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This essay was published in 2007 in ICFAI Press’ anthology of essays titled ‘Women Balancing Home and Career’.
Bhagya is a fifty year-old mother of two children. Her older child, a daughter, ismarried and is herself a new mother. Her second born, a son, is in ninth grade at a boarding school not too far away from her home.
Bhagya is also a working woman. She works as a house maid in two homes, doing various chores as the day-to-day running of her employers’ households demands – cleaning, cooking, babysitting and grocery shopping.
During the last set of holidays when her son came home from boarding school, she discovered that his left eye, which had taken a hit from a ball three years ago, was now on the verge of going blind. Four months ago, her son had lost the pair of spectacles she had purchased to try and stem the deterioration in that eye. The consequent strain on the eye aggravated the condition.
A visit to the eye doctor was in order, obviously. So she went to work early one day, scrambled to finish all her work and rushed home to take her son to the doctor. A rather lengthy visit to the doctor followed during which they could not meet the doctor that could help them. This meant a follow up visit the next day, again taking time off from work. This time she took a neighbor with her, met with the doctor, learned that her son’s eye condition was not curable and that he would go blind in that eye, left him with her neighbor to get an eye glass prescription for his right eye and rushed to work in time to put in a whole day’s worth.
That is the predicament of a working mother in these times.
She needs to work; she is primarily responsible for her children; she has no extended family to reach out to for regular daycare or in times of emergencies; she is at the mercy of neighbors and employers to accomplish household tasks during her work day; the needs of her children, beyond a certain limit, necessarily take the back seat in order to preserve the goodwill of her employers.
What are the issues that face working mothers? Is there such a thing as work/family balance? If there is, whose responsibility is it to ensure that working women achieve that balance?
First a few parameters and assumptions that are at play in this essay:
For purposes of distinction, this essay will refer to mothers whose only activity is the care of their families as “stay at home mothers” and will refer to mothers who do any sort of paid or unpaid work which is distinct from taking care of their households as “working mothers”. However, it should be made clear at the outset that whether mothers stay at home or go outside of their homes to work, the fact is they all work. “Stay at home mothers” is not used pejoratively.
Notwithstanding this, the paper mainly discusses problems faced by professional working mothers, on the understanding that some of them may face all the issues and others may face some with very few facing none of the issues.
III. Mothers in the Workforce: The Juggling Act
The term “juggling act” is a close approximation of the state working mothers find themselves in in their daily lives. I say close approximation
because when a juggler performs his or her act, what you see is that all the balls, the dumbbells or whatever else the juggler is using in the act neatly fall into place, each one in perfect harmony with the other, and all of them in harmony with the juggler.
Unfortunately, that is not true in the case of a working mother. If her career is not crashing to the floor then parenting is splattering onto the all. If her health is not ramming into the ceiling, then her social and familial relationships are flying out the window.
According to Ann Crittenden, Pulitzer prize nominee and author of The Price of Motherhood,[i]
Working mothers put in longer hours than almost anyone else in the economy…. Time-use surveys confirm that as women enter the workplace, they take on the equivalent of two full-time jobs, forcing them to cut back on everything in their lives but paid work and children.
Women on this path to paid work and children find that it is strewn with road blocks, bumps, detours, excruciatingly painful choices and other impediments. Even before the time working women decide whether to have children or not right up to the time the children leave home to go away to college, working women encounter prejudices, inhospitable work conditions and entrenched social and familiar attitudes with regard to parental roles.
A. The “Working Mothers Don’t Cut It” Argument
The prejudices against women being able to handle both work and childcare start making an appearance even before “working women” become “working mothers”. A year ago, the advertising profession found itself in the middle of a storm raging over the remarks of one of the stars of the British advertising industry, Neil French.[ii] According to French, “Women don’t make it to the top [in the advertising
industry] because they don’t deserve to. They’re crap.” Later, he clarified as to what he meant by “crap,” I didn’t say all female creative directors are crap. If you can’t commit yourself to any job then, by definition, you’re crap at it. Nobody deserves a job unless they can commit to it.”
By “commit to it” French presumably meant deciding not to have children. It is assumed, in French’s words, that women “will wimp out and go suckle something.”
Although attitudes such as this may seem outdated (what with images of women handling both family and workplace pressures with panache flooding popular culture), it is not so, according to Nancy Wonk, Co-Chief Creative Office at Ogilvy Toronto,… [I]n his honest opinion he was voicing the inner thoughts of legions of men in the senior ranks of our business. Before us was a big part of the explanation of why more women aren’t succeeding in advertising.[iii]
This scenario is not limited to the advertising field alone. The legal profession has seen similar upheavals in the United States, with women making up a measly seventeen per cent of partners, and this despite the fact that women make up fifty per cent of all law school graduates.[iv]
In the “macho” work environments of advertising and law (and conceivably other professions such as publishing and academia), “part-time” and flex-time” are dirty words, stratospheric levels of billable hours and sufficient “face time” (neither of which, ironically, is necessarily
directly proportional to productivity) are viewed as evidence of a person’s commitment to the profession and treated as parameters for deciding compensation and elevation to top levels.
There is the assumption that women, if they have families to take care of, simply cannot work these hours.[v] Karen Lockwood, a partner at a Washington law firm, describes this “maternal wall” as the “unstated assumption among male partners that women who return to firms after having children will automatically be less willing to work hard or will be less capable than they were prior to that — resulting in less-choice assignments or less-senior postings.”
A working woman, therefore, even before she herself has reached a decision as to whether or not she will have children, enters her profession with certain prejudices already stacked against her.
This ‘maternal wall’[vi] and the idea that women will eventually “wimp out to go suckle something” serve to cloud male partners’ (in most cases the decision makers) view of working women and their work, as Wonk says,[vii] no matter how capable, driven or smart the women are.
And if you thought this sort of prejudice against working women and mothers is at play only in large professional firms, think again. I recently talked to an acquaintance about possibly hiring someone who was available to work as a housemaid in her household and the first question I got was whether the housemaid had children. Why? Because, if the housemaid had children, then she would ask for time off to take her children to the doctor or to deal with school issues. If that is not discrimination based on gender and familial status, then I don’t know what is.
B. Once You Get Out, It’s Hard to Get Back In
In the sort of workplace paradigm described above, it is hardly surprising that women are forced to spend time considering the possible impact of having children on their lives in general, and their careers in particular. There are various factors that come into play in that sort of thought process. There is the assessment of the implications of having a child on the family’s finances – what happens if it becomes necessary for the mother to stay home once the baby is born; what happens if the mother does not have the same career path as before the child is born; can the family survive on one income, that of the father; how long can the mother afford to stay home to take care of the baby before she must return to gainful employment; how long must the mother work before she can save enough money to take a few years off from employment.
Then there are social and medical factors to consider – the pressure from family to have children or perhaps the advancing age of the woman making it medically necessary to have a child without waiting any longer.
Finally, the career factor – can a mother expect to have a successful career after she has a child; what impact does motherhood have on a woman’s career prospects?
No matter how much analysis goes into the decision to have a child, once women take time off to have children, it is never the same as before having a child.
In a landmark study published in the Harvard Business Review last year[viii], the authors found that while many factors are at play in forcing a woman to take time off from work – pregnancy, childcare, caring for a family member, etc., which are only exacerbated by the long hours that professional careers demand – it is incredibly difficult for mothers to get back to work from their hiatus, a “process full of compromise and failure.”
Not that the women did not want to return to work. The study found that two-thirds of highly qualified women who were at home with children wanted to get back to work and full-time. But hard data does not support their ambitions. Women made less money when they took time off than if they had not taken time at all (the longer the women stay out the lesser the salary they can expect when they return). Women were concerned about skills attrition while they were away from work and about being left behind while their peers moved on to higher positions.
Is it any surprise then that one third to one half of all professional women in the U.S. forego having children so they can focus on their careers?[ix]
C. The Daily Grind Just Got More Relentless
In the face of these incredible odds, women do have children and they do get back to work. Once they do, it is obvious that now there is an added layer of responsibilities.
Not only do women have all of the household and workplace responsibilities they had before having children, now they have another human being to take care of and nurture.
Just imagine twenty-four hours in an average working mother’s life: wake up early in the morning to get her children ready for school or day care, prepare breakfast and lunches, get herself ready, supervise and monitor the babysitter if the family has one, drop off children at school or day care, get herself to work, put in a full day at work, pick up her children from school or day care, head back home with perhaps a stop at the grocery store to buy items for dinner, prepare dinner, feed the children, get them to finish their homework, finish work that she might have brought home and get to bed.
The grind begins again the next morning.
Add to this visits to the doctor, taking care of sick children and family members, visits to school for parent teacher conferences, taking care of the children’s other needs such as extra-curricular activities, play, visits to their friends’ houses, etc. and you can see how nearly impossible it is to keep up with this schedule.
And all of this can crumble like a cookie if one spoke in the wheel gets wobbly – what if the day care center or school is closed unexpectedly?; what if the child is sick?; what if the babysitter does not turn up?; what if the school calls you and tells you to get to school straight away?; what if?
The carefully choreographed dance through the day’s activities goes haywire and conference calls are not attended, meetings are missed and deadlines fall by the wayside. To top it all, accusatory fingers are pointed in the direction of the mother who’s trying not to feel guilty about taking an hour to get her child to the doctor or feel like she’s cheating her employer out of an honest day’s work while she does the things she needs to do as a mother.
We have not even talked about the working mother’s time for herself. In the Indian context, according to Sivakami Muthusamy[x],
working mothers spend “considerably less time on childcare, leisure time and personal activity” than non-working women. Although the study uses the term “working women,” since it assessed working women’s time spent on childcare, it is safe to assume that the study meant working mothers.
We’ll come to working mothers and parenting in the section below, but Crittenden reiterates the idea that working mothers spend little time on their own personal activities,
The other incredibly shrinking thing in working mothers’ time is leisure. Women are protecting their children from a parental “time famine” by subjecting themselves to a “time crunch.”
In the “juggling act” that is a working mother’s life, it is personal time and leisure activities that fall by the wayside.
D. Where Do the Children Fit In?
The notion that working mothers spend less time on their children than stay at home mothers seems almost a given. If a mother works at a job requiring her to stay in the office for twelve or fourteen hours a day with more work once she gets home and on weekends, how does she have time to take care of a child? The child has been in day care for that amount of time plus the time it takes the woman to drive to and from work.
The only time the child spends any time with the mother is when the mother is bathing, feeding and putting the child to bed. If the child is not already asleep by the time the mother gets home and if the mother is not exhausted, then perhaps a few minutes here and there of playtime.
There seems to be enormous amount of anecdotal evidence and personal history accounts[xi] of working mothers just not having enough time to spend on anything more than their children’s basic needs, enough fodder to feed the “Mommy Wars”, the supposed raging battle between working mothers and stay at home mothers over the merits of one group’s lifestyles and the demerits of the other group’s.[xii]
What seems so obvious at first glance, however, is not so simple.
While Muthusamy reports that working mothers in urban areas spent 2.6 hours less on childcare and working mothers in rural areas spent 3.1 hours less than non-working mothers, Crittenden reports that that does not mean there is a parenting crisis in families: “Sociologists, economists, demographers and historians have all reported a profound shift from quantity to quality in child-rearing, not just in the United States but almost everywhere in the globe.” This is particularly true in cases where women have studied and held paid jobs for longer before having children.
So the idea that somehow children are shortchanged by working mothers does not seem to hold water.
What does hold water, however, is the fact that in order for the children not to be shortchanged, women work harder to ensure that their children get quality attention during the time that the mothers do spend with them, and in the bargain, reserve less time for themselves, as mentioned earlier.
E. Where is the Family in All This?
No matter how much we like to think that “women’s liberation” has been a success, countenance the strides that women have made in the workforce or hear stories of men giving up their careers to become “stay at home dads” to be responsible for parenting, there is no hiding from the fact that social norms and familial expectations place the burden of taking care of children and the household squarely on women. Where men do share that burden and contribute to childcare and parenting, it is more than likely a one-off situation in which the husband and wife have sat together to arrive at a mutually workable arrangement. For the most part, as studies show, it is the women who struggle to balance their careers with the demands of their families, particularly childcare, not the men.
Hewlettand Luce, for example, point to the “pervasiveness of a highly traditional division of labor on the home front” and note that in a 2001 Center for Work-Life Policy survey, “fully 40% of highly qualified women with spouses felt that their husbands create more work around the house than they perform.”[xiii] Their Off-Ramp, On-Ramp study found that while 44% of women left their jobs to be able to give more time to their families, only 12% of the men assigned more family time as the reason for leaving their jobs.
Crittenden cites one study across “various classes, races, and work patterns, [that] found that the man rarely had primary responsibility for any single child-rearing duty. In no household did a father take responsibility for all child-rearing tasks.”[xiv]
Further diminishing the family’s role in childcare is the fact that most families now live in the nuclear set up. Almost none of the families in my peer group lives in a joint family. Often families are hundreds of miles away making emergency visits extremely difficult to arrange. Muthsamy’s study found that “the data do not indicate any major role of other care providers except for a minor role of teenage girls from the family.” Suffice to say that a working woman receives no support from family when it comes to childcare.
F. Where Does the Baby Go When the Mother Goes to Work?
A vital question that must be considered and an answer found before the mother heads back to work from whatever maternity leave she has is, Where does the baby go when the mother goes to work? For a mother returning to work only a few weeks after the baby is born, this question can be excruciatingly painful to consider. Who can she trust to take care of the baby she carried for nine months and just gave birth to?
But consider and think about it she must. A childcare arrangement that does not work is the undoing of many a working mother’s career.
A workable solution can be frustratingly difficult to find. If the babysitter comes home, the family must be comfortable with the babysitter and with the idea of leaving her alone with the baby during the entire day at home – obviously a trust issue. Many mothers prefer leaving their children in a group daycare setting where the babysitter takes care of a number of children in her own house. There is also the option of taking the child to a daycare center that is run in a school-type setting. The fourth option is to leave the child with family.
Except for the last option, working hours of the babysitter or the daycare centers is definitely a concern. Working mothers must make sure to get to wherever their child is before the center shuts down for the day or the babysitter’s working day is done. From personal experience, especially for women with professional careers, this is an impossible task to accomplish. It is simply not feasible to predict when the workday will end for the mother, let alone have it end everyday at the appointed hour on the dot.
While leaving the child with a family member seems to be the most desirable option – the baby is with family, overtime is not an issue with family, if the baby falls sick the mother will not have to take time off or rush to pick up the baby, family members might pitch in to take the baby to the doctor to keep appointments – it is not always a viable option. As mentioned earlier, most young parents don’t have their families living nearby. Moreover, there is the question of whether the family member (a grandparent is usually the choice) is willing or able to take on the burden of taking care of a young child.
Then there is the issue of expense. Not all families, even with two incomes, can afford to have their children in daycare centers or with babysitters on a full-time basis. Added to the full-time daycare expense there might be overtime charges.
The litany of issues facing a working mother is long and the problems can be pinpointed not to a single cause, but two at least two – office policies and lack of familial support.
Office policies regarding various aspects of a working mother’s life are crucial in determining whether a new mother heads back to work or not and whether working mothers stay on in the workforce. It could be something as simple as making it convenient for the mother to pump her breast milk while at work[xv] or something a little bit more complicated as providing flexibility in terms of working hours or taking time off to attend to familial needs.
As Hewlett and Luce note in their Off Ramp, On Ramp study,
Like it or not, large numbers of highly qualified, committed women need to take time out. The trick is to help them maintain connections that will allow them to come back from that time without being marginalized for the rest of their careers.
At least as important as office policies is family support in helping a working mother balance her work and household responsibilities.
A. The Role of the Firm: Work/Life Balance Initiatives
If you type work-life balance in the Google search bar, it comes back with 7,780,000 results in 0.22 seconds. Obviously, in the last few years, there’s been a lot of thinking on this topic and a lot has been written about it. Huge multi-national companies from IBM to Deloitte & Touche to Ernst & Young – basically every recognizable name in international business and then some – have all jumped on the work-life bandwagon.
Firm policies are written up and employees made to sign documents that bandy about terms such as “job sharing”, “flex-time”, “part-time”,
“up ramp, down ramp”.
All this has come about not because there was some epiphany regarding the struggles working mothers were facing day in and day out on their jobs, but because – as with all issues that drive corporate action – working mothers’ struggles were affecting the bottom line. Money had been spent on hiring women, training them, getting them on projects, putting them in front of clients and when they left, companies incurred huge costs in replacing the departed employee. It just made more sense to keep working mothers on the job, somehow.
Attention then turned to what was prompting the women to leave and what would persuade them to stay on.
Working mothers cited reduced number of work hours and flexibility in how they accomplished their work as the two most important factors that would enable them to balance their work lives and home lives.
Although it is understood that reduced-hour and job sharing arrangements come with reduced pay, requests for fixed or lower working hours or flexible schedules or job sharing arrangements are typically met with disdain. Such requests are viewed as evidence that working mothers are not committed to their careers, when in fact, what they are asking for are resources to enable them to be more committed to their careers.
Professional services firms are realizing, on paper at least, that although these new workplace paradigms mark a shift in the way businesses are run, they do make business sense, that requiring “face time” and unsustainable billable hours only lead to higher rates of attrition and do not necessarily provide gains in productivity. On the contrary, by retaining employees who have been trained in a firm’s practices and who are familiar with deals and projects they have been working on, it only serves to sustain or increase productivity – no matter that the project may now be shared between two employees as part of a job-sharing arrangement (one of whom picks up during the latter half of the day or week when the other left off to get back to her family); no matter that working mothers come in late or leave early or work from home or take a couple of hours off in the middle of the day to attend to their other responsibilities.
What would also serve working mothers well is to have role models – women in their firm who have continued and succeeded in their chosen careers after having children. With alarmingly low rates of women in the higher echelons of power, many having sacrificed family lives to reach there, new female entrants have no choice but to assume that family lives and work lives just don’t mesh.
The Off-Ramp, On-Ramp study recounts the efforts of one multi-national firm to address these issues, that of Ernst & Young. The company focused on five areas to work on – life balance, flexible work arrangements, mentoring, and internal and external networking for women. According to the study, Ernst & Young is now reaping the rewards of its investment – there are more women partners, even women who work on flexible schedules and women are not leaving in droves anymore.
Deloitte & Touche is another firm making strides in this area. In addition to the above, it “also maintains generous sabbatical policies and outreach practices so that women who depart the firm to raise children have an easier time re-entering the work force – and rejoining Deloitte – when they are ready to do so.”[xvi]
It remains to be seen if the example set by these firms is followed in letter and in spirit by the rest. It is only when the majority of the employers embrace worker friendly policies will the employees utilize them without fear of retaliation.
B. The Role of the Family: Time to Discard Entrenched Familial Roles
While the workplace setup in most firms is still very far away from the ideal when it comes to countenancing the needs of working mothers, there is, in some organizations at least, some movement in the right direction. In the household, on the other hand, there has been hardly any movement in the direction of reducing a woman’s workload at home even when the woman holds a full-time job.
Crittenden provides anecdotal evidence and remarks that while men may share at least some of the responsibilities in the home before the birth of children, once the children arrive, the job sharing stops cold. She quotes economist George Akerlof: “Although there is a lot of variation, between most spouses there is not complete reciprocity.”
While this situation (that of the working mother shouldering a majority of the responsibility for running the household and childcare) may continue for a while, it is more than likely that eventually working mothers will cut back on their work responsibilities or suffer burn out from pushing themselves too hard on both fronts due to lack of support. As Edith R. Matthai, President of the Los Angeles County Bar Association says, “One thing we need is a sense of shared responsibilities for the household and, most importantly, shared responsibilities for taking care of the kids.”[xvii]
While the solution is obvious – mothers and fathers need to work together on household chores and on childcare and parenting in such a manner that the working mother is not overburdened – there is no magic bullet approach to implementing it. Needless to say, the needs of each family are different as are the dynamics at play in familial relationships.
There are a finite number of choices available to families when it comes to managing careers and household duties including raising children – one parent stays home and is responsible for the well-being of the children while the other parent works, or both parents work and share the responsibility for raising children. As we have seen above, however, working mothers end up solely being responsible for the children.
Organizations were compelled to address the work-life balance issue because working mothers leaving the workforce was seen to affect their bottom line. Wht will motivate fathers to recognize the monumental struggle faced by working mothers and share household responsibilities? What is the bottom line for families with working mothers? Is it the emotional and physical well-being of the working mother? Is it the financial well-being of the family (most families need two incomes to lead reasonably comfortable lives these days)?
If working mothers are to continue and succeed in their careers and be able to take care of childcare responsibilities, it is obvious they need help. At the risk of sounding preachy, it is time to throw entrenched social norms regarding familial roles out the window. There should be no expectation from the family that working mothers can be Superwoman[xviii]; neither should working mothers aspire to that status. Open communication between spouses as to what needs to be accomplished and how to go about getting the tasks done will certainly help.
The fact is that more and more graduating classes in colleges, even professional ones (more than fifty percent in the U.S.), are made up of women. These women are heading straight to the workforce. The fact also is that most of these women will have children. Workplaces are no longer the domain of men who traditionally had stay at home wives to take care of their children. These wives and mothers are now working alongside them in the workforce. Are the two facts – that more and more women are employed and most of them will have children – irreconcilable? If it is thought to be so, then the losers are not only working mothers, but to a larger extent, families and organizations.
Many firms are shedding traditional approaches to dealing with the time crunch faced by working mothers (which was to simply push them out the door under some pretext or the other) and are taking their first, tentative steps towards retaining working mothers by providing resources to better manage their time. Similar steps are long overdue in the familial context.
It is up to working mothers to take full advantage of their firm’s work-life balance initiatives and to legitimize their use. Not only will they be serving their own interests, but they will also serve as role models for future classes of working mothers. On the home front, while the burden of recognizing working mothers’ time crunch and addressing it must fall on both spouses, it, unfortunately, does not. The practical approach to this problem would be for working mothers to initiate discussions that will lead to their recognition and redressal.
What is not practical is to aspire to Superwoman status. It is viable for the short term but a sure recipe for burn out in the long run.
[i] Crittenden, Ann. The Price of Motherhood, Why the Most
Important Job in the World Is Still the Least Valued. New York: Henry Holt, 2001, p. 22
[ii] Leonard, Tom. Advertising Chief Loses Job Over French Maid
and Sexist Insults, THE TELEGRAPH, Oct. 22, 2005. Available from http://www.telegraph.co.uk/news/main.jhtml?xml=/news/2005/10/22/ncrap22.xml&sSheet=/news/2005/10/22/ixnewstop.html
[iii] Wonk, Nancy. Female
Like Me. Available from http://ihaveanidea.org/articles/archives/268-Female-Like-Me.html
[iv] O’Brien, Timothy L. Why Do So Few Women Reach the Top of Big Law
Firms? THE NEW YORK TIMES, Mar. 19, 2006. Available from http://www.nytimes.com/2006/03/19/business/yourmoney/19law.html?ex=1300424400&en=f9b2756ce77b02bc&ei=5088&partner=rssnyt&emc=rss
[v] See supra note 2
[vi] Porter, Nicole Buonocore. Re-Defining Superwoman: An Essay on
Overcoming the “Maternal Wall” in the Legal Workplace, 13 DUKE J.
OF GENDER L. & POL’Y 55. Available from http://www.law.duke.edu/journals/djglp/articles/gen13p55.htm
[vii] See supra note 3
[viii] Hewlett, Sylvia Ann and Luce,
Carolyn Buck. Off-Ramps and On-Ramps,
Keeping Talented Women on the Road to Success, HARVARD BUSINESS REVIEW,
Mar. 2005 (hereinafter Off-Ramp, On-Ramp Study)
[ix] McGinn, Daniel. Trading Places, NEWSWEEK, Updated Sept.
18, 2006. Available from http://www.msnbc.msn.com/id/14895681/site/newsweek/
[x] Muthusamy, Sivakami. Are Working Mothers in India Investing
Less Time in the Next Generation? Paper presented at the Population
Association of America 2006 Annual Meeting, Apr. 30, 2006. Available from http://paa2006.princeton.edu/download.aspx?submissionId=60451#search=%22indian%20working%20mothers%20statistics%22
[xi] Hingston, Sandy. Mommy Wars. Book Excerpt, NEWSWEEK,
Updated Feb. 26, 2006. Available from http://www.msnbc.msn.com/id/11566036/site/newsweek/
[xii] Thompson, Tracy. A
War Inside Your Head, THE WASHINGTON
POST, Feb. 15, 1998. Available from http://www.washingtonpost.com/wpsrv/national/longterm/mommywars/mommy3.htm
[xiv] See supra note 1, p. 25
[xv] Kantor, Jodi. On the Job, Nursing Mothers Find a 2-Class
System, THE NEW YORK TIMES, Sept, 1, 2006. Available from http://www.nytimes.com/2006/09/01/health/01nurse.html?pagewanted=1&ei=5090&en=ed01e1dd900324e2&ex=1314763200&partner=rssuserland&emc=rss
[xvi] See supra note 4
[xvii] See supra note 4
[xviii] See supra note 6