[00:00:00] Speaker 03:
Those two matters are submitted and we'll begin with the case of Kogan versus Trabuco.

[00:00:05] Speaker 03:
I assume that you're Mr. Kogan, right?

[00:00:07] Speaker 03:
I am, Your Honor.

[00:00:08] Speaker 04:
Good morning to the panel.

[00:00:09] Speaker 04:
Good morning.

[00:00:09] Speaker 04:
Please proceed.

[00:00:10] Speaker 04:
Thank you, Your Honor.

[00:00:11] Speaker 04:
May it please the Court, Jeffrey Kogan representing himself in this matter.

[00:00:16] Speaker 04:
The facts are relatively simple on... You've got to be kidding.

[00:00:21] Speaker 04:
The facts?

[00:00:22] Speaker 03:
The relevant facts are simple.

[00:00:24] Speaker 03:
Oh, but the procedural facts are a mirage.

[00:00:26] Speaker 04:
A nightmare.

[00:00:28] Speaker 04:
July 2013, on behalf of my clients, filed a complaint in the Bankruptcy Court, which is a court proceeding under 28 United States Code 157.

[00:00:40] Speaker 04:
Court proceeding meaning that only the Bankruptcy Court has subject matter jurisdiction over that matter.

[00:00:46] Speaker 04:
It was subsequently dismissed in February 2014.

[00:00:49] Speaker 04:
Dr. Cipucco sued me and my clients

[00:00:54] Speaker 04:
The claim that survived was malicious prosecution.

[00:00:59] Speaker 04:
After it went to judgment, I appealed to the Court of Appeals.

[00:01:03] Speaker 04:
In reading the Court of Appeals decision, I came about MSR Exploration Limited, which is a Ninth Circuit case.

[00:01:13] Speaker 04:
And I'll get to that in a bit.

[00:01:15] Speaker 04:
I filed the declaratory relief in the District of Nevada on November 20th, 2021, asking the Nevada District Court to declare that the Arizona courts are without subject matter jurisdiction to enter any order, any judgment under the MSR Exploration Holding, which said that a malicious prosecution claim for any pleading in the bankruptcy court must be filed

[00:01:45] Speaker 04:
either in the United States Bankruptcy Court or at the very least at the district court level for the United States for that district.

[00:01:54] Speaker 03:
Well, that's all not true.

[00:01:56] Speaker 04:
Okay.

[00:01:56] Speaker 03:
But you didn't go there.

[00:01:59] Speaker 03:
You went to Arizona in a state court and you went all the way up to the Supreme Court of Arizona.

[00:02:04] Speaker 04:
I did.

[00:02:05] Speaker 03:
Then if you believe that the jurisdiction was in the Bankruptcy Court, why didn't you go to the Bankruptcy Court?

[00:02:13] Speaker 04:
To file the complaint on November 20th, 2021?

[00:02:16] Speaker 03:
Whatever, as I understand your plea, you're basically saying you're exempted from Ricker Feldman because this is an exception to Ricker Feldman.

[00:02:26] Speaker 03:
Yet when you look at the case that you're talking about, there was in fact a breach of the automatic stay.

[00:02:32] Speaker 03:
You don't have that here.

[00:02:33] Speaker 04:
No, it's not an automatic stay.

[00:02:35] Speaker 03:
you what it is not an automatic state all right so you don't fit into the same exception so why why why does your case fall outside the Ricker Feldman bar it seems like you have gone to a state court all the way up and then you say no I don't like that one so I want you

[00:02:54] Speaker 03:
to rehear it and overturn the state court, which is a very substance of Rucker-Feldman.

[00:02:59] Speaker 04:
Well, what's interesting is the district court's order dismissing the case is devoid of any analysis of Exxon Mobil versus Saudi Industries.

[00:03:10] Speaker 04:
Justice Ginsburg said that Rucker-Feldman applies to state court losers following a judgment.

[00:03:21] Speaker 04:
The operative facts are for this case was the district court complaint was filed on November 20th, 2021.

[00:03:28] Speaker 04:
The judgment in the state of Arizona was entered January 15th, 2022, eight weeks later.

[00:03:36] Speaker 04:
Justice Ginsburg and Exxon Mobil said, we can have jurisdiction.

[00:03:41] Speaker 04:
And just because a state court judgment is entered does not remove the jurisdictional grant to the district court.

[00:03:50] Speaker 04:
In light of the fact that the district court did not do any ExxonMobil analysis, I think is the first basis to reverse the court.

[00:03:59] Speaker 01:
Mr. Kogan, I have a different question I want to ask.

[00:04:03] Speaker 01:
I'm looking at the settlement agreement.

[00:04:06] Speaker 01:
Yes, Your Honor.

[00:04:07] Speaker 01:
And I'm looking at it.

[00:04:09] Speaker 01:
It says, if Dr. Tribucco prevails in the Nevada case, meaning that the district court denies plaintiff's request for entry of a judgment,

[00:04:20] Speaker 01:
et cetera, et cetera, et cetera.

[00:04:22] Speaker 01:
So that happened, correct?

[00:04:24] Speaker 01:
Yes, Your Honor.

[00:04:24] Speaker 01:
The district court did, in fact, deny exactly what is listed here.

[00:04:30] Speaker 01:
which I contend is reversible error, but yes.

[00:04:33] Speaker 01:
I understand that, but this doesn't say if the district court denies this and it's upheld on appeal.

[00:04:41] Speaker 01:
If there is an appeal, it says if the district court denies it.

[00:04:45] Speaker 01:
So given that, if that means literally what it says, what relief can we grant you here?

[00:04:53] Speaker 01:
Why isn't this case moot?

[00:04:55] Speaker 01:
And if you contend, if you agree that if it means what it says,

[00:04:59] Speaker 01:
literally this case is moot, why shouldn't we read it literally?

[00:05:04] Speaker 04:
A few reasons.

[00:05:05] Speaker 04:
One reason it's not moot was Dr. Tribugo sued me again in the Mojave Superior Court, which I removed to the United States District Court for the District of Arizona.

[00:05:15] Speaker 00:
What's the status of that case?

[00:05:17] Speaker 00:
Are you litigating over this very issue that Judge Bennett has raised as to whether or not an appeal counts for purposes of whether that prevailing condition is met?

[00:05:28] Speaker 04:
no Judge Collins.

[00:05:29] Speaker 04:
We are litigating over a claim preclusion.

[00:05:34] Speaker 04:
I argued to the Arizona District Court that the judgment entered in Mojave Superior Court prevented the second lawsuit to collect on the eight million dollars.

[00:05:47] Speaker 04:
And it's been fully briefed on summary judgment.

[00:05:51] Speaker 04:
We're awaiting the court's decision on summary judgment on

[00:05:55] Speaker 04:
those types of issues.

[00:05:56] Speaker 00:
What is the relief that's being sought in that case in Arizona now in federal court?

[00:06:02] Speaker 04:
Sixteen million dollars, eight million for some reason on the judgment of the Mojave County Superior Court and then I don't understand another eight million dollars.

[00:06:12] Speaker 00:
Relief being sought is monetary, there's no sort of declaratory or equitable relief being sought?

[00:06:19] Speaker 04:
The reason I agreed to the settlement agreement, it is strictly a contract

[00:06:24] Speaker 04:
that the judgment was entered.

[00:06:29] Speaker 04:
A malicious prosecution will form malicious injury under 523A6 of the Bankruptcy Code.

[00:06:36] Speaker 04:
So if I were to ever file for bankruptcy, Dr. Tribuco could file a non-dischargeability requiring me, if I were to lose, to owe the $8 million despite the bankruptcy.

[00:06:49] Speaker 01:
So is it your view

[00:06:54] Speaker 01:
that paragraph 2C means just what it says that if Dr. Tribucco prevails in the district court, which he did, you agree to pay $8 million or does it mean something else?

[00:07:15] Speaker 01:
I took it as, you know, frankly I was surprised the Arizona Supreme Court denied my motion.

[00:07:32] Speaker 01:
precedent to the owing of the eight million dollars is 100% finally satisfied regardless of what we do here on appeal or if not why it means something else.

[00:07:43] Speaker 04:
It means something else because I think that if the district court makes reversible error then Dr. Tribuco doesn't prevail.

[00:07:51] Speaker 01:
But you could have

[00:07:54] Speaker 01:
Bargained for a language that says that and it does say literally if dr. Trujillo Trujillo prevails now if it had said just that I would agree with you, but then you have an explanatory phrase Meaning that the district court denies plaintiffs request etc.

[00:08:12] Speaker 01:
So couldn't you have bargained for what you're talking about, but you didn't I would Wow, I have two minutes left.

[00:08:20] Speaker 04:
I would agree with the court that I did not bargain with

[00:08:24] Speaker 04:
in anticipation of the US District Court for Nevada granting the motion to dismiss.

[00:08:31] Speaker 04:
It was beyond my contemplation.

[00:08:33] Speaker 04:
I thought MSR exploration is so binding and we're on all four points that it wouldn't have even come into my contemplation.

[00:08:45] Speaker 00:
Have you argued in the Arizona case in opposition to the effort to enforce the

[00:08:54] Speaker 00:
the obligation that this condition is not satisfied because of this ongoing appeal?

[00:09:02] Speaker 04:
No, I argued exclusively on claim preclusion based upon the pleadings that Dr. Tribuco's attorneys filed

[00:09:11] Speaker 04:
in opposition to my motion for summary judgment.

[00:09:14] Speaker 00:
And is the claim in that case in Arizona Federal Court for the contractual obligation for $8 million under paragraph 2C?

[00:09:26] Speaker 04:
Yes, Your Honor.

[00:09:29] Speaker 03:
And if you lose in that case, does it matter what we do here?

[00:09:34] Speaker 04:
I believe so because if this court reverses and remands the case back to the district court, I have the opportunity to prevail.

[00:09:42] Speaker 04:
If I may, since I have 33 seconds.

[00:09:45] Speaker 00:
You would take the view that if we reversed in this case and the district court on remand entered the order that's described in 2C, then you would prevail and the obligation would be undone.

[00:10:02] Speaker 04:
Nevada District Court is not affected by the settlement agreement.

[00:10:07] Speaker 04:
It would be the Arizona District Court that would enter a judgment based on 2C.

[00:10:14] Speaker 04:
Nevada District Court is only a declaratory relief.

[00:10:16] Speaker 00:
I think you're misunderstanding.

[00:10:17] Speaker 00:
My question is if we were to reverse in this case and send it back down and then on remand the District Court entered

[00:10:27] Speaker 00:
the the order that you wanted so that Mr. Dr. Tribuco would not have prevailed because the district court would not have denied your request, then that would undo the 2C 8 million obligation, correct?

[00:10:49] Speaker 04:
Yes, Your Honor.

[00:10:49] Speaker 04:
Yes, Judge Bounds.

[00:10:51] Speaker 03:
So you're over time.

[00:10:52] Speaker 03:
We've asked you some questions.

[00:10:54] Speaker 03:
Why don't, because this is rather important to you,

[00:10:57] Speaker 03:
We'll give you a couple of minutes on rebuttal after we hear from the other side, OK?

[00:11:02] Speaker 03:
Thank you, Your Honor.

[00:11:04] Speaker 03:
All right, I believe Mr. Will uncheck.

[00:11:10] Speaker 03:
Yeah, I want to check.

[00:11:12] Speaker 03:
OK, please proceed.

[00:11:17] Speaker 02:
Thank you, Your Honor.

[00:11:18] Speaker 02:
I have just a few points to make, some of which have already been discussed.

[00:11:23] Speaker 02:
First of all,

[00:11:25] Speaker 02:
Mr. Cogan's settlement came after he had filed a district court action, which clearly mooted this appeal.

[00:11:35] Speaker 02:
No different than in the Allard case, really.

[00:11:38] Speaker 00:
Well, as the questioning that I just went through illustrates, there'd be an issue if we were to remand, we would find this order to be erroneous and we were to remand.

[00:11:52] Speaker 00:
And then on the remand,

[00:11:54] Speaker 00:
he was not denied the request that's described in 2C, then that would change things, wouldn't it?

[00:12:04] Speaker 00:
So how could it be moved?

[00:12:08] Speaker 02:
Well, it's moved, Your Honor, because he, as I started to say, he entered into a settlement agreement after that action was filed.

[00:12:15] Speaker 02:
And that settlement agreement is pretty clear, as was pointed out.

[00:12:20] Speaker 02:
No, in no way did we bargain for this appeal specifically.

[00:12:25] Speaker 01:
But counsel, I'll ask you a variant of a question that I asked the plaintiff.

[00:12:31] Speaker 01:
You could have bargained for a provision that says the district court denies plaintiff's request for entry regardless of whether there is an appeal because as Judge Collins said, if we reverse and we instruct the district court

[00:12:48] Speaker 01:
not to deny, then he wouldn't have denied.

[00:12:50] Speaker 01:
So couldn't you have bargained for, and this provision becomes final, irrespective of an appeal, or he agrees if he loses not to appeal?

[00:13:01] Speaker 01:
So isn't that something you could have bargained for?

[00:13:06] Speaker 02:
I respectfully believe we did bargain for that.

[00:13:10] Speaker 02:
Now, we didn't put the language exactly as the court just put it.

[00:13:13] Speaker 02:
I don't think we needed to.

[00:13:15] Speaker 02:
I think it's very clear that we defined what it meant

[00:13:18] Speaker 02:
He bargained for the district court ruling, period.

[00:13:21] Speaker 02:
That ruling came.

[00:13:22] Speaker 02:
And this appeal is not bargained for, it is moot.

[00:13:28] Speaker 02:
This is exactly what he bargained for for the district court's ruling.

[00:13:31] Speaker 02:
Now, he has injected into this an appeal that clearly was not contemplated by the very language in this document.

[00:13:38] Speaker 01:
I think it's very clear.

[00:13:39] Speaker 01:
You know, I think reasonable, counsel, respectfully, I think reasonable people could differ

[00:13:44] Speaker 01:
as to whether the meaning of this is the district court denies one and done, it's all over, or when the case is over, what we're left with is a denial, and it strikes me that both parties could have bargained for something more specific, but for whatever reason, either didn't think about it or didn't do it.

[00:14:07] Speaker 02:
That's not accurate, Your Honor.

[00:14:08] Speaker 02:
With all due respect, it was thought about, and it's very clear.

[00:14:12] Speaker 02:
If it had said,

[00:14:13] Speaker 02:
final judgment, which is what I'm used to in many settlement agreements, a final decision, a final judgment, that would be the language that would typically be used.

[00:14:22] Speaker 02:
We didn't use that language very clearly when this was settled on the eve of the trial, I might add, which is why it's not as formal perhaps as maybe it could be.

[00:14:33] Speaker 02:
But it's very clear to me and should be to the court

[00:14:36] Speaker 02:
objectively that this definition was specifically put in there.

[00:14:41] Speaker 02:
If it said if Dr. Tribuco prevails in the Nevada case without that language, I would tend to agree with the court.

[00:14:46] Speaker 02:
If it said upon a final judgment, which is typically the language used, I'd agree with the court.

[00:14:52] Speaker 02:
That is not what was used.

[00:14:54] Speaker 02:
It was very clearly used as this language

[00:14:57] Speaker 02:
to define exactly what it meant.

[00:14:59] Speaker 02:
And I don't know how, with all due respect, it can be interpreted anything other than what it says.

[00:15:04] Speaker 00:
What is on the district court rules.

[00:15:07] Speaker 00:
Council, suppose we do not agree with you on this point.

[00:15:10] Speaker 00:
Tell us why you think you would still win on other grounds.

[00:15:16] Speaker 02:
Well, I'm not sure, Your Honor, that there are other grounds that I can honestly

[00:15:24] Speaker 00:
So you would then agree that the MSR case confirms that the malicious prosecution action was within the exclusive jurisdiction of the federal courts and therefore the entirety of the state judgment is void?

[00:15:40] Speaker 00:
Is that, you're conceding that point then?

[00:15:44] Speaker 02:
No, I understand, sorry, I understand what the MSR case says and generally I would tend to agree.

[00:15:50] Speaker 02:
However, in this particular case,

[00:15:53] Speaker 02:
I would argue that, again, Mr. Kogan is an experienced bankruptcy lawyer.

[00:15:59] Speaker 02:
Mr. Kogan gamed the system.

[00:16:00] Speaker 02:
He played this throughout to the Arizona Supreme Court.

[00:16:04] Speaker 02:
As the lower court pointed out, his appeal would be typically to the U.S.

[00:16:08] Speaker 02:
Supreme Court, and that Rucker Feldman preempts this.

[00:16:11] Speaker 02:
And I think it was purposeful action.

[00:16:15] Speaker 00:
The fact that it was, you know, sharp lawyering or whatever, the question remains, we have to apply the doctrines as they're set forth.

[00:16:24] Speaker 00:
And we have held that exclusive federal jurisdiction is an exception to Rooker-Feldman.

[00:16:32] Speaker 00:
And we've also held that it's an exception to the application of preclusion.

[00:16:37] Speaker 00:
So the state court judgment against where they asserted jurisdiction that should have been exclusively federal is void.

[00:16:46] Speaker 00:
And so why isn't this an exception of Rooker Feller where you, under MSR, you brought a malicious prosecution action over which the federal courts have exclusive jurisdiction?

[00:17:00] Speaker 02:
First of all, Your Honor, the way I read the MSR case, I don't have it right in front of me, but I believe it states in it something about while the bankruptcy is pending or pending the bankruptcy, there is no bankruptcy case here.

[00:17:15] Speaker 02:
And that's important.

[00:17:17] Speaker 02:
because Mr. Kogan, as I said, I believe, purposely gained the system as an experienced bankruptcy lawyer in this regard and did not move under MSR at any point in time until after the Arizona Supreme Court ruled.

[00:17:30] Speaker 02:
knowing that 10 years ago the bankruptcy was dismissed.

[00:17:33] Speaker 02:
There is no case to be put in the bankruptcy court.

[00:17:36] Speaker 00:
I'm not sure factually what you said about MSR is correct.

[00:17:39] Speaker 00:
What I'm reading here is it says, MSR waited until its reorganization plan was confirmed and substantially consummated, whereupon it brought this malicious prosecution action in the district court.

[00:17:55] Speaker 00:
And then we went on to say that the major issue in this case is whether state malicious prosecution actions for events taking place within the bankruptcy court proceedings are completely preempted by federal law.

[00:18:06] Speaker 00:
If they are, it is clear that there is a federal question involved in the action, and that will establish the jurisdiction of the district court to rule on the issue.

[00:18:19] Speaker 02:
Well, all I'm trying to say, Your Honor, is there is no bankruptcy proceeding.

[00:18:24] Speaker 02:
There is no proceeding at this point for 10 years now that we could go and put this matter into.

[00:18:30] Speaker 02:
So what he's trying to do is get out of a settlement agreement in which he clearly agreed to pay the $8 million.

[00:18:35] Speaker 02:
And now he would be left with apparently no judgment and no ability for Dr. Tribuco to go after the $8 million, even in a bankruptcy proceeding, which is 10 years long debt.

[00:18:47] Speaker 02:
So I do believe the purpose of MSR was, and again,

[00:18:52] Speaker 02:
My notes reflected that it was during dependency of the bankruptcy court, and if that's not correct, Your Honor, then I would apologize, but I believe that was the... Let me ask you this.

[00:19:01] Speaker 03:
Let's just say, arguendo, that this was sent back to the district court in order for Mr. Kogan to get what he wants, would the district court send it back to the bankruptcy court?

[00:19:13] Speaker 03:
Would it order the bankruptcy court to reopen a case?

[00:19:16] Speaker 03:
What would it do?

[00:19:18] Speaker 02:
Yeah, that's the problem, Your Honor, exactly what I'm trying to identify, which is he waited until long after there is a bankruptcy proceeding.

[00:19:26] Speaker 02:
I don't know how the district court could deal with it.

[00:19:28] Speaker 02:
I don't know.

[00:19:28] Speaker 02:
It can't send it to the bankruptcy court proceeding.

[00:19:31] Speaker 02:
You'd have to open up a 10-year-old bankruptcy that was discharged.

[00:19:35] Speaker 02:
And that's the problem here.

[00:19:37] Speaker 01:
That's why she... Of course, counsel, if we disagreed with you on the merits, one way we would deal with it is just say the district court is wrong.

[00:19:46] Speaker 01:
Rooker Feldman doesn't bar it.

[00:19:48] Speaker 01:
You can't maintain the action you maintained at all.

[00:19:52] Speaker 01:
And then if you thought you had another action, some bankruptcy court, you could try to bring it.

[00:19:57] Speaker 01:
But if we agree that Rooker Feldman

[00:20:04] Speaker 01:
doesn't bar this, then, you know, there might not be anything left for the district court to do.

[00:20:12] Speaker 02:
Well, that's exactly my point.

[00:20:14] Speaker 02:
Absolutely correct.

[00:20:15] Speaker 02:
There is nothing.

[00:20:15] Speaker 02:
And he gets away with playing this game for many, many years and going through the Arizona courts and entering into a settlement agreement, which is I still come back to, that's very clear on its face.

[00:20:26] Speaker 02:
We didn't just abandon that trial for no reason.

[00:20:29] Speaker 02:
We abandoned it very specifically for him to go to the district court.

[00:20:32] Speaker 02:
And once that was done and he got his ruling, that was it.

[00:20:35] Speaker 02:
There was no contemplation of any appeal, as he tries to say.

[00:20:38] Speaker 02:
That could have easily been stated in there to say it would be a final judgment.

[00:20:42] Speaker 02:
And that would contemplate going to the appellate court.

[00:20:44] Speaker 02:
That was not the agreement.

[00:20:46] Speaker 02:
And I think, uh, understand the Rockefellman doctrine issues.

[00:20:49] Speaker 02:
I understand there's problems with that issue.

[00:20:51] Speaker 02:
Um, but again, given the practicality of the matter, uh, there is no bankruptcy proceeding at this point.

[00:20:58] Speaker 02:
So Rooker Feldman is interesting.

[00:21:02] Speaker 02:
But I think the other case is really more on point, which deals with a party entering into a settlement agreement after a case is pending, which it was in the district court.

[00:21:13] Speaker 02:
And that moots any issue except under the settlement agreement, which would be under the state court jurisdiction to determine what this all meant, not the federal court, appellate court, with all due respect to this court.

[00:21:25] Speaker 02:
That's what should happen.

[00:21:26] Speaker 02:
This court should stand aside.

[00:21:28] Speaker 02:
declare it to be a moot issue, and leave the contract issue, which the court cannot undo, to the state court to decide what the intent was or meaning, if that's what his position is.

[00:21:38] Speaker 02:
I have no doubt what the finding of that would be.

[00:21:40] Speaker 03:
Your time is up.

[00:21:40] Speaker 03:
I'm going to ask my colleagues whether either has additional questions.

[00:21:44] Speaker 03:
All right.

[00:21:44] Speaker 03:
Thank you very much.

[00:21:45] Speaker 03:
So, Mr. Kruggen, we're going to give you two minutes to respond.

[00:21:49] Speaker 03:
Thank you, your honor.

[00:21:50] Speaker 04:
Rick Feldman doesn't apply also in that.

[00:21:53] Speaker 04:
Dr. Tribuco chose the venue, which is also an exception, where you attack the adverse party.

[00:22:01] Speaker 04:
Additionally, 28 U.S.C.

[00:22:03] Speaker 04:
1334 is the bankruptcy jurisdictional statute.

[00:22:08] Speaker 04:
And

[00:22:09] Speaker 04:
Ricker Feldman is a jurisdiction case.

[00:22:13] Speaker 04:
Therefore, the bankruptcy jurisdictional statute could apply subject matter jurisdiction to this case.

[00:22:21] Speaker 03:
You know, with respect, counsel, what I don't understand, as has been said, you appear to be a very experienced practitioner.

[00:22:29] Speaker 03:
You know it about the bankruptcy court.

[00:22:31] Speaker 03:
This isn't grunts.

[00:22:33] Speaker 03:
This case is not grunts.

[00:22:34] Speaker 03:
That's the exception that you all seem to be relying upon to get out of Ricker Feldman.

[00:22:38] Speaker 03:
Yet all these years, you've gone to the state court, you've gone to Arizona, you've got another federal action based on the pending, I guess the issue of preclusion, as you said, was the only thing there.

[00:22:52] Speaker 03:
I just, what's your best argument, at least from my perspective, that Ricker-Feldman doesn't apply here?

[00:23:01] Speaker 04:
that the complaint in the district court was filed before the judgment in the state court.

[00:23:09] Speaker 04:
Exxon Mobil.

[00:23:11] Speaker 04:
And you think that settles it?

[00:23:13] Speaker 04:
100% your honor.

[00:23:16] Speaker 04:
The, Enrique Gonzalez also says that the federal courts should protect their jurisdiction and that Rooker Feldman does not prevent where there's an attack on the bankruptcy jurisdiction

[00:23:30] Speaker 04:
Um, a district court exercising jurisdiction.

[00:23:36] Speaker 03:
Okay.

[00:23:36] Speaker 03:
Other questions about my colleague?

[00:23:38] Speaker 03:
No.

[00:23:38] Speaker 03:
All right.

[00:23:39] Speaker 03:
Thank you very much.

[00:23:40] Speaker 03:
Council.

[00:23:40] Speaker 03:
This obviously is a, an unusual case.

[00:23:43] Speaker 04:
Yeah.

[00:23:43] Speaker 04:
Uh, I, I have dealt with this for 12 years and believe me, I would much rather not have dealt with it at all.

[00:23:52] Speaker 03:
Thank you.

[00:23:52] Speaker 03:
Understand that the case just argued is submitted.