[00:00:00] Speaker 01:
Feliciano versus the Department of Transportation, 2022-2019.

[00:00:10] Speaker 01:
Good morning, Mr. Lalo, when you are ready.

[00:00:16] Speaker 04:
Good morning, Your Honors.

[00:00:18] Speaker 04:
May it please the Court, Brian Lawler on behalf of the petitioner, Nick Feliciano, and subsequently the petitioner, Charles Flynn.

[00:00:25] Speaker 04:
I'll defer to the Court if the Court would like to ask questions about both.

[00:00:30] Speaker 04:
I don't think I'm going to have anything different to say.

[00:00:33] Speaker 04:
But procedurally, I suppose I can speak and then government counsel can speak, then we can do Flynn after.

[00:00:39] Speaker 01:
You have a different government counsel in these two cases.

[00:00:42] Speaker 04:
Yes, sir.

[00:00:43] Speaker 04:
I'm aware of that.

[00:00:45] Speaker 04:
My opening would sound remarkably like Mr. Marshall's opening for the Nordby case.

[00:00:49] Speaker 04:
What we're talking about here is 5538.

[00:00:52] Speaker 04:
And as the court has now heard quite a bit.

[00:00:55] Speaker 03:
Can I just ask you factually again about the type of training your client was called to duty for in this case?

[00:01:01] Speaker 04:
So Mr. Feliciano is a Coast Guard reservist.

[00:01:05] Speaker 04:
He went to the Federal Law Enforcement Training Center.

[00:01:07] Speaker 04:
He was doing counter drug.

[00:01:09] Speaker 04:
counter-human smuggling operations during his active period.

[00:01:14] Speaker 04:
Though, I mean, I think if we're looking to the nexus between what the reservist or guardsman or woman is doing, I think it's pretty easy factually that Mr. Feliciano was- What statutory provision was- 12301D, Your Honor.

[00:01:30] Speaker 04:
He was under 12301D orders as the vast majority of reserve and guard personnel are when they're activated.

[00:01:37] Speaker 04:
And I'd like to

[00:01:39] Speaker 04:
perhaps help them enlighten the court, respectfully, with how reserve and guard personnel are activated and ordered.

[00:01:45] Speaker 04:
And I think 5538 and the holding in Adams, which we also believe is incorrect, Your Honor.

[00:01:51] Speaker 04:
I know it's difficult to stand here and tell you that after you wrote it.

[00:01:53] Speaker 04:
But we don't agree with Adams.

[00:01:55] Speaker 04:
We think it is wrong.

[00:01:56] Speaker 04:
We think the court got it correct in O'Farrell.

[00:01:59] Speaker 03:
I'm a little confused why you see

[00:02:02] Speaker 03:
inconsistency between the two, when O'Farrell explicitly recognizes that not every reserve is called to active duty gets this type of pay.

[00:02:12] Speaker 04:
That's exactly right, Your Honor.

[00:02:13] Speaker 04:
And that's what I wanted to kind of help enlighten the court.

[00:02:15] Speaker 04:
So of my 28 years in the rank or 17 were in the reserve component, what Note 5 and O'Farrell would exclude are drills for weekends, IDTs and active duty for training periods, annual training.

[00:02:29] Speaker 04:
You know, as the court knows, in Adams, we didn't bring, I was Mr. Adams' counsel as well, which the court probably is aware, we didn't even raise the issue on appeal of the denial of differential pay for the annual training, which is a two week requirement that almost all reserve and guard personnel do, because that would fall under note five of a fail.

[00:02:46] Speaker 04:
That wouldn't be subject to differential pay.

[00:02:49] Speaker 04:
So we recognize that 12301D being a provision of law, every reservist your honor asked Mr. Marshall,

[00:02:57] Speaker 04:
is your position that every reservist called to orders under 12301D is going to get differential pay.

[00:03:02] Speaker 04:
That's exactly our position.

[00:03:04] Speaker 04:
And note five and O'Farrell would exclude those periods.

[00:03:06] Speaker 04:
I just mentioned drill, annual training, other IDTs.

[00:03:10] Speaker 04:
There are other ways that reserve and guard personnel come on active duty and get paid, but those would not be subject to 5538 differential pay.

[00:03:19] Speaker 04:
But it is our position that if you're on 12301D orders, which is voluntary,

[00:03:24] Speaker 04:
sometimes on hold, but voluntary, at least for the statute, every one of those orders would qualify for differential pay.

[00:03:31] Speaker 03:
And that's because of the argument that the statute of referral

[00:03:36] Speaker 03:
explicitly has the in support of contingency operation.

[00:03:39] Speaker 03:
And 5538 just cross-references contingency operation.

[00:03:45] Speaker 04:
Yes, sir.

[00:03:45] Speaker 04:
And I would go further to say that in the analysis that this court did in O'Farrell, it parses out, it discusses Mr. O'Farrell's relationship.

[00:03:56] Speaker 04:
He's indirectly supporting because he backfilled for an attorney who went forward to Afghanistan.

[00:04:01] Speaker 04:
But then the court goes a little further and says,

[00:04:05] Speaker 04:
It's sort of immaterial because he's called to, this is Mr. O'Farrell, called to active duty under a provisional law, 12301D, during a time of national emergency.

[00:04:14] Speaker 04:
And that's one of the last holdings that this court had in O'Farrell.

[00:04:19] Speaker 04:
That requirement, again, we've been talking about the cross-reference, isn't in 5538.

[00:04:24] Speaker 04:
And I would humbly submit that when this court defined contingency operation, it simply took the or any provision of law after the comma,

[00:04:33] Speaker 04:
in 101A13 and said, that is the contingency operation.

[00:04:36] Speaker 04:
So it's a little circular, but we keep saying contingency operation, but this court's already defined it using the catch-all provision.

[00:04:43] Speaker 04:
So that's where we are.

[00:04:46] Speaker 04:
But such a requirement doesn't exist under 5538.

[00:04:49] Speaker 04:
And the reason I respectfully disagree with Adams is it went further than O'Farrell just requiring any sort of indirect support, didn't need to show the operation that it was being supported.

[00:05:00] Speaker 04:
The Adams court directly called

[00:05:03] Speaker 04:
to the operation.

[00:05:04] Speaker 04:
So without defining that further, and candidly, both as an attorney and as a career marine, I didn't even understand what that meant, what directly called to serve.

[00:05:13] Speaker 04:
It didn't really resonate.

[00:05:15] Speaker 04:
I thought the court's analysis in O'Farrell, albeit with a different statute, was correct and respectfully Adams is not.

[00:05:23] Speaker 04:
And we, too, would, under Rule 35, request that the panel refer to a certain

[00:05:29] Speaker 02:
Assuming we are bound by atoms and we don't go in bonk, or at least the three of us are not in bonk at the moment, how, if at all, can you prevail in this appeal?

[00:05:41] Speaker 04:
Under atoms, I don't think we can.

[00:05:43] Speaker 04:
We would certainly welcome being remanded and being able to open the

[00:05:50] Speaker 04:
The factual discussion.

[00:05:51] Speaker 02:
You haven't asked for a renounce though, at least in your briefing.

[00:05:55] Speaker 04:
Right, and the reason we didn't develop a factual record was Mr. Feliciano's record closed prior to Adams at the time.

[00:06:02] Speaker 04:
The controlling law was, if you want to develop 12301D orders, during a national emergency you were going to get the differential pay.

[00:06:09] Speaker 04:
That decision took almost a year to come out, during which Adams happened, so we didn't develop the record because we didn't have to.

[00:06:16] Speaker 02:
Could you have petitioned to reopen the record after Adams was issued?

[00:06:20] Speaker 04:
I suppose we probably could have, yes.

[00:06:22] Speaker 02:
Are you asking us to... I guess you're not asking for a remand, so I don't have to think about why you didn't.

[00:06:28] Speaker 04:
We're not asking for a remand because, candidly, we don't want to go back down if Adams is still controlling, because I don't know that he went, or any other reservist under 12301D.

[00:06:37] Speaker 04:
OPM's guidance, which was adopted by the Adams court, it's pretty clear that no

[00:06:43] Speaker 04:
12301D orders, no voluntary orders will ever qualify for differential pay.

[00:06:47] Speaker 04:
That's not, thousands and thousands of reserve and guard personnel get activated under 12301D and go forward and go into harm's way.

[00:06:55] Speaker 04:
That's just a simple fact.

[00:06:57] Speaker 03:
But under Adams and- You're from before you referred to the NECIS brief, so there's a number of members of Congress who clearly disagree with Adams.

[00:07:05] Speaker 03:
Has there been any movement since Adams in Congress?

[00:07:09] Speaker 03:
Legislatively?

[00:07:10] Speaker 03:
Legislatively.

[00:07:11] Speaker 04:
I don't know the answer to that.

[00:07:14] Speaker 04:
I would like it to be, but I don't know the answer to that question.

[00:07:20] Speaker 04:
I think just one piggyback, and again, I'm trying to avoid repetition here, but when we discuss, Congress knows what it writes and writes what it knows.

[00:07:30] Speaker 04:
In 6323, the additional pay leave statute that was at issue in O'Farrell, enacted in 66, amended most recently in 2004, the impetus for

[00:07:42] Speaker 04:
5538 start in 2001, 6323 says in support of contingency operation 5538 doesn't, it would be, I think, clear that as those two statutes were overlapping,

[00:07:54] Speaker 04:
if Congress wanted to put in support of contingency upgrades.

[00:07:56] Speaker 03:
Well, can I just ask you the same question I asked your friend before you?

[00:07:59] Speaker 03:
If Congress was really just concerned about the differentials between civilian and military pay, there was a lot easier way to do this, wasn't there?

[00:08:08] Speaker 03:
They could have just said, you always get a differential when you're called to active duty, or you're called for reserve duty.

[00:08:16] Speaker 04:
And respectfully, I think that's what they did do.

[00:08:18] Speaker 04:
I think that's what 5538 reads.

[00:08:20] Speaker 03:
I mean, but it's a really complicated way of doing it.

[00:08:22] Speaker 03:
I agree with that.

[00:08:24] Speaker 03:
If that's what they admit, all they would have had to say is when you're a civilian employee of the federal government and you get called to reserve training under whichever statute, the D1 you're referring to, you get differential pay.

[00:08:39] Speaker 03:
full stop, right?

[00:08:40] Speaker 03:
That's all you require instead of what 5538 says now, which is a fairly convoluted language that then refers to cross-references contingency operation, which is also fairly convoluted.

[00:08:53] Speaker 04:
I agree with everything you're saying.

[00:08:54] Speaker 04:
And I wish Congress acted differently and wrote statutes that were more simple and easy to interpret.

[00:09:00] Speaker 04:
I agree.

[00:09:01] Speaker 03:
I mean, I understand your position.

[00:09:03] Speaker 03:
It's hard for me to parse the statutes in the same way you do when they cross-reference a definitional section and say they only meant to apply part of the definition, not all of the definition, when they could have made it much clearer and much more simple.

[00:09:21] Speaker 04:
I agree.

[00:09:22] Speaker 04:
The way Your Honor wrote that statute, if that's how 5530 it read right now, I don't think we would be here.

[00:09:28] Speaker 04:
I don't know that I have anything to add with respect to Mr. Feliciano.

[00:09:32] Speaker 04:
I'm happy to.

[00:09:33] Speaker 02:
I guess it's just the issue you've already alluded to, but I want to make sure I understand.

[00:09:36] Speaker 02:
It took the board a while here to write its opinion.

[00:09:40] Speaker 02:
Are you contending that's an abuse of discretion?

[00:09:43] Speaker 04:
We absolutely contend that, Your Honor.

[00:09:44] Speaker 02:
And on what authority could we find that's an abuse of discretion?

[00:09:48] Speaker 04:
I don't have any, Your Honor.

[00:09:49] Speaker 03:
Isn't it harmless, anyway?

[00:09:51] Speaker 03:
I mean, if Adams is controlling, Adams is controlling.

[00:09:54] Speaker 04:
Adams would not have been controlling had the administrative judge issued that opinion in six months or nine months.

[00:09:59] Speaker 04:
But she took a year, and in that year... Well, I don't know that that's necessarily true.

[00:10:04] Speaker 03:
I mean, O'Farrell was a different provision.

[00:10:06] Speaker 03:
Adams could have

[00:10:07] Speaker 03:
You know, your case could have come out the same way as Adams.

[00:10:12] Speaker 04:
I respectfully disagree with that, Your Honor.

[00:10:14] Speaker 04:
I've had dozens of these now.

[00:10:15] Speaker 04:
And every AJ, I had Marquis, which was 2015, before O'Farrell.

[00:10:20] Speaker 03:
I mean, I think trying to predict what the AJ would have done is difficult, whether the government would have petitioned for review under the OPM, you know, director of petition for review.

[00:10:31] Speaker 03:
I don't think you can say full stop that your client would necessarily have.

[00:10:35] Speaker 04:
I'm not saying that, Your Honor.

[00:10:37] Speaker 03:
Well, that's pretty much what you have to show for it to be prejudicial, don't you?

[00:10:41] Speaker 04:
I thought it was worth raising to the court's attention.

[00:10:43] Speaker 01:
Do you think there's anything wrong in an agency deferring a decision when it knows that a higher tribunal is evaluating a similar issue or the same issue?

[00:10:57] Speaker 04:
Are you suggesting that's what happened in this case, Your Honor?

[00:10:59] Speaker 04:
I don't think I understand the question.

[00:11:01] Speaker 01:
I thought your brief was implying there was something wrong.

[00:11:07] Speaker 01:
in the agency waiting until Adams was decided?

[00:11:13] Speaker 04:
The administrative judge.

[00:11:14] Speaker 04:
I'm sorry.

[00:11:14] Speaker 01:
I was interpreting that to mean the government.

[00:11:18] Speaker 04:
We are implying that.

[00:11:19] Speaker 04:
We're actually saying that.

[00:11:20] Speaker 04:
And I do think that's only sensible and reasonable, isn't it?

[00:11:25] Speaker 01:
If you know the issue's going to be decided by a higher tribunal.

[00:11:30] Speaker 04:
If Judge Pomeranzi knew that Adams was up and being considered and was waiting on those grounds, then yes, I would agree with that.

[00:11:36] Speaker 04:
I don't know that that's true.

[00:11:37] Speaker 04:
That's completely speculative, like Your Honor just pointed out.

[00:11:40] Speaker 04:
How would that case have come out?

[00:11:41] Speaker 04:
Did she know that Adams was up?

[00:11:44] Speaker 03:
I don't know.

[00:11:45] Speaker 03:
You pointed out, I mean, the board does have

[00:11:48] Speaker 03:
you know, time deadlines that it's supposed to comply with.

[00:11:54] Speaker 03:
You could have asked the full board, and I know the board didn't have a quorum probably, but that's, you know, part of the issue.

[00:12:01] Speaker 03:
But you could have at least asked for the AJ to comply with the time deadline.

[00:12:07] Speaker 03:
Did you?

[00:12:08] Speaker 04:
After the record closed and before she issued her opinion, no, Your Honor, we did not.

[00:12:15] Speaker 04:
So absent any further questions about Mr. Feliciano, I'll sit and presume that there will be something about Mr. Flynn.

[00:12:20] Speaker 01:
All right.

[00:12:21] Speaker 01:
Thank you, Your Honor.

[00:12:22] Speaker 01:
See you later.

[00:12:24] Speaker 01:
Mr. Long?

[00:12:32] Speaker 00:
Thank you, Your Honor.

[00:12:33] Speaker 00:
May it please the court, I think it

[00:12:37] Speaker 00:
I think we've explained why that is, and as my friend Mr. Lawler has noted, he can't win under Lawler.

[00:12:44] Speaker 00:
I'm sorry, he can't win under Adams, I apologize.

[00:12:48] Speaker 00:
I think that disposes of that.

[00:12:50] Speaker 00:
Just with respect to some of the procedural points that I think Judge Stark was asking about, after the initial decision was issued,

[00:12:58] Speaker 00:
one basis for a petition for review would have been for Mr. Feliciano to say that he was able to meet the factual requirements of Adams and to reopen the record in order to make that demonstration.

[00:13:10] Speaker 00:
He didn't make that motion, or he didn't make that petition.

[00:13:14] Speaker 00:
And so I think that, and obviously Mr. Lawler has conceded that, and that disposes of that.

[00:13:19] Speaker 00:
He didn't attempt to make the showing that is required.

[00:13:23] Speaker 00:
And also with respect to the timing,

[00:13:25] Speaker 00:
I would just point out that Mr. Feliciano's appeal at the MSBB was complicated and brought up a lot of issues, many of which have not been raised here on appeal.

[00:13:37] Speaker 00:
And so I don't know the exact reason for the administrative judge's timing.

[00:13:42] Speaker 00:
But it was a complicated case that required digestion, a fair bit of hearing material and evidence.

[00:13:50] Speaker 00:
One other point I'll make, I would just

[00:13:52] Speaker 03:
What do you know is the board's time deadline for deciding these cases for AJs?

[00:13:56] Speaker 03:
It's just in the regulations, isn't it?

[00:14:00] Speaker 00:
I'm not sure whether it's in the regulations.

[00:14:04] Speaker 03:
I mean, I know that AJs probably get their performance evaluated based on compliance with, what is it, 180 days.

[00:14:12] Speaker 00:
And I think that may be right.

[00:14:15] Speaker 00:
I'm only thinking of the regulation that Mr. Feliciano cited in his opening brief, which was not applicable to DOT employees.

[00:14:25] Speaker 00:
And so that's all I have in mind.

[00:14:27] Speaker 00:
I'm not sure what other limits there might be on their ability to, or time requirements there might be.

[00:14:33] Speaker 03:
I mean, I'm just thinking of generally when there are time deadlines, unless Congress has made it clear somehow

[00:14:41] Speaker 03:
they're often more encouraging rather than rendering the agency action invalid.

[00:14:49] Speaker 00:
Right.

[00:14:50] Speaker 00:
Yes.

[00:14:50] Speaker 00:
I don't have the regulation in mind, but I think that's generally right.

[00:14:53] Speaker 00:
As was discussed with Mr. Lawler, I'm not sure what the prejudice would be here.

[00:15:00] Speaker 00:
I mean, I'm not aware.

[00:15:01] Speaker 00:
He has not pointed out any case law for the proposition that an intervening decision from this court somehow can

[00:15:08] Speaker 00:
effectuate prejudice and render it improper at the length of time that it took.

[00:15:15] Speaker 00:
One final point I'll make is my friend Mr. Lawler said that this court, I think, adopted OPM's guidance.

[00:15:23] Speaker 00:
I think that's a slight misread of Adam's.

[00:15:25] Speaker 00:
This may not be the most

[00:15:26] Speaker 00:
important point, but I think the court viewed OPM's guidance as consistent with its own reading, which is a little bit different from saying that the court relied on it or incorporated it.

[00:15:36] Speaker 02:
On that point then, does the government have a position as to whether 12301D voluntary

[00:15:43] Speaker 02:
service you know voluntary activation essentially or activation with the consent of the reservist is is per se not a provision that allows for eligibility for differential pay I don't because that's what OPM says right yes yeah I don't think that Adam stands for that proposition

[00:16:07] Speaker 00:
I think that I read Adams as holding that there could be a showing that a reservist was called to directly serve in a contingency operation under 12301D and that a factual showing of the board would suffice to make a demonstration of entitlement to differential pay.

[00:16:25] Speaker 00:
I realize that that's different from what the OPM guidance says.

[00:16:29] Speaker 00:
I don't think this is the case where we need to resolve that precisely because

[00:16:33] Speaker 00:
Mr. Feliciano is only saying that the existence of the national emergency arising from September 11th at the point when he was called to active duty, that was sufficient.

[00:16:46] Speaker 00:
And I think Adams completely disposes of that argument.

[00:16:49] Speaker 00:
And we can deal with what connection might be required in perhaps another case.

[00:16:58] Speaker 00:
If there are no further questions, we respectfully ask that the court affirm the notice decision.

[00:17:02] Speaker 01:
Thank you, Council.

[00:17:03] Speaker 01:
Mr. Lowe, do you have any rebuttal?

[00:17:05] Speaker 04:
I do, Your Honor.

[00:17:06] Speaker 04:
Thank you.

[00:17:11] Speaker 04:
With respect to the question about timing, I don't have the regulation number.

[00:17:15] Speaker 04:
I believe it's 120 days, though, Your Honor.

[00:17:17] Speaker 04:
I think that's right.

[00:17:19] Speaker 04:
I certainly could be wrong, but in the board's regs, it does indicate when the case should be fully disposed of.

[00:17:25] Speaker 04:
And the AJs suspend them quite often, suspend case processing quite frequently.

[00:17:30] Speaker 04:
In fact, Mr. Feliciano's case was suspended three or four times.

[00:17:33] Speaker 04:
because he was back on and off orders.

[00:17:36] Speaker 03:
I suspect that's because it's tied to their performance evaluations, which may affect their potential... I don't want to worry about that.

[00:17:46] Speaker 04:
I do want to bring something up that we haven't talked about, and it's USERA-specific.

[00:17:50] Speaker 04:
We're talking about these two statutes, specifically 5538 but 6323, but I feel like we're losing the macro a bit in USERA, and my colleague, Mr. Marshall,

[00:18:01] Speaker 04:
In his rebuttal remarks talked about the broad interpretation and that.

[00:18:06] Speaker 04:
But what I think is important is the current status of the law, if Adams does in fact control and OPM's guidance is promulgated, is that voluntary service does not receive a benefit of employment but involuntary service does.

[00:18:21] Speaker 04:
Those two conflicting holdings themselves

[00:18:25] Speaker 04:
conflict with USERRA.

[00:18:26] Speaker 04:
USERRA is very, very clear that it protects benefits of employment for all types of service, voluntary and involuntary.

[00:18:33] Speaker 04:
So if we have one, and I think we cited in our brief, two service members get activated, 112301D, 112304, and they're on the same voxel, on the same cockpit, on the same ship.

[00:18:46] Speaker 04:
One of them is going to get differential pay and one of them is not.

[00:18:48] Speaker 04:
That simply cannot be the right result.

[00:18:52] Speaker 04:
Obviously, there's no evidence before this court how many people, service members, are activated under 12301D and who would ultimately be deployed.

[00:19:01] Speaker 04:
But if it's 12301D, it's still voluntary.

[00:19:04] Speaker 04:
And again, I respectfully disagree with what my friend Mr. Long said.

[00:19:08] Speaker 03:
You don't think Adams leaves open the possibility of getting activated under 12301D

[00:19:14] Speaker 03:
of being deployed in a contingency operation.

[00:19:17] Speaker 04:
So we think it forecloses through 1D, but I understand that the language is a little... I don't think that that's what Adam says.

[00:19:23] Speaker 03:
Obviously, you can read it and come to a different conclusion.

[00:19:27] Speaker 03:
I mean, because the opinion is what it says now, not what anybody happened to intend by it.

[00:19:35] Speaker 03:
But it seems to me that

[00:19:38] Speaker 03:
Because it was following O'Farrill and talking about in support of contingency operations that if somebody got called to serve in a unit in the military theater, even if it was under 12301D, they would qualify.

[00:19:54] Speaker 04:
Directly called to serve, right.

[00:19:56] Speaker 04:
I understand that.

[00:19:57] Speaker 04:
And again, we pointed out that.

[00:19:59] Speaker 03:
So why wouldn't that take?

[00:20:03] Speaker 03:
of your voluntary versus involuntary size.

[00:20:07] Speaker 03:
Does anybody get called to involuntary duty for just routine training?

[00:20:20] Speaker 04:
I don't know the answer to that, Your Honor.

[00:20:21] Speaker 04:
My guess is that probably yes.

[00:20:22] Speaker 04:
I mean, we've all been called at various times to do things at the

[00:20:28] Speaker 04:
DOD says we have to do.

[00:20:30] Speaker 04:
But the vast majority of this pot of money, if you will, 12301D, the numerated statutory provisions that are in 101A13 and then 12301D, those really, if you take a half step back, they're just pots of money.

[00:20:42] Speaker 04:
Yes, there's different statutory authority under which those orders would be executed, but they're really just pots of money.

[00:20:47] Speaker 04:
And 12301D happens to be the biggest pot of money.

[00:20:49] Speaker 04:
That's how we get to

[00:20:51] Speaker 04:
The all-volunteer force, it incentivizes an all-volunteer force, I mean obviously it is an all-volunteer force, but it incentivizes people to continue to serve in the reserves and the guard where they can go on voluntary duty for whatever they need to do and still be assured of receiving this differential pay.

[00:21:07] Speaker 04:
I understood Your Honor's point very clearly that the post-enactment

[00:21:12] Speaker 04:
legislative intent isn't really legislative intent, but there's really not much dispute that the intent of 5538 was to provide differential pay to any reservist or guardsman or woman any time he or she is activated, with those exceptions that I pointed out earlier, DRIL, AT, and IDTs.

[00:21:30] Speaker 01:
Thank you, Mr. Lallem.

[00:21:33] Speaker 01:
You might sit down and change your opening a different notebook.

[00:21:41] Speaker 01:
Government council wants to change seats.

[00:21:43] Speaker 01:
They can, but needn't if they don't want.