Did You Know?

Some questions as we start…

1. Did you know that Bob Kellemen “is an outsider to biblical counseling”?

2. Did you know that Jason Kovacs, Brad Hambrick, Nate Brooks, Kristin Kellen, Sam Williams, and Tate Cockrell (the biblical counseling faculty at Southeastern Baptist Theological Seminary), and all Clinically-Informed Biblical Counselors (CIBC) are not truly biblical counselors?

3. Did you know that, “If one becomes a member of the ACBC organization, it thus prohibits them from being a CIBCer.”

4. Did you know that true biblical counselors must align with and be certified by ACBC? Did you know that, “true biblical counselors who want to communicate clearly their position should focus on their certification and their organization’s certification with ACBC”?

5. Do you know who publicly made these statements and where?

Greg Gifford and ACBC 

Greg Gifford made these statements (Greg is pictured in the featured image for this post).

He made them in ACBC’s Journal of Biblical Soul Care in his article, “I’m a Biblically-Informed Psychologist”: Is Clinically-Informed Biblical Counseling Really Just Integrationism? 

Some of you might be asking, “Who is Greg Gifford?”

Greg is the General Editor for ACBC’s Journal of Biblical Soul Care. He is also Associate Professor at The Master’s University.

Is Bob Kellemen “An Outsider to Biblical Counseling”?

 It is Gifford who said in his ACBC article that Bob Kellemen is “an outsider to biblical counseling.” He slipped that comment about me into his larger argument that clinically-informed biblical counseling is not truly biblical counseling at all. Gifford places Bob Kellemen (who is not CIBC) and all Clinically-Informed Biblical Counselors outside the camp of biblical counseling.

It is my hope that CIBC leaders will publicly respond to Gifford’s accusations about them—accusations I disagree with. [Note: On January 1, 2026, Jason Kovacs responded. You can read his response here: Jason Kovacs Responds to Greg Gifford and ACBC.] In today’s post, I’ll publicly respond to both of Gifford’s accusations/mischaracterizations: about me and about CIBC.

Greg and Bob 

One biblical counseling leader, after reading Gifford’s statement, reached out to me and said,

“Wait! Does he actually not know you?? Like how is that the way you’re framed?”

Let me answer that question: Yes, Greg Gifford knows me. We have spoken one-to-one in person. We have emailed back and forth several times. We have been in group meetings together. I have been in ACBC sessions where Greg has spoken. Greg has been in ACBC conferences where I have spoken. Greg knows me. But, apparently, he does not know me in the positive way that Elf knows Santa,

“Santa! I know him! I know him!!!” 

It’s more like,

Kellemen. I know him. He is not a biblical counselor. He’s an outsider.” 

At this stage of my life, my view of what Greg or others think of me mirrors Paul’s perspective toward the end of his life. “I care very little if I am judged by you or by any human court; indeed, I do not even judge myself. My conscience is clear, but that does not make me innocent. It is the Lord who judges me” (1 Corinthians 4:3-4). God is my Judge. (Interestingly, Paul then does expend a great deal of ink in 1 Corinthians defending his ministry as from God and for God’s glory.)

So, why is it important to publicly assess Gifford’s characterization of me?

When an author mischaracterizes one biblical counselor in a way which is demonstrably false, it calls into question his objectivity and capability as a researcher and presenter of facts about other biblical counselors—such as Clinically-Informed Biblical Counselors.

A Dozen Historical Facts About Whether Bob Kellemen Is a Biblical Counseling “Insider” or “Outsider” 

Let’s explore whether I am “an outsider to biblical counseling.”

1. Before Greg was born, I was being trained in first generation nouthetic counseling by Jay Adams’s right-hand man, Pastor Bill Goode—who started Faith Church’s Biblical Counseling Ministry. Pastor Goode was later the Executive Director of NANC (ACBC before they changed their name). Does that sound like “an outsider to biblical counseling”?

2. David Powlison and Randy Patten (who was then the NANC/ACBC Executive Director), personally recruited me to be the founding Executive Director of the Biblical Counseling Coalition. I explicitly remember saying to David, Randy, and the other biblical counseling leaders, “I’m not ACBC certified. Are you sure I’m the right person to help launch the Biblical Counseling Coalition?” David spoke for everyone. “Bob, you’re the exact right person for this role. If people can’t see you as a biblical counselor, then they would not be a fit for the Biblical Counseling Coalition.” Does that sound like “an outsider to biblical counseling”?

3. I’ve authored or co-authored twenty-six biblical counseling books. At least 72 times these books have been endorsed by NANC/ACBC Academy Members, NANC/ACBC Fellows, NANC/ACBC Board of Directors, and NANC/ACBC Certified Biblical Counselors. Does that sound like “an outsider to biblical counseling”?

4. I spoke for many years at the annual NANC/ACBC National Conference when NANC was led by Randy Patten and ACBC was led by Heath Lambert. Does that sound like “an outsider to biblical counseling”?

5. I spoke multiple times alongside Greg’s colleagues at The Master’s University, Dr. John Street and Dr. Stuart Scott (who is now at Bob Jones), in 2017 at The Master’s University International Conference in Wittenberg, Germany on the 500^th anniversary of Luther’s 95 Theses. Does that sound like “an outsider to biblical counseling”?

6. I was the keynote plenary speaker at the IBCD Conference when IBCD was led by ACBC Fellow, Dr. Jim Newhesier. Does that sound like “an outsider to biblical counseling”?

7. I’ve spoken at CCEF national conferences when CCEF was led by Dr. David Powlison. Does that sound like “an outsider to biblical counseling”?

8. I taught in more than 100 sessions over the course of over a decade at the Faith Biblical Counseling Ministry’s annual conference—a ministry that is an ACBC-approved training center. Does that sound like “an outsider to biblical counseling”?

9. I was an adjunct professor of biblical counseling at Reformed Theological Seminary in Charlotte, North Carolina, under the leadership of Dr. Jim Newhesier. Does that sound like “an outsider to biblical counseling”?

10. Before my “retirement from making money” (I retired early to care for my wife, Shirley, after her stroke), I worked full-time as VP, Academic Dean, and Professor of Biblical Counseling at Faith Seminary in Lafayette, Indiana—an ACBC-approved training ministry. Before that, I worked full-time as VP, Chair of Biblical Counseling, and Professor of Biblical Counseling at Crossroads Bible College in Indianapolis, Indiana—an ACBC-approved training ministry. Does that sound like “an outsider to biblical counseling”?

11. Many ACBC Fellows who are Professors of Biblical Counseling continue to require my books in their biblical counseling courses. Does that sound like “an outsider to biblical counseling”?

12. Most importantly, anyone, including Greg, can read any of my over 2,500 blog posts, any of my nearly 200 published articles, and any of my 26 books. They will see that in each post, article, and book I build my model of biblical counseling on the Bible, and that I also use the history of biblical soul care and biblical counseling as an adjunctive resource for building my approach to biblical counseling Does that sound like “an outsider to biblical counseling”?

I could go on and on. But does any of that sound like “an outsider to biblical counseling”?

Have You Reached Out to Greg? 

You may be wondering,

“Bob, You frequently encourage people to have one-to-one conversations about issues in the biblical counseling world. So, have you personally, privately reached out to Greg, before sharing this public post?” 

Yes.

The day that someone informed me of this quote about me, I emailed Greg, sharing my surprise at his a-historical mischaracterization of me. I documented the facts regarding my 40+ years as an insider to biblical counseling. I then share with Greg:

“I would appreciate it if you would speak more accurately about my historical and current involvement as an insider to biblical counseling, especially in published journal articles.” 

Greg responded,

“Hey Bob, Email has been received. Thank you.”

Since Greg publicly mischaracterized me as a biblical counseling outsider, after addressing my concerns directly to Greg, it is appropriate for me to publicly respond to his public mischaracterization.

“There You Go Again!”

On October 28, 1980, during a Presidential Debate with incumbent President Jimmy Carter, Carter accused Ronald Reagan of planning to cut Medicare. This was an oft-stated mischaracterization. How did presidential candidate Ronald Reagan respond?

“There you go again.” 

Reagan was calmly, yet firmly, exposing the consistent pattern of mischaracterizations.

Sadly, in our modern biblical counseling world, we are forced to say,

“There you go again.”

For at least the past several years, ACBC leaders have been on a constant barrage against non-ACBC biblical counselors.

• Heath Lambert and his associates produced multiple podcasts and posts about “zombie-infected” biblical counselors.
• Dale Johnson, ACBC Executive Director, has hosted multiple ACBC podcasts speaking against fellow biblical counselors.
• Dale and Francine Tan produced a multi-part series of podcasts speaking against fellow biblical counselors. I tried to address some of them, but they came so fast and furious, that I gave up. You can read one of my interactions here, and another here.
• ACBC’s Journal of Biblical Soul Care, in recent edition after recent edition, continues to focus their articles on their disagreements with other biblical counselors on issues such as trauma, being clinically-informed, common grace, etc.
• Sean Perron recently claimed that Ed Welch, CCEF, the biblical counseling faculty at Southeastern Baptist Theological Seminary, and the Biblical Counseling Coalition are unreliable as biblical counselors/biblical counseling institutions, and that they fall short of a true commitment to the sufficiency of Scripture. You can read my interactions with Sean here: A Crisis in the Biblical Counseling World? 

Gifford claims that CIBCers are not biblical counselors.

Perron proclaims that CCEF, SEBTS, the BCC, and, well, all non-ACBCers, are not biblical counselors.

Believe it or not, Omri Miles outdoes Gifford and Perron! Miles is an ACBC Certified Counselor, who frequently blogs at the ACBC site, frequently is interviewed by ACBC ED, Dale Johnson on ACBC podcasts, and who has been an ACBC Conference Plenary speaker.

What does he exclaim? He calls into question the salvation of non-ACBC-approved counselors! Read all about it here: Can You Be a Christian If You Are Not an ACBC-Approved Biblical Counselor? 

Given this relentless attack on non-ACBCers, perhaps you can understand why I entitled this section, “There you go again!”

Nouthetic for Sure: The Instinct to Confront; the Instinct to Monologue 

Perhaps ACBC should have kept the nouthetic name. They focus consistently and relentlessly on the nouthetic confrontation of fellow biblical counselors.

Many of the modern nouthetic biblical counseling leaders evade dialogue and choose monologue. They focus on telling you how you are wrong and they are right. When invited to conversation, they ignore or decline. For documentation of these patterns, and for discussions of a more biblical way, see here, here, here, here, here, here, here, and here.

This instinct to monologue is built into the Jay Adams’s DNA of the modern nouthetic counseling movement. Read Adams approach to nouthetic counseling, and you’ll see time after time that he believes in directive counseling. The nouthetic counselor is the expert who talks at the counselee and teaches the counselee from his superior understanding of Scripture. Nouthetic counseling is primarily a monologue. (Read my book, Gospel Conversations: How to Care Like Christ, and you’ll see my biblical support for biblical counseling/the personal ministry of the Word being a trialogue: the counselor and the counselee listen together to the Divine Counselor through God’s Word.)

The Nouthetic DNA: The Instinct to Instruct from a Position of Perceived Superiority; The Instinct to Be Stridently Offensive 

This directive, monologue, expert approach was part of Adams’s own DNA, part of his personality, as was the instinct to be stridently offensive. This is why Adams took this same directive, expert, moralizing approach not only with counselees, but with peers with whom he disagreed. In The Biblical Counseling Movement: History and Context, David Powlison explicitly states,

“Adams was wrong to claim—in fact, to proclaim, in strident tones—that he was the biblical answer to a briar patch of thorny intellectual, historical, social, and practical problems. He was wrong to announce, in fact to pronounce, sententiously—that all others in the field were benighted” (185-186, emphasis in the original). 

Sententious means to communicate in a way that is pompous, overly moralizing, judgmental, and self-righteous. Powlison also asserts that “Adams’s manner was obstreperous” (186)—a word that means clamorous, marked by unruly and aggressive noisiness. Powlison writes of “the offensiveness of Adams’s tone. He frequently claimed novel insights while dismissing all other thinkers as benighted” (186). Powlison continues:

“There is no doubt that Adams’s manner aggravated controversy into hostility” (186).

“He would not grant others even a modicum of professional respect” (186).

“Other readers, both pastors and laity, were frequently repelled by the stinging tone and totalitarian message of Adams’s rhetoric. They described him in terms such as belligerent, brash, abrasive, bombastic, argumentative, strident, polarizing, angry” (186).

“What Adams termed clear convictions were widely perceived as censorious, divisive, and arrogant” (186).

“The grating effect of Adams’s style compounded the offense generated by his concepts” (186).

Powlison summarizes his assessment of Adams by affirmingly quoting Christian counselor Gary Collins saying,

“I think Jay Adams’s approach to counseling is more a reflection of Jay Adams’s personality than anything else. He tends to be a somewhat confrontational type guy, and he’s a confrontational counselor” (186).

Powlison then concludes by noting “Adams’s own belligerence and intransigence” (188).

Clearly, according to David Powlison, Adams’s approach to people he disagreed with was to monologue—to talk at and teach at them from an assumed position of superiority. He personified an instinct to instruct, an instinct to nouthetically, aggressively confront his peers in a manner that was argumentative, strident, belligerent, intransigent, sententious, and obstreperous.

This argumentative nouthetic DNA continues to this day. Some current leaders in the modern nouthetic biblical counseling movement demonstrate this same instinct to instruct from a position of perceived superiority. They write, and write, and write, but they don’t accept invites to iron-sharpening-iron conversations. Again, for documentation of these patterns, and for discussions of a more biblical way, see here, here, here, here, here, here, here, and here.

In summary:

For some nouthetic biblical counseling leaders, to engage in conversation is to admit that those with whom they disagree are peers, are equals. It is in the nouthetic DNA to monologue from a position of perceived superior wisdom. To use the words of Powlison, it is in the historic DNA of nouthetic biblical counseling to be stridently offensive, obstreperous, and sententious.

CIBCers ARE Biblical Counselors 

At I noted, Gifford only mentioned me in a cursory way. His focus was on CIBCers. He mentioned me (mischaracterized me) in the context of saying that he was not the only one who questioned the CIBC label. Here’s the expanded context:

“Even outsiders to biblical counseling have commented on the unhelpfulness of the term CIBC and how it lacks clarity.”44

Footnote 44 then references me and my blog post, Why I Don’t Call Myself a “Clinically-Informed Biblical Counselor” (CIBC). Gifford inaccurately frames my views in this blog post. I never use the word “unhelpfulness.” I never use the phrase “lacks clarity.” In fact, at one point I say the opposite—that CIBC leaders repeatedly are refining and clarifying what they mean by “clinically-informed.”

You can read my blog post and see my positive support for my CIBC brothers and sisters as helpful biblical counselors. For example, I begin with these words:

“First, I want to be clear that I have great respect for my CIBC friends and their approach to biblical counseling. Please notice what I say here: ‘their approach to biblical counseling.’ There is no reason to question the fact that people like the biblical counseling faculty at SEBTS, and CIBC leader (and BCC Council Board member), Jason Kovacs, are indeed biblical counselors. Many CIBC leaders have publicly shared robust descriptions of what they mean by ‘clinically-informed biblical counseling.’ For example…” (I then link to CIBC definitions.)

I continue with these words of clear support of CIBCers as true biblical counselors.

“I also respect my CIBC friends enough to encourage them to be sure that the ‘biblical’ in their ‘BC’ remains authoritative, as it certainly does for the SEBTS biblical counseling faculty, and other CIBC leaders like Jason Kovacs.”

I then conclude with these words of positive support:

“While I choose not to use ‘clinically-informed,’ I continue to learn much helpful biblical counseling theory and practice from my CIBC brothers and sisters. In fact, I would be glad to offer ‘guest posts’ from any of my CIBC friends—engaging with this post, and describing why they choose to describe themselves as CIBC.”

As part of my conclusion, I link to another of my posts, 8 Questions for Biblical Counselors Who Are Against Clinically-Informed Biblical Counseling (CIBC). In that post I consistently/repeatedly affirm my conviction that my CIBC brothers and sisters are helpful biblical counselors from whom we can all learn a great deal.

Gifford never even hints at all of this positive support I repeatedly provide for the CIBC approach. He never hints at all the times I clearly state that they are biblical counselors.

As I noted earlier, here is what has motivated my public response to Gifford saying I am an outsider to biblical counseling:

If Gifford can’t fairly assess me, or accurately summarize my views on CIBC, then how do we know if he has fairly assessed and accurately characterized CIBC leaders?

ACBC Is Saying the Quiet Part Out Loud: Defining “Outsider” 

While Gifford is clearly inaccurate to say that I am “an outsider to biblical counseling,” there is something that Gifford could accurately say:

“ACBC is declaring that people who are not ACBC certified are outsiders to biblical counseling.” 

Gifford said it with crystal clarity in his conclusion:

“Thus, to clarify the movement going forward, true biblical counselors who want to communicate clearly their position should focus on their certification and their organization’s certification with ACBC” (42).

“If one becomes a member of the ACBC organization, it thus prohibits them from being a CIBCer” (42).

ACBC has drawn the line. Dale Johnson, Heath Lambert, Sean Perron, Omri Miles, Greg Gifford, and others, could not be more clear. In their minds:

If you are not aligned with ACBC, if you are not certified by ACBC, then you are an outsider to true biblical counseling.

How sad.

This current generation of nouthetic biblical counseling leaders are doing exactly what Powlison criticized Adams for doing. We could paraphrase Powlison like this:

“ACBC leaders are wrong to claim—in fact, to proclaim, in strident tones—that they alone have the biblical answer to a briar patch of thorny intellectual, historical, social, and practical problems. They are wrong to announce, in fact to pronounce, sententiously—that all others in the field of biblical counseling are benighted” (my paraphrase of Powlison, The Biblical Counseling Movement, 185-186).

It was this separatistic, superior, sententious attitude that motivated our launch of the Biblical Counseling Coalition fifteen years ago. People were saying, “I am of ACBC.” “I am of CCEF.” “I am of ABC.” We launched the BCC to unite the biblical counseling movement.

We launched the BCC to promote the humble attitude that we could all listen to and learn from one another.

But now, fifteen years later, the division is even greater. ACBC has publicly drawn their line in the sand.

You’re either one of us, or you are not a true biblical counselor. 

You’re either one of us, or you are an outsider to biblical counseling.

Can Someone Express Disagreement with NANC/ACBC and Still Be a Biblical Counselor? 

Some might think,

“Well, Bob, you have expressed disagreement with ACBC. You have said you see issues with some of the DNA of nouthetic counseling. So, maybe you are an outsider!” 

Well, if the criteria for being a biblical counselor is never disagreeing with fellow biblical counselors, then there are likely zero biblical counselors!

For the past fifty years, biblical counselors have disagreed with one another. I’ve documented this historically:

Is It Biblical for Biblical Counselors to Disagree Publicly?: A History Lesson.

Healthy Iron-Sharpening Disagreements 

In that post on disagreeing publicly, I discuss differences between healthy and unhealthy disagreements.

What we need to consider is what differentiates healthy from unhealthy disagreement?

Healthy public disagreement is humble. It is willing to learn from those we disagree with. It engages in face-to-face, iron-sharpening-iron conversations with those with whom we disagree. It is careful to accurately characterize others. It addresses issues rather than label or accusing people. It engages in detailed biblical, theological, and historical (church history) evidence.

Unhealthy and unholy public disagreement is arrogant. It is unwilling to learn from those we disagree with. It mischaracterizes the views of others. It labels and accuses others with loaded, pejorative words like “unbiblical,” “integrationist,” “neo-integrationist,” “so-called biblical counselor,” “zombie-infected.” It makes generic, broad statements rather than dealing in detailed biblical, theological, and historical arguments.

Expressing disagreement with fellow biblical counselors does not make you an outsider to the biblical counseling movement: not if you do it in a biblical way.

Just four years ago I wrote a book on mistakes we make as biblical counselors: Consider Your Counsel: Addressing Ten Mistakes in Our Biblical Counseling. It was endorsed by seven ACBC Fellows—who saw it as a respectful, helpful, iron-sharpening way to encourage all of us within the modern biblical counseling movement to keep growing—the progressive sanctification of the biblical counseling movement.

Unhealthy Us Versus Them Disagreements 

I would have had no issue with Gifford engaging with CIBC and highlighting their strengths, truths he has learned from them, discussing any concerns he has with them, outlining any perceived weaknesses, and then sharing suggestions for growth. But that is not what Gifford did.

Gifford made his discussion “us versus them,” “good versus evil,” “right versus wrong,” “in versus out.” He does so not on the basis of the sufficiency of Scripture, but on the basis of the sufficiency of ACBC’s definition of counseling.

From the outset of his article, Gifford purposefully and explicitly sets up ACBC as the basis, the standard for what is and is not truly biblical counseling. He uses ACBC’s definition of “biblical counseling” as the guideline for whether others are or are not truly biblical counselors. Gifford writes:

“In order to establish the author’s thesis, a few terms need defining to ensure clarity…. The author will seek to find categories of biblical counseling in this paper. Biblical counseling will be utilized according to ACBC’s definition” (27).

Gifford is not saying, “You’re not aligned with ACBC if you disagree with ACBC’s definition.” That would have been reasonable. Instead, Gifford’s paper is saying,

You’re not a biblical counselor if you fail to align with our interpretation of our manmade definition of what a biblical counselor is.

Having used ACBC’s manmade definition of biblical counseling throughout his paper, at the end of his paper Gifford then draws his manmade conclusion:

“The subtitle of this paper is, ‘Is Clinically-Informed Biblical Counseling Really Just Integrationism?’ The answer to that question is, ‘yes.’ What has historically been claimed as Integrationism is now what the clinically-informed biblical counseling movement is practicing. Though the CIBC movement is yet to be identified and clearly delineated, one can be sure that the CIBC movement is quite different from biblical counseling” (44-45).

Gifford outs Clinically-Informed Biblical Counselors as outsiders to biblical counseling, as not true biblical counselors—on the basis of his manmade definition of biblical counseling. This is not an incidental or minor action; it is a significant, deliberate, calculated, knowing deed designed to designate others as outsiders, and to declare yourself and your group as the only true, acceptable insiders. This is the classic Pharisaical, legalistic, fundamentalist move:

Place someone “outside the camp,” as “other,” as “unclean” on the basis of manmade regulations.

Yes, there is a healthy, holy way for us to engage with one another and to sharpen one another as fellow biblical counselors. And there is an unhealthy way to disengage from one another and to exclude others—based upon human commands and teachings (Colossians 2:16-23).

What Might I Hope For? 

I would hope that Greg Gifford, ACBC, and The Journal of Biblical Soul Care might be responsive in several potential ways. I’ll frame them as questions.

1. Greg, ACBC, JBSC, would you consider offering Jason Kovacs an opportunity in your journal to respond to your claims about his model of biblical counseling?
2. Greg, ACBC, JBSC, would you consider offering the biblical counseling faculty at SEBTS an opportunity in your journal to respond to your claims about their model of biblical counseling?
3. Greg, ACBC, JBSC, is it now your official position that the only true sign of a true biblical counselor is ACBC certification?
4. ACBC leaders, would you reconsider the suggestion that biblical counseling leaders convene a face-to-face conciliation summit (not hosted or moderated by ACBC, but my outside leaders such as seminary Presidents)?
5. Greg, after considering Bob Kellemen’s post and his history as a leader in the modern biblical counseling movement, would you think about reframing your characterization of him as “an outsider to biblical counseling”?
6. Greg, if you mischaracterized Bob Kellemen, why should readers be confident that you accurately characterized Jason Kovacs, the SEBTS biblical counseling faculty, and Clinically-Informed Biblical Counselors? 
7. Greg, what are the strengths that you see in CIBC? What have you learned from CIBC leaders? What could ACBC learn from CIBC teaching and practice?

What Do I Anticipate?

I am not sure what to anticipate… I suppose there are various options.

Positive Response: I’d like to say that I anticipate a positive response to the questions above and to the feedback provided in this post. That’s possible.

Ignoring: If past history is indicative of future possibilities, then I might anticipate that this post is ignored.

Mocking: Other past history indicates, sadly, that a post like this may be mocked.

“That’s a lot of words for one off-handed comment by Gifford. Don’t you know that where there are many words, sin is not lacking (Proverbs 10:19)?” 

It’s interesting that a group (ACBC) that produces seemingly endless lengthy critiques of fellow biblical counselors, then mocks fellow biblical counselors who respond with a robust, well-reasoned, lengthy reply.

Mischaracterizing: Still other past history could predict further mischaracterizing—taking quotes out of context, not engaging fairly or accurately with feedback.

Praying for Unity in Humility and Civility with Wisdom for God’s Glory: My prayer is that we would all, as biblical counseling leaders, engage with one another in a spirit of Ephesians 4:1-7 unity, Philippians 2:1-5 humility, and James 3:13-18 civility and wisdom, as we speak the truth in love for the glory of God and for the progressive sanctification of the biblical counseling movement (Ephesians 4:15-16).