3 Freedom of information issues|
74. We are not a tribunal reviewing whether breaches
of the Freedom of Information Act 2000 (FOIA) have taken place
but see as our role in this inquiry as considering whether:
(a) the arrangements for examining whether
CRU breached FOIA are adequate;
(b) whether the six-month time limit on the
initiation of a prosecution where a public authority acts so as
to prevent intentionally the disclosure of requested information
needs to be revised; and
(c) whether UEA ensured that CRU was able
to meet the requirements of the legislation when it received FOIA
Freedom of Information legislation
75. The FOIA creating new rights of access to information
came into operation on 1 January 2005. CRU, as part of UEA, is
classed as a "public authority" for the purposes of
the FOIA. In his submission Richard Thomas, who was Information
Commissioner from 2002 until June 2009, explained the application
of the FOIA to scientific data held by UK universities:
the public must be satisfied that publicly-funded
universities, as with any other public authority in receipt of
public funding, are properly accountable, adopt systems of good
governance and can inspire public trust and confidence in their
work and operations [...] The fact that the FOIA requests relate
to complex scientific data does not detract from this proposition
or excuse non-compliance.
76. When he gave oral evidence, we asked Mr Thomas
if the legislation drew a distinction between, on the one hand,
scientific data and modelling and, on the other hand, administrative
records. He replied:
the broad answer [...] is no [...] First of all,
the legislation applies to information held by the public authority,
and information is not elaborated in that sense. [...] It is not
ownership. The legislation uses the word "held", and
in the Environmental Information Regulations [EIR] that phrase
"held" is slightly elaborated. If I can quote the regulation
for you there, "It is held by a public authority if the information:
(a) is in the authority's possession and has been produced or
received by the authority, or (b) is held by another person on
behalf of the authority." So that is an elaboration of the
concept of "held". It is not ownership.
77. Mr Thomas considered that the issues in this
case which were most relevant to the information law appeared
(a) the relevance and impact of the information
laws on scientific and academic research conducted within universities;
(b) the adequacy of section 77 of FOIA to
deal with suggestions that CRU researchers deleted information,
not in the course of normal work, but to frustrate FOIA/EIR
(c) the handling of a large number of FOIA/EIR
requests by UEA relating especially to climate change research
which (within CRU) it "held"; and
(d) whether this case illustrates that there
is scope to extend the "proactive" disclosure provisions
of FOIA as they relate to universities.
78. Parliament has created a presumption in favour
of disclosure but there are exclusions.
Mr Thomas explained:
There are over 20 exemptions to the fundamental
duty to disclose requested information in FOIA.[...] Eight of
the main exemptions are absolute and 16 are qualified. Qualified
means that there is a "public interest override," which
means that, even where the exemption applies, the public interest
considerations must be considered. In formal terms, there must
still be disclosureeven though the qualified exemption
appliesunless the public interest in the exemption outweighs
the public interest in disclosure.
Mr Thomas added that:
The exemptions are similar to those found in
other Freedom of Information laws in force in the world. I am
not aware which exemptions were considered by the University as
potentially applicable to some or all of the requests to CRU.
I can speculate that some or all of the following [...] might
have been considered:
(a) Section 22where the requested
information is intended for future (but imminent) publication;
(b) Section 40where disclosure of
personal data would breach any of the data protection principles;
(c) Section 41where the information
had been obtained from elsewhere in such circumstances that its
disclosure would constitute an actionable breach of confidence
under common law;
(d) Section 43 (qualified)where disclosure
would, or would be likely to, prejudice the commercial interests
of any person, including the public authority;
(e) Section 44where disclosure is
prohibited by another enactment or inconsistent with an EU obligation
(which may include some intellectual property restrictions); and
(f) Section 14 (not an exemption, strictly
speaking)where the request is vexatious.
79. We were grateful to Mr Thomas for explaining
the operation of the FOIA and EIR. He did, however, point out
that he did not have detailed knowledge of events at UEA since
leaving the Information Commissioner's Office:
I have no idea at all what has happened inside
my former office. I cannot say because this is a serious matter.
It depends a great deal on the circumstances of the particular
case, the evidence. I have had no direct contact with the office
as to how this case is being handled.
Alleged breaches of the Freedom
of Information Act 2000
80. Some of the hacked e-mails appear to reveal scientists
encouraging their colleagues to resist disclosure and to delete
e-mails, apparently to prevent them from being revealed to people
making FOIA requests. Below are examples, in chronological order,
of e-mails sent by Professor Jones which address FOIA and requests
E-mail: 1107454306 [Extract]
At 09:41 AM 2/2/2005, Phil Jones wrote:
Mike,[...]Just sent loads of station data to Scott. Make sure he documents everything better this time! And don't leave stuff lying around on ftp sites - you never know who is trawling them. The two MMs have been after the CRU station data for years. If they ever hear there is a Freedom of Information Act now in the UK, I think I'll delete the file rather than send to anyone. Does your similar act in the US force you to respond to enquiries within 20 days? - our does ! The UK works on precedents, so the first request will test it. We also have a data protection act, which I will hide behind. Tom Wigley has sent me a worried email when he heard about it - thought people could ask him for his model code. He has retired officially from UEA so he can hide behind that. IPR should be relevant here, but I can see me getting into an argument with someone at UEA who'll say we must adhere to it !. [...]
E-mail: 1219239172 [Extract]
Subject: Re: Revised version the Wengen paper
Date: Wed Aug 20 09:32:52 2008
[...] Keith/Tim still getting FOI requests as well as MOHC and Reading. All our FOI officers have been in discussions and are now using the same exceptions not to respond - advice they got from the Information Commissioner. As an aside and just between us, it seems that Brian Hoskins has withdrawn himself from the WG1 Lead nominations. It seems he doesn't want to have to deal with this hassle.
The FOI line we're all using is this. IPCC is exempt from any countries FOI - the Sceptics have been told this. Even though we (MOHC, CRU/UEA) possibly hold relevant info the IPCC is not part our remit (mission statement, aims etc) therefore we don't have an obligation to pass it on.
Subject: Re: Schles suggestion
Date: Wed Dec 3 13:57:09 2008
When the FOI requests began here, the FOI person said we had to abide by the requests. It took a couple of half hour sessions - one at a screen, to convince them otherwise showing them what CA was all about. Once they became aware of the types of people we were dealing with, everyone at UEA (in the registry and in the Environmental Sciences school - the head of school and a few others) became very supportive. I've got to know the FOI person quite well and the Chief Librarian - who deals with appeals. The VC is also aware of what is going on - at least for one of the requests, but probably doesn't know the number we're dealing with. We are in double figures.
One issue is that these requests aren't that widely known within the School. So I don't know who else at UEA may be getting them. CRU is moving up the ladder of requests at UEA though - we're way behind computing though. We're away of requests going to others in the UK - MOHC, Reading, DEFRA and Imperial College. So spelling out all the detail to the LLNL management should be the first thing you do. I hope that Dave is being supportive at PCMDI. The inadvertent email I sent last month has led to a Data Protection Act request sent by a certain Canadian, saying that the email maligned his scientific credibility with his peers!
If he pays 10 pounds (which he hasn't yet) I am supposed to go through my emails and he can get anything I've written about him. About 2 months ago I deleted loads of emails, so have very little - if anything at all. This legislation is different from the FOI - it is supposed to be used to find put why you might have a poor credit rating ! In response to FOI and EIR requests, we've put up some data - mainly paleo data. Each request generally leads to more - to explain what we've put up. Every time, so far, that hasn't led to anything being added - instead just statements saying read what is in the papers and what is on the web site! Tim Osborn sent one such response (via the FOI person) earlier this week. We've never sent programs, any codes and manuals.
In the UK, the Research Assessment Exercise results will be out in 2 weeks time.
These are expensive to produce and take too much time, so from next year we'll be moving onto a metric based system. The metrics will be # and amounts of grants, papers and citations etc. I did flippantly suggest that the # of FOI requests you get should be another.
When you look at CA, they only look papers from a handful of people. They will start on another coming out in The Holocene early next year. Gavin and Mike are on this with loads of others. I've told both exactly what will appear on CA once they get access to it!
E-mail: 1237496573 [Extract]
Subject: Re: See the link below
Date: Thu Mar 19 17:02:53 2009
[...] CRU has had numerous FOI requests since the beginning of 2007. The Met Office, Reading, NCDC and GISS have had as well - many related to IPCC involvement. I know the world changes and the way we do things changes, but these requests and the sorts of simple mistakes, should not have an influence on the way things have been adequately dealt with for over a century.
81. In his submission Andrew Montford stated that:
Research materials should be made available to
outsiders as a requirement of the scientific method. That scientists
have failed to do so is reprehensible, but the fact that they
have apparently also resorted to breaches of the Freedom of Information
Act in order to do so requires urgent attention from policymakers.
82. As we explained in the previous chapter, David
Holland was the author of several FOIA requests that were mentioned
in the leaked e-mails. In his submission he pointed out that on
9 May  in e-mail 1210367056, Professor Jones sent "my
formal information request to 'team' members Mann, Hughes and
You can delete this attachment if you want. Keep
this quiet also, but this is the person who is putting in FOI
requests for all emails Keith and Tim have written and received
re Ch 6 of AR4.
We think we've found a way around this.
83. Mr Holland also drew attention to e-mail 1212063122
dated 29 May 2008 in which Professor Jones asked Professor Mann:
Can you delete any emails you may have had with
Keith re AR4? Keith will do likewise. Can you also email [Eu]Gene
[Wahl] and get him to do the same? I don't have his new email
address. We will be getting Caspar [Ammann] to do likewise.
CORRESPONDENCE WITH THE DEPUTY INFORMATION
84. On 22 January 2010, when the Deputy Information
Commissioner, Graham Smith, issued a statement which suggested
that at l east some of the requested information should have been
disclosed in the absence of applicable exemptions, it gave support
to the criticisms of CRU's handling of FOIA requests. Mr Smith
The FOI Act makes it an offence for public authorities
to act so as to prevent intentionally the disclosure of requested
information. Mr Holland's FOI requests were submitted in 2007/8,
but it has only recently come to light that they were not dealt
with in accordance with the Act. The legislation requires action
within six months of the offence taking place, so by the time
the action came to light the opportunity to consider a prosecution
was long gone.
85. Mr Thomas commented that this was "clearly
a reference to section 77 of the Act and/or the near-identical
Regulation 19 of EIR".
Section 77 of the FOIA provides:
(a) a request for information has been made
to a public authority,
(b) under section 1 of this Act or section
7 of the Data Protection Act 1998, the applicant would have been
entitled (subject to payment of any fee) to communication of any
information in accordance with that section,
any person to whom this subsection applies is
guilty of an offence if he alters, defaces, blocks, erases, destroys
or conceals any record held by the public authority, with the
intention of preventing the disclosure by that authority of all,
or any part, of the information to the communication of which
the applicant would have been entitled.
2. Subsection (1) applies to the public authority
and to any person who is employed by, is an officer of, or is
subject to the direction of, the public authority.
3. A person guilty of an offence under this section
is liable on summary conviction to a fine not exceeding level
5 on the standard scale.
86. Mr Thomas added that the Deputy Commissioner
also appeared "to have in mind" section 127(1) of the
Magistrates Court Act 1980, which provides that
a magistrates' court shall not try an information
or hear a complaint unless the information was laid, or the complaint
made, within 6 months from the time when the offence was committed,
or the matter of complaint arose.
Mr Thomas confirmed in oral evidence that
because of the interaction with the Magistrates
Court Act, any prosecution must be brought within six months of
the offence being committed.
87. In its memorandum to our inquiry, UEA defended
CRU has been accused of refusing to release data
requested under the FOIA. There are many obstacles outside CRU's
control surrounding the release of data provided by NMSs [National
Meteorological Services]. Many FOIA requests made to CRU related
to primary data provided by the NMSs. Some of these data are subject
to formal non-publication agreements between the NMS and CRU.
Other primary data had been provided to CRU on an individual-to-individual
basis, with accompanying verbal agreements that they may be used
within the gridded dataset, but should not be passed on to others.
CRU responded to the FOIA requests for primary data by pointing
out that approximately 90% of the stations in the CRU dataset
are available from other sources, particularly GHCN.
88. On 29 January there was an exchange between UEA
and Mr Smith, the Deputy Commissioner. Brian Summers, the Registrar
and Secretary of UEA responded forcibly to Mr Smith's 22 January
press statement, which asserted that UEA had not dealt with FOIA
requests "as they should have been under the legislation".
He did not consider it was "acceptable that such a statement
which has led to an extremely damaging commentary on the University
[was] first communicated to the University by a journalist".
His letter goes on to defend UEA's actions in detail and to ask
that, if the Information Commissioner's Office (ICO) cannot retract
the 22 January statement, it issue a clarification regarding the
alleged breaches of the FOIA. A response from the ICO was issued
the same day. It did not retract the original statement but offered
1. [No] decision notice has yet been issued
and no alleged breaches have yet been put to the University for
comment. That matter has yet to be addressed, but it will be over
2. The fact that the elements of a section
77 offence may have been found here, but cannot be acted on because
of the elapsed time, is a very serious matter. The ICO is not
resiling from its position on this.
3. The ICO's position is as stated in point
2 above. The statement may be read to indicate that.
Under section 77, an offence may be committed by an individual,
not necessarily the public authority itself.
4. Errors like this are frequently made in
press reports and the ICO cannot be expected to correct them,
particularly when the ICO has not itself referred to penalties
or sanctions in its own statement.
89. UEA responded on 1 February thanking the ICO
for the clarification but setting out its concerns relating to
the press coverage of the ICO's original statement:
Your clarification that the press cannot infer
from your statement to the Sunday Times that it has been established
that the University (or indeed any individual associated with
the University) has breached the terms of the Freedom of Information
Act is welcome. [UEA's] reputation which has been subjected to
these damaging and incorrect assertions claiming to be based on
your statement and we must take some steps to put this right.
We will be writing to the media which carried reports based on
your statement, pointing out the inaccuracies and asking them
to rectify the position.
90. In his oral evidence Professor Acton questioned
the ICO statement of 22 January:
our principle is that prima facie evidence
is evidence which on the face of it and without investigation
suggests that there is a case to answer. To my mind if there is
prima facie evidence; why did I set up the Muir Russell
independent review? Prima facie evidence is not the same as, you
have been found to breach. [...] If it is sub judice, if, as we
had in the letter ten days ago from the ICO, the investigation
has not even begun, I am puzzled how we could have been found
to breach if there has been no investigation.
91. The ICO's most recent letter, dated 3 March,
in UEA's view, "makes plain that there is no assumption by
the ICO, prior to investigation, that UEA has breached the Act;
and that no investigation has yet been completed."
The ICO's letter confirmed that the "ICO is not pursuing
any investigation under section 77 of the Act. That matter is
closed as far as the ICO is concerned, given the statutory time
limits for action". It added that:
The ICO acknowledges your concern about the statement
made and the subsequent media and blog reports. Given that the
Deputy Commissioner has already been publicly associated with
the matter, any Decision Notice will be reviewed and signed off
by another authorised signatory.
We regret that the ICO made a statement to the
press that went beyond that which it could substantiate and that
it took over a month for the ICO properly to put the record straight.
We recommend that the ICO develop procedures to ensure that its
public comments are checked and that mechanisms exist to swiftly
correct any mis-statements or misinterpretations of such statements.
92. The disclosed e-mails appear to show a culture
of non-disclosure at CRU and instances where information (disclosable
or otherwise) may have been deleted, to avoid disclosure. The
Deputy Information Commissioner's letter of 29 January gives a
clear indication that a breach of the FOIA may have occurred but
that a prosecution was time-barred.
As, however, UEA pointed out, no investigation has been carried
93. It seems to us that both sides have a point.
There is prima facie evidence that CRU has breached
the Freedom of Information Act 2000. It would, however, be premature,
without a thorough investigation affording each party the opportunity
to make representations, to conclude that UEA was in breach of
the Act. In our view, it is unsatisfactory to leave the matter
unresolved simply because of the operation of the six-month time
limit on the initiation of prosecutions. Much of the reputation
of CRU hangs on the issue. We conclude that the matter needs to
be resolved conclusivelyeither by the Independent Climate
Change Email Review or by the Information Commissioner.
94. On the question of the six-month time limit on
the initiation of prosecutions, Mr Thomas pressed for a revision
of the law. He pointed out that apart from in the most blatant
cases "it will usually be impossible for the ICO to detect
an offence within 6 months of its occurrence" and thus to
be able to initiate a prosecution.
He drew attention to a recent debate in the House of Lords on
a proposal to amend the time limit. In reply, in the debate the
Parliamentary Under-Secretary of State at the Ministry of Justice
The Freedom of Information Act 2000 came into
force only in 2005, and [...] we have no evidence at present that
the current six-month time limit presents a systemic problem for
the Information Commissioner or any other prosecutor in taking
action under Section 77. [...] We will listen to the views of
the Information Commissioner and other interested parties on this
point, and if there is evidence that the current legislation is
causing systemic difficulties, we will look for ways to address
the matter, if necessary by means of an alternative legislative
vehicle in the future. However, I cannot go further than that
today on behalf of the Government.
No change was made to the legislation.
95. We consider that events at CRU throw light on
the operation of the Freedom of Information Act 2000 and, in particular,
whether there is a need to amend the time limit on prosecutions
from six months from the time the alleged offence was committed.
If the Minister was correct to assert in July 2009 that the
Government had no evidence that the current six-month time limit
presents a systemic problem, then it is now clear that such evidence
exists. Irrespective of whether or not CRU breached the Freedom
of Information Act 2000, we recommend that the Government review
the operation of section 77 of the 2000 Act and the six month
limit on the initiation of prosecutions provided by section 127(1)
of the Magistrates Court Act 1980.
VOLUME OF REQUESTS
96. In the face of allegations of poor handling of
FOIA requests, one of the explanations offered by UEA was that
July 2009 UEA received an unprecedented, and
frankly administratively overwhelming, deluge of FOIA requests
related to CRU. These amounted to 61 requests out of a 2009 total
of 107 related to CRU, compared to annual totals of 2 in 2008
and 4 in 2007 (University totals for those years were 204, 72
and 44 respectively).
97. At the oral evidence session Lord Lawson commented
on the increase in the volume of FOIA requests:
what had happened was there had been a very,
very small number of FOI Act requests to begin with and it was
in response to those that there was all the evasion, the lack
of disclosure and all the other things which we have seen in the
emails: discussions about possibly destroying evidence and so
on. All that came well before the 2009 flood of stuff. The 2009
flood, if you look at the sequence of events, was a response to
the refusal to give disclosure of various things before. That
was what came first.
98. There are two issues here: the adequacy of CRU's
handling of the FOIA requests and whether the increase in the
number of requests in July 2009 was a deluge. On the latter, Mr
Thomas said that, whilst agreeing that UEA had faced a significant
rise in FOIA requests in July 2009, he did not consider that a
total of 61 was a "huge number".
99. On handling, CRU claimed that it could not cope
with the significant rise in FOIA requests because it only had
three full-time academic staff.
We therefore wrote to UEA on 2 March 2010 to ask what extra resources
were provided to assist CRU cope with these requests. UEA responded
additional support was provided to the University's
Information Policy Compliance Manager (IPCM) who handles FOI requests.
This included rescheduling workloads to allow him to concentrate
on the CRU FOI requests and diverting secretarial support to provide
additional resource. Given the high volume of requests received,
the Director of Information Services (DoIS) also took an active
role in the first stage of a number of requests, thus providing
additional support to the IPCM. (Should any cases where the DoIS
was directly involved in the first stage be appealed then we have
arranged for the PVC Academic to adjudicate to ensure impartiality).
ISD also fast-tracked the merging of the Security Policy and Compliance
team to ensure that a fully trained back-up to the IPCM was available.
100. The Science Faculty also provided additional
administrative support, including that of the Director of Faculty
Administration, the most senior member of the Faculty's administrative
staff. UEA pointed out that many of the requests were of a very
technical nature and:
required scientific knowledge and understanding
of the subject area in order to provide the details. Despite the
additional administrative resources provided, the requirement
to respond to the 61 requests received in July 2009 impacted considerably
upon the work of CRU.
101. We also asked UEA to outline what legal advice
and guidance on handling had been offered to CRU in handling these
FOIA requests. UEA confirmed that the:
IPCM provided advice to CRU on the requirements
of the Act both generally, and in relation to any applicable sections,
exemptions or exceptions pertaining to the specific request. In
this latter role, the IPCM set out the requirements of any possible
exemption or exception, inclusive of the public interest test,
and elicited from CRU staff whether the public interest test had
been met. Additional advanced training was provided to the 'FOI
Contact' for the Faculty of Science, the Director of Faculty Administration.
In this role, the FOI contact acted as a support to CRU in the
location and retrieval of information and provided assistance
to the IPCM in exploring the application of the Act to the specific
102. On the evidence we took we have concerns about
the handling of FOIA requests by CRU. First, the disclosed e-mails
betray an attitude to freedom of information that was antipathetic
to the spirit of disclosure in the legislation. Mr Thomas pointed
the simplest approach, particularly where requests
tend to generate either a defensive attitude or place a great
burden on the public authority, is proactive disclosure in the
first place.[...] Public authorities ought to decide what really
has to be kept away from the public. If it is particularly sensitive
or there is a good reason for withholding it, fair enough, but
where there is no good reason for withholding information, then
why not proactively disclose it and avoid the hassle of large
numbers of requests?
103. Whether or not CRU liked it, those making FOIA
requests were entitled to have their requests dealt with in accordance
with the legislation and, if the information sought did not fall
within one of the exclusions provided by the FOIA, it should have
been disclosed. We have already recommended in paragraph 54
above that in future information, including data and methodology,
should be published proactively on the internet wherever possible.
However, a culture of withholding informationfrom those
perceived by CRU to be hostile to global warmingappears
to have pervaded CRU's approach to FOIA requests from the outset.
We consider this to be unacceptable.
104. In the face of such an unhelpful approach we
are not surprised that FOIA requests multiplied. When the surge
in FOIA requests hit CRU in July 2009 UEA provided extra resources
but because of their technical nature the same small group of
staff at CRU had a pivotal role in handling the requests. We are
not clear that the culture changed. We cannot reach a firm
conclusion on the basis of the evidence we took but we must put
on record our concern about the manner in which UEA allowed CRU
to handle FOIA requests. Further, we found prima facie
evidence to suggest that the UEA found ways to support the culture
at CRU of resisting disclosure of information to climate change
sceptics. The failure of UEA to grasp fully the potential damage
to CRU and UEA by the non-disclosure of FOIA requests was regrettable.
UEA needs to review its policy towards FOIA and re-assess how
it can support academics whose expertise in this area is limited.
105 Ev 8, para 3.2 Back
Qq 59-60 Back
EIR: Environmental Information Regulations 2004. Deriving from
European Directive 2003/4/EC these give rights of public access
to environmental information held by public authorities. Back
Ev 8, para 2.2 Back
Ev 9, para 3.6 Back
Ev 9, para 3.7 Back
Q 58 Back
Ev 159, para 6 Back
Intergovernmental Panel on Climate Change: Fourth Assessment Report Back
Ev 117, para 23 Back
Ev 118, para 32 Back
Ev 9, para 4.1 Back
Ev 10 Back
Ev 10, para 4.1 Back
Ev 10, para 4.2 Back
Q 56 Back
Ev 20, para 3.7.2 Back
"Scientists in stolen e-mail scandal hid climate data",
The Times, 28 January 2010 Back
Registrar and Secretary to Deputy Information Commissioner - 29
January 2010, UEA website, Correspondence between University of
East Anglia and the Information Commissioner's Office, www.uea.ac.uk/mac/comm/media/press/CRUstatements/ICOcorrespondence
UEA had asked the Deputy Commissioner to confirm that "your
statement cannot be taken to mean that there has been a demonstrable
breach of Section 77, which is a breach of the FOI which can result
in prosecution"; Registrar and Secretary to Deputy Information
Commissioner, 29 January 2010, UEA website, Correspondence between
University of East Anglia and the Information Commissioner's Office,
Deputy Information Commissioner to Registrar and Secretary - 29
January 2010, UEA website, Correspondence between University of
East Anglia and the Information Commissioner's Office, www.uea.ac.uk/mac/comm/media/press/CRUstatements/ICOcorrespondence Back
Registrar and Secretary to Deputy Information Commissioner - 1
February 2010, UEA website, Correspondence between University
of East Anglia and the Information Commissioner's Office, www.uea.ac.uk/mac/comm/media/press/CRUstatements/ICOcorrespondence Back
Ev 39, para A Back
Ev 39, annex Back
UEA website, Correspondence between University of East Anglia
and the Information Commissioner's Office, www.uea.ac.uk/mac/comm/media/press/CRUstatements/ICOcorrespondence Back
Ev 10, para 4.3 Back
HL Deb, 21 July 2009, col 1571 Back
Ev 20, para 3.7.4 Back
Q 9 Back
Q 68 Back
Q 92 [Professor Acton], Ev 20, para 3.7.4; Ev 37, Q 1 Back
Ev 37, para 1 Back
Ev 37, para 1 Back
Ev 37, para 2 Back
Q 70 Back