[00:00:02] Speaker 00:
May it please the court, honorable justices.

[00:00:08] Speaker 00:
Appellant's position is- Can you tell us your name?

[00:00:10] Speaker 00:
Oh, forgot a critical fact.

[00:00:11] Speaker 00:
Thank you, Your Honor.

[00:00:12] Speaker 00:
My name is Wilmer Harris, appearing on behalf of Appellant JG.

[00:00:15] Speaker 03:
All right.

[00:00:16] Speaker 00:
Good morning.

[00:00:16] Speaker 00:
Good morning.

[00:00:18] Speaker 00:
The district court order denying attorney sees in this motion must be reversed for two fundamental reasons.

[00:00:26] Speaker 00:
First,

[00:00:27] Speaker 00:
The critical question of law is whether the district court judgment in appellant's favor fundamentally or materially altered the legal relationship between the litigants.

[00:00:38] Speaker 00:
In this case, the district court issued a judgment which found, as a matter of its observation of the trial, that defendant LAUSD had violated my client's rights under the Americans with Disabilities Act, as well as the Rehabilitation Act.

[00:00:55] Speaker 02:
The district court referred to Rhodes

[00:00:58] Speaker 02:
And it was extensively cited by your friend on the other side.

[00:01:03] Speaker 02:
I could only find Rhodes cited once in your opening brief on page 16 inside a block quote from another case.

[00:01:14] Speaker 02:
Do you agree with the district that Rhodes is directly on point?

[00:01:17] Speaker 02:
And if not, why not?

[00:01:20] Speaker 00:
I do not agree, Your Honor, and the reason is because in this case, what we have is a declaratory judgment which establishes that plaintiffs' claims, still pending in the district court, trial set for March 10th, will prevail because of the principles of collateral estoppel.

[00:01:36] Speaker 00:
Roads do not involve an application of a collateral estoppel doctor.

[00:01:39] Speaker 00:
What we have here is a case where, in essence, the invocation of the district's rights under the 11th Amendment, the case was split into two.

[00:01:48] Speaker 00:
In the federal court action, the underlying facts were determined by the court in a bench trial.

[00:01:55] Speaker 00:
The court found that there was unlawful segregation of my client for the 2018-2019 school year.

[00:02:01] Speaker 02:
Does it matter that the declaratory relief was only pursuant to that unlawful segregation

[00:02:09] Speaker 02:
for 2018 and 19 school year, given that J.G.

[00:02:14] Speaker 02:
had already left Loman at the time when the district court issued its judgment?

[00:02:18] Speaker 00:
Well, the answer to that, Your Honor, I think is that there was no

[00:02:23] Speaker 00:
Unlike the district court's statement in the order, there was no mootness in this case.

[00:02:29] Speaker 03:
But what relief can you now get?

[00:02:31] Speaker 03:
Because obviously that's in the past.

[00:02:35] Speaker 03:
You got no money for that time, but you got the declaration that he was not in the least restrictive environment for a period of time that's already passed.

[00:02:46] Speaker 03:
What more can he get?

[00:02:48] Speaker 03:
out of this judgment.

[00:02:50] Speaker 03:
That's what I'm having a hard time.

[00:02:51] Speaker 00:
And you would concede you have to show that, right?

[00:02:59] Speaker 00:
Has been altered.

[00:03:01] Speaker 00:
And it has been directly altered, Your Honor, by virtue of the fact that we have a state court action that we will take the findings of the district court, they apply in the state court action, and they compel a judgment in our favor in that action.

[00:03:17] Speaker 03:
Well, except for now, your client's how old?

[00:03:20] Speaker 00:
He is 23.

[00:03:21] Speaker 03:
All right.

[00:03:22] Speaker 03:
And he continues to be evaluated?

[00:03:28] Speaker 03:
Right.

[00:03:29] Speaker 00:
Although he's not with LAUSD anymore, just so that's clear.

[00:03:31] Speaker 03:
OK.

[00:03:32] Speaker 03:
So he's not there anymore.

[00:03:34] Speaker 03:
So you can't compel them to give you money for that period of time, right?

[00:03:39] Speaker 03:
That's done.

[00:03:40] Speaker 00:
Yes, we can.

[00:03:41] Speaker 00:
Because in the state court action, the judgment entered by the district court compels us to a judgment in that case.

[00:03:48] Speaker 00:
So we will recover damages directly as a result of the district court judgment.

[00:03:53] Speaker 03:
Well, and so what did the district court say about that?

[00:03:55] Speaker 03:
The district court said that's not true, right?

[00:03:58] Speaker 00:
The district court didn't rule on that issue because it wasn't in front of the district court.

[00:04:02] Speaker 00:
The district court merely issued a finding that my client's rights under the Americans with Disabilities Act and Rehabilitation Act were violated.

[00:04:11] Speaker 00:
The court also found that my client suffered damage as a result of that.

[00:04:15] Speaker 00:
And, of course, there's the difference in standard under the federal statutes that we tried the case under.

[00:04:20] Speaker 00:
They require filing of either intentionality or reckless disregard.

[00:04:24] Speaker 03:
In the state court action... Well, and didn't the district court make some sort of ruling about that?

[00:04:29] Speaker 00:
The court said that there was no finding of deliberate indifference or recklessness or intentionality.

[00:04:34] Speaker 00:
But under the state court action, we don't have to show that.

[00:04:37] Speaker 00:
It's a normal preponderance of the evidence standard for finding damages.

[00:04:42] Speaker 00:
So based on the district court's judgment in this action, we are therefore entitled to victory in state court.

[00:04:49] Speaker 00:
Pardon me.

[00:04:51] Speaker 00:
And so as a result, that is the most fundamental alteration of a legal relationship than one can imagine.

[00:04:58] Speaker 00:
Imagine, for a second, justices, if this case were tried and won.

[00:05:04] Speaker 00:
And of course, the district had the right under the 11th Amendment to compel them to be litigated in separate venues.

[00:05:10] Speaker 00:
But if they were litigated in one case,

[00:05:15] Speaker 00:
It would have been very clear that the judge would have had to find for us based on his ruling.

[00:05:22] Speaker 00:
that there were a breach of the duty not to segregate students unlawfully, that that breach caused my client damages, which is in the findings of fact and conclusions of law.

[00:05:34] Speaker 00:
And then the only thing would have been different that will occur now in state court is that instead of applying the more rigorous deliberate indifference standard, the court will have to apply the preponderance of the evidence standard.

[00:05:46] Speaker 03:
Well, I think in Farrar v. Hobby, the Supreme Court said, a judicial pronouncement that the defendant has violated a law unaccompanied by an enforceable judgment on the merits does not render the plaintiff a prevailing party.

[00:06:03] Speaker 03:
and that the moral satisfaction that results from any favorable judgment of law cannot bestow prevailing party status.

[00:06:12] Speaker 03:
So how is the district court's finding of unlawful segregation anything other than this type of moral satisfaction?

[00:06:19] Speaker 00:
It's the same sort of situation as the Zuckerman case we cited in our papers, Justice, where there was a finding that the Postal Service violated the rights of the plaintiff.

[00:06:30] Speaker 02:
But does it matter that

[00:06:32] Speaker 02:
The Ziegerman court didn't address whether the plaintiff was a prevailing party within the context of a fee-shifting statute?

[00:06:40] Speaker 00:
It matters in the sense that Justice Wallach is correct.

[00:06:44] Speaker 00:
It was in the different procedural posture.

[00:06:46] Speaker 00:
What the court did in that case was made clear that the judgment in that case secured the plaintiff in that case right to be free from viewpoint discrimination in that case, clarify that the Postal Service could no longer discriminate against him or anyone else.

[00:07:03] Speaker 00:
And that is the critical factor in our case.

[00:07:05] Speaker 00:
We not only have

[00:07:07] Speaker 00:
as I've argued before, the collateral stopper ruling that will and is, by stipulation of the parties, applying in the state court action.

[00:07:16] Speaker 00:
So that is the most fundamental alteration possible.

[00:07:19] Speaker 00:
There will be a monetary damage award in the state court because of the district court's judgment.

[00:07:25] Speaker 00:
Secondly, the judgment clarified the rights.

[00:07:28] Speaker 00:
My client was still an LAUSD student at the time of the trial, at the time of the judgment.

[00:07:35] Speaker 00:
So there was still the right, the re-segregation was a real threat, as I've stated in the papers, and therefore this judgment clarified his right to be free from the discrimination.

[00:07:46] Speaker 03:
I'm sorry, but at any given time where a student belongs, they evaluate them, and the circumstances can change.

[00:07:54] Speaker 03:
So that particular judgment doesn't automatically mean at a particular time, like client says they get older, maybe they would become

[00:08:03] Speaker 03:
you know, like they've been violent in school or things have happened.

[00:08:07] Speaker 03:
And then they would say, well, no, you can't go back there.

[00:08:10] Speaker 03:
So that judgment doesn't automatically mean he could never be kept out of that school again, does it?

[00:08:18] Speaker 00:
I would concede that point, Your Honor, but I would raise this one in its place.

[00:08:21] Speaker 00:
The issue was that the district, as we stated in our papers, throughout the entirety of the litigation, through trial, post-trial, has always contended that my client was not properly placed, that he should have been left at the Lowman School and not placed at the general education campus.

[00:08:37] Speaker 00:
So the controversy that was still pending

[00:08:39] Speaker 00:
at the time of the judgment that the judgment satisfied was whether the district's contention was correct.

[00:08:46] Speaker 00:
It was a live controversy all the way through judgment.

[00:08:49] Speaker 00:
And therefore, it did, it's not like the circumstance you mentioned, Your Honor, where they could just, as a result of their normal routine reevaluation, would have an opportunity to reconsider.

[00:09:00] Speaker 00:
It was a live contention between the parties that had gone on for five years as to whether the client should- I'm sorry, I interrupted you, Judge Wallach.

[00:09:08] Speaker 03:
Oh, I'll save my question for-

[00:09:09] Speaker 03:
OK, do you want to save a little time for rebuttal?

[00:09:11] Speaker 03:
Yeah, I'll save a minute or so for rebuttal.

[00:09:13] Speaker 00:
OK, thank you.

[00:09:13] Speaker 03:
Thank you very much.

[00:09:16] Speaker 03:
OK, we're ready to hear from the district.

[00:09:20] Speaker 01:
Good morning, Your Honor.

[00:09:21] Speaker 01:
Good morning.

[00:09:22] Speaker 01:
Good morning.

[00:09:22] Speaker 01:
Matthew, may it please the court?

[00:09:24] Speaker 01:
Matthew Hicks for defendant and appellee, Los Angeles Unified School District.

[00:09:29] Speaker 02:
Mr. Hicks says, has the school district stipulated to a judgment in the state court action?

[00:09:36] Speaker 01:
Absolutely not.

[00:09:38] Speaker 01:
Council's statement is significant overreach to answer your first question Rhodes is directly on point Where they say it is not on point because of a some sort of collateral estoppel doctrine no legal authority has been cited that apply some sort of small win on a declaratory relief issue and federal action and then relate it to the related state court action what

[00:10:03] Speaker 01:
the courts are talking about about material alteration or fundamental change between the parties is between those parties on the issues in the federal court.

[00:10:13] Speaker 03:
Well, what I heard him to say, your friend on the other side, that J.G.

[00:10:18] Speaker 03:
is using the district court's judgment in the pending California state court action.

[00:10:24] Speaker 03:
Why is that not enough to establish that he is the prevailing party?

[00:10:30] Speaker 01:
First of all, I will address that.

[00:10:31] Speaker 01:
But first of all,

[00:10:33] Speaker 01:
They never, Judge Bernal and the district court specifically asked for supplemental briefing on the issue of whether there was a material alteration.

[00:10:41] Speaker 01:
They buried the Rhodes case in a footnote and did not address it where Judge Bernal said this case is directly on point.

[00:10:48] Speaker 01:
Judge Bernal evaluated all of that through the supplemental briefing in four days of trial and said there was absolutely no material alteration.

[00:10:56] Speaker 01:
They not once in the supplemental briefing or in their opening brief took up this argument about some sort of victory in this related state court action.

[00:11:04] Speaker 01:
They only brought it up in the reply brief.

[00:11:05] Speaker 01:
So I would argue it had been waived.

[00:11:08] Speaker 01:
That being said, to answer your question,

[00:11:11] Speaker 01:
We have destroyed their state court action.

[00:11:13] Speaker 01:
They brought seven, eight causes of action through demurs and motions to strike.

[00:11:18] Speaker 01:
We have gotten rid of their California Disabled Persons Act cause of action.

[00:11:22] Speaker 01:
We have gotten rid of their California Unruh Civil Rights cause of action.

[00:11:27] Speaker 01:
We have gotten rid of their intentional infliction of emotional distress cause of action.

[00:11:31] Speaker 01:
We got rid of their negligence per se.

[00:11:34] Speaker 01:
What's left?

[00:11:34] Speaker 01:
What's left?

[00:11:35] Speaker 01:
Negligence and a cause of action for violation of the Equal Protection Clause.

[00:11:41] Speaker 01:
And for counsel to say they're going to automatically get some sort of damage judgment in the state court action is absolutely incorrect.

[00:11:48] Speaker 01:
They haven't moved from some sort of motion for summary judgment or adjudication on that issue.

[00:11:54] Speaker 01:
We have to try that issue.

[00:11:56] Speaker 01:
There's going to be jury instructions.

[00:11:59] Speaker 01:
They can argue collateral estoppel that they got this one unpetite victory on the issue of

[00:12:06] Speaker 01:
not the most integrated setting for one school year, although Judge Bernal said the other 12 years it was the perfect setting for this kid.

[00:12:14] Speaker 01:
They're going to have to try that case before a jury in March of 2025.

[00:12:18] Speaker 01:
So they're not automatically going to get a win on this.

[00:12:20] Speaker 01:
If they're going to argue collateral estoppel allows them to win on this, well, then we can argue collateral estoppel allows us to win on every other facet of their claim in the state court action, because we won on every facet of all the claims in the federal court action.

[00:12:33] Speaker 01:
So I totally disagree with their position that they're automatically going to get some victory in the state court.

[00:12:38] Speaker 01:
That has to be tried.

[00:12:39] Speaker 01:
But before we even go there, the federal court cases don't tie some sort of related state court action to the fundamental material alteration of the party's conduct between the two.

[00:12:52] Speaker 01:
In this case,

[00:12:53] Speaker 01:
Javier Guerrero, by the way, he had IEPs every year where the mom, the guardians are part of the IEP team and they agreed to Lohman Special Education Center and this was litigated in the federal court before Judge Bernal.

[00:13:08] Speaker 01:
That was, the IEP team agrees on where the setting is.

[00:13:12] Speaker 01:
It wasn't until, in fact... We need to call him JG.

[00:13:17] Speaker 01:
No, no, because they've used his full name, Javier Guerrero, in all kinds of briefings that are public with the court now that he's 22, 23 years old.

[00:13:24] Speaker 01:
OK, so what I was saying was I kind of lost my train of thought.

[00:13:31] Speaker 01:
Sorry.

[00:13:32] Speaker 03:
But I think you were saying this was a Pyrrhic victory, basically, that has no collateral estoppel.

[00:13:42] Speaker 01:
And what I take offense at is they've now tried to recast this case in several different ways.

[00:13:48] Speaker 01:
Their three theories during the district court trial was a failure to provide effective communication.

[00:13:53] Speaker 01:
That was a huge part of their case.

[00:13:55] Speaker 02:
You shouldn't take offense just because you disagree.

[00:13:58] Speaker 01:
Fair enough.

[00:13:59] Speaker 01:
Thank you, Your Honor.

[00:14:00] Speaker 01:
I get personally engaged in these cases.

[00:14:04] Speaker 01:
The second claim was that there was a failure to reassess this kid and provide psychological assessments over the years.

[00:14:11] Speaker 01:
The third part of the case was what they would call unlawful segregation.

[00:14:14] Speaker 01:
They totally lost on the first part, effective communication, 100% victory for the school district.

[00:14:19] Speaker 01:
We won on the failure to reassess portion of their claim.

[00:14:23] Speaker 01:
We won on 98% of the unlawful segregation part of their claim.

[00:14:28] Speaker 01:
And the judge found no intentional conduct, no deliberate indifference, and no damages.

[00:14:33] Speaker 01:
So what do they do on their fee motion?

[00:14:35] Speaker 01:
They recast this as only an unlawful segregation case, that 2% victory that they say they had versus what really they tried and what they alleged in their complaint.

[00:14:45] Speaker 01:
And then, what's worse, on the opening brief on their appeal, they recast this as a declaratory relief case.

[00:14:51] Speaker 01:
Oh, because he said there was improper placement for one school year.

[00:14:55] Speaker 01:
We went on declaratory relief.

[00:14:57] Speaker 01:
So I do take umbrage at the fact that they're trying to recast this case to get what they really want, attorney's case.

[00:15:06] Speaker 03:
Well, I was a little, was it for a year, or was it for four months, or what was it exactly that he was improperly

[00:15:14] Speaker 03:
segregated.

[00:15:15] Speaker 01:
Okay, so there was an underlying IDEA case where there was an administrative law ruling where, I think it was a three or more time period, he was not in the least restrictive environment.

[00:15:26] Speaker 01:
He was not in the most integrated setting.

[00:15:28] Speaker 01:
They filed a motion for summary judgment, and Judge Bernal ruled, yes, I agree with the administrative law judges ruling on that.

[00:15:35] Speaker 01:
And then we tried the issue, and it was for Judge Bernal extended it to a school year 2018-2019, which was his senior year.

[00:15:43] Speaker 01:
The evidence is clear.

[00:15:44] Speaker 01:
The mom wanted him to graduate with his classmates at Lohman, and there was a decision to move him to Sun Valley High School.

[00:15:52] Speaker 01:
So there was no material alteration or fundamental change in the party's conduct, whether they filed litigation or not.

[00:15:58] Speaker 02:
Your friends rely on Wilcox.

[00:16:00] Speaker 02:
There was a dollar there.

[00:16:03] Speaker 02:
If there had been a dollar here, it would be a different case, wouldn't it?

[00:16:10] Speaker 01:
I would still think you'd have to go back to the US Supreme Court decisions.

[00:16:13] Speaker 01:
It would be a different case.

[00:16:16] Speaker 03:
A dollar would be a different case.

[00:16:19] Speaker 03:
It's not exactly the same.

[00:16:20] Speaker 03:
It would be some damages.

[00:16:22] Speaker 03:
And we'd have to look at the nominal damages and decide.

[00:16:26] Speaker 01:
But the case law is clear.

[00:16:27] Speaker 01:
You have to take that little component and say, well, they didn't prevail on all of this.

[00:16:32] Speaker 01:
So maybe they prevail on this.

[00:16:33] Speaker 01:
They don't get $750,000 in attorney's fees, which is what they sought.

[00:16:39] Speaker 03:
Say it that way.

[00:16:43] Speaker 03:
You would still make your arguments, but it would be a different case if they got a dollar.

[00:16:48] Speaker 01:
The legal analysis would flow from the US Supreme Court decisions that talk about what you can get when you're mostly unsuccessful and slightly successful on one part of it, yes.

[00:16:58] Speaker 02:
So your friends, as you point out, are seeking a large amount of attorney's fees, and they make a public policy argument.

[00:17:07] Speaker 02:
Respond to that, please.

[00:17:09] Speaker 02:
The public policy argument, I would argue, is that... They say they've clarified the law and have an important decision here.

[00:17:23] Speaker 01:
There's no evidence of that.

[00:17:25] Speaker 01:
This wasn't written up in any journals.

[00:17:30] Speaker 01:
In fact, our victory at LASD was written up in the Daily Journal.

[00:17:37] Speaker 01:
We do address that in our brief, but their statement that this is some great victory for humankind is significant overreach, and there's no evidence of that.

[00:17:51] Speaker 03:
So what do we do from your perspective of the district court found there was no deliberate indifference?

[00:17:59] Speaker 03:
Basically, the district court said it was kind of an administrative

[00:18:05] Speaker 01:
Bureaucratic slippage?

[00:18:07] Speaker 03:
Yeah, I guess kerfuffle as it were.

[00:18:09] Speaker 03:
Yeah, bureaucratic slippage.

[00:18:12] Speaker 03:
What do we make of those findings?

[00:18:13] Speaker 03:
How do those findings play into whatever we decide?

[00:18:18] Speaker 01:
Well, I think you're relevant because what the issue is, whether based on this one finding, you know, to their credit, based on this one finding that he was not in the most integrated setting for one school year, the issue is whether there was a material alteration or fundamental change between the parties.

[00:18:36] Speaker 01:
But I do think, looking at it globally, I think it's important that the judge Bernal found no intentional conduct or deliberate indifferent standard met, and therefore there's no right to damages.

[00:18:48] Speaker 01:
I think that is important, but when it comes to the legal issue of what they're entitled to on terms of attorney's fees, it would come down to the Rhodes case and the progeny they're in.

[00:18:57] Speaker 03:
Okay.

[00:18:58] Speaker 03:
I want to make sure.

[00:18:59] Speaker 03:
Do my colleagues have any additional questions?

[00:19:03] Speaker 03:
So then you can wrap it up with, we should affirm, I guess, is what you would say.

[00:19:08] Speaker 01:
We do believe you should affirm the district court's decision denying their motion for attorney's fees correct.

[00:19:13] Speaker 01:
Thank you, Your Honor.

[00:19:14] Speaker 03:
Thank you.

[00:19:21] Speaker 00:
Very briefly, Your Honor.

[00:19:23] Speaker 00:
One of the critical things I think it's important for the court to notice is that in

[00:19:27] Speaker 00:
If there are opposition papers, the district pointed out that they claim that they're entitled to a Rule 68 reduction here.

[00:19:36] Speaker 00:
I think that actually inadvertently shows the connectedness between the two cases.

[00:19:40] Speaker 00:
The district offered to settle the federal court case, but contingent upon dismissal of both the state and federal court actions.

[00:19:47] Speaker 00:
That shows what we've been arguing, that this is really a two-part act.

[00:19:51] Speaker 00:
We've won in the federal court.

[00:19:53] Speaker 02:
Sure authority for that.

[00:19:55] Speaker 00:
Well, it flows from their own acknowledgment, Your Honor.

[00:19:58] Speaker 00:
You have two cases.

[00:20:00] Speaker 02:
What legal authority do you have for the proposition that under Rule 68 offer, if it's global, that links the two cases in this fashion?

[00:20:11] Speaker 00:
I think as we said in our papers, Your Honor, we've made an argument that the papers, excuse me, that the two claims are basically interconnected and the findings in one case will apply as collateral stop on the other.

[00:20:22] Speaker 00:
I don't have a case to cite to Your Honor's point about the interconnectedness from Rule 68 perspective.

[00:20:28] Speaker 00:
I believe that's a relatively unique argument.

[00:20:31] Speaker 00:
But I think what it does show that's relevant to the court's consideration is that you have one case that's being played out in two different venues.

[00:20:40] Speaker 00:
As a result of the ruling from the district court, the judgment entered in plaintiff's favor here.

[00:20:46] Speaker 00:
Then we now will be able to demonstrate to the state court of appeals, excuse me, the state court litigation in trial court that we are a prevailing party.

[00:20:57] Speaker 00:
If the court has any concern about whether the rule of collateral estoppel will apply in the state court action, that will be resolved very shortly.

[00:21:07] Speaker 00:
We have a March 10th trial date.

[00:21:09] Speaker 00:
The parties, as we put into the record, the parties entered into a stipulation in state court as a result of the trial court in state courts.

[00:21:20] Speaker 00:
Request to meeting confer about the about the collateral stop on race judicata judicata doctrines in this case What plaintiff did as a result of that was in acknowledgement of the fact that collateral stopple applies against us We removed the claims that we did not prevail on in federal court and included the claims that judge Bernal fawn on our favor on so from that perspective There I mean all of the elements of a negligence cause of action duty breach and causation of

[00:21:48] Speaker 00:
are satisfied by Judge Bernal's findings in this case.

[00:21:52] Speaker 00:
So there's really no question, as a matter of law, that the collateral estoppel doctrine will apply.

[00:21:57] Speaker 00:
All right.

[00:21:57] Speaker 03:
You're over your time.

[00:21:58] Speaker 03:
Let me make sure whether my colleagues have any additional questions.

[00:22:02] Speaker 03:
I don't.

[00:22:02] Speaker 03:
All right.

[00:22:02] Speaker 03:
They do not.

[00:22:03] Speaker 03:
So please just wrap up in a few words that you want us to reverse.

[00:22:08] Speaker 00:
I'd like you to reverse, Your Honor, because I believe the district court did not address the collateral estoppel argument, even though it was made before it.

[00:22:15] Speaker 00:
And once that doctrine is recognized, it's clear that there's been far more than just nominal damages received here, that there's been far more than just a Pyrrhic victory.

[00:22:25] Speaker 00:
We have an actual victory that we will just be able to reap in a different court at a different time.

[00:22:30] Speaker 00:
Thank you.

[00:22:30] Speaker 03:
All right.

[00:22:31] Speaker 03:
Thank you both for your arguments.

[00:22:32] Speaker 03:
This matter will stand submitted.

[00:22:34] Speaker 03:
Thank you.