[00:00:06] Speaker 02:
Morning.

[00:00:08] Speaker 04:
So this is the latest.

[00:00:09] Speaker 02:
Do you want to reserve any time?

[00:00:11] Speaker 04:
I'd like to reserve five minutes.

[00:00:15] Speaker 04:
Thank you.

[00:00:16] Speaker 04:
This is the latest chapter in a long-running history of litigation involving Bernd Schaeffer's and his LLC on April 15th of this year.

[00:00:36] Speaker 04:
the Superior Court entered a judgment that had been previously imposed on Mr. Shaffer's against his LLC, in which he is a 50% member along with his ex-wife.

[00:00:53] Speaker 04:
And that was after an appellate decision that had reversed the previous ruling imposing the judgment on the LLC.

[00:01:05] Speaker 04:
So upon rehearing, the Superior Court reimposed the judgment on the LLC.

[00:01:16] Speaker 04:
And at the same time, a tax option was pending against the LLC's property because the LLC owns the property that's at issue here today.

[00:01:32] Speaker 04:
So we filed a Chapter 11 on May 12th.

[00:01:38] Speaker 04:
And we were converted to Chapter 7 on day 70.

[00:01:46] Speaker 04:
And the OSC was set on day 58.

[00:01:51] Speaker 04:
I'm here today because I object to having my cases converted to Chapter 7.

[00:02:00] Speaker 04:
When we have closed out all the bank accounts, we have filed operating reports, we have filed all the schedules, we have obtained insurance, and

[00:02:16] Speaker 04:
We never got the opportunity to, and our plan was to sell the property after seven or eight years of litigating over the property.

[00:02:26] Speaker 04:
We had intended to sell the property for $3.5 million.

[00:02:31] Speaker 04:
And we had scheduled a motion to do that prior to the date that the case was converted.

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We also had a motion on to approve the employment of two realtors.

[00:02:46] Speaker 04:
And that motion was scheduled for September the 9th.

[00:02:51] Speaker 04:
And the bankruptcy court converted the case anyway because I didn't file a motion or a response within seven days.

[00:02:58] Speaker 04:
I object to that.

[00:02:59] Speaker 04:
I didn't have time to file a response within seven days.

[00:03:03] Speaker 04:
I had to find realtors, which I did ultimately find, and I had to determine what the sale price was, which I ultimately did.

[00:03:13] Speaker 04:
We're now being told for the court's information

[00:03:16] Speaker 04:
that the chapter 7 trustee is going to sell the property for 2.5 million dollars.

[00:03:20] Speaker 04:
I haven't seen that in writing.

[00:03:22] Speaker 04:
That's just what I'm being told.

[00:03:24] Speaker 04:
We had a plan to sell it for 3.5.

[00:03:28] Speaker 04:
So, at the time of the hearing on the OSC, it sounded to me like the bankruptcy court was intending to dismiss the case based on his comments and then he changed his mind

[00:03:44] Speaker 04:
after being told by Mr. Bell to go ahead and dismiss the case, if you saw that, because he thought we were going to refile another bankruptcy, which is a reflection of the smearing that has been given to my client based on Mr. Bell's representation of this judgment creditor.

[00:04:04] Speaker 04:
In the prior chapter 11 that was followed by Mr. Schaeffer's, which again was converted,

[00:04:10] Speaker 04:
He had objected to the appointment of a Chapter 7 trustee on the ground that the Chapter 7 trustee would have nothing to do.

[00:04:18] Speaker 04:
He was right about that.

[00:04:20] Speaker 04:
The property that was owned by the LLC couldn't be sold at the request of Mr. Bell because the debtor didn't own the property.

[00:04:29] Speaker 04:
It was a fundamental proposition which this court, I believe, made clear.

[00:04:34] Speaker 04:
It was this court that straightened out that whole record.

[00:04:37] Speaker 04:
So months and months and...

[00:04:39] Speaker 04:
Hours and hours of time and attorney's fees were wasted trying to sell the property that the debtor didn't own.

[00:04:47] Speaker 04:
Somehow, Mr. Schaffer was being smeared with that history, even in this case.

[00:05:03] Speaker 04:
If you file a case and you've complied with the rules,

[00:05:06] Speaker 04:
And none of the grounds in 11-12 apply, which they don't, as a basis for converting the case.

[00:05:14] Speaker 04:
Why is my case being converted?

[00:05:16] Speaker 02:
Well, isn't there a couple issues?

[00:05:19] Speaker 02:
First of all, you were seeking to be appointed as counsel for the debtor in possession, but you also represented the 50% shareholder.

[00:05:28] Speaker 02:
And in fact, you filed a proof of claim on behalf of that 50% shareholder.

[00:05:32] Speaker 02:
That means you're not disinterested.

[00:05:34] Speaker 02:
You couldn't have been appointed to be a counsel for the debtor in possession under the bankruptcy code.

[00:05:41] Speaker 04:
Well, we had a plan to sell the property, so there was no real need to not to appoint me.

[00:05:47] Speaker 02:
Well, but it's an LLC.

[00:05:49] Speaker 02:
The debtor's an LLC.

[00:05:50] Speaker 02:
The debtor has to be represented by counsel.

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The debtor can't represent itself.

[00:05:54] Speaker 02:
So there needs to be counsel appointed for the debtor in possession in this bankruptcy case.

[00:06:00] Speaker 02:
But you wouldn't have been able to be, and there was no other employment of an attorney, is my understanding of the record.

[00:06:08] Speaker 04:
I happen to know this client.

[00:06:09] Speaker 04:
I happen to know the history of this litigation for eight years.

[00:06:13] Speaker 04:
It would take thousands of dollars to find an attorney to step in and represent this debtor, especially when the LLC was added under a theory of reverse veil piercing in April of this year.

[00:06:26] Speaker 04:
That meant there was no longer a distinction between the two entities.

[00:06:31] Speaker 04:
The imposition of the judgment against Mr. Shaffer's was imposed on the debtor.

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So we no longer have a conflict, whether one in the same.

[00:06:42] Speaker 04:
And if you don't want to appoint me, which I don't believe was the basis for converting the case, why don't you just give the debtor a chance to hire another attorney, which I believe as a practical matter would have been impossible.

[00:06:56] Speaker 02:
Well then you have the other aspect of it that you only had two creditors and one of the creditors said that they wouldn't be voting for a plan so you said that there wasn't grounds under 1112 but one of those is not is the inability to reorganize and if you have a creditor that's not going to vote for a plan you can't cram the plan down over the objection of the creditor.

[00:07:21] Speaker 02:
So how could you have the debtor reorganized?

[00:07:25] Speaker 04:
Well, the creditor would have received, the creditor would not have been impaired under the plan.

[00:07:30] Speaker 04:
The creditor would have received everything he was entitled to after selling the property.

[00:07:35] Speaker 04:
In other words, the property has a certain value.

[00:07:38] Speaker 04:
Whether he sells the property in a state court proceeding or it's sold in a bankruptcy proceeding, he's only going to get the net equity out of the property.

[00:07:48] Speaker 04:
He's not impaired.

[00:07:50] Speaker 03:
there's no other asset to be disposed of council you indicated that you were given notice that there was a certain period of time in which you were to respond and you made a decision

[00:08:02] Speaker 03:
that it was more important to file the motion to sell, to file the applications to employ than it was to respond.

[00:08:11] Speaker 03:
And that was something that you tactically decided, strategically decided was how you were going to deal with this issue.

[00:08:18] Speaker 03:
And then you were going to argue to the court

[00:08:20] Speaker 03:
at the time of the hearing on the OSC, I've gotten further down the line than we were when we started and therefore the fact that I didn't respond is evident from what I did do and you should just ignore the fact that I didn't respond.

[00:08:34] Speaker 03:
The court didn't view it that way.

[00:08:35] Speaker 03:
The court viewed it as a concession that you didn't oppose what he had suggested was necessary and set the OSC for, correct?

[00:08:46] Speaker 03:
That is a literal interpretation of his decision in the facts of as it says they occurred on the ground at the time well Right, I mean you made a choice.

[00:08:57] Speaker 04:
I filed a response.

[00:08:58] Speaker 04:
Okay.

[00:08:58] Speaker 04:
You didn't file response timely I would follow response because I had I didn't have a realtor at the time of the

[00:09:06] Speaker 03:
But you could have said, I intend to employ a realtor.

[00:09:09] Speaker 03:
I intend to employ a broker.

[00:09:11] Speaker 03:
I will be responsive.

[00:09:13] Speaker 03:
We will demonstrate to the court over some reasonable period of time, this is what I want to do in opposition.

[00:09:19] Speaker 03:
But you didn't oppose it.

[00:09:21] Speaker 01:
And you could have asked for more time.

[00:09:23] Speaker 01:
You could say,

[00:09:25] Speaker 01:
Court, please give me an extension of time because I intend to get a realtor.

[00:09:32] Speaker 01:
I intend to do this.

[00:09:33] Speaker 01:
I need more time to do that.

[00:09:34] Speaker 01:
But you waited until the time period expired before you did anything.

[00:09:39] Speaker 01:
Is that right?

[00:09:40] Speaker 04:
A lot of moving parts in this case.

[00:09:42] Speaker 04:
And when he set the OSC, you know, I didn't have a realtor.

[00:09:48] Speaker 04:
I didn't have it in my mind what the sale price would be.

[00:09:52] Speaker 04:
So maybe I should have said give me more time.

[00:09:55] Speaker 04:
But it didn't sound like he was going to give me more time anyway.

[00:09:57] Speaker 04:
And then I did come up with a realtor.

[00:10:00] Speaker 04:
We got the realtors and we decided what the sale price would be.

[00:10:03] Speaker 04:
And I filed a response.

[00:10:04] Speaker 04:
It was seven days late and I believe I should have been excused from that.

[00:10:09] Speaker 04:
Instead of converting the case, you want to sanction me, or you want to make some other orders besides the devastating decision to convert the case?

[00:10:22] Speaker 04:
Please give me a break.

[00:10:25] Speaker 02:
Do you want to reserve five minutes?

[00:10:28] Speaker 02:
We're at 4.49.

[00:10:36] Speaker 00:
Good morning, and may it please the court.

[00:10:38] Speaker 00:
I'm William Bell, Bell and Burkhardt.

[00:10:40] Speaker 00:
I'm here on behalf of Blizzard Energy, Inc., not technically the appellee, because it really was the judge's motion that got granted, but we're sort of trying to stick up for it.

[00:10:51] Speaker 00:
What we never hear from the appellant is the standard of review, and we kind of have to start there.

[00:10:58] Speaker 00:
And it is clearly abuse of discretion, and I've cited the Ninth Circuit case,

[00:11:04] Speaker 00:
Consolidated pioneer mortgage entities for that proposition and and that's a very very high standard for an appellant to overcome They have to prove that it's based on an erroneous Conclusion of law or that the record contains no evidence upon which the decision could be reached And we never hear that what I just hear mr.. Ramey say I don't like the decision.

[00:11:26] Speaker 00:
That's just not the standard and

[00:11:29] Speaker 00:
I think the panel understands that not only did we not have counsel for the debtor, but we never could have counsel for the debtor.

[00:11:39] Speaker 00:
So Mr. Raimi did eventually file something that looked a little bit like an employment application.

[00:11:46] Speaker 00:
Though I point out in my brief the different both local rule and national rules, it violated.

[00:11:53] Speaker 00:
It didn't meet the requirements of an appropriate employment application for counsel for the debtor.

[00:11:59] Speaker 00:
And as Judge Neiman pointed out, an LLC cannot appear without counsel.

[00:12:05] Speaker 00:
And then we have these just

[00:12:07] Speaker 00:
incurable deficiencies of conflicts between Mr. Shaffers that Mr. Raimi admittedly continues to represent and BKS Cambria.

[00:12:17] Speaker 00:
And I just want to talk a little bit about the unavoidable conflicts.

[00:12:22] Speaker 00:
First of all, Mr. Shaffers received both preferential and

[00:12:26] Speaker 00:
avoidable post-petition transfers from this debtor.

[00:12:30] Speaker 00:
It's kind of a rookie mistake, frankly, but what he did was he wrote himself a check the day before he filed, then he filed the case, then he cashed the check the next day.

[00:12:40] Speaker 00:
That's a 549 avoidable transfer.

[00:12:44] Speaker 00:
It is a clear conflict between Mr. Schafer's and the estate.

[00:12:48] Speaker 00:
Also, we have the bizarre activity.

[00:12:52] Speaker 00:
Mr. Schafer signed the schedules under penalty of perjury saying there were only two creditors, my client and the property taxes, and then turned around and filed a proof of claim himself.

[00:13:08] Speaker 00:
Was the proof of claim intentionally fraudulent or were the schedules intentionally filed falsely?

[00:13:16] Speaker 00:
One or the other has to be right.

[00:13:18] Speaker 00:
Third thing, the Statement of Financial Affairs, which is required to include these things, omitted payments to Mr. Raimi that occurred within 30 days of the filing of the case.

[00:13:28] Speaker 00:
I'm not talking about the retainer.

[00:13:29] Speaker 00:
We'll get to that in a second.

[00:13:31] Speaker 00:
But there was a $3,800 payment to Mr. Raimi.

[00:13:34] Speaker 00:
That's got to be in the Statement of Financial Affairs.

[00:13:37] Speaker 00:
There were payments to Mr. Schafer's over a period of time.

[00:13:41] Speaker 00:
Those have to be in the Statement of Financial Affairs, and they weren't.

[00:13:45] Speaker 00:
Here we have an individual party that is, I don't know how else you can put it, but concealing the conflicts that he had with the estate and that he's also represented by Mr. Raimi.

[00:13:57] Speaker 00:
And then we have the kind of bizarre situation.

[00:14:01] Speaker 00:
I mean, part of the employment application is that you have to reveal the retainer and what you intend to do with it.

[00:14:08] Speaker 00:
And Mr. Raimi said, I got $7,500.

[00:14:11] Speaker 00:
Now, we went to the first meeting of creditors, and I asked him, I said, well, what's this $7,500 for?

[00:14:18] Speaker 00:
And Mr. Ramey's answering, it's in the record because I put in my declaration, he said, well, you could say it had been earned pre-petition.

[00:14:27] Speaker 00:
You could say?

[00:14:28] Speaker 00:
He didn't even say.

[00:14:29] Speaker 00:
He just said, you could say.

[00:14:31] Speaker 00:
And in addition, then he said, well, yeah, it was earned pre-petition.

[00:14:35] Speaker 00:
And the petition is six pages long.

[00:14:38] Speaker 00:
It has the address of the debtor and the EIN of the debtor.

[00:14:43] Speaker 00:
That's not $7,500 worth of work.

[00:14:45] Speaker 00:
Now, Mr. Ramey, I'm sure if he had done a retainer properly and obeyed the requirements of the U.S.

[00:14:52] Speaker 00:
trustee in our district, could have earned $7,500 in this case.

[00:14:56] Speaker 00:
He's right, that's not a lot to pay a debtor's lawyer in a Chapter 11 case.

[00:15:00] Speaker 00:
I think we all know that wherever we're from.

[00:15:03] Speaker 00:
But still, he didn't do it.

[00:15:05] Speaker 00:
He just said, I'm taking $7,500 and I'll tell you later what it's for.

[00:15:09] Speaker 00:
I mean, so this is stacking up the completely inappropriate activities that were going to keep Mr. Raimi's application forever being granted, even if he'd ever done it procedurally properly.

[00:15:22] Speaker 00:
Now, there's been talk about 1112 and whether the 1112B requirements were met by the court, but the

[00:15:31] Speaker 00:
You know, as the judge pointed out, inability to consummate a plan, sorry, confirm and consummate a plan.

[00:15:41] Speaker 00:
These two parties go back a long way.

[00:15:45] Speaker 00:
And I know that Mr. Shavers doesn't like it that my client got a $3 million fraud judgment against him.

[00:15:51] Speaker 00:
He doesn't like it that that was affirmed on appeal in the state of Missouri.

[00:15:55] Speaker 00:
He doesn't like it that it was affirmed on appeal by the Missouri Supreme Court.

[00:16:00] Speaker 00:
He doesn't like it that it was domesticated in California.

[00:16:03] Speaker 00:
He doesn't like it that BKS Cambria was

[00:16:06] Speaker 00:
had its veil pierced and is found to be jointly liable for the judgment.

[00:16:11] Speaker 00:
But those things all happened, and they're not before this court, nor were they before Judge Clifford.

[00:16:16] Speaker 00:
The past is prologue, as Shakespeare said.

[00:16:19] Speaker 00:
Those are the facts.

[00:16:21] Speaker 00:
And Mr. Schafer doesn't really get to re-argue them again in this form.

[00:16:26] Speaker 00:
And then we also have the failure to comply with the orders of the court, including to file a response to the OSC.

[00:16:34] Speaker 00:
Mr. Raimi acts like the OSC was just some emergency thing that got dropped on his head, but he had about 45 days to produce a status report.

[00:16:47] Speaker 00:
after the court entered an initial order for status conference.

[00:16:51] Speaker 00:
And the initial order clearly says, if your case isn't straight when you come in front of me, I can convert your case at the status conference.

[00:16:59] Speaker 00:
It's in the judge's order creating the status conference.

[00:17:01] Speaker 00:
Well, the case wasn't straight.

[00:17:04] Speaker 00:
I mean, Mr. Raimi wasn't employed and didn't have anything going on that.

[00:17:09] Speaker 00:
There were other issues.

[00:17:11] Speaker 00:
And so the judge, instead of saying, my order raise status conference says I can convert the case,

[00:17:17] Speaker 00:
He said, I'm going to give you another chance.

[00:17:19] Speaker 00:
I'm going to do an order to show cause.

[00:17:21] Speaker 00:
Mr. Raimi says, I didn't get enough time.

[00:17:24] Speaker 00:
The interesting thing is, instead of if the judge filed his order to show cause, if I had filed a motion to convert or dismiss the case,

[00:17:33] Speaker 00:
I would have filed it on exactly the day the judge filed the order to show cause, 21 days prior to the date of the hearing.

[00:17:41] Speaker 00:
That's our local rule.

[00:17:42] Speaker 00:
I could have filed the motion then.

[00:17:44] Speaker 00:
Our local rule gives you till 14 days before the date of the hearing to file a response.

[00:17:50] Speaker 00:
In other words, the OSC gave the debtor exactly the amount of time that any motion filed under local rule would have done.

[00:17:59] Speaker 00:
And then I would have had seven days after that to file a reply brief.

[00:18:03] Speaker 00:
I did file a brief.

[00:18:05] Speaker 00:
It was in the nature of a reply, except there had been no opposition filed.

[00:18:10] Speaker 00:
The debtor actually filed its response to the OSC after I filed the reply, which there's an issue of due process there, but it isn't the debtor that's gotten not due process.

[00:18:24] Speaker 00:
It's my client, because I didn't get the opportunity to see their response before I filed my reply.

[00:18:29] Speaker 00:
Not that it mattered much, I don't think.

[00:18:32] Speaker 00:
The other thing is, the way the case was briefed, the debtor didn't give you the judge's opinion.

[00:18:41] Speaker 00:
I mean, I never know what to do when I see that because I think I frankly could have just walked in here today and said, you know, the opinion's not part of the debtor's appendix.

[00:18:53] Speaker 00:
You got to deny relief for that.

[00:18:55] Speaker 00:
But I just feel that's not fair to the panel.

[00:18:58] Speaker 00:
I thought the panel might want to look at what Judge Clifford said in the OSC, what he said in his tentative decision, because he gets to the end of the hearing, and he says, I'm going to adopt my tentative decision.

[00:19:10] Speaker 00:
So the tentative decision has been adopted, and the debtor just didn't even give it to you.

[00:19:20] Speaker 00:
Some thing called request for judicial notice was filed this week that had a whole bunch of other stuff to stick in.

[00:19:27] Speaker 00:
I mean, again, it was all arguments about the stuff that happened back in Missouri and the stuff that happened in the Superior Court.

[00:19:35] Speaker 00:
The other thing is, I just can't let it go.

[00:19:37] Speaker 00:
Mr. Raimi suggested that he had a motion to sell teed up.

[00:19:44] Speaker 00:
Again, I don't know how things go in Washington or in Arizona or up in Sacramento, but

[00:19:50] Speaker 00:
Where I practice, when you tee up a motion to sell, you usually have an offer.

[00:19:55] Speaker 00:
At least a stocking horse offer.

[00:19:59] Speaker 00:
Here's our offer.

[00:20:01] Speaker 00:
He just filed a motion to sell the property with no buyer, no offer.

[00:20:07] Speaker 00:
Hadn't yet, of course, had a realtor employed because he did put in a few days before the hearing on the OSC, he did put in an application to employ a realtor.

[00:20:18] Speaker 00:
One would think if you were going to get into Chapter 11 and your whole plan was to sell the property,

[00:20:26] Speaker 00:
But the first thing you would be doing is hiring a realtor, not waiting 60 days until the judge is going, why is there no realtor here at the status conference?

[00:20:36] Speaker 00:
So the case wasn't going anywhere, and it never could go anywhere, because frankly, my client and Mr. Schafer's couldn't agree on whether the day of the week ends in a why, frankly.

[00:20:50] Speaker 00:
And who can blame my client, who's been defrauded out of $3 million, according to every court that's heard the matter, including the bankruptcy court, which held it non-dischargeable, and the district court, which affirmed that?

[00:21:03] Speaker 00:
had a lot of appeals between Mr. Schafer's and my client, and Mr. Ramey did provide to you the one sort of successful result he got, which was after his case was dismissed, the Ninth Circuit dismissed his appeal

[00:21:19] Speaker 00:
and vacated the opinion of, not this panel, but another panel of this court, and the bankruptcy court saying that he wasn't entitled to a homestead.

[00:21:28] Speaker 00:
So that's been vacated, so I guess he can argue it again if he's ever in another personal case.

[00:21:33] Speaker 00:
But he filed a claim for a homestead in this case, of course, as well, despite the fact that it's an LLC, there are no exemptions.

[00:21:43] Speaker 00:
So I mean that's what I have I don't know if the panel's got questions.

[00:21:48] Speaker 03:
I'm happy to answer anything I can I guess the only question I have is that The judge asked you At some point when he made the decision that he was going to either dismiss or convert the case what you want what you preferred Oh sure is that pursuant to 1112 be well.

[00:22:06] Speaker 00:
Yeah, it says that if it's a

[00:22:08] Speaker 00:
If the court's going to do it, it either converts or dismisses whichever is in the best interests of creditors.

[00:22:15] Speaker 00:
I'm looking around, I'm the only guy in the room.

[00:22:17] Speaker 00:
So yeah, and because of course my client, where our choices were, tried to do a lean sale of the property and tried to sell this property that Mr. Schafer's lives on and it's got problems.

[00:22:28] Speaker 00:
Or have a chapter 7 trustee do it and then we'd get the bulk of the consideration But pay the trustee and pay his broker her broker and her agents and accountants of course there's costs but my client believes that that's in our best interests and Judge Clifford listen to us since we're the only creditor at which I believe is absolutely correct on his part Thank you

[00:23:07] Speaker 04:
So the fee I received of $7,500, I told Judge Clifford it was a no-look fee.

[00:23:18] Speaker 04:
I intended it to be treated as a no-look fee, since it was so modest.

[00:23:24] Speaker 04:
And I had no intention of asking for more fees.

[00:23:27] Speaker 04:
In other words, it was a flat fee.

[00:23:30] Speaker 04:
I told him that, and he appeared to be OK with it.

[00:23:33] Speaker 04:
Didn't question me on it at all.

[00:23:35] Speaker 04:
It's just unbelievably.

[00:23:37] Speaker 04:
irritating to me that I would be attacked over this fee for Chapter 11.

[00:23:44] Speaker 04:
And it didn't seem to be relevant to him anyway when he converted the case.

[00:23:49] Speaker 04:
Which again, his thinking was at the time as I interpret it, we would file another bankruptcy, which of course is unjustified.

[00:23:59] Speaker 04:
The previous bankruptcy had been turned into chaos by Mr. Bell and by the United States trustee to their everlasting discredit attempting to sell the property that was not property of the estate.

[00:24:14] Speaker 04:
And it took this panel to, not this panel, but this court to straighten that out.

[00:24:21] Speaker 04:
And years and months of waste was caused directly by Mr. Bell and by the trustee.

[00:24:29] Speaker 04:
who, by the way, the trustee in this case recommended or moved to dismiss the case.

[00:24:35] Speaker 04:
Mr. Bell said the judge should dismiss the case with a bar, and the judge winds up converting my case, which nobody asked him to do.

[00:24:45] Speaker 04:
I request the court reverse that.

[00:24:49] Speaker 04:
Thank you.

[00:24:59] Speaker 03:
I think you're ready to call this the last case.

[00:25:01] Speaker 03:
Thank you.

[00:25:02] Speaker 03:
Thank you both.

[00:25:03] Speaker 03:
Thank you for your arguments.

[00:25:04] Speaker 03:
We'll take this matter under advisement and we'll issue a decision as quickly as we can.