[00:00:00] Speaker 00:
is Mosek, Patrice Mosek, Justice Secretary of HHS, 2018-2341.

[00:00:13] Speaker 00:
Mr. Blumenspiel, when you're ready.

[00:00:18] Speaker 02:
Thank you, Your Honors.

[00:00:19] Speaker 02:
I thank you very much for this opportunity to discuss what I consider a grave injustice to a young 12-year-old girl.

[00:00:25] Speaker 02:
I represent the petition repellent in this case.

[00:00:28] Speaker 02:
I've had the privilege, pleasure of working with, I assume you are, Rob Coleman.

[00:00:33] Speaker 02:
I look forward to meeting you.

[00:00:36] Speaker 02:
She was a 12-year-old four-point student in a gifted program, very social, hiking, dancing, having a good time.

[00:00:44] Speaker 02:
School mandated that she take tetanus, diphtheria, pertussis, vaccine, and meningiococcal.

[00:00:51] Speaker 02:
And they sent her to a specific clinic where the doctor then also said,

[00:00:56] Speaker 02:
I want you also to take a fifth vaccine as part of the cell.

[00:01:03] Speaker 00:
Council, we're very sympathetic to anyone who was injured, either from a vaccine or not.

[00:01:09] Speaker 00:
But we have a particular proceeding here.

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We have the requirements of the law.

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And the special master dismissed your case for failure to prosecute.

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And I count three times.

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when you were required to do something and didn't act.

[00:01:30] Speaker 00:
And so why was that an abuse of discretion?

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That is, you were focusing much like the special master did.

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The evidence of the damage is incredible.

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And we'll leave that for a secondary one.

[00:01:42] Speaker 02:
The fear to prosecute.

[00:01:43] Speaker 01:
Well, there is, I mean, the special master did lay out his conclusion that he didn't think it was a strong case in any event because of the prior history of illnesses and problems.

[00:01:56] Speaker 01:
But he set that aside at the end, right?

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And said, even if I don't find that, even if I assume that this is a strong case, I find that all of the other questions don't justify allowing the additional extension.

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Yes.

[00:02:13] Speaker 02:
He did seem to over-focus on the procedural, what he calls the fair, to prosecute.

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And I can understand

[00:02:21] Speaker 02:
his animosity towards me on that.

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And that's why I appreciate the opportunity to talk with you directly so you can judge my honesty and sincerity.

[00:02:29] Speaker 02:
He said I was somewhat disingenuous.

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I have practiced for 52 years in every state east of the Mississippi and three west.

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I've never had a judge or an attorney that I worked in opposition with that would have ever told you folks that Jim ever violated and intentionally and knowingly ignored an order.

[00:02:51] Speaker 03:
Okay, but let me tell you what your problem is here.

[00:02:55] Speaker 03:
There is evidence of at least negligence in terms of responding to the court's orders.

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The question, however, is whether in setting aside the merits of the case pursuant to court of federal claims precedent,

[00:03:16] Speaker 03:
He made a mistake because the Court of Federal Claims President, as I understand that he relied on, says that the merits of the case are not relevant to the question of whether this is excusable neglect or not.

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And I'm not sure that's correct.

[00:03:32] Speaker 02:
It isn't.

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It isn't.

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He has to balance the thing.

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We had a duty of preponderance the evidence.

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We met it by four experts to zero.

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We met it.

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So set that aside and the primary issue, and I agree with you.

[00:03:46] Speaker 02:
Is me.

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Was there justification?

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I showed you, and I couldn't understand it when in his opinion, he attached documents that allegedly showed the email worked.

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And when I, on my reply brief, took a magnifying glass, couldn't figure out why the print was so small.

[00:04:06] Speaker 02:
The key ruling was the show cause or I'm going to dismiss this case.

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And that one was not sent.

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to the right email address.

[00:04:18] Speaker 02:
By their own document, they show that.

[00:04:21] Speaker 02:
And that's what was frustrating.

[00:04:23] Speaker 02:
He made a comment in his opinion to support his opinion of failure to prosecute when he said, for 11 months in this case, the email process worked perfectly.

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You got every one of some 34 entries.

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I likewise shared with him a mistaken view.

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relied on that 11 months of 34 entries as justification, which brings in the word invertence.

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I was invertent in what happened there.

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But I relied on the fact that, yes, they come through all the time.

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So I looked.

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I have never in 52 years ever had a circumstance like this.

[00:05:09] Speaker 02:
It's the most extraordinary, exceptional circumstance where a doctor had a personal crisis, a family health member dying,

[00:05:15] Speaker 01:
I think, you know, and I can see this special master tends to use harsh language that isn't necessary sometimes to the circumstances.

[00:05:26] Speaker 01:
But having said that, wasn't it not just a situation where you had some reasonable problems, but you didn't let the special master know about those problems?

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That's a very, I'm an old fashioned person.

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I trust people until they prove to me, I can't trust them.

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I trust people.

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That's what guys my age do or did.

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And that's the way I felt about Judge Special Master in this case is that he was kind enough.

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And when I asked to have until the end of July, he gave it into, or end of August, three weeks, whatever it was, he then gave me another three, four weeks.

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I thought he was a kind, patient sort.

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Then when I checked email every day,

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Nothing in September or October came through.

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It seems to me difficult to say that because the special master had been kind and patient, that that somehow excused your neglect, which is pretty clear from the record.

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You didn't do what you should have done.

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The question, at least in my mind, is whether in resolving this question of excusable neglect, the special master

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in putting aside the merits of the case, which it seems to me may not be correct.

[00:06:43] Speaker 02:
If I understand you right, no, he should not overlook the merits of the case when dealing with failure to prosecute.

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And the pioneer, the U.S.

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Supreme Court and pioneer and Clappard both said it is to be liberal.

[00:06:59] Speaker 02:
Well, your court said when judging whether or not to set aside a judgment is to be liberally construed

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with the exception of the finality of judgment, for the purpose of doing substantial justice.

[00:07:09] Speaker 02:
The substantial justice is not sanctioning me.

[00:07:13] Speaker 02:
It is whether or not this 12-year-old girl who has had to drop out of school lives in constant pain in the arms and legs.

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Her heart doesn't function properly.

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Her legs swell.

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She is in constant fatigue.

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Everything in her life has stopped, and she has no way to support herself in the future.

[00:07:29] Speaker 01:
And this is... But how do you address the special master's specific references to

[00:07:35] Speaker 01:
documentation that showed that there were substantial problems before the administration of these vaccines.

[00:07:46] Speaker 02:
Because she's just absolutely dead wrong.

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She had a burst ovary and the cyst re-healed.

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She had some minor problems, but you don't have a whole lot of serious problems when you're a four-point student in a gifted program and you are socially active.

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You go hiking and dancing.

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and having fun with friends, and now she has no friends, no social activity, she sleeps during the whole day, she can't sleep at night, her world has been destroyed.

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And that cannot be lost in this court's judgment.

[00:08:19] Speaker 02:
It's got to be looked at because, and I would not, you know, there's a public opinion.

[00:08:25] Speaker 02:
If he wants to just sanction me in the future by having that public opinion, that's fine.

[00:08:29] Speaker 02:
But my, that's why I have waved

[00:08:33] Speaker 02:
when that argument was made, that's why I have waived all fee and all expenses so that you folks know from this heart, and I swear to my God, my whole focus and intent is that justice is done for this young girl whose life has been ruined and not some sanctioning for their own document that said they sent it to the wrong email for the show cause order.

[00:09:00] Speaker 02:
These things cannot

[00:09:02] Speaker 02:
exist override and destroy this girl's life who had nothing to do with this.

[00:09:07] Speaker 02:
The school mandated the four and it is an interesting to note when weighing the value of her injuries is that you have to look and the vaccine act itself says, I've got it written down here, the TB, the tetanus, diphtheria, pertussis, meningococcal, and Gardasil, they're all listed.

[00:09:29] Speaker 02:
as recognizing their adverse events secondary to those drugs.

[00:09:34] Speaker 02:
And anaphylaxis, neuritis, vasovagal syncope, encephalopathy, encephalitis, she literally has symptoms of every one of those.

[00:09:44] Speaker 02:
And the vaccine people have recognized that and said that is an acknowledged adverse reaction.

[00:09:50] Speaker 02:
That cannot be set aside for a two-month delayed report, which was not the fault of anybody, and none of us had any control over it.

[00:09:58] Speaker 02:
The court had no control over it.

[00:10:00] Speaker 02:
Dr. Miller had no control over the crisis he had in his practice.

[00:10:03] Speaker 02:
And the family member that was in critical condition and Dr. Mazer who was in a two-month trial, those doctors, they had no control over it.

[00:10:13] Speaker 02:
I had no control over it.

[00:10:15] Speaker 02:
It just simply, I couldn't understand.

[00:10:17] Speaker 02:
I didn't know whether to approach the judge and say, Judge, I don't know whether they're dead or whether they had a stroke or a heart attack, they're hospitalized.

[00:10:26] Speaker 02:
I can't get through to them.

[00:10:27] Speaker 02:
And I kept thinking, this is where inadvertence comes in, which does allow reversals.

[00:10:33] Speaker 02:
I was inadvertent.

[00:10:33] Speaker 02:
I was so, every time, I'm going to get them the next time.

[00:10:36] Speaker 02:
I just know I'm going to get them on the phone the next time.

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And I didn't.

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And I waited another two, three days.

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And I could never even leave a voicemail for Dr. Miller.

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And I left multiple voicemails for Dr. Mazer, who was supposed to be the corresponding in go between, and he admitted,

[00:10:53] Speaker 02:
I never even answered my phone or listened to my voicemails for the two months I was tied up in that litigation.

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Everything just all coupled together there for those two months.

[00:11:03] Speaker 02:
And the court's email system, for whatever reason, didn't work until, oddly enough, the public decision on November 14th was posted.

[00:11:14] Speaker 02:
That's the first in two months that I ever heard.

[00:11:16] Speaker 02:
And I got that from my email notification.

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And that's what I have to convince you folks

[00:11:22] Speaker 02:
I'm swearing to God that I was inadvertent, and I think I would fit the terms of the Rule 60B1.

[00:11:30] Speaker 02:
There was some mistakes, but the judge made them too.

[00:11:33] Speaker 00:
Yes.

[00:11:34] Speaker 00:
Counsel, the question isn't the servancy or the dedication of your advocacy for your client.

[00:11:43] Speaker 00:
The question is whether there was an abusive discretion, a narrow question on the part of the special master,

[00:11:50] Speaker 00:
which the Court of Federal Claims affirmed.

[00:11:54] Speaker 02:
I know, but I think they also were wrong.

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And in other words, the abuse of discretion was arbitrary.

[00:12:03] Speaker 02:
He focused more on me than on my client.

[00:12:07] Speaker 02:
And it was a mistake.

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He also mistakenly failed to even look at the full record and see Dr. Flynn's where his record, her record, repeatedly said, she's been injured by Gardasil.

[00:12:19] Speaker 02:
And then two letters to the school saying she can't come back to school at least for the rest of the year because of a Gardasil injury.

[00:12:27] Speaker 02:
He never seemed to recognize that treating physician.

[00:12:30] Speaker 02:
And he said only one treating physician, no, two treating physicians.

[00:12:36] Speaker 00:
Counsel, you wanted to save some time for rebuttal.

[00:12:38] Speaker 00:
Shortly.

[00:12:39] Speaker 00:
So why don't we save your time and hear from Mr. Coleman.

[00:12:42] Speaker 02:
Thank you.

[00:12:53] Speaker 04:
It plays the court.

[00:12:54] Speaker 04:
My name is Robert Coleman.

[00:12:55] Speaker 04:
I represent the Respondent Secretary of Health and Human Services.

[00:12:59] Speaker 03:
Let me tell you what my problem is here.

[00:13:01] Speaker 03:
It's clear that counsel was negligent.

[00:13:03] Speaker 03:
No question about it.

[00:13:05] Speaker 03:
The question is, what role does the merits of the case play in this?

[00:13:10] Speaker 03:
And reading this record, it looks as though the case is pretty substantial.

[00:13:14] Speaker 03:
And to the extent that the special master suggests that it was insubstantial, I think that's hard to sustain.

[00:13:21] Speaker 03:
The question is, what role does the merits of the case play in making the excusable neglect determination?

[00:13:29] Speaker 03:
As I understand, the Court of Federal Claims in this case and in the earlier case on which it relies, it says that's not relevant to making the decision.

[00:13:39] Speaker 03:
And I'd like you to address that, because that seems to me not to be correct.

[00:13:44] Speaker 04:
My understanding from the law is that, as affirmed by this very court in Fisher v. Anderson,

[00:13:51] Speaker 04:
that excusable neglect for failing to respond to orders, there is no claim there.

[00:13:58] Speaker 04:
Failing to respond to orders does not constitute excusable neglect.

[00:14:01] Speaker 04:
And in Fisher v. Anderson, this court did not address it.

[00:14:04] Speaker 03:
Did Fisher consider the question of whether the merits of the case should be taken into account in making that determination?

[00:14:13] Speaker 04:
No.

[00:14:13] Speaker 04:
In this court's opinion, the merits were not.

[00:14:16] Speaker 03:
But the Court of Federal Claims has said, no, it's irrelevant.

[00:14:19] Speaker 03:
in an earlier case which they relied on here.

[00:14:22] Speaker 03:
I'm not sure that's correct.

[00:14:24] Speaker 03:
I mean, no question that there's negligence here, but doesn't, in making the determination of excusable neglect, doesn't the special master have to consider the strength of the merits of the case?

[00:14:41] Speaker 04:
I don't believe that the case law indicates that he does.

[00:14:43] Speaker 04:
However, even if he does, he did address the merits.

[00:14:47] Speaker 03:
Is there any case that's apart from those court of federal claims cases, is there any case that says you don't consider the merits?

[00:14:55] Speaker 04:
There's no case that I'm aware of that affirmatively says you do not consider the merits when addressing excusable neglect.

[00:15:00] Speaker 04:
However, here, the special master's... Aren't you supposed to look at prejudice as well?

[00:15:04] Speaker 01:
What is the prejudice to HHS?

[00:15:07] Speaker 04:
Here, HHS did not argue prejudice.

[00:15:10] Speaker 04:
In the first instance, there is, of course, some prejudice inherent in this type of case, because it just would have to spend additional resources to deal with the claim.

[00:15:18] Speaker 04:
But because of the strength of the other arguments, particularly the third prong identified by Pioneer, which is the most important prong, which is whether the reason for the delay was the reasonable control of the moving party.

[00:15:32] Speaker 04:
And here, that factor weighs heavily against Petitioner.

[00:15:36] Speaker 01:
Well, there's no sign of bad faith or anything, right?

[00:15:39] Speaker 04:
Which is another that's

[00:15:40] Speaker 04:
Correct.

[00:15:41] Speaker 04:
Respondent has not argued that.

[00:15:42] Speaker 01:
There's no bad faith.

[00:15:43] Speaker 01:
There's no prejudice.

[00:15:44] Speaker 01:
And as Judge Dyke says, there's real issues with respect to the merits.

[00:15:52] Speaker 04:
The Sullivan's case, which comes from the Second Circuit, indicates that the preponderant factor is that third factor, whether the moving party had reasonable control over the reason for the delay.

[00:16:07] Speaker 04:
And here, the reason for the delay was not any issues with

[00:16:10] Speaker 04:
the experts in the underlying case.

[00:16:14] Speaker 04:
The real issue is that the petitioner's attorney did not act.

[00:16:17] Speaker 03:
Well, I'm not sure the real issue is correct.

[00:16:20] Speaker 03:
That is an issue.

[00:16:22] Speaker 03:
And certainly, apart from this fact that the September 19 thing was sent to the wrong address, which is not something the special minister recognized, but even apart from that, there's evidence of neglect.

[00:16:34] Speaker 03:
There's no question about it.

[00:16:35] Speaker 03:
The question is whether

[00:16:38] Speaker 03:
There's an abuse of discretion here in failing to consider the merits of the case and weighing that together with the lack of prejudice to make a determination.

[00:16:49] Speaker 04:
Although the court may disagree with the weighing of the merits, the special master here did unquestionably weigh the merits.

[00:16:55] Speaker 03:
Well, yeah, but he explicitly refused to consider the merits of the case in making the determination.

[00:17:03] Speaker 04:
He weighed the merits and found that there was no merits of the case, in fact.

[00:17:08] Speaker 03:
I think that, to me, that's not supported by substantial evidence.

[00:17:11] Speaker 03:
I'll tell you, looking at this record, I just think that's not supportable.

[00:17:16] Speaker 03:
This is a substantial case, whether they ultimately win or not, who knows, but it's not an insubstantial case.

[00:17:23] Speaker 04:
Well, the special minister did go through the underlying evidence as well as the expert reports that were filed by Petitioner.

[00:17:29] Speaker 04:
Here, Petitioner filed three expert reports, but all three expert reports had different diagnoses for the condition.

[00:17:35] Speaker 04:
And they offer no

[00:17:37] Speaker 04:
convincing explanation.

[00:17:38] Speaker 04:
The special master.

[00:17:39] Speaker 03:
That's the question.

[00:17:40] Speaker 03:
Convincing.

[00:17:41] Speaker 03:
That's for a trial.

[00:17:43] Speaker 04:
Here, under Vaccine Rule 8D in this program, the special master does not have to afford petitioner an evidentiary hearing.

[00:17:52] Speaker 04:
He can make a determination based on the written submission.

[00:17:54] Speaker 03:
Okay.

[00:17:54] Speaker 03:
But do you agree that the failure to consider the merits of making the excusable neglect determination is error?

[00:18:02] Speaker 04:
No.

[00:18:02] Speaker 03:
And why is that?

[00:18:04] Speaker 03:
What authority do you have for that aside from

[00:18:07] Speaker 03:
what the Court of Federal Claims has said about this.

[00:18:09] Speaker 04:
This court and Fisher v. Anderson has upheld.

[00:18:12] Speaker 03:
But you said that Fisher didn't consider the merits question.

[00:18:15] Speaker 04:
Exactly.

[00:18:16] Speaker 04:
So the merits... But it wasn't argued.

[00:18:19] Speaker 03:
I don't know if it was argued by the... Well, there's no indication in the face of the opinion that it was argued, right?

[00:18:25] Speaker 04:
Right.

[00:18:25] Speaker 04:
I'm not aware of that.

[00:18:27] Speaker 04:
However, here the merits were addressed.

[00:18:30] Speaker 04:
So although this court may disagree with the value placed on the merits, those merits were

[00:18:35] Speaker 04:
addressed, the special master did go through all of the evidence submitted.

[00:18:39] Speaker 04:
And moreover, the special master did address even the late file expert report.

[00:18:46] Speaker 00:
The special master devoted several paragraphs to the issue.

[00:18:51] Speaker 00:
The expert support remains weak.

[00:18:55] Speaker 00:
Causation theory is facially unpersuasive.

[00:18:59] Speaker 00:
Granting relief would likely be a futile exercise.

[00:19:04] Speaker 04:
That's correct.

[00:19:04] Speaker 00:
That's your point?

[00:19:05] Speaker 04:
Yes, and the special master on page 18 of the appendix note 14 indicates that not only is the case meritless, but if it were to be reopened, it may not even have a reasonable basis to move forward.

[00:19:16] Speaker 00:
The question is whether he should not have considered the merits.

[00:19:22] Speaker 04:
Either way here, I believe the special master is covered, because the special master did address the merits on one side, and on the other side, he also did address petitioners' claims for relief from judgment and found that on those grounds,

[00:19:34] Speaker 04:
Primarily because petitioner here unquestionably knew of the initial deadline as he played an active role.

[00:19:40] Speaker 04:
He, meaning petitioner's counsel, played an active role in setting that deadline.

[00:19:44] Speaker 04:
So petitioner knew of that deadline at minimum and failed to comply with that.

[00:19:48] Speaker 01:
Is there a difference between seeking relief because of mistake or inadvertence versus excusable neglect?

[00:19:58] Speaker 04:
They're delineated as separate factors.

[00:20:02] Speaker 04:
However, here, Petitioner hasn't put forward any case law directly addressing mistake and inadvertence.

[00:20:08] Speaker 01:
Well, you wouldn't necessarily need to even get to excusable neglect if there were a conclusion that really what happened here was just inadvertence as opposed to full-on neglect.

[00:20:22] Speaker 04:
Perhaps.

[00:20:23] Speaker 04:
But here, Petitioner knew of the first deadline, so willingly

[00:20:27] Speaker 04:
failed to act.

[00:20:28] Speaker 01:
But there is some confusion in the record as to whether he ever got the show cause order.

[00:20:33] Speaker 04:
No, that's not correct.

[00:20:34] Speaker 04:
And I can address that issue as the primary reason for the discrepancy regarding that's appendix page 27 that Petitioner identifies.

[00:20:41] Speaker 04:
The primary reason for the discrepancy there is a poor quality photocopy.

[00:20:46] Speaker 04:
The original document is court exhibit four that the special master filed along with his decision denying Petitioner's request for release from judgment.

[00:20:54] Speaker 04:
That document is clear.

[00:20:56] Speaker 04:
I brought copies here today.

[00:20:57] Speaker 04:
I could submit those to the court, or I could just identify where the court can find the clean document.

[00:21:02] Speaker 04:
But that was submitted on February 16, 2018.

[00:21:05] Speaker 04:
It shows the petitioner received the proper order, received that order, the proper email address.

[00:21:11] Speaker 04:
It was sent to the correct address?

[00:21:12] Speaker 04:
Yes, it was sent to the correct address.

[00:21:15] Speaker 04:
That's something that's also addressed in Fisher v. Anderson, that once the information is sent to the correct address, it is presumed that

[00:21:25] Speaker 04:
petitioners and receive that.

[00:21:30] Speaker 04:
If there are no further questions, the respondent respectfully requests that this court affirm.

[00:21:34] Speaker 04:
Thank you.

[00:21:35] Speaker 00:
Thank you, Mr. Coleman.

[00:21:36] Speaker 00:
Mr. Blumenstiel has about two and a half minutes.

[00:21:40] Speaker 02:
Just a couple of particular points here.

[00:21:44] Speaker 02:
It was only a two-month delay, this report.

[00:21:46] Speaker 02:
This whole thing is over a two-month delay for a doctor's report who was having a family crisis and a practice crisis.

[00:21:54] Speaker 02:
And we couldn't find out about it.

[00:21:57] Speaker 02:
But here's what the U.S.

[00:21:59] Speaker 02:
Supreme Court and Pioneers said.

[00:22:00] Speaker 02:
Congress intended courts to be able to be permitted to accept late filings caused by inadvertence, yes me, mistake, both the judge and I, carelessness, yes, not just by those caused by intervening circumstances beyond the party's control.

[00:22:17] Speaker 02:
Willingly failed to react.

[00:22:18] Speaker 02:
That is not the case.

[00:22:21] Speaker 02:
I struggled every two or three days.

[00:22:24] Speaker 02:
But my focus was I trusted the judge.

[00:22:27] Speaker 02:
I trusted the email.

[00:22:29] Speaker 02:
I don't think you're going to get anywhere with that.

[00:22:31] Speaker 02:
Well, yeah, maybe not.

[00:22:32] Speaker 02:
But still, it's in my heart, Your Honor.

[00:22:35] Speaker 02:
That's the problem.

[00:22:35] Speaker 02:
The other thing I want to say, rule 60B6, which is the alternative to the rule B1, is must be justified by a showing exceptional circumstance.

[00:22:45] Speaker 02:
I doubt if anybody in this courtroom had any more exceptional circumstances than that doctor having his crises

[00:22:52] Speaker 02:
the failing of the email address, things of that nature, but must be justified by exceptional circumstances where a grave miscarriage of justice.

[00:23:03] Speaker 02:
Now we're weighing where the grave miscarriage of justice would result in the substantial rights of a party would be harmed if relief is not granted.

[00:23:14] Speaker 02:
That's the Kenzora and the Kennedy case.

[00:23:17] Speaker 02:
Her rights to relief were completely destroyed.

[00:23:19] Speaker 00:
But here the special master said,

[00:23:21] Speaker 02:
uh... granted relief would be a futile exercise because this is weak on the merits did you not perceive the way i perceive that futile exercise when i knew we had the preponderance because he there's no no respondent expert but he also talked about it could be a futile exercise and bring it back and i'm going to deny it but i might also find it was unreasonable and no good cause even file this claim

[00:23:51] Speaker 02:
What he was saying to me was, Blumensteel, don't appeal this, or I may deny your fee and your expenses.

[00:23:58] Speaker 02:
Well, to show how genuine and sincere I am, that's why I waived all my fee and all my expenses.

[00:24:04] Speaker 02:
This is my last legal event of my 52-year career.

[00:24:07] Speaker 02:
If you are kind enough to reverse this case and send it back, I will step out of the case.

[00:24:14] Speaker 00:
Also, humbleness isn't the issue.

[00:24:17] Speaker 00:
We appreciate your argument, and your time is up.

[00:24:20] Speaker 00:
And we will consider your arguments.

[00:24:22] Speaker 00:
Thank you for your time.

[00:24:24] Speaker 02:
I appreciate very much the opportunity.