[00:00:00] Speaker 05:
Base number 21-1715, UAD Sky Road Leasing at Ballant versus Oak, Daji Air, the Republic of Tajikistan.

[00:00:09] Speaker 05:
Mr. Kryan for the at Ballant, Mr. Silliman for the Eveli.

[00:00:15] Speaker 04:
Good morning, Council.

[00:00:18] Speaker 04:
You may proceed.

[00:00:19] Speaker 02:
Good morning, Your Honors.

[00:00:23] Speaker 02:
It's an honor and a pleasure to be here in person with at least two of the judges and good morning, Judge Rogers,

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And with counsel, the district court's piecemeal analysis of the circumstances of control and domination of Tajik air by Tajikistan transformed the presumption of separateness into a conclusive presumption.

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The district court's own language reveals the piecemeal approach

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taken by the district court, which conflicts directly with this circuit's rule and requires reversal.

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The error here is the district court made it an irrebuttable presumption on a motion to dismiss.

[00:01:21] Speaker 04:
In fairness, counsel, I understand that the district court opinion doesn't ever say that, and looking at everything together,

[00:01:31] Speaker 04:
But he does go through each of the arguments and he does more than make a conclusory statement.

[00:01:39] Speaker 04:
He explains why he isn't persuaded by your argument.

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So where's the error?

[00:01:46] Speaker 02:
Your honor, I understand your point.

[00:01:49] Speaker 02:
The language of the district court that I'm pointing to is scattered throughout the opinion, and I'll show it to your honor specifically.

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For example, on the issue of- I mean, where it is in the JA, and I'll bring it up.

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Your honor, we're starting with page A, 452.

[00:02:09] Speaker 03:
Right.

[00:02:10] Speaker 02:
On the issue of high ranking government officials occupying all seats on the board, the district court stated, quote, the presumption cannot be overcome simply because high ranking officials sit on the board.

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On that same page, the district court stated that this fact, quote,

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by itself, close quote, was insufficient to overcome the presumption.

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So that's the point of my question.

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He went through each of your objections and found them unpersuasive and said, why?

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He never said, and looking at them all together, I conclude that you have not met your burden.

[00:03:01] Speaker 04:
Is that the error?

[00:03:03] Speaker 02:
You are right, Your Honor.

[00:03:05] Speaker 02:
The district court did not follow circuit precedent set in 2020 in the TIG versus Argentina case in which this court stated, quote, we joined several other circuits in holding that district courts should look to the totality of the circumstances to make this determination.

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Another example on page 448 of the JA,

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Regarding the facts of 100% ownership and the government's authority to appoint and fire the director general, the district judge stated that these 2 facts quote.

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do not by themselves establish the required control," end quote.

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Your Honors, we never argued that those two facts by themselves establish the required control, but this language from the opinions shows that the district court conducted the wrong analysis.

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It's like pieces of a puzzle.

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The district court picked up each piece and discarded it without putting them together and seeing the full picture.

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It never got the view because... So where did you bring this to the district court's attention?

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Your Honor, we stated throughout all of our briefs and in the hearing,

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that it's the totality of the facts, not any one fact that is determinative here.

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And that's why this decision must be vacated and remanded.

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You cannot have an opinion out there that goes fact by fact, discards each one.

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but never gives the petitioner the ability to present the total facts and circumstances.

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For example, on the fact that they were represented by a civil servant, non-lawyer, head of the transportation department, the district court stated at 457 that that fact, quote, cannot bear

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the burden of overcoming the presumption of separateness.

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Close quote.

[00:05:24] Speaker 05:
Mr. Cried, I mean, in making a fact by fact determination, I mean, to take all of the facts in the totality, you still have to consider each fact.

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along the way and at the end of its discussion of this I mean the district court talks about the fact that this is that taking everything together you know this is closer to the spectrum of cases in which in which there was you know separateness.

[00:05:51] Speaker 02:
Yes, your honor, but the language that I pointed to throughout the opinion shows the district court did not follow the analysis that this court set down, which is to examine the totality of the circumstances.

[00:06:06] Speaker 04:
But why isn't what Judge Rao just pointed to where the judge did that?

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Your honor, the judge absolutely did not do that.

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And the reason I say that is based on the text of the ruling, the language that I just quoted to your honor, wherein the judge did not conduct the totality of the circumstances analysis quite the opposite.

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No, I don't understand your point.

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The judge said, look, you raised 10 points.

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I don't find each alone enough.

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And then at the end,

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The point that Judge Rao makes says, why isn't the judge saying and looking at everything together?

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Yes, Your Honor.

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And Judge Rao is absolutely correct.

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The district judge does intone that at the very end of the opinion.

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But the whole opinion leading up to that refutes that that was the analysis conducted.

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Your Honors.

[00:07:02] Speaker 04:
I don't understand.

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When the judge was considering allegation one,

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Was he supposed to say, I don't find this persuasive?

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And in the totality, I don't find it persuasive?

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As distinct from saying, none of these facts that you allege is persuasive and looking at all of them together.

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Why isn't that sufficient?

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I don't see our cases as limiting the judge or the district court the way you suggest so long as the judge

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Does at some point address totality totality and i'm not even sure I know my one of my colleagues and i've had this discussion in another context, but I don't even know that.

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it's necessary to do, other than as the judge did here that's what i'm trying to understand what what what is as we're.

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the prejudice to your client by the judge saying, this alone doesn't do it, that alone doesn't do it, that alone, and taking all these things together, not enough.

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That's why I don't understand about this argument.

[00:08:18] Speaker 02:
Your Honor, it is because this is a motion to dismiss.

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There's never been an evidentiary hearing held in this case.

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With facts such as 100% ownership, control of the board of directors, but also the government controlled each and every decision large and small, it inserted their version of the FAA, the Civil Aviation Agency, into that airline, and that agency made every day-to-day business decision.

[00:08:48] Speaker 02:
That's not correct.

[00:08:52] Speaker 01:
It's contradicted.

[00:08:56] Speaker 02:
Your honor, that was never contradicted.

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In fact, there's no declaration that even mentions the CAA and Tajik Air's brief never mentioned it.

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What we do have is the recitation of decisions that were made apart from the CAA.

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You are correct, your honor, but they never this is a motion to dismiss no evidentiary hearings been held.

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They never even mentioned the CAA, your honor.

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They also never mentioned the written admission before this court that was in the underlying proceedings.

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They said that the government of Tajikistan quote determines both the complexity

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and length of the decision adoption process.

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These decisions are taken by the state through its institutions.

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Close quote.

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That is more than sufficient to overcome a presumption at the outset of a case before an evidentiary hearing has been held.

[00:10:04] Speaker 05:
So the cases, I mean, of course, this is an inherently fact-specific inquiry.

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But it seems, looking at the cases, one of the primary factors from the case law is whether the instrumentality was acting on behalf of the state.

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And that seems to be a factor that gets a lot of weight.

[00:10:25] Speaker 05:
So what evidence is there that Tajik Air was acting on behalf of Tajikistan?

[00:10:33] Speaker 02:
Your honor, in this case, but which is different from being controlled by it.

[00:10:37] Speaker 02:
Yes.

[00:10:37] Speaker 02:
What is really happening here?

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The president of the country set up a different airline called Fallen Air owned by the brother in law of the president of the country.

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And they took steps of control and domination.

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to suppress this particular entity, Tajik Air.

[00:10:57] Speaker 02:
They used it as their own agent, and they showed control and domination, not in the way Your Honor's talking about, but day-to-day control.

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For example, Your Honor, they passed a statute.

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They used that quintessential government power of passing a statute.

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It transformed and dealt into every business decision and business relationship of his airline.

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And it transformed vendor debts into potentially worthless tax credits.

[00:11:30] Speaker 02:
That is government interference into the day-to-day business functions of the airline.

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And it's those totality of the circumstances you are in.

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And that's why I think that this decision, which shows by its own language that the court went fact by fact,

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requires vacatur and reverse, just as this court did in the Ornos-McKesson versus Iran and the TIG against Argentina cases.

[00:11:56] Speaker 02:
We're at the outset of the case, Your Honors, and we had more than sufficient facts to overcome the presumption.

[00:12:03] Speaker 01:
Let me ask you about one other passage in the district court's opinion.

[00:12:08] Speaker 01:
And this is at 447 to 448.

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we're told Sky Road argues that the following facts overcome the presumption of separate.

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And there are then seven itemized things.

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Following which the court says, these facts, these seven taken as a whole fall short of overcoming the presumption that it's a separate from the solver.

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Now, was there anything besides those seven that was in play?

[00:12:39] Speaker 02:
Yes, your honor.

[00:12:40] Speaker 02:
But let me just take up directly the language that your honor is pointing to because the district court's language leading up to that point made clear that the court looked at each piece of the puzzle and discarded it.

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In other words, the district court never looked at the forest.

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It looked only at each individual tree.

[00:13:00] Speaker 04:
What's the answer to the judge's question?

[00:13:04] Speaker 02:
The answer is yes, there are numerous other facts.

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For example, they appointed the head of the Department of Transportation Legal Department, a non-lawyer.

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He was the person who represented them in the underlying arbitration.

[00:13:22] Speaker 01:
Right, so according to the judge, there were those seven facts we just referred to, and then there are actions taken in the arbitration.

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And as to these seven, he's saying, looking at them in the totality.

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So all that leaves out is the actions in the arbitration.

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Right?

[00:13:43] Speaker 01:
Yes.

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And that's why, Your Honor, at the posture of this case, motion to dismiss without an evidentiary hearing being held,

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This opinion has to be vacated so that all those facts can be presented in their totality to the district court.

[00:14:01] Speaker 02:
Exactly as this court did in those other cases, here you have a piecemeal analysis that does not comport with circuit precedent.

[00:14:10] Speaker 04:
So is your point that Tajik Air couldn't hire the head of the transportation department to represent it in the arbitration?

[00:14:21] Speaker 02:
No, Your Honor, but the record says that the Department of Transportation itself is who made that appointment.

[00:14:28] Speaker 02:
So imagine.

[00:14:29] Speaker 04:
Well, Patrick said we need somebody.

[00:14:31] Speaker 04:
Who do you say?

[00:14:32] Speaker 02:
No, that's not in the record, Your Honor.

[00:14:37] Speaker 04:
No, but you don't have the opposite in the record.

[00:14:41] Speaker 04:
That's what I'm trying to get at.

[00:14:43] Speaker 02:
No, we do, Your Honor.

[00:14:44] Speaker 02:
It says the Department of Transportation appointed him.

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I know that it's strange.

[00:14:49] Speaker 04:
At whose request?

[00:14:52] Speaker 02:
Your honor, it did not say that there had been a prior request.

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That's the level of control here.

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The government controls this airline.

[00:15:00] Speaker 04:
It seems to me that you would have to show something more than make that leap that the department just inserted itself against Hajin's wishes.

[00:15:18] Speaker 02:
Well, that was the plain language of the record, your honor.

[00:15:21] Speaker 04:
But imagine that- I didn't find that council.

[00:15:24] Speaker 04:
And I didn't see it in the judge's opinion.

[00:15:28] Speaker 02:
You're right.

[00:15:28] Speaker 02:
The judge omitted that.

[00:15:30] Speaker 04:
But where was it beforehand?

[00:15:34] Speaker 02:
It was in the record where it said it was the Department of Transportation that appointed this individual, this civil servant.

[00:15:42] Speaker 04:
I know, but it still doesn't say who requested it.

[00:15:45] Speaker 03:
OK.

[00:15:55] Speaker 02:
I see that my time is expired.

[00:15:57] Speaker 02:
May I briefly conclude?

[00:16:02] Speaker 04:
Briefly.

[00:16:04] Speaker 02:
Your honors, nothing drives this point home better than the analogy brought up by the appellee in their brief to US-based airlines.

[00:16:14] Speaker 02:
We all know.

[00:16:15] Speaker 02:
that the U.S.

[00:16:16] Speaker 02:
government does not control a U.S.-based airline.

[00:16:19] Speaker 02:
But a U.S.-based airline would never have occasion to say that the U.S.

[00:16:24] Speaker 02:
government determines both the complexity and the length of the decision adoption process.

[00:16:32] Speaker 02:
These decisions are taken by the state through its institutions.

[00:16:37] Speaker 02:
So we ask that you vacate this ruling.

[00:16:40] Speaker 04:
All right, thank you.

[00:16:41] Speaker 04:
Whoops, sorry.

[00:16:41] Speaker 04:
Thank you, Your Honor.

[00:16:42] Speaker 04:
My colleagues have a question.

[00:16:44] Speaker 02:
No, no, no.

[00:16:46] Speaker 04:
Thank you.

[00:16:47] Speaker 04:
All right, Council for Appellee.

[00:17:00] Speaker 03:
Thank you, Your Honor.

[00:17:01] Speaker 00:
May it please the court, Arsalan Soliman for Respondent, Appellee, Oakland Joint Stock Company, logic here.

[00:17:08] Speaker 00:
The District Court properly dismissed Sky Road's petition for lack of personal jurisdiction pursuant to the due process clause of the Fifth Amendment because Tajik Air, a corporation wholly owned by Tajikistan, lacks minimum contacts with the United States.

[00:17:22] Speaker 00:
The District Court arrived at this ruling by making findings a fact after examining the whole record in depth and hearing the parties in an oral hearing lasting over 90 minutes.

[00:17:33] Speaker 00:
Judge Mehta's opinion is detailed, comprehensive, and fits squarely within this circuit's precedent on the issue, in particular following Judge Ginsburg's opinion in trans-America leasing versus Venezuela.

[00:17:47] Speaker 00:
Your Honors, I'll jump straight to Judge Rogers' question, which was whether the court, the lower court, ever said whether the judge was looking at all the factors together.

[00:17:59] Speaker 00:
As pointed out by Judge Ginsburg,

[00:18:01] Speaker 00:
In fact, the record does show that the judge was looking at all the factors together.

[00:18:07] Speaker 00:
Judge Ginsburg pointed to A448 in the opinion, where the judge says these facts taken as a whole fall short of overcoming the presumption.

[00:18:17] Speaker 00:
But there's another part of the judge's opinion at the very end, at page A457 of the record,

[00:18:25] Speaker 00:
where the judge says, accordingly, the court holds that the facts offered by Sky Road to show Tajikistan's control over Tajik air when viewed as a whole are insufficient to satisfy the principal Asian exception, the ban checks presumption of separateness.

[00:18:42] Speaker 00:
And he goes on to say that this conclusion is reinforced by other cases in the circuit where that presumption is overcome.

[00:18:49] Speaker 00:
And he compared those cases to the case before him and showed that the factors in those cases were never present in this case.

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And one of those factors was the factor of Judge Rao mentioned, which was the factor of an indication that Tajikgir was acting on behalf of Tajikistan in some way to pursue some sort of government policy.

[00:19:10] Speaker 00:
Examples are, for example,

[00:19:12] Speaker 00:
show him the Iran, where the finding of the court was that the bank in that case, which was nationalized, was carrying out the policy of the government of Iran to promote and sponsor terrorists.

[00:19:22] Speaker 00:
There is obviously no such promotion of any government policy here in terms of the airline carrying out its commercial activities and operations as a airline.

[00:19:33] Speaker 00:
There's another case, TMR Energy versus Ukraine, where the finding was that that particular entity, its expenses were being paid directly by the state, and it was implementing state policy.

[00:19:44] Speaker 00:
And of course, that finding is not present in this case.

[00:19:47] Speaker 00:
And that showing was not made by Sky Road in this case.

[00:19:52] Speaker 04:
Far from being... Given those statements by the judge, what would a appellate have to show

[00:20:03] Speaker 04:
I mean, he says this is fraud and injustice, but would he have to show that the district court's findings were inherently incredible?

[00:20:16] Speaker 04:
I mean, normally that's a phrase referred to testimony, but just plain error here.

[00:20:23] Speaker 00:
Yes, Your Honor, it would be clear error.

[00:20:25] Speaker 00:
They would have to show that there was a clearly erroneous finding by the district court in terms of the district court's consideration of all the facts here in this case.

[00:20:35] Speaker 04:
So for example, about the Department of Transportation appointing the representative, would he have to have some evidence to offer at that point?

[00:20:52] Speaker 04:
I mean, hypothetically, some written evidence of a request or no request or request, but it was rejected by the transportation department.

[00:21:04] Speaker 04:
I mean, what is the level of overcoming?

[00:21:08] Speaker 04:
Yes, Your Honor.

[00:21:11] Speaker 04:
Airplane error standard in this case.

[00:21:16] Speaker 00:
Right.

[00:21:16] Speaker 00:
The appellant would have to show that any particular fact in this case, if they're arguing the appointment of this attorney, they would have to show that that particular fact somehow in the totality of the circumstances shows that the government of Tajikistan was exerting dominant and overall control over Tajik air.

[00:21:37] Speaker 00:
or that it created some sort of principal agent relationship.

[00:21:40] Speaker 00:
Now, on this fact specifically, counsel actually has it wrong on the record.

[00:21:46] Speaker 00:
First of all, the record shows that Tajik Air hired this gentleman, Mr. Hafizov, in his personal capacity for the arbitration hearing.

[00:21:54] Speaker 00:
And that's substantiated not only by Tajik Air's CEO's declaration to that effect, which is found in the record at A412, but in the arbitration proceedings themselves,

[00:22:07] Speaker 00:
At A-51 of the record, the tribunal references an authorization letter from Tajik Air dated October 2017 authorizing Mr. Kafizov to represent Tajik Air.

[00:22:18] Speaker 00:
It is Sky Road itself that then asked the tribunal, the arbitration tribunal, to request from Tajik Air and Mr. Kapusov some sort of letter or authorization from the Ministry of Transport to show that he is allowed to represent Tajik Air in this capacity.

[00:22:39] Speaker 00:
And it is only after that request was made to the tribunal that Mr. Kofizov then went back to his Ministry of Employment and asked for such a letter of authorization.

[00:22:49] Speaker 00:
And this is at record A52.

[00:22:51] Speaker 00:
And then at record A54, we see that Mr. Kofizov does present a letter of authorization.

[00:22:59] Speaker 00:
It's not a letter of hiring.

[00:23:01] Speaker 00:
It's not a letter of appointment.

[00:23:02] Speaker 00:
It's not a letter of engagement.

[00:23:04] Speaker 00:
It's a letter of authorization

[00:23:06] Speaker 00:
in which the ministry where he is employed said he is authorized.

[00:23:09] Speaker 00:
He is OK to conduct this representation where he's representing Tajik Air in his personal capacity, which was explained in the declaration of the CEO of Tajik Air.

[00:23:21] Speaker 00:
So, Your Honor, I submit that the record is very clear and obvious that this particular hiring of this attorney, which happened during the arbitration proceedings, does not indicate the type of day-to-day control that Sky Road would have to show in order to overcome

[00:23:36] Speaker 00:
presumption of ban check.

[00:23:37] Speaker 05:
Is it common in Tajikistan for government officials to also have private employment in terms of representing private parties?

[00:23:47] Speaker 05:
I mean, that's just something that would be fairly foreign to us here.

[00:23:52] Speaker 00:
I'm not sure.

[00:23:53] Speaker 00:
I wish I knew more about the practice in Tajikistan.

[00:23:56] Speaker 00:
I will say, however, that Tajik air used to be a state unitary enterprise, meaning it used to be completely owned by the government.

[00:24:04] Speaker 00:
And then it was

[00:24:05] Speaker 00:
reorganized and privatized in December of 2009.

[00:24:09] Speaker 00:
And that restructuring of it into a private corporation may have created some circumstances where the leadership at the time felt more comfortable in hiring an individual in an individual capacity who may have had experience in this particular industry to make this representation of Tajik Air at these arbitration proceedings.

[00:24:33] Speaker 00:
But again, the record is very clear

[00:24:35] Speaker 00:
And this is from the declaration of the CEO, that that representation was always in his personal capacity, that he was paid funds for that representation.

[00:24:47] Speaker 00:
He was provided a per diem, his hotel costs were paid, and in fact, he was given money to pay for the fees in the court.

[00:24:55] Speaker 00:
There was a problem with that, but we don't have to get into that at this time.

[00:25:02] Speaker 05:
Can you just speak a little bit about the equitable factors?

[00:25:05] Speaker 05:
So Tajik Air and the arbitration and in the Lithuanian courts argued that it was a state enterprise.

[00:25:13] Speaker 05:
Is that inconsistent with the position it's taking before this court?

[00:25:19] Speaker 00:
Well, Your Honor, it's not correct that they argued that they were a state enterprise.

[00:25:23] Speaker 00:
That's actually not the case.

[00:25:24] Speaker 00:
In the arbitration proceedings in Lithuania,

[00:25:28] Speaker 00:
There was a provision of Lithuanian law, Article 12.3 of the Lithuanian Commercial Arbitration Act, which provided that state-owned entities need to get the permission of their parent in order to sign arbitration agreements.

[00:25:44] Speaker 00:
The argument made by Tajikgir at that time was simply that at the time the lease was signed, which was September of 2009, when Tajikgir was still a state unitary enterprise,

[00:25:55] Speaker 00:
And at that time, it was clearly state-owned enterprise.

[00:25:58] Speaker 00:
It still is a state-owned open joint stock company, meaning that the state is the primary shareholder.

[00:26:07] Speaker 00:
But the language of the Lithuanian statute simply was looking at ownership, not control.

[00:26:12] Speaker 00:
It said that state-owned entities would need to get the permission of their parents.

[00:26:16] Speaker 00:
So the argument of Tajikgir was, well, there needs to be a showing that Tajikistan then had to give that permission.

[00:26:23] Speaker 00:
The tribunal and then the Lithuanian Court of Appeals held that, in fact, the Lithuanian law doesn't say that.

[00:26:30] Speaker 00:
It only applies to Lithuanian entities.

[00:26:33] Speaker 00:
So it's not applicable to any Tajik entities.

[00:26:35] Speaker 00:
And there's no provision of Tajikistan law that would require such permission.

[00:26:39] Speaker 00:
And so that argument failed.

[00:26:42] Speaker 00:
But there was no contradiction between that argument and the argument we made here in these proceedings.

[00:26:47] Speaker 00:
The argument before the district court is that,

[00:26:51] Speaker 00:
as a private company, as a corporation that's separate from the state,

[00:26:56] Speaker 00:
that presumption of separateness can only be overcome by a showing of a particular amount of control over the corporation.

[00:27:04] Speaker 00:
And Sky Road, which has the burden to show that, did not meet that burden.

[00:27:08] Speaker 00:
Judge made the look at that very carefully.

[00:27:10] Speaker 00:
He said that there was no contradiction between these two arguments.

[00:27:13] Speaker 00:
And we submit that is correct.

[00:27:15] Speaker 00:
Also, in terms of the court's precedent on what standard is for looking at that equitable exception,

[00:27:25] Speaker 00:
The examples are always where the party is using a particular argument as both a sword and a shield, meaning that they are not only trying to use their status being state-owned in order to deflect jurisdiction, but they're also trying to invoke the US courts for some sort of benefit.

[00:27:45] Speaker 00:
And that was most clearly demonstrated in the Banchek opinion, the Supreme Court's case in Banchek, where the Cuban state-owned entity was

[00:27:54] Speaker 00:
had brought an action to seek payment on a letter of credit.

[00:27:58] Speaker 00:
And then it was seeking to use its state-owned status in order to prevent the hearing of a counterclaim, an offset claim.

[00:28:07] Speaker 00:
And the court held that that type of sword and shield usage was inappropriate.

[00:28:13] Speaker 00:
That's my time, Your Honor.

[00:28:14] Speaker 00:
Thank you so much.

[00:28:14] Speaker 00:
We respectfully submit that the district court's opinion could be affirmed on definitively.

[00:28:21] Speaker 04:
Thank you.

[00:28:23] Speaker 04:
Thank you, Council.

[00:28:24] Speaker 04:
Councilor Pillin.

[00:28:32] Speaker 02:
Thank you, Your Honor.

[00:28:33] Speaker 02:
And to give Your Honor the specific record reference about the appointment by the Department of Transportation of the civil servant non-lawyer to represent them, it's in the paragraph numbered 45.

[00:28:46] Speaker 02:
It's in the record at page A54.

[00:28:50] Speaker 02:
But the language that cannot stand here

[00:28:53] Speaker 02:
When the district court said, quote, by itself, close quote, at 452, by themselves at 448, simply because at 452, quote, bear the burden of overcoming at 457, your honors, this is the precise kind of case, such as the Foremost McKesson case and the TIG case, in which this court vacates and remands for further fact-finding because

[00:29:22] Speaker 02:
No evidentiary hearing has ever been held.

[00:29:25] Speaker 02:
We're at the stage of a motion to dismiss.

[00:29:29] Speaker 02:
And Your Honor, to Judge Ginsburg's question earlier, they never mentioned the CAA in any declaration, but the agency that controls their day-to-day operations.

[00:29:40] Speaker 02:
They never mentioned it in their brief.

[00:29:42] Speaker 02:
They never mentioned it today.

[00:29:44] Speaker 02:
They just seek to ignore the control by that federal agency.

[00:29:50] Speaker 02:
And I ask that your honors reverse on that basis.

[00:29:54] Speaker 02:
Thank you, your honor.

[00:29:55] Speaker 04:
Thank you.

[00:29:56] Speaker 04:
We'll take the case under advisement.