[00:00:00] Speaker 02:
And so, with that, Madam Clerk, I would ask you to call the first case.

[00:00:07] Speaker 00:
The first cases are Inray Cash and Family Trust and Inray Western Steel, Inc., Stephen Mark Hayden, Appellant Arguing Pro Se, and Joel Schwartz, appearing for Appellee's.

[00:00:24] Speaker 02:
Right.

[00:00:24] Speaker 02:
And I see Mr. Schwartz, Mr. Hayden, I don't see you.

[00:00:31] Speaker 02:
except now you're on mute.

[00:00:34] Speaker 02:
So could you please unmute yourself?

[00:00:37] Speaker 03:
Yes, ma'am.

[00:00:38] Speaker 02:
All right.

[00:00:38] Speaker 02:
Thank you very much.

[00:00:40] Speaker 02:
All right.

[00:00:40] Speaker 02:
So you're the appellant, Mr. Hayden.

[00:00:42] Speaker 02:
You've got two appeals, but it's the same issue.

[00:00:45] Speaker 02:
So you will have 15 minutes in total to make your argument.

[00:00:49] Speaker 02:
So please let me know if you would like to reserve any time for rebuttal.

[00:00:54] Speaker 03:
I would like to reserve approximately five minutes for rebuttal.

[00:00:58] Speaker 02:
All right.

[00:00:59] Speaker 02:
Thank you.

[00:00:59] Speaker 02:
Please begin.

[00:01:00] Speaker 03:
Thank you.

[00:01:03] Speaker 03:
First of all, I appreciate the time of the course.

[00:01:08] Speaker 03:
This is a great honor to speak in front of you.

[00:01:13] Speaker 03:
And we all just have so much time.

[00:01:17] Speaker 03:
We have that clock over there.

[00:01:20] Speaker 03:
Your attention is very important.

[00:01:24] Speaker 03:
Now prior to this hearing today, there were 3,000 pages filed in an appendix.

[00:01:33] Speaker 03:
I didn't have time to read them.

[00:01:36] Speaker 03:
I hope y'all haven't had your time to read them.

[00:01:39] Speaker 03:
But I did ask that the court, in a motion filed just a few days within the last 48 or 72 hours, that the court strike those 3,085 pages in a record excerpt.

[00:01:57] Speaker 03:
Those 3,000 pages were intended to show that I was vexatious.

[00:02:01] Speaker 03:
But I think that such a long excerpts that I'm not able to spend time reading really does not prove that, proves quite the opposite.

[00:02:10] Speaker 03:
But I'll go ahead and give my opening statement.

[00:02:13] Speaker 03:
And I have included a short brief about why the reasons that Joel Schwartz is not authorized to represent the Cash and Family Trustee.

[00:02:24] Speaker 03:
He represented the Cash and Family Trustee

[00:02:28] Speaker 03:
at the hearing on both of these appeals that are very interrelated.

[00:02:35] Speaker 03:
He was not authorized.

[00:02:37] Speaker 03:
And I refer the appellate court to that brief, which is part of the record before this hearing actually started.

[00:02:45] Speaker 03:
And I think it's always important for me to show respect to Joel, for me to show respect to members of the court.

[00:02:55] Speaker 03:
And I'll let the court, at their time and leisure,

[00:02:58] Speaker 03:
review that brief.

[00:03:00] Speaker 03:
I thank you.

[00:03:02] Speaker 03:
So with that, I'll begin my opening brief.

[00:03:06] Speaker 03:
I'll spend approximately eight minutes.

[00:03:10] Speaker 03:
The July 29th, 2024 hearing was a combined hearing.

[00:03:18] Speaker 03:
It was invalid because attorney Schwartz never established authority to represent the Cash and Family Trust.

[00:03:26] Speaker 03:
That was the debtor of one of the cases.

[00:03:30] Speaker 03:
Motion 43 was filed in the Cash and Family Trust without proper standing for him to represent the Cash and Family Trust.

[00:03:42] Speaker 03:
And the court relied on it to impose sanctions.

[00:03:47] Speaker 03:
That's a very serious statement.

[00:03:51] Speaker 03:
And I am aware of the severity of that statement.

[00:03:54] Speaker 03:
However, if you look at the docket sheet for the Cash and Family Trust,

[00:03:59] Speaker 03:
And for brevity, I'll refer to it as 1-3-583.

[00:04:03] Speaker 03:
In that docket, Schwartz is not listed as the appearing attorney of record, and yet he appears in the hearing entries.

[00:04:17] Speaker 03:
The consolidated hearing created due process defect affecting both appeals.

[00:04:25] Speaker 03:
The bankruptcy docket shows the debtor as the cash in family trust, EIN 817843.

[00:04:32] Speaker 03:
Representation, according to the docket sheet, pro se.

[00:04:38] Speaker 03:
No trustee appeared.

[00:04:40] Speaker 03:
No trust document was filed showing that Joel Schwartz could appear.

[00:04:47] Speaker 03:
No trustee affidavit was filed.

[00:04:50] Speaker 03:
No motion to appear for the trust was filed by Attorney Schwartz.

[00:04:54] Speaker 03:
Motion 43, the motion to declare me a vexatious litigant, was only filed on behalf of Western Steel and William Cashin.

[00:05:03] Speaker 03:
Yet at the July 29th hearing, Mr. Schwartz appears and argued as though he represented both the trust and the creditors.

[00:05:14] Speaker 03:
And the creditors would have included Cashin Family Trust.

[00:05:20] Speaker 03:
A trust is not a natural person, and it must act through a trustee.

[00:05:23] Speaker 03:
and the lawyer must be engaged by the trustee.

[00:05:25] Speaker 03:
None of that appears in this record.

[00:05:29] Speaker 03:
Under federal law, when authority is challenged or unclear, the court must require counsel to produce their authorization.

[00:05:39] Speaker 03:
That never happened.

[00:05:41] Speaker 03:
This goes to jurisdiction.

[00:05:45] Speaker 03:
If a party appears to an unauthorized lawyer, the proceeding cannot stand.

[00:05:54] Speaker 03:
Motion 43 lacked standing because it was filed by non-party creditors.

[00:06:02] Speaker 03:
Motion 43 was styled as filed by Joe Schwartz on behalf of William Cash and Western Steel.

[00:06:10] Speaker 03:
The movements were not the debtor, the trustee, or the party authorized to act for the Cash and Family trustee.

[00:06:19] Speaker 03:
Yet the bankruptcy court treated the Motion 43 as if it came from the debtor or representative of the debtor.

[00:06:27] Speaker 03:
This court's vexatious litigant order depends entirely on the legitimacy of Motion 43.

[00:06:36] Speaker 03:
If the movement lacks standing and he clearly did, the resulting order is void.

[00:06:46] Speaker 03:
The consolidated July 29th hearing caused due process violations.

[00:06:51] Speaker 03:
The hearing combined the Cash and Family Trust order to show cause, Motion 43, Western Steel adversary order to show cause, and a vexatious litigant motion in the adversary.

[00:07:05] Speaker 03:
This single hearing became factual foundation for both orders now on appeal.

[00:07:11] Speaker 03:
But the parties and roles were never clarified.

[00:07:16] Speaker 03:
I hadn't had notice that the debtor previously listed as pro se would suddenly be represented.

[00:07:22] Speaker 03:
I had no notice that Schwartz would appear and claim to be the Cash and Family Attorney lawyer because that's not what the docket states.

[00:07:30] Speaker 03:
And as a normal person, I depend on the docket.

[00:07:36] Speaker 03:
Had I known I would have called witness and I could have rebutted that in person in the rebutted his represent false representations at the hearing.

[00:07:47] Speaker 03:
I did not know that, and I had asked for a delay for the hearing and was unable to attend.

[00:07:56] Speaker 03:
By consolidating the hearing, without clarifying authority or representation, the court denied me a fair notice and an opportunity to be heard.

[00:08:12] Speaker 03:
The remedy, I respectfully request

[00:08:16] Speaker 03:
reversal of the vexatious litigant orders, vacating the July 29th hearing findings, and remand for proceeding where counsel's authority is established on the record.

[00:08:31] Speaker 03:
I'm at seven minutes and 31 seconds, and I want you to know that life is short.

[00:08:38] Speaker 03:
My life is short.

[00:08:39] Speaker 03:
Your life is short.

[00:08:40] Speaker 03:
Your attention is short.

[00:08:42] Speaker 03:
And I just, we're all short.

[00:08:46] Speaker 03:
We don't need 3,000 pages attached to an exhibit as record excerpts.

[00:08:53] Speaker 03:
We need to stick one case at a time because God knows I can't handle more than one case at a time.

[00:09:00] Speaker 03:
Thank you.

[00:09:01] Speaker 03:
That's it.

[00:09:02] Speaker 03:
Save the rest of my time.

[00:09:03] Speaker 03:
Thank you.

[00:09:04] Speaker 02:
All right.

[00:09:04] Speaker 02:
Thank you very much, Mr. Hayden.

[00:09:07] Speaker 02:
We'll turn to you, Mr. Schwartz.

[00:09:11] Speaker 01:
Thank you, Your Honors.

[00:09:12] Speaker 01:
May it please the court, Joel Schwarz, on behalf of Appellee's William B. Cashin and Western Steel Inc.

[00:09:18] Speaker 01:
and Alabama Corporation.

[00:09:20] Speaker 01:
I've previously argued to at least two of the panel judges today in another prior appeal by Mr. Hayden.

[00:09:29] Speaker 01:
And so I know Your Honors are familiar with the background of this case.

[00:09:34] Speaker 01:
I would say between Mr. Hayden's brief and his arguments today, Your Honors have now seen a glimpse

[00:09:41] Speaker 01:
of what the Bankruptcy Court Judge Spraker dealt with for more than two years across four vexatious proceedings commenced by Mr. Hayden and what I have been dealing with as counsel to Mr. Cashin and to Western Steel Inc., the legitimate Alabama company, not the sham Nevada company that's a debtor in one of those four proceedings for about seven years now.

[00:10:05] Speaker 01:
And what my clients have been dealing with with regard to Mr. Hayden for over 15 years.

[00:10:11] Speaker 01:
Uh, and, uh, Mr. Mr. Hayden, uh, did make reference to a couple of his recent rogue filings in this case or in these consolidated cases.

[00:10:22] Speaker 01:
Um, I would like to briefly address, uh, Mr. Hayden's utterly false contention that I have at any time, uh, purported to be representing one of his sham trusts in particular, the cash and family trust, which does not exist.

[00:10:40] Speaker 01:
And that is one of the issues among many that is noted by Judge Spraker in his orders to show cause and in his 72-page memorandum decision that accompanied the vexatious litigant order.

[00:10:58] Speaker 01:
There were two other entities, fraudulent trusts that Mr. Hayden created more than 15 years ago,

[00:11:06] Speaker 01:
for the purposes of trying to commit fraudulent transfers of Mr. Cash's assets, those were dealt with in a final judgment in 2013 in Alabama.

[00:11:19] Speaker 01:
But I have never, and the record is quite clear, and Mr. Hayden himself admits, I've never filed any document on behalf of the Cash and Family Trust, and I've never purported to represent the Cash and Family Trust, which is a sham, non-existent trust.

[00:11:32] Speaker 01:
There is another rogue filing by Mr. Hayden that suggests that the appellees supplemental excerpts of the record should be stricken.

[00:11:41] Speaker 01:
I would just like to note that.

[00:11:45] Speaker 01:
Mr. Hayden initially attempted to commence this bankruptcy as if there was no appellees.

[00:11:52] Speaker 01:
And so, of course, there was never any consultation about what would be the appendices or the excerpts from the record in in connection with

[00:12:03] Speaker 01:
the Appellee's answering brief, we provided, among other things, the memorandum decision itself, which was absent from any of Mr. Hayden's filings.

[00:12:14] Speaker 01:
In Judge Breaker's 72-page memorandum decision, he extensively set forth factual findings that were supported by citations to the record.

[00:12:24] Speaker 01:
The supplemental excerpts to the record that Appellee's have presented the court are those

[00:12:29] Speaker 01:
are those documents in the record that Judge Breaker was citing to support his determination that Mr. Hayden was a vexatious litigant.

[00:12:40] Speaker 01:
So essentially what Mr. Hayden is telling you today and in his recent rogue filing is, I don't want the court to actually make any decision based upon the documents that Judge Breaker himself was relying upon in making his decision.

[00:12:54] Speaker 01:
I'm appealing a determination that I'm vexatious

[00:12:57] Speaker 01:
but I don't want this court to actually see why it is that Judge Breaker decided that I am vexatious.

[00:13:06] Speaker 01:
I note that Mr. Hayden did not spend any time today talking about the standard of review on appeal, nor did he talk about it in his briefs, but it is for abuse of discretion, and I would respectfully submit that there is nothing remotely approaching an abuse of discretion by Judge Breaker in this case.

[00:13:26] Speaker 01:
If anything,

[00:13:26] Speaker 01:
Judge Breaker repeatedly demonstrated judicial restraint.

[00:13:31] Speaker 01:
That is part of the reason why these proceedings went on as long as they did.

[00:13:35] Speaker 01:
And so I'm at a loss as to where in a 72 page memorandum decision that accompanied this vexatious litigant order, Judge Breaker in any way abused his discretion.

[00:13:53] Speaker 01:
Mr. Hayden,

[00:13:56] Speaker 01:
fundamentally misunderstands the difference between a party and a party in interest.

[00:14:02] Speaker 01:
This was gone over with Mr. Hayden in proceedings with Judge Spraker, and what you have here today is again an argument that doesn't understand that as judgment creditors of Mr. Hayden, specifically with respect to Alabama Western Steel, my client,

[00:14:26] Speaker 01:
that they are parties in interest to proceedings wherein Mr. Hayden, before the bankruptcy court, attempted to conflate his sham debtor company, Western Steel Inc.

[00:14:36] Speaker 01:
and Nevada Corporation, with my client, Alabama Western Steel.

[00:14:42] Speaker 01:
They were parties in interest.

[00:14:43] Speaker 01:
Judge Spraker extensively addressed this.

[00:14:45] Speaker 01:
It is talked about in his memorandum decision.

[00:14:49] Speaker 01:
And Mr. Hayden continues to either

[00:14:53] Speaker 01:
just disregard that because he doesn't understand it or because he doesn't like it, and so he just ignores it.

[00:14:58] Speaker 01:
But my clients were parties in interest.

[00:15:00] Speaker 01:
They were directly interested in multiple proceedings, one of which was an adversary within the Western Steel Bankruptcy where Mr. Hayden tried to argue that by my clients as his judgment creditors in Alabama trying to proceed against his assets,

[00:15:18] Speaker 01:
he was somehow violating the automatic stay in the Western Steel Bankruptcy.

[00:15:23] Speaker 01:
It is a bit rich that he would argue about standing considering he tried to commence an adversary proceeding in his personal capacity against his judgment creditors on behalf of the sham debtor, Western Steel Inc.

[00:15:37] Speaker 01:
When he had no such standing, that was part of an order to show cause issued by Judge Spraker.

[00:15:46] Speaker 01:
There is before this court,

[00:15:49] Speaker 01:
as was before the district court, a substantial record of vexatious litigation tactics and actions by Mr. Hayden across four bankruptcy proceedings.

[00:16:02] Speaker 01:
His individual bankruptcy is Chapter 13 wherein he falsely attested that he was a Nevada resident, filed that to stop a foreclosure sale from occurring in Alabama, and then dismissed that within two weeks

[00:16:16] Speaker 01:
and was sanctioned ultimately for filing that in bad faith for more than $75,000.

[00:16:21] Speaker 01:
Undeterred, he filed three more proceedings.

[00:16:25] Speaker 01:
And the district court has set forth, Judge Frager has set forth 37 pages worth of factual findings about what Mr. Hayden did across four proceedings.

[00:16:38] Speaker 01:
Lastly, I think Mr. Hayden wants to argue that there's been somehow a due process violation because he chose not to show up for the July 29th, 2024 evidentiary hearing.

[00:16:51] Speaker 01:
I would note, and this is in the record and we talk about it in our briefs, that there was a March 14th, 2024 scheduling conference that Mr. Hayden received notice of, and he did not appear for that.

[00:17:06] Speaker 01:
We were scheduled to appear in person before Judge Breaker in Las Vegas on July 11th, 2024.

[00:17:14] Speaker 01:
Mr. Hayden indicated that he would not be appearing in person for that, but he did appear telephonically.

[00:17:20] Speaker 01:
We had that hearing with Judge Breaker at that time.

[00:17:23] Speaker 01:
That is when we decided, collectively, we would have the evidentiary hearing on the vexatious litigants motions and the court's orders to show cause.

[00:17:33] Speaker 01:
on July 29th, 2024, in person in Reno.

[00:17:38] Speaker 01:
We were all present for that hearing.

[00:17:40] Speaker 01:
Mr. Hayden agreed and then decided on July 29th, 2024, he was not going to show up.

[00:17:47] Speaker 01:
That is not a due process violation.

[00:17:49] Speaker 01:
It is, as you will see from all of the previous litigation actions that Mr. Hayden has vexatiously commenced, a common practice by Mr. Hayden to

[00:18:01] Speaker 01:
file things, and then when it actually comes time to have the hearing on the merits, he doesn't show up.

[00:18:08] Speaker 01:
But that's not a due process violation by the district court in any way.

[00:18:13] Speaker 01:
I don't see that Mr. Hayden has in any way addressed the scope of the actual vexatious litigant order.

[00:18:21] Speaker 01:
That is an issue that he raised in his opening briefs.

[00:18:25] Speaker 01:
But I would respectfully submit that those are essentially standard vexatious litigant

[00:18:31] Speaker 01:
pre-litigation filing restrictions that were imposed by the court, they're not quite frankly as broad as what I had hoped.

[00:18:37] Speaker 01:
And what we've now seen in the district court since then is that Mr. Hayden has tried to skirt the vexatious litigant order by having his son, who attempted to appear today, file things and having his wife file things.

[00:18:50] Speaker 01:
We had asked that they be included within the scope of the vexatious litigant order and they were not.

[00:18:55] Speaker 01:
So the order was significantly more narrowly tailored than what we asked for.

[00:19:04] Speaker 01:
I don't think I have anything further unless Your Honors have questions for me.

[00:19:08] Speaker 01:
But I respectfully submit that this is just as frivolous of an appeal as all of the proceedings before the district court have been frivolous and vexatious.

[00:19:20] Speaker 02:
All right.

[00:19:20] Speaker 02:
Thank you.

[00:19:20] Speaker 02:
I don't have any questions.

[00:19:22] Speaker 02:
Judge Lafferty or Judge Gann?

[00:19:25] Speaker 01:
Thank you for your time, Your Honors.

[00:19:26] Speaker 02:
All right.

[00:19:26] Speaker 02:
Thank you, Mr. Schwartz.

[00:19:28] Speaker 02:
Mr. Hayden, you've got about seven and a half minutes left, or seven minutes approximately.

[00:19:35] Speaker 02:
Yeah.

[00:19:36] Speaker 02:
And you're, you're on mute again.

[00:19:39] Speaker 03:
Thank you, Mr. Schwartz.

[00:19:45] Speaker 03:
I believe he said he had never appeared for the fraudulent cash and family trust.

[00:19:54] Speaker 03:
At least that's what I thought he said.

[00:19:57] Speaker 03:
And I think he said correctly, the judge that the honorable

[00:20:05] Speaker 03:
Judge Spraker, a man of great learning, which I have never said he is not a very extremely intelligent person, extremely experienced, highly respected by his peers, honored among lawyers, and yet, Judge Spraker has been burdened with all these things thrown in his plate.

[00:20:36] Speaker 03:
Now, I am responding to what he said.

[00:20:39] Speaker 03:
He said he had never represented the Cashin Family Trust.

[00:20:43] Speaker 03:
But if you look in the appeal, numbered 1069, document 14-2, affidavit of Joel Schwartz, he says, I am the representative of the Cashin Family Trust.

[00:21:00] Speaker 03:
The three magic words.

[00:21:02] Speaker 03:
That's exactly right.

[00:21:04] Speaker 03:
And so, yes, he is claimed to be a representative of the Cash and Family Trust at that hearing.

[00:21:11] Speaker 03:
He did take witness testimony.

[00:21:14] Speaker 03:
I was not informed of the witness that would appear.

[00:21:18] Speaker 03:
And in fact, I was told that I could not call witnesses.

[00:21:21] Speaker 03:
Now, ordinarily, Judge Spraker would never get involved in stuff like that.

[00:21:27] Speaker 03:
But Judge Spraker, like all judges, has the right to expect the highest level of

[00:21:34] Speaker 03:
honor and dignity among the lawyers that come before them.

[00:21:40] Speaker 03:
That's your right as attorneys.

[00:21:42] Speaker 03:
I may be totally stupid when it comes to the law or the facts or legal tactics, but I do know words.

[00:21:54] Speaker 03:
One word is inherent, inherent authority.

[00:21:58] Speaker 03:
And one of the things about inherent authority is what's in your court.

[00:22:03] Speaker 03:
You have so much on your plate that your attention is best devoted to what's in your court, not what's outside your court.

[00:22:11] Speaker 03:
We've heard Joel today talking about other cases, other courts, Alabama courts, state courts, all these things that are grounds for the use of inherent authority.

[00:22:28] Speaker 03:
But hey, do we really wanna exercise that power?

[00:22:33] Speaker 03:
if we don't have a duty.

[00:22:34] Speaker 03:
And I would say, as human beings, as responsible, honored members of the court, you have no duty to go outside your court and listen to the trash that happened in other courts.

[00:22:49] Speaker 03:
And if I did trash crap, pardon the expression, garbage, if I did garbage in other courts, that's for those courts to take care of that garbage in their courts.

[00:23:01] Speaker 03:
Other courts don't need, district courts and state courts don't need you to be bothered by that garbage.

[00:23:09] Speaker 03:
And if you don't have a duty to take care of that garbage, then you don't have the responsibility to take care of that garbage.

[00:23:16] Speaker 03:
And it really is an abuse of discretion for a judge in Nevada district court to take care of my garbage

[00:23:25] Speaker 03:
in other courts.

[00:23:27] Speaker 03:
So even assuming that I am the most garbage, I'm the biggest garbage man in world history, garbaging up every other court in the entire world.

[00:23:39] Speaker 03:
You only need to worry about the garbage I bring to your court.

[00:23:43] Speaker 03:
That's all you need to be burdened with.

[00:23:45] Speaker 03:
Don't saturate your mind with any garbage I brought to any other court or any other state proceedings.

[00:23:51] Speaker 03:
And as for my family, if they brought garbage someplace else, let whoever they take out care of the garbage.

[00:23:58] Speaker 03:
Your life is too short.

[00:23:59] Speaker 03:
There is no excuse for this judge to be burdened with 72 pages because garbage is dumped on him.

[00:24:07] Speaker 03:
because 3,000 pages of documents that Joe Schwartz knew were not a part of the record on appeal.

[00:24:16] Speaker 03:
Those should have never been in the record on appeal of this case because they're not part of the record of appeal.

[00:24:22] Speaker 03:
I am stupid.

[00:24:24] Speaker 03:
I am very stupid.

[00:24:26] Speaker 03:
But I know record of appeal means it has to be excerpts of the record to be in the excerpts of the record appeal.

[00:24:34] Speaker 03:
He, at the 2085 page, they didn't come from these cases.

[00:24:39] Speaker 03:
So if you had a case at a time, they were not inserted in both cases simultaneously.

[00:24:44] Speaker 03:
They were a case at a time, and they did not come from the record on appeal.

[00:24:47] Speaker 03:
He did not have the authority as a non-party to amend

[00:24:51] Speaker 03:
the record.

[00:24:51] Speaker 03:
He did not take the effort to amend the original record on appeal.

[00:24:56] Speaker 03:
So they're not part of the case.

[00:24:58] Speaker 03:
Once those go out, even in this case, what he wanted to do was same tactics he used on Spreaker.

[00:25:04] Speaker 03:
throw a bunch of garbage against the wall, and then you get overwhelmed and say, hey, I'm vexed even now.

[00:25:10] Speaker 03:
Yes, I'm vexed even trying to read the excerpts of the record.

[00:25:14] Speaker 03:
It costs me like 15 bucks just to download it.

[00:25:18] Speaker 03:
It's so stinkin' large.

[00:25:20] Speaker 03:
I don't want that crap.

[00:25:21] Speaker 03:
You don't need that.

[00:25:23] Speaker 03:
Excuse me.

[00:25:23] Speaker 03:
You don't need that.

[00:25:25] Speaker 03:
I don't need that.

[00:25:26] Speaker 03:
Spraker doesn't need that.

[00:25:28] Speaker 03:
Your time is too valuable.

[00:25:30] Speaker 03:
Mine is too.

[00:25:32] Speaker 03:
asked for, hey, did he represent the Cash and Family Trust?

[00:25:36] Speaker 03:
He hasn't denied that it was a combined hearing.

[00:25:39] Speaker 03:
He's calling witnesses.

[00:25:40] Speaker 03:
He's biasing the judge.

[00:25:41] Speaker 03:
He's overloading it.

[00:25:43] Speaker 03:
And in the end, he files, many of the documents that he files are responses to his.

[00:25:50] Speaker 03:
He's much more garbage, he's as big a garbage man as I am.

[00:25:55] Speaker 03:
but he's getting paid 500 bucks an hour, and I'm not.

[00:25:59] Speaker 03:
I went through bankruptcy.

[00:26:03] Speaker 03:
So that's the way it is, but we don't need this.

[00:26:07] Speaker 03:
And million dollar clients can afford Schwartz, but that's not what our courts need.

[00:26:12] Speaker 03:
What our courts need is to go by the briefs, and I refer you all to my briefs, throw out the extra, and let's keep it life simple.

[00:26:19] Speaker 03:
Let's keep the relief which I asked for.

[00:26:22] Speaker 03:
Thank you.

[00:26:25] Speaker 02:
All right.

[00:26:25] Speaker 02:
Thank you.

[00:26:25] Speaker 02:
Thank you, Mr. Hayden.

[00:26:27] Speaker 02:
Thank you, Mr. Schwartz, for your arguments.

[00:26:28] Speaker 02:
This matter will be submitted.

[00:26:30] Speaker 02:
We'll issue a decision promptly.

[00:26:33] Speaker 02:
Thank you.

[00:26:34] Speaker 01:
Thank you, Your Honor.