[00:00:06] Speaker 03:
We have two Smiths on our court, too.

[00:00:09] Speaker 02:
All righty.

[00:00:13] Speaker 02:
I believe the law said there must be extrinsic evidence of actual fraud in addition to the badges of fraud or, I would add, included in the badges of fraud in order that the Homestead exemption can be reduced by the purchase price.

[00:00:33] Speaker 04:
But the standard of review is clear error.

[00:00:36] Speaker 01:
That's what I was going to ask.

[00:00:37] Speaker 01:
So if the standard of review is clear error, where is the clear error here?

[00:00:44] Speaker 01:
In the courts, to be blunt about it, that this was bought with essentially ill-gotten gains or funds that she was not entitled to.

[00:01:00] Speaker 02:
Well, the clear error is that the cases establish a measuring device.

[00:01:06] Speaker 02:
And what this case has done is decide if somebody is a rich man and because his business takes in a lot of money and he deposits a lot, but not looking at what the expenses are, what the out go is.

[00:01:21] Speaker 02:
It wasn't measured with the right tape measure.

[00:01:25] Speaker 02:
And the judge did not evaluate all the facts.

[00:01:29] Speaker 02:
including the batches of fraud.

[00:01:32] Speaker 03:
And Collier says no particular... So just to tell us that you don't agree with what the judge did, you've got to give us more than that to establish clear error.

[00:01:41] Speaker 03:
What can you point to that should cause us to conclude that the bankruptcy court's determination was clearly erroneous?

[00:01:50] Speaker 02:
Clear error is not the final result.

[00:01:53] Speaker 02:
Clear error is a mistake in what they did.

[00:01:56] Speaker 03:
And so just telling us it's a mistake isn't persuasive.

[00:02:00] Speaker 02:
No.

[00:02:00] Speaker 03:
Give me something that explains why the Bankruptcy Corps was off base.

[00:02:04] Speaker 02:
Because the cases say that it's a mistake.

[00:02:07] Speaker 03:
Stop.

[00:02:08] Speaker 03:
What is a mistake?

[00:02:09] Speaker 02:
We're talking about facts here.

[00:02:11] Speaker 03:
You can't just tell me that in other cases the court decided there was error.

[00:02:15] Speaker 03:
You've got to tell me what about this case, what facts, what evidence, what in the record tells us the factual determination was clearly erroneous.

[00:02:23] Speaker 02:
It's not that the factual determination is clear error.

[00:02:26] Speaker 04:
I'm sorry, could you just move to the center so the microphones pick you up?

[00:02:29] Speaker 02:
Not that the factual determination is clear error.

[00:02:37] Speaker 02:
findings that have to be made and so it's not clear error to say a man's a rich man because he takes in millions a month in his business and it could be true but you haven't done the right measure and you've made a legal error and a legal error is

[00:02:55] Speaker 02:
I have considered the man takes in millions a month in his business, and I've also considered what his expenses are.

[00:03:02] Speaker 02:
And the judge never even stated that she was looking at all the facts.

[00:03:11] Speaker 01:
For instance... Counsel, let me be more specific.

[00:03:14] Speaker 01:
The bankruptcy court found specifically that the debtor intended

[00:03:21] Speaker 01:
to hinder, delay and defraud the creditors by taking certain actions, including depositing and withdrawing from the Citibank account.

[00:03:35] Speaker 01:
That's a factual finding about intent.

[00:03:39] Speaker 01:
Why is that clearly erroneous?

[00:03:42] Speaker 02:
It's a conclusion.

[00:03:43] Speaker 02:
It describes no evidence.

[00:03:45] Speaker 02:
It does no tracing.

[00:03:47] Speaker 01:
There are pages and pages of descriptions of the evidence to result in the finding that the debtor had the intent to defraud.

[00:04:00] Speaker 01:
So just to say that there isn't anything is not helpful because there's a lot there about how these transactions occurred and when they occurred and they sort of

[00:04:19] Speaker 01:
of the situation, and I'm having a hard time seeing where there's clear error.

[00:04:27] Speaker 02:
Your Honor, I'm not saying that at all, but look exactly what they say.

[00:04:32] Speaker 02:
There were transfers to Montenegro, there were transfers back, there were transfers for people with strange

[00:04:39] Speaker 02:
There was defaultation, which means stealing money.

[00:04:44] Speaker 02:
There were all of these pages and pages.

[00:04:47] Speaker 02:
There was a trust, and it's a sham trust because we say it's a sham trust.

[00:04:52] Speaker 02:
Yes.

[00:04:52] Speaker 03:
There were payments for women's shoes.

[00:04:54] Speaker 03:
There were payments to clothing boutiques, nail salon, cosmetic stores, which the court observes is pretty unlikely for a priest in his 80s.

[00:05:03] Speaker 03:
That's evidence cited in the decision and you're just telling us, oh, there's no evidence, there's no record.

[00:05:08] Speaker 03:
You've got to give us something more than that if you want us to hold that the actual finding was clearly erroneous.

[00:05:14] Speaker 02:
If we were doing technical trust, did you do the letter of the law?

[00:05:18] Speaker 02:
Fine.

[00:05:18] Speaker 02:
But what happened was there was a bank account and there was Father Doni or Father Kehoney

[00:05:25] Speaker 02:
There was a bank account.

[00:05:28] Speaker 02:
Oh, Rita opened it up in his name, I guess, to control it.

[00:05:32] Speaker 02:
Well, maybe she did.

[00:05:34] Speaker 02:
The money in it, and we did not go with what Mr. Pena did, that this was a complete done deal.

[00:05:43] Speaker 02:
It wasn't a done deal.

[00:05:44] Speaker 02:
It was basically Rita herself trying to start a deal.

[00:05:48] Speaker 02:
It was the start of a deal.

[00:05:51] Speaker 02:
Money was put in the account.

[00:05:53] Speaker 02:
They shared the account.

[00:05:55] Speaker 02:
She even lived with Father Donnie, which he denies.

[00:05:58] Speaker 02:
And so that kind of was a big problem why he didn't want to go through it, because he figured the archdiocese might... Mr. Smith, I guess I'll say I was impressed by your candor at your opening brief, page eight.

[00:06:14] Speaker 04:
You said that the debtor's overall behavior regarding the property was consistent with someone who was attempting to hide property from creditors, but was making major mistakes in this effort.

[00:06:24] Speaker 04:
which would have been enough, but it was also just as consistent with someone who was not thinking of creditors and exemptions at all.

[00:06:30] Speaker 04:
Under a clear error standard, that is the district court's choice to make, which inference to draw from that evidence.

[00:06:44] Speaker 02:
If either interest inference could be drawn, if either one could be drawn, the court actually has to take the one that points towards honesty.

[00:06:53] Speaker 02:
I cited a case, I think it was a Supreme Court case, and that makes sense.

[00:07:00] Speaker 01:
But counsel, it's a credibility question.

[00:07:03] Speaker 01:
For example, as you just said, the priest denied that they had shared the property, and that's a credibility finding, which is classically within the fact-finder's bailiwick.

[00:07:22] Speaker 01:
Basically, what they found was that the debtor bought this property with stolen funds.

[00:07:29] Speaker 01:
That's a factual finding.

[00:07:34] Speaker 01:
And I have yet to hear why that is implausible or improper.

[00:07:41] Speaker 02:
That's a conclusion.

[00:07:43] Speaker 02:
Who was it stolen from?

[00:07:45] Speaker 02:
The money was put in the daughter's account well before there was any dispute.

[00:07:50] Speaker 02:
And Adrida never denies it.

[00:07:53] Speaker 02:
A Montenegrin account in Montenegro and before there was any dispute with the

[00:08:00] Speaker 02:
her money, but with two, with the daughter's names on it, a sort of a normal... I'm not sure that helps you.

[00:08:09] Speaker 03:
Because if it's put into accounts held in another name, it seems to suggest that, in fact, this is an effort by Ms.

[00:08:17] Speaker 03:
Kessler to keep assets out of her name because they might be reached in the bankruptcy.

[00:08:24] Speaker 02:
Well, this is 10 years.

[00:08:25] Speaker 03:
I mean, I got to tell you, the facts here make me think I'm watching a Saturday Night Live sketch.

[00:08:30] Speaker 03:
And so to tell us, oh no, the facts don't support, it's sort of like telling me, don't believe what your eyes are seeing.

[00:08:37] Speaker 03:
You've got to come up with more specific reasons for why we should reject the factual finding made by the bankruptcy court.

[00:08:45] Speaker 02:
10 people saw somebody do a 30-foot long jump and at the end of the pit.

[00:08:51] Speaker 02:
And they said, no, the guy didn't.

[00:08:52] Speaker 02:
He doesn't get any credit for it.

[00:08:55] Speaker 02:
It was a clear as day.

[00:08:56] Speaker 02:
He didn't get credit for it.

[00:08:58] Speaker 02:
He shouldn't have.

[00:08:59] Speaker 03:
And you'll have testimony from the 10 witnesses saying what they saw.

[00:09:01] Speaker 02:
And he would not get up.

[00:09:02] Speaker 03:
Point me to something similar to that on behalf of your client.

[00:09:05] Speaker 03:
I haven't seen anything other than your client insisting, oh, I didn't mean to cheat anybody.

[00:09:10] Speaker 02:
OK.

[00:09:11] Speaker 02:
On that analogy.

[00:09:14] Speaker 02:
The mistake would be he doesn't get a world record, he doesn't get anything, he gets zero because it wasn't measured.

[00:09:19] Speaker 02:
It's the same thing here.

[00:09:21] Speaker 02:
There's a lot of cases that uphold inheritance.

[00:09:25] Speaker 02:
Yes, before the dispute arose, we put money and we put it in the kids' accounts so that when we finally died, they would have it.

[00:09:36] Speaker 02:
Then the dispute arises.

[00:09:38] Speaker 02:
That's a legitimate inheritance that had another meaning and

[00:09:43] Speaker 02:
I cited cases in my brief where that was fine.

[00:09:48] Speaker 03:
How does that make the assets where you're insisting that were actually hers, she put into her kids' accounts.

[00:09:55] Speaker 03:
But if they're hers, then they're within the reach of the bankruptcy court.

[00:09:57] Speaker 02:
And they were.

[00:09:59] Speaker 03:
And the bankruptcy court is free to conclude, well, this effort to put them in somebody else's name, her kids, Father Kahane, anybody else,

[00:10:09] Speaker 03:
That's an attempt to keep them away from her creditors.

[00:10:13] Speaker 03:
That seems pretty consistent.

[00:10:14] Speaker 02:
They are in the reach, Your Honor, and they went into the bankruptcy court and the judge herself said you can claim a home state.

[00:10:21] Speaker 02:
You have an equitable interest.

[00:10:22] Speaker 02:
You've never denied it's your money.

[00:10:24] Speaker 02:
Yes, of course they went in.

[00:10:26] Speaker 02:
We're not denying it.

[00:10:27] Speaker 02:
The question is, now does she get an exemption?

[00:10:31] Speaker 02:
An exemption that she never denied was property of this state.

[00:10:35] Speaker 02:
And we say she gets an exemption

[00:10:38] Speaker 03:
If she acquired the property for which she's claiming an exemption from funds that were within the reach of the estate, I'm having trouble understanding where it is that she's been shorted.

[00:10:52] Speaker 02:
She's not been shorted.

[00:10:53] Speaker 02:
There's no problem with it.

[00:10:55] Speaker 02:
The funds were within the reach of the estate.

[00:10:58] Speaker 02:
Anything she buys is within the reach of the estate.

[00:11:01] Speaker 02:
She's not denying it.

[00:11:02] Speaker 02:
She never denied it.

[00:11:03] Speaker 02:
The judge didn't deny it.

[00:11:05] Speaker 02:
She says, you have an equitable interest.

[00:11:07] Speaker 02:
Whatever money you put in is an interest you can fight to protect on a homestead.

[00:11:12] Speaker 02:
So there's no question.

[00:11:15] Speaker 02:
And she's simply saying, OK.

[00:11:17] Speaker 02:
I want the homeless.

[00:11:18] Speaker 02:
See, this is a bit of an odd statute.

[00:11:21] Speaker 02:
I think it happened because OJ went to Florida and so

[00:11:26] Speaker 02:
You know, they have to make something special, but the absolute cases say you can file a bankruptcy and you know it'll harm creditors.

[00:11:33] Speaker 02:
You can even pay three years back IRS debt, $100,000 in non-exempt money.

[00:11:39] Speaker 02:
I'll pay off the IRS right before the bankruptcy and that way I'll get rid of a debt that would survive and I'll harm all the unsecured creditors.

[00:11:48] Speaker 02:
because they won't get sort of like a preference.

[00:11:51] Speaker 02:
And that doesn't mean you don't get 523 or 522-0.

[00:11:54] Speaker 02:
So we're not talking about any facts.

[00:11:59] Speaker 02:
And yes, there were pages and pages.

[00:12:02] Speaker 02:
But if you go through the pages, practically all of them were findings that Mr. Park

[00:12:07] Speaker 02:
It's a 20, uh, 40 page or 28 page minute order.

[00:12:11] Speaker 02:
Oh, there's findings that Mr. Park said this and Mr. Park said that and Mr. Park said that, yes, see, Mr. Park did say that.

[00:12:18] Speaker 02:
But no, you have to find it.

[00:12:20] Speaker 02:
And when Mr. Park was said, were, were no descriptions of property, no tracing.

[00:12:25] Speaker 02:
He would say, it's a sham trust, and it went to a person in Slovenia.

[00:12:32] Speaker 02:
My gosh, Slovenia, that really must be hiding money.

[00:12:35] Speaker 02:
But that's where the family's from.

[00:12:38] Speaker 02:
So yes, there was a clear error.

[00:12:41] Speaker 02:
They have a measuring device.

[00:12:42] Speaker 02:
They didn't use the measuring device.

[00:12:45] Speaker 02:
No one described any facts.

[00:12:47] Speaker 02:
No one described any property permanently put out of the reach of creditors.

[00:12:51] Speaker 03:
You and I are not reading the same bankruptcy court order, because I see lots of recitation there to support the conclusion, and all you're telling me is that you disagree.

[00:12:59] Speaker 02:
No one can say anything except the conclusions.

[00:13:01] Speaker 02:
They can't repeat a fact.

[00:13:03] Speaker 02:
You can read it, and you can say, yeah, this conclusion was made, and that it was.

[00:13:08] Speaker 02:
What fact?

[00:13:09] Speaker 02:
This man named Gorky Jick or something like that got $7,000.

[00:13:14] Speaker 02:
Pretty mysterious.

[00:13:16] Speaker 02:
Why did he get it?

[00:13:17] Speaker 02:
What did he pay for it?

[00:13:20] Speaker 02:
This was simply the way they do things in Montenegro is they buy stuff as a family.

[00:13:27] Speaker 02:
And they said that the funds where they use the term... Ms.

[00:13:40] Speaker 03:
Kessler says that she purchased the Aldea property from Father Kehane.

[00:13:49] Speaker 03:
Father Kehane says, I never sold my property to Miss Kessler.

[00:13:53] Speaker 03:
The bankruptcy court concluded that his testimony was credible and hers was not.

[00:14:00] Speaker 03:
You need to persuade us that that was a clearly erroneous finding.

[00:14:06] Speaker 03:
And what have you offered other than insisting that the bankruptcy court messed up?

[00:14:11] Speaker 02:
He didn't sell Aldito.

[00:14:14] Speaker 02:
No question he didn't sell it to her.

[00:14:18] Speaker 02:
It didn't go through.

[00:14:18] Speaker 02:
And Aldia is not the property that people are calling exempt.

[00:14:24] Speaker 02:
The property is Texahoma that was bought.

[00:14:26] Speaker 03:
Your client said that she received a deed transferring that property, me and my two daughters.

[00:14:31] Speaker 03:
And you're now saying there's no question that wasn't really true.

[00:14:35] Speaker 03:
So why shouldn't the bankruptcy court be sustained in saying your client's not very credible?

[00:14:42] Speaker 03:
She's given multiple stories.

[00:14:44] Speaker 03:
You're denying one of them.

[00:14:46] Speaker 03:
It's hard to say.

[00:14:47] Speaker 03:
It's clearly erroneous.

[00:14:49] Speaker 02:
And Father Donnie said that he didn't sign an offer of purchase in front of a notary, which he did.

[00:14:54] Speaker 02:
But the fact is, this was not... They all thought maybe it wasn't a sale.

[00:15:02] Speaker 02:
It was Drita was trying to start something that would end up in a sale, and it just did not go through.

[00:15:09] Speaker 02:
And they kind of don't even need-they spend all their time on that.

[00:15:14] Speaker 02:
They spend a lot of time on the 12, 15 days, which you don't need when it's in the same state.

[00:15:20] Speaker 02:
And so, because of that, they pay no attention to 523-0.

[00:15:23] Speaker 02:
But the real- Thank you, Mr. Smith.

[00:15:25] Speaker 04:
We'll give you a minute for rebuttal.

[00:15:28] Speaker 04:
You're out of time.

[00:15:44] Speaker 04:
Mr. Park.

[00:15:46] Speaker 00:
Good morning, Your Honor.

[00:15:47] Speaker 00:
My name is Nathan Park.

[00:15:48] Speaker 00:
I'm here on behalf of Travelers.

[00:15:52] Speaker 00:
I will be brief, and I will only make just a handful of points, and I will be happy to answer any questions that Your Honors may have.

[00:16:02] Speaker 00:
First point I would raise is the fact that I just want to address Mr. Smith's point that Ms.

[00:16:09] Speaker 00:
Kessler has been forthright during the bankruptcy process.

[00:16:13] Speaker 00:
Can you speak a little louder?

[00:16:14] Speaker 00:
I apologize.

[00:16:15] Speaker 00:
I want to address the point by Mr. Smith that Ms.

[00:16:19] Speaker 00:
Kessler has been forthright during the bankruptcy process.

[00:16:22] Speaker 00:
I just want to point out the fact that the record makes it rather clear that travelers, after getting the judgment, conducted post-judgment discovery by sending subpoenas to financial institutions, and the information that travelers receive established a pattern of fraud of concealing assets.

[00:16:42] Speaker 00:
such that travelers filed a verified complaint alleging fraudulent transfer.

[00:16:48] Speaker 00:
Shortly after that complaint was filed and served, that's when Ms.

[00:16:53] Speaker 00:
Kessler filed for bankruptcy and then also claimed for the homestead exemption.

[00:16:58] Speaker 00:
So whatever admission that Ms.

[00:17:02] Speaker 00:
Kessler made in bankruptcy was bounded by the fact that she was facing a fraudulent transfer action that is verified and supported by

[00:17:11] Speaker 00:
supported by business records and other records from the financial institutions.

[00:17:16] Speaker 00:
The second point I would make is this.

[00:17:21] Speaker 00:
In this appeal, Ms.

[00:17:23] Speaker 00:
Kessler seems to be making the argument that all of this was a legitimate exemption planning pre-bankruptcy.

[00:17:31] Speaker 00:
That narrative was not presented before the bankruptcy court.

[00:17:34] Speaker 00:
As Your Honors have noted,

[00:17:37] Speaker 00:
multiple rounds of briefing that took place at the bankruptcy court was entirely centered around whether or not it is true that Ms.

[00:17:45] Speaker 00:
Kessler bought this Aldea property, then used that money to tax Homer property.

[00:17:49] Speaker 00:
There was never, this narrative of fact that this was legitimate exemption planning was never before Judge Kaufman.

[00:17:58] Speaker 00:
So it's not even so much that there were two plausible factual narratives and Judge Kaufman chose one.

[00:18:04] Speaker 00:
The argument by Ms.

[00:18:06] Speaker 00:
Kessler is that Judge Kaufman erred by not considering a factual narrative that was not even presented to her.

[00:18:16] Speaker 00:
And I believe that that just cannot stand in the clearly erroneous standard.

[00:18:22] Speaker 00:
Two more small points.

[00:18:25] Speaker 04:
Mr. Park, I guess on that point, the bankruptcy court relied on California law as to the badges of fraud in terms of deciding whether the

[00:18:35] Speaker 04:
there was clear error or not.

[00:18:38] Speaker 04:
Are we compelled to use that lens or can we bottom this just on the ultimate finding that there was intent?

[00:18:46] Speaker 04:
In other words, I'm not sure whether or not state law, it may be helpful, but I'm not sure whether it was required here.

[00:18:53] Speaker 04:
What's your take on that?

[00:18:55] Speaker 00:
Yes, your honor.

[00:18:56] Speaker 00:
The standard for bankruptcy court in assessing whether or not there is a homestead exemption is sufficient facts and

[00:19:05] Speaker 00:
Badges of fraud gives guidance as to whether or not those factors are sufficient.

[00:19:09] Speaker 00:
So my understanding of the law is that it is a guiding principle.

[00:19:18] Speaker 00:
So two small points and I will be finished and I'll be happy to answer questions.

[00:19:23] Speaker 00:
There were a few evidentiary objections that were raised by Ms.

[00:19:27] Speaker 00:
Kessler about, for example, the internal memorandum received

[00:19:32] Speaker 00:
received from Morgan Stanley that travelers received in the part of the post-judgment discovery.

[00:19:41] Speaker 00:
That evidence, Your Honor, was admitted in bankruptcy without objection.

[00:19:47] Speaker 00:
It was not preserved for this appeal, which means that it is to be assessed under plain error.

[00:19:52] Speaker 00:
And that piece of evidence, Your Honor, is business record that Morgan Stanley kept in its ordinary course of business.

[00:19:58] Speaker 00:
It is also a party admission to the, party admission to adverse interest because the declarant in that memorandum is Ms.

[00:20:09] Speaker 00:
Kessler herself.

[00:20:11] Speaker 00:
And final point is I believe Ms.

[00:20:14] Speaker 00:
Smith, Mr. Smith just made that argument in his oral argument as well as several times in his brief that when there are two competing factual narratives the court is compelled to choose the, lean to the side of honesty

[00:20:29] Speaker 00:
That I don't believe is a correct statement of the law.

[00:20:33] Speaker 00:
It is based on a Second Circuit case called Kellison.

[00:20:36] Speaker 00:
And when you review the actual Kellison opinion, the opinion does not say anything of that sort.

[00:20:43] Speaker 00:
That is actually in the full quotation of that record of that case at the Second Circuit is that the appellant in that case made that argument as in there were two competing cases and there should be the court should

[00:20:57] Speaker 00:
lean towards the explanation of honesty in the immediate Second Circuit language that follows that argument is we disagree.

[00:21:06] Speaker 00:
That is not the holding.

[00:21:09] Speaker 00:
That concludes my oral argument, Your Honor.

[00:21:11] Speaker 04:
I'll be happy to answer questions.

[00:21:12] Speaker 04:
Colleagues have any questions?

[00:21:15] Speaker 01:
No, thank you.

[00:21:17] Speaker 04:
All right.

[00:21:17] Speaker 04:
Thank you, Mr. Park.

[00:21:18] Speaker 04:
Thanks for joining us today.

[00:21:25] Speaker 02:
Thank you, Your Honor.

[00:21:25] Speaker 02:
Pooled was the word I was trying to

[00:21:28] Speaker 02:
And that's what Travis always called it, pooled money, which goes hand in hands with it being family money that she's using for a family purpose, because how much of her money was in the pool?

[00:21:41] Speaker 02:
And Mr. Park did just what has been done throughout this case.

[00:21:46] Speaker 02:
We had 30 subpoenas.

[00:21:48] Speaker 02:
We found a lot of evidence.

[00:21:50] Speaker 02:
Everyone reviewed the evidence.

[00:21:52] Speaker 02:
It was clear, tons of evidence.

[00:21:54] Speaker 02:
Yes, if you have a lot of evidence and

[00:21:58] Speaker 02:
Lots of evidence, and it all supports you.

[00:22:01] Speaker 02:
Then you win.

[00:22:02] Speaker 02:
But you can't just say that you have it.

[00:22:04] Speaker 02:
You have to describe it.

[00:22:06] Speaker 02:
No tracing at all.

[00:22:08] Speaker 02:
No saying that, no defalcation, she stole it.

[00:22:13] Speaker 02:
No, no, it never happened.

[00:22:15] Speaker 02:
They can't say it.

[00:22:16] Speaker 02:
No saying she gave it to a man with a Montenegrin name, and he didn't get a fair amount back, or there wasn't a good reason.

[00:22:24] Speaker 02:
Convoluted, they call it.

[00:22:26] Speaker 02:
Byzantine.

[00:22:28] Speaker 02:
sham.

[00:22:29] Speaker 02:
All their words, judge follows them, quotes Mr. Park and yet never gets down to saying this was transferred and was put out of the reach of creditors.

[00:22:42] Speaker 02:
No money was ever, nothing was ever put out of the reach of creditors and the way to tell actual fraud from

[00:22:49] Speaker 02:
that you'd have to have someone lying about who owned the money.

[00:22:54] Speaker 02:
She always said it was her money.

[00:22:56] Speaker 02:
It wasn't money.

[00:22:57] Speaker 02:
It was at the meeting.

[00:22:59] Speaker 02:
Oh, she admitted it was her money.

[00:23:01] Speaker 02:
No, she never denied it was her money.

[00:23:03] Speaker 04:
Thank you.

[00:23:04] Speaker 04:
Thank you, Mr. Smith.

[00:23:06] Speaker 04:
All right, the case is submitted.