DATE: OCTOBER 13, 1994
CASE NO.: 94-STA-33
In the Matter of
DEE KERRICK,
Complainant
v.
JLC INDUSTRIES, INC.,
Respondent
Appearances:
Dee Kerrick, pro se
Steven D. Riskin, Esq.
For the Prosecuting Party
H. Todd Bullard, Esq.
For the Respondent
Before: THOMAS M. BURKE
Administrative Law Judge
RECOMMENDED DECISION AND ORDER
Dee Kerrick ("Complainant") filed a complaint with the
Department of Labor on October 6, 1992, alleging that JLC
Industries, Inc. ("Respondent") took disciplinary action against
him in violation of section 405 of the Surface Transportation
Assistance Act of 1982, 49 U.S.C. § 2305 ("STAA"). The Acting
Regional Administrator of the Occupational Safety and Health
Administration in New York, New York, issued her determination on
March 23, 1994 for the Secretary of Labor, that complainant's
complaint had merit and Respondent's action violated section 405 of
the STAA.
Respondent filed a written objection to the Acting Regional
[PAGE 2]
Administrator's determination on April 14, 1994 and requested a
hearing. The Assistant Secretary of Labor for Occupational Safety
and Health becomes the prosecuting party in this matter by
operation of 29 C.F.R. §1978.107(a).
The hearing was held on July 13, 1994 in Rochester, New York.
Administrative Law Judge's exhibit No. 1 was admitted into
evidence; Prosecuting Party's exhibits No. 1 through 5 were
admitted into evidence; Respondent's exhibits No. 1 through 3 were
admitted into evidence. Upon the conclusion of the hearing, the
parties requested and were granted the opportunity to submit post-
hearing briefs. The Respondent's brief was received on September
14, 1994. The Prosecuting Party's brief was received on September
15, 1994.
FINDINGS OF FACT
Complainant, Dee Kerrick, is a forty-four year old tractor
trailer driver who was employed by Respondent, JLC Industries.
Complainant has a Class A special license to drive a truck and has
been a truck driver for over twenty years. Complainant was a full-
time employee for Respondent from March 1992 to October 1992.
Respondent is in the business of delivering cargo through out the
United States. It operates a terminal at 545 Colfax Street,
Rochester, New York. Respondent rents and leases many different
types of vehicles from DeCarolis Rent-a-Truck ("DeCarolis").
During the last week of September 1992, Complainant was
driving tractor 2180 which Respondent had rented from DeCarolis.
Tractor 2180 is capable of hauling an 80,000 gross pound trailer.
Complainant drove this tractor from Rochester, New York to Elk
Grove, Illinois then to Monroe, Ohio. Complainant then returned to
Rochester, New York on Sunday October 4, 1992 around 2:00 p.m.
The Complainant testified that during his return trip, exhaust
fumes began leaking into his cab. The Complainant explained that
he could not sleep in the bunk of the cab with the motor running
because the fumes came into the sleeper. Complainant had to drive
back to Rochester with the windows open due to the fumes.
Upon his return to Rochester, the Complainant filled out a
driver's vehicle inspection report stating that his truck had an
exhaust leak. Complainant left one copy of the vehicle inspection
report inside the truck and placed two copies, along with other
paper work, in a mailbox located on Respondent's premises.
[PAGE 3]
Complainant explained that the mailbox is used when his supervisor
is not at Respondent's premises to collect his paper work. Because
the Complainant returned on Sunday afternoon, no one was present at
Respondent's place of business to receive the report.
Complainant testified that he called his supervisor, Joe
DeBrock, on Monday morning, October 5, 1992. Complainant informed
DeBrock that the truck had an exhaust leak. Complainant testified
that DeBrock responded that the exhaust leak would be fixed.
DeBrock also told the Complainant that his next trip would be
that evening, October 5, 1992. Complainant was scheduled to make
a delivery to Canton, Michigan using the same truck that had the
exhaust leak. When Complainant arrived at work on that evening, he
started his truck, and he noticed that exhaust fumes still leaked
into his cab. Complainant turned off the truck, and because his
supervisor was not working since it was late in the evening, he
drove his own vehicle to DeCarolis to see if DeCarolis had worked
on the truck. Complainant was informed that no work order was ever
received on Tractor 2180. Complainant therefore filled out a
second vehicle inspection report indicating that the truck had an
exhaust problem. Complainant then returned home.
The Complainant testified that on October 6, 1992, DeBrock
called the Complainant at 7:00 a.m. and asked Complainant why he
had not taken his delivery out. Complainant asked DeBrock why he
had not fixed his truck; DeBrock failed to answer this question and
hung-up the phone. About one half hour later, DeBrock called the
Complainant and fired him for not making the delivery.
Since being fired by Respondent, Complainant has worked as a
truck driver hauling black top for an employer he could identify
only as "Collins" and hauling containers for Bill Dewick. He
worked for Collins from April 1993 to November 1993 before being
laid off because the work was seasonal. He worked for Dewick for
three weeks. He quit because he was not getting paid. Complainant
has been unemployed since working for Bill Dewick.
Complainant seeks the following remedies: reinstatement to his
former position at the wage rate and with the benefits to which he
would be entitled if he had not been discharged, recovery of back
wages with interest adjusted by interim earnings, reinstatement of
seniority, and expunging Complainant's employment records of
information related to the Complainant's discharge by Respondent.
Timothy Smith's Testimony[PAGE 4]
Timothy Smith testified on behalf of the Respondent. Smith is
employed by DeCarolis as a service manager. Smith testified that
DeCarolis' place of business is located in Rochester, New York, one
block from Respondent's place of business.
Smith testified that Respondent and DeCarolis are currently in
their second five-year agreement whereby DeCarolis rents and leases
many different types of vehicles to Respondent.
Smith informed that DeCarolis operates a facility in Ohio and
operates six other facilities in western New York. He testified
that there are about 4,000 service vendors throughout the United
States that service their vehicles. Smith explained that if a
driver experiences an emergency, the driver can call an 800 number
for instructions of where to go to have the problems fixed. This
service is available seven days a week, twenty-four hours a day.
Every vehicle rented by DeCarolis has a local telephone number
for Rochester, New York and a 1-800 number located on the dash
board in case of an accident or break-down. Smith explained that
if one of their customers brings a rented or leased vehicle into
DeCarolis' repair facilities, a determination is made whether the
repair can be made in a reasonable amount of time. If the vehicle
requires extensive repairs, the customer is offered a replacement
vehicle. Smith testified that Complainant did not request a
replacement vehicle on October 5, 1992.
Smith testified that after a driver returns from a delivery,
he is required to submits a driver's report. Repairs are made
according to the submitted driver's report. Smith explained that
normally Respondent's drivers bring the leased vehicles directly
back to DeCarolis after completing a delivery. Smith informed that
DeCarolis' shop is closed from 4:00 p.m. Saturday until 6:00 a.m.
Monday morning. Smith testified that DeBrock brought tractor 2180
in for repairs on October 6, 1992 at 8:30 a.m..
Brian K. Campbell's Testimony
Brian K. Campbell was employed by Respondent as a business
manager from May 28, 1990 until June, 1993. Campbell testified
that the chain-of-command for Respondent's company went from
DeBrock to himself then to Jack Cannon, president of Respondent.
Both Cambell and DeBrock had direct contact with the drivers.
[PAGE 5]
Campbell testified that Respondent is an "on-time"
trucking company which means that the Respondent provides next day
delivery service. Respondent requires all drivers to fill out a
safety and maintenance report prior to their departure. Respondent
maintained an 800 number which was open twenty-four hours a day for
a driver to call if he experienced mechanical problems. Campbell
also testified that drivers could call him or DeBrock collect at
any time if the driver experiences any problems.
Campbell testified that Xerox was one of Respondent's biggest
clients and that the October 5, 1992 load was a crucial one that
had to be delivered. Campbell explained that if there is any
mechanical problems with a vehicle, the driver normally calls the
dispatcher which allows the dispatcher to notify Xerox that there
will be a delay in delivery of its load and, if necessary, to
attempt to find a replacement vehicle. Campbell testified that he
did not receive any calls from Complainant requesting a replacement
vehicle. The contract with Decarolis permitted Respondent to
request a replacement vehicle if one of the rented DeCarolis'
vehicles broke down.
Campbell concluded that a driver's "dropping a load" or
failure to deliver a load on time would be a cause for termination
of his employment.
Jack Cannon's Testimony
Jack Cannon is the president of Respondent and Cannon
Industry. He has been the president of Respondent for about seven
years and the president of Cannon Industry for about fifteen years.
Respondent and Cannon Industry share office space; Cannon Industry
is the manufacturing division and Respondent is the transportation
division.
Cannon testified that in September and October 1992,
Respondent owned about eight trucks. He explained that Respondent
owned 60 percent of the vehicles it used, leased 40 percent of the
vehicles it used, and rented 5 percent. Cannon explained that
renting vehicles involves a short-term contract while leasing
vehicles involves a long-term contract.
Cannon testified that drivers are required to fill out a
vehicle inspection report on a daily basis. If the driver
experiences any safety or repair problem with the vehicle while
driving a truck, the driver is instructed to call the office or the
800 number. If the driver can not reach anyone at the office, they
are instructed to contact their supervisors through the chain-of-
command which went from DeBrock to Campbell then to Cannon.
[PAGE 6]
Cannon testified that DeCarolis had addition requirements with
respect to its vehicles. DeCarolis requires the driver to fill out
a pre-inspection report on the vehicle before it leaves the
DeCarolis premises and the driver fills out an additional report
when he returns the vehicle to DeCarolis. Cannon explained that
DeCarolis vehicles are kept at DeCarolis' premises.
If a driver experienced problems while driving a DeCarolis
truck, the driver is instructed to call the dispatcher for
Respondent. The driver is also instructed to call DeCarolis who
has a mechanic on duty twenty-four hours a day. DeCarolis'
mechanic would inform the driver of where to get the vehicle
repaired.
Cannon testified that if a driver has to deliver a load and
his truck has mechanical problems, the driver is expected to notify
dispatch. Cannon explained that this is required so that the
customer is informed about any delays in shipping. If a vehicle
needs repair, the driver is also instructed to call dispatch for
instructions on getting the vehicle repaired or getting a
replacement vehicle.
Cannon explained that a DeCarolis truck is to be returned to
DeCarolis at the completion of a trip. If the vehicle needs a
repair, the driver is to explain the problem on the driver's
inspection report which is left inside the truck. DeCarolis'
mechanics will than check and repair the vehicle.
Cannon testified that on October 6, 1992, he arrived at work
about 6:00 a.m. Cannon observed a trailer in the yard which was to
have been delivered. He informed DeBrock and DeBrock answered that
he would investigate why the trailer was not delivered. Cannon
received a call from a manager at Xerox inquiring about its load.
DeBrock then informed Cannon that the truck left in the yard had
Xerox's cargo.
Cannon testified that Respondent is an "on-time" company. He
explained that Respondent maintains a 97 to 98 percent on-time
performance with its customers. Cannon explained that the proper
conduct of a driver if he experiences a mechanical problem is to
notify the Respondent's dispatch and take the vehicle to DeCarolis
which is only one block away.
Cannon testified that grounds for termination include leaving
a load without calling dispatch. He emphasized that the refusal to
drive a truck that is mechanically defective is not grounds for
[PAGE 7]
termination. Cannon testified that he was not involved in the
decision to terminate Complainant.
DISCUSSION
Section 405 of the STAA was enacted in 1983. This legislation
is intended to promote safety of the highways by protecting
employees from disciplinary action because of an employee's
engagement in protected activity. Section 405(b) provides as
follows:
No person shall discharge, discipline, or in any manner
discriminate against an employee with respect to the
employee's compensation, terms, conditions, or privileges
of employment for refusing to operate a vehicle when such
operation constitutes a violation of any Federal rules,
regulations, standards, or orders applicable to
commercial motor vehicle safety or health, or because of
the employee's reasonable apprehension of serious injury
to himself or the public due to the unsafe condition of
such equipment. The unsafe conditions causing the
employee's apprehension of injury must be of such nature
that a reasonable person, under the circumstances then
confronting the employee, would conclude that there is a
bona fide danger of an accident, injury, or serious
impairment of health, resulting from the unsafe
condition. In order to qualify for protection under this
subsection, the employee must have sought from his
employer, and have been unable to obtain, correction of
the unsafe condition. 49 U.S.C. § 2305(b)(1983).
In a case brought under section 405, the initial burden is on
the Complainant to establish a prima facie case of retaliatory
discharge. To do so, Complainant must establish: (1) that he was
engaged in protected activity under the STAA; (2) he was the
subject of adverse employment action and the employer was aware of
the protected conduct when it took the adverse action; and (3)
there was a casual link between his protected activity and the
adverse action of his employer. Once Complainant establishes a
prima facie case, raising the inference that the protected activity
was the likely reason for the adverse action, the burden shifts to
Respondent to demonstrate a legitimate non-discriminatory reason
for its action. Even if Respondent demonstrates such a reason,
Complainant may prevail by showing that the stated reason was
pretextual. Moon v. Transport Drivers, Inc., 836 F.2d 226,
229 (6th Cir. 1987). If, however, the trier-of-fact decides that
there were "dual motives" for the adverse action, that is, that the
employer's action was motivated by both an illegal motive and a
legitimate
[PAGE 8]
management reason, the employer may prevail only by showing by a
preponderance of the evidence that it would have taken the same
action even if the employee had not engaged in the protected
activity. Palmer v. Western Truck Manpower, 85-STA-6,
Decision of the Secretary (January 11, 1987).
Protected Activity
The employee protection provision of the STAA provides that a
refusal to operate a motor vehicle constitutes protected action
"when such operation constitutes a violation of any Federal rules,
regulations, standards or orders applicable to commercial motor
vehicle safety" [when clause] or "because of the employee's
reasonable apprehension of serious injury to himself or the public
due to the unsafe condition of such equipment" [because clause]. 49
U.S.C. § 2305(b); see Boone v. TFE, Inc., 90-STA-7,
Decision of the Secretary (July 17, 1991).
a. When Clause
To invoke protection under the "when clause" of section
2305(b), a complainant must prove that his assessment of the
condition is correct. See Robinson v. Duff Truck Line, Inc.,
86-STA-3, Decision of the Secretary (March 6 1987), aff'd Duff
Truck Line, Inc. v. Rock, No. 87-3324 (6th Cir. 1988).
In the instant case, the Complainant testified that on October
4, 1992 while on his return trip to Rochester, New York, exhaust
fumes were coming into his cab.[1] He testified that he had to
drive the truck with the windows down, and he was unable to sleep
in the cab the previous evening with the motor running because of
the exhaust fumes.[2] The Complainant filled out vehicle
inspection reports describing the exhaust problem and left them
with his truck and in Respondent's mail box on October 4, 1992.[3]
He again filled out a vehicle inspection report on October 5, 1992
and submitted it to DeCarolis. The Complainant also called his
supervisor Joe DeBrock on October 5, 1992 and informed him that the
truck had an exhaust leak; DeBrock told the Complainant that the
problem would be fixed.[4] In fact, the record shows that
Respondent submitted a repair order to DeCarolis on October 6, 1992
to repair an exhaust leak and replace the muffler on the truck.[5]
The operation of tractor 2180 by the Complainant on the
evening of October 5, 1992 would therefore have violated 49 C.F.R.
§ 383.83 which provides in pertinent part:
(e) the exhaust system of every truck and truck tractor
shall discharge to the atmosphere at a location to the
[PAGE 9]
rear of the cab or, if the exhaust projects above the cab, at a
location near the rear of the cab.
. . .
(g) no part of the exhaust system shall leak or discharge
at a point forward of or directly below the
driver/sleeper compartment. The exhaust outlet may
discharge above the cab/sleeper roofline.
Complainant's testimony that tractor 2180 had an exhaust leak
and violated the Department of Transportation regulations is
corroborated by the repair order form which shows that the vehicle
had an exhaust leak repaired and its muffler replaced on October 6,
1992. Accordingly, the Complainant has shown that his refusal to
drive tractor 2180 constituted protective activity under the "when
clause" of STAA.
b. Because Clause
Respondent's actions also violated the "because clause" of
STAA. The purpose of this clause is the protection from employer
discipline to employees who refuse to operate equipment they
reasonably believe to be unsafe. Section 2305(b) provides the
standard for the application of the "because clause" as follows:
The unsafe conditions causing the employee's apprehension
of injury must be of such nature that a reasonable
person, under the circumstances then confronting the
employee, would conclude that there is a bona fide danger
of an accident, injury, or serious impairment of health,
resulting from the unsafe condition. In order to qualify
for protection under this subsection, the employee must
have sought from his employer, and have been unable to
obtain, correction of the unsafe condition.
The Complainant drove his truck for an entire day with exhaust
fumes escaping into his cab. He notified Respondent on October 4,
1992 and October 5, 1992 both in writing and orally of the problem.
When he arrived at work on October 5, 1992, the exhaust leak on
truck 2180 still had not been fixed. Clearly, exhaust escaping
into a cab would cause a reasonable employee apprehension of danger
to himself as well as to the public if the exhaust fumes caused him
to lose control of the truck. Therefore, Complainant has
established that his refusal to operate this truck also constituted
protected activity under the "because clause" of STAA.
Adverse Action[PAGE 10]
The Complainant testified that he refused to drive tractor
2180 on October 5, 1992 because the exhaust problem was not fixed
by Respondent. Instead, Complainant drove his own vehicle to
DeCarolis and inquired into why the truck was not repaired.
Complainant was told that no work order for tractor 2180 was ever
received by DeCarolis.[6] Complainant therefore filled out a
second vehicle inspection report and went home.[7]
The Complainant testified that on October 6, 1992 his
supervisor, DeBrock, called the Complainant and asked him why he
did not take out his load.[8] Complainant inquired into why the
truck was not fixed; DeBrock did not answer Complainant's question
and hung-up the phone.[9] About one-half hour later, DeBrock
terminated Complainant for not taking his load out.[10]
Respondent's actions constituted adverse action against
Complainant. Further, the Respondent was aware of the protected
activity when it took the adverse action. Complainant testified
that he filled out two vehicle inspection reports and telephoned
DeBrock informing him that the vehicle had an exhaust leak. In
fact, Cannon, President of Respondent, testified that DeBrock had
told him that the Complainant "refused to drive the truck . . .
."[11] Therefore, Complainant has established the second element
of his prima facie case.
Casual Link Between Adverse Action and Protected Activity
In establishing a prima facie case a complainant need only
raise the inference that his engaging in protected activity caused
the adverse action. Stiles v. J.B. Hunt Transportation, Inc.,
92-STA-34, Decision of the Secretary (September 24, 1993).
The proximity in time between protected conduct and adverse action
alone may be sufficient to establish the element of causation for
purposes of a prima facie case. Deeneway v. Matlack, Inc.,
88-STA-20, Decision of the Secretary (June 15, 1989).
Complainant has presented sufficient evidence that raises the
inference that the protected activity was the likely reason for the
adverse action. The record shows that the Complainant was
terminated from his employment within 24 hours of engaging in
protected activity. Furthermore, the content of the two telephone
conversations between the Complainant and DeBrock on October 6,
1992 establishes a causal link between the protected activity and
the adverse employment action. Complainant testified that he asked
DeBrock why his vehicle was not fixed; DeBrock failed to answer and
hung-up the phone. DeBrock called Complainant one half hour later
[PAGE 11]
and terminated Complainant's employment. Complainant's testimony
concerning the telephone conversation is uncontradicted.
Complainant has therefore established a prima facie case under
STAA.
Respondent's Defense
If the complainant establishes a prima facie case, the burden
shifts to the Respondent to rebut the presumption of disparate
treatment by producing evidence that suggests the employer's action
was motivated by legal nondiscriminatory reasons. However, the
Respondent need only produce this evidence, the ultimate burden of
persuasion is on the Complainant to show the action against him or
her was discriminatory. McGavock v. Elbar, Inc., 86-STA-5,
Decision of the Secretary (July 9, 1986).
The Respondent argues that there were "several legitimate
business reasons" for Complainant's termination. Respondent
asserts that the major reason for Complainant's termination was the
failure to deliver a load to Xerox which is one of Respondent's
largest customers. Cannon, President of Respondent, testified that
"leaving a load" is cause for termination. However, the
consequence of Complainant's decision to refuse to drive
Respondent's truck was the non-delivery of Xerox's load.
Respondent's argument that Complainant was fired for failure to
deliver a load is therefore not a distinct legal nondiscriminatory
reason for Complainant's termination.
Respondent also argues that Complainant failed to follow
company procedure when he decided not to drive this vehicle.
Respondent argues that Complainant failed to notify dispatch that
the vehicle had mechanical failure which would allow dispatch to
notify the customer that its cargo would not be delivered on time.
Complainant filled out a motor vehicle inspection report on October
4, 1992 when he returned to Rochester, New York stating that the
vehicle had an exhaust leak.[12] The Complainant left one copy of
the report in the truck and another in a mailbox provided by
Respondent.[13] On October 5, 1992, Complainant called DeBrock,
who is the dispatcher for Respondent, and told him that the vehicle
had an exhaust problem.[14] DeBrock told the Complainant that the
vehicle would be repaired.[15] When the Complainant arrived at
work on the evening of October 5, 1992, he discovered that the
truck was not repaired. Complainant therefore filled out a second
vehicle inspection report and submitted it to DeCarolis.[16]
Complainant notified the Respondent in writing and orally that the
vehicle needed to be repaired. The Respondent had an entire day to
either have the vehicle repaired or get a replacement vehicle. The
record
[PAGE 12]
shows that Complainant adequately followed the Respondent's
required procedures.
Respondent also argues that Complainant could have taken the
vehicle directly to DeCarolis where he would have received a
replacement vehicle. However, the Complainant could not have done
this when he returned from his delivery on Sunday October 4, 1992
because DeCarolis is closed from 4:00 p.m. Saturday until 6:00 a.m.
Monday.[17] Furthermore, Campbell, a former business manager for
Respondent, testified that if a DeCarolis vehicle experiences
mechanical failure and a replacement vehicle is required, the
driver could not on their own receive a replacement vehicle; the
driver had "to give us [Cannon, DeBrock, or Campbell] the call so
we could put everything in place."[18] Campbell emphasized that
the driver "had to give us the opportunity."[19] The Complainant
gave DeBrock the opportunity to get a replacement vehicle by
filling out a vehicle inspection report on October 4, 1992 and by
telephoning DeBrock on October 5, 1992. DeBrock, however, failed
to obtain a replacement vehicle.
The Respondent has failed to produce any evidence that shows
its termination of Complainant was motivated by legal
nondiscriminatory reasons. Even the president of Respondent
testified that Complainant was terminated because he refused to
drive the truck. Respondent's "legitimate business reasons" for
Complainant's termination are not supported by the record. The
record shows that Respondent terminated Complainant because he
refused to drive a vehicle that leaked fumes from the exhaust
system to the driver's cab. This dismissal was a violation of
section 405 of STAA.
CONCLUSIONS OF LAW
1. The Surface Transportation Assistance Act governs the
parties and the subject matter.
2. Complainant has demonstrated that he was engaged in
protected activity when he refused to drive tractor 2180 on October
5, 1992 because exhaust fumes were escaping into his cab, as the
evidence shows operation of this vehicle would have violated 49
C.F.R. § 383.83 and the evidence shows Complainant had a
reasonable apprehension of harm to himself and the public.
3. Complainant has demonstrated that his employment with
Respondent was terminated as a result of his protected activity.
4. Respondent has not demonstrated a legitimate non-
discriminatory reason for its termination of Complainant.
[PAGE 13]
RECOMMENDED ORDER
Based on the foregoing, the following order is recommended:
1. Respondent, JLC Industries, shall:
a. Reinstate Complainant, Dee Kerrick, to his
employment, effective immediately;
b. Pay directly to Complainant back wages plus
interest, adjusted by interim earnings; and
c. Reinstate Complainant his seniority and expunge
Complainant's employment records of information
related to his October, 6, 1992 termination of
employment.
THOMAS M. BURKE
Administrative Law Judge
NOTICE: The Recommended Decision Order and the administrative
file in this matter will be forwarded for review by the Secretary
of Labor to the Office of Administrative Appeals, U.S. Department
of Labor, Room S-4309, Frances Perkins Building, 200 Constitution
Ave., NW, Washington, DC 20210. The Office of Administrative
Appeals has the responsibility to advise and assist the Secretary
in the preparation and issuance of final decisions in employee
protection cases adjudicated under the regulations at 29 C.F.R.
Parts 24 and 1978. See 55 Fed. Reg. 13250 (1990).
[ENDNOTES]
[1] N.T. p.9.
[2] N.T. p.9.
[3] N.T. pp. 10, 15.
[4] N.T. p. 13.
[5] Government's exhibit no. 2.
[6] N.T. p. 14.
[7] N.T. p. 15.
[8] N.T. p. 16.
[9] N.T. p. 16.
[10] N.T. p. 16.
[11] N.T. p. 153.
[12] N.T. pp. 10-12.
[13] N.T. p. 10.
[14] N.T. p. 13.
[15] N.T. p. 13.
[16] N.T. pp. 15-16.
[17] N.T. p. 103.
[18] N.T. p. 126.
[19] N.T. p. 126.
