[00:00:10] Speaker ?:
Thank you.

[00:00:38] Speaker 03:
Our final case this morning is number 15-5118, Knot versus United States, Mr. Maloney.

[00:00:46] Speaker 01:
Thank you, Your Honor.

[00:00:52] Speaker 01:
May it please the Court, I represent the plaintiff appellants here who were victims of government negligence not once but twice.

[00:00:59] Speaker 01:
First, when a drunken army soldier drove his army truck across the WL line,

[00:01:05] Speaker 01:
and had a head-on collision with Mr. James Nutt Sr.

[00:01:08] Speaker 01:
killing him.

[00:01:09] Speaker 01:
He left behind a young widow and a two-year-old son.

[00:01:12] Speaker 01:
The government correctly settled that case fairly quickly.

[00:01:16] Speaker 01:
The second victimization that my clients have experienced at the hands of the government was the breach of a settlement.

[00:01:21] Speaker 03:
It's not victimization.

[00:01:23] Speaker 03:
It's just a question.

[00:01:24] Speaker 03:
We've got a contract issue.

[00:01:25] Speaker 01:
We have a contract issue.

[00:01:26] Speaker 01:
That's right, Your Honor.

[00:01:27] Speaker 01:
You didn't run your client.

[00:01:28] Speaker 01:
The Federal Tort Claims Act was a final and conclusive settlement.

[00:01:33] Speaker 01:
What is pending before the court today is a breach of that settlement agreement, a breach of contract.

[00:01:38] Speaker 01:
And as this court has held many times, the analysis begins with the four corners of the document, and you look at the language, determine whether or not it's plain and unambiguous.

[00:01:47] Speaker 03:
Yeah, and your problem, it seems to me, is that unlike the Massey case, there is language here saying that the payments that the government is going to make to your client and to the insurance company and to the lawyers

[00:02:03] Speaker 03:
was a complete settlement.

[00:02:06] Speaker 03:
That language does not appear in the Massey agreement.

[00:02:11] Speaker 03:
This is on page 27.

[00:02:14] Speaker 01:
Page 27 of the appendix

[00:02:19] Speaker 03:
And that's setting forth a provision from the agreement.

[00:02:23] Speaker 03:
That's what's labeled 11 in the left-hand column.

[00:02:27] Speaker 03:
It says the payments by the United States set forth above shall operate as a full and complete discharge of all payments to be made.

[00:02:33] Speaker 03:
That's right.

[00:02:34] Speaker 03:
And the payments that are listed up above are payments to the insurance company, initial payments to the client, and so on and so forth.

[00:02:42] Speaker 01:
Well, Your Honor, it is substantially the same as the contract that we saw in the Massey case.

[00:02:48] Speaker 03:
What that's referring to is... That language does not appear in the Massey contract.

[00:02:51] Speaker 01:
I understand, Your Honor.

[00:02:52] Speaker 01:
That language that you just read speaks to payments being all the payments above, which include the periodic payments that are an express material part of this contract.

[00:03:03] Speaker 01:
So that includes the lump sums that you referred to.

[00:03:07] Speaker 01:
It also includes the periodic payments.

[00:03:09] Speaker 03:
They use the mandatory language of... Well, I don't think it includes the periodic payments because it's saying the payments by the United States.

[00:03:17] Speaker 01:
That's right.

[00:03:18] Speaker 01:
This is a contract.

[00:03:19] Speaker 03:
The United States is making a payment to the insurance company, right?

[00:03:23] Speaker 01:
Well, it doesn't say who the insurance company is going to be or how much they're going to pay the insurance company.

[00:03:30] Speaker 01:
The express terms of this contract, and the contract is only between the government and the Nutt family, not the insurance company.

[00:03:36] Speaker 03:
They're not part of this contract.

[00:03:38] Speaker 03:
Well, the contract says that they'll have standing to sue the insurance company.

[00:03:43] Speaker 01:
That's right.

[00:03:44] Speaker 01:
They would have standing to sue, but it does not say,

[00:03:47] Speaker 01:
The government's off the hook.

[00:03:49] Speaker 01:
In other words, it doesn't say you give up your rights to sue us here.

[00:03:51] Speaker 01:
If they wanted that, they should have said that.

[00:03:53] Speaker 01:
They should have expressed that in the contract.

[00:03:55] Speaker 01:
They didn't do that.

[00:03:57] Speaker 02:
Has the insurance company been sued?

[00:03:59] Speaker 01:
The insurance company's out of business.

[00:04:01] Speaker 01:
They liquidated.

[00:04:01] Speaker 01:
There's no point in doing that.

[00:04:04] Speaker 01:
They took all their funds and put it into a receivership.

[00:04:07] Speaker 01:
This family's getting about 45% of the money that was promised to them, and it was expressly articulated in these periodic payments in this contract.

[00:04:17] Speaker 02:
How do you deal with the fact that the Massey case, in that case, the contract twice had language about how the payments were guaranteed.

[00:04:26] Speaker 02:
And it said it not once, but twice, I think.

[00:04:30] Speaker 02:
How do you deal with that and the absence of any similar language in the contracted issue here?

[00:04:34] Speaker 01:
Well, we do have similar language about, I think, approximately half a dozen times.

[00:04:40] Speaker 01:
The Nutt family shall be paid.

[00:04:43] Speaker 01:
It says the government and the annuity that they get will pay.

[00:04:46] Speaker 01:
It doesn't tell the Nutt's or anybody that reads this contract what happens if the insurance company defaults, other than they have a right to sue that insurance company.

[00:04:55] Speaker 02:
And then the United States would also be involved in that.

[00:04:58] Speaker 01:
That's correct.

[00:04:59] Speaker 01:
That's correct.

[00:05:00] Speaker 01:
They may have the ability to delegate, but that doesn't remove their obligation.

[00:05:03] Speaker 01:
If I could read just a quote from the Massey opinion,

[00:05:08] Speaker 01:
Judge Mayer actually wrote it, and it was a great analysis.

[00:05:12] Speaker 01:
It says, we cannot agree with the government's interpretation.

[00:05:14] Speaker 01:
And the court was looking at the interpretation of the contract, very, very similar language here, which is no surprise.

[00:05:21] Speaker 01:
It's the same defendant and the same people that are writing these contracts and using the same broker and using the same annuity company.

[00:05:28] Speaker 01:
And the court said, the language specifying that the annuity will result in distributions, we have that in our case, and that the disbursements shall be paid

[00:05:38] Speaker 01:
we have that language in our case, is unambiguously mandatory and says unequivocally that the masses must receive the payments.

[00:05:46] Speaker 01:
We have that language in our contract.

[00:05:48] Speaker 01:
The government urges an interpretation of these terms that is at odds with their plain meaning.

[00:05:53] Speaker 01:
Because the payments are mandatory, the government must be responsible for their payment.

[00:05:58] Speaker 01:
No one else is a party to the agreement, although the government may delegate its duties under the agreement to another entity, such as executive life insurance company,

[00:06:08] Speaker 01:
This delegation does not absolve it of its obligations.

[00:06:12] Speaker 01:
I couldn't have said any better.

[00:06:14] Speaker 01:
That is exactly what we have here.

[00:06:16] Speaker 01:
The language is substantially the same.

[00:06:18] Speaker 01:
It shows a mandatory obligation.

[00:06:20] Speaker 01:
If there is a latent ambiguity, this court's already held, that's going to be construed against the drafting government party in this case, not against the nuts.

[00:06:28] Speaker 03:
The interpretation that- Yeah, but we've said that canon is a last resort if you can't figure out what the meaning of it is without it.

[00:06:37] Speaker 01:
That is true, Your Honor.

[00:06:38] Speaker 01:
I think that you don't need to go that far.

[00:06:40] Speaker 01:
I don't think you need to look at parole evidence here.

[00:06:43] Speaker 01:
I think if you look at the plain meaning of the language here, it's mandatory and obligatory.

[00:06:49] Speaker 01:
Exactly the same language on these particular terms was used in the Massey decision.

[00:06:54] Speaker 01:
The government in this case is trying to distinguish Massey by saying, well, this is a Federal Tort Claims Act case.

[00:07:01] Speaker 01:
That was a Military Claims Act case.

[00:07:03] Speaker 01:
And there's a difference.

[00:07:04] Speaker 01:
I think it's a distinction without a difference.

[00:07:07] Speaker 01:
The government came to this court in the Massey case and argued the court didn't have jurisdiction because it was a military claims act case.

[00:07:14] Speaker 01:
The court said, we're not disagreeing with that, but this is no longer a military claims act case.

[00:07:19] Speaker 01:
This is now simply a breach of contract case.

[00:07:22] Speaker 01:
That's what we have here today.

[00:07:23] Speaker 01:
It's no longer a Federal Attorney Claims Act case.

[00:07:26] Speaker 01:
That claim was extinguished.

[00:07:28] Speaker 01:
There was a final judgment on it.

[00:07:31] Speaker 01:
And now we have simply a breach of contract.

[00:07:33] Speaker 01:
And I think you need to look no further than the terms that were used in the contract itself and the meaning, certainly the intent.

[00:07:41] Speaker 01:
Even the government wouldn't argue the intent was otherwise.

[00:07:43] Speaker 01:
The intent was to make sure that she was guaranteed payments under the schedule that's expressly articulated in the contract.

[00:07:50] Speaker 01:
the Nutt family, how they read it, how the lawyer that represented at the time read it, and I think even how the government read it.

[00:07:56] Speaker 01:
What is unsaid here is what happens in the case of default in terms of the government's obligations.

[00:08:01] Speaker 01:
This court has already ruled on that in the Massey decision, because those terms are substantially the same terms that we see here.

[00:08:10] Speaker 01:
You had striking similarities as a personal injury.

[00:08:14] Speaker 01:
The Massey case was a personal injury case against the Navy for

[00:08:19] Speaker 01:
a Navy doctor.

[00:08:21] Speaker 01:
We have an Army official here who was negligent.

[00:08:24] Speaker 01:
In the Massey case, they purchased the annuity.

[00:08:26] Speaker 01:
The total amount was unknown, same as we have here.

[00:08:29] Speaker 01:
They didn't discuss what the purchase price of the annuity was in the contract in Massey, nor did they say that here.

[00:08:34] Speaker 01:
They're substantially the same.

[00:08:37] Speaker 01:
The Massey decision is binding on the government and the court below in this case.

[00:08:44] Speaker 01:
I can address some of the other government's arguments, but I don't think we get to those.

[00:08:47] Speaker 01:
We need not get to those unless the court believes that parole evidence is necessary.

[00:08:53] Speaker 01:
And according, I'd like to reserve the rest of my time for rebuttal.

[00:08:57] Speaker 03:
OK, thank you.

[00:09:05] Speaker 03:
Mr. Majeres.

[00:09:06] Speaker 03:
Thank you, Your Honor.

[00:09:10] Speaker 03:
Let me tell you, I'm a little troubled by your brief, because you cite a couple of cases for the proposition that under the Federal Tort Claims Act and cases involving settlements, that it can't be paid in installments.

[00:09:27] Speaker 03:
And you cite the Riley case and the Vanahoy case.

[00:09:30] Speaker 03:
Those cases specifically say that you can structure a settlement with payments over time.

[00:09:35] Speaker 03:
So long as- You didn't disclose that in your brief,

[00:09:39] Speaker 03:
I think is an obligation that you had.

[00:09:43] Speaker 00:
Yes, Your Honor, and we weren't intending to mislead the court.

[00:09:45] Speaker 00:
But what those cases held is that once the government's obligation is extinguished, the courts can then fashion a periodic remedy through installment payments, through a trust created by the court.

[00:09:56] Speaker 03:
And if I could direct your court specifically to the cases you referenced, I'd- They say that Riley says periodic damages of words are permissible in lieu of lump sums in certain situations.

[00:10:06] Speaker 03:
And it also says that the outcome can be achieved by agreement of the parties.

[00:10:11] Speaker 00:
It also says, though, that Congress has never enacted legislation permitting the routine imposition of structured payments.

[00:10:16] Speaker 03:
I don't think you're addressing my point.

[00:10:19] Speaker 03:
These cases say specifically that you can have a structured settlement with payment over time, right?

[00:10:25] Speaker 00:
They do if the government's obligation is extinguished at the time of settlement or judgment.

[00:10:31] Speaker 00:
And that's consistent with what the whole case said, whole by whole, which is 971 federal

[00:10:37] Speaker 03:
uh... register second fourteen ninety nine they said we agree the courts cannot subject the government to ongoing obligations like the continues in those cases say the government can agree to make payments over time itself they say what they stand for is that the court no no answer my question those cases say that the government construct for a settlement whereby the government is obligated to make payments over time

[00:11:02] Speaker 00:
only if the obligation of the government is extinguished at the time of judgment or settlement.

[00:11:07] Speaker 03:
What obligation?

[00:11:07] Speaker 03:
The obligation to pay over time is not extinguished.

[00:11:11] Speaker 00:
The Federal Tort Claims Act has been interpreted by virtually every circuit in the country to say... I think you understand my point.

[00:11:17] Speaker 03:
I think that it was not appropriate for you to fail to recognize that those cases are potentially inconsistent with your position.

[00:11:26] Speaker 03:
But go ahead with your argument.

[00:11:27] Speaker 00:
My apologies, Your Honor.

[00:11:28] Speaker 00:
That was not our intent.

[00:11:29] Speaker 00:
The distinction in Frankel, the court held, that unless Congress authorizes a different type of award, the only type of damages under money damages under section 1346 can be maximum lump sum payments that satisfy the maximum financial obligation at the time of judgment.

[00:11:46] Speaker 03:
But you can enter into a settlement that provides for payment over time, and that's all that's involved here.

[00:11:52] Speaker 00:
You cannot because of section 28 USC, section 2672.

[00:11:57] Speaker 00:
That statute says that settlements can only be paid like judgments.

[00:12:03] Speaker 00:
The circuits across the country that the money damages in section 1346 can only constitute damages that result in the maximum financial obligation of the government extinguishing a judgment and settlement.

[00:12:20] Speaker 00:
Now, courts later, as Your Honor noted, like Riley and Whole v. Whole, and also Cebula, which we cite,

[00:12:26] Speaker 00:
They allowed for installment payments as long as the government's financial obligation was extinguished.

[00:12:33] Speaker 03:
Their obligation to make the installment payments is not extinguished?

[00:12:37] Speaker 03:
What are you talking about?

[00:12:39] Speaker 00:
Because they all say, just to give a few examples, again, Riley says Congress has never enacted legislation permitting routine imposition of structured payments on the government.

[00:12:48] Speaker 00:
Whole by whole, again, said the courts cannot subject the government to ongoing obligations.

[00:12:53] Speaker 00:
And then in discussing the Frankel case, which is the seminal case

[00:12:56] Speaker 00:
you know, in this line, they noted that two rationales were employed there and they adopted them.

[00:13:01] Speaker 00:
The primary one being that the federal waiver of sovereign immunity, I'm quoting from the case, under the FGCA incorporates the traditional common law principle that awards and civil suits must take the form of common law money judgments.

[00:13:14] Speaker 00:
So in terms of structuring payments down the road, these cases I've held, yes, there can be installment payments.

[00:13:20] Speaker 00:
But the government's obligation has to be extinguished at the time the case is over.

[00:13:22] Speaker 03:
Well, not to make the installment payments, right?

[00:13:26] Speaker 03:
They say you can agree to make installment payments.

[00:13:29] Speaker 03:
Those are payments by the government.

[00:13:31] Speaker 03:
The obligation to make the installment payments is not extinguished.

[00:13:34] Speaker 00:
And they're done as a remedy to assist and to provide payments periodically.

[00:13:39] Speaker 00:
But that doesn't change the fact that under the FTCA, the government's obligation has to be finished at the time of settlement and judgment.

[00:13:45] Speaker 03:
Well, except where there's a settlement.

[00:13:46] Speaker 03:
And then they can agree to make payments over time.

[00:13:48] Speaker 03:
And if they don't, they can be sued.

[00:13:50] Speaker 03:
Those cases recognize that explicitly.

[00:13:54] Speaker 00:
Here's the reason they don't, because again, 2672 says that settlements have to be treated the same way as judgments.

[00:14:00] Speaker 00:
Congress has explicitly held that in settling, the attorney general cannot do remedies in addition or different than what a court can do in a judgment.

[00:14:11] Speaker 00:
All of these courts have held, though, that the damages have to be finalized and discharged at the time of settlement or judgment.

[00:14:20] Speaker 00:
And this is consistent with how the FTCA has been

[00:14:23] Speaker 00:
handled throughout history.

[00:14:24] Speaker 00:
And that's the important context that distinguishes this case from Massey.

[00:14:27] Speaker 00:
As we noted in our briefs, back in the 40s and 50s, in order for settlements and judgments to go through, there had to be supplemental appropriations from Congress.

[00:14:35] Speaker 00:
Congress had to sign off on these judgments.

[00:14:38] Speaker 00:
Now, things were harmonized with Section 2414 in order to say that settlements have to be treated like judgments.

[00:14:45] Speaker 00:
But because judgments have to be

[00:14:48] Speaker 00:
obligation for the government has to be extinguished at the time of settlement.

[00:14:51] Speaker 03:
The cases say you can have a settlement with periodic payments and if the government doesn't make the payments it can be sued.

[00:14:57] Speaker 03:
And they say that's exactly what's going on here in this case.

[00:15:01] Speaker 03:
Now you may say the language of the contract is different or the settlement agreement was different than it was in Massey.

[00:15:09] Speaker 03:
Maybe that's an argument.

[00:15:10] Speaker 03:
But I do not see in the light of these authorities how you can say that the government can't enter into

[00:15:17] Speaker 03:
an agreement for payment over time and be sued if it reaches that agreement.

[00:15:21] Speaker 03:
I don't understand how you can possibly say that.

[00:15:25] Speaker 00:
Well, and there's a critical distinction between those cases that I think the court should keep in mind.

[00:15:30] Speaker 00:
This case involved the purchase of an annuity.

[00:15:31] Speaker 00:
And this ties back to the terms in the settlement agreement.

[00:15:34] Speaker 00:
A huge distinction between the FDCA and the Military Claims Act is that at the negotiating table, if the parties don't want an annuity, they can go to court.

[00:15:44] Speaker 00:
And they can pursue a claim before court.

[00:15:45] Speaker 00:
The Military Claims Act doesn't allow that at all.

[00:15:48] Speaker 00:
If they don't receive money from the designated Department of Defense authority to resolve their case, they have no remedy.

[00:15:57] Speaker 00:
And it's a critical distinction in this case, because what happened here is the parties wanted to have an annuity that would make payments down the road.

[00:16:05] Speaker 00:
But under the FTCA, and historically this has always been the case, the government cannot agree to guarantee obligations down the road.

[00:16:12] Speaker 00:
So we agreed to buy an annuity, a low risk, highly rated annuity,

[00:16:15] Speaker 00:
And that would make the payments.

[00:16:17] Speaker 00:
At the time, nobody thought the DLNY would go under, and it's very unfortunate that it did for everyone.

[00:16:23] Speaker 00:
But the government could only agree to lump some payments at the time of judgment and settlement.

[00:16:28] Speaker 03:
How could you say that?

[00:16:29] Speaker 03:
I just pointed out to you how the cases say you can enter into a settlement in which the government agrees to make periodic payments.

[00:16:36] Speaker 03:
And that's exactly what they say happened here.

[00:16:38] Speaker 03:
There was a settlement.

[00:16:39] Speaker 03:
The government agreed to make periodic payments.

[00:16:41] Speaker 03:
And it's libel.

[00:16:42] Speaker 03:
And those cases say, that's fine.

[00:16:43] Speaker 03:
There's nothing wrong with that.

[00:16:45] Speaker 03:
Now, you may dispute whether that's what the agreement says.

[00:16:48] Speaker 03:
But if the agreement does say that, there's nothing wrong with it.

[00:16:52] Speaker 00:
Respectfully, Your Honor, that's not what the cases say.

[00:16:54] Speaker 00:
They all indicate clearly that Congress has not authorized the government to guarantee payments down the road.

[00:17:02] Speaker 00:
And I think that's the critical distinction here.

[00:17:04] Speaker 00:
Frankel v. Himes explicitly held that in court.

[00:17:08] Speaker 00:
you know, like Riley in Askew and Hole by Hole have gotten creative in creating mechanisms to allow for installment payments.

[00:17:14] Speaker 00:
But that doesn't change the fact that the government's obligation has to be extinguished at the time of settlement or judgment.

[00:17:19] Speaker 00:
And that's entirely consistent with the terms of the agreement.

[00:17:23] Speaker 00:
As your honor pointed out, the agreement says that the United States agrees to purchase annuities which will provide the following.

[00:17:30] Speaker 00:
It says which, not that.

[00:17:32] Speaker 00:
It notes that if the insurance company goes under, that the plaintiff or the appellant

[00:17:37] Speaker 00:
as standing to sue, and that the government will assist in those efforts.

[00:17:40] Speaker 00:
It indicates the government will purchase a low-risk annuity, which costs the government more.

[00:17:44] Speaker 00:
I mean, if the government was the guarantor, why would that provision be in there?

[00:17:47] Speaker 00:
And then the most convincing provision, in my mind, if you look at page 827, specifically, it's paragraph 14, as noted in the appellant's notations in the agreement.

[00:18:00] Speaker 00:
It says, the United States will furnish to the offerees through their attorney a certificate of insurance or other evidence of the purchase

[00:18:07] Speaker 00:
by the United States of annuities in an amount sufficient to satisfy those obligations of the United States under the settlement agreement, which are to be satisfied by the purchase of annuities.

[00:18:18] Speaker 00:
Under the appellant's interpretation, these provisions are nonsensical or just have no meaning.

[00:18:22] Speaker 00:
And I respectfully submit that the court is obligated to interpret this agreement to give meaning to all the provisions that are in effect.

[00:18:32] Speaker 03:
OK.

[00:18:32] Speaker 03:
Anything further?

[00:18:35] Speaker ?:
No.

[00:18:35] Speaker ?:
I do.

[00:18:35] Speaker ?:
All right.

[00:18:41] Speaker 01:
The government's taken inconsistent positions over the periodic payments.

[00:18:47] Speaker 01:
They've asked for a revisionary trust.

[00:18:49] Speaker 01:
The federal court claims that clearly allows for it.

[00:18:51] Speaker 01:
There's no case that they've cited that says it doesn't.

[00:18:54] Speaker 01:
So just commenting on the last point on the language of the contract itself with respect to the certificate of insurance or the purchase, there's no question that the contract

[00:19:08] Speaker 01:
lets everyone know that the government's going to be purchasing an annuity from a life insurance company.

[00:19:13] Speaker 01:
That's in there.

[00:19:15] Speaker 01:
And that's all that that is referring to.

[00:19:16] Speaker 01:
There's an obligation to the government saying, we're going to get you a good policy.

[00:19:19] Speaker 01:
We're going to get one from an excellent or A-plus company.

[00:19:23] Speaker 01:
Now, if they didn't use an A-plus or excellent company, that would be a separate breach.

[00:19:27] Speaker 01:
I suspect here that executive life was not what it said it was.

[00:19:33] Speaker 01:
But even if it was at the time,

[00:19:35] Speaker 01:
That is an obligation that the government is saying, we're going to take on that obligation.

[00:19:39] Speaker 01:
They didn't involve the plaintiffs in this selection.

[00:19:42] Speaker 01:
It was a unilateral decision by the government lawyers on who they were going to select and who they used.

[00:19:47] Speaker 01:
And they went to their go-to broker and their go-to life insurance company for a period of a few years in the 1980s.

[00:19:55] Speaker 01:
And unfortunately, they did a poor job in their due diligence in selecting that company.

[00:19:59] Speaker 01:
But now it shouldn't be the plaintiff's fault.

[00:20:02] Speaker 01:
It shouldn't be an innocent party who had nothing to do with selecting that life insurance company.

[00:20:08] Speaker 01:
And just as an aside, because I think this sort of touches on it, in the government's brief, they talk about some parole evidence here.

[00:20:15] Speaker 01:
And that is there was a question about whether or not there should be insurance taken out on the life insurance agreement.

[00:20:21] Speaker 01:
The plaintiffs weren't allowed to do that.

[00:20:22] Speaker 01:
because the policy was owned by the United States government.

[00:20:25] Speaker 01:
Only the government could take out a separate insurance on the life insurance policy, not the plaintiffs.

[00:20:30] Speaker 01:
So this is merely an instruction similar to what the court held in Massey, an instruction to JMW Settlements, Inc.

[00:20:38] Speaker 01:
to make sure that they selected correctly, just as we saw in the Massey decision.

[00:20:44] Speaker 01:
Unless there's any further questions, I'll conclude by saying if there's one party that should always make good on the promises, it should be our government.

[00:20:51] Speaker 01:
a government by the people and for the people.

[00:20:54] Speaker 01:
And this court should compel the government to live up to its obligations and reverse the lower court's decision remand for further findings and damages.

[00:21:02] Speaker 03:
OK.

[00:21:02] Speaker 03:
Thank you, Mr. Moreno.

[00:21:03] Speaker 03:
We thank both counsels.

[00:21:04] Speaker 03:
The case is submitted.

[00:21:06] Speaker 03:
That concludes our session.