[00:00:00] Speaker 00: Case number 23-3080, United States of America versus Eggball Serafinia, also known as Eddie Serafinia, at balance. [00:00:09] Speaker 00: Ms. [00:00:09] Speaker 00: Fischel for the at balance, Ms. [00:00:11] Speaker 00: Rolston for the at belief. [00:00:14] Speaker 02: Ms. [00:00:14] Speaker 02: Fischel. [00:00:20] Speaker 02: Good morning. [00:00:20] Speaker 01: Good morning. [00:00:21] Speaker 01: Thank you, Your Honor. [00:00:21] Speaker 01: May it please the court? [00:00:23] Speaker 01: Section 1519 requires intent to obstruct an investigation or the proper administration of a matter. [00:00:32] Speaker 01: There are two potential investigations or matters in this case. [00:00:36] Speaker 01: One was never charged by the grand jury and the other falls outside the statute's reach. [00:00:43] Speaker 01: I would like to focus this morning on those two defects and why they require Mr. Safarinia be granted acquittal or at the very least a new trial on his 1519 counts. [00:00:56] Speaker 01: Starting with the never charged investigation. [00:00:58] Speaker 01: That is the investigation that SIGI and the FBI conducted into contract steering, which was not alleged in the indictment because it was never [00:01:09] Speaker 01: offered to the grand jury as a basis for the charges. [00:01:12] Speaker 01: It was never charged by the grand jury. [00:01:15] Speaker 01: But within days of trial, the government declared it an important basis for the counts, for the 1519 charges. [00:01:23] Speaker 01: That constructively amended the indictment, because the indictment at page 543 of the joint appendix says that what the only investigation or matter at issue in this case that was charged [00:01:37] Speaker 01: was the obstruction of HUD and OGE's review of Forms 278. [00:01:42] Speaker 05: Council, can you direct me to any language in the jury instructions that permitted the jury to convict your client based on this other investigation? [00:01:55] Speaker 01: The jury instructions, it authorized the jury to make the factual determination about what fell within the jurisdiction of Hutter OGE. [00:02:06] Speaker 01: It described the jurisdictional element and said any authorized function of an agency. [00:02:13] Speaker 01: And then it named Hutter OGE. [00:02:16] Speaker 01: The government's argument in closing specifically invited the jury to make that finding which we contend should have been a legal finding and we objected to authorizing the jury to make that determination at. [00:02:32] Speaker 01: But the district court permitted the government to make the factual argument that somehow. [00:02:38] Speaker 01: HUD and OGE's jurisdiction extended to the FBI and SIGI investigation, and the jury could have believed that argument. [00:02:45] Speaker 01: Nothing told them that they were not permitted to follow the government's argument when it made that argument. [00:02:51] Speaker 01: And that is exactly the fact that they were permitted to make that inference. [00:02:57] Speaker 01: to believe the jury's argument that the Sigi FBI investigation fell within the scope of Hutter OGE is why this was a constructive amendment. [00:03:06] Speaker 01: And we know it was because the government conceded repeatedly pre-trial that the grand jury's charge was limited to review of the forms. [00:03:17] Speaker 01: Nothing in the jury instructions limited the jury to finding review of the forms was the subject of the obstruction here. [00:03:25] Speaker 01: For example, the government conceded at page 222 to 223 of the Joint Appendix, they said, to be clear, the indictment alleges, and then they identified the subject or matter of the investigation or matter as, quote, review of the forms 278, or, quote, receipt and review by HUD and OGE. [00:03:47] Speaker 01: At page 86 of the Joint Appendix, [00:03:49] Speaker 01: They also specified that the indictment was adequately alleged because it named agencies tasked with, quote, reviewing that form. [00:03:57] Speaker 01: At page 2117 of the Joint Appendix, they conceded that the grand jury had charged obstruction of HUD and OGE and no other agency. [00:04:07] Speaker 01: But they argued something different to the court and to the jury. [00:04:10] Speaker 01: And the jury could have convicted on that basis. [00:04:12] Speaker 01: And nothing in the jury instructions, Your Honor, prevented them from doing that. [00:04:17] Speaker 01: The district court accepted those concessions over and over as well. [00:04:21] Speaker 01: The district court agreed that the indictment was clear because it named quote agencies that reviewed those forms. [00:04:27] Speaker 01: The district court found quote review of his OGE forms was the adequately alleged matter or investigation and the district court denied the grand jury discovery based on the government's representations. [00:04:39] Speaker 01: There was more in a letter in motion and lemonade papers in pretrial hearings throughout the pretrial process up until days before trial. [00:04:48] Speaker 01: The government consistently and repeatedly said this is a little trouble. [00:04:53] Speaker 05: With. [00:04:57] Speaker 05: Understanding your argument in the sense that. [00:05:03] Speaker 05: HUD and. [00:05:06] Speaker 05: I mean, the FBI, it doesn't get to the FBI or any later stage of the investigation unless the other agencies review the documents first and then deem them worthy of referring them further. [00:05:27] Speaker 05: So, I mean, the jury, in order for your [00:05:32] Speaker 05: theory to be viable, we have to ignore the fact that there is a preparatory review that necessarily took place. [00:05:46] Speaker 01: No, Your Honor. [00:05:47] Speaker 01: And the reason is because the preparatory review was entirely separate from the CIGI FBI investigation. [00:05:55] Speaker 01: You're correct that the government argues certainly there could have been something that are rise out of these forms nothing arise out of these forms. [00:06:04] Speaker 01: And they can see that the city FBI investigation germinated from outside allegations of age 13 of their brief and. [00:06:13] Speaker 01: That is critical because nothing in the indictment said anything about that exterior investigation. [00:06:19] Speaker 01: All the government would have needed to do in this case is charge the grand jury with the SIGI FBI investigation into contract steering as the basis for the obstruction counts. [00:06:29] Speaker 01: They knew about that investigation. [00:06:31] Speaker 01: But they didn't charge it, as they repeatedly conceded. [00:06:34] Speaker 01: They didn't charge it, and they didn't raise that with the district court when we challenged the sufficiency of the allegations. [00:06:40] Speaker 01: And in the lead up to trial, they argued background and context as the reason for entering this evidence into trial. [00:06:49] Speaker 01: It was only after the district court excluded the evidence as background and context because it would be unfairly prejudicial that the government said this was a basis for the charges. [00:06:59] Speaker 01: That was a classic constructive amendment. [00:07:02] Speaker 01: And here it results in acquittal because Section 1519 does not criminalize the sole surviving basis for the charges, which is the routine review. [00:07:11] Speaker 01: Maranello is directly on point there as to the definition of proper administration of a matter, and it is not an investigation as the government practically concedes. [00:07:22] Speaker 01: in their brief. [00:07:23] Speaker 01: And I see I've entered my rebuttal time, so just one final note. [00:07:26] Speaker 01: The government argued for the first time on appeal that we forfeited our jury instructions argument. [00:07:32] Speaker 01: I would just direct the court's attention to page 2532, that's 2532 of the joint appendix, where the district court found there was an objection and a request for a new trial on the jury instructions issue before it addressed our argument. [00:07:47] Speaker 01: I will reserve the remainder of my time if there are no further questions. [00:07:49] Speaker 01: Thank you. [00:07:51] Speaker 02: Mr. Raulston. [00:08:03] Speaker 03: Good morning, your honors. [00:08:04] Speaker 03: May it please the court? [00:08:05] Speaker 03: I'd like to begin with the argument that the government changed its theory midstream. [00:08:10] Speaker 03: This is simply not true. [00:08:12] Speaker 03: The government alleged and continued to argue for and prove to the jury that this was one single investigation [00:08:19] Speaker 03: within the jurisdiction of HUD and OGE. [00:08:22] Speaker 03: I point the court to the indictment language at 543, which does not, contrary to my friend on the other side's argument, say the word review at all. [00:08:32] Speaker 03: It repeats the statutory language, including in contemplation and relation to an investigation and the proper administration of a matter within the jurisdiction of a federal agency. [00:08:43] Speaker 03: The identified agencies are HUD and OGE. [00:08:46] Speaker 03: The district court's jury instructions [00:08:49] Speaker 03: as the court itself found, were virtually identical. [00:08:54] Speaker 04: Yeah, but the question is whether or not you presented significant evidence regarding the CGI and FBI investigation, which I think you did. [00:09:02] Speaker 03: So I think that would go to whether there's a variance, not an amendment. [00:09:05] Speaker 04: All right. [00:09:06] Speaker 04: I understand the difference, I think, between variance and amendment. [00:09:10] Speaker 04: But you still have a problem with the variance. [00:09:12] Speaker 04: And it sure looks like at least a variance. [00:09:15] Speaker 04: There's extensive evidence. [00:09:17] Speaker 04: on the CIG. [00:09:19] Speaker 04: And they tried to get the district court to cut them a break by raising an objection. [00:09:26] Speaker 04: And the district court allowed it to go ahead and proceed during the trial. [00:09:31] Speaker 04: There's extensive evidence. [00:09:33] Speaker 04: It's not in the indictment. [00:09:36] Speaker 04: And I agree, there's consistency between the indictment and jury instructions. [00:09:41] Speaker 04: but it's inconsistent with the evidence, extensive evidence, that you put on a CIGE and FBI investigation. [00:09:48] Speaker 04: The CIGE and FBI investigation are not what the indictment is about, and yet there's extensive evidence on it. [00:09:55] Speaker 04: My understanding is that's a variance. [00:09:58] Speaker 03: I disagree, Your Honor, for three reasons. [00:10:00] Speaker 03: The first is that the indictment alleges, it's a speaking indictment, and it alleges in the first 11 pages, which are reincorporated into the accounts five through seven charge, that the conflict of interest, the investigation here to the extent we're talking about investigation, is into the conflict of interest. [00:10:18] Speaker 03: Second, whether that investigation into the conflict of interest was within the jurisdiction of HUD and OGE is a question essentially of agency. [00:10:28] Speaker 03: whether the FBI agent was acting as the agent of HUD or OGE. [00:10:34] Speaker 03: This is as the district court found twice at pages 28 and again at 2523. [00:10:39] Speaker 04: I'm impressed with what you're arguing now. [00:10:41] Speaker 04: Are you suggesting the indictment included the CIGE and FBI investigation? [00:10:46] Speaker 04: Because you conceded post-trial that that was not the case. [00:10:50] Speaker 04: You conceded it. [00:10:51] Speaker 04: I'm looking at your quoted words here. [00:10:53] Speaker 04: They were not charged or instructed that the investigation on that or obstructed was a CIGE or FBI investigation. [00:11:01] Speaker 04: That's your concession. [00:11:02] Speaker 03: I agree, your honor, but that's because there is no separate investigation. [00:11:06] Speaker 03: There is a single investigation into the conflict of interest. [00:11:10] Speaker 04: There's two very distinct things going on here. [00:11:13] Speaker 04: One, that maybe they're all chargeable, but the only thing that was charged did not include [00:11:19] Speaker 04: the CIG FBI investigate absolutely did not. [00:11:21] Speaker 04: In fact, you said that, and yet your testimony went extensively to that. [00:11:27] Speaker 04: That's prejudicial. [00:11:30] Speaker 03: I disagree for additional reasons. [00:11:32] Speaker 03: So first, I want to go back to the extensive evidence. [00:11:35] Speaker 03: SIGI, or the FBI, is mentioned only on 12 of the 1,000 pages. [00:11:39] Speaker 03: Most of that is about the fact that a referral was made. [00:11:43] Speaker 03: The FBI agent gives one paragraph giving his foundation for how he [00:11:48] Speaker 03: then is in the position to testify about the records that he goes on about. [00:11:55] Speaker 03: It's not extensive records. [00:12:00] Speaker 03: Moreover, I think this factual question, right, the district court before trial at page 28 calls it a question of fact for the jury. [00:12:09] Speaker 03: The jury instructions in no way permitted the jury to convict on the basis of... It doesn't matter if you're looking at a variant. [00:12:19] Speaker 03: I disagree to some extent because- You can't disagree because you know that's not the law. [00:12:23] Speaker 04: And when you're talking about a variance as opposed to an amendment, if you have extensive evidence that's inconsistent with the indictment and the instruction, that's a variance. [00:12:34] Speaker 04: So I want to go back to- Because the prejudice is they weren't able to prepare and put in testimony to deal with something they didn't expect to see and that the district court was not allowing them to get it. [00:12:47] Speaker 03: So a variance deals with the concept of notice. [00:12:49] Speaker 03: They had completely fair notice that all investigations into the conflict of interest were part of the charge. [00:12:56] Speaker 03: You look at the speaking indictment, the reverse progress. [00:12:59] Speaker 04: No, wait. [00:12:59] Speaker 04: Let me come out. [00:13:00] Speaker 04: You're mixing me up. [00:13:01] Speaker 04: Now are you saying that the CIG, ENF, the investigation were included? [00:13:06] Speaker 04: Because you conceded they were not. [00:13:09] Speaker 03: As we argued throughout the case, and I point you to the district, [00:13:16] Speaker 03: Point at pages 807, I'm sorry, at 820 and 860 at the pre-trial conference where the prosecutor repeatedly says, it's not a different investigation. [00:13:30] Speaker 03: Siggy and FBI stand in the shoes of HUD. [00:13:34] Speaker 03: The district court finds. [00:13:36] Speaker 04: Post trial, I'm conceded. [00:13:39] Speaker 04: The jury was not charged or instructed that the investigation of a matter obstructed was a CIG or FBI investigation. [00:13:45] Speaker 03: Yes, we did not charge, we did not prove, we did not ask the jury to convict on any basis that the investigation was within the jurisdiction of CIGI and FBI. [00:13:56] Speaker 03: The investigation is within the jurisdiction of the charged agencies as we made clear throughout. [00:14:02] Speaker 03: But I want to go back to this notice point. [00:14:05] Speaker 03: I think you notice at the end of the day comes down to the question of what would have been different if they say we changed, if that's true, what would have been different? [00:14:14] Speaker 03: And nothing. [00:14:14] Speaker 03: And I think that's clear because it's all one case. [00:14:18] Speaker 03: If you look at count one, count one urges concealment based on an intent to deceive that is a scheme or a trick. [00:14:28] Speaker 03: All of that has to go to this idea that there's a conflict of interest, a potential conflict, [00:14:34] Speaker 03: that's covered up by the lie on the form. [00:14:37] Speaker 03: That's the case, right? [00:14:39] Speaker 03: That's the case throughout all of the charges. [00:14:41] Speaker 03: Those are the facts. [00:14:42] Speaker 03: He had noticed that that was the charge and that that charge that he defended against in count one, in all the counts, he had a single defense. [00:14:51] Speaker 03: His defense was it was an honest mistake. [00:14:53] Speaker 03: There's no honest mistake. [00:14:55] Speaker 03: The jury rejects that when they convict him on all seven counts. [00:14:59] Speaker 03: There's no other defense. [00:15:00] Speaker 03: There's nothing else he could have said. [00:15:02] Speaker 03: And this was within the jurisdiction of HUD and OGE. [00:15:05] Speaker 03: That's the only thing the government asked the jury to convict about. [00:15:09] Speaker 04: What I would have done if I were counsel on their side is their subpoena and discovery would have been entirely different if they knew [00:15:17] Speaker 04: that the CIGE and FBI investigation was in play. [00:15:23] Speaker 04: And I certainly would have had a very different discovery if I had known, oh, that's in play. [00:15:29] Speaker 04: Oh, we're going to be here a long time in discovery because we're going to go into all of that had I known that. [00:15:34] Speaker 04: And you conceded post trial that wasn't, and yet you put in extensive evidence that it was. [00:15:39] Speaker 03: So it's not extensive, 12 pages. [00:15:42] Speaker 03: It's not even 12 full pages. [00:15:44] Speaker 03: It's parts of 12 pages. [00:15:45] Speaker 03: And I refer you to [00:15:47] Speaker 03: the citations in our brief about that. [00:15:50] Speaker 03: It is, however, there was no more discovery. [00:15:53] Speaker 03: The government gave all the discovery. [00:15:55] Speaker 03: This includes 3,600 pages of files from ODNI, which is the agency to which Siggy enlisted to stand in HUD shoes because of the recusal. [00:16:05] Speaker 03: There was nothing else to give them. [00:16:08] Speaker 03: We highlighted the hot documents for them. [00:16:10] Speaker 03: The district court found that that was sufficient at 488. [00:16:13] Speaker 03: We were consistent, there were reverse proffers, they had complete notice about the conflict of interest investigation that was this. [00:16:21] Speaker 03: And I would point out that until Mr. Safarinia was terminated from HUD in 2017, HUD [00:16:29] Speaker 03: still had a strong interest in figuring out whether there was a conflict of interest and whether he lied on those forms because those helped form the basis of his termination. [00:16:40] Speaker 03: So I think there's a good reason, not only that this was the argument in the jury instruction, but that there was reason, factual reason to understand that this was [00:16:51] Speaker 03: within HUD's jurisdiction. [00:16:54] Speaker 03: Also, OGE has jurisdiction to investigate these forms. [00:16:58] Speaker 03: And I think that's clear, both in the statute. [00:17:01] Speaker 03: It's clear throughout the bill of particulars. [00:17:02] Speaker 03: I think at 222, we talk about OGE's power to investigate. [00:17:08] Speaker 03: And also, I want to talk about the contemplation. [00:17:11] Speaker 03: On this idea of 1519, we have the contemplation or relation to language. [00:17:16] Speaker 03: It doesn't have to be the actual investigation that he's [00:17:21] Speaker 03: It can be any, you know, investigation within the jurisdiction of the charged agency that he would anticipate. [00:17:27] Speaker 03: And we made it clear that we were talking about contemplated investigations throughout. [00:17:32] Speaker 03: I think 220 in the motion to dismiss response, 85 to 86 in the bill of particulars response, highlight that clearly. [00:17:39] Speaker 03: And the last thing I want to just point out both here about the variance and about 1519 is that [00:17:46] Speaker 03: A variance, according to Jordan, has to go to an essential element of the offense. [00:17:50] Speaker 03: The essential element here are two things. [00:17:54] Speaker 03: First, it's the intent to obstruct. [00:17:55] Speaker 03: And second, it's the false document. [00:17:57] Speaker 03: There's no dispute at all about the documents or that they were false. [00:18:01] Speaker 03: And the intent to obstruct is the same. [00:18:03] Speaker 03: It doesn't matter who the agency is. [00:18:05] Speaker 03: I'm not saying that we changed the agency. [00:18:08] Speaker 03: But the intent is the same. [00:18:09] Speaker 03: The intent is to cover up the conflict of interest. [00:18:12] Speaker 03: And that was the argument throughout trial about all seven counts. [00:18:16] Speaker 03: The intent is that's the scheme to conceal, is the intent to cover up this conflict of interest. [00:18:23] Speaker 03: And moreover, I think some of the SIGI evidence, at least, would have been admissible regardless. [00:18:30] Speaker 03: And that goes to his notice. [00:18:32] Speaker 03: There's discussion that he knows about this investigation. [00:18:35] Speaker 03: And by the time he files that last form in 2016, so at 1116 and 1606, the references to SIGI are about that awareness. [00:18:48] Speaker 03: So that's not, I think, in any way saying that he, varying from the indictment, right? [00:18:55] Speaker 03: The other things go to materiality. [00:18:58] Speaker 03: They would have been admissible anyway. [00:18:59] Speaker 03: They're saying that I would have made this referral. [00:19:02] Speaker 03: That's what Antigua says at 1596. [00:19:05] Speaker 03: They're talking about follow-up information at 1069. [00:19:09] Speaker 03: That's internal to HUD OIG investigation. [00:19:14] Speaker 03: Kirkland is going out and gathering evidence. [00:19:16] Speaker 03: He's interviewing witnesses. [00:19:18] Speaker 03: He's gathering documents. [00:19:19] Speaker 03: And that's inside HUD. [00:19:21] Speaker 03: And then he says he provides that information to SIGI. [00:19:24] Speaker 03: But the fact that he provided the information isn't the necessary part. [00:19:29] Speaker 03: The necessary thing there is that he's gathering the information. [00:19:33] Speaker 03: And as we point out in our brief at page 27, that is an investigation well within the jurisdiction of HUD. [00:19:41] Speaker 03: And I think under the jury instructions, that if the jury relied on the investigation prong at all as opposed to the administration prong, then I think that's the better idea of what they were relying on because his investigation. [00:19:56] Speaker 02: You're over your time if there are no questions, Judge Wilkins. [00:20:01] Speaker 05: One last question. [00:20:05] Speaker 05: What's your response to your friend on the other side's argument that based on the jury instructions, the defendant could have been convicted not because of an investigation by, I guess, [00:20:28] Speaker 05: heard an OIG, but because of an investigation by the FBI or CIA. [00:20:34] Speaker 03: I think it's not possible in any way. [00:20:39] Speaker 03: The jury instructions mention the statutory, the indictment language, they copy that verbatim, which says HUD and OGE. [00:20:50] Speaker 03: The unanimity instruction additionally is explicit that the jury has to find it's a matter [00:20:56] Speaker 03: within the jurisdiction of HUD, unanimously agree that it's within the jurisdiction of OGE or both, there's no way that the jury could have followed both of those instructions, or really either of them, and convicted on the basis of something that's within the jurisdiction of another agency. [00:21:12] Speaker 03: I'm not disputing that there was someone referred through SIGI and an FBI agent who did some of the investigating that I think could have been contemplated by the defendant. [00:21:24] Speaker 03: people were acting as agents of HUD because HUD OIG was recused because of the defendant's position. [00:21:31] Speaker 03: So the jury instructions, I don't think, in any way allowed this conviction. [00:21:37] Speaker 03: And he received completely fair notice. [00:21:39] Speaker 03: It doesn't go to an essential element. [00:21:41] Speaker 03: And just one last thing I'd like to say is that throughout, the standard of review is an issue for the court. [00:21:48] Speaker 03: The Rule 52, Rule 30 are addressed to what may be considered [00:21:53] Speaker 03: which is by the court. [00:21:54] Speaker 03: It's not something I think that the party can waive. [00:21:56] Speaker 03: But in any event, didn't waive it. [00:21:59] Speaker 03: If there are no further questions. [00:22:01] Speaker 02: Thank you. [00:22:02] Speaker 03: Thank you. [00:22:12] Speaker 01: May I please the court? [00:22:13] Speaker 01: I have three points I want to quickly touch on in rebuttal. [00:22:16] Speaker 01: The first is that there is no way to read this indictment as providing notice to Mr. Safrania [00:22:23] Speaker 01: that he could be put on trial for obstructing a conflict of interest investigation or contract steering investigation. [00:22:29] Speaker 01: That means that there are two ways to resolve this case. [00:22:32] Speaker 01: Either the government was right when it opposed the bill of particulars, motion to dismiss, when it opposed our motion for grand jury minutes, that the indictment was limited to routine review of the forms, or the indictment is fatally vague and fails to provide constitutionally adequate notice of the charges to Mr. Safrania. [00:22:51] Speaker 01: If the former acquittal is required, if the latter, the district court denial of our motion to dismiss should be reversed. [00:22:58] Speaker 01: On the jury instruction secure point, the jury instructions here were not consistent with what the grand jury charged, which is the essential question here. [00:23:07] Speaker 01: The government concedes at page 35 to 36 of their brief that the jury could have convicted based on evidence of the SIGI FBI investigation. [00:23:16] Speaker 01: That is not what the grand jury charged, as the government also conceded below. [00:23:20] Speaker 01: And that question should not of whose jurisdiction the SIGI FBI investigation fell within. [00:23:28] Speaker 01: That was a legal question that never should have been sent to the jury. [00:23:32] Speaker 01: What happened in the jury instructions is the court permitted the jury to decide. [00:23:38] Speaker 01: whether or not the SIGI FBI investigation fell within the jurisdiction of HUD or OGE. [00:23:43] Speaker 01: That should never have happened, but it did. [00:23:45] Speaker 05: And I would directly... I don't understand your argument. [00:23:48] Speaker 05: You're saying that it's a legal question that shouldn't have been sent to the jury. [00:23:52] Speaker 05: Well, did the jury answer it incorrectly? [00:23:56] Speaker 05: I mean, legally, were they acting as agents for OGE and HUD? [00:24:04] Speaker 05: And if so, then what's the error? [00:24:06] Speaker 01: Legally, they were not acting as agents. [00:24:09] Speaker 01: Your Honor, this was a completely separate investigation by completely separate agencies that was referred out of a bid protest, which related to contract steering and not the forms. [00:24:19] Speaker 01: And it would make no sense for a referral out of an agency that is specifically to avoid a conflict of interest to result in something still being within the original agency's jurisdiction. [00:24:36] Speaker 01: I would just add, Your Honors, that there was certainly prejudice here. [00:24:41] Speaker 01: There was no notice. [00:24:42] Speaker 01: And we would have proceeded on a different strategy, reviewed discovery differently, if we had known that the government would assert this as a basis for their charges. [00:24:51] Speaker 01: There are no further questions. [00:24:52] Speaker 01: My time is up. [00:24:53] Speaker 02: Thank you. [00:24:54] Speaker 01: Thank you, Your Honors.