[00:00:00] Speaker 04: Case number 23-3023, United States of America versus Russell Dean Alfred Appellant. [00:00:08] Speaker 04: Ms. [00:00:08] Speaker 04: Oswald for the appellant, Mr. Hansberg for the appellant. [00:00:15] Speaker 03: Good morning, Ms. [00:00:16] Speaker 03: Oswald. [00:00:16] Speaker 04: We're ready when you are. [00:00:17] Speaker 04: Good morning. [00:00:18] Speaker 04: May it please the court, I would like to reserve a rebuttal. [00:00:24] Speaker 04: Trustee Alford's mere presence in the Capitol on January 6th is not sufficient to convict him of disorderly or disruptive conduct under Title 18 or under Title 40. [00:00:37] Speaker 04: But even if the court disagrees and finds that his conduct is sufficient to violate those statutes, it was not enough to justify the 12-month day-for-day sentence that was imposed in this case. [00:00:50] Speaker 04: Starting with the statutes. [00:00:52] Speaker 02: Each counsel, excuse me. [00:00:53] Speaker 02: This is Judge Rogers. [00:00:55] Speaker 02: I'm sorry. [00:00:56] Speaker 02: I mentioned this to the court clerk. [00:01:03] Speaker 02: The audio is not very strong. [00:01:07] Speaker 02: So could you speak loudly? [00:01:11] Speaker 04: Yes, Your Honor. [00:01:12] Speaker 04: I apologize. [00:01:13] Speaker 04: Excellent. [00:01:14] Speaker 04: Thank you so much. [00:01:16] Speaker 04: Starting with the text of the statutes, each contains an element requiring the government to prove that Mr. Alford engaged in a disorderly or disruptive act. [00:01:29] Speaker 04: Reading the conduct element to require conduct that is boisterous or unruly gives meaning to all of those terms. [00:01:36] Speaker 04: Congress could have drafted a statute that criminalizes any conduct, but it did not do so in this case. [00:01:45] Speaker 03: So Council, it strikes me that the difference between you and your friends on the other side is whether the terms disruptive or disorderly should be inherently so, or whether it's the effect of the conduct that is disruptive or disorderly. [00:02:03] Speaker 03: And so I wanted to ask you, what in your view is inherently disruptive or disorderly? [00:02:11] Speaker 03: Because it seems that that's very context dependent. [00:02:14] Speaker 03: For example, screaming in a courtroom would be disruptive, but screaming at a ballgame would not. [00:02:20] Speaker 03: So what is inherently disruptive in your view? [00:02:24] Speaker 04: I understand, Your Honor. [00:02:25] Speaker 04: I think, first, the text, especially in Title 18, gives us a clue that Congress intended effect to be judged separately. [00:02:36] Speaker 04: And that might be where context comes in to decide where something is disorderly or disruptive. [00:02:44] Speaker 04: Screaming at a ball game, for example, that conduct on its own, it might qualify as disorderly or disruptive if it's loud or abusive screaming towards the other team. [00:02:55] Speaker 04: However, in context, it might not have the effect. [00:02:59] Speaker 03: But how is that disruptive if everybody else is screaming too and it's expected to [00:03:03] Speaker 03: people are expected to scream at ball games. [00:03:05] Speaker 03: So is it inherently disruptive in that context? [00:03:09] Speaker 04: It is, because it is conduct that you would expect would be disruptive, or that tends to be disruptive. [00:03:18] Speaker 04: But in the context of a ball game, it's just not having the same effect that it would somewhere else. [00:03:23] Speaker 03: But is it disruptive? [00:03:24] Speaker 03: It's cheering on the team. [00:03:26] Speaker 03: It's promoting the purpose of that proceeding. [00:03:29] Speaker 04: cheering might be, but also at a ball game, you might have people that are cheering the other team or trying to distract them from what's happening on the field. [00:03:37] Speaker 03: So you don't think cheering is inherently disruptive? [00:03:42] Speaker 04: If it's allowed cheering, it might be inherently disruptive. [00:03:48] Speaker 03: You said might be, meaning it's context dependent and not inherently so, right? [00:03:53] Speaker 04: No. [00:03:53] Speaker 04: I just simply mean that a jury could look at someone who was cheering [00:03:59] Speaker 04: and decide that that conduct is inherently disruptive. [00:04:03] Speaker 04: However, I don't think the court needs to draw this. [00:04:05] Speaker 03: But how would it decide that? [00:04:07] Speaker 03: How would the jury decide if that's inherently disruptive or not? [00:04:11] Speaker 04: I think just using their common sense, they can make that determination. [00:04:16] Speaker 04: But they have to. [00:04:17] Speaker 03: Based on the context? [00:04:18] Speaker 04: No, Your Honor, not based on the context, based on the behavior itself. [00:04:22] Speaker 04: But I don't think the court, I respect that. [00:04:25] Speaker 04: Our interpretation of the statute might lead to some difficult line drawing problems about what is or is not disruptive. [00:04:33] Speaker 04: But I don't think that the court needs to create a hard and fast rule in this case. [00:04:38] Speaker 04: It need only decide that mere presence in the Capitol is not enough, because that was the theory that the government presented to the jury in this case. [00:04:47] Speaker 04: And that was the theory on which the jury convicted. [00:04:49] Speaker 03: But mere presence, it depends on the context, again. [00:04:52] Speaker 03: If you were president of the Capitol for a tour, that's one thing. [00:04:57] Speaker 03: But if you're president in the context of a mob that's trying to overturn a presidential election, it's a whole different thing. [00:05:02] Speaker 03: I don't think you can divorce the conduct from the context. [00:05:06] Speaker 04: I understand your point, Your Honor. [00:05:08] Speaker 04: And I would point, Your Honor, to the case Garner v. Louisiana. [00:05:13] Speaker 04: which is actually a case that the government cited first in their brief. [00:05:17] Speaker 04: And in that case, the facts of that case involved black students who entered a department store to sit at a lunch counter that was reserved for white customers. [00:05:28] Speaker 04: It was a case from the 1960s. [00:05:31] Speaker 04: And they created a disruption, and they were asked by the police to leave, and they refused to leave. [00:05:39] Speaker 04: And they were eventually prosecuted under Louisiana's version of disorderly and disruptive conduct. [00:05:46] Speaker 04: And their case eventually reached the Supreme Court. [00:05:50] Speaker 04: And the court, in its plurality decision, said, you do not have to reach the constitutionality of the statute. [00:05:57] Speaker 04: Because sitting at a lunch counter is not disorderly or disruptive conduct. [00:06:02] Speaker 04: Even if it has disruptive effect, even if it was intended to be disruptive, that conduct on its own terms is not disorderly or disruptive. [00:06:14] Speaker 03: So I think looking at constitutional issues is different from the statutory interpretation issue that's before the court. [00:06:22] Speaker 03: And it appears that when Congress passed these statutes, they wanted to address [00:06:26] Speaker 03: conduct that was disruptive of the proceedings. [00:06:30] Speaker 04: I don't disagree with that, Your Honor. [00:06:32] Speaker 04: So that's the effect of the conduct. [00:06:37] Speaker 04: Yes, and I believe the statute as a whole does address the effect of the conduct, because especially in Title 18, one of the elements is the effect of the conduct is disruptive. [00:06:50] Speaker 03: So that seems to me, though, what the government's position is. [00:06:54] Speaker 03: that we should define disruptive based on the effects that the conduct has. [00:06:59] Speaker 03: For example, if your client was merely present but walked onto the floor of the Senate during the vote certification and just was present there, would that be disruptive in your view? [00:07:09] Speaker 04: No, Your Honor. [00:07:10] Speaker 03: No? [00:07:10] Speaker ?: No. [00:07:11] Speaker 03: So he's allowed to do that and there'd be no [00:07:14] Speaker 03: no criminal penalty under these statutes for doing that? [00:07:17] Speaker 04: Well, there would be under subsection A1 of Title 18, because he's in a place that he is not authorized to be. [00:07:24] Speaker 03: And Mr. Alfred was also- But you don't think it's disruptive for him to go and stand on the floor of the Senate during the vote certification, causing them to stop the certification? [00:07:33] Speaker 04: It might have disruptive effect, but that is a separate element from disruptive conduct. [00:07:40] Speaker 04: And so our position is that [00:07:42] Speaker 04: Because especially in Title 18, where Congress has set out a separate element of the offense, it would be inappropriate to read out the conduct element from the statute. [00:07:53] Speaker 04: Because that statute sets forth, essentially, it sets out a location element. [00:07:57] Speaker 04: And then it sets out three additional elements. [00:07:59] Speaker 04: The first is disruptive intent. [00:08:02] Speaker 04: The second is disruptive conduct. [00:08:04] Speaker 04: And the third is disruptive effect. [00:08:07] Speaker 04: And so the court should give meaning to all three of those elements separately. [00:08:13] Speaker 03: So it seems to me, though, you're saying 1752, you would conflate two elements if you interpret disruptive to mean effect, because then it has to, in fact, impede the proceeding. [00:08:26] Speaker 03: Something can have a disruptive effect but not succeed. [00:08:29] Speaker 03: It could end up not impeding the proceeding. [00:08:32] Speaker 03: So how does that fit with your theory? [00:08:37] Speaker 03: But you could hold up a sign, for example, in the middle of a court hearing or in the middle of a congressional hearing. [00:08:42] Speaker 03: And the hearing can just continue. [00:08:44] Speaker 03: They could ignore you. [00:08:45] Speaker 03: Would you be guilty under that statute? [00:08:48] Speaker 04: Well, potentially, because the statute also covers attempts. [00:08:53] Speaker 04: So if you're doing it with intent to disrupt the proceeding, and you attempt to do so. [00:09:00] Speaker 03: So putting attempt aside, I'm asking you hypothetically, would that be a disruption under the statute? [00:09:07] Speaker 04: No. [00:09:07] Speaker 04: If there's no disruptive effect, then I don't. [00:09:11] Speaker 03: That's a different element. [00:09:12] Speaker 03: Would that be disruptive? [00:09:14] Speaker 03: Put effect aside, put attempt aside. [00:09:16] Speaker 03: Is it disruptive to stand up with a sign that says whatever it says in the middle of a proceeding? [00:09:23] Speaker 03: But the proceeding continues, so it didn't succeed. [00:09:25] Speaker 04: Oh, understood. [00:09:25] Speaker 04: No, Your Honor, we would view that as being not disruptive. [00:09:31] Speaker 03: That seems to be a difficult position to take. [00:09:37] Speaker 04: That holding up a sign during a proceeding is not disruptive? [00:09:40] Speaker 04: Yes. [00:09:41] Speaker 04: Well, Your Honor, we go back to the language of the statute, which has disruptive or disorderly conduct. [00:09:49] Speaker 03: But you can reconcile it with the language if you adopt the interpretation of the government. [00:09:55] Speaker 04: It would be odd to interpret a criminal statute to essentially remove an element of the offense. [00:10:05] Speaker 04: I understand that redundancy appears sometimes in statutes, particularly when you have a series of synonyms or near synonyms and it appears that Congress is trying to cover all its bases. [00:10:18] Speaker 04: But when you have a statute that sets out three separate elements, the best understanding of what Congress was trying to do [00:10:30] Speaker 04: was to require the government to prove three separate elements. [00:10:37] Speaker 04: And I've seen that. [00:10:38] Speaker 04: I've gone over my time. [00:10:40] Speaker 04: And so if the court has other questions, I'm happy to answer them. [00:10:43] Speaker 03: I'm sorry. [00:10:44] Speaker 03: I've taken up all your time. [00:10:45] Speaker 03: I should ask my colleagues. [00:10:46] Speaker 03: Do either of you have any questions? [00:10:49] Speaker 01: I don't have any questions. [00:10:50] Speaker 01: Thank you. [00:10:52] Speaker 03: No, thank you. [00:10:54] Speaker 03: Thank you. [00:10:55] Speaker 03: We'll give you time for rebuttal. [00:11:08] Speaker 00: Good morning, and may it please the court, Eric Hansford of the United States. [00:11:13] Speaker 00: On January 6th, the defendant engaged in disorderly or disruptive conduct by entering the breached Capitol building through a broken open door, undergoing no security screening, and joining the mob that was occupying the building, preventing the electoral certification going forward. [00:11:32] Speaker 00: That conduct fits the plain established meaning of disorderly or disruptive conduct [00:11:38] Speaker 00: And in addition, the defendant's sentence, which was in the lower half of the undisputed sentencing guideline that's undisputed here, was substantive. [00:11:49] Speaker 00: So starting with the disorderly or disruptive conduct issue, as we, I think we collect a lot of citations for this on 31 to 32 of our brief and footnote three, [00:12:02] Speaker 00: These terms are inherently context dependent. [00:12:06] Speaker 00: It makes little sense to think of whether conduct is disorderly or disruptive without considering context. [00:12:13] Speaker 00: And the plain language the case law supports does interpret it that way. [00:12:19] Speaker 00: So disruptive has, in the Supreme Court case, ingrained [00:12:25] Speaker 00: In other cases, the courts in Braunstein have said this is a context-dependent, circumstance-dependent inquiry. [00:12:34] Speaker 00: And then disorderly conduct, which is an old offense and relates back to the common law offense, that likewise depends on context. [00:12:44] Speaker 00: Let me ask you this, Council. [00:12:45] Speaker 03: If we decide that the conduct here is sufficient to prove disruptive, do we have to reach the issue of disorderly? [00:12:53] Speaker 03: No, we do not. [00:12:55] Speaker 03: And is there a preference for whether we reach both issues or just one? [00:13:00] Speaker 00: I don't think it matters to the government as to whether, yeah. [00:13:03] Speaker 00: I don't think we would need double liability for these circumstances. [00:13:09] Speaker 00: So no, I don't think there's a preference in terms of that. [00:13:12] Speaker 00: And I do think disruptive probably is the more straightforward path here. [00:13:17] Speaker 00: But I think, as you've heard this morning, it is hard to understand what it would mean to be inherent [00:13:24] Speaker 00: categorically disruptive or disorderly. [00:13:28] Speaker 00: There's lots of conduct you can think of that is going to be appropriate in certain circumstances. [00:13:34] Speaker 00: This court in Bronstein said a security officer firing a gun during the Supreme Court proceeding isn't disruptive. [00:13:42] Speaker 00: It's meant to protect the court. [00:13:44] Speaker 00: And so likewise, shouting [00:13:48] Speaker 00: is not going to be disruptive if you're at a speech that the president is giving and you're cheering the president on. [00:13:55] Speaker 00: On the other hand, if you are shouting and preventing congressional hearing or the president's speech from going forward, that is disruptive. [00:14:04] Speaker 00: So it is going to be very, very context dependent. [00:14:09] Speaker 00: 1752, I think it's notable, is about secret service restraints. [00:14:14] Speaker 00: So it's not focused specifically on the Capitol in the way 5104 is. [00:14:20] Speaker 00: For example, if you have someone who holds up a boombox blaring sound in the middle of an Iowa cornfield, if the president is giving a speech there, that's disruptive. [00:14:30] Speaker 00: But in the vast majority of circumstances, that's not going to be disruptive. [00:14:35] Speaker 02: So in all of your arguments, [00:14:38] Speaker 02: is not the assumption that there is a passage of time such that a person, a potential defendant has an opportunity to withdraw so that it is not a situation where someone is caught up but not supporting whatever is going on. [00:15:09] Speaker 00: I think it's accurate that a person is not, if this is going to kind of the mere presence idea, I think it's accurate that if you are in a place you are otherwise lawfully allowed to be, somehow a mob comes to you. [00:15:26] Speaker 00: The fact that you happen to be present in that place and the mob has come to you is not going to mean that you are part of the mob and therefore disorderly or disruptive, but as in this case, [00:15:39] Speaker 00: the January 6 cases, when you are entering what's supposed to be a secured building and you are foregoing the security screenings that you obviously know should be there. [00:15:51] Speaker 00: Mr. Alfred, in this case, said he entered through a broken open door. [00:15:54] Speaker 02: Well, counsel, what I'm trying to define is your use and reliance on the word obvious. [00:16:03] Speaker 02: Because some of the appellant's argument, it seems to me, it's the notion that [00:16:09] Speaker 02: one is there for innocent reasons and gets caught up in a situation which that individual is not supporting. [00:16:22] Speaker 02: And I just wanted to clarify, it seems to me that the record here, and we haven't talked about it so far this morning, makes clear that people were on notice [00:16:37] Speaker 02: and had the opportunity to withdraw or never to enter in the first place because of all the signs and the warnings, both the oral warnings that were given at the time prior to the actual breaking and entering. [00:17:02] Speaker 00: So that's right, Your Honor. [00:17:04] Speaker 00: And there was kind of a jury argument as to whether or not [00:17:08] Speaker 00: He was on notice, but he's not pressing that. [00:17:10] Speaker 00: The jury clearly found he was on notice. [00:17:13] Speaker 00: But I think intentionally, or importantly, in terms of your question about accidentally being caught up in this, the statutes, both statutes, have a requirement that there be an intent to disrupt. [00:17:25] Speaker 00: And so this is not a case where you could accidentally stumble. [00:17:28] Speaker 00: I know. [00:17:29] Speaker 02: I'm just trying to focus on how the government might meet its burden of proof. [00:17:38] Speaker 02: Sure. [00:17:39] Speaker 02: The statute says there has to be intent. [00:17:41] Speaker 02: So how do you show intent, for example? [00:17:44] Speaker 00: So I think in this case and in many of these cases, there's lots of kind of prior posts that the defendant has done on social media indicating that, in fact, the intent is to join the efforts to disrupt the election. [00:17:59] Speaker 00: And I do want to note that I think there was the question about the time for, the time at which you're acting. [00:18:08] Speaker 00: There is a difference between disorderly or disruptive conduct and the effect of a disruption, which is that the disorderly or disruptive conduct is a prospective inquiry. [00:18:20] Speaker 00: The question is whether it tends to disrupt or tends to reach the piece. [00:18:27] Speaker 00: classic lax law dictionary of what is disorderly conduct, lots of case law to support that. [00:18:34] Speaker 00: And by contrast, the effect that the result element is retrospectively did in fact a disruption or interruption result. [00:18:44] Speaker 02: So hypothetically, suppose this particular defendant said a lot of things before he got to the Capitol, both before the sixth [00:18:57] Speaker 02: as well as in other contexts. [00:19:05] Speaker 02: But what I'm trying to focus on is, and I'm surprised you haven't grabbed onto this, or maybe I misunderstand what you're trying to emphasize, [00:19:17] Speaker 02: is that this is not a situation where the defendant is being prosecuted because of what he said on January 3rd or January 4th. [00:19:28] Speaker 02: And it's not because of innocent presence, if I can put it that way, because the argument here is mere presence and that normally assumes innocent presence. [00:19:44] Speaker 00: That's right. [00:19:45] Speaker 00: That's exactly right, Your Honor. [00:19:46] Speaker 00: He's not being prosecuted for what he said beforehand. [00:19:50] Speaker 00: He's being prosecuted for his actions on January 6th. [00:19:53] Speaker 00: And I agree that mere presence is probably not really the correct term to use. [00:19:59] Speaker 03: So what's the evidence that supports the sufficiency in this case? [00:20:04] Speaker 00: So the evidence is that he entered through a... [00:20:08] Speaker 00: As to the intent, we've got all these social media posts that we go through in the brief that he is planning to be aware of what's happening with the electoral certification and wanting to disrupt. [00:20:19] Speaker 00: And then on January 6th itself, he enters through what he admits is a broken open building. [00:20:26] Speaker 00: He forgoes the security screenings and he walks through a magnetic, like a metal detector, sets off the alarm as he's walking through it. [00:20:36] Speaker 00: obviously is not going through that security screening, and joins the mob that is occupying Congress. [00:20:43] Speaker 00: And there's testimony in this case that a single unsecured person in the Capitol building forces the Capitol police officers there under Capitol protocols to stop the proceedings from going forward, to stop the hearings, because it's a safety risk, understandably. [00:21:00] Speaker 00: to the members of Congress who are there. [00:21:03] Speaker 00: So that joining of the mob that's occupying the Capitol building is certainly within the plain and established meaning of disorderly or disruptive conduct. [00:21:13] Speaker 00: A report in Washington Mobilization Committee discussed how blocking city streets is a form of disorderly or disruptive conduct that would certainly fit [00:21:27] Speaker 01: So is your position that no one who was in the Capitol that day was there innocently? [00:21:35] Speaker 00: We're not taking a categorical position along those lines. [00:21:41] Speaker 00: So we're not taking a categorical position. [00:21:46] Speaker 01: Well, who would be there innocently in your mind? [00:21:49] Speaker 00: I think it is hard to come up with people actually who were there innocently, but you could have hypothetical [00:21:56] Speaker 00: The security officer who works in a nearby building, who's not associated with the Capitol, who sees the police are overrun, runs in to try to help out the police. [00:22:06] Speaker 00: Something along those lines. [00:22:09] Speaker 00: So you could certainly have circumstances along those lines where people would be there innocently. [00:22:16] Speaker 00: And I think usually the innocence is going to, the innocent person is going to come down to the intent. [00:22:24] Speaker 00: And I think the intent element, the intent to disrupt or the intent to, is going to be doing a lot of work in trying to distinguish between people who are guilty and people who are there accidentally. [00:22:39] Speaker 02: Well, I mean, you might say in addition, I'm sorry, Joe Henderson. [00:22:45] Speaker 01: Well, I was going to say, and you may not know the answer to this. [00:22:49] Speaker 01: So is it your intent [00:22:51] Speaker 01: to prosecute everyone who was in that building that day, every lay person, not law enforcement officers from somewhere else, because no one was there innocently. [00:23:05] Speaker 00: I don't know the answer to that. [00:23:10] Speaker 01: Right. [00:23:10] Speaker 01: I didn't think so. [00:23:11] Speaker 01: OK. [00:23:11] Speaker 00: If there are no further questions from the court, we'd ask this court to affirm. [00:23:22] Speaker 03: Thank you. [00:23:25] Speaker 03: We'll give you two minutes of rebuttal time. [00:23:29] Speaker 04: Thank you, Your Honor. [00:23:29] Speaker 04: I did want to make one clarification regarding the Garner case. [00:23:33] Speaker 04: That was not a case of a constitutional question. [00:23:36] Speaker 04: It was initially brought in that [00:23:39] Speaker 04: But the Supreme Court resolved it on sufficiency of the evidence grounds and said that sitting at a lunch counter, even if you're doing it in a way that has a disruptive effect, even if you intend that disruptive effect, is not disorderly conduct under the Louisiana statute. [00:23:55] Speaker 03: It wasn't a statute about impeding a lunch counter. [00:23:59] Speaker 03: Whereas we're looking at a statute here that's about impeding a congressional proceeding. [00:24:03] Speaker 04: Again, context dependent, correct? [00:24:06] Speaker 04: It was a disorderly conduct statute under Louisiana law that, in fact, in that statute was broader than this one because it prohibited any conduct that had a tendency to disrupt. [00:24:17] Speaker 04: And so it was very similar to this case. [00:24:20] Speaker 04: A lot of other cases at the government sites have a conduct element and an effect element. [00:24:28] Speaker 04: For example, the Bronstein case that my friend just mentioned. [00:24:31] Speaker 03: If I can go back to your Garner example, it seems to me that sitting at a lunch counter is not disruptive. [00:24:38] Speaker 03: What was disruptive is the reaction to them sitting at the counter. [00:24:42] Speaker 03: Isn't that different from what we have here? [00:24:45] Speaker 03: Just sitting in a public accommodation at a lunch counter is not disruptive. [00:24:50] Speaker 03: It's not like going into the floor of Congress during a vote certification. [00:24:56] Speaker 03: In the lunch counter situation, it's the reaction to it that became unruly and disruptive. [00:25:04] Speaker 04: Your Honor, there's no principled way to distinguish the two. [00:25:08] Speaker 04: The breadth of the way the government reads the statute covers any kind of nonviolent direct action that's intended to be disruptive and garner attention. [00:25:19] Speaker 03: It doesn't, not in a baseball stadium, for example. [00:25:22] Speaker 03: It's context dependent. [00:25:24] Speaker 04: I'm talking about nonviolent direct action where a group of people, for example, go sit at a lunch counter where they're told they're not supposed to be. [00:25:35] Speaker 03: There's a hypothetical in the government's brief. [00:25:36] Speaker 03: Somebody goes to a wedding and goes and stands between the bride and the groom when they're supposed to kiss peacefully. [00:25:44] Speaker 03: You don't think that's disruptive? [00:25:46] Speaker 04: It's not disruptive conduct. [00:25:49] Speaker 04: It might have the effect of being disruptive, but it's not disruptive conduct. [00:25:54] Speaker 04: I see that my time is up. [00:25:55] Speaker 04: So if there's no further questions, we ask the court to reverse. [00:25:58] Speaker 04: Thank you. [00:25:58] Speaker 04: Thank you. [00:26:00] Speaker 03: Case is submitted. [00:26:01] Speaker 03: Thank you very much.