[00:00:06] Speaker 01:
We have three cases scheduled for argument this morning and one case on the briefs.

[00:00:16] Speaker 01:
We have four cases before us for argument and one on the briefs.

[00:00:20] Speaker 01:
So let's start with Green Valley Company versus Army 18-2285.

[00:00:30] Speaker 01:
Counselor Cicagli?

[00:00:32] Speaker 02:
Yes, good morning.

[00:00:32] Speaker 01:
Good morning.

[00:00:33] Speaker 01:
And you have reserved five minutes of your time for rebuttal, correct?

[00:00:36] Speaker 02:
That's correct, thank you.

[00:00:37] Speaker 01:
Okay.

[00:00:37] Speaker 01:
We're ready when you are.

[00:00:40] Speaker 02:
Thank you.

[00:00:40] Speaker 02:
May it please the court?

[00:00:42] Speaker 02:
My name is Salma Cicagli.

[00:00:43] Speaker 02:
I represent the petitioner in this case, Green Valley Company.

[00:00:47] Speaker 02:
We are asking the court to respectfully reverse the board's decision in summary judgment in this case because the equitable tolling of the statute of limitations is the only just position that this case can come up with.

[00:01:01] Speaker 02:
there would be unjust enrichment should the result of the judgment not be reversed.

[00:01:07] Speaker 02:
Your Honor, this case is a case of extraordinary facts beyond the control of the appellant and possibly beyond the control of the army.

[00:01:17] Speaker 02:
So, unreasonable diligence was exercised in pursuit in the rights of the appellant.

[00:01:25] Speaker 02:
To my first point, the Board dismissed the case without

[00:01:30] Speaker 02:
fact-finding summary judgment and on page four five and nine of the response to appeal the army made a material fact and error that the VPA which is a subject for this case was not included in the civil action the civil action was filed Do I remember right that that although the government

[00:01:53] Speaker 05:
made that error in its brief and then submitted us a letter that the board did not rely on the absence from the Texas case of these invoices or this contract.

[00:02:09] Speaker 02:
Well, Your Honor, I don't think that it's very clear from the record of the board's decision that they did not take into consideration BPA 0063.

[00:02:20] Speaker 02:
the Palm Springs versus the Army, which was also a board case with BPA 001.

[00:02:29] Speaker 02:
Judge Ting dismissed that case because of the civil action and stayed the proceedings because he said it would be a conflict and parallel discovery for the civil action.

[00:02:39] Speaker 02:
So, yeah, when you read it carefully, the board's decision on this case,

[00:02:46] Speaker 02:
It's not clear that they didn't take into consideration because they say that it's irrelevant that what I perceived or what the appellant perceived to be a risk for filing during the civil action, which carried very heavy penalty.

[00:03:05] Speaker 02:
It was the Statue of Fraud, False Claim Act, Special Pleasance Fraud Statue, Contract Dispute Act.

[00:03:12] Speaker 02:
forward-and-forced fraud enforcement.

[00:03:14] Speaker 03:
I just want to make sure I understand what you're saying is that there was a fear that there would be additional charges or counterclaims, I guess, over and above the claims that were being made in the Texas litigation.

[00:03:29] Speaker 02:
Correct.

[00:03:29] Speaker 02:
It wasn't just a fear.

[00:03:31] Speaker 02:
It was actually a reliance upon the Department of Justice lawyer that said to... Just to be clear, what record evidence is there of that?

[00:03:40] Speaker 02:
The only record evidence is an email after I traveled to DC and met with the Department of Justice lawyers and they gave me the warning, do not file during this civil action.

[00:03:51] Speaker 02:
We want you to cooperate.

[00:03:53] Speaker 02:
Your client must cooperate in this case to clear the situation.

[00:03:57] Speaker 02:
Where and what page is that in the appendix?

[00:04:00] Speaker 02:
It was an email from John Kohler.

[00:04:03] Speaker 02:
Do you have an appendix page?

[00:04:05] Speaker 02:
No, I didn't submit it.

[00:04:11] Speaker 05:
So if you had, say, filed a certified claim in 2010, so after the 2009 initiation of the Texas, of the Federal District Court case in Texas,

[00:04:25] Speaker 05:
What is your understanding of what the contracting officer would have, should have, must have done with such a certified claim on the assumption, which I think is now undisputed, that this contract and indeed maybe even some of these invoices were part of the Texas case?

[00:04:48] Speaker 02:
The assumption is that they would have dismissed the case and then the Department of Justice would have filed

[00:04:54] Speaker 02:
additional charges against us for bribery, saying that the contract BPA-0063 would have been tainted by additional bribery by Cockerham.

[00:05:06] Speaker 02:
And then it would have gone to appeal possibly to the board, and then the board would state the claim for further proceedings with the Civil Action, which is what they did with the BPA-001.

[00:05:19] Speaker 05:
But the contracting officer could have

[00:05:23] Speaker 05:
And maybe I think I'm understanding you to say would have, in fact, ruled on the claim under my hypothetical if received in a certified form in 2010.

[00:05:35] Speaker 02:
It's possible or not, because the Department of Justice pretty much put a wall between us and the Department of Defense so that they could adjudicate this case against Cockerham and Momon

[00:05:49] Speaker 02:
and Saud al-Tawash, which is the target of the investigation and the target of the civil action because Saud al-Tawash was specifically named by Cockerham in his handwritten notes that said,

[00:06:00] Speaker 02:
Tell Saud, don't cooperate, don't confess, get a lawyer, and we'll do trading later.

[00:06:07] Speaker 02:
So the Department of Justice was fearful of allowing me or anybody to go to the Department of Defense and submit a claim that would hinder the investigation in the civil action against Cockerham and Momon in Sur al-Tawash.

[00:06:25] Speaker 02:
So it's not 100% sure.

[00:06:28] Speaker 02:
I'm not sure, to be honest with you, what the contacting officer would have done or not done.

[00:06:34] Speaker 02:
I think that they would have just sent it straight to the Department of Justice and said, she's filed a claim.

[00:06:43] Speaker 01:
The problem is we don't know what would have happened.

[00:06:45] Speaker 02:
That's correct.

[00:06:47] Speaker 01:
That's your problem.

[00:06:48] Speaker 01:
That's the problem that you have.

[00:06:53] Speaker 02:
But it was a very difficult time.

[00:06:57] Speaker 02:
I mean the diligence that we exercised in correcting the record.

[00:07:03] Speaker 02:
The Army was under the impression that Green Valley was owned by Saud al-Tawash because he had declared that.

[00:07:09] Speaker 02:
He took a contract in their name without their knowledge.

[00:07:12] Speaker 02:
The first time that we found out BPA-001 was in the name of Green Valley is when Attorney Geraldine Chanel called Green Valley and said, well, there's a claim for this BPA in your name.

[00:07:24] Speaker 02:
And they said, we don't know about this.

[00:07:27] Speaker 03:
So you're arguing for equitable tolling, saying that you have the extraordinary circumstance that stood in your way of going to the contracting officer, was the uncertainty of knowing whether the government would take action

[00:07:42] Speaker 03:
against you of some sort or what the contracting officer would do with that claim.

[00:07:47] Speaker 03:
Do I understand that claim?

[00:07:49] Speaker 02:
Well, I really believed and the appellant believed at the point of time that the DOJ would have taken severe action against that claim in order to garner bribery, additional bribery charges and false claims.

[00:08:05] Speaker 03:
But you already were facing fraud claims, right?

[00:08:08] Speaker 02:
Yeah, but it would have caused more, it would have compounded it more, and then we would have been compromising the investigation and the civil action with the parallel discovery for the facts, and we were cooperating with the Department of Justice.

[00:08:26] Speaker 03:
Can I interrupt for a minute?

[00:08:27] Speaker 03:
I thought that the Texas action already involved the same contracted issue already, so what was the additional

[00:08:35] Speaker 03:
complicating factor or discovery that you're talking about?

[00:08:38] Speaker 02:
Well, that was what the Department of Justice said, that we would assess more penalties against you should you file during this civil action.

[00:08:48] Speaker 02:
So we relied upon, the appellant relied upon the Department of Justice, relied upon the case of Judge Ting's decision in the 001,

[00:08:59] Speaker 02:
and made the decision to diligently pursue clearing their name and clearing the BPA-0063 from fraud because it wasn't something that Cockerham signed.

[00:09:10] Speaker 02:
It was signed by James Beard.

[00:09:12] Speaker 02:
And it was put into the civil action in order to coerce the Green Valley to cooperate and to help the Department of Justice clear the record, which they did.

[00:09:25] Speaker 02:
They sent them bank statements.

[00:09:28] Speaker 02:
They sent them anything that the Department of Justice requested was submitted.

[00:09:33] Speaker 02:
And then there was a cooperation where the pallet flew to Dubai and had the cooperation and deposition.

[00:09:43] Speaker 03:
What is the basis?

[00:09:44] Speaker 03:
The other requirement under equitable tolling is that you diligently pursue your rights.

[00:09:50] Speaker 02:
Yeah, diligently pursued, but not maximum feasible diligence.

[00:09:54] Speaker 02:
I mean, it was diligently pursuing to clear the misinformation and the false information that the Army, Department of Defense, and the Department of Justice had about this BPA-063 and Green Valley.

[00:10:09] Speaker 02:
So it was reasonable diligence to do what the appellant did in that time, which is to cooperate, to provide information, to write letters, to participate in BPA 001, oppose that by giving the... Before the Green Valley got involved with BPA 001 case,

[00:10:28] Speaker 02:
The court was going to award money to a claim that was submitted and the whole contract, BP 001, was based upon fraud, a conspiracy between Cockerham and Sir Hidalto Wash.

[00:10:45] Speaker 01:
The Army debarred Green Valley from contracting in May 2007, correct?

[00:10:51] Speaker 01:
Correct.

[00:10:52] Speaker 01:
What does debarment mean?

[00:10:54] Speaker 01:
Does that mean you cannot submit any type of communication or have any communication?

[00:11:01] Speaker 01:
That's correct.

[00:11:04] Speaker 02:
The debarment meant that they could not do any business with the United States, could not do any, and that was what Captain Troy said to them.

[00:11:10] Speaker 02:
You have been debarred.

[00:11:11] Speaker 02:
We're not going to pay these invoices.

[00:11:13] Speaker 02:
There was nine months where the Army held onto these invoices and accepted the DD-250s and did not pay them.

[00:11:20] Speaker 02:
And during that nine months, they awarded

[00:11:23] Speaker 02:
A modification would be increasing it to $100 million.

[00:11:27] Speaker 02:
But yet, right after they did the modification for $100 million, they put them on a debarment.

[00:11:32] Speaker 02:
And the debarment was because of the BPA 001.

[00:11:35] Speaker 01:
Isn't a debarment prospective, applying from the date of the debarment as opposed to retrospective, accounting for matters that have already taken place?

[00:11:45] Speaker 02:
Well, yes, but that's not the advice that was given to Green Valley from Captain Choi.

[00:11:50] Speaker 01:
So they relied on... That's how debarment works, right?

[00:11:53] Speaker 01:
Right.

[00:11:55] Speaker 02:
But it also stopped the payment of the invoices that were in question.

[00:12:01] Speaker 02:
They had to litigate it.

[00:12:02] Speaker 02:
But it wasn't BPA-0063 that was the debarment.

[00:12:06] Speaker 02:
It was BPA-001, which was the one that was a civil action for Cockerham getting bribes and coercion.

[00:12:14] Speaker 02:
Conspiracy, I'm sorry, with Sir Delta Wash Pump Springs.

[00:12:20] Speaker 02:
Pump Springs took that contract in the name of Green Valley without their knowledge because they did a joint venture agreement.

[00:12:26] Speaker 02:
Then they tried to get the payments to be submitted to them.

[00:12:30] Speaker 02:
So it was a very tough time, a lot of confusion.

[00:12:36] Speaker 02:
Kuwait was a very unstable situation for the contractors.

[00:12:40] Speaker 02:
They were afraid.

[00:12:42] Speaker 02:
Three of the military committed suicide.

[00:12:44] Speaker 02:
You know, it was in the market.

[00:12:47] Speaker 02:
Three military officers committed suicide because they were being investigated for fraud.

[00:12:52] Speaker 01:
Okay.

[00:12:52] Speaker 01:
You're into your rebuttal time.

[00:12:53] Speaker 01:
Do you want to save your rebuttal time?

[00:12:55] Speaker 02:
Yeah, I'll save my rebuttal time.

[00:12:57] Speaker 02:
Thank you.

[00:13:02] Speaker 00:
May I please record on behalf of the Department of Army we ask this panel to affirm the board's decision granting summary judgment in favor of the Army.

[00:13:14] Speaker 00:
It's undisputed that the statute of limitations ran from roughly December 2006 through December 2012 and no certified claim was filed in that time frame.

[00:13:25] Speaker 00:
With respect to equitable tolling, we submit that the board properly determined that there was no genuine issue of material fact with respect to that equitable tolling claim.

[00:13:34] Speaker 00:
The government moved for summary judgment.

[00:13:37] Speaker 05:
Was the board aware of what you say in your Rule 28J letter?

[00:13:43] Speaker 05:
Or did the board think, based on the records submitted to it, that the Texas litigation really had nothing to do with either this contract or these invoices under this contract?

[00:13:56] Speaker 00:
Yes, Your Honor.

[00:13:57] Speaker 00:
So in connection with that 28-J letter, I did go back and review all of the

[00:14:00] Speaker 00:
the briefing before the board to see what representations were or were not made.

[00:14:05] Speaker 00:
The only thing that was represented before the board was the existence of that district court action and Green Valley being named as a defendant in that action.

[00:14:13] Speaker 00:
There were no representations from either party either way with respect to whether and to what extent it encompassed

[00:14:21] Speaker 00:
the issues in this appeal.

[00:14:23] Speaker 05:
Can I ask you the same question I asked earlier?

[00:14:27] Speaker 05:
If a certified claim had been filed in 2010, this same certified claim that was ultimately filed in 2017, what could, should the CO have done with that claim while the Texas litigation was pending on the assumption that sooner or later it would have

[00:14:49] Speaker 05:
been revealed that the Texas litigation actually involved some of the same subject matter of the claim?

[00:14:56] Speaker 00:
Because the claim wasn't filed in 2010, I can't say for certain.

[00:15:00] Speaker 05:
But either statutorily or regulatory?

[00:15:03] Speaker 00:
Right.

[00:15:03] Speaker 00:
A contracting officer statutorily does not have authority to compromise a claim within which that contracting officer suspects fraud.

[00:15:14] Speaker 00:
So to the extent a certified claim was

[00:15:16] Speaker 00:
had been timely submitted in 2010, if we assume that hypothetically.

[00:15:21] Speaker 00:
The contracting officer either would have paid it if no fraud was suspected, or paid it in part and made a decision in the ordinary course, or would have referred it probably for a fraud investigation.

[00:15:33] Speaker 00:
But what's critical with respect to this appeal is that that claim would have been timely filed.

[00:15:39] Speaker 00:
The government would have been on notice of the claim, could have investigated the claim in that timely fashion.

[00:15:45] Speaker 00:
and Green Valley would have preserved its rights.

[00:15:48] Speaker 03:
Do you think there would have been an impact on the Texas case?

[00:15:52] Speaker 03:
I mean, I realize it's hypothetical, but I'm just trying to understand.

[00:15:55] Speaker 03:
We've got a situation where one party's saying that they were threatened not to file a claim because it could have an impact on the Texas litigation.

[00:16:04] Speaker 03:
So I'm just trying to understand that.

[00:16:06] Speaker 00:
So the district court litigation in Texas, the primary focus of that Texas complaint was another blanket purchase order.

[00:16:16] Speaker 00:
awarded to Palm Springs, another entity.

[00:16:18] Speaker 03:
Right, but this, as you 28-J letter explains, this case was also referenced.

[00:16:23] Speaker 00:
Right.

[00:16:24] Speaker 00:
So, and Green Valley was a responded defendant in that action.

[00:16:28] Speaker 00:
Blanket Purchase Order Agreement 63, which is at issue in this appeal, was named in that district court action, and the invoices at issue in this appeal were part of that action.

[00:16:37] Speaker 00:
So it was all wrapped up together.

[00:16:39] Speaker 00:
But again, there's nothing

[00:16:41] Speaker 00:
in law that would have prevented Green Valley from timely submitting a certified claim while that district court action was pending.

[00:16:49] Speaker 01:
What about the debarment?

[00:16:51] Speaker 00:
The debarment also does not preclude them from filing a certified claim.

[00:16:54] Speaker 00:
And we know that based on this record because they are still debarred.

[00:17:00] Speaker 01:
I thought the debarment was lifted.

[00:17:02] Speaker 00:
The debarment in 2008.

[00:17:04] Speaker 00:
So there were two debarments.

[00:17:06] Speaker 00:
There was the first debarment that would have expired in its ordinary course in

[00:17:13] Speaker 00:
December 1st, 2009, that debarment was then extended to December 1st, 2019.

[00:17:19] Speaker 00:
So they are still debarred and have been debarred for the last 10 years or so.

[00:17:23] Speaker 00:
That did not preclude them from filing a certified claim in February 2017.

[00:17:28] Speaker 00:
It did not preclude the contracting officer from taking up that certified claim in 2017.

[00:17:33] Speaker 05:
And taking it up and saying it's out of time?

[00:17:39] Speaker 00:
Well, they looked at it on the merits.

[00:17:41] Speaker 00:
They determined it was

[00:17:43] Speaker 00:
untimely.

[00:17:44] Speaker 00:
The contracting officer was not precluded from looking at the claim by virtue of the debarment.

[00:17:48] Speaker 00:
The debarment, as this panel noted a few minutes ago, is prospective only.

[00:17:53] Speaker 00:
It doesn't prohibit an entity from filing a certified claim.

[00:17:57] Speaker 03:
I asked you a question earlier, I'm not sure you quite answered it.

[00:18:00] Speaker 03:
Sure.

[00:18:00] Speaker 03:
So my question was whether the filing of a claim would have had an impact, the filing of the claim to the contracting officer would have had an impact in the Texas case and what would that have been?

[00:18:15] Speaker 03:
if there is more.

[00:18:16] Speaker 00:
Right.

[00:18:16] Speaker 00:
Hypothetically, the email to which Ms.

[00:18:20] Speaker 00:
Sakhali references does not threaten the Green Valley with consequences.

[00:18:26] Speaker 00:
It does not tell Green Valley not to file.

[00:18:29] Speaker 00:
It says, if you file a certified claim, we reserve our rights to respond as appropriate, which is the government's right.

[00:18:36] Speaker 00:
So yes, theoretically.

[00:18:39] Speaker 00:
some other amendment to the complaint could have been sought in the district court action.

[00:18:45] Speaker 00:
But the Supreme Court Menominee Tribe has held that fear of consequences or fear of future litigation risk is not sufficient to constitute an extraordinary circumstance for satisfaction of the second element of equitable tolling.

[00:19:04] Speaker 05:
So I understand.

[00:19:05] Speaker 05:
I mean, are we in the position where

[00:19:10] Speaker 05:
If the claim had been filed say in 2010 and it came to the CO's attention that the Texas case actually did involve this subject matter and therefore

[00:19:25] Speaker 05:
by assumption anyway, but maybe even inevitably, the CEO had reason to suspect fraud because the United States alleged it in the Texas case and therefore could not, while that was going on, pay it.

[00:19:39] Speaker 05:
So it would have been futile, pointless, but nevertheless not meet the standard for equitable tolling because nothing prevented the, by assumption, feudal act.

[00:19:51] Speaker 00:
That is true.

[00:19:52] Speaker 00:
Nothing presented hypothetically the feudal act.

[00:19:56] Speaker 00:
But futility, the Supreme Court Menominee Tribe has also held is not sufficient to meet the extraordinary circumstances.

[00:20:02] Speaker 00:
A perception of futility does not meet that circumstance.

[00:20:06] Speaker 00:
But importantly, Your Honor, we have a statute of limitations and we have criteria for equitable tolling because the government has a right to know what claims it faces, right?

[00:20:18] Speaker 00:
Witnesses disappear, paper disappears.

[00:20:21] Speaker 00:
If Green Valley had a valid claim, they had an obligation to submit it in a timely fashion.

[00:20:28] Speaker 00:
They were a Kuwaiti government contractor, right?

[00:20:31] Speaker 00:
The government had a right to know what claims were pending against it in a timely fashion so that it could have investigated it.

[00:20:39] Speaker 05:
So even if it would have been futile in terms of getting

[00:20:44] Speaker 05:
payment during the period, it was not purposeless from the public interest point of view.

[00:20:50] Speaker 00:
Yes.

[00:20:51] Speaker 00:
And by way of comparison, Ms.

[00:20:53] Speaker 00:
Cicali mentioned other board actions.

[00:20:57] Speaker 00:
Palm Springs and other entities that were included in the district court action had timely filed claims or certified claims for their invoices.

[00:21:09] Speaker 00:
up to and surrounding the district court action and had appealed the denial of those invoices to the board in other board actions.

[00:21:16] Speaker 00:
And once the district court litigation was pending, the government sought to stay the board action pending the adjudication of the district court action.

[00:21:28] Speaker 00:
Conceivably, had Green Valley timely filed a certified claim, the contracting officer either would have denied it or not acted on it in a reasonable time, such that it would be a deemed denial.

[00:21:39] Speaker 00:
Green Valley could have proceeded to the board, and either the board would have adjudicated it, or the parties or the government might have sought to stay the board.

[00:21:48] Speaker 00:
Actually, we don't know.

[00:21:48] Speaker 00:
But importantly, Green Valley would have preserved its rights.

[00:21:54] Speaker 00:
There is no exception.

[00:21:57] Speaker 00:
recognized by the Supreme Court or any authority that we're aware of, that would have forgiven Green Valley's failure to have timely filed a claim based for the reasons that they've asserted in this proceeding, right?

[00:22:10] Speaker 00:
Fear of future legal consequences, Menominee Tribe has found that's not appropriate.

[00:22:17] Speaker 00:
Fear increased cost, not appropriate under Menominee Tribe.

[00:22:21] Speaker 00:
Futility, not appropriate under Menominee Tribe.

[00:22:25] Speaker 05:
Can I just double check on the email that was referenced, which I guess we do not have, but that was submitted as part of the summary judgment record to the board or not even there?

[00:22:38] Speaker 00:
Yes and no.

[00:22:39] Speaker 00:
So the email to which Ms.

[00:22:42] Speaker 00:
Sicali refers was not before the board during the summary judgment briefing.

[00:22:47] Speaker 00:
It was first mentioned by Ms.

[00:22:49] Speaker 00:
Sicali on behalf of Green Valley in her motion for reconsideration of the summary judgment decision.

[00:22:55] Speaker 00:
It was not attached or in any way presented as competent evidence.

[00:23:00] Speaker 00:
It was excerpted in her brief.

[00:23:04] Speaker 00:
in the text narrative of her brief.

[00:23:07] Speaker 00:
But importantly, I will represent to this court, it does not tell Green Valley not to file a claim.

[00:23:13] Speaker 00:
It does not rise to that level, right?

[00:23:18] Speaker 00:
It's the government saying, if you file a claim, we reserve our rights to respond.

[00:23:22] Speaker 05:
The document as such was never submitted.

[00:23:25] Speaker 00:
The document as such was never submitted, no.

[00:23:31] Speaker 01:
OK, any other?

[00:23:34] Speaker 00:
No, just in further response to Ms.

[00:23:37] Speaker 00:
Zaccalli, she had represented that while the district court action and the debarment were pending, there was a wall between the contractor and the contracting officer.

[00:23:46] Speaker 00:
We submit that the record does not support that.

[00:23:52] Speaker 01:
Thank you.

[00:23:56] Speaker 01:
You have a little under three minutes.

[00:23:58] Speaker 02:
One of the things that the Army has failed to show that it would be prejudicial to them to hold statute of limitations and to pay them, and it's not burdensome whatsoever to pay these invoices.

[00:24:11] Speaker 02:
And there was a time when Green Valley submitted a claim and it went unanswered in 2007.

[00:24:16] Speaker 02:
It went unanswered in any way by the Army.

[00:24:20] Speaker 05:
So it would be... That was the unsigned one?

[00:24:22] Speaker 02:
Well, they're on notice.

[00:24:24] Speaker 02:
She claims that they were never on notice and that it's burdensome, but they've never proven that it's burdensome for them to pay these invoices of work that was done.

[00:24:34] Speaker 02:
And it was burdensome for the appellant to have to clear their name, go through civil action, and all of the diligence that they've exercised.

[00:24:44] Speaker 02:
In addition, cooperating with the Department of Justice to, if you want to say that the precedent says, don't cooperate, just file your claim,

[00:24:52] Speaker 02:
That's the only way you're going to get money for the claim.

[00:24:56] Speaker 05:
You could do both.

[00:24:57] Speaker 02:
You could do both if you didn't have a civil action that carried very severe penalties.

[00:25:06] Speaker 02:
Okay.

[00:25:07] Speaker 02:
Thank you.