Few workplace situations present the intense, rapidly changing work environment as do fire & rescue operations at an emergency scene. Even with all safety policies followed and procedures in place, unpredictable hazards can still create an extremely threatening environment – one that emergency responders cannot simply back away from. After all, the job often entails creating order out of chaos, a task that can put a substantial burden on both response personnel and scene commanders. Officers must move beyond ensuring that all safety measures have been taken and become risk analysts, constantly evaluating and predicting current and future situations that develop in what can be a very dynamic environment.

East Manatee Fire Rescue has recognized this potential and taken steps to create an atmosphere within the organization where all members are keenly aware of the need for constant situational awareness when it comes to safety concerns, and then be prepared to take immediate corrective action when and where needed. To best prepare for this potential, the fire district has embraced a coordinated safety and training effort involving department personnel all the way down to the newest rookie. This work ethic has been incorporated into the mainstream of the organization through a more consistent awareness of the need for workplace safety – a success rate that can be attributed to the oversight of the district safety committee through quarterly meetings, monthly station inspections, and a rigid follow-up system for any identified deficiencies.

As stated earlier, however, the needs of the district go beyond workplace and incident scene safety alone. Addressing these needs through a broader view of both internal and external risk potential requires that all personnel become an integral part of the process. This process begins by providing more thorough administrative oversight of the individual areas of responsibility that are assigned to certain district personnel. For example, testing and maintenance of all personal protective equipment must be ensured and tracked with great accuracy, while the maintenance procedures and record keeping that keeps response vehicles in top shape contributes to the safety of district personnel and the public alike.

CONTINUED ON PAGE 2

 The Importance of Best Practices in Fire & Rescue Safety - If it’s Predictable, it’s Preventable Exclusive Article:

Title VII Alert - Supreme Courts Ruling Will Likely Favor Employers ................ 3

Special Article: Safe Festivals & Fairs - A Guide to Municipal Event Safety ............................ 4

Welcome New Preferred Members .............. 6

News Extra: Preferred Announces Launch of New Mobile Claims App .......................... 6

Preferred HR Risk Management Helpline Update .................................. 7

Member Spotlight ............... 8

Breaktime Fun -n- Games .................... 11

Fall 2013

Inside This Issue:

By Tim Hyden, Training & Safety Officer - East Manatee Fire Rescue

News

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FEATURE ARTICLE

Both are just two examples of the many areas of responsibility when considering the potential for things to go wrong at the worst possible time.

With this potential in mind, the subject of risk management is seen as a very sensible approach to the concept of what is predictable is preventable. From an overall view, the process provides a means of evaluating where risk potential lies and begins the process of mitigating that risk before a negative impact occurs. Likewise, the same process is used on an emergency scene – though usually much more abbreviated and immediate. To help solidify this message, the well-known risk management expert Gordon Graham was brought to Manatee County in the fall of 2010 to share his expertise on the subject as it relates to fire, EMS, and law enforcement operations. The seminar was well attended and considered a great success. Consequently, with all efforts considered, an improved ability to predict and divert injury to personnel and embarrassment or loss to the organization is being realized.

So what does the future hold for East Manatee Fire Rescue when it comes to safety and risk management? Administrators are confident that the accomplishments made over the past few years will guide district members as they move up into more supervisory roles and thereby assume more influence and control of future district direction – an effort and effect meant to serve the interests of the public we serve and the personnel entrusted to carry out that mission.

Tim Hyden is the training and safety officer for East Manatee (FL) Fire Rescue and has been a member of the Florida fire service since 1992. He has an associate degree in fire science, an advanced technical certificate in fire science administration, and is nearing completion of a bachelor’s degree in public safety administration from the State College of Florida. He is a graduate of the Florida Fire Chiefs’ Association Emergency Services Leadership Institute and holds several state certifications through the Florida Bureau of Fire Standards and Training. He is a contributing writer to Florida Fire Service and Fire Engineering magazines and speaks on leadership, motivation, officer development, risk management, and marketing. Tim and his wife Maureen live in Manatee County.

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Suzanne A. Singer is a partner of Rumberger, Kirk & Caldwell and focuses her practice primarily in the areas of employment and labor law, casualty defense, and professional liability. Rumberger, Kirk & Caldwell provides litigation and counseling services in product liability, commercial litigation, construction, IP litigation, employment, insurance coverage, professional liability and toxic torts. Offices in Florida and Alabama. www.rumberger.com

EXCLUSIVE ARTICLE

Title VII Alert - Supreme Courts Ruling Will Likely Benefit EmployersBy Suzanne A. Singer, Partner - Rumberger, Kirk & Caldwell

Narrow definition of Supervisor for Title VII liability

In the late 1990s, the Supreme Court held in Burlington Industries v. Ellerth and Faragher v. Boca Raton that an employer is automatically liable under Title VII of the 1964 Civil Rights Act for discrimination by a “supervisor.” On the other hand, if the discriminating employee is the plaintiff’s co-worker, the company is liable only if the victim complains to her employer and the employer is negligent in responding to the complaint. Potential liability against an employer is affected by the classification of the harassing employee as either a co-worker or a supervisor. In the wake of those decisions, there has been much dispute about what employees qualify as “supervisors” because the Supreme Court had not defined the term.

On June 24th, 2013, in Vance v. Ball State University, the Supreme Court resolved the issue in a 5-4 decision by defining a “supervisor” as one who has the power to take a “tangible employment action” against the victim. He or she must be able to “effect a ‘significant change in employment status, such as hiring, firing, failing to promote, reassignment with significantly different responsibilities, or a decision causing a significant change in benefits.’”

It should be noted that the Equal Employment Opportunity Commission (“EEOC”) had previously defined a supervisor based upon one’s ability “to exercise significant direction over another’s daily work.” Similarly, the Second and Fourth Circuits of the United States Court of Appeals had adopted the EEOC’s definition. The Supreme Court has now adopted a bright-line definition, rather than the open-ended definition set forth by the EEOC, thereby narrowing the scope of who qualifies as asupervisor for Title VII liability. The Court’s opinion may make it more difficult for employees to win workplace harassment suits against their employers because of the narrow definition of “supervisor.” Nonetheless, employers should continue to carefully monitor the work environment because an employer will always be found liable when a court finds that the employer’s own negligence lead to the creation or continuation of a hostile work environment.

The New Standard for Retaliation Claims

In another 5-4 decision issued the same day, the Supreme Court also imposed a more stringent causation standard for retaliation lawsuits. In University of Texas Southwestern Medical Center v. Nassar, the Supreme Court held that the appropriate causation standard for retaliation lawsuits was “but-for” rather then the “motivating factor” test. It is no longer sufficient to prove that the adverse employment action may have been motivated, in part, by a desire to retaliate. In establishing liability, an employee must now show that the adverse action would not have been taken “but for” the motive to retaliate. This holding will also impact the causation standard in retaliation lawsuits under the Florida Civil Rights Act because the Florida Act was patterned after Title VII and is interpreted in accordance with decisions construing Title VII. Retaliation claims are the most common type of claim filed against employers, having more than doubled in the past 15 years. The Court’s recent ruling is favorable and will make retaliation claims more difficult to prove. The Court predicts that this ruling will reduce the amount of frivolous lawsuits. Because of the Court’s Nassar decision, for a plaintiff to survive summary judgment and to prevail at trial, the employee will now have to prove that retaliation by the employer actually caused the harm that is alleged. The previous standard would have permitted an employee to prove liability even if the allegedly illegal conduct was merely a motivating factor for the adverse action.

CONTINUED ON PAGE 5 4

SPECIAL ARTICLE

Safe Festivals & Fairs - A Guide to Municipal Event SafetyBy Chris Kittleson, Senior Safety & Risk Consultant - Public Risk Underwriters of Florida

Municipalities often provide their citizens with special events such as fairs, parades and holiday/seasonal events such as Fourth of July Fireworks or Halloween. These events whether the municipality or an outside organization is sponsoring them may create liabilities and hazards that the municipality must control.

When a municipality decides to use their own resources to conduct a special event there are a multitude of potential exposures that would require planning to more effectively control hazards depending on the type of the event. An excellent example of “Special Event Safety” is the City of North Miami’s annual Halloween Haunted Trail event that is held at the City’s Enchanted Forest Park.

The Halloween Haunted Trail event is entering its ninth year at the Enchanted Forest Park, which is a 22 acre oak filled park and green space. The park is completely fenced in with access for pedestrians at one main entrance. The park event is divided into three main sections, the haunted trails, hayrides and children’s fun zone. In addition, the event includes bounce houses, games, face painting and food. The City averages approximately 2500 patrons within a span of three hours for the event.

To date, there has only been one minor trip and fall injury reported, which speaks volumes to the effectiveness of the City’s extensive pre-planning and safety coordination endeavors. The event planning takes place six months out from the actual date, which is initiated by the Parks and Recreation Department. Other City departments assist during the planning stages such as, Risk Management/Safety, City Engineer, Building Department, Police, as well as Volunteers. In addition, the Miami-Dade Fire Department is notified prior to the event.

The basic plan includes the formation of ideas, budget, layout of the event and advertising. The following is a list of North Miami’s pre-event planning activities that is used to coordinate the event:

• Recruitment of Volunteers.• Review of budget and supplies, three months prior to event. • Consideration of event insurance coverage and hold harmless/indemnity agreements.• Trees cleared, dead branches trimmed, pathways evaluated for clearance, one month prior to event. • Comprehensive structural evaluation by City Engineer/Building Department for shop made structures, i.e. Haunted House and

existing infrastructure, i.e. canal bridges, one month prior to event. • Review of water’s edge is evaluated for steepness and areas marked for fencing.• Areas for Scare Zones are marked with paint for guidance in accordance with event plan.• Night time inspection to assess lighting conditions.• Sidewalks are evaluated for slip, trip and fall hazards and repaired as required.• A safety meeting and walk though is conducted by City Safety Officer to evaluate event plans on-site, two weeks prior to event.• Establishment of emergency evacuation locations, Exit signage and fire extinguisher stations are identified and reviewed with

Staff. • A full dress rehearsal of Scare Zones are reviewed with Staff in the evening to correctly place lighting, one week prior to event.• Night training of Staff and Volunteers takes place, including a full workshop on etiquette, scare tactics, safety and evacuation

routes.• Final walk through including full lighting review/placement as well as evaluation of delineation of pedestrian walkways to

determine if lines are properly located as per plan. • Final walk through, one day prior to event.• Event execution, day of event. • Clean up and removal of temporary structures, day after the event.

In some instances organizations including civic groups and non-profit charities are available to sponsor and participate in special events. Special events provide these organizations a means of promoting their groups as well as fund-raising. These organizations usually do an excellent job of securing volunteers, selecting vendors, and providing additional Staff to police the event once it is underway. Before trying to seek the participation of an outside organization(s) to sponsor and event, the municipality should evaluate how hazardous the event may be. To do this, the municipality should evaluate the activity itself, any physical activity the event may require of participants and exposure to the participants. For a municipality, using such organizations may make it easier to transfer the risk thus minimizing its exposure if the special event results in claims of any kind.

In order to lend assistance with special event safety please refer to the Event Safety Check List located at the following link, www.pgit.org /Resources/Preferred News 2013 - Fall 2013/Event Safety Checklist. In addition, Karen Muir, Risk Manager and Anna Cramarossa, Safety Officer, from the City of North Miami’s Risk Management Division would be more than happy to discuss their special event planning process in more detail. They can be reached at kmuir@northmiamifl.gov and acramarossa@northmiamifl.gov respectively.

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SPECIAL ARTICLE

Christopher H. Kittleson joined Public Risk Underwriters of Florida, Inc. as a Sr. Risk Control Consultant in 2010 and provides Loss Control services for the southern Florida region. With over 15 years of safety & health consulting experience Chris has developed industry expertise in the areas of Construction, Manufacturing and USL&H as well as safety programming expertise in the areas of Safety Program Development, Return to Work Programs, Regulatory Compliance, Accident Investigation and Safety Training. Prior to working in the Insurance industry Chris’ career was with IBM where he held various Engineering positions. Chris graduated Cum Laude from St. Cloud State University, St. Cloud, MN with a Bachelors of Science in Engineering Technology, is a Professional Member of the American Society of Safety Engineers and has earned his Associate in Risk Management (ARM) designation.

Preferred Panel Attorney is Chosen as One of Florida Trend Magazine’sLegal Elite / Legal Leaders for 2013

Preferred would like to congratulate Leonard J. Dietzen III of Rumberger, Kirk & Caldwell in making Florida Trend Magazine’s Florida Legal Elite / Legal Leaders for 2013. Florida Trend began publishing its Legal Elite special report ten years ago in recognition of those top attorneys in the state as chosen by their peers.

Leonard is a partner of Rumberger, Kirk & Caldwell and focuses his practice in the area of labor and employment and commercial litigation. Rumberger, Kirk & Caldwel provides litigation and counseling services in product liability, commercial litigation, construction, IP litigation, employment, insurance coverage, professional liability and toxic torts. They currently have offices in Florida and Alabama.www.rumberger.com.

Would you l ike additional copies of the Prefer red News..? Additional copies of the Preferred newsletter may now be printed in PDF format by going to www.pgit.org and accessing the Resources section of the website.

There you will find not only the most recent edition of the newsletter, but also previous editions as well, or if you like, you may also look up current and past articles of interest by utilizing the article index.

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NEWS EXTRA

As a PREFERRED member you will be able to:

• Readily access pre-approved vendors for repairs and remediation services

• Contact your designated adjusters or agent via phone or email

• Link to external organizations such as FEMA or OSHA

• Find information on other PREFERRED services available

The app is available for Apple and Android mobile devices and can be downloaded for free by utilizing the QR Code links to the right:

If you need assistance obtaining your app, call support at 321-832-1462.

We hope you’ll find this new service and capability valuable to you in the future.

Preferred Announces Launch of New Mobile Claims App

Android

Apple

Preferred Governmental Insurance Trust is pleased to announce the launching of a mobile app for claims reporting purposes and other valuable uses. It enables on- site reporting of claims** including damage from windstorms/hurricanes and other catastrophic events but can also be used to report workers compensation, automobile, general liability and all other property claims.

** Claim reporting requires pre-registration. If you do not already have online claims access through PGCS, please  register at www.pgcs-tpa.com

Preferred would like to welcome the following new members...

Viera Stewardship District

Bay County School Board

Belmont Academy

Gulf Coast Middle School

Odyssey Preparatory Academy

Lee County School Board

BEST Academy (Brooksville Engineering, Science & Technology Academy, Inc.)

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NEWS EXTRA

Preferred HR Risk Management HELPLINE Update

ADA/Disability

Policies & Procedures

Drug Testing

FMLA

All Other Issues

EXCITING NEWS:

As of July 1st, 2013 this valuable service is nowmade available to all School members withELL/EPLI coverage through Preferred...

On October 1st, 2013 this valuable service will be made available to all Peferred members withPOL/EPLI coverage through Preferred...

Since Preferred rolled out the HR Risk Management HELPLINE it has had a great impact on and has received numerous positive testimonials from the members who utilize this great resource on a regular basis. Here is just a sample of the testimonials that have been received...

“The HELPLINE is so useful to me as the only HR person here. It seems that any question I have, they always have an answer that is easy to understand and applicable for me. I like and use it so much that I no longer have my membership in the SHRM. It is a cost saver for the City and helpful to me. I would have no problem referring others to this site and hope that Preferred never “lets it go”

- HR Administrator; Northeastern Florida Municipal Member

“I’m finding the Preferred HR Management HELPLINE through Preferred a really neat tool. I thought the online Sexual Harassment training was great; it was nice that we could track progress and see who completed it and who did not. We managed to get everyone completed on time due to this feature. We thought the training was very informative overall. I think it’s great that a Relationship Manager reached out to me and gave me a tour of the website. Through that I was able to learn new features about the service. It’s a great thing to have access to attorneys in case we ever run into a situation”

- Drew Hunter, Administrative Assistant/HR; Alachua County Housing Authority, FL; Administration of Housing Programs

“I think the HELPLINE is a very good tool for managers; I am so glad to have it! My first impression of the website was that it is professional and easy to use. My favorite part of the service is the ability to ask questions specific to my needs. I generally use the service once or twice a month. When I log on, I am usually looking for a specific topic or case related to my needs at the time. The Questions of the Month are my favorite. I would ABSOLUTELY recommend this service to other employers! I am SO glad to have the HELPLINE; I am grateful that it is included as part of our membership with Preferred!”

- City Clerk; General Government, NEC

Currently there are 168 Preferred members enrolled to utilize the HELPLINE. The following statistics reflect HELPLINE activity by members for the last 12 months...

• 80% have proactively utilized the services, which is over 16 times the industry standard for value-add/risk management services.

• With an average of 2.7 proactive requests per utilizing member. HELPLINE users have recorded a total of 371 touch points.

• 221 member contacts of the enrolled 168 members currently have access to HELPLINE services including the employment law attorneys via toll-free number and/or the internet website. These member contacts also receive monthly HR Express Updates and 4-6 HR Alerts thoughout the year.

2nd Quarter Touch Point Topic Summary

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Pictured are City of Naples Fire & Rescue personnel administering oxygen to injured canine utilizing mask specifically designed for administering oxygen to animals during pet rescues

MEMBER SPOTLIGHT

City of Naples Fire & Rescue Department is Truly Commendable Whenit Comes to Honoring the Firefighter’s Pledge

On the night of Friday - July 26th, 2013 the City of Naples Fire & Rescue Department received a 9-1-1 call per smoke coming from a residential structure. Upon arriving on the scene Firefighters discovered what appeared to be a fire at the back of the structure.

Firefighters immediately entered the structure and began performing firefighting protocols which including an immediate search of the structure for possible occupants. During the intensive search the Firefighters did not discover any human occupants, but did discover two small canines in a room adjacent to the room that was on fire. Both appeared to be unconscious and not breathing.

Firefighters quickly rushed the two small canines outside where they administered CPR along with oxygen utilizing a mask specifically designed for administering oxygen to animals during pet rescues.

Even though only one of the canines could be revived and saved, neither of the canines may have had a chance if it were not for the well qualified and competent firefighters of the City of Naples Fire & Resue Department.

This story is exemplary of just how strongly dedicated, courageous and compassionate these firefighters are in helping those in need and saving the lives of others, and is a reflection of just how truly commendable they are when it comes to honoring the Firefighter’s Pledge...

Submitted By Public Risk Underwriters of Florida, Inc. - Safety & Risk Management Department

I promise concern for others.A willingness to help all those in need.

I promise courage - Courage to face and conquer my fears.

Courage to share and endure the ordeal of those who need me.I promise strength -

Strength of heart to bear whatever burdens might be placed upon me.Strength of body to deliver to safety all those placed within my care.

I promise the wisdom to lead, the compassion to comfort,and the love to serve unselfishly whenever I am called.

- Author Unknown -

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Pictured (L to R) Amy Mercer, Executive Director - FPCA; Allen Durham, Star & Shield Group CEO; Captain William Fowler, Bradenton Police Department; Tami Spyker, Neighborhood Watch Liaison; Michael Radzilowski, Chief of Police - City of Bradenton PD; Dennis Jones, Chief of Police - City of Tallahassee PD & FPCA Immediate Past President

MEMBER SPOTLIGHT

The City of Bradenton Police Department was recently awarded the Rocky Pomerance Law Enforcement Excellence Award for its Neighborhood Liaison Communication Project at the FPCA’s 61st Annual Summer Training Conference & Exposition Banquet, which was held in Bonita Springs.

The “Rocky Pomerance Law Enforcement Excellence Award” provides a mechanism for the Florida Police Chiefs Association to recognize member agencies for developing and implementing an innovative approach to policing.

Bradenton Police Chief Michael Radzilowski commented “I am very proud of our Neighborhood Liaison Project, and the rapport that it has developed between the Bradenton Police Officers and the residents, this has helped foster the ongoing respect and feeling of teamwork resulting in collateral changes in the targeted areas including increased business activity, increased home sales, and a drop in the crime rate by 28.8 %.

The citizens of Bradenton expressed that their efforts were effective in reducing crime, thereby reducing fear, and increasing the feeling of safety, ownership and teamwork alongside the members of the Bradenton Police Department. This collaborative effort has saved the Bradenton PD in excess of 6,000 man hours and $200,000 in taxpayer monies.”

City of Bradenton Police Department Wins FPCA Award for NeighborhoodLiaison Communication ProjectSubmitted By Public Risk Underwriters of Florida, Inc. - Safety & Risk Management Department

City of Haines City Receives 2013 FSA Outstanding Achievement Awardfor Stormwater Educational UnitSubmitted By Public Risk Underwriters of Florida, Inc. - Safety & Risk Management Department

The City of Haines City is proud to announce that on June 14, 2013, at the Florida Stormwater Association (FSA) Annual Conference held in Fort Myers, the City’s Public Works Department - Stormwater Division received the 2013 FSA Outstanding Achievement Award for it’s Stormwater Educational Unit. Gail Myhand, David Barnes and Ed Trail, of the City’s Stormwater Team, came up with the idea to build a mobile model that would serve to educate the public about the importance of stormwater management and the harmful effects that untreated stormwater run-off can have on area lakes.

With a $5,000 grant from Florida Department of Environmental Protection (FDEP), and $3,200 from both the Water Utilities division and the Stormwater division, a trailer was designed and constructed. This award gives the Stormwater Team statewide recognition for their hard work and dedication.

The Haines City Stormwater Educational Unit, or Water Wagon as it is called, will allow the City’s Stormwater division to further comply with the educational requirements of it’s MS4 permit.

Pictured (L to R) David Barnes, Stormwater Foreman - City of Haines City; Gail Myhand, Streets Superintendent - City of Haines City; Ed Trail, Traffic Maintenance Coordinator - City of Haines City

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MEMBER SPOLIGHT

City of Bradenton Receives 2013 FSA Excellence Award for RiverwalkRestoration ProjectSubmitted By Public Risk Underwriters of Florida, Inc. - Safety & Risk Management Department

The City of Bradenton is proud to announce that the City recently received the 2013 FSA Excellence Award for it’s Riverwalk Restoration Project, which was presented at the Florida Stormwater Association (FSA) Annual Conference held in Fort Myers on June 14, 2013.

A project team consisting of the City’s Department of Public Works & Utilities, Downtown Development Authority, and Realize Bradenton earned the award through its combined teamwork in designing and constructing a public park that restores and enhances natural systems, improves native habitats, and improves stormwater quality discharge along a 1.5 mile stretch of the Manatee River. The Signature park also creates numerous educational opportunities for park visitors to interact with the natural systems along the river. The restoration project was funded through an agreement with the Southwest Florida Water Management District, which included $400,110 for restoration activities, and additional funds from the Bradenton Downtown Development Authority and the citizens of Bradenton.

If interested, please contact:Mike Stephens - Safety & Risk Management ConsultantEmail: mstephens@publicrisk.com Phone: 321-832-1658

We would like to share your best practices, risk management expertise, success stories, and the accomplishments of your entity and employees with fellow members in our next news letter.

BE IN THE MEMBER SPOTLIGHT...

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24 10  1  1 24  12  17   3 14  15  14   3  14  12 17   10   6 12 19  5  5  1

KEY STAFF CONTACTS:

As a member of Preferred your first call should always be to your agent, if however you need help beyond your agent please feel free to contact us as indicated below:

Marketing:marketing@publicrisk.com321-832-1455Kurt Heyman

Operations:ahansen@publicrisk.com321-832-1510Ann Hansen

Loss Control:mstephens@publicrisk.com321-832-1658Mike Stephens

Claims:liability claims@pgcs-tpa.com866-683-7710Julius Hajas

BREAKTIME FUN -N- GAMES

Please visit www.pgit.org/Resources/Preferred News 2013 - Fall 2013/Article Index for cross word & cryptogram solution keys

“FALL” IS IN THE WORD ACROSS: 1. An unexpected legacy, or other gain 5. Made while moving away from the basket in basketball 7. Moving under the influence of gravity toward a celestial object 9. A humiliating mishap or blunder11. To come to pass; to happen12. A failure to come up to expectation or need16. A fancy ornament especially in  dress19. Butterfly-shaped pasta21. Sighting or making land when at sea23. A rope used in hoisting the anchor  to

the cathead of a sailing ship24. A sudden descent from rank or  state, reputation or happiness; ruin26. A pit deceitfully covered to entrap wild beasts or men; a trap of any kind27.  With hanging head; hence, dispirited; dejected; cowed28. Not liable to fail, deceive, or

disappoint; indubitable; sure; certain

DOWN: 2.  A deposit of volcanic ash 3. A fresh-water fish of the United States; called also silver chub and shiner 4. Liable to fail, mistake, or err; liable to deceive or to be deceived 6. Not morally fallen: innocent 8. The close of the day10. A secondary and often lingering effect, result, or set of consequences13. The mouth of a river; the lower end of a water course; the open end of a drain or culvert where discharge occurs14. Beginning of evening15. A decline in quantity or quality17. A tangled mass of fallen trees and branches

18. An argument, or apparent argument, which professes to be decisive of the matter at issue, while in reality it isn’t; a sophism20. Land that has lain a year or more untilled or unseeded; land plowed without being sowed for the season22. A falling back: retreat25. Dropped; prostrate; degraded; ruined; decreased; dead

FALL CRYPTOGRAM

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