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Phase number 23-50-06, Sylvia E. Farrington, Appellant, versus Alejandro N. Mayorkas in his official capacity as the Secretary of the U.S.

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Department of Homeland Security and United States Department of Homeland Security.

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Ms.

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Lies for the Appellant, Mr. Walker for the Appellees.

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Good morning, Your Honors.

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May it please the Court?

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My name is Catherine Lies, and I represent the Appellant Sylvia Farrington.

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I'd like to reserve two minutes for rebuttal.

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The district court's decision to dismiss Ms.

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Farrington's complaint should be reversed for two basic reasons.

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The first is that the court used the higher standard typically used in Rule 56 motions for summary judgment instead of the Rule 12b6 motion standard that should have been applied in analyzing the sufficiency of her claims.

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Second, Ms.

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Farrington

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plausibly alleges several facts that bear upon causation, which is the main reason that we are here today.

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The appellee, FEMA, does not dispute the first two allegations of the claim, one being that Ms.

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Farrington alleged unprotected activity and the second being that she suffered from an adverse action.

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So really, we're here today to discuss causation and whether Ms.

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Farrington sufficiently pledged facts that bear upon causation and pretext.

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So I'm gonna start briefly with...

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the standard issue.

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The district court improperly applied a higher standard of proof used at the motion for summary judgment stage instead of the standard that should have been used for a motion to dismiss.

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In fact, every case cited by the district court was decided at the motion for summary judgment stage or the motion notwithstanding a verdict stage, rule 50 and rule 56, rather than rule 12.

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So FEMA argues that these cases are instructive and we agree they are instructive to show what a plaintiff needs to do to get to a jury trial, not to get to the discovery stage, which is where this complaint should have proceeded.

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Well, they're instructive in that you have to plead facts that, you know, when you review them, take them in the light most favorable to the plaintiff.

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if proven would make a claim.

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Correct.

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And so, to the extent that there's cases out there that talk about what evidence is or is not sufficient, they're going to be relevant to what facts being pled are or not sufficient, right?

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Correct.

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Yes.

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That brings me to my second point, which is the facts that Miss Farrington alleged.

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She alleged facts that directly bear upon causation in this case.

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What's primarily briefed both at the district court level and before your honors

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is an issue of temporal proximity.

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While we admit that there was a large gap between the first EEO complaint that Ms.

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Farrington filed, you have to look at the ongoing continuing acts of protected activity

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that Ms.

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Farrington engaged in.

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So we're looking at not only the first complaint, but also her and her counsel's attempts to argue discrimination as it relates to the initial 2005 EEO complaint.

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So when we're looking at temporal proximity, FEMA repeatedly argues that the time gap is just too large.

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Yes, that may be true, but we're looking at a pattern.

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We're looking at a continued engagement in protected activity, which should have afforded Ms.

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Farrington the protection and thereby shortening the time gap that the court could look at when examining temporal proximity.

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But it goes beyond that, right?

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So we have- Well, for that argument.

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You're the suggestion must be that they're alleged facts of protected activity closer to 2015.

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Correct then the district court gave you credit for and so what are those specific shares so there's a there's a few different operate there's a few different instances that we can look at.

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The first is as it relates to this issue of Miss Farrington's debt so FEMA.

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argues that the reason for Ms.

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Farrington's termination was that she had this outstanding debt that was raised in a background check.

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Throughout that entire process, Ms.

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Farrington and her counsel were opposing the reason for this debt in the first place.

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They were arguing this is because of the original act of discrimination and the agency's ongoing failure

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to abide by the EEOC's order, which is actually continuing to date in the district court.

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So at every, we're not just looking at 2005, we're not just looking at 2012, we're looking at every instance that Ms.

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Farrington and her prior counsel communicated to the agency.

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This is the reason for the debt.

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The reason for the debt is- So if I was going to look in the complaint,

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or the allegation that says we complained about the debt in 2013, 2014, or early 2015, where would I find that?

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So we don't have the exact dates because it was ongoing in every instance, but the... Is there an allegation that it was ongoing?

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Joint appendix page 10 paragraph 28 discusses, so Ms.

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Farrington alleges that the outstanding debt was caused by the financial hardship attributable to the defendant's discriminatory actions and defendant's ongoing failure to comply with the AJ's or the EEOC's order, so.

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They had paid her a substantial amount.

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Yes, that is.

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How much was it?

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I believe it was $410,000 in back pay and a smaller sum in compensatory damages.

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And she's alleging that she has a major credit card debt, notwithstanding having received the bulk of the award.

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Yes, that is correct.

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I don't believe that it's outlined specifically in the complaint in maybe as much detail as it could have or should have been.

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But that back pay award was disputed from the very beginning.

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So that money was not ever touched by Ms.

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Farrington.

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So it's really,

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it yes it is received but she chose not to because it was in dispute it you know i i believe it was the advice of her counsel not to touch the money until the the dispute was resolved and that dispute has not yet been dissolved they weren't claiming that it was going to be clawed back they were claiming that they didn't know her anymore and she was claiming that they did

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In a subsequent proceeding, they did actually argue that they did overpay her and that she owed approximately $100,000.

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So the debate of what she owed and what she may have owed back to the agency was in progress and really never fully resolved up until present date.

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To get back to Judge Garcia's question,

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Where did you say in the complaint that we are engaged in protected activity means saying that that I have a debt that's caused by by a failure to comply with a prior order.

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How does that tell the district court that I'm still engaged in protected activity?

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So it's less so engagement and protected activity, more so opposition to the discrimination.

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So in that sentence that I cited to Judge Garcia on paragraph 28 of the complaint, she talks about the ongoing failure and her efforts to

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get the EEOC to comply with the order.

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So no, she did not necessarily engage in productive activity aside from the two EEO complaints, but she consistently opposed the debt as it related to the underlying discrimination that occurred.

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But we don't have any timing on paragraph 28, nor

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who the explaining was directed at.

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So as explained by Ms.

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Farrington and her attorney, the outstanding debt was caused by the financial hardships directly attributable to the defendant's discriminatory action, defendant's ongoing failure to comply with the AJA order, as well as the unfair and unlawful predatory lending practices.

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Is there any allegation that Fima was told that that was her view?

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There are no other allegations in the complaint, no.

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Does that even allege that she told Fima this is why I have this big debt?

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I believe that is alleged in the next paragraph.

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I think it's sort of undermined by the next paragraph.

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Her explanations are supported by her credit report, but, oh, this was visible to defendants, personnel, security officers.

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She's saying that the credit report showed the defendants, but it doesn't show the reasons that she's asserting.

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Right.

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And that is accurate.

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Those are the few sentences that bear upon the issue that we are discussing.

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Just to probe this a little bit more.

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Her view is that this is enmeshed with the past discriminatory action on FEMA's part and her opposition to it because it is her view that the reason she's in such deep debt is that the prior case has not really been resolved and that she is complaining that the prior case

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has not been satisfactory result.

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And therefore, that's her opposition to the defendants on lawful conduct.

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And that is the locus of their retaliation against her.

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Yes.

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Yes, that is correct.

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The overarching theme that she presents is that this is a coordinated, concurrent act that you can't really separate the two.

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started with this first EEO complaint in 2005 that led to her being demoted, led to her being in a financial state that incurred such debt throughout the decade and a half that followed.

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She worked with several attorneys.

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She worked with FEMA to get that issue resolved and

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It never, it never truly was.

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Is there an allegation that when Barrington obtained a favorable resolution of her dispute with Chase that she communicated that to FEMA basically saying, you know, they were wrong.

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I was right.

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And that's been resolved.

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I believe that was communicated in her appeal of the termination that came in 2015.

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She explained the debt's been resolved.

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This is the reason for the debt.

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And again, reiterated her discriminatory allegations through that written appeal.

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But that was obviously after the decision had been made to terminate her employment.

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So to the extent, I guess I'm just trying to understand, to the extent that the, and I take you to acknowledge that it's legitimate for FEMA to have the credit check, that that is otherwise a legitimate non-discriminatory criterion.

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And that she didn't meet it at the time when they're reviewing her

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Yeah, that's correct.

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And on the report that FEMA was able to see, it said that it was in dispute.

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So they had an understanding.

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They have the right, sure, to conduct this background check as part of their standard business practices.

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They were aware, though, that this was a debt that was in dispute.

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And it wasn't just that she went and put her hands up and let them figure it out.

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She did communicate, this is why I'm in this debt.

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This is why maybe perhaps hindsight is 20-20.

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She could have been more explicit at the time.

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But looking from where we are today, what you described is accurate in terms of the time frame.

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Do you, and there's nothing alleging that she told them that because what she'd already been paid was still in dispute, that she didn't feel free to spend it.

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And if you think about what they did know, they've given you a few hundred thousand dollars over a short period of time, that's gone to zero, and you have this debt, and yeah, you're saying it's the bank's fault, but how often do people prevail against the bank?

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As it happens, she prevails against the bank.

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And as it happened, you give an explanation why, notwithstanding that she had a large sum of money, that she's nonetheless running a major debt.

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But I didn't see allegations that they knew that.

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I think that's correct.

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I don't know that she communicated her plan not to spend the money that was given to her.

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However, it's been subject to,

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I want to say a dozen litigations over the course of the last 10 years in district court.

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So maybe at that moment, they were not aware of what the plan was in terms of the money, but certainly within a year, litigation ensued and it became clear that that money was very much in dispute.

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So in your opening brief, you framed a version of this as that the FEMA stated reason for firing her was pretextual.

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The government pointed out you didn't raise that type of argument below and you didn't respond to this point in the reply brief.

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So I just wanted to ask if you are

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Do you have any dispute with the government's position that you forfeited this, or are you otherwise abandoning that version of the argument?

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Certainly.

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So we did raise that in the opposition brief at the district court level.

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It's cited in the Joint Appendix 101, 102.

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the district court cites the three additional arguments that we make to pretext and list those three arguments.

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So we are not forfeiting those arguments.

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In fact, I think the pretext argument is stronger than maybe the temporal proximity argument and the fact that the agency did not terminate Ms.

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Farrington for two years after

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she was found to be unfit for service.

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They could have, maybe they should have terminated her as soon as they got that fitness, the negative suitability determination, but they waited two years.

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So that begs the question as to, did they reasonably believe that just because Ms.

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Farrington had that debt, that she was unfit for service?

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I think that's a question of,

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that goes to pretext and it goes to credibility.

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However, to your point in the briefs before your honors, temporal proximity was the large focus of the arguments.

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I heard you to say that the district court thought you had made an argument based on the delay, the two and a half year delay in firing her based on the fitness determination.

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Yes, that's correct.

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And it's in our it's in the amended complaint of paragraph 37 and 30 3740.

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Yes, I'm asking about I didn't see it in your opposition to the motion dismissed and I didn't see it in the district court.

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So you're you were directing me to 101 and 102 and

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I don't see them addressing the district.

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Sure.

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So it's at the bottom of 101 into 102, where the district court goes into the three arguments that were raised on pretext.

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I mean, I will say it's not a lengthy analysis by either the district court or by Ms.

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Farrington in the lower court.

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But we do preserve those arguments and think that there are some merit to them that would warrant the case to move forward to discovery if your honors would reverse and remand the district court decision.

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Thank you.

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All right.

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Mr. Walker.

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Good morning, Your Honors.

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May it please the Court, Johnnie Walker, for the Secretary of Homeland Security.

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The District Court correctly dismissed Ms.

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Farrington's retaliation claim because her complaint draws no causal connection between the protected activity that she began in 2005 and her eventual termination a decade later in 2015.

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She acknowledges in her complaint that a routine background investigation uncovered that she had $65,000

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delinquent debt to her mortgage lender and that this led to a determination by FEMA's personnel security staff that she was not suited to continued federal services, federal service.

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She provides no plausible allegations that would indicate that her later termination was anything but the necessary consequence of that unsuitability determination.

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For that reason she has not established the causal connection between

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protected activity and adverse employment action that this court's case law requires, and the district court's order dismissing this case should be affirmed.

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I'm happy to answer any questions the court may have.

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I mean, isn't it readily apparent that she was challenging and that there was even other litigation involving whether FEMA has

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complied with the prior relief that she had obtained.

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There was certainly ongoing litigation dating back to 2005 that continues to this day in a case in the district court over that initial 2005 discrimination complaint.

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But what she does not allege is any particular protected activity by her during the course of that event that was proximate in cause to the adverse employment action.

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I mean, she's opposing an unlawful employment

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action, and she's continuing to oppose it because she's saying it hasn't been fully remedied.

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And I guess it seems a little semantic to say, well, she's not opposing any unlawful employment action.

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She got an award, and she's saying, in her view, it hasn't been fully remedied.

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So that is ongoing opposition to an not yet fully remedied

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unlawful employment action, no?

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It is certainly ongoing opposition, but there's no temporal proximity to a specific act that would give rise to an inference of retaliation.

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So what this court looks at.

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Temporal proximity to her then being fired.

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The being terminated needs to be temporally proximate to some particular protected activity.

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Ongoing opposition to the agency's failure to, in her view, fully remedy

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the established unlawful conduct of the agency in the past.

[00:20:41] Speaker 01:
But what this court's cases look at is temporal proximity to some particular action by the individual, such that there could be.

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Or not some ongoing action?

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No, not some ongoing action.

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It doesn't have to be the initial discrimination complaint.

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So what if somebody is harassing someone over a period of time?

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I mean, that's ongoing.

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And the fact that it began more than 10 years ago wouldn't

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mean that there's no temporal proximity.

[00:21:07] Speaker 01:
Well, it would have to be temporal proximity to some particular oppositional or otherwise protected action.

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And you don't think that maintaining a claim is a particular opposition

[00:21:20] Speaker 01:
No, Your Honor, and that's not what the cases look at.

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If you take a look at this court's recent decision in Hoe versus Garland, I mean, there was ongoing litigation there, and the court drew temporal proximity to the filing of an actual formal discrimination complaint.

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And I think there's very good reason for that, because when you have this ongoing decade-long course of background litigation, and the agency takes no action for a decade, and then terminates her a decade after that has been ongoing for 10 years,

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the opposite inference has to be drawn, that there is some other cause that gave rise to that termination other than the ongoing background litigation that's been... I appreciate your...

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your suggestion that an opposite inference needs to be drawn.

[00:22:01] Speaker 04:
An opposite inference might be permissible by a fact finder, but it's hard for us sitting here to say which inference in this complicated, thorny, ongoing, contentious relationship, which inference to draw.

[00:22:17] Speaker 01:
Well, I think you have to think about the underlying reasons why the court draws an inference from temporal proximity.

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And the reason is because a supervisor becomes aware of protected activity and then suddenly takes an action within a very short period of time.

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This court generally says within three or four months.

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It's inconsistent with the supervisor's prior actions.

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And so there, when you have that kind of temporal proximity,

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there's a reasonable inference that can be drawn that that new knowledge was the basis for the new course of activity.

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Here you have ongoing litigation that's been in place for over a decade.

[00:22:52] Speaker 01:
There's no reason that these personnel security staff members and HR staff members suddenly gained knowledge of this at the time that they took the actions.

[00:22:59] Speaker 01:
In fact, the only allegations about knowledge that Ms.

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Farrington alleges is that these individuals may have known about this because FEMA was required to post it throughout its offices.

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after she obtained her award back in 2008.

[00:23:11] Speaker 01:
So there's no sort of like sudden change in circumstance or sudden gaining in knowledge that this.

[00:23:19] Speaker 02:
Should work if it said hypothetically at about this time.

[00:23:26] Speaker 02:
Miss Farrington filed an opposition to motion for summary judgment and then the supervisor became aware of that and then you maybe you could measure temporal proximity from that.

[00:23:35] Speaker 02:
Is that what you're saying?

[00:23:35] Speaker 02:
We need some kind of specific protected activity allegation.

[00:23:39] Speaker 01:
Yeah, it could be.

[00:23:39] Speaker 01:
I think you need some kind of specific protected activity litigation.

[00:23:42] Speaker 01:
The fact that there's just ongoing background litigation, then the two or three month benchmark really means nothing, right?

[00:23:48] Speaker 01:
Because she's engaging in litigation over the course of a decade, there's always going to be the two or three month.

[00:23:53] Speaker 01:
But there has to be an event followed closely by an adverse personnel action.

[00:23:58] Speaker 03:
Kind of counter to the old adage that revenge is a dish best served cold.

[00:24:04] Speaker 01:
Exactly.

[00:24:05] Speaker 01:
I think so.

[00:24:05] Speaker 01:
I mean, the opposite notion of that is precisely what the temporal proximity inference is built upon, I think.

[00:24:12] Speaker 01:
The fact that there is a change in circumstance, that there's a knowledge of protected activity and then followed closely by a change in circumstance.

[00:24:20] Speaker 01:
Here, as alleged, there is knowledge dating back to 2008 and no change in circumstance until 2013 when she's deemed unsuitable and 2015 when she's removed.

[00:24:32] Speaker 04:
What about that two-year gap?

[00:24:34] Speaker 04:
It's a little hard to understand.

[00:24:36] Speaker 04:
Ms.

[00:24:36] Speaker 04:
Barrington argues that the adverse fitness determination is seized upon as a pretext to terminate her.

[00:24:46] Speaker 04:
If they really cared about it, they would have done it earlier.

[00:24:49] Speaker 04:
What about the two-year gap?

[00:24:54] Speaker 01:
I understand 2 years seems like a long time.

[00:24:56] Speaker 01:
It's not such a long time when it comes to federal personnel actions.

[00:24:59] Speaker 01:
She certainly hasn't alleged anything indicating that the amount of time that it took was atypical or delayed for any improper purpose.

[00:25:07] Speaker 01:
And again, I think that the only inference that can be drawn from the amount of time that the agency took to finalize its action is that this was not being used as pretext, that the delinquent debt was not being used as pretext to terminate Ms.

[00:25:19] Speaker 01:
Farrington because that amount of time just gave her additional time in which to resolve her debt and bring that to the agency's attention.

[00:25:25] Speaker 02:
So why is that?

[00:25:27] Speaker 02:
I mean, it's the exact same amount of time since her undisputed last protected activity, which is 2012.

[00:25:34] Speaker 02:
And you're saying,

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It's plausible that her argument is the fact you waited two and a half years means you didn't really believe in the reason you gave.

[00:25:46] Speaker 02:
No one actually cared about this lack of fitness determination.

[00:25:49] Speaker 02:
And there seems like there's something to that.

[00:25:51] Speaker 02:
Why would you let this person continue having access to government systems, et cetera, et cetera, for two and a half years?

[00:25:58] Speaker 02:
Why isn't that a plausible interpretation of what's going on?

[00:26:05] Speaker 01:
But, well, again, because she has not alleged anything that would indicate that the amount of time was atypical or otherwise delayed for any improper purpose.

[00:26:11] Speaker 01:
As we note in our brief, she doesn't, she is a temporary employee with FEMA.

[00:26:14] Speaker 01:
She's a reservist.

[00:26:15] Speaker 01:
So she is deployed to various disaster situations when the need arises.

[00:26:20] Speaker 01:
And as we note that she has not alleged that she was actually deployed by FEMA between the time that she got the initial letter of concern, or I think she did between the letter of concern and the actual unsuitability determination.

[00:26:30] Speaker 01:
But after the unsuitability determination, there's no allegation that she actually deployed for FEMA during the period of time between then and her termination.

[00:26:36] Speaker 04:
She wasn't actually in the ways that we would think of like going to work or having access to a FEMA credit card.

[00:26:42] Speaker 04:
She wasn't actually in a position to use it.

[00:26:47] Speaker 04:
The FEMA credit card or?

[00:26:48] Speaker 01:
I think she does allege that she received a FEMA credit card.

[00:26:51] Speaker 01:
Her credit worthiness is a completely different inquiry from her suitability.

[00:26:56] Speaker 01:
The government doesn't extend the line of credit.

[00:26:58] Speaker 01:
So whether or not the contractor that the government uses to provide government credit cards saw fit to extend the line of credit to her is a completely different inquiry from whether or not she is, the delinquent debt allows her to remain suitable for federal employment.

[00:27:12] Speaker 01:
I guess she does not dispute that a delinquent debt is a factor in suitability to federal employment.

[00:27:17] Speaker 01:
She does not dispute that her debt was well over FEMA's debt threshold.

[00:27:20] Speaker 01:
And she does not dispute that that type of unsuitability determination is grounds for removal.

[00:27:26] Speaker 04:
She does.

[00:27:26] Speaker 04:
I think she alleges that she participated in some paid trainings between the time of the unsuitability determination and the time that she was formally terminated.

[00:27:37] Speaker 04:
How can we not see that as

[00:27:42] Speaker 04:
supporting her notion that FEMA didn't really, wasn't really alarmed by this.

[00:27:48] Speaker 04:
Yeah, I think participating in unsuitability, that's yours.

[00:27:53] Speaker 01:
Again, the real reason that the delay is not grounds for FEMA not taking it seriously is because she has not alleged that it was atypical.

[00:28:00] Speaker 01:
But in addition, I think that

[00:28:02] Speaker 01:
participating in some paid trainings, getting paid to do a remote training or something like that for FEMA is completely different in kind from being deployed and holding yourself out as a federal employee.

[00:28:12] Speaker 01:
The suitability determinations are to ensure that the public views its federal employees as possessing integrity, being efficient, and so allowing her to do training when not necessary.

[00:28:22] Speaker 02:
Why would we think two and a half years is typical?

[00:28:24] Speaker 02:
I mean, literally what happened here is a new supervisor came in.

[00:28:28] Speaker 02:
And maybe she was doing everything right, but it took her four months to discharge her based on this lack of fitness finding.

[00:28:34] Speaker 01:
Yes, but there's no allegation that the new super fit.

[00:28:36] Speaker 01:
And that's where I understand her argument about the delay to really come into play is that is that it shows that she was terminated at the first opportunity by this new supervisor.

[00:28:45] Speaker 01:
But she doesn't allege anything indicating that that new supervisor was the impetus for the termination or that the new supervisor would have any reason to be.

[00:28:53] Speaker 01:
uh, possessed retaliatory animus against her.

[00:28:55] Speaker 01:
Certainly the supervisor was not involved in any way or implicated in any way in the prior protected activity from 2005 over a decade ago.

[00:29:03] Speaker 01:
In fact, she alleges exactly the opposite.

[00:29:05] Speaker 01:
She out.

[00:29:06] Speaker 01:
She alleges that a representative from the Human Resources Department named Miss Silva contacted her supervisor and advised her that she needed to terminate Miss Farrington immediately due to the unsuitability determination.

[00:29:18] Speaker 04:
Why is it that this litigation, the underlying litigation has been continuing for so long?

[00:29:24] Speaker 04:
2008, there's an order.

[00:29:29] Speaker 04:
That can't be resolved.

[00:29:34] Speaker 01:
I'm thankfully to report that in the last status report, the parties have reported that they have finally resolved their dispute about the back pay.

[00:29:41] Speaker 01:
There's some additional details to work out.

[00:29:44] Speaker 01:
But the reason that it lasted so long, I think, is that there was some remands to the EEOC to clarify some of its orders.

[00:29:52] Speaker 01:
So you had a whole other round of administrative proceedings that took place after that.

[00:29:55] Speaker 01:
And then the parties went back to just report after that.

[00:29:57] Speaker 01:
But that is a long litigation.

[00:29:59] Speaker 01:
The government is happy to see it coming to a close.

[00:30:06] Speaker 01:
Thank you very much.

[00:30:07] Speaker 01:
Please affirm.

[00:30:11] Speaker 04:
Ms.

[00:30:12] Speaker 04:
Lees, have any rebuttal time?

[00:30:15] Speaker 04:
We'll give you two minutes.

[00:30:19] Speaker 05:
Thank you, Your Honors, and I'll just touch upon a few points.

[00:30:24] Speaker 05:
First is in regards to the two-year period.

[00:30:27] Speaker 05:
I do think that is very crucial, or two-and-a-half-year period.

[00:30:30] Speaker 05:
I think one of you were referring to Joint Appendix, page 11, paragraph 34, and that sort of describes

[00:30:40] Speaker 05:
At two and a half year period where miss Harrington was receiving requests, you know, for deployment, regardless of whether she actually did deploy participating in trainings and was listed as available for for deployments in in the agency system.

[00:30:56] Speaker 05:
So, you know, my experience in the federal sector, as soon as someone becomes found to be unsuitable for federal government employment, typically the removal action happens relatively quickly.

[00:31:12] Speaker 05:
So the two and a half year period is something that we think is extremely relevant for the court to consider.

[00:31:18] Speaker 05:
A second point is the fact that there was a new supervisor who did act at the first opportunity within four and a half months of becoming her supervisor.

[00:31:28] Speaker 05:
And I just want to point out that we have now discussed temporal proximity.

[00:31:34] Speaker 05:
We have discussed

[00:31:35] Speaker 05:
that the proffered reason is unworthy of belief.

[00:31:38] Speaker 05:
We have discussed the supervisor change in the first opportunity to retaliate.

[00:31:44] Speaker 05:
So all of these, we've discussed the knowledge that all of these agency officials have had of her ongoing EEO activity.

[00:31:51] Speaker 05:
So based on all of those

[00:31:54] Speaker 05:
factors either taken separately or better taken us as a whole.

[00:31:58] Speaker 05:
We believe that Miss Farrington has alleged more than sufficient facts to withstand the motion to dismiss stage and allow her case to move forward to discovery to really flesh out some of the factual questions that still remain dispute.

[00:32:13] Speaker 05:
Thank you.

[00:32:14] Speaker 04:
Cases submitted.