The Crowland chronicler agrees with Vergil’s later account, for he too reports that ‘when [the king] heard the news he was greatly displeased’.1 The Crowland writer implies that the immediate cause of the king’s displeasure was George’s reading of Burdet’s statement to the council. However, he hints at other causes, stating that Edward IV also ‘recalled information laid against his brother which he had long kept in his breast’.2 This information was probably a message from Louis XI:
Through the mouth of an envoy the King of France sent word that, according to reliable information, one of the reasons Edward’s treacherous brother George of Clarence, aided by his sister Margaret, had hoped to secure the hand of Marie of Burgundy was in order to make himself King of England … According to the interpolator of Jean de Roye’s Parisian chronicle, usually reliable and here quite circumstancial, Edward IV, on receiving Louis’ report, immediately dispatched an envoy to France to ask what, in the king’s opinion, he should do about Clarence. Louis asked one question: ‘Do you know for certain that my brother the King of England has the Duke of Clarence in his power?’ ‘Sire, yes’, was the reply. The king then quoted a line of Lucan: Tolle moras, sepe nocuit differe paratas. (Avoid delay – postponement of a planned course of action often causes harm.) The ambassador asked for an explanation, ‘but he was unable to get anything more out of the king’.3
As a result, ‘the duke was summoned to appear, on a fixed day, at the royal palace of Westminster in the presence of the mayor and aldermen of the city of London’.4 These officials may have been involved because Burdet’s verses had been published in Holborn as well as Westminster. Hicks suggests that the hearing was scheduled for 10 June or very soon after.5 Once the group was assembled, and George stood before them:
the king, from his own lips, began to treat the duke’s action already touched upon [i.e. causing Burdet’s statement to be read to the council], amongst other things [not specified], as a most serious matter, as if it were in contempt of the law of the land and a great threat to the judges and jurors of the kingdom. What more is there to say? The duke was placed in custody and was not found at liberty from that day until his death.6
Of course, a great deal more could have been said but unfortunately this is all we have. In (probably) mid-June 1477 George was placed under arrest in the Tower of London, where he remained for about six months. Meanwhile, Edward IV and Elizabeth Woodville were preoccupied with the plans for the splendid wedding of their 4-year-old second son, Richard, to Eleanor Talbot’s niece, Anne Mowbray, heiress of the late Duke of Norfolk. The marriage was to take place at the Palace of Westminster in January 1477/8. At about the same time, however, a Parliament was to assemble, to try the Duke of Clarence.
In fact, Parliament was opened on 16 January, two days after the royal wedding, and Edward IV himself presented the case against his brother. The text of the Act of Attainder which was finally passed against George is quoted in full below, each section of the medieval English text preceded by a brief modern English summary. Essentially, the case put by Edward IV begins by recalling how he had confronted various earlier attempts to overthrow him. It then goes on to say that there was now a new and particularly dangerous and malicious plot against not only the king, but also the queen and all their children. This plot was led by the Duke of Clarence. Despite all the kindness Edward IV had shown George, the latter was now protesting that his servant Thomas Burdet had wrongly been put to death. The Duke’s underlying aim was to make himself king. Clarence was protesting that the king had deprived him of his livelihood. He had also preserved a document from the time of the Readeption that declared that if Henry VI and Edward of Westminster died without heirs [as, of course, they both subsequently had died], Clarence should become king. Moreover, Clarence had been plotting with the Abbot of Tewkesbury and others to send his son and heir, the Earl of Warwick, out of the kingdom, to Ireland or Flanders.7 Because of all his plotting the king was now forced, despite their close relationship, to seek the conviction of the duke for treason:
Act of Attainder against George, Duke of Clarence.8
General introduction – how with God’s help the king has survived various plots and rebellions against him in the past.
The Kyng, oure Sovereigne Lorde, hath called to his Remembraunce the manyfold grete Conspiracies, malicious and heynous Ttresons, that hertofore hath be compassed by dyverse persones his unnaturall Subgetts, Rebelles and Traytoures, wherby Commocions and Insurrections have been made within this his Royaulme, for entent and purpose to have destroyed his moost Roiall persone, and with that to have subverted the state, wele publique and politic of all his said Royaulme; ne had so been, that by th’elp of Almyghty God, with the grete laboures and diligences and uttermost explette of his persone by Chevalrye and Werr, he had mightly and graciously repressed the same. Wherthrogh grete nowmbre of the said his Rebelles and Traytours he hath at dyverse tymes punysshed, as well by swerd as other punysshments, in exemple to others to have been ware of suche attempting hereafter. And yet as a benigne and a gracious Prince moeved unto pitie, after his grete Victories sent hym by God, not oonly he hath spared the multitudes in theire feldes and assembles overcomen, but thaym and certeyn other, the grete movers, sturters and executours of suche haynous Tresons, at the reverence of God, he hath taken to his mercy and clerly pardoned, as may not be unknowen to all the Worlde.
However, he has recently become aware of a particularly unnatural and wicked plot, directed against himself, his queen, his son the Prince of Wales, and all his other children by the queen. This plot has been orchestrated by the one person who more than any other owed the king loyalty and gratitude.
This notwithstondyng, it is comen nowe of late to his knowlage, howe that agaynst his mooste Royall persone, and agaynst the persones of the blessed Princesse oure alther soveraigne and Liege Lady the Quene, of my Lorde the Prince theire son and Heire, and of all the other of thaire moost noble issue, and also against the grete parte of the Noble of this Lande, the good rule, politike and wele publique of the same, hath been conspired, compassed and purposed a moch higher, moch more malicious, more unnaturall and lothely Treason than atte eny tyme hertoforn hath been compassed, purposed and conspired, from the Kyng’s first Reigne hiderto; which Treason is, and must be called, so moche and more henyous, unnaturell and lothely, for that not oonly it hath proceded of the moost extreme purpensed malice, incomparably excedyng eny other that hath been aforn, but also for that it hath been contryved, imagined and conspired, by the persone that of all erthely creatures, beside the dutie of ligeaunce, by nature, by benefette, by gratitude, and by yeftes and grauntes of Goodes and Possessions, hath been moost bounden and behalden to have dradde, loved, honoured, and evere thanked the kyng more largely, than evere was eny other bounden or beholden, whom to name it gretely aggruggeth the hert of oure said Sovereigne Lorde, sauf oonly that he is of necessite compelled, for the suertie, wele and tranquillite of hym and all this Royaulme, which were full neer the poynt of perdicion, ne were the help and grace of Almyghty God:
This plotter was his brother, George, Duke of Clarence, whom the king has always loved and cared for and endowed very generously.
He sheweth you therefore, that all this hath been entended by his Brother, George, the Duke of Clarence. Wherein it is to be remembered that the Kynges Highnesse, of tendre youthe unto now of late, hath evere loved and cherysshed hym, as tenderly and as kynderly, as eny creature myght his naturell Brother, as well it may be declared, by that that he beyng right yonge, not borne to have eny lifelode, butt oonly of the Kynges grace he yave hym soo large porcion of Possessions that noo memorie is of, or seldom hath been seen, that eny Kyng of Englande hertoforn within his Royaulme yave soo largely to eny his Brothers. And not oonly that, butt above that, he furnyssed hym plenteously of all manere stuff, that to a right grete Prynce myght well suffice; so that aftre the Kynges, his lifelode and richesse notably exceded any other within his Lande at thatt tyme.
The king had raised Clarence to a higher position than anyone else, trusting that their relationship, and Clarence’s gratitude and loyalty to the kingdom would make him the king’s most faithful servant.
And yet the kyng, not herewith content, butt beyng ryght desirous to make hym of myght and puissance excedyng others, caused the greate parte of all the Nobles of this Lande to be assured unto hym next his Highnesse; trustyng that not oonly by the bond of nature, butt also by the bondes of soo grete benefitt, he shulde be more than others loving, helping, assisting and obeissaunt to all the Kyngs good pleasures and commaundments, and to all that myght be to the politik wele of his Lande.
Nevertheless, Clarence had rebelled against the king in the past, depriving him of liberty, forcing him abroad, and aiding usurpers – but had been forgiven.
All this notwithstondyng, it is to remember, the large grace and foryevnesse that he yave hym uppon, and for that at dyverse tyme sith he gretely offended the Kyng, as in jupartyng the Kyngs Royall estate, persone and life, in straite warde, puttyng hym thereby from all his libertie, aftre procuryng grete Commocions, and sith the voydaunce oute of his Royaulme, assistyng yevyng to his enemies mortall, the usurpers, laboryng also by Parlement to exclude hym and all his from the Regalie, and enabling hymself to the same, and by dyverse weyes otherwyse attemptyng; which all the Kyng, by nature and love moeved, utterly foryave, entendyng to have putte all in perpetuell oblivion.
Despite this, Clarence had hatched new plots to destroy and disinherit the king and his children. He had campaigned to induce the king’s subjects to withdraw their loyalty, sowing sedition and arguing that his servant Thomas Burdet had been wrongfully condemned and executed.
The said Duke, nathelesse for all this, noo love encreasyng, but growyng daily in more and more malice, hath not left to consedre and conspire newe Treasons, more haynous and lothely than ever aforn, how that the said Duke falsly and traitrously entended, and puposed fermely, th’extreme distruction and disherityng of the Kyng and his Issue, and to subverte all the polityk rule of this Royaulme, by myght to be goten as well outewarde as inward, which false purpose the rather to brynge aboute, he cast and compassed the moyans to enduce the Kynges naturell Subgetts to withdrawe theire herts, loves and affections from the Kyng, theire naturell Sovereigne Lorde, by many subtill, contryved weyes, as in causyng dyverse his Servauntes, suche as he coude imagyne moste apte to sowe sedicion and aggrugge amonge the People, to goo into diverse parties of this Royaulme, and to laboure to enforme the People largely in every place where they shulde come, that Thomas Burdett, his Servaunte, which was lawefully and truly atteynted of Treason, was wrongefully putte to Deth; to some his Servauntes of suche like disposicion, he yave large Money, Veneson, therewith to assemble the Kynges Subgects to Feste theym and chere theym, and by theire policies and resonyng, enduce hem to beleve that the said Burdett was wrongfully executed, and so to putte it in noyse and herts of the People;
Clarence alleged that the king had used the black arts to corrupt his subjects.
he saide and laboured also to be noysed by such his Servauntez apte for that werk, that the Kyng, oure Sovereigne Lorde, wroght by Nygromancye, and used Crafte to poyson his Subgettes, suche as hym pleased; to th’entent to desclaundre the Kyng in the moost haynous wyse he couth in the sight and conceipt of his Subgetts, and thefore to encorage theym to hate, despice and aggrugge theire herts agaynst hym, thynkyng that he ne lived ne dealid with his Subgettes as a Christien Prynce.
Clarence had now specifically claimed the throne for himself and his heirs on the grounds that Edward IV was illegitimate. He induced some of the king’s subjects to swear on the Blessed Sacrament to support his claim to the throne. He promised people to restore to them the lawful inheritance of which Edward IV had allegedly deprived them.
And overe this, the said duke beyng in full purpose to exalte hymself and his Heires to the Regallye and Corone of Englande, and clerely in opinion to putte aside from the same for ever the said Corone from the Kyng and his Heirez, uppon oon the falsest and moost unnaturall coloured pretense that man myght imagine, falsely and untruely noysed, published and saide, that the Kyng oure Sovereigne Lorde was a Bastard, and not begottone to reigne uppon us; and to contynue and procede ferther in this his moost malicious and traytorous purpose, after this lothely, false and sedicious langage shewed and declared amonge the People, he enduced dyverse of the Kynges naturall Subgetts to be sworne uppon the blessed Sacrament to be true to hym and his heires, noon exception reserved of theire liegeaunce; and after the same Othe soo made, he shewed to many other, and to certayn persones, that suche Othe had made, that the Kyng had taken his lifelode from hym and his men, and disheryed theym, and he wolde utterly endevoire hym to gete hem theire enheritaunce as he wolde doo for his owen.
Clarence argued that the king intended to dispossess and break him. Wherefore he made an agreement with Henry VI and Margaret of Anjou which recognised Clarence as next-in-line to the throne after Edward of Westminster. Clarence had secretly preserved this document.
He shewed also that the Kyng entended to consume hym in like wyse as a Candell consumeth in brennyng, wherof he wolde in brief tyme quyte hym. And overe this, the said Duke continuyng ín his false purpose, opteyned and gate an exemplificacion undre the Grete Seall of Herry the Sexte, late in dede and not in right Kyng of this Lande, wherin were conteyned alle suche appoyntements as late was made betwene the said Duke and Margaret, callyng herself Quene of this Lande, and other; amonges whiche it was conteyned, that if the said Herry, and Edward, his first begoton Son, died withoute Issue Male of theire Bodye, that the seid Duke and his Heires shulde be Kyng of this Lande; which exemplificacion the said Duke hath kepyd with hymself secrete, not doyng the Kyng to have eny knowlegge therof, therby to have abused the Kynges true Subgetts for the rather execucion of his said false purpose.
Clarence had requested the Abbot of Tewkesbury,9 John Tapton and Roger Harewell to bring a child to Warwick Castle, to impersonate his son the Earl of Warwick, while sending the real Earl of Warwick to Ireland or the Low Countries, to provide a focus for rebellion against Edward IV.10 Clarence’s servant John Taylour was sent to take the earl abroad, but Tapton and Harewell refused to hand the boy over.
And also, the same Duke purposyng to accomplisse his said false and untrue entent, and to inquiete and trouble the Kynge, oure said Sovereigne Lorde, his Leige People and this his Royaulme, nowe of late willed and desired the Abbot of Tweybury, Mayster John Tapton, Clerk, and Roger Harewell Esquier, to cause a straunge childe to have be brought into his Castell of Warwyk, and there to have beputte and kept in likelinesse of his Sonne and Heire, and that they shulde have conveyed and sent his said Sonne and Heire into Ireland, or into Flaundres, oute of this Lande, whereby he myght have goten hym assistaunce and favoure agaynst oure said Sovereigne Lorde; and for the execucion of the same, sent oon John Taylour, his Servaunte, to have had delyveraunce of his said Sonne and Heire, for to have conveyed hym; the whiche Mayster John Tapton and Roger Harewell denyed the delyveraunce of the said Childe, and soo by Goddes grace his said false and untrue entent was lette and undoon.
Clarence sent his servants to various parts of the kingdom to incite rebellion and to muster armed forces to support his uprising, the aim of which was to utterly destroy Edward IV and his children, and to enthrone Clarence and his heirs.
Over all this, the said Duke, compassyng subtelly and trayterously to brynge this his trayterous purpose to the more redy execucion by all meanes possible, and for to putte these said Treasons fynally to pleyn execucion, falsely and trayterously he commaunded and caused dyverse of his Servauntes to goo unto sundry parties of this Royaulme to commove and stirre the Kynges naturall Subgetts, and in grete nowmbre to be redy in harnays within an Houre warnyng, to attend uppon hym, and to take his parte to levy Werre agaynst the Kynges moost Royall persone, and hym and his heirez utterly to destroye, and therby the Corone and Royall Dignite of this Royaulme to obteigne, have, possede and enjoye to hym and to his heirez for evere, contrarie to all nature, ryght and duetie of his Ligeaunce.
Because of their blood relationship and the love he had felt for him in his youth, Edward IV would be inclined to forgive Clarence, if the latter had not now proved himself incorrigible, had not risked bloodshed on a large scale, and if Edward were not sworn to preserve himself, his children, the Church and the welfare of all in the kingdom.
The Kyng, remembryng over, that to side the neernesse of Blode, howe be nature he myght be kynde to his Brother; the tendre love also, whiche of youthe he bare unto hym, couthe have founden in his hert, uppon due submission, to have yet foryeven hym estsones, ne were, furst that his said Brother by his former dedes, and nowe by this conspiracye, sheweth hymself to be incorrigible, and in noo wyse reducible to that by bonde of nature, and of the grete benefices aforn reherced, he were moost soveraynly beholden of all Creature: Secondly, ne were the grete juparty of effusion of Christien blode, which most likkely shulde therof ensue: And thridenly and principally, the bond of his Conscience, wherby and by solempne Othe, he is bounden anenst God, uppon the peryll of everlastyng dampnacion, to provyde and defende, first the suertie of hymself and his moste Royall Issue, secondly, the tranquilite of Goddes Churche within this, his Royaulme, and after that, the wele publique, peas and tranquilite of all his Lordez, Noblemen, Comens and others of every degree and condicion, whiche all shulde necessarily stande in extreme jupartie, yf Justice and due punyshement of soo lothely offencez shulde be pardoned; in pernicious example to all mysdoers, theves, traytours, rebelles and all other suche as lightly wolde therby bee encoraged and enbolded to spare noo manner of wikkednesse.
Therefore, for the sake of justice, the king in Parliament had convicted and attainted Clarence of high treason, and all Clarence’s property was forfeit.
Wherfore thof all [sic]11 the Kynges Highnesse be right sory to determyne hymself to the contrarie, yet consideryng that Justice is a vertue excellently pleasyng Almyghty God, wherby Reaulmes stande, Kynges and Pryncez reign and governe, all goode rule, polyce and publique wele is mayteigned; and that this vertue standeth not oonly in retribucion and rewarde for goode dedes, butt also in correccion and punysshement of evil doers, after the qualitees of theire mysdoyngs. For whiche premissez and causez the Kyng, by the avyse and assent of his Lordes Speretuell and Temporell, and by the Commons, in this present parliament assembled, and by the auctorite of the same, ordeyneth, enacteth and establith that the said George, Duke of Clarence, be convicte and atteyntit of Heigh Treason commyttet and doon agaynst the Kynges moost Royall persone; and that the same Duke, by the said auctorite, forfett from hym and his heyres for ever the Honoure, Estate, Dignite and name of Duke. And also that the same Duke, by the said auctorite, forfett from hym and his heyres for ever, all Castelles, Honoures, Maners, Landes, Tenements, Rents, Advousons, Hereditaments and Possessions that the same Duke nowe hath by eny of the Kynges Lettrez Patents to his owen use, or that any other persone nowe hath to the use of the same Duke by eny of the Kynges Letterez Patents, or that passed to hym fro the Kyng by the same: And that all Lettrez Patents made by the kyng to the said Duke bee from henseforthe utterly voyde and of noon effecte.
Property which the Duke held jointly with others is not forfeit, but Clarence’s share shall now pass to his co-holders.
And that it be also ordeigned by the same auctorite that noo Castelles, Honoures, Maners, Landez, Tenementz, Rents, Advousons, Hereditaments or Possessions that the same duke nowe hath joyntly with other, or sole to hymself, to the use of eny other persone, be forfett, nor conteyned by or in this present Acte; but that by the said auctoritee, every other persone to whose use the said Duke is sole seised in eny Castelles, Honoures, Maners, Landez, Tenements, Rents, Advousons, Hereditaments and Possessions, otherwyse than by the Kyngs Lettres Patents, have power and auctorite by this present Acte lawefully to entre into theym, and theym to have and holde after the entent and trust that the said Duke nowe hath theryn. And also where the same Duke is joyntly seased with any other persone in any Castells, Maners, Landez, Tenementz, Rents, Hereditaments or Possessions to the use of eny other persone, otherwyse than by the Kyngs Lettrez Patents: that by the said auctorite, the said joynt feffez stonde and be feoffez to the same use and entent as they nowe arre and be; and that suche right, interest and title as the same Duke nowe hath with theym in the same premyssez, by the said auctorite, be in his cofeffez to the same entent as the same Duke nowe ys: Savyng to every of the Kynges Liege people, other than the said Duke and his Heyrez, and all other persone and persones that clayme or have eny tytell of interest in eny of the premyssez by the same Duke, suche right, tytle and interest as they owe or shulde have in eny of the premyssez, as if this Acte had never been made.
A cest Bille les Comunez sont assentuz.
Le Roy le voet.
This Act of Attainder is a carefully worded but somewhat curious document. It establishes two important facts about George’s latest plot. First, this was directed not only against the king, but against Elizabeth Woodville, and against Edward’s children by her. Second, unlike his earlier plots (which had imprisoned Edward, depriving him of real power, or had forced him into exile, giving the throne to usurpers) the latest plot had the specific aim of destroying Edward and his family, and making George himself king.
The Act also states that in his latest plot George had sought to achieve his objective by having his servants spread seditious stories. Although Thomas Burdet is not specifically said to have taken part in this activity, Burdet is named, and the sedition is then said to have been spread by George’s servants ‘of similar disposition’. Mention of Thomas Burdet was apparently considered important by the crown. The phrasing employed is vague, but it implies that Burdet spread sedition – presumably via his verses. Not surprisingly, the content of the verses is not cited – but contemporary members of Parliament may have been familiar with them.
The lack of clarity in explaining who exactly spread George’s seditious stories (whatever they were), and how Thomas Burdet was connected with that activity, leads on to a further lack of clarity in respect of the means George had sought to employ to oust his brother. George is accused of possessing a document bearing the seal of Henry VI, which recognised him as heir to the throne if Henry and Edward of Westminster both died heirless. George probably did posses such a document. However, he is not accused in the Act of having used it in any way. Reference to it therefore seems rather like scraping the bottom of the barrel on the part of the crown, in order to produce evidence against George that could safely be cited in public. George is also said to have accused Edward of being a bastard. Surprising though it may seem that the king mentioned this publicly in Parliament, Edward (and Elizabeth Woodville) may have felt that this was the least dangerous accusation to publicise, because evidence could be produced to disprove it. George is not said to have accused the king of bigamy. But, of course, if he had raised this issue, both Edward and Elizabeth Woodville would have done everything in their power to suppress the fact.
The Act also invites questions on three other points:
Why is reference made to the many previous problems and disturbances of the king’s reign, and to earlier conspiracies against the king? Did Edward IV wish to present his reign as a series of disasters – or is this simply an example of the standard practice in such documents (see, for example Richard III’s titulus regius of 1484).
Why is George said to have accused the king of using the black arts against his subjects?
Strong circumstantial evidence (with named witnesses) is cited to show that George attempted to send his son out of the country – but did not succeed in this. Why was it considered important to mention this attempt – and to establish publicly that it had not succeeded?
Finally, while the Act is very specific about what is to be done with George’s possessions, it says nothing about the proposed fate of the Duke himself. Indeed, there is no mention of George being sentenced to death – but presumably he was, since Edward IV was later asked by the Speaker of the Commons to take action in this respect. Parliament may therefore have sentenced George to the usual, rather brutal form of execution for a traitor – hanging, drawing and quartering – followed by a clause allowing the king to commute this sentence if he so desired. Evidence to this effect is cited in the next chapter.
It is often stated that the Act of Attainder was passed on Friday 16 January 1477/8. That was the date on which Parliament was opened, but the surviving text of the Act itself contains no date. Once the Act had been passed (and depending on the precise date of that event) it is possible that no further action was taken immediately – except perhaps by Cecily Neville (see below). However, on Saturday 7 February Edward IV appointed his cousin, Henry Stafford, Duke of Buckingham, to the post of Steward of England with specific reference to the recent judgement against the Duke of Clarence. The king explained that:
despite the close blood ties and the inner feelings of love, which We had and practiced to the aforesaid George in his tender age, and which naturally move Us in a contrary direction, as We understand it, the Office of the Steward of England (whose presence is required here for the execution of a Judgement which has yet to be carried out) is currently vacant.12
He then instructed Buckingham, as the new steward, to execute the recent judgement against his brother. Buckingham had hitherto been out of favour. However, he was married to Catherine Woodville, a younger sister of the queen, who had recently borne him a son and heir, to whom the king had stood as godfather. Buckingham obviously acted efficiently in the role assigned to him, for on 11 February he was rewarded with the grant of a manor in Wales.13
1. Crowland, p.145.
3. P. M. Kendall, Louis XI (London, 1971, 1974), p.396; pp.407–8, n.7.
4. Crowland, p.145.
5. FFPC, p.126.
6. Crowland p.145, my emphasis.
7. George may have visited Ireland in February/March 1476/7, just after the death of his wife and younger son – see above, chapter 11.
8. RP, vol. 6, pp.193–5, ‘from the original in the Tower of London’. Abbreviations expanded without comment.
9. John Strensham, or Streynsham. He was abbot until 1481, but it is not known precisely in which year he succeeded John de Abingdon (abbot 1442–?). ‘Abbot Strensham was godfather to Clarence’s son, Edward’. M. Hicks, in R. K. Morris and R. Shoesmith (eds), Tewkesbury Abbey: History, Art and Architecture (Hereford: Logaston Press, 2003; repr. with corrections, 2012), chapter 2, p.29.
10. In the light of later events, in the reign of Henry VII, this allegation is particularly intriguing. For more on this, see my forthcoming sequel: J. Ashdown-Hill, The Dublin King (Stroud, 2014).
11. Perhaps: ‘Wherfore therof, although the kynge’s Highnesse …’?
12. RP, vol. 6, p.195, citing Rot. Pat. 17 E.IV, p.2, m.19. The original text is in Latin.
13. FFPC, p.135.