*fn1 Plaintiff's Rule 12(n)(3)(b) Statement of Additional Material Facts P 1 ("Plaintiff's Additional Facts").
*fn2 Plaintiff's Additional Facts P 3.
*fn3 Plaintiff's Additional Facts P 3.
*fn4 Plaintiff's Additional Facts P 3.
*fn5 Plaintiff's Additional Facts P 3.
*fn6 Plaintiff's Additional Facts P 5.
*fn7 Plaintiff's Additional Facts P 6.
*fn8 Plaintiff's Additional Facts P 6.
*fn9 Plaintiff's Additional Facts P 7.
*fn10 Plaintiff's Additional Facts P 7.
*fn11 Plaintiff's Additional Facts P 7.
*fn12 Plaintiff's Additional Facts P 8.
*fn13 Plaintiff's Additional Facts P 8.
*fn14 Plaintiff's Additional Facts P 8.
*fn15 Plaintiff's Additional Facts P 8.
*fn16 Plaintiff's Additional Facts P 9.
*fn17 Plaintiff's Additional Facts P 9.
*fn18 Plaintiff's Additional Facts P 9.
*fn19 Plaintiff's Additional Facts P 9.
*fn20 Plaintiff's Additional Facts P 9.
*fn21 Plaintiff's Additional Facts P 10.
*fn22 Plaintiff's Additional Facts P 10.
*fn23 Plaintiff's Additional Facts P 10.
*fn24 Plaintiff's Additional Facts P 10.
*fn25 Plaintiff's Additional Facts P 10.
*fn26 Plaintiff's Additional Facts P 12.
*fn27 Plaintiff's Additional Facts P 12.
*fn28 Plaintiff's Additional Facts P 13.
*fn29 Plaintiff's Additional Facts P 13.
*fn30 Plaintiff's Additional Facts P 13.
*fn31 Plaintiff's Additional Facts P 15.
*fn32 Plaintiff's Additional Facts P 15.
*fn33 Plaintiff's Additional Facts PP 15-16.
*fn34 Plaintiff's Additional Facts P 16.
*fn35 Plaintiff's Additional Facts P 16.
*fn36 Plaintiff's Additional Facts P 16.
*fn37 Plaintiff's Additional Facts P 16.
*fn38 Plaintiff's Additional Facts P 16.
*fn39 Plaintiff's Additional Facts P 18.
*fn40 Plaintiff's Additional Facts P 17.
*fn41 Plaintiff's Additional Facts P 17.
*fn42 Plaintiff's Additional Facts P 19.
*fn43 Plaintiff's Additional Facts P 19.
*fn44 Plaintiff's Additional Facts P 19.
*fn45 Plaintiff's Additional Facts P 20.
*fn46 Plaintiff's Additional Facts P 20.
*fn47 Plaintiff's Additional Facts P 20.
*fn48 Plaintiff's Additional Facts P 20.
*fn49 Plaintiff's Additional Facts P 20.
*fn50 Plaintiff's Revised Memorandum in Opposition to Defendant Wickes' Motion for Summary Judgment p.2 ("Plaintiff's Revised Memo").
*fn51 Plaintiff's Additional Facts P 22.
*fn52 Plaintiff's Additional Facts P 22.
*fn53 Plaintiff's Additional Facts P 22.
*fn54 Plaintiff's Additional Facts P 25.
*fn55 Plaintiff's Additional Facts P 25.
*fn56 Plaintiff's Additional Facts P 25.
*fn57 Plaintiff's Additional Facts P 26.
*fn58 Plaintiff's Additional Facts P 26.
*fn59 Plaintiff's Additional Facts P 26.
*fn60 Plaintiff's Additional Facts P 28.
*fn61 Plaintiff's Additional Facts P 28.
*fn62 Plaintiff's Additional Facts P 28.
*fn63 Plaintiff's Additional Facts P 28.
*fn64 Plaintiff's Additional Facts P 29.
*fn65 Plaintiff's Additional Facts P 30.
*fn66 Plaintiff's Additional Facts P 30.
*fn67 Plaintiff's Additional Facts P 32.
*fn68 Plaintiff's Additional Facts P 32.
*fn69 Plaintiff's Additional Facts P 32.
*fn70 Plaintiff's Additional Facts P 32.
*fn71 Plaintiff's Additional Facts P 32.
*fn72 Plaintiff's Additional Facts P 32.
*fn73 Plaintiff's Additional Facts P 35.
*fn74 Plaintiff's Additional Facts P 35.
*fn75 Plaintiff's Additional Facts P 36.
*fn76 Plaintiff's Additional Facts P 36.
*fn77 Plaintiff's Additional Facts P 36.
*fn78 Plaintiff's Additional Facts P 36.
*fn79 Plaintiff's Additional Facts P 37.
*fn80 Plaintiff's Additional Facts P 37.
*fn81 Plaintiff's Additional Facts P 39.
*fn82 Plaintiff's Additional Facts P 39.
*fn83 Plaintiff's Additional Facts P 41.
*fn84 Plaintiff's Additional Facts P 42.
*fn85 Plaintiff's Additional Facts P 42.
*fn86 Plaintiff's Additional Facts P 42.
*fn87 Plaintiff's Additional Facts P 42 and 45.
*fn88 Plaintiff's Additional Facts P 42.
*fn89 Plaintiff's Additional Facts P 43.
*fn90 Plaintiff's Additional Facts P 43.
*fn91 Plaintiff's Additional Facts P 43.
*fn92 Plaintiff's Additional Facts P 43.
*fn93 Plaintiff's Additional Facts P 44.
*fn94 Plaintiff's Additional Facts P 44.
*fn95 Plaintiff's Additional Facts P 44.
*fn96 Plaintiff's Additional Facts P 44.
*fn97 Plaintiff's Additional Facts P 44.
*fn98 Plaintiff's Additional Facts P 49.
*fn99 Plaintiff's Additional Facts P 49.
*fn100 Plaintiff's Additional Facts P 49.
*fn101 Plaintiff's Additional Facts P 49.
*fn102 Plaintiff's Additional Facts P 49.
*fn103 Plaintiff's Additional Facts P 50.
*fn104 Plaintiff's Additional Facts P 50.
*fn105 Plaintiff's Additional Facts P 52.
*fn106 Plaintiff's Additional Facts P 52.
*fn107 Plaintiff's Additional Facts P 54.
*fn108 Plaintiff's Additional Facts P 54.
*fn109 See Plaintiff's Additional Facts P 54.
*fn110 Plaintiff's Additional Facts P 55.
*fn111 Plaintiff's Additional Facts P 55.
*fn112 Plaintiff's Additional Facts P 57.
*fn113 Plaintiff's Additional Facts P 57.
*fn114 Plaintiff's Additional Facts P 57.
*fn115 Plaintiff's Additional Facts P 57.
*fn116 Plaintiff's Additional Facts P 57.
*fn117 Plaintiff's Additional Facts P 58.
*fn118 Plaintiff's Additional Facts P 62.
*fn119 Plaintiff's Additional Facts P 62.
*fn120 Plaintiff's Additional Facts P 62.
*fn121 Plaintiff's Additional Facts P 65.
*fn122 plaintiff's Additional Facts P 65.
*fn123 Plaintiff's Additional Facts P 65.
*fn124 Plaintiff's Additional Facts P 67.
*fn125 Plaintiff's Additional Facts P 67.
*fn126 Plaintiff's Additional Facts P 67.
*fn127 Plaintiff's Additional Facts P 67.
*fn128 Plaintiff's Additional Facts P 67.
*fn129 Plaintiff's Additional Facts P 67.
*fn130 Plaintiff's Additional Facts P 67.
*fn131 Plaintiff's Additional Facts P 67.
*fn132 Plaintiff's Additional Facts P 67.
*fn133 Plaintiff's Additional Facts P 67.
*fn134 Plaintiff's Additional Facts P 67.
*fn135 Plaintiff's Additional Facts P 67.
*fn136 Plaintiff's Additional Facts P 68.
*fn137 Plaintiff's Additional Facts P 68.
*fn138 Plaintiff's Additional Facts P 68.
*fn139 Plaintiff's Additional Facts P 68.
*fn140 Plaintiff's Additional Facts P 68.
*fn141 Plaintiff's Additional Facts P 68.
*fn142 Plaintiff's Additional Facts P 64.
*fn143 Plaintiff's Additional Facts P 64.
*fn144 Plaintiff's Additional Facts P 64.
*fn145 Plaintiff's Additional Facts P 64.
*fn146 Plaintiff's Additional Facts P 72.
*fn147 See Plaintiff's Revised Memo p. 2.
*fn148 Plaintiff's Additional Facts P 72.
*fn149 Plaintiff's Additional Facts P 72.
*fn150 Plaintiff's Additional Facts P 74.
*fn151 Plaintiff's Additional Facts P 74.
*fn152 Plaintiff's Additional Facts P 74.
*fn153 Plaintiff's Additional Facts P 74.
*fn154 Plaintiff's Additional Facts P 76.
*fn155 Plaintiff's Additional Facts P 76.
*fn156 Plaintiff's Additional Facts P 76.
*fn157 Plaintiff's Additional Facts P 76.
*fn158 Plaintiff's Additional Facts P 80.
*fn159 Plaintiff's Additional Facts P 82.
*fn160 Plaintiff's Additional Facts P 82.
*fn161 Plaintiff's Additional Facts P 84.
*fn162 Plaintiff's Additional Facts P 86.
*fn163 Plaintiff's Additional Facts P 86.
*fn164 Plaintiff's Additional Facts P 87.
*fn165 Plaintiff's Additional Facts P 87.
*fn166 Plaintiff's Additional Facts P 89.
*fn167 Plaintiff's Additional Facts P 89.
*fn168 Plaintiff's Additional Facts P 89.
*fn169 Plaintiff's Additional Facts P 89.
*fn170 Plaintiff's Additional Facts P 89.
*fn171 Plaintiff's Additional Facts P 89.
*fn172 Plaintiff's Additional Facts P 91.
*fn173 Plaintiff's Additional Facts P 91.
*fn174 Plaintiff's Additional Facts P 92.
*fn175 Plaintiff's Additional Facts P 92.
*fn176 Plaintiff's Additional Facts P 108.
*fn177 Plaintiff's Additional Facts P 108.
*fn178 Plaintiff's Additional Facts P 108.
*fn179 Plaintiff's Additional Facts P 108.
*fn180 Plaintiff's Additional Facts P 95.
*fn181 Plaintiff's Additional Facts P 97.
*fn182 Plaintiff's Additional Facts P 97.
*fn183 Plaintiff's Additional Facts P 97.
*fn184 Plaintiff's Additional Facts P 98.
*fn185 Plaintiff's Additional Facts P 98.
*fn186 Plaintiff's Additional Facts P 98.
*fn187 Plaintiff's Additional Facts P 98.
*fn188 Plaintiff's Additional Facts P 98.
*fn189 Plaintiff's Additional Facts P 114.
*fn190 Plaintiff's Additional Facts P 114.
*fn191 Plaintiff's Additional Facts P 115.
*fn192 Plaintiff's Additional Facts P 106.
*fn193 Plaintiff's Additional Facts P 106.
*fn194 Plaintiff's Additional Facts P 107.
*fn195 Plaintiff's Additional Facts P 106.
*fn196 Plaintiff's Additional Facts P 125.
*fn197 Plaintiff's Additional Facts P 125.
*fn198 Plaintiff's Additional Facts P 125.
*fn199 Plaintiff's Additional Facts P 133.
*fn200 See Plaintiff's Additional Facts P 134.
*fn201 Plaintiff's Additional Facts P 125.
*fn202 Plaintiff's Additional Facts P 136.
*fn203 See Plaintiff's Additional Facts P 136-146.
*fn204 See Plaintiff's Additional Facts PP 147-155.
*fn205 Plaintiff's Additional Facts P 147.
*fn206 See Plaintiff's Additional Facts PP 156-161.
*fn207 Plaintiff's Additional Facts P 156.
*fn208 See Plaintiff's Additional Facts PP 162-164.
*fn209 Plaintiff's Additional Facts P 162.
*fn210 Plaintiff's Additional Facts P 166.
*fn211 Plaintiff's Additional Facts P 167.
*fn212 See Plaintiff's Additional Facts P 167.
*fn213 See Plaintiff's Additional Facts P 167.
*fn214 Plaintiff's Additional Facts P 170. [*36]
*fn215 Plaintiff's Additional Facts P 170.
*fn216 Plaintiff's Additional Facts P 170.
*fn217 See Plaintiff's Additional Facts P 170.
*fn218 Plaintiff's Additional Facts P 172.
*fn219 Plaintiff's Additional Facts P 170.
*fn220 Plaintiff's Additional Facts P 175.
*fn221 Plaintiff's Additional Facts P 175.
*fn222 See Plaintiff's Additional Facts P 175.
*fn223 See Plaintiff's Additional Facts P 175.
*fn224 Plaintiff's Additional Facts P 176.
*fn225 Plaintiff's Additional Facts P 176.
*fn226 Plaintiff's Additional Facts P 182.
*fn227 Plaintiff's Additional Facts P 182.
*fn228 Plaintiff's Additional Facts P 183.
*fn229 Plaintiff's Additional Facts P 183.
*fn230 Plaintiff's Additional Facts P 180.
*fn231 Plaintiff's Additional Facts P 180.
*fn232 Plaintiff's Additional Facts P 180.
*fn233 Plaintiff's Additional Facts P 185.
*fn234 Plaintiff's Additional Facts P 185.
*fn235 Plaintiff's Additional Facts P 185.
*fn236 Plaintiff's Additional Facts P 185.
*fn237 Plaintiff's Additional Facts P 185.
*fn238 Plaintiff's Additional Facts P 187.
*fn239 Plaintiff's Additional Facts P 188.
*fn240 Plaintiff's Additional Facts P 188.
*fn241 Plaintiff's Additional Facts P 188.
*fn242 Plaintiff's Additional Facts P 188. See also PP 197-200.
*fn243 Plaintiff's Additional Facts P 196.
*fn244 Plaintiff's Additional Facts P 196.
*fn245 Plaintiff's Additional Facts P 196.
*fn246 Plaintiff's Additional Facts P 196.
*fn247 Plaintiff's Additional Facts P 196.
*fn248 Plaintiff's Additional Facts P 196.
*fn249 Plaintiff's Additional Facts P 204.
*fn250 Plaintiff's Additional Facts P 205.
*fn251 Plaintiff's Additional Facts P 205.
*fn252 Plaintiff's Additional Facts P 205.
*fn253 Plaintiff's Additional Facts P 210.
*fn254 Plaintiff's Additional Facts P 210.
*fn255 Plaintiff's Additional Facts P 210.
*fn256 Plaintiff's Additional Facts P 210.
*fn257 Plaintiff's Additional Facts P 210.
*fn258 Plaintiff's Additional Facts P 211.
*fn259 Plaintiff's Additional Facts P 211.
*fn260 Plaintiff's Additional Facts P 211.
*fn261 Plaintiff's Additional Facts P 211.
*fn262 Plaintiff's Additional Facts P 213.
*fn263 Plaintiff's Additional Facts P 213.
*fn264 Plaintiff's Additional Facts P 213.
*fn265 Plaintiff's Additional Facts P 214.
*fn266 Plaintiff's Additional Facts P 214.
*fn267 Plaintiff's Additional Facts P 215.
*fn268 Plaintiff's Additional Facts P 215.
*fn269 Plaintiff's Additional Facts P 216.
*fn270 Plaintiff's Additional Facts P 216.
*fn271 Plaintiff's Additional Facts P 216.
*fn272 Plaintiff's Additional Facts P 217.
*fn273 Plaintiff's Additional Facts P 217.
*fn274 Plaintiff's Additional Facts P 217.
*fn275 Plaintiff's Additional Facts P 217.
*fn276 Plaintiff's Additional Facts P 219.
*fn277 Plaintiff's Additional Facts P 219.
*fn278 Plaintiff's Additional Facts P 219.
*fn279 Plaintiff's Additional Facts P 219.
*fn280 Plaintiff's Additional Facts P 220.
*fn281 Plaintiff's Additional Facts P 223.
*fn282 Plaintiff's Additional Facts P 223.
*fn283 See Plaintiff's Additional Facts P 223.
*fn284 Plaintiff's Additional Facts P 226.
*fn285 Plaintiff's Additional Facts P 226.
*fn286 Plaintiff's Additional Facts P 226.
*fn287 Plaintiff's Additional Facts P 227.
*fn288 Plaintiff's Additional Facts P 227.
*fn289 Plaintiff's Additional Facts P 228.
*fn290 Plaintiff's Additional Facts P 228.
*fn291 Plaintiff's Additional Facts P 228.
*fn292 Plaintiff's Additional Facts P 228.
*fn293 Plaintiff's Additional Facts P 228.
*fn294 Plaintiff's Additional Facts P 229.
*fn295 Plaintiff's Additional Facts P 230.
*fn296 Plaintiff's Additional Facts P 229.
*fn297 Plaintiff's Additional Facts P 240.
*fn298 Plaintiff's Additional Facts P 240.
*fn299 Plaintiff's Additional Facts P 241.
*fn300 Plaintiff's Additional Facts P 243.
*fn301 Plaintiff's Additional Facts P 243.
*fn302 Plaintiff's Additional Facts P 243.
*fn303 Plaintiff's Additional Facts P 244.
*fn304 Plaintiff's Additional Facts P 245.
*fn305 Plaintiff's Additional Facts P 245.
*fn306 Plaintiff's Additional Facts P 245.
*fn307 Plaintiff's Additional Facts P 245.
*fn308 Plaintiff's Additional Facts P 248.
*fn309 Plaintiff's Additional Facts P 248.
*fn310 Plaintiff's Additional Facts P 248.
*fn311 Plaintiff's Additional Facts P 249.
*fn312 Plaintiff's Additional Facts P 250.
*fn313 Plaintiff's Additional Facts P 250.
*fn314 Plaintiff's Additional Facts P 253.
*fn315 Plaintiff's Additional Facts P 253.
*fn316 Plaintiff's Additional Facts P 253.
*fn317 Plaintiff's Additional Facts P 259.
*fn318 Plaintiff's Additional Facts P 260.
*fn319 Plaintiff's Additional Facts P 263.
*fn320 Plaintiff's Additional Facts P 263.
*fn321 Plaintiff's Additional Facts P 263.
*fn322 Plaintiff's Additional Facts P 263.
*fn323 Plaintiff's Additional Facts P 263.
*fn324 Plaintiff's Additional Facts P 263.
*fn325 Plaintiff's Additional Facts P 265.
*fn326 Plaintiff's Additional Facts P 266.
*fn327 Plaintiff's Additional Facts P 267.
*fn328 Plaintiff's Additional Facts P 267.
*fn329 Plaintiff's Additional Facts P 270.
*fn330 Plaintiff's Additional Facts P 270.
*fn331 Plaintiff's Additional Facts P 272.
*fn332 Plaintiff's Additional Facts P 272.
*fn333 Plaintiff's Additional Facts P 10.
*fn334 See Plaintiff's Additional Facts P 22.
*fn335 Defendant's contend that plaintiff was only involved in one offensive incident at work. See Wickes Lumber Company's Memorandum of Law in Support of Motion for Summary Judgment ("WLC's Memo of Law") p. 10.
*fn336 See Plaintiff's Additional Facts PP 42-44.
*fn337 Plaintiff's Additional Facts P 64.
*fn338 Plaintiff's Additional Facts P 64.
*fn339 Plaintiff's Additional Facts P 64.
*fn340 Plaintiff's Additional Facts P 114.
*fn341 Plaintiff's Additional Facts P 114.
*fn342 Plaintiff's Additional Facts P 115.
*fn343 See Plaintiff's Additional Facts P 108.
*fn344 Plaintiff's Additional Facts P 215.
*fn345 Plaintiff's Additional Facts P 215.
*fn346 See Plaintiff's Additional Facts P 62.
*fn347 See WLC's Memo of Law p. 10.
*fn348 Plaintiff's Additional Facts P 22.
*fn349 Plaintiff's Additional Facts P 22.
*fn350 Plaintiff's Revised Memorandum p. 18.
*fn351 Wickes Lumber Company's Reply to Plaintiff's (Revised) Memorandum in Opposition to Defendant's Motion for Summary Judgment ("WLC's Reply") p. 4.
*fn352 Agency principles and the goals of Title VII law make appropriate some limitation on the liability of employers for the acts of supervisors. Meritor Sav. Bank v. Vinson 477 U.S. 57 77 91 L. Ed. 2d 49 106 S. Ct.2399 (1986) (Marshall J. concurring in the judgment). Where for example a supervisor has no authority over an employee because the two work in wholly different parts of the employer's business it may be improper to find strict liability. Id.
*fn353 Plaintiff's Additional Facts P 72.
*fn354 Plaintiff's Additional Facts P 89.
*fn355 Plaintiff's Additional Facts P 80.
*fn356 Plaintiff's Additional Facts P 82.
*fn357 See Plaintiff's Additional Facts P 82.
*fn358 Plaintiff's Additional Facts P 108.
*fn359 Plaintiff's Additional Facts P 108.
*fn360 Plaintiff's Additional Facts P 108.
*fn361 Plaintiff's Additional Facts P 92.
*fn362 Plaintiff's Additional Facts P 92.
*fn363 Plaintiff's Additional Facts P 98.
*fn364 See Plaintiff's Additional Facts P 125.
*fn365 See Plaintiff's Additional Facts P 180.
*fn366 Plaintiff's Additional Facts P 185.
*fn367 Plaintiff's Additional Facts P 185.
*fn368 Plaintiff's Additional Facts P 185.
*fn369 See Plaintiff's Additional Facts P 188.
*fn370 Plaintiff's Additional Facts P 188.
*fn371 See Plaintiff's Additional Facts P 196.
*fn372 See WLC's Memo p. 19.
*fn373 Plaintiff's Additional Facts P 114.
*fn374 Plaintiff's Additional Facts P 115.
*fn375 Plaintiff's Additional Facts P 216.
*fn376 Plaintiff's Additional Facts P 223.
*fn377 Plaintiff's Additional Facts P 223.
*fn378 Plaintiff's Additional Facts P 219.
*fn379 See Plaintiff's Additional Facts P 210.
*fn380 Plaintiff's Additional Facts P 205.
*fn381 Plaintiff's Additional Facts P 5.
*fn382 Plaintiff's Additional Facts P 6.
*fn383 Plaintiff's Additional Facts P 7.
*fn384 Plaintiff's Additional Facts P 7.
*fn385 See Plaintiff's Additional Facts PP 9-10.
*fn386 Plaintiff's Additional Facts P 13.
*fn387 See Plaintiff's Additional Facts P 188.
*fn388 WLC's Memo of Law p. 25.
*fn389 WLC's Memo of Law p. 25.
*fn390 WLC's Memo of Law p. 25.
*fn391 WLC's Memo of Law p. 25.
*fn392 WLC's Memo of Law p. 25.
*fn393 Plaintiff's Additional Facts P 9-10.
*fn394 Plaintiff's Additional Facts P 20.
*fn395 See Plaintiff's Additional Facts P 20.
*fn396 See Plaintiff's Revised Memo p. 29.
*fn397 See Appendix to Plaintiff's Response Volume I Exhibit E.
*fn398 There is no dispute that plaintiff and Stein White and Walker had similar working conditions.
*fn399 Plaintiff's Additional Facts P 9.
*fn400 Plaintiff's Additional Facts P 249.
*fn401 See Appendix to Plaintiff's Response Vol. I Exhibit E.
*fn402 Plaintiff's Additional Facts P 250.
*fn403 Plaintiff's Additional Facts P 253.
*fn404 Plaintiff's Additional Facts P 20.
*fn405 Plaintiff's Additional Facts P 10.
*fn406 Plaintiff's Additional Facts P 270.
*fn407 Plaintiff's Additional Facts P 16.
*fn408 Plaintiff's Additional Facts P 272.
*fn409 Plaintiff's Additional Facts P 20.
*fn410 Plaintiff's Additional Facts P 260.
*fn411 Plaintiff's Additional Facts P 17.
*fn412 Plaintiff's Additional Facts P 10.
*fn413 Plaintiff's Additional Facts P 267.
*fn414 Plaintiff's Additional Facts P 10.
*fn415 Plaintiff's Additional Facts P 272.
*fn416 Plaintiff's Additional Facts P 272.
*fn417 Plaintiff's Additional Facts P 263.
*fn418 Plaintiff's Additional Facts P 263.
*fn419 WLC's Memo of Law p. 30.
*fn420 WLC's Memo of Law p. 30.
*fn421 See Plaintiff's Additional Facts P 3.
*fn422 Plaintiff's Additional Facts P 5.
*fn423 See generally WLC's Memo of Law; WLC's Reply.
*fn424 WLC's Memo of Law p. 32.
*fn425 WLC's Memo of Law p. 32.
*fn426 WLC's Memo of Law p. 32.
*fn427 See Plaintiff's Revised Memo p. 33.