[00:00:00] Speaker 04:
Good morning, Jeffrey Jones for the appellant and Tom, I'm not sure how to say it either.

[00:00:04] Speaker 04:
I'd like to reserve two minutes for rebuttal.

[00:00:08] Speaker 04:
Please.

[00:00:08] Speaker 04:
Sure.

[00:00:09] Speaker 04:
In the four counts here of impersonating a federal agent.

[00:00:13] Speaker 04:
Mr. Yuganov was convicted.

[00:00:15] Speaker 04:
I believe it's uncontested that one of his purposes, if not his only purpose, was to warn people about what he believed was a threat to national security, the narrative that he put in the affidavit that he submitted in each count.

[00:00:30] Speaker 03:
If that was his purpose, there were other ways to achieve that, you would agree, right?

[00:00:33] Speaker 03:
Other than fraudulently creating search warrants.

[00:00:37] Speaker 04:
No question.

[00:00:39] Speaker 04:
And for all we know, I know that there was

[00:00:42] Speaker 04:
The record in one place touches on one of the FBI agents that testified.

[00:00:46] Speaker 04:
He had contacted the agent.

[00:00:48] Speaker 04:
It didn't come out at trial.

[00:00:49] Speaker 04:
Defense counsel didn't develop why he had contacted the agent.

[00:00:55] Speaker 04:
But he has, if you consider the content of the affidavit, just telling people, he may well have, this is speculative, but he may well have told a lot of people and no one is going to take it seriously.

[00:01:10] Speaker 04:
And perhaps he's decided that

[00:01:12] Speaker 04:
if people thought he was a federal agent and this was coming from the government and was part of an investigation, people would take it seriously.

[00:01:21] Speaker 03:
Yeah, but doesn't that just beg the question?

[00:01:23] Speaker 03:
I mean, can we even get into what his intent was?

[00:01:27] Speaker 03:
Like at the end of the day, there's no dispute.

[00:01:32] Speaker 03:
He fraudulently created search warrants.

[00:01:35] Speaker 03:
That is the trigger for the enhancement, isn't it?

[00:01:39] Speaker 04:
No.

[00:01:39] Speaker 04:
The trigger for the enhancement is to have the purpose of conducting an unlawful search.

[00:01:44] Speaker 04:
And I agree there's a connection there.

[00:01:46] Speaker 04:
And if someone goes to a court seeking a search warrant, I think in the general, you can infer that's certainly evidence that they intended to conduct an unlawful search.

[00:01:59] Speaker 04:
But it's far from dispositive.

[00:02:01] Speaker 04:
And there's a lot more evidence here that he didn't have the intent to actually show up at the Pentagon by himself with a fake ID

[00:02:08] Speaker 04:
and demand entry.

[00:02:10] Speaker 04:
And some of that evidence is, in count one, he did the same thing.

[00:02:15] Speaker 04:
He had the same affidavit.

[00:02:16] Speaker 04:
It was a search warrant.

[00:02:17] Speaker 04:
He submitted it to the Capitol Police.

[00:02:19] Speaker 04:
He didn't try to conduct a search or obtain information from them.

[00:02:22] Speaker 04:
He wanted them to think it was leaked by the media.

[00:02:26] Speaker 04:
And then he takes that same search warrant.

[00:02:27] Speaker 04:
I think the question then becomes, it seems clear in count one, there was no purpose to conduct a search.

[00:02:33] Speaker 04:
So in counts two through four, which happened a little later,

[00:02:37] Speaker 04:
he submits it to courts.

[00:02:39] Speaker 04:
Did that reflect a new purpose that he didn't have in Count 1?

[00:02:42] Speaker 04:
I think for a few reasons, the preponderance of the evidence says no, because he never submitted it to a court that had the authority to grant the search warrant.

[00:02:54] Speaker 02:
Let's say we take your argument as face value.

[00:03:01] Speaker 02:
How can we argue that this error was plain?

[00:03:03] Speaker 02:
Nobody complained about it before the court.

[00:03:06] Speaker 04:
So how can you show that this this error about the sixth level and adjustment that was that was litigated below the defense counsel did object to this one.

[00:03:18] Speaker 02:
I also made a claim about the one claim one but but on the obstruction enhancement issue that was not objective to was it that's playing that's under plane error review.

[00:03:30] Speaker 04:
Yes, sir.

[00:03:32] Speaker 02:
It was okay.

[00:03:33] Speaker 04:
Yes, sir.

[00:03:35] Speaker 04:
Count one was

[00:03:36] Speaker 04:
abuse of discretion is the standard of review for count one.

[00:03:40] Speaker 04:
I mean, sorry, for claim.

[00:03:41] Speaker 04:
For the first claim I'm raising, it's abuse of discretion.

[00:03:43] Speaker 03:
Out of curiosity, and I guess I'll ask probably the same question from the government, I was trying to figure out, I'm not sure how relevant it is to our analysis, how did he actually think he was ever going to

[00:03:55] Speaker 03:
get these documents, which I think is sort of what you were leading to.

[00:03:58] Speaker 03:
He never walked down there and tried to execute the search warrant.

[00:04:01] Speaker 03:
So at best, as I understand it, he sends it into the government or he later on sends it to a court that has no ability.

[00:04:12] Speaker 03:
Did he ever think he was actually going to get these documents?

[00:04:17] Speaker 04:
He submitted everything by email.

[00:04:21] Speaker 04:
I think what he believed is

[00:04:26] Speaker 04:
He did a lot.

[00:04:27] Speaker 04:
We do know the record shows that he did a lot of research.

[00:04:32] Speaker 04:
He wasn't ignorant about how things worked.

[00:04:33] Speaker 04:
I mean, he's not a lawyer certainly, but he did a lot of research.

[00:04:37] Speaker 04:
The government discusses that.

[00:04:38] Speaker 03:
He might be better than some lawyers we see before us.

[00:04:41] Speaker 04:
He certainly thinks so.

[00:04:44] Speaker 04:
But I think he didn't...

[00:04:48] Speaker 04:
He wasn't going to show up before a magistrate judge and argue for the search warrant.

[00:04:53] Speaker 04:
I don't think his target was a judge.

[00:04:55] Speaker 03:
And you would agree if he did that, that the enhancement would be appropriate?

[00:05:01] Speaker 04:
That would be odd.

[00:05:02] Speaker 04:
I'm not sure.

[00:05:04] Speaker 04:
I think that would certainly be a factor in favor.

[00:05:09] Speaker 04:
However, I think it's inherently implausible

[00:05:12] Speaker 04:
That he's going to show up at the Pentagon and say he's a NASA agent.

[00:05:19] Speaker 04:
I think he's clearly, with all due respect, he's delusional in many respects, but he's not irrational in the pursuit of his goals.

[00:05:27] Speaker 04:
I think he would realize that showing up at the Department of Defense, they'd make one call to NASA and he'd be in handcuffs.

[00:05:34] Speaker 03:
Right but my I guess I'm just struggling with where I understand your argument is well this was so implausible but at what point does it become plausible enough and I'm worried that if we adopt that argument.

[00:05:48] Speaker 03:
we just open this up to a whole bunch of problems.

[00:05:53] Speaker 04:
I think what it comes down to in that sense is that it's looking at all the circumstances here, looking at all the evidence.

[00:06:01] Speaker 04:
This is a unique case.

[00:06:02] Speaker 04:
I could see nine cases out of 10 were just applying for a warrant, especially applying for a warrant in a court that has the authority

[00:06:09] Speaker 04:
to grant the warrant, especially since we know he didn't make a mistake.

[00:06:15] Speaker 04:
The record shows that he researched, one of the searches on his computer was, can a search warrant be filed in any federal's jurisdiction?

[00:06:22] Speaker 04:
He knows the answer is no, and he never filed it in the only district court that could grant it.

[00:06:31] Speaker 01:
counsel the Guidelines aren't binding the district court didn't have to impose this enhancement and could have imposed enhancement and very downward It wasn't district court the one who observed this defendant saw Had greater understanding the content of the materials and we do perhaps and saw them in person and made a decision that this was serious the district the district court certainly was there for the trial and

[00:06:58] Speaker 04:
Mr.. Mr.. Uginoff didn't testify at trial he did address the court at sentencing I think the court's reasoning speaks for itself, and I I just I believe the court I believe the court essentially believed that that if you apply for a warrant that you must you must intend to conduct a search and I Respectfully, I think the court failed to agree failed to just to

[00:07:23] Speaker 04:
adequately consider a lot of facts here that simply rebut that.

[00:07:27] Speaker 03:
Are there any cases you can cite?

[00:07:30] Speaker 03:
I was trying to remember, go back through, that where a defendant has applied for a warrant and the court has said more is required to apply this enhancement.

[00:07:43] Speaker 04:
No, I looked at this particular guideline has very little case law.

[00:07:49] Speaker 04:
And I searched case law not only in this circuit, but nationwide.

[00:07:52] Speaker 04:
There's nothing on point either way.

[00:07:54] Speaker 04:
It's a pretty, it's a novel issue, if you will.

[00:07:59] Speaker 03:
All right, we'll give you time for rebuttal.

[00:08:01] Speaker 03:
Thank you.

[00:08:28] Speaker 00:
Good morning, Your Honors.

[00:08:30] Speaker 00:
To please the Court, James Connolly on behalf of the United States.

[00:08:33] Speaker 00:
We would ask that the Court affirm the sentence for the following three reasons.

[00:08:38] Speaker 00:
First of all, the District Court did not abuse its discretion when it found that Mr. Yaganov impersonated a federal agent for the purpose of ultimately conducting an illegal search.

[00:08:49] Speaker 00:
The District Court found that he had earned that guideline section's enhancement, that's 2J1.4B1's enhancement,

[00:08:57] Speaker 00:
for committing his crime with that ultimate purpose.

[00:09:02] Speaker 00:
The court found by a preponderance of the evidence that his detailed creation of the warrant, the manner in which he submitted it, and the work that he had gone to to deceive people was- Can I ask, in your view, what's the triggering factor that gets us across that?

[00:09:18] Speaker 03:
You talk about how much detail he put into creating it, and the district court relied on that, and that it was submitted to a court, but we all agree that the court didn't have

[00:09:27] Speaker 03:
I mean, well, do you agree that the court didn't have jurisdiction to actually enter or grant the search warrant?

[00:09:37] Speaker 00:
Well, insofar as it was a false search warrant.

[00:09:40] Speaker 03:
No, but I mean, otherwise it would have had jurisdiction.

[00:09:43] Speaker 03:
I thought the court had never had jurisdiction in the first place, even in a bed and a real warrant.

[00:09:49] Speaker 00:
Well, if Your Honor means just the various courts that he sent it to,

[00:09:55] Speaker 00:
I would imagine that they wouldn't have had jurisdiction necessarily unless there was a proper nexus to that district.

[00:10:03] Speaker 03:
Why is that seeking a search warrant if it never could have been granted in the first place?

[00:10:10] Speaker 03:
We all agree that there's nothing that could have been done to grant the search warrant.

[00:10:15] Speaker 00:
Well, that assumes a level of sophistication on Mr. Yagenoff's part.

[00:10:19] Speaker 03:
Well, no, it doesn't.

[00:10:21] Speaker 03:
I mean, I know you made that argument, but the point is he sent it to a court that never could have gotten it.

[00:10:26] Speaker 03:
So your point is he tried to get one, and just the fact that he did it the wrong way doesn't negate the warrant.

[00:10:34] Speaker 03:
And I'm just trying to flesh out where the line is here.

[00:10:37] Speaker 03:
Let's say he did the detailed search warrant, kept it on his computer, and never sent it.

[00:10:42] Speaker 03:
Could a district court have awarded the sixth level enhancement now and said,

[00:10:45] Speaker 03:
He clearly was thinking about doing this.

[00:10:49] Speaker 00:
Well, if he never sent it, then there would be a diminished amount of evidence that he intended to execute.

[00:10:54] Speaker 00:
That's my question.

[00:10:55] Speaker 03:
So you would say that if that were the facts, the district court would have abused its discretion by granting the enhancement?

[00:11:03] Speaker 02:
Not necessarily.

[00:11:04] Speaker 02:
I want to follow up on this line of questioning because I think we would all agree this is a really bizarre case.

[00:11:13] Speaker 02:
And I am interested in the government's response to Laganov's argument that the allegations in the counterfeit warrants were so bizarre that they could not have possibly been for the purpose of conducting an unlawful search.

[00:11:29] Speaker 02:
What's the government's response to that?

[00:11:32] Speaker 00:
Well, if the defendant had thought that they were so bizarre as to not be plausible, he would not have been found to have had the intent to deceive.

[00:11:40] Speaker 00:
It's not just the facts in the affidavit.

[00:11:42] Speaker 00:
It's the formatting.

[00:11:43] Speaker 00:
It's the emails that it was attached to, the NASA OIG supervising agents that he falsely alleged for it to be coming from.

[00:11:52] Speaker 03:
I agree.

[00:11:52] Speaker 03:
I mean, to me, there's no question about the impersonating a federal officer.

[00:11:57] Speaker 03:
That's clear.

[00:11:58] Speaker 03:
He impersonated a federal officer.

[00:12:00] Speaker 03:
He did that.

[00:12:01] Speaker 03:
But that's not the issue.

[00:12:03] Speaker 03:
The issue is, was that for the intent of conducting an illegal search, or yeah, an unlawful search?

[00:12:13] Speaker 03:
And I mean, abuse of discretion gets you a lot of the way here.

[00:12:19] Speaker 03:
But I'm struggling with at what point, the argument sort of seems to be, well, if you do any action, then that

[00:12:29] Speaker 03:
can qualify to get an unlawful search, but certainly there has to be something that, I mean, what if he took it to the post office and handed it in and said, I want, I want you to search this residence.

[00:12:40] Speaker 03:
Would you say, well, he tried.

[00:12:42] Speaker 00:
Yes.

[00:12:42] Speaker 00:
If he, if he handed it in the post office and said, I want to search this residence, then, then certainly that, that would be trying.

[00:12:48] Speaker 03:
It almost doesn't make sense because no rational person would think that going to the post office and handed him a search warrant is a way that you conduct an unlawful search.

[00:12:59] Speaker 03:
What if he took it to a grocery store and handed it, was checking out of Albertsons and hands it and he says, hey, give me the milk.

[00:13:08] Speaker 03:
Here's the money.

[00:13:08] Speaker 03:
And by the way, execute the search warrant.

[00:13:11] Speaker 00:
I see what your honor is saying.

[00:13:13] Speaker 00:
But if I may, the court abuses its discretion in applying this enhancement only if its findings are illogical, implausible, or without support in inferences that can be drawn from the record.

[00:13:24] Speaker 00:
He is submitting this to clerk's offices with urgency, making it appear real.

[00:13:30] Speaker 00:
Several of the clerk's office personnel said, it looked real.

[00:13:34] Speaker 00:
I was stressed by that, and so I passed it up the chain.

[00:13:38] Speaker 00:
So in certain ways, he was actually successful in getting part of the way there.

[00:13:44] Speaker 00:
He is trying to get a search warrant authorized, as the court found, explicitly on the record at sentencing.

[00:13:50] Speaker 00:
And I can provide those sites if the court would like.

[00:13:52] Speaker 00:
He said that the court said very clearly that he was that he'd found by preponderance of the evidence That he was trying to get that search warrant authorized And so from the inference that we draw from the fact that he's trying to get a federal search warrant.

[00:14:07] Speaker 00:
He's sending it to multiple courts He's doing as much as he can and and keep in mind of course.

[00:14:11] Speaker 00:
He doesn't have to be successful every time Every time he sends it in and gets a response he gets more information

[00:14:19] Speaker 03:
about how to do it better the next time.

[00:14:22] Speaker 03:
Correct.

[00:14:23] Speaker 00:
And so if we say if his goals were so lofty, they're implausible, is a defense, then that would simply encourage every defendant who does something like this to swing for the fences.

[00:14:34] Speaker 00:
But what's happening is, and the government has argued,

[00:14:39] Speaker 00:
He sent it to the Capitol Police.

[00:14:41] Speaker 00:
He didn't get a response.

[00:14:42] Speaker 00:
It triggered a response, but he didn't know that.

[00:14:45] Speaker 00:
It triggered a response because it looked, according to the Capitol Police investigator, it looked like a real warrant or like it was done by someone who knew what a real warrant looked like.

[00:14:54] Speaker 00:
And so he investigated and he contacted NASA, which, by the way, is something the defendant, while he was sending it to these judges in June and July of 2022, and he was sending it to the federal courts,

[00:15:04] Speaker 00:
He had the email addresses of those supervisory agents from NASA.

[00:15:09] Speaker 00:
He didn't send it to them.

[00:15:10] Speaker 00:
He didn't send them a letter saying, you know, we've come across this information.

[00:15:15] Speaker 00:
He was sending it to judges for the purpose of getting the search warrant authorized.

[00:15:19] Speaker 00:
And the court looked to that when it made its decision in its discretion to apply the sixth level enhancement.

[00:15:26] Speaker 00:
Because even if there were some other parallel purpose of

[00:15:31] Speaker 00:
of raising awareness that the evidence simply does not support that that was the sole reason or even that that was a major reason.

[00:15:40] Speaker 02:
Can I change the subject briefly?

[00:15:42] Speaker 02:
What should we do with his procedural challenge to his sentence?

[00:15:50] Speaker 00:
I'm sorry.

[00:15:52] Speaker 00:
Could the court elaborate, please?

[00:15:54] Speaker 02:
Well, basically, he approaches in a variety of ways

[00:16:00] Speaker 02:
but he also makes a procedural challenge in effect to the sentence.

[00:16:04] Speaker 02:
And I'm asking what the government's response is to that approach.

[00:16:10] Speaker 03:
I think, I don't want to speak over Judge Smith, but I think he's referencing the 3553A factors.

[00:16:19] Speaker 03:
Did the district court appropriately walk through those in enhancing the sentence?

[00:16:24] Speaker 02:
No, that's part of it, certainly.

[00:16:27] Speaker 00:
Yes, it certainly did.

[00:16:29] Speaker 00:
And again, I can certainly point to sites in the record where the court said that although it had reviewed the guidelines and it had calculated the guidelines, that was, as in all sentencing, that was just the beginning.

[00:16:44] Speaker 00:
The court said at least twice in the sentencing hearing that, in fact, the guidelines weren't ultimately what was driving this case.

[00:16:52] Speaker 00:
And the Ninth Circuit has found before that

[00:16:55] Speaker 00:
If a judge is going to say, I'm not going to go with the guidelines, he can't simply just say that.

[00:17:00] Speaker 00:
And indeed, Judge Calabretta here did not.

[00:17:02] Speaker 00:
He explained the reasons why he was deviating from the guidelines, which included the fact that the defendant did not seem to have learned from his arrest and prosecution.

[00:17:13] Speaker 00:
He was continuing to impersonate a federal agent from jail.

[00:17:17] Speaker 00:
He was also making outlandish accusations against the prosecutors in this case.

[00:17:21] Speaker 00:
And those were, of course, set against this backdrop where he has this long history, which the court acknowledged at sentencing, of harassing law enforcement.

[00:17:31] Speaker 00:
And so the 3553A factors were certainly taken into consideration, the antagonistic behavior, but also the danger of recidivism.

[00:17:40] Speaker 00:
The court made clear that Mr. Yaganov did not seem to be able to get out of his own way and was going to continue with this.

[00:17:48] Speaker 00:
The court was deeply concerned he was going to continue with this behavior.

[00:17:51] Speaker 00:
And while the court's language may have been in fairly plain terms, the concern, taken as a whole in reading the transcript, the concern is certainly there and it is attached to some very serious behaviour when it comes to harassing law enforcement, harassing the prosecution and trying to impede the sentencing process.

[00:18:13] Speaker 03:
On obstruction of justice, there's like kind of three bases.

[00:18:20] Speaker 03:
We only need to find one of those, don't we, to say one of those is not in violation of plain error.

[00:18:28] Speaker 03:
And the reason I raise that is I'm a little suspicious about whether it's obstruction of justice to call the CIA.

[00:18:36] Speaker 03:
you know, just a phone call to the CIA.

[00:18:38] Speaker 03:
I think filing false claims against the prosecutor to get them removed strikes me as more in the obstruction of justice category.

[00:18:47] Speaker 03:
So I wonder if you could just quickly address that.

[00:18:49] Speaker 00:
Yes, there only need to be, the court only need to find one basis.

[00:18:53] Speaker 00:
But also I would point to the standard of review here which allows the court to look to the entire record that the district court had before it to see if

[00:19:03] Speaker 00:
if there was plain error in identifying that.

[00:19:06] Speaker 00:
And I think there's ample evidence.

[00:19:08] Speaker 00:
But from those three incidents, but as I said, also this long history of harassing the prosecutors, aside from the accusations that we saw from the defendant after conviction.

[00:19:23] Speaker 00:
OK, thank you.

[00:19:26] Speaker 03:
We'll give time for rebuttal now.

[00:19:39] Speaker 04:
regarding how he made the warrant look real.

[00:19:43] Speaker 04:
The email chains, the formatting, it looked like a real warrant.

[00:19:46] Speaker 04:
If it hadn't looked like a real warrant, no one would have thought he was a federal agent.

[00:19:50] Speaker 04:
If the front of the warrant, if the formatting of the warrant matched the content of the warrant, then his poi wouldn't have worked.

[00:19:59] Speaker 04:
And it's the same ploy in count one and we know from count one there's no evidence there that he was trying to conduct a search.

[00:20:05] Speaker 04:
He just wanted to spread the information.

[00:20:06] Speaker 04:
He needed a real looking warrant for the Capitol Police to take him seriously.

[00:20:11] Speaker 04:
And the same counts two through four.

[00:20:13] Speaker 04:
He didn't need a real warrant to get

[00:20:16] Speaker 04:
to actually get the search warrant authorized.

[00:20:18] Speaker 04:
He needed that in the first place simply for people to think he was a federal agent.

[00:20:23] Speaker 03:
Can I ask about the practical implications?

[00:20:25] Speaker 03:
He's basically served his sentence at this point, right?

[00:20:29] Speaker 04:
Yes.

[00:20:31] Speaker 03:
He's released this month.

[00:20:32] Speaker 03:
So he's still detained?

[00:20:34] Speaker 04:
He's still detained right now.

[00:20:36] Speaker 04:
Yes.

[00:20:37] Speaker 03:
Okay.

[00:20:39] Speaker 03:
What does, if we were to go with this and send it back, I guess he would just have a lower sentence.

[00:20:46] Speaker 03:
It wouldn't affect any time in prison because he's already served it.

[00:20:50] Speaker 03:
Would that have an impact in the future?

[00:20:51] Speaker 04:
Yes.

[00:20:52] Speaker 04:
He was sentenced to 12 months of supervised release.

[00:20:56] Speaker 04:
So if the sentence, if it went back and the judge, the district court decided to impose a lower sentence, it would reduce his term of supervised release commensurally.

[00:21:09] Speaker 03:
Although, I'm not so sure this guy shouldn't have some supervised release.

[00:21:12] Speaker 03:
What's that?

[00:21:13] Speaker 03:
I'm not so sure he shouldn't have some supervised release.

[00:21:16] Speaker 03:
I mean, he needs a little bit of guidance, I think.

[00:21:19] Speaker 04:
No comment.

[00:21:19] Speaker 03:
Yeah.

[00:21:20] Speaker 04:
Except it is, supervised release is part of the sentence.

[00:21:23] Speaker 04:
It is punishment, whether he needs it or, yeah.

[00:21:28] Speaker 04:
In fact, briefly with the Capitol Police, one important, one fact I think is that he went to the Capitol Police first.

[00:21:36] Speaker 04:
And if he was planning to search the Pentagon,

[00:21:39] Speaker 04:
I don't think he wants to give it.

[00:21:41] Speaker 04:
I don't think he would give a heads up to federal law enforcement.

[00:21:44] Speaker 03:
I get your argument, which is this is outlandish.

[00:21:46] Speaker 03:
I think to some degree you're right.

[00:21:49] Speaker 03:
The more difficult question is, does it matter?

[00:21:52] Speaker 03:
I see.

[00:21:53] Speaker 03:
And I think we're going to have to grapple with that.

[00:21:55] Speaker 04:
Yeah.

[00:21:56] Speaker 04:
If I could very briefly address the point about applying for a warrant equals having the purpose to search.

[00:22:06] Speaker 04:
I think while that does have logical appeal,

[00:22:09] Speaker 04:
This one thing particular about this case is we have very clear evidence of another purpose and we see that from count one the purpose to spread information We know he had that purpose and given that he had that purpose That that fully explains is that fully explains his conduct across all four counts that doesn't mean he didn't also have the purpose to search something but if you had a case where someone

[00:22:37] Speaker 04:
Submitted a warrant application, and there's no evidence that they had any other purpose I think one could infer well They must have wanted to do a search then but here we the records pretty strong that he we know we had a purpose that wasn't to to Search anything and it's just a question of did he also have the additional purpose of conducting a search Okay, thank you.

[00:22:57] Speaker 03:
Thank you to both parties for your arguments in the case the case is now submitted