[00:00:00] Speaker 01:
judges it's an honor to meet you how much time would you like to reserve for rebuttal um it depends on how much time my speech takes i haven't had a chance to time it out um probably at least five minutes five minutes okay go ahead please okay my name is jacy floris and i represent appellant uh tangeela islam who i'll call defendant because it's easier for me or she um i'd like to think of myself as the best

[00:00:26] Speaker 01:
lawyer or bankrupt person can buy.

[00:00:28] Speaker 01:
Can you still hear me?

[00:00:29] Speaker 01:
Oh my goodness.

[00:00:30] Speaker 02:
Yes, we can hear you.

[00:00:32] Speaker 01:
This is what I would call a no half no fury like a creditor scorned case because prior to this appeal, plaintiff has spent upward of $400,000 to chase $253,000 and remaining principal in this matter.

[00:00:46] Speaker 01:
This matter involves a simple breach of contract and nothing more.

[00:00:50] Speaker 01:
plain vanilla breach of contract and no worse than negligence, but not fraud or anything non-dischargeable in a bankruptcy.

[00:00:57] Speaker 01:
In this matter, defendant personally guaranteed a promissory note for about $506,000 for her wholly owned company, Tiger Trade Services, which I'll call Tiger Trade.

[00:01:06] Speaker 02:
Let me interrupt you for a second and kind of cut to what I think is the central question on this part of your case.

[00:01:13] Speaker 02:
The court held a trial and found basically that your client made a promise that she never intended to keep.

[00:01:20] Speaker 02:
And that's a finding of fact that we review for clear error.

[00:01:23] Speaker 02:
Isn't that true about the standard review?

[00:01:29] Speaker 01:
Whatever I wrote in my appellate brief, which was a while ago,

[00:01:35] Speaker 01:
would be my opinion.

[00:01:38] Speaker 02:
What I'm saying is you have a pretty high hurdle to get over to convince us that that finding about your client's intention was wrong.

[00:01:47] Speaker 02:
So please focus on that part of the case.

[00:01:51] Speaker 01:
Well, he also found that she intended to repay the note.

[00:01:57] Speaker 01:
And yes, I think there was clear error because he

[00:02:04] Speaker 01:
made a dispositive holding that certain goods were worthless.

[00:02:08] Speaker 01:
And that was dispositive.

[00:02:10] Speaker 01:
And then he didn't allow expert rebuttal testimony to show that they weren't worthless.

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And these same goods that were used to offer in lieu of monetary payment were still being dealt with by the Mexican buyers, we were calling them.

[00:02:26] Speaker 01:
I don't know if you're following me at all.

[00:02:27] Speaker 01:
Hopefully you are.

[00:02:30] Speaker 01:
Eight months later, they were still dealing with it.

[00:02:33] Speaker 01:
So it's a clear error to find that these goods were worthless.

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I think it was a clear error, and the expert witness would have rebutted that.

[00:02:43] Speaker 03:
Is that the issue, though?

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I mean, whether the goods are worthless, does that really matter?

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The question was, was there a decision that, you know, dealing with the other goods, that they wouldn't be shipped to Mexico until payment was made or something?

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That's where I think the court found

[00:03:01] Speaker 03:
that there was an intent to fraud.

[00:03:05] Speaker 01:
Right.

[00:03:05] Speaker 01:
But the facts show that she did ship them to Mexico.

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And she never did, quote unquote, release the goods to the buyers.

[00:03:16] Speaker 01:
So the court held that she intended to release the goods to the buyers, which she never did.

[00:03:21] Speaker 00:
So you're challenging his finding, which is based on the credibility of the witness testimony.

[00:03:33] Speaker 01:
I think we had documentary evidence to support that she did not release the goods to the buyers.

[00:03:39] Speaker 01:
We had, the process was that she would release the goods to the customs broker and then the buyers have time to process the merchandise by removing foreign language labels from the tags, which is what she testified to.

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And that then the customs broker then would arrange for export to Mexico.

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And so the facts show that she actually did not deliberately release goods to anybody.

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And that she didn't intend to do so at the outset.

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She intended to repay the note, which is the other, of course, other.

[00:04:21] Speaker 00:
But those are not necessary things that go together.

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She can have intended to pay the note, correct, but she

[00:04:31] Speaker 00:
You know, if the trial court's ruling is correct, she may have intended to pay the note, but she didn't intend to fulfill the agreement and hold on to the collateral until she received the money.

[00:04:43] Speaker 00:
Those are two different things, are they not?

[00:04:47] Speaker 01:
I don't think so, because repaying the note would mean getting payment from the clients or from the buyers.

[00:05:01] Speaker 01:
I don't think they're different.

[00:05:07] Speaker 01:
All right.

[00:05:07] Speaker 01:
Thank you.

[00:05:13] Speaker 02:
Okay.

[00:05:13] Speaker 02:
Would you like to reserve the rest of your time or do you have more you want to say at this point?

[00:05:18] Speaker 01:
Well, plaintiff makes a big deal about them taking goods from the warehouse, the buyers taking goods from the warehouse without permission and her not reporting it.

[00:05:30] Speaker 01:
The plaintiff was the one in the driver's seat here.

[00:05:36] Speaker 01:
My argument is the plaintiff had nothing to do with the deal.

[00:05:41] Speaker 01:
He was writing a promissory note, right?

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He didn't get involved in the deal until later on.

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So all of this stuff about she had to have his permission to do anything is silly.

[00:05:57] Speaker 00:
Wasn't that written down in the security agreement?

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It was a condition, was it not?

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That's not silly, is it?

[00:06:04] Speaker 01:
The trial court incorrectly held that.

[00:06:07] Speaker 01:
There was nothing in the promissory note that indicated that she would have to receive his permission.

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He was hands off.

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This was just a note to loan her money.

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She was to do everything.

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It wasn't material.

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They had to fabricate a bunch of material factors in order to

[00:06:24] Speaker 01:
do the adversary proceeding as discussed in my reply to their opening brief.

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So what they what the plaintiff was claiming was material didn't really become material until the adversary proceeding.

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Okay, you want to reserve the rest of your time?

[00:06:47] Speaker 01:
Yes.

[00:06:48] Speaker 02:
Okay, very good.

[00:06:49] Speaker 02:
Thank you.

[00:06:50] Speaker 02:
Mr. Knox, please go ahead.

[00:06:53] Speaker 04:
Your Honor, thank you very much.

[00:06:55] Speaker 04:
Each of you has asked the precisely relevant questions to this matter, starting with the actual standard by which this is reviewed.

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It is in fact clear error is the standard and obviously plaintiff cannot meet the standard of clear error.

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She's effectively hoping that this court will retry the case and that's not the appellate court's role to retry the case.

[00:07:17] Speaker 04:
As Your Honor correctly observed, the trial court below made its determination based on the credibility and the feasibility of the appellant story, which the appellant story just was not credible.

[00:07:31] Speaker 04:
The dispute, as you've gathered, is a fraud case.

[00:07:33] Speaker 04:
Her debt was deemed non-dischargeable as a result of that fraud.

[00:07:36] Speaker 04:
It sounds like Your Honors have a good grip on the actual facts of the case, our client having provided financing for particular goods and those goods constituting his collateral.

[00:07:47] Speaker 04:
All of the evidence in the record establishes that

[00:07:52] Speaker 04:
The appellant, in fact, voluntarily released those goods, voluntarily released those collateral.

[00:07:58] Speaker 04:
You heard Ms.

[00:07:59] Speaker 04:
Flores say just now that she thinks that there's documentary evidence in the record that showed that the appellant did not release the goods.

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She's wrong.

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She didn't cite to any now and she couldn't cite to any in the trial court below.

[00:08:12] Speaker 04:
To the contrary, the only documentary evidence in the record, and it's dispositive, and it's upon which the trial court relied, were the communications that the appellant sent nearly immediately after executing the deal with our client, where she in fact instructed that the documentation that would have been required for the warehouse to release the goods to the buyers

[00:08:36] Speaker 04:
that that documentation be provided such that the goods could be released.

[00:08:41] Speaker 04:
The documentation that's in our supplemental excerpts of record, I believe page is 21 through 23 as correspondence that was in September and October of 2017.

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That's what the trial court was referencing when it said that there are emails that quote unquote the lie plaintiff story that she didn't authorize the goods release.

[00:09:03] Speaker 04:
She was hoping that the matter would work out.

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She was attempting to rob Peter to pay Paul and hoped that it would work out in the end.

[00:09:13] Speaker 04:
She hoped that she would ultimately be able to pay Peter.

[00:09:18] Speaker 04:
She ultimately was not.

[00:09:19] Speaker 04:
It didn't work out the way that she hoped it would, but the fact was that she made the misrepresentation at the outset of the party's transaction as the trial court correctly found.

[00:09:29] Speaker 04:
Your honor asked a correct question and it's fascinating and somewhat jarring to hear Council's quite candidly misrepresentation of the docket.

[00:09:41] Speaker 04:
She claims both in her brief and even in the oral argument today, I'll read you from your brief.

[00:09:45] Speaker 04:
She said that the promissory note, quote, contained no promise the debtor agreed to obtain creditors consent and writing before releasing the goods, nor the tiger trade that's debtors company would not release the goods until after it was paid for the collateral.

[00:10:00] Speaker 04:
That's an appellate's opening brief, page eight.

[00:10:04] Speaker 04:
As your honor asked, doesn't the deal explicitly say that?

[00:10:07] Speaker 04:
Short answer is yes.

[00:10:09] Speaker 04:
The deal explicitly says that.

[00:10:10] Speaker 04:
Paragraph three of the promissory note provides, quote, until payment in full under the note, company will not, without lender's written consent, exchange, lease, lend, use, sell, or dispose of the collateral or the company's rights therein.

[00:10:26] Speaker 04:
She was prohibited from releasing the goods.

[00:10:30] Speaker 04:
There could not be a more clear written indication that she was prohibited from releasing the goods.

[00:10:35] Speaker 04:
She released the goods.

[00:10:36] Speaker 02:
I'd like to jump you ahead a little bit and ask you about the question of interest.

[00:10:42] Speaker 02:
What confuses me about this case is we start off with a judgment from the district court basically liquidating the amount of money owed under this note

[00:10:52] Speaker 02:
that bears interest at the rate applicable to that judgment, which I think was something like 1.7, 1.8 percent, somewhere in that vicinity.

[00:11:01] Speaker 02:
But then the bankruptcy court a few years later entered its own judgment on the same debt for the same amount minus payments at a higher rate.

[00:11:12] Speaker 02:
I think it was 5.8 percent as prejudgment interest.

[00:11:16] Speaker 02:
And I'm confused by the fact that we have post-judgment interest and pre-judgment interest running on the same obligation over the same time period at two different rates.

[00:11:26] Speaker 02:
Can you help me clear that up?

[00:11:29] Speaker 04:
The interest rate of pre-judgment interest was awarded on the underlying judgment.

[00:11:38] Speaker 04:
The underlined judgment being the judgment from the district court.

[00:11:41] Speaker 04:
And the applicable rate for the judgment as it was entered in the bankruptcy court, that rate does adjust pursuant to statute based on, and I'm pulling up the language right now.

[00:11:53] Speaker 02:
No, I'm aware of that.

[00:11:54] Speaker 02:
It's more of a practical problem of entering prejudgment interest on an obligation that's already bearing interest at a different rate.

[00:12:04] Speaker 02:
See what I'm saying?

[00:12:06] Speaker 02:
Do we have the district court judgments bearing interest at 1.8%, then the bankruptcy court goes sort of backwards and rules that accrued interest at 5.8% before the bankruptcy court's judgment was entered?

[00:12:21] Speaker 04:
Well, the bankruptcy court's judgment was based on the interest starting to accrue from the entry of the district court's judgment.

[00:12:31] Speaker 04:
the prejudgment interest that the district court would have approved would have been up to that point, and then the interest thereafter would have been from that date and time from the district court's judgment.

[00:12:42] Speaker 02:
I'm actually asking about the post-judgment interest on the district court's judgment, because that judgment bore interest post-judgment at the statutory rate, which then was 1.8 percent, give or take.

[00:12:55] Speaker 02:
But then the bankruptcy court says, no, it's actually 5.8 percent.

[00:12:59] Speaker 02:
I'm not sure how

[00:13:01] Speaker 04:
the bankruptcy court justified that change of the interest rate during the same period between the entry of the district court judgment and the entry of the bankruptcy court judgment the prejudgment interest and i can see where there could be uh... a bit of a conflict between uh... prejudgment being the bankruptcy court and post-judgment being the district court uh... we would argue that the district court i'm sorry that the bankruptcy courts

[00:13:28] Speaker 04:
the bankruptcy court's determination on that based on the time that occurred in between those two dates is the operative amount.

[00:13:37] Speaker 04:
It obviously does present a bit of a complex situation when you are dealing with two judgment.

[00:13:43] Speaker 04:
But the short answer is that the bankruptcy court being the later judgment, that determination of interest in that calculation appropriately trumps the preceding calculation.

[00:13:59] Speaker 02:
All right, anything else you'd like to add?

[00:14:07] Speaker 02:
I kind of jumped you out of sequence, I'm sorry.

[00:14:08] Speaker 02:
But I wanted to make sure I got my question in there.

[00:14:12] Speaker 04:
OK, that's fair.

[00:14:13] Speaker 04:
And you did.

[00:14:14] Speaker 04:
And I think that where I left off was discussing the fact that the

[00:14:20] Speaker 04:
Appellant of clearly intentionally authorized the release of the goods despite the fact that she's arguing that she did not do that She clearly was prohibited from doing so under the plain language of the agreement despite the fact that she somehow Arguing that that was not in fact the plain language of the agreement

[00:14:38] Speaker 04:
Uh, the court focused and there was a good amount of discussion in the district court regarding bills of lading and the telex release, which is the documentation that was necessary for, uh, affecting the release of the goods.

[00:14:53] Speaker 04:
Uh, that was one of the factual disputes.

[00:14:55] Speaker 04:
Uh, as the, as the briefs discuss, uh, those documents authorize the goods release.

[00:15:01] Speaker 04:
Appellant again argues, and this speaks to her credibility and frankly, her understanding of the case.

[00:15:07] Speaker 04:
that the requirement to turn over to plaintiff the bills of lading was quote was never a part of the final agreement because plaintiff did not request it to be and again much like with the other provision that we were just talking about the contract unambiguously required the appellant to turn over the bills of lading the contract unequivocally says the container numbers and the bills of lading will be provided to lender upon shipping

[00:15:32] Speaker 04:
Yet she disputes the fact that she had this obligation.

[00:15:35] Speaker 04:
This is the equivalent of lying about the weather.

[00:15:37] Speaker 04:
You can confirm by looking at the document that she had this obligation to do so.

[00:15:42] Speaker 04:
Throughout the trial court proceedings and here, she attempts to blame the victim for the fact that he was essentially robbed.

[00:15:51] Speaker 04:
She said the creditor never asked for the bills of lading, as if that somehow absolves her of her obligation to provide the bills of lading.

[00:15:59] Speaker 04:
It does not.

[00:16:00] Speaker 04:
Instead of providing the bills of lading to the plaintiff, she provided the bills of lading

[00:16:06] Speaker 04:
and the appropriate documentation with respect to the TELUS release, she provided all of that to the warehouse and to the buyers, authorizing the warehouse to release the goods to the buyers.

[00:16:17] Speaker 04:
And that clearly ran afoul of the express plain language of the contract.

[00:16:22] Speaker 04:
She's now arguing that that plain language of the contract somehow was quote unquote not material.

[00:16:29] Speaker 04:
holding on to the collateral that was plaintiff's ability to get paid is potentially the most material aspect of the entire transaction.

[00:16:39] Speaker 04:
So it's difficult to come up with a response for how far off the argument could be that this is somehow not a material term of the agreement.

[00:16:47] Speaker 04:
It was.

[00:16:51] Speaker 04:
She denies having instructed the release of the goods, the sequence of events that I just described, where she did authorize that.

[00:16:59] Speaker 04:
The court came to a correct conclusion, reading the evidence that was in front of it.

[00:17:05] Speaker 04:
And that conclusion was not clear error, as would be required for this court to actually overturn that ruling.

[00:17:13] Speaker 04:
The ruling was correct, and the ruling was a matter of common sense.

[00:17:16] Speaker 04:
Even upon her own cross-examination with respect to the documentation that would have been required for the release of the goods, appellant said of the warehouse, quote, they had the documentation.

[00:17:28] Speaker 04:
They just needed the authorization from me, unquote.

[00:17:31] Speaker 04:
Yet she continues to deny that she authorized the release of the goods.

[00:17:35] Speaker 04:
She did not protest the release of the goods.

[00:17:39] Speaker 04:
As she notes, the trial court makes a big deal out of the fact that she didn't protest the release of the goods.

[00:17:44] Speaker 04:
She didn't report the supposed unauthorized release of the goods to the police.

[00:17:50] Speaker 04:
She didn't report it to the warehouse.

[00:17:52] Speaker 04:
She didn't report it to her insurer.

[00:17:53] Speaker 04:
She didn't report it to customs.

[00:17:55] Speaker 04:
She didn't tell anybody.

[00:17:57] Speaker 04:
because she authorized release.

[00:17:59] Speaker 04:
There was nothing to tell.

[00:18:00] Speaker 04:
Now she's saying that she didn't and it's clearly a fabrication.

[00:18:04] Speaker 04:
The trial court clearly didn't believe it.

[00:18:06] Speaker 04:
More tellingly, she doesn't point to any evidence of her having made any protests or complaints.

[00:18:11] Speaker 04:
She doesn't point to any evidence of her having demanded payment for the goods that were supposedly robbed from her.

[00:18:17] Speaker 04:
The goods weren't robbed from her.

[00:18:19] Speaker 04:
The goods weren't released without authorization.

[00:18:21] Speaker 04:
She authorized the goods release.

[00:18:24] Speaker 04:
And again, she blames the victim for that, arguing that she didn't tell the authorities or didn't complain to the supposed culprits or didn't tell her insurance carrier because the plaintiff didn't tell her to, as if it was the plaintiff's obligation to cause all these things to happen when it was only his role, no matter, to receive the money that he had lended.

[00:18:49] Speaker 04:
So this is a clear indication on all fronts, all the evidence that's in front of us that, A, the appellant authorized the release of the goods and that she had the intent to do that from nearly the outset of the party's transaction, which was sufficient to establish her lack of intent to perform under the party's agreement.

[00:19:10] Speaker 04:
She knew that trouble was brewing, was the trial court's description of it, and the evidence in the record clearly establishes that trouble was brewing because the Mexico-based buyers were having trouble moving the Miss 60 goods.

[00:19:23] Speaker 04:
The Miss 60 goods that she tried to dumb off on plaintiff, and plaintiff had no obligation to take those goods.

[00:19:30] Speaker 04:
Those goods weren't a part of the deal.

[00:19:32] Speaker 04:
And contrary to what she said a moment ago in her oral argument, and she said in her papers, and this is a key point.

[00:19:40] Speaker 04:
The expert testimony that she sought to offer on the issue of the value of the Miss 60 goods absolutely was not relevant.

[00:19:48] Speaker 04:
And the value of the Miss 60 goods, despite what she said just now, absolutely was not dispositive of anything that the trial court ruled on.

[00:19:58] Speaker 04:
The trial court specifically said that the value of those goods is neither here nor there

[00:20:04] Speaker 04:
because the plaintiff did not have an obligation to take those goods.

[00:20:23] Speaker 04:
is referring to as rebuttal expert testimony, but plaintiff didn't offer any expert testimony on this issue.

[00:20:29] Speaker 04:
So there was nothing to rebut because this was not a relevant issue and it certainly was not dispositive of the trial court's ruling.

[00:20:37] Speaker 04:
With that, I see that I only have a minute left.

[00:20:38] Speaker 04:
I'd like to reserve that minute.

[00:20:41] Speaker 02:
Any questions for Mr. Knox?

[00:20:43] Speaker 02:
No.

[00:20:43] Speaker 02:
Okay.

[00:20:43] Speaker 02:
Thank you very much.

[00:20:45] Speaker 02:
Ms.

[00:20:45] Speaker 02:
Flores, back to you for rebuttal.

[00:20:48] Speaker 01:
But Your Honor, the testimony that those goods were worthless was dispositive and ruling.

[00:20:54] Speaker 01:
because that's how she knew trouble was brewing, that her Mexican buyer partners were having trouble moving the goods.

[00:21:03] Speaker 01:
And they keep talking about robbing Peter to pay Paul.

[00:21:09] Speaker 01:
The tiger trade co-owned goods with the Mexican buyers.

[00:21:14] Speaker 01:
So about a third of those goods that were valued at $3 million, tiger trade co-owned.

[00:21:20] Speaker 01:
So why would you go to the hassle and effort

[00:21:23] Speaker 01:
coming up with a whole new shipment when they could just have given her their portion of the goods to begin with.

[00:21:31] Speaker 01:
There was a global release of the goods just because a Mexican, they can't sell high-end denim jeans worth $110 a piece in Mexico doesn't mean that she couldn't have sold them around the world.

[00:21:44] Speaker 01:
So there was no robbing of Peter to pay Paul.

[00:21:47] Speaker 01:
She also used the money to pay for the goods and ship the goods to the United States.

[00:21:53] Speaker 01:
Now, let's just assume, for argument's sake, that she went ahead and released the goods that earlier on.

[00:22:01] Speaker 01:
That doesn't mean that at the time she made the contract, she intended to defraud plaintiff.

[00:22:07] Speaker 01:
Intent to defraud has to be at the time you make the contract.

[00:22:11] Speaker 01:
It can't be later on.

[00:22:12] Speaker 01:
And she did what plaintiff asked her to do.

[00:22:17] Speaker 01:
He was an expert in the off-price industry.

[00:22:21] Speaker 01:
Court would not allow rebuttal testimony that it's standard practice in the off-price industry to offer goods, merchandise, in lieu of monetary payments.

[00:22:32] Speaker 01:
And that's what happened.

[00:22:33] Speaker 01:
And she did what he told her to do.

[00:22:35] Speaker 01:
He said, as of December, I believe, he said it was still early in the deal.

[00:22:40] Speaker 01:
And she had no reason to visit the warehouse.

[00:22:43] Speaker 01:
She had an ongoing successful relationship with them, and I think

[00:22:49] Speaker 01:
She had no reason to visit the warehouse or inspect anything.

[00:22:52] Speaker 01:
So she did not know that they had taken it.

[00:22:57] Speaker 01:
And the plaintiff did not instruct her to report this to anybody.

[00:23:01] Speaker 01:
He went ahead, and with the blessing of his own attorney, which speaks to the fact that paying in merchandise is standard practice, with the blessing of his own attorney, he tried to move the goods for quite a while.

[00:23:14] Speaker 01:
And as late as April of the following year, some seven, eight months later,

[00:23:20] Speaker 01:
the Mexican buyers were still talking about the goods.

[00:23:23] Speaker 01:
So it's illogical that the court found that the buyers were really upset that early on when in April they were still talking about it in an email that was in one of my exhibits.

[00:23:39] Speaker 01:
I can't access my computer too easily here.

[00:23:42] Speaker 01:
But I have the email where she's asking, I think it's April of 2018 to Benyamiga, one of the Mexican buyers,

[00:23:49] Speaker 01:
you know, what's this worth now?

[00:23:51] Speaker 01:
And he said 6.25 a piece.

[00:23:53] Speaker 01:
So that's not worthless.

[00:23:54] Speaker 01:
So again, the judge is finding the fact that goods were worthless is dispositive and knowing that quote unquote trouble was brewing.

[00:24:06] Speaker 01:
So it's just to me, even if she deliberately released the goods, that's not really speak to fraud and the inducement.

[00:24:13] Speaker 01:
This was a contract, nothing more.

[00:24:16] Speaker 01:
And at worst she breached the contract.

[00:24:20] Speaker 01:
I reserve remaining time to rebut anything else that Mr. Knox might say.

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

[00:24:25] Speaker 02:
Well, that's the end of the argument.

[00:24:26] Speaker 02:
So there'll be no more rebuttal.

[00:24:29] Speaker 02:
Any questions from the panel?

[00:24:31] Speaker 02:
No.

[00:24:32] Speaker 02:
Okay.

[00:24:32] Speaker 02:
Thank you very much.

[00:24:33] Speaker 02:
The matter is submitted and we'll be issuing a written decision.

[00:24:37] Speaker 02:
Thank you.

[00:24:37] Speaker 01:
Thank you, Your Honor.

[00:24:38] Speaker 01:
Thank you, Your Honor.