amendments to s  11, 14 and 15 of The Indian Evidence Act  [58]  , upon which the EA was modeled on  [59]  , had been made pursuant to a review in 2003.  [60]  However, the changes made were very minor.  [61] (a) Section 11 An explanation, inserted after s  11(2)  [62]  , qualified the type of evidence rendered relevant under s  11 such that the degree of relevancy is dependent on the opinion of the Court  [63]  . (b) Section 14 Clarifications to illustration (h) of s  14 were made such that the similar fact evidence has to show that A either had constructive or actual knowledge of the public notice of the loss of the property.  [64] (c) Section 15 The changes merely show that the acts made, pursuant to s 15, must be done by the same person.  [65] (d) Analysis It would appear that the amendments to the Indian Evidence Act do not have any substantial impact on the law. However, the amendment of s  11 explicitly mentions that the degree of relevancy of facts is subjected to the opinions of the court, which suggests an approach more in line with the balancing test. (3) England and Wales Criminal Justice Act 2003  [66]  (CJA) The admissibility of criminal evidence is presently governed entirely  [67]  by the CJA. Part II of CJA addresses the admissibility of bad character  [68]  evidence, which is defined as a persons disposition for a particular misconduct. Evidence of the defendants bad character can be adduced if it falls under one of the seven gateways unde r s 101(1)  [69]  . Significantly, under s 101 (1) (d), bad character evidence is admissible if it is relevant to an important issue between the defendant and the prosecution  [70]  . This includes the propensity to commit a particular type of offence which the accused is charged with or the propensity to lie  [71]  . Moreover, past convictions may be admissible to prove the defendants propensity to commit the crime he was charged with.  [72] Regardless, s  101 (3) allows the court to exclude evidence, falling under s 101  (1)(d), upon the application of the defendant if the court views that admission of such evidence would infringe on the fairness of the proceedings.  [73] The scope for the admissibility of bad character evidence has widened under the CJA.  [74]  In fact, evidence of bad character has changed from one of prima facie inadmissibility to that of prima facie admissibility  [75]  . Although, under s  103, bad charact er evidence would be inadmissible if it does not heighten the culpability of the accused, suggesting that the evidence must have some probative force, it appears that the CJA has abandoned the balancing test. Hence, similar fact evidence in the form of bad character evidence would be inadmissible if it lacks probative value in the establishment of the defendants culpability. However, s  101 (1), with the exception of s  101(1)(e), merely requires the evidence to be probative, without the need to outweigh prejudicial effect. 4. Proposal The EA would require more than a mere amendment. Hence, the type of reform advocated under the Indian Evidence Act should not be adopted. However, a radical change from the categorization approach to the balancing approach, following UEA, would give the court too much discretion. This is worrying as judges may not be entirely indifferent to inadmissible facts when deciding the case. On the other hand, the approach under the C JA would be contrary to Phyllis Tan  [76]  and potentially allows highly prejudicial similar fact evidence to be admissible as long as the prosecution can show some probative value which points towards the guilt of the accused. Hence, a hybridised model should be adopted where the categorisation approach under s 14 and s 15 is kept, but admissibility of such evidence must be subjected to the balancing test. A. Amendments (1) Changes to the Headings s  5 to s 16, under the general heading of Relevancy of facts, could be further sub-divided. First, s  5 to s  11 should be placed under a sub-heading of Governing Facts in issues  [77]  . Second, s  12 to s  16 could be placed under Relevancy of other facts sub-heading. This sub-division of the relevancy provisions would clarify the functions of each section and discourage courts from admitting similar fact evidence which does not have a specific connection with the facts in issue via s 11(b). (2) Incorporating balancing test Most importantly, EA should be amended to include the balancing test with guidance drawn from the UEA, such that the probative value of the similar fact evidence should substantially outweigh the prejudicial effect. However, the definition of substantially outweigh should be left undefined and allowed to develop under the common law. The courts could draw assistance from the Australian case law. (3) Proving Identity A provision could be inserted to the EA allowing similar fact evidence to prove that the accused was responsible for the offence. In addition to the balancing test, the provision should also reflect the proposition that that such similar fact evidence must satisfy the threshold test of being strikingly similar to the offence, almost akin to a signature or special feature of the accused. However, it is submitted that the extension of similar fact evidence to prove actus reus should be limited to the situation w here the identity of the perpetuator is in doubt. B. Clarifications (1) Similar fact evidence produced by the accused mistakenly It is proposed that such evidence should subjected to a higher standard of balancing test where the probative value substantially outweighs prejudicial effect. (2) Only prior convictions are allowed Prior acquittals should not be admissible as similar fact evidence as this would be unduly prejudicial to the accused. Furthermore, this could result in the undesirable situation whereby the accused is subjected to a second round of trials with regards to the prior charges. In relation to the type of prior convictions that should be allowed, the EA should incorporate the definitions found in s 103(2)  [78]  and s  103(4)  [79]  of the CJA. (3) Clarification of s. 15 s  15 should be extended to include single act or conduct of the accused to rebut the defendants defence of accident. However, in light of a potential d anger of placing too much importance on a single episode, a qualification, such as the no rationale reason  [80]  test, should be implemented along with the extension of s  15. 5. Additional Safeguards A system of notice, as seen in UEA, should be included into the EA. This reduces the prejudicial effect as the evidence would not be a surprise. Furthermore, this approach would be in line with the CPC, which has already adopted such a procedural reform. 6. Conclusion Regarded as one of the most difficult area of the law of evidence, similar fact evidence can serve as a double-edged sword. It has the potential to convict the accused although the facts do not relate to the facts in issue and is highly prejudicial to the defendant. In light of the rapid development of the rules governing the admissibility of similar fact evidence under the common law and the recent trend of common law countries codifying the test of admissibility into statutes, the EA should be reformed to reflect these developments, instead of relying on case law which can lead to inconsistency and uncertainty. Further, as information of a persons past is easily obtained with present technological advancements, safeguards against similar fact evidence should be incorporated so as to ensure a fair trial.