Just a note to echo all the sentiments on here; this one is *hard*. I've come back to it on and off for several days and I'm not getting anywhere. I find 19a a bit annoying because I want to inflate the last two letters and can't; I just can't get many of the rest.
Retiring injured :)
PS mdmaylwin @69: The vowelless one wasn't harder than this, was it?! If so, apologies :)