[00:00:00] Speaker 04:
We'll move on to the second case set for argument, which is Cassell versus O'Malley, case number 23-55402.

[00:00:27] Speaker 03:
May it please the court Lawrence Rolfing on behalf of Stacey Cassell.

[00:00:30] Speaker 03:
This is a social security disability case.

[00:00:32] Speaker 03:
It's a cessation case arising out of a very old finding that Ms.

[00:00:37] Speaker 03:
Cassell was in fact disabled.

[00:00:39] Speaker 03:
The primary thrust of this case centers on the documented mental impairment in 2007 and redocumented in 2018.

[00:00:50] Speaker 03:
Ms.

[00:00:50] Speaker 03:
Cassell lacks the sufficient concentration to perform serial sevens.

[00:00:55] Speaker 03:
or in the later evaluation, even serial fives, which is not standard testing, but if you can't do serial fives, that's pretty poor concentration.

[00:01:07] Speaker 03:
And so this manifests in two ways.

[00:01:10] Speaker 03:
The first thing that it manifests as, Dr. Riyanajad in the earlier application said that MIS-CASEL would have moderate to severe deficiencies in performing detailed and complex tasks, which would eliminate the ability to perform work that's classified in this case as reasoning level two, which is all of the work that's been described.

[00:01:33] Speaker 03:
And the fact that it was,

[00:01:36] Speaker 03:
an older opinion, it's still probative to this time period because the findings on concentration on mental status examination, serial sevens, is the same.

[00:01:50] Speaker 03:
It's poor or failed.

[00:01:52] Speaker 03:
She doesn't have the concentration to subtract seven serially from 100.

[00:01:57] Speaker 03:
She fails on that.

[00:01:58] Speaker 03:
She can't even do fives, which is a far simpler task.

[00:02:02] Speaker 03:
The other manifestation of this problem is that the judge

[00:02:05] Speaker 03:
described Ms.

[00:02:06] Speaker 03:
Gesell as able to perform simple work, as this court has defined in Zavalin and its progeny, as including reasoning level two, but limited her further to a static work environment.

[00:02:19] Speaker 03:
And a static work environment is an unchanging environment.

[00:02:24] Speaker 03:
It is

[00:02:25] Speaker 03:
It doesn't fit with the types of work that are performed at Reasoning Level 2.

[00:02:29] Speaker 03:
It is quintessentially the type of work that would be described as Reasoning Level 1, and then even a small sliver of that.

[00:02:38] Speaker 04:
Let me ask you about that, because for a static work environment, does that describe, I mean, that's an accommodation that could be made.

[00:02:47] Speaker 04:
It doesn't really describe anything about the task performed, does it?

[00:02:52] Speaker 04:
I mean, you could do complicated tasks in a static work environment or you could do simple tasks in a non-static work environment.

[00:03:05] Speaker 03:
Let me just break that into pieces, Judge.

[00:03:07] Speaker 03:
The Commissioner disavows the use of accommodation in disability adjudications at all?

[00:03:12] Speaker 03:
That's fine.

[00:03:13] Speaker 04:
But I guess I wasn't using it as a legal hook.

[00:03:18] Speaker 04:
I was just saying, it doesn't seem to me that static work environment defines the disability.

[00:03:25] Speaker 04:
I mean, it doesn't define the work that can be done.

[00:03:27] Speaker 04:
It defines the environment in which it can be done.

[00:03:30] Speaker 04:
So you could have, it doesn't really tell, it doesn't tell us anything about the task that she can do, just where she can do it and under what environment.

[00:03:38] Speaker 03:
But static also implies not the task singular, but the tasks plural that she can perform.

[00:03:46] Speaker 03:
And if an occupation requires more than one task, you would define it as a non-static environment, right?

[00:03:52] Speaker 03:
Because they're doing different tasks throughout the day or at different

[00:03:58] Speaker 03:
days or at different periods of time, but it's not a static work environment.

[00:04:03] Speaker 03:
Whereas reasoning level one and two, which is performing one and two-step instructions, and many of the occupations that are defined as reasoning level one have one function that's performed as defined in the dictionary of occupational titles.

[00:04:18] Speaker 03:
And that is what static means.

[00:04:22] Speaker 03:
And this court recently,

[00:04:24] Speaker 03:
in Stiffler versus O'Malley said that the limitation to occasional changes was fits within the rubric of reasoning level two.

[00:04:34] Speaker 03:
And that decision is the final binding precedent of the circuit.

[00:04:41] Speaker 03:
This case is a much more strict limitation.

[00:04:44] Speaker 03:
It is a further narrowing of the kinds and types of work that Stacey Cassell can perform.

[00:04:53] Speaker 03:
a complex job in a static work environment, maybe physically static.

[00:05:00] Speaker 03:
I sit in my office every day and I sashay up to my computer and I look at records and I write briefs.

[00:05:09] Speaker 03:
And so I do the same thing every day.

[00:05:12] Speaker 03:
But it's complicated because

[00:05:16] Speaker 03:
As this court wrestles with varying fact patterns, I have to wrestle with varying factor.

[00:05:21] Speaker 03:
And so it's it is mentally non static.

[00:05:24] Speaker 04:
It is your definite.

[00:05:25] Speaker 04:
So that's your definition of static work.

[00:05:27] Speaker 03:
Yes, it is.

[00:05:29] Speaker 03:
What kinds of tasks is this person required to perform?

[00:05:34] Speaker 03:
And so a static work environment is going to be the same

[00:05:37] Speaker 03:
nature and quality of tasks or tasks singular over and over again.

[00:05:44] Speaker 03:
It's one and two step instructions.

[00:05:47] Speaker 03:
There's no details.

[00:05:48] Speaker 03:
There's no complexity.

[00:05:50] Speaker 03:
There's little or no variability.

[00:05:53] Speaker 03:
That is a static work environment.

[00:05:57] Speaker 03:
A non-static work environment is going to require more duties, more variability, more variables,

[00:06:05] Speaker 03:
And even if they're from standardized situations, that is a non-static work environment.

[00:06:15] Speaker 03:
The only other issue that's kind of lingering in the background is the doctrine of the continuing presumption, which this court in Lambert struck down under Brandeis deference.

[00:06:34] Speaker 03:
I don't believe that we need to get into Loper-Brite on the facts of this case.

[00:06:40] Speaker 03:
The fact of the matter is that even under the Patty D. Schweiker progeny, including Chavez, evidence of a preexisting impairment flows forward in time absent a change in circumstances.

[00:06:57] Speaker 03:
And the district court in this case says, well, her asthma got better.

[00:06:59] Speaker 03:
It's like, yes, but her mental functioning never did.

[00:07:02] Speaker 03:
Her mental functioning never did.

[00:07:04] Speaker 03:
And the record doesn't support a conclusion that her mental functioning never got better, which is why Dr. Rayenjad's opinion is still probative today.

[00:07:14] Speaker 00:
Do you want to say something about your motion for a sentence six remand?

[00:07:19] Speaker 00:
My question is, as I understand our case law under Luna, that sort of remand is appropriate if you have some later

[00:07:30] Speaker 00:
decision that's not reconcilable with the earlier one.

[00:07:33] Speaker 00:
And here, I mean, the stroke happened during the time period that's at issue in this case, but the determination of the effects that it was causing that caused impairment was afterwards.

[00:07:49] Speaker 00:
So can't the two decisions be reconciled by saying, well, you know, the symptoms were worse later on and they don't seem inconsistent.

[00:07:57] Speaker 00:
So what's your answer to that?

[00:07:59] Speaker 03:
The A.M.J.

[00:08:00] Speaker 03:
in Ms.

[00:08:02] Speaker 03:
Cassell's second application for benefits bookended two findings.

[00:08:08] Speaker 03:
The stroke in 2019 and the continued lack of ability to ambulate effectively in 2023 and 2024.

[00:08:23] Speaker 03:
The ALJ never suggested that Cassel got worse during this period of time, only that she had a stroke that damaged her ability to engage and function, the musculature to ambulate effectively, and that it's disabling.

[00:08:43] Speaker 03:
as of the date of application.

[00:08:44] Speaker 03:
And the date of application in an SSI case is typically the way that an ALJ is instructed to adjudicate a Title 16 claim because there's no retroactivity.

[00:08:55] Speaker 03:
You can't get benefits until the month after the month in which you apply.

[00:08:58] Speaker 03:
And so to infer that ALJ Reich's decision is limited to the date of application in 2021 is

[00:09:07] Speaker 03:
is actually not the right inference to draw.

[00:09:11] Speaker 03:
That inference doesn't flow from it because of the non-retroactivity nature of an SSI claim.

[00:09:19] Speaker 03:
And we also have, in terms of filing a motion for sentence agreement, we have a good cause requirement.

[00:09:26] Speaker 03:
And Stacey Cassell appeared at her termination hearing

[00:09:31] Speaker 03:
by herself.

[00:09:32] Speaker 03:
She's a borderline intellectual functioning person.

[00:09:34] Speaker 03:
That's well documented in this file.

[00:09:37] Speaker 03:
And she goes into the hearing alone and doesn't have the sophistication to realize that her later medical events are actually relevant to the claim that was before ALJ Hawkinsmith in 2020.

[00:09:51] Speaker 03:
And so the unique facts of this case, she has a mental impairment.

[00:09:55] Speaker 03:
She's unrepresented.

[00:09:58] Speaker 03:
And we have a later ALJ decisions finding that based on the evidence of the 2019 stroke that she's disabled, not later than the month after the month in which the appeals council denies review on Judge Hawkinsmith's decision.

[00:10:12] Speaker 03:
That establishes that this decision and the evidence that this decision is pointing to relates back in time and there is good cause for a remand.

[00:10:23] Speaker 03:
because of Stacey Cassell's borderline intellectual functioning and unrepresented status.

[00:10:31] Speaker 01:
What's the closest authority that says that we take into account that she was unrepresented and don't have to look at the record that was made?

[00:10:44] Speaker 03:
The closest authority would be Brown versus Heckler, where the court says the ALJ has a duty to fully and fairly develop the record.

[00:10:53] Speaker 03:
And then it would fall under that umbrella of fully and fairly developing the record.

[00:11:01] Speaker 04:
OK, thank you.

[00:11:02] Speaker 04:
Thank you.

[00:11:07] Speaker 04:
Go ahead, Council.

[00:11:14] Speaker 02:
Good morning, may it please the court, C. Modi on behalf of the Commissioner of Social Security.

[00:11:18] Speaker 02:
This case has taken a number of twists and turns, but ultimately nothing changes the fact that substantial evidence supports the Commissioner's final decision and should be affirmed.

[00:11:26] Speaker 01:
Could you just slow down just a little bit?

[00:11:28] Speaker 02:
Of course, Your Honor, thank you.

[00:11:31] Speaker 02:
So Your Honor, the context of this case is that the claimant was found disabled in March 2010 because she had respiratory impairments that satisfy the criteria of a presumptive disabling impairment.

[00:11:40] Speaker 02:
No other findings about the claimant's other impairments were made as part of that determination.

[00:11:44] Speaker 02:
And the claim of subsequent medical improvement in her respiratory impairments to the point that it no longer satisfy the criteria of a disabling impairment, that is not an issue at any point in this litigation.

[00:11:54] Speaker 04:
So your position is that this is a whole new claim based on new disabilities?

[00:12:04] Speaker 02:
Well, Your Honor, when it comes to the mental limitations and the ALJ's assessment of the mental limitations, that was a new in the claim that's an issue in this appeal, because there was never any findings made about the claimant's mental impairments back in when she was found disabled in 2010.

[00:12:19] Speaker 02:
So there's no basis for comparison.

[00:12:21] Speaker 02:
The ALJ determined the claimant's mental limitations essentially anew as part of the issue, the case at issue here.

[00:12:27] Speaker 02:
So looking at the time period from December 2017 through September 2020.

[00:12:31] Speaker 02:
And based on the evidence that was before the ALJ, so looking at the consultative examination,

[00:12:38] Speaker 02:
the same examination my opponent mentions where she did have limitations performing serial sevens and serial fives calculations that same examiner found that she had intact concentration persistence and pace overall and concluded that she had no limitations performing simple routine tasks and at most only mild limitations performing mental activities overall.

[00:12:59] Speaker 01:
We are stuck with looking at whether or not there was improvement in the

[00:13:04] Speaker 01:
the conditions that she was originally found disabled.

[00:13:08] Speaker 02:
Yes, Your Honor.

[00:13:09] Speaker 02:
It's solely the comparison.

[00:13:10] Speaker 01:
And we ignore everything else that we know existed then.

[00:13:14] Speaker 02:
Well, Your Honor, because there was no basis of comparison back.

[00:13:16] Speaker 02:
The only findings were made regarding the respiratory impairment.

[00:13:19] Speaker 02:
And so that improvement was made in that context.

[00:13:21] Speaker 02:
There was nothing to compare with the mental limitations.

[00:13:23] Speaker 02:
But even when we look at that evidence, which predates the period of issue by almost over nine years,

[00:13:30] Speaker 02:
Even then, there's absolutely nothing inconsistent with what that examiner found in 2008, because that examiner also found that the claimant could carry out simple instructions without any limitations.

[00:13:42] Speaker 02:
That examiner did find that the claimant had moderate or severe limitations in performing detailed and complex tasks.

[00:13:48] Speaker 02:
But the ALJ also found that, too.

[00:13:50] Speaker 02:
The ALJ found that the claimant couldn't perform detailed and complex tasks and found that she can only perform simple routine tasks.

[00:13:56] Speaker 02:
So again, there is absolutely nothing inconsistent with even this remote evidence.

[00:14:00] Speaker 04:
Can you address this static work environment issue?

[00:14:04] Speaker 04:
I mean, do you take the position that static work environment describes the environment that you work in, or does it actually describe the tasks that you're asked to perform?

[00:14:14] Speaker 02:
Your Honor, this case, this court in Stifler has answered that question definitively by saying that the work environment relates to your physical location, the surroundings where you work.

[00:14:24] Speaker 02:
It does not relate to the task itself.

[00:14:26] Speaker 02:
And the claimant in Stifler made the same error that the claimant here is making, which is trying to conflate tasks with environment.

[00:14:34] Speaker 02:
this court in Stiftler clearly said that they're distinct, that tasks involve your responsibilities during the day, what you do.

[00:14:40] Speaker 02:
And as you are, I think in the hypothetical you had mentioned earlier, Your Honor, that somebody can perform detailed tasks in a static work environment or simple tasks in a changing environment, but ultimately they're different.

[00:14:50] Speaker 02:
And the way we know they're different is because the RFC lists them as different things, tasks versus environment.

[00:14:56] Speaker 04:
Well, and didn't the

[00:14:58] Speaker 04:
didn't ALJ also look at basically do a comparator and say look you can clearly do multiple tasks because your daily your daily life involves multiple tasks like I think for her it was you know child care and you know other other things that she was involved in on a day you know shopping I mean so if you can do that then why can't you you can do multiple tasks but

[00:15:26] Speaker 04:
did recognize some limitations, right?

[00:15:29] Speaker 02:
Exactly, Your Honor.

[00:15:29] Speaker 02:
The ALG determined the claimant's functional capacity based on the totality of the evidence, including the medical opinions I outlined earlier, which plainly endorsed her ability to perform a minimum of simple tasks, and also looked at the claimant's day-to-day activities, her ability to take care of her children and manage her household, looked at the treatment evidence, her intact mental status findings,

[00:15:50] Speaker 02:
I looked at all of that and then crafted the RFC saying that she could perform simple routine tasks in a simple in a static work environment.

[00:15:57] Speaker 02:
And again,

[00:15:59] Speaker 02:
When it comes to comparing the RFC with the Dictionary of Occupational Titles, and as this court held in Stifler, there's absolutely nothing inconsistent between an RFC for simple routine tasks and reasoning level two jobs, which are at issue here.

[00:16:13] Speaker 02:
The ALJ relied upon reasoning level two jobs to find the claimant not disabled.

[00:16:18] Speaker 02:
And it's the exact same circumstance here as in Stifler, that we have a simple routine task RFC and reasoning level two jobs, and they're entirely compatible with one another.

[00:16:27] Speaker 02:
And then the issue of the work environment is completely irrelevant to this calculus because the DOT doesn't discuss work environment.

[00:16:35] Speaker 02:
It is silent on that issue about the work setting, their location, and things like that.

[00:16:40] Speaker 02:
So there can be no conflict between the RFC and the DOT on an issue where the DOT is silent.

[00:16:51] Speaker 02:
Now I think beyond the issue of the ALJ's evaluation of the mental limitations and the application of Stiffler to this case, which should be controlling, I want to touch briefly on the sentence 6 motion that was filed recently and to discuss

[00:17:08] Speaker 02:
Why does not justify why remain under sentence six of section four or five G is not justified here.

[00:17:14] Speaker 02:
And I think, Your Honor, Judge Miller touched on this by by highlighting that the two claims of all two different periods, we have the subsequent award which.

[00:17:23] Speaker 02:
deals with the period from July 2021 onward through the decision date of August 2024.

[00:17:28] Speaker 02:
And the decision issue in this appeal runs from 2017 to September 2020.

[00:17:33] Speaker 02:
And so we have a gap of almost 10 months separating these two decisions.

[00:17:38] Speaker 02:
And in the cases where this court has found that a subsequent award of benefits does justify remand or sentence six, we've had a much tighter timeline.

[00:17:47] Speaker 02:
I think, you know, again, Luna, for example, your honor, the claimant was found not disabled on a Wednesday and was found disabled as of the fall of the next day, basically.

[00:17:56] Speaker 02:
And so they're in the court here found that it was not possible to reconcile the two when when they were basically abutting time periods.

[00:18:03] Speaker 02:
Here we have a gap of over 10, nearly 10 months.

[00:18:06] Speaker 02:
And as your honor also highlighted as well, we have also different pieces of different impairments, different theories of the case.

[00:18:13] Speaker 02:
You know, in this case, we've discussed mental limitations and the respiratory impairments that dealt entirely with that finding of disability was based on the stroke.

[00:18:22] Speaker 02:
And I think I want to touch on another point that my opponent made.

[00:18:28] Speaker 00:
But the stroke did occur during the time period.

[00:18:31] Speaker 00:
That's an issue in this case, didn't it?

[00:18:34] Speaker 02:
Well, Your Honor, ultimately we have absolutely no evidence of that.

[00:18:37] Speaker 02:
I know that is referenced in the ALJ's decision, but notably there's nothing attached to the motion that documents a stroke occurring during the time period issue.

[00:18:46] Speaker 02:
And I think we noted in our opposition,

[00:18:49] Speaker 02:
The claimant did not reference experiencing a stroke.

[00:18:52] Speaker 02:
The hearing in the case that issue was in May 2020 when the stroke supposedly had occurred.

[00:18:57] Speaker 02:
And even though she was not represented, the ALJ provided her a full opportunity to testify about all of her conditions.

[00:19:02] Speaker 02:
And she did so.

[00:19:03] Speaker 02:
She spoke about her history of respiratory impairments, her history of psychiatric symptoms,

[00:19:08] Speaker 02:
her history of experiencing a heart attack, a stem procedure.

[00:19:13] Speaker 02:
She mentioned all of that in detail.

[00:19:15] Speaker 02:
The ALJ provided her multiple opportunities, open ended questions.

[00:19:18] Speaker 02:
Is there anything else you'd like to share with me here?

[00:19:20] Speaker 02:
And twice she said no.

[00:19:22] Speaker 02:
So this was in May, 2020.

[00:19:24] Speaker 02:
And notably the claimant when she requested a review from the appeals council was represented.

[00:19:28] Speaker 02:
She had an attorney and her attorney submitted a brief in May, 2021.

[00:19:34] Speaker 02:
There was no mention of a stroke in that brief.

[00:19:36] Speaker 02:
Presumably, if she had a stroke and had, you know, limited her to the degree that she alleges, she would have mentioned it, at least through her attorney.

[00:19:44] Speaker 02:
By then, there was no mention of it in that appeals council brief.

[00:19:47] Speaker 02:
As part of her request for review, she submitted dozens of pages of evidence, including evidence from 2019 and 2020, when again, supposedly she had experienced a stroke, there's zero mention of a stroke in any of those records.

[00:20:00] Speaker 02:
There was no mention of a stroke throughout the district court proceedings and throughout the briefing in this case until she filed the motion, there was no mention of a stroke.

[00:20:06] Speaker 02:
So if she, again, if we had a condition like that, which did limit her to that degree and had, and if it did have any bearing on this case, one would have expected it would have been raised at some point until, you know, the eve of this argument, but it wasn't.

[00:20:21] Speaker 02:
So ultimately the claimant, and the claimant importantly has the burden to show that remand under sentence six is justified.

[00:20:28] Speaker 02:
She can by failing to identify any evidence that calls into question the decision issue here.

[00:20:33] Speaker 02:
She has not met that burden Further questions I Don't I don't think so So for these reasons to be asked this court uphold the district court's order and judgment affirming the commission's final decision in this case.

[00:20:52] Speaker 04:
Thank you counsel We'll give you rebuttal

[00:21:00] Speaker 03:
Appeals Council denied review in May of 2021 and the appointment of representative is sent to the Appeals Council in June of 2021.

[00:21:08] Speaker 03:
She was not represented before the Appeals Council by Council.

[00:21:12] Speaker 03:
It's just not, Council misread the record.

[00:21:14] Speaker 03:
The appointment of representative is dated after the date of the Appeals Council denial of review.

[00:21:20] Speaker 03:
And Judge Schroeder posited the question of whether the claimant is limited to the impairments that were existing when she was found disabled in 2010.

[00:21:29] Speaker 03:
And that's not true.

[00:21:32] Speaker 03:
You're not limited to the impairments that exist in 2010 because the judge found medical improvement on the asthma and then adjudicated not as of the termination date, but through the date of decision, which would include all of the impairments that arose

[00:21:46] Speaker 03:
between the termination date in 2017 and the date of decision in 2020.

[00:21:52] Speaker 03:
And so everything counts.

[00:21:55] Speaker 03:
Everything counts.

[00:21:56] Speaker 03:
And the judge really did not give Miss Cassell

[00:22:06] Speaker 03:
an opportunity to even cross-examine the vocational expert.

[00:22:09] Speaker 03:
He just closed the hearing after the vocational expert testified, and he asked, is your testimony consistent?

[00:22:14] Speaker 03:
And not that I would have expected Ms.

[00:22:15] Speaker 03:
Cassell to have a vigorous interrogation of the vocational expert at that time.

[00:22:23] Speaker 03:
Most attorneys don't do it right, so I wouldn't expect somebody with a borderline intellectual functioning to do it right.

[00:22:34] Speaker 03:
versus Heckler, Lester, V. Chader, and the entire line of cases, including Murray versus Heckler, they all require that the judge articulate reasons so that we understand why the judge rejected Dr. Rayanajad's opinion.

[00:22:50] Speaker 03:
And we have these book-end findings of inadequate mental functioning on concentration persistence pace.

[00:23:00] Speaker 03:
During the period that Cassell applied for benefits,

[00:23:03] Speaker 03:
The regulations, the listings, stated that serial 7s and serial 3s was the quintessential attest for maintaining concentration persistence and pace.

[00:23:14] Speaker 03:
And it's true that the later evaluation

[00:23:18] Speaker 03:
Discre in 2018 said that that ms.

[00:23:22] Speaker 03:
Cassell had had no limitations But before saying that she has no or mild limitations.

[00:23:26] Speaker 03:
The doctor said if she gets benefits, she's gonna need a representative payee Which means that she's not capable of maintaining her own finances according to this doctor's report and not being able to maintain your own finances is inconsistent with her running my cash register

[00:23:45] Speaker 03:
It's just not, it doesn't make sense.

[00:23:46] Speaker 03:
And a cash register is a reasoning level three job.

[00:23:49] Speaker 03:
It's not simple.

[00:23:49] Speaker 03:
But if somebody can't handle their own finances, that speaks highly of their inability to sustain mental functioning.

[00:23:58] Speaker 03:
And this court in Garrison and other cases have adopted the Seventh Circuit standard of

[00:24:04] Speaker 03:
cautioning the agency not to use activities of daily living that are performed when I feel like I can do it, as opposed to getting into work and performing work at the beck and call of a reasonable employer.

[00:24:18] Speaker 03:
Cassel, according to the mental status examinations in 2007 and in 2018, and according to Dr. Rayanjad, her attention deficit disorder and borderline intellectual functioning

[00:24:34] Speaker 03:
means that she can't do that kind of work.

[00:24:36] Speaker 03:
She can't.

[00:24:37] Speaker 03:
She couldn't do it then, and she can't do it now.

[00:24:39] Speaker 03:
The fact that she was found disabled on a different basis, the asthma listing, is not dispositive of the probative value of that earlier psychological examination.

[00:24:53] Speaker 03:
Okay.

[00:24:55] Speaker 04:
Thank you.

[00:24:56] Speaker 04:
We'll take it back.

[00:24:57] Speaker 04:
It's always good to give the court something.

[00:24:59] Speaker 03:
I was telling the clerk earlier that I'm in time debt to the court already.

[00:25:03] Speaker 04:
Well, no, we're grateful to your preparation and both your arguments have helped us understand the case.

[00:25:11] Speaker 04:
So thank you.

[00:25:11] Speaker 04:
The case is now submitted.