Tom Holland on the New Perspective

by Mark M. Mattison

On March 20, 2006, Tom Holland of the Evangelical Theological College of Wales spoke at the Puritan Reformed Theological Seminary, a conservative institution in Grand Rapids, Michigan. His lecture, entitled “A Reformed Response to the New Perspective on Paul,” summarized some of the arguments from his book, Contours of Pauline Theology, which I reviewed for The Paul Page in December of 2004.

As I mentioned in my book review, Holland’s criticism of the new perspective is unique and, I believe, deserving of serious consideration by Pauline scholars of all persuasions. Many conservative Reformed criticisms of the new perspective follow a familiar outline: They begin by listing propositions from historic Protestant confessions (assuming that they simply restate scriptural propositions), compare those propositions with selected quotations from one or more contemporary biblical scholars who advocate the new perspective, seek to demonstrate a difference (with varying degrees of success), and conclude that the new perspective must therefore be “heretical.” Not so with Holland, who better appreciates the differences between various biblical and theological disciplines.

He began his lecture by describing what he regards as the failure of Evangelicalism: “We have not focused on the texts of scripture; we have focused on the texts of the confessions. Being reformed is not being committed to the confessions, it is being committed to the convictions of the reformers, that of on-going reform.” Doubtless many evangelical biblical scholars will concur, including N.T. Wright, who has written of “the kind of serious biblical scholarship the Protestant Reformation was built on,” a tradition he is proud to “carry on … if need be, against those who have turned the Reformation itself into a tradition to be set up over scripture itself” (The Shape of Justification).

Holland went on to talk about the importance of distinguishing between historical theology, pastoral theology, philosophical theology, systematic theology, and biblical theology, arguing that “Biblical theology cannot be controlled by confessional interests. It must put all preferences aside and listen to the message of the sacred text.” Generally I would agree; however, I question the degree to which any of us is capable of completely extricating ourselves from our presuppositions and hearing the scriptural texts exactly as they would have been heard by those to whom it was first read aloud. I believe we can achieve this to a certain degree by rigorously articulating and admitting our own proclivities so that we can recognize the dissonance between the text and our own sensitivities (and those of others), but I question the epistemology of positivism which presumes that we are capable of approaching the text unfettered by our own presuppositions. Not to dwell on this point too long, what I do appreciate is Holland’s recognition of the distinction between biblical theology and systematic theology, a distinction which seems to me to be lost on some of those who are of the Calvinist persuasion.

The bulk of Holland’s lecture was dedicated to identifying methodological weaknesses of the new perspective, with a particular criticism of what he believes is “the assumption of uniformity” in reconstructing the belief system of second-temple Judaism (another prominent feature of his book). He quoted J. Neusner as stating that “What is wrong with the established view is simple. People join together books that do not speak the same language of thought, that refer to distinctive conceptions and doctrines of their own. If books so close in topic and sentiment as the four Gospels no longer yield harmonization [here he paused to register a quick point of dissent], books so utterly remote from one another as the Mishnah and Philo and Fourth Ezra and Enoch should not contribute doctrines to the common pot: Judaism.”

He went on to quote J.H. Charlesworth on the Pseudepigrapha: “In these writings, as in the Dead Sea Scrolls, we are introduced to the ideas, symbols, perceptions, fears, and dreams of pre-AD 70 Jews. Since none of them can with assurance be assigned to Pharisees, Sadducees, Zealots or Essenes, it is wise not to describe early Judaism in terms of four such sects; rather we must now think of many groups and numerous subgroups.”

However, I believe it may be overstating the case to argue that the new perspective necessarily presupposes an essential uniformity of thought among the various sects of second-temple Judaism. The two scholars quoted above clearly argue against homogenization, but that does not mean that they, like Holland, doubt that extrabiblical literature can yield insights about ancient Judaism or shed light on the scriptural text. For instance, as James D.G. Dunn has written, “Worth noting is the fact that J. Neusner, though fiercely critical of [E.P.] Sanders’ methodology, nevertheless accepts Sanders’ understanding of Judaism in terms of ‘covenantal nomism’ as valid. That rabbinic discussions presupposed the covenant and ‘were largely directed toward the question of how to fulfil the covenantal obligations’ is to Neusner a ‘wholly sound and … self-evident proposition’. ‘So far as Sanders proposes to demonstrate the importance to all the kinds of ancient Judaism of covenantal nomism, election, atonement, and the like, his work must be pronounced a complete success’ -- ‘Comparing Judaisms’, History of Religions, 18 (1978-9), pp. 177-91 (Jesus, Paul, and the Law: Studies in Mark and Galatians [Westminster: John Knox Press], 1990, p. 204, n. 16).

Similarly, in a recent review of Craig A. Evans’ book Ancient Texts for New Testament Studies, J.H. Charlesworth has written that the collection “will assist all interpreters of Scripture. The New Testament texts come alive with fresh meaning when read in the context of the literature of their time. Evans demonstrates how these texts provide meanings for words and concepts, clarify the history and sociology of the period, and illustrate the historical, exegetical, hermeneutical, and canonical context of the New Testament documents.” This is hardly the commendation of someone who believes that noncanonical literature cannot clarify the meaning of the scriptural text.

Another point of methodology criticized by Holland was “the assumption of dependency.” He stated that “Most of the Pseudepigrapha was written in Palestine while most of the NT was written to people throughout the Roman world. Is it really reasonable to think that the apostles refer to writings that most of their readers had no access to and expected their readers to interpret their statements in the context of these writings?”

He expressed the same sentiment during the question-and-answer session, when I asked what he thought about the use of the phrase “the works of the law” in 4QMMT since its meaning there appears to approximate the meaning proposed by Dunn in the letters of Paul. Holland questioned whether the recipients of Paul’s letters would have known of 4QMMT. But this again overstates the argument. The assertion that documents like the Dead Sea Scrolls can shed light on Paul’s letters doesn’t require that Paul’s audience have personal knowledge of a particular document. The point is merely that a certain term can be shown to have a particular meaning in a related first-century context.

Simply put, I’m still not persuaded that the literature of second-temple Judaism is irrelevant to the study of Paul’s letters.

The most interesting part of Holland’s presentation, however, was the last portion, his Reformed response to the new perspective. Ironically, his response not only challenges the new perspective but evangelical biblical scholarship as well. His response(s) consisted of four points:

·         We have not appreciated the corporate nature of the NT

·         We have not appreciated the OT dimension of the NT

·         We have not appreciated the New Exodus paradigm of the NT

·         We have not appreciated the paschal model for the NT

My review of his book highlights these arguments and celebrates the willingness of a conservative scholar both to question excessively individualistic readings of Paul and to locate Paul’s meaning on the map of a historical, biblical narrative instead of on the abstract grid of a systematic, philosophical construct. This is where Holland is at his best and it is precisely where I believe his contribution to the field of Pauline studies is worthwhile.

 

Response by Tom Holland

Dear Mark,

 

It was good to meet you at the lecture in Grand Rapids. You were very kind to restructure your day to attend an afternoon event and especially to go the extra mile in writing a report on the lecture for the Paul Page. I am glad to be able to respond to your comments in the report as you have invited me to do.

 

What you have written is very fair and you have highlighted the things I wanted to say. I am grateful for the positive comments in both your review of my book as well as in the report on the lecture. It is clear that the major difference we have relates to the Pseudepigrapha and its relevance to NT research. I understand why you are unhappy with my position and naturally I want to focus on this. I will, if you don't mind, also make reference to some other reviews that challenge me on the same point, as it is an ideal place to deal with this issue that has been raised elsewhere. All the reviews are available on my home page www.tomholland.instant.org.uk for your readers to access.

 

Firstly, let me say from the outset that my position is not that of someone who cannot step outside of the text of the Christian Bible through fear of losing his way, or even his confidence, in those texts -- indeed it is the very opposite. I was trained to interact with such texts and for many years used this method to interpret the scriptures for the people I taught. I was a Baptist pastor for eighteen years, and while the Pseudepigrapha did not figure highly in most commentaries  a couple of decades ago, I was more than comfortable in using the insights my teachers imparted, which were largely based on engagement with extra Biblical literature.

 

But, I do want to correct a possible misunderstanding. I have never said that the ITL is of no use, only of limited use (see Contours p. 60). I accept that they give us a good idea of the main issues occupying Jewish thought in the first century. These include the expectation of the Second Exodus, the raising up of a descendent of David and the fulfilment of many prophetic predications that related to this momentous event. I also accept that they can alert us to a meaning of a word that clearly existed among some of the communities of ITL that might fit the NT text in a surprisingly helpful way. But before transposing the meaning great care needs to be taken to ensure that the writer of the NT text is actually sharing the same understanding. What I am anxious to underscore is that we cannot construct a theology of ITL and use it as the key to NT thought.1 There was no such thing as a Jewish theology, only Jewish theologies. Even Rabbinical Judaism was a minority viewpoint at that time. Later, of course, it was to become the dominant (and representative as far as Rome was concerned) school of theology.

 

So to gather statements, for example about wisdom, and to argue that these are the source of the ideas of wisdom in the NT, is an example of abusing these texts. As you know, I have sought to use this as an example in Contours (appendix 4) to show how this material has totally confused the real picture of what the NT writers refer to in calling Christ "the wisdom of God". I am naturally delighted at the widespread agreement that my argument has elicited.

 

To put my case into the context of my visit to Grand Rapids: it is as if, having visited a range of churches in the US visit, I gathered all the views of the people I spoke to and merged them to produce 'the American view'. If I were to be so foolish as to give a lecture to a UK audience from the perspective of my synthesis of American Christianity, I would be doing all of the groupings that I spoke to a deep disservice, for even among those who had a lot in common, there were still some very important differences. I am sure you would feel the force of this and would be very unhappy for me impose on you the views of others I met with and addressed.

 

But even within a community upholding a common tradition, there are divisions. In a recent class of post graduate students, I asked for opinions on what the baptism of the Spirit meant. It was clear that there were, even in a class where the students had a common confessional position, a range of different opinions. I asked them how they would feel if I listened to all their views and then wrote up a position that they were to sign and embrace as their own. The students response was a firm rejection -- such a treatment would not represent the understanding they were concerned to preserve. If we cannot do this reliably for a group of likeminded theologians, what chance is there of doing if for such a disparate range of theological opinion that existed in Second Temple Judaism?

 

I have to confess, that, since writing Contours, I have come to see that the usefulness of the Inter Testamental Literature is even more limited for NT scholarship than I had previously appreciated. Even though Charlesworth has cautioned against misusing the Pseudepigrapha because of its complex theological diversity, from his endorsement of Craig Evans' book he is obviously very positive about it as a source of customs and social practices for Second Temple Judaism. Despite the endorsement of such an able scholar, I am forced to warn of the danger of assuming that customs were uniform throughout intertestamental Judaism. In this area I have come to think that Charlesworth, along with many others, is making a serious mistake.

 

Let me try to explain. In the early days of our married life my wife and I had regular debates as to the correct way of doing things and the meanings of certain practices and even words. We came from the same country, shared a common history and had the same language, yet in her home area, some 150 miles from where I was brought up, there was a slightly different culture from the one that had moulded my thinking and expectations.

 

I have encountered this difference in other contexts. As a Baptist pastor, I have done some itinerant preaching. It is interesting to find how practice and even understanding varies from one congregation to another. Differences exist, even between different congregations that are in the same town and of the same denomination. I have no doubt that this is also found in other Christian denominations. Words, rituals and practices all have a range of meanings that are particular to that one congregation. Ask any minister of his experience when he moves to pastor a new congregation -- there is always a steep learning curve!

 

An example of the above variation is the way funerals are conducted. In the town where I was a minister there were people from all over the British Isles. It was an education in itself to learn what adaptations I had to make to reflect the practices that they were used to and which they wanted their loved ones' funerals to follow.

 

Clearly the tribes of Israel had different traditions and value systems. You only have to read the OT to see this fact. Such differences can also be found in the NT documents themselves. In addition to the natural evolution of their local cultures, the Hebrews were influenced, depending on their geographical location, by a range of invaders and occupiers throughout their history. Hengel demonstrates the influence of the Greek occupation.2 Others identify the influences of other invaders and occupiers as well as the normal cross cultural influences of neighbouring states. In other words, even in the practice of customs, there is diversity. So, finding a practice in a document of the Pseudepigrapha and then claiming, without the required support, that it is evidence of Jewish understanding and practice, is to make a jump of such magnitude that no social anthropologist or historian could take as serious scholarship.

 

So, even in the useful information we get from the ITL about customs etc. we have to be very careful that examples of practice or understanding are not forced onto the NT text to support a meaning. The safest thing is to work with the texts that are the product of the group of people we are seeking to understand, and in this case, for the NT church, it is the OT biblical text. But, even in that collection of literature, there are many variations that ought to be recognised and respected!

 

And this is what is not being done! The Pseudepigraphal literature is being blindly used without the controls that the specialists in these fields of study would say are essential to good practice. I am forced to the conclusion that using this literature to open up the meaning of the NT is fundamentally flawed and with it are the conclusions which its adherents reach.

 

Such an example is found in Tom Wight's Jesus and the Victory of God (pp. 250-251). He draws our attention to how Josephus made demands on a man to become his disciple and uses this to explain the calling of the disciples by Jesus. The fact that Josephus had no religious mission, whereas Jesus obviously did, ought to cause us to question the transfer of the model. But other basic questions need answering. Is this practice related to Josephus' social status? It was a status that Jesus clearly never had. Is it a practice that was locally recognised rather than widespread -- in other words does it reflect the customs of a region or the entire nation? How can we establish its wider significance for Jewish practice? To use this example as the cornerstone of a major argument is building on very unsure foundations. This sort of analysis can be applied to much of the material that is used to 'enlighten' the NT text.

 

You mention in your report that after the lecture you asked me about 4QMMT. I replied, asking how widely such a text would be available for Paul's readers, or even Paul himself, to interact with. You rightly say this is not the point; that the text shows that such understanding did exist in Judaism. I agree with this, but the last thing that must be done is to take this meaning (which certainly does not have unanimous agreement) and impose it on the uses of the Greek form found in the NT. I warn of this in Contours pp. 217 & 232. Words can have different meanings in different contexts and this is true in the NT just as much as it is in the Pseudepigrapha. Only a careful evaluation of the context, and the argument being made can tell us how the word is being used and it is my contention that the full range of meanings found in the semantic domain for 'justify' is present in the NT writings. In some of these texts the meaning seems to match that of Dunn's reading of 4QMMT, but in other passages this is certainly not the case.

 

I have already argued in Contours that there are certainly 'covenantal nomistic' readings of the term present in Paul.3 However, I don't come to this conclusion by imposing the meaning from any outside text but from the arguments that are being made within the letters. I do not have a problem with the New Perspective view of justification being in some of the Pauline texts, but I certainly have a problem in arguing that it is in all of the uses of 'justify'. The point I have made is that Paul's audiences were victims of different misunderstandings, and the errors of one church must not be imposed on the other churches -- this would be just as disastrous as imposing the meaning of 4QMMT, if we could agree on it, onto the argument being made in any one of the NT documents. Because Paul writes into the situation of individual churches, we must assume he knows the issues they were struggling with and his argument was tailored to meet their needs. What justification might mean in one letter must not be presumed to mean the same in another, even though written by the apostle himself!

 

This response would be the same as I would make to Craig Evan's review of Contours.4 He also raises 4QMMT and adds that in 4Q521 we find allusions to words and phrases from Isaiah, in connection with the appearance of the Messiah. Evans argues that it is surely relevant to Jesus' reply to the imprisoned John, where Jesus alludes to similar prophetic vocabulary.

 

I do not find any problem in this. It simply demonstrates overlap in the way different Jewish groups interpreted scripture. However, it would be quite wrong to conclude that there was strict equivalence in their views of the Messiah and that of the NT writers. Indeed, others have noted5 the danger of transferring DSS material into the NT to understand theological details. Parallels do not necessarily constitute sources and even more so when the nature of the 'parallel' is not clearly understood. All that we have established is the widespread knowledge and influence of the OT texts, and that is the very point I have been seeking to make! However, how the different groups interpreted the details of these texts is another matter.

 

Just as I have failed to convince you, I am afraid you have not convinced me. But what I am anxious to make clear is that I am happy to embrace covenantal nomism for some texts, but not for others. I find no difficulty in accepting that some Jews had this perspective, but I certainly cannot accept that all Jews did. Sanders' conclusions have gone off the rails because he failed to recognise the diversity of Intertestamental Judaism. Consequently, the arguments that build on his conclusions are building on sand. Because of this, I cannot agree with Wright that justification is about ecclesiology (although in some Pauline texts it is!), and not about soteriology. In excluding soteriology, Wright has misrepresented the understanding of the reformers and has imposed one meaning on all texts. Both are methodologically wrong.

 

The issue of methodology is very important. It has been my goal to keep to those texts that the first-century believing community would have known, i.e. the scriptures of Israel. It is my commitment to scrutinising these texts that has led reviewers to speak of Contours being a significant breakthrough. In other words, the eclectic method failed to identify this particular thinking. Because scholars turned to the Pseudepigrapha and borrowed from its Wisdom tradition they failed to see that calling Christ 'the firstborn of all creation' (Col 1.15) was soteriological and rooted in the Passover. It was equally because the same scholars imported the meaning of hilasterion from 4 Macc 4.22 into Romans 3.25 that they failed to see the Paschal structure of the passage and how it contributed greatly to appreciating the Paschal theology of the early church.

 

And so, I would claim from these two examples that the use of the Pseudepigrapha has been hugely detrimental to gaining a clearer Biblical understanding. If the method of exclusion has born such significant fruit, it would be wise not to reject it too quickly in preference for a methodology of inclusion that to my mind has fragmented and diminished understanding rather than adding to it. I am encouraged by the range of scholars who have acknowledged that this issue needs to be reflected on.

 

So, any suggestion that the reason I cannot cope with the development of Biblical scholarship is a reflection of my conservative theological position, which seems to be being suggested by Bird in RBL6, does not understand either my development or myself. As a young pastor, I had grabbed this method with both hands and used it for many years before coming to realise its flaws.

 

The last mentioned reviewer says "Holland states the New Testament letters [were] written to communities outside of Palestine and presumably outside of access to most Pseudepigraphal writings (67). Yet this is patently false, not all of the pseudepigraphal writings were composed in Palestine (Aristeas and Jospeph and Aseneth were probably in Alexandria and the epistle of Jude for one quotes 1 Enoch and Assumption of Moses. Holland wants to argue that Paul's theology had the Hebrew Bible as its substructure but needlessly asserts in the process that Paul would not borrow or echo thoughts from a "dubious Palestinian perspective" (i.e. referring to the Pseudepigrapha) in the process."

 

I have to confess that the argument that Bird has made is certainly, to my mind, weaker than the one he has dismissed. He cites me correctly, saying that the gentile churches were "presumably outside of access to most Pseudepigraphal writtings" which I would have thought needs no defence, but he answers this by saying that three works of the Pseudepigrapha were "probably written in Alexandria". How does this deny the statement that most of the Pseudepigrapha was unknown by the gentile churches?

 

Bird then appeals to the apparent citation of a part of 1 Enoch found in Jude as evidence that the Pseudepigrapha was widely known. But this argument is far from persuasive. Why are these sorts of quotations not found littering the NT text if they have had the influence that they are supposed to have had on the thinking of the NT church? No one is denying that some people in Palestine, and maybe a few other places, might have known of some of the documents, but the likelihood of many gentile congregations knowing even a sample selection is remote. Also, the fact that the terminology means different things depending on the group the author belonged to means that we cannot, or should not, be assuming that they are all telling us the same message.

 

Furthermore, it is not until it can be established that Jude is quoting Enoch, and not a commonly known oral tradition that is attributed to Enoch, which inevitably a writer wanting to pass a work off as the patriarch's would naturally include, can the weight that he wants to give to the text of Jude be allowed. But even allowing it to be a direct quote from 1 Enoch, it is a single document, written specifically to Jews, possibly living in Palestine. That is not the sort of evidence that any historian would accept for concluding that this literature permeates the letters of Paul which were written to gentile churches throughout the empire. These communities were separated by hundreds of miles from the source of the vast majority of these documents. Not until it can be shown that these documents are turning up regularly throughout the Roman world can there be an appeal to them as keys to interpret Paul, or even the gospels themselves, for all were mostly written to non-residents of Palestine. And even then, as I have argued earlier, we have no right to assume that the terminology is the same within the Pseudepigraphal collection, never mind that it matches the meaning of the NT authors. I have to confess to being at a loss to understand why scholarship so readily embraces this material. I cannot imagine for one moment that such undisciplined thinking would be allowed past the door of a history department -- the historical/textual evidence is just not good enough.

 

And finally, in response to Bird, he claims that Jude cites from the Assumption of Moses. Bird is more confident in the way he claims this than are the experts in the text. Charlesworth for example has provided an insightful discussion and rejection of this proposal!7

 

I have also been criticised by Craig Evans. He says: "Major complicated questions of interpretation and criticism are treated too simply, with the author frequently lapsing into the logical fallacy of excluded middle. For example, NT interpreters err, H. says, in appealing to the Dead Sea Scrolls and the Pseudepigrapha, because the theological perspectives of these writings are not the same as the perspectives of the NT authors."

 

Evans goes on to say: "What he identifies as a "growing dependence" is the ongoing effort to flesh out and contextualize as much as possible the exegetical and theological discussions of late antiquity, out of which the writings of the NT emerged. Often it is this extracanonical literature that helps the interpreter understand how a given OT passage quoted by a NT writer was understood. Failure to take into account the parallels in the Scrolls, Pseudepigrapha, and other writings from late antiquity may well result in faulty interpretation and dubious theological inferences."

 

I have to confess that the logic loses me! Because I question the validity of using the Pseudepigrapha, I am guilty of seriously faulty interpretation. But that is the case I am making against using the Pseudepigrapha and I have not been shown by Evans, other than by his deep commitment to this literature, that there are grounds for relying on this corpus as a hermeneutical key!  The argument that I have made has been ignored and the charge is made that I lapse into "the logical fallacy of excluded middle". I am afraid that our thinking is in different parts of the universe! I refuse to allow these documents to control my reading of the NT text because I truly believe that they are the source of a "logical fallacy of a polluted middle".

 

If we apply the guiding principles that Hays8 has given for establishing the presence of a previous text in the argument of a text that we are considering, the possibility of Pseudepigraphal texts having any significant influence in the NT is very low indeed.

 

My position on the Pseudepigrapha and the DSS is not in any way confessional, it is solely on scholarly grounds that I refuse to give them the sort of control that many are allowing them to have. If this is not understood then I am afraid that what I have written has totally missed its mark.9

 

You have done me a great kindness to say that Contours is groundbreaking. The only reason I arrived at these conclusions was that I came to see that the Greek world was being imported into essentially Hebraic texts. In fact, my reservation about using the Greek texts and culture explains my concern about using the Pseudepigrapha. Indeed, I think a more reasonable case can be made for using these Greek texts than for the intertestamental texts because these writings, or at least many of the practices they record, were widely known throughout the Roman world and therefore their ideas were accessible to Paul's hearers and readers. This was not so with the Pseudepigraphal texts. If I had stayed with the methodology that Bird, Evans and yourself are so committed to, I would never have made the 'groundbreaking' progress.

 

Thank you again for your interaction and all that you do in serving the wider community interested in the theology of Paul. Your willingness to serve this community is a very valuable contribution to the task of wrestling with the texts of the Christian Scriptures.

 

With my very best wishes,

 

Tom Holland

The Evangelical Theological College of Wales

 

 

Notes

 

1I do accept Helyer's argument that the ITL can show us trends that we can reflect on and see if the same trends are reflected in NT understanding, but that is not the same as relying on details of vocabulary as a key to exegesis, which Helyer practices, see Helyer, R.L., "The Necessity, Problems, And Promise of Second Temple Judaism for Discussions of New Testament Eschatology" JETS 47/4 (December 2004) 597-615.

 

2Hengel, M.,  Judaism and Hellenism, 2 vols. ET London, 1974.

 

3For a full discussion see Contours, chapters 9 & 10.

 

4CBQ 68 2006 (3).

 

5Barrett, C.K., The Second Epistle to the Corinthians,  London, 1973,75 challenges those who use parallels concerning the Spirit in Qumran for understanding the NT doctrine of the Spirit

 

6http://www.bookreviews.org/pdf/4443_4477.pdf#search=%22michael%20bird%20contours%20of%20pauline%22

 

7J.H.Charlesworth and J.C.Mueller, New Testament Apocrypha and Pseudepigrapha. A Guide to Publications (ALTA Bibs 17; Metuchen, NJ: American Theological Library and Scarcrow Press, 1987) p. 77.

 

8Hays, R. B.,  Echoes of Scripture in the Letters of Paul, New Haven/London, 1989. See pages 29-32.

 

9I am encouraged by the warnings given by Helyer "Problems" 609-614 who, though he is very committed to the literature, cautions against their misuse by using similar arguments to what I am presenting.

 

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