Tuesday, March 11, 2014

Dr. John Grabowski and JPII's take on Ephesians 5

St. Paul’s teaching on subordination has met with considerable public backlash since the advent of feminism in the late 19th and 20th centuries. Questions abound as to whether the teaching itself is even based on the message of Jesus, or on some abstractions of Judaic or Hellenistic practices of running a household. Dr. John Grabowski does well to point out the differences between non-Christian cultures’ approach to marriage versus the way the early Church lived out marriage in the light of St. Paul’s teaching. He explains how radically different the Christian husband’s headship looked versus the paterfamilias of the Roman society. Drawing largely from the thought of John Paul II, Grabowski fashions “Mutual Subordination of Husband and Wife” into an authentic, historical, and applicable document for today’s confusion about marriage. His argument is broken down by chapter as follows:

1) The authentic interpretation of Ephesians Five consists in mutual subordination as opposed to any sort of domination, as explained by John Paul II. The historical basis for this.
2) Help of other scolars to explain man and woman as made Imago Dei, and therefore complementary
3) The proper understanding of a husband’s headship, as related to Christ’s authority

To begin with, Judeo-Christianity has always viewed the human person, male and female, as made in the image and likeness of God. As a consequence of sin, personal relations have been severely wounded—to such a degree that a kind of male domination was seen to be acceptable in society in order to maintain order and unity. Although St. Paul would have been all too familiar with such a dominant view of women by men, particularly through his Roman citizenship and Jewish education, his teaching is not tainted by the surrounding culture, but is based, rather, on the fresh concept of Christ as servant of his bride the Church. Furthermore, he introduced to the ancient world a new approach to marriage which eliminated the curse of sin on personal relations by the grace of Christ’s self-sacrificial love. Therefore, the Christian household did look different in operation and dynamic than the Roman or Jewish household. It looked different because the husband derived his authority from Christ the Servant, and the wife also shared in that authority—largely in response to the initiative of her husband’s self-sacrificial love.

Indeed, it is the responsibility of the Christian husband to initiate the “living sacrifice” of his body for the sake of his wife, even to the point of death. St. Paul’s teaching really demands much more of the husband than contemporary interpretations of Ephesians care to admit. Read properly, there is no opportunity for the husband to take advantage, to dominate, or to “lord over” his wife if his intention is to imitate the authority and headship of Jesus. Rather, the sense of mutual subordination to Christ gets the first emphasis in the thought of John Paul II, and the subordination of a wife to her husband only follows to the degree that the husband is authentically imitating Christ as servant. The moment he diverts from the authority of Christ, is the moment he loses his wife’s respect.

The other scholars Grabowski cites besides the Pope are chiefly Angelo Cardinal Scola and Sister Prudence Allen, particularly in regard to their work on sexual complementarity. Their work is not to be confused with the myth of Aristophanes, which proposes that man and woman are just separate halves of a greater whole person. Nor is it, obviously, to be confused with Plato’s proposition that bodily existence aside, man and woman are the same. Rather, Scola and Allen teach that man and woman are distinctly other, whole, and unique from each other. When united in marriage, this distinction of persons gives rise to an imaging of the Trinity, especially in the begetting of a third, distinctly unique person.

Given the philosophical explanations from Scola and Allen, as well as the historical and exegetical analysis from Grabowski and John Paul II, one can begin to see how the Sacrament of Marriage differs from the feministic reactions to St. Paul’s teaching in Ephesians. In reality, the wife who was once seen as mere property by the Roman world is given the utmost dignity and authority due to her status as an adopted daughter of God in Christ. Only in light of Jesus’ defeat of sin and death is this marital dynamic made possible. Otherwise, the influence of sin and selfishness is too great a strain on marriage to be lived as a Sacrament. As we have seen so often in the contemporary world, many divorces result from a fundamental misunderstanding of the sacramentality of marriage (of course manifested in practical disorders: finances, infidelity, domination, etc.), whether the couple cares to admit it or not.

Lastly, Grabowski gives a thorough explanation to the controversial concept of the husband’s headship. As I have already mentioned in this regard, only insofar as the husband imitates Christ’s servant leadership, initiates self-sacrificial love and the laying down of his life, does he share in the authority of Jesus. Likewise, the husband’s headship is merely analogous to the relationship between Christ and the Church, and does not guarantee him any type of divinization or superior ontology to his wife. They are, after all, equal in dignity but with separate and complementary categories.

I have briefly pointed out the breadth and depth of Grabowski’s work in “Mutual Subordination of Husband and Wife”, but with full intent to make available the entire pdf document through various hypertext in this post. It is worth perusing for specific topics and for parish Pre-Cana events, as it was originally made available to Our Lady of Good Counsel parish.

Monday, March 3, 2014

JPII and Lectio Divina


Lectio Divina consists of three "steps" in approaching the Sacred Scriptures:

1) Meditation or chewing on the Word

2) Oratio or seeking the face of God

3) Contemplation or beholding the Lord


JPII says this of Lectio:

"Dear brothers and sisters, this development needs to be consolidated and deepened, also by making sure that every family has a Bible. It is especially necessary that listening to the word of God should become a life-giving encounter, in the ancient and ever valid tradition of lectio divina, which draws from the biblical text the living Word which questions, directs, and shapes our lives."


from "Novo Millennio Ineute": Apostolic Letter of His Holiness Pope John Paul II to the Bishops, Clergy and Lay faithful at the close of the Great Jubilee of the Year 2000. n. 39.

Ironically, it is more a question of being read by the Word than of reading the Word. The Word of God, after all, is "living and active..."

Tuesday, February 18, 2014

JPII, Dali, and Exorcism


Karol Wojtyla's education in Rome culminated in his doctoral thesis on St. John of the Cross: Questio de fide apud S. Joannem a Cruce (The Question of Faith according to St. John of the Cross). For Spanish Surrealist Salvador Dali, a question of faith is what determined dignified art from garbage. He too was inspired by his fellow Spaniard, and painted Christ crucified in accord with a sketch done by the Doctor of the Church:

Salvador Dali struggled with faith to a great extent, unable to reconcile it early on with his passion for Freudian psychology. However, because he placed so much emphasis on dreams, as did Freud’s Interpretation of Dreams, Dali’s inspiration for “Christ of St. John of the Cross” as a result of a dream he recalled was irresistibly convicting to him. He notes the affect of the dream on his work:


In the first place, in 1950, I had a ‘cosmic dream’ in which I saw this image in color and which in my dream represented the ‘nucleus of the atom’. This nucleus later took on a metaphysical sense; I considered it ‘the very unity of the universe’, the Christ! In the second place, when thanks to the instructions of Father Bruno, a Carmelite, I saw the Christ drawn by Saint John of the Cross, I worked out geometrically a triangle and a circle, which ‘aesthetically’ summarized all my previous experiments, and I inscribed my Christ in this triangle.

Not too many years before this dream, Dali requested in 1947 for an exorcism. A Carmelite friar, Gabriele Maria Berardi, performed the exorcism and was given a handmade crucifix in return.


The rite of exorcism used for Dali was dated 1614, and was later revised twice during the pontificate of John Paul II. The Pope is rumored to have performed two exorcisms, one successful and one unsuccessful. Fr. Gabrielle Amorth was Rome's exorcist at the time, and came to the aid of the Pope after the second unsuccessful attempt.

I want to suggest a correlation between Dali's obsession with Freud and his need for an exorcism, and refer to my previous post on JPII vs. Jungian/Freudian Psychology. While psychology can be enormously beneficial to discernment of spirits, I suggest it can also be a major impediment or excuse: recall men like Jim Morrison, Aldous Huxley, etc.

Dali's repentant response to grace was very admirable, and his post-conversion artwork reflects his interior disposition. Fellow surrealists persecuted him to a great degree, but he portrayed the strength and substance of the Gospel to be infinitely more significant than mere dreams.

For further reading on dream interpretation from a Catholic perspective, see Sirach 34.

http://www.williambennettgallery.com/artists/dali/portfolios/divine2.php

http://www.ewtn.com/johnpaul2/writings/prepontifical.htm

http://www.firstthings.com/web-exclusives/2007/12/god-in-the-gallery

Tuesday, February 4, 2014

JPII and Solzhenitsyn


In June of 1978, Alexander Solzhenitsyn gave the commencement address at Harvard concerning Soviet Russia and the weakness of the West. By mid October of the same year, Karol Wojtyla would ascend to the chair of St. Peter. “A direct gift from God” was Solzhenitsyn’s response to the news of the first Slavic Pope. Below are some examples of how desperate the socialist situation was in Solzhenitsyn’s eyes, and how the West was powerless to stop it with only capitalism as its standard.

He describes his concern for the West in a financial metaphor of sorts:

Relations with the former colonial world now have switched to the opposite extreme and the Western world often exhibits an excess of obsequiousness, but it is difficult yet to estimate the size of the bill which former colonial countries will present to the West and it is difficult to predict whether the surrender not only of its last colonies, but of everything it owns, will be sufficient for the West to clear this account[…] But the persisting blindness of superiority continues to hold the belief that all the vast regions of our planet should develop and mature to the level of contemporary Western systems, the best in theory and the most attractive in practice; that all those other worlds are but temporarily prevented (by wicked leaders or by severe crises or by their own barbarity and incomprehension) from pursuing Western pluralistic democracy and adopting the Western way of life. Countries are judged on the merit of their progress in that direction. But in fact such a conception is a fruit of Western incomprehension of the essence of other worlds, a result of mistakenly measuring them all with a Western yardstick. The real picture of our planet's development bears little resemblance to all this.[1]

At its core, Solzhenitsyn’s address identifies the West’s need for redemption—indeed, the entire world’s need! He continues, “All the celebrated technological achievements of progress, including the conquest of outer space, do not redeem the twentieth century’s moral poverty, which no one could have imagined even as late as the nineteenth century.[2]”

He accuses westerners of “weak human personality” due to avoidance of suffering, “decline in courage” from hiding behind rationalized laws based on weakness and cowardice, “lack of manhood” and “they [western governments] get tongue-tied and paralyzed when they deal with powerful governments and threatening forces, with aggressors and international terrorists”. By and large, Solzhenitsyn basically calls America and Western Europe, “girly men” compared with his own people.

He goes on to describe Soviets as stronger than westerners, on account of their sufferings:

But should I be asked, instead, whether I would propose the West, such as it is today, as a model to my country, I would frankly have to answer negatively. No, I could not recommend your society as an ideal for the transformation of ours. Through deep suffering, people in our own country have now achieved a spiritual development of such intensity that the Western system in its present state of spiritual exhaustion does not look attractive.[3]

To what does he attribute such weakness? Irresponsibility: “A total emancipation occurred from the moral heritage of Christian centuries with their great reserves of mercy and sacrifice. The West has finally achieved the rights of man, and even excess, but man’s sense of responsibility to God and society has grown dimmer and dimmer.[4]”

Now, based on my last post, anyone can see why Wojtyla’s election was an answer to Solzhenitsyn’s prayer! Redemption, Responsibility, Mercy…they all are at the heart of John Paul’s prophetic life. Furthermore, they are all rooted in Christ—the source of such abundant grace. But, when Christ is divorced from the public square, Solzhenitsyn speaks from his own experience:

Humanism which has lost its Christian heritage cannot prevail in this competition. Thus during the past centuries and especially in recent decades, as the process became more acute, the alignment of forces was as follows: Liberalism was inevitably pushed aside by radicalism, radicalism had to surrender to socialism, and socialism could not stand up to communism[…] The communist regime in the East could endure and grow due to the enthusiastic support from an enormous number of Western intellectuals who (feeling the kinship!) refused to see communism's crimes, and when they no longer could do so, they tried to justify these crimes. The problem persists: In our Eastern countries, communism has suffered a complete ideological defeat; it is zero and less than zero. And yet Western intellectuals still look at it with considerable interest and empathy, and this is precisely what makes it so immensely difficult for the West to withstand the East.[5]


Unfortunately, those who do not learn from the mistakes of history are doomed to repeat them. How true is the above statement even a quarter century later! We are too slow to learn from Solzhenitsyn and Wojtyla.

Nevertheless, there is hope—just as there was for Solzhenitsyn when Wojtyla was elected; when he visited him in 1993 (a few years after the fall of the Iron Curtain) and with John Paul’s canonization fast approaching this Easter. Not that Wojtyla is himself the source of the hope—but that he is a “witness to hope”. He is a witness to the rediscovery of our Christian heritage through the New Evangelization, finally being enacted in parishes nearly ten years after his passing. He is a witness to vindication from the despotism of Stalin and others. He is a witness to suffering, probably the most needed of all crosses.

Alexander Solzhenitsyn stood as a forerunner to Wojtyla, and Wojtyla stands as a forerunner to the Redeemer. With the Olympics in Russia this year, and the World Youth Day in Krakow following, it will be interesting to see what transpires in these forerunners’ homelands.







-----------------------------------------------------------------------------

[1] Alexander Solzhenitsyn. “A World Split Apart: Commencement Address to Harvard University, June 8, 1978” http://www.orthodoxytoday.org/articles/SolzhenitsynHarvard.php


[2] Ibid

[3] Ibid

[4] Ibid

[5] Ibid


Update: While the '14 olympics were low-profile for the most part, the Ukrainian/Russian conflict erupted soon after this post. It will interesting to see how the conflict turns out...
Further reading: http://www.catholicworldreport.com/Item/2978/his_beatitude_sviatoslav_shevchuk_speaks_truth_to_secular_powers.aspx

And again: http://www.catholicherald.co.uk/news/2014/03/13/ukrainian-catholics-fear-new-oppression-after-russian-takeover/

03/19/14 Update from http://www.aawsat.net/2014/03/article55329733:
Last month, when Vladimir Putin ordered that the Black Madonna of Kazan, the holiest icon of the Russian Orthodox Church, be flown over the Black Sea, many believed he wished to secure blessings for the Winter Olympics in Sochi.

It was the first time the icon, or rather a copy of it, since the original was stolen and possibly destroyed in 1904, was deployed to bless a peaceful enterprise. Over the centuries, the “Black Virgin” has been taken to battlefields to bless Russian armies fighting Swedish, Polish, Turkish, Persian, French and German invaders. Stalin sent it to Stalingrad in 1943 to ensure victory over the German invaders under Field Marshal Friedrich Paulus.

With Putin’s troops in control of Crimea and threatening to move further into Ukraine, we now know that the icon was brought in to bless a military operation this time as well.

Lastly, Weigel on the topic http://denvercatholicregister.org/opinion/orthodoxy-state-society/:
the Ukrainian Orthodox Churches faced a dramatic choice: stand in pastoral solidarity with the people, or stand with the state that was brutally repressing Ukrainian citizen-reformers? The Ukrainian Greek Catholic Church (UGCC), largest of the Eastern Catholic Churches (Byzantine in liturgy and Church organization, but in full communion with the Bishop of Rome), did not face this dilemma; the UGCC was long the safe-deposit box of Ukrainian national consciousness, and in the post-Soviet period it has devoted its public life to building Ukrainian civil society. But the Ukrainian Orthodox Churches did face a historic fork-in-the-road: civil society, or the state?


Monday, February 3, 2014

JPII and/vs Religious Freedom

Several questions arise in my mind as to how religious freedom should be interpreted in light of Personalism.  Thankfully, the Second Vatican Council dealt heavily with this issue in its Declaration Dignitatis humanae, and John Paul II proved to be a crucial contributor.  In an article for Communio, David Schindler has written an extensive study of the topic in question, inspired largely by the true intentions of Wojtyla for the Declaration.  The topic itself interests me tremendously, because it substantially clears up questions that have been obstacles in my understanding of the relationship between Personalism and Truth. 
“Freedom, Truth, and Human Dignity” is the comprehensive study written by Schindler to clarify a variety of interpretations of Dignitatis humanae’s approach to religious freedom.  He makes reference to John Courtney Murray’s “juridical approach” to Dignitatis humanae, alongside John Paul II’s “ontological approach”[1] in order to explain the process of redaction that the council fathers took to edit the formal documents.  Furthermore, Schindler makes the following basic argument, as I understand it, in summary of Wojtyla’s contribution (as recorded in what are called the “interventions” for Vatican II documentation, more specifically Acta Synodalia, abbreviated AS):
The dignity of the human person is dependent on the integrity of freedom and truth lived by him.  A person’s right to religious freedom must intrinsically correspond to his understanding of truth, and not as a “negative immunity”[2]from it.  To this end, freedom must be understood to stand for truth and not as freedom from truth. Fullness of truth is, ultimately, the Person of Christ.  In response to this Truth, a person only has the right to err insofar as he does not recognize the Truth.  He who denies the Truth abuses his freedom in the name of his right to religious freedom.
To the best of my ability, I have summarized Schindler’s argument for the “ontological approach” of JPII and the Second Vatican Council on religious freedom.  I will then flesh out this argument with explanations given by Schindler, Wojtyla, and others in an attempt to cover the entire scope of Schindler’s study “Freedom, Truth and Human Dignity”.  I also intend to show even more how Personalism must follow the same argument of Schindler in order to be in line with the thinking of the Church on human dignity.  I am aware that, to a degree, such a clear definition of human dignity can be offensive without the aid of mercy.  Indeed, I believe that mercy is also at the heart of the Church’s and Wojtyla’s view of the dignity of the human person in relation to God, that is, God’s merciful grace in helping people to seek the truth and abide by it.
 Schindler goes to great lengths to differentiate between the “negative immunity” stance connected with the “juridical approach” to religious freedom, and the “intrinsically positive good” connected with Wojtyla’s “ontological approach” to the same.  He further summarizes Wojtyla’s thinking as follows:
Wojtyła objected to the purely ‘negative’ concept of religious freedom as an, ‘immunity from coercion.’ Such a concept, he thought, lacked an adequate sense of the right to religious freedom as an intrinsically positive good owed to all persons.  Emphasizing religious freedom only in the negative terms of immunity leaves this right logically vulnerable to indifference in the matter of truth.[3]
Ironically, Wojtyla is often accused of the very thing he sought to avoid in the Second Vatican Council—indifference to the truth.  This is also true of his intentions for Personalism, namely, it is not meant to disregard truth in favor of an overemphasis on the freedom of the human person.  I find such a clarification very helpful in my doubts about Personalism, especially in regard to the question of its attitude toward virtue[4].  At the same time, it does not allow for a type of non-denominationalism either, insisting instead on the fullness of truth to subsist entirely in the Catholic Church.
Because of what is at stake in the topic of religious freedom, basically a strict attention to freedom and truth or a cowardly indifference to them, Schindler sides with Wojtyla’s emphasis not only on truth but on responsibility:
Again, Wojtyła insisted that one cannot say ‘I am free’ without saying at the same time that ‘I am responsible’ to God and others. ‘This teaching has its foundation in the Church’s living tradition of confessors and martyrs. Responsibility is, as it were, the culmination and necessary complement of freedom. This must be stressed, so that our Declaration may be seen to be deeply personalistic in the Christian sense, yet not subject to liberalism or indifferentism’[5]
Although the word “Truth” is sufficient as a compliment to freedom, Wojtyla adds an essential qualifier to truth by adding responsibility.  And responsibility is not limited to just individuals but entire governments in terms of insuring the religious freedom of individuals[6].  He takes great pains to ward off the abuse of duty to be responsible with freedom by essentially putting freedom at the service of truth.  In my opinion, it may be said that freedom is a means to truth.  Especially if truth is personal, as in Truth is the Person of Christ, then freedom is a means to the end of Truth.  Schindler agrees to this ‘means-end’ dynamic with different wording:
this abstraction of freedom from truth makes truth extrinsic to freedom: truth becomes a simple object of freedom rather than a natural end providing freedom with its original order as freedom.[7]
For this reason of means/end dynamic, Schindler defines the human person’s dignity as an “integrated order of freedom and truth”[8].  In light of this definition, government must take into account the proper understanding of man’s dignity, if it is to uphold a lasting approach to religious freedom.  Wojtyla and his fellow Bishops concluded, in the words of Schindler:
Indeed, they were convinced that it is only in the recognition by government that freedom is intrinsically tied to truth that the right to religious freedom can be sustained permanently and as a matter of principle for all human beings—whether they are believers or nonbelievers.[9]
 No government to date, especially the American and French constitutional experiments of the last few centuries, has successfully recognized the ontological reality of man’s dignity, as it relates to the juridical[10].  Instead they adopt a relativistic attitude towards truth, and an indifferent attitude towards freedom.  In the view of Wojtyla and the Bishops, such attitudes will ultimately erode the very framework of said governments.  If they do not alter their attitudes in favor of truth and the freedom of excellence and virtue, they will continue to disintegrate.
Now, it is not my intention to enter into an extended criticism of democracy or government, but it is worth noting that Schindler goes to great lengths to point out governmental inadequacies in his “Freedom, Truth, and Human Dignity”.  After all, the question of religious freedom is intimately linked with government in a pluralistic society.  My intentions are to continue to explore Schindler’s definition of human dignity as it relates to Personalism in Dignitatis humanaeand the Catholic understanding of religious freedom. 
According to Schindler, the original drafts of the Vatican II Declaration on religious freedom, “emphasized that truth alone had rights, and that error was at best to be tolerated”, but the final copy of the Declaration was much more Personalistic in scope:
The Council shifted its emphasis away from the formal question of truth to the rights of the human person [...] I argue in this article that the prevalent readings of DH today, while rightly recognizing the Council’s shift of emphasis away from the notion of truth formally considered to the notion of the person, fail for the most part to take note of the profound ways in which the issue of truth emerges once more, precisely from within this new context centered in the person (Ibid--elipses mine).
The human person is, in fact, the appropriate context for religious freedom.  But Schindler is quick to warn those who would read Personalism into the Declaration without the integration of truth and freedom.  Wojtyla also makes such a clarification by qualifying the type of personalism that he wanted to be read in the Declaration, as I have already quoted, “This must be stressed, so that our Declaration may be seen to be deeply personalistic in the Christian sense, yet not subject to liberalism or indifferentism”[11].  This qualification of Personalism is necessary, in my view, precisely because of the alternatives that Wojtyla points out in the aforementioned quote.  Again, much is at stake in the Church’s definition of religious freedom, including the very dignity of the human person as an ‘integration of freedom and truth’.
As previously noted, Wojtyla adds ‘responsibility’ as a qualifier for truth, and in particular, “responsibility to God and others”.  The dimension of Biblical shema, that is, love of God and love of neighbor, as inseparable parameters for Christian Personalism brings me tremendous satisfaction.  Without such parameters, we have relativism and indifference.  Therefore, Schindler clarifies Wojtyla’s “ontological approach” to the Declaration with an implicit “theological approach”:
The merely civil right to religious freedom asserted by Murray had to be tied in principle to an ontological-moral—indeed by implication ultimately theological—right, or, more precisely, had to be tied to some form of an ontology of freedom of excellence as distinct from freedom of indifference.[12]
Furthermore, Schindler narrows down this “theological approach” to the following:
That Jesus Christ is the ultimate and most basic foundation for an integrated view of freedom and truth was repeatedly stressed by Archbishop Wojtyla, as we have seen.[13]
I would merely add, in light of Schindler’s “theological approach” in connection with human dignity, that if man is an integration of freedom and truth---and that freedom is a means to truth—then, truth is ultimately the Person of Christ, the end and goal of all human inquiry.  So, the council fathers were right to shift the emphasis of religious freedom from truth to the person, knowing all along that Truth is himself a Person! 
In conclusion then, I admit to the truth of Personalism in regard to interpretingDignitatis humanae, so long as Personalism recognizes the supreme truth of the Person of Christ.  Likewise, human freedom is a means to truth, so long as coercion is not employed.  Since a person’s dignity is based on an integration of freedom and truth, other individuals and institutions are meant to be at the service of such integration and not as an obstacle or domineering impediment to it.  Interpreted correctly, thanks to the work of Schindler and others, a society in which religious freedom corresponds properly to personal dignity is attainable, and indeed, is already (but not yet) present in the Catholic Church.
      

  

[1] David Schindler.  “Freedom, Truth, and Human Dignity”.  Communio: International Catholic Review, 2013.  PDF available http://www.communio-icr.com/files/dlschindler40-2.pdf
[2] Ibid.
[3] Ibid.
[4] Father Servais Pinckaers.  Sources of Christian Ethics.  Catholic U Press, 1995. Thomistic account of freedom as either “indifference” or “excellence/quality”.
[5] Acta Synodalia or AS IV/2, 12. 
[6] Schindler explains that governments are in principle allowed to favor one religion over another, so long as those other religions are still allowed to function.
[7] David Schindler.  “Freedom, Truth, and Human Dignity”.  Communio: International Catholic Review, 2013
[8] Ibid.
[9] AS IV/2, 12
[10] Schindler: The truth of this argument is in fact verified historically, in that there exists no liberal society today whose legal-constitutional order has not over time evolved in just this direction of relativistic monism, with respect to the anthropological-ontological claims noted above regarding the nature and dignity of the human being.
[11] Ibid.
[12] Ibid.
[13] Ibid.