[00:00:00] Speaker 03:
The next case is Benito Chavez versus the Secretary of Veterans Affairs, 2022-1942.

[00:00:07] Speaker 03:
Mr. Leah.

[00:00:11] Speaker 01:
Your Honor, may it please the Court.

[00:00:16] Speaker 01:
My name is Sean Raven.

[00:00:17] Speaker 01:
I represent Mr. Benito Chavez and his appeal from the Veterans Court.

[00:00:23] Speaker 01:
The issue presented by this appeal is whether reversal is required when the board fails to support its decision that a rating reduction was proper and made in accordance with law.

[00:00:35] Speaker 01:
As the Veterans Court held in its decision on its appendix, appendix 6 and 7, and has acknowledged, the Secretary bears the burden of establishing by the remembrance of the evidence that rating reduction was warranted.

[00:00:49] Speaker 03:
Council, I'm looking at appendix 8.

[00:00:52] Speaker 01:
It's Appendix 6, Your Honor, on the bottom of Appendix 6.

[00:00:55] Speaker 03:
The court agrees with Mr. Chavez that it's unclear whether the board relied on evidence developed, et cetera.

[00:01:06] Speaker 03:
And the court finds the board uses an inadequate and that remand is required.

[00:01:14] Speaker 01:
if you're out of it i think that's a personal question this case fits under the williams criteria the wings exception for jurisdiction because first off if the the issue is whether or not

[00:01:31] Speaker 01:
Inadequate reasons or bases require reversal rather than remand.

[00:01:36] Speaker 01:
If this court were to decide and reverse the Veterans Court that reversal is required, then the remand is unnecessary.

[00:01:43] Speaker 01:
And actually, it has a change in law.

[00:01:46] Speaker 01:
And actually, the issue is on appendix page 6, where the Veterans Court at the bottom of that page acknowledges that the burden of proof is on the secretary to prove that a rating reduction was proper.

[00:02:01] Speaker 01:
And on the last sentence, it says, this reflects the general rule that reinstatement of a pre-reduction rating is warranted when the reduction was made but the law not observed.

[00:02:09] Speaker 01:
Now, the next sentence is key.

[00:02:11] Speaker 01:
And that says, that said, reversal and reinstatement are not appropriate when the board erred only in failing to provide adequate reasons or basis for its decision on the propriety of reduction.

[00:02:21] Speaker 01:
And the court cites defoust.

[00:02:23] Speaker 01:
Payton and Payton and a host of other cases for the proposition that inadequate reasons are basis in a rating reduction case Require remand rather than reversal, but we know that's not true because the Veterans Court later issued is its decision in Sterns Can we that sounds like the merits can we focus on whether we have jurisdiction first it seems like if I'm following you correctly I

[00:02:50] Speaker 02:
every veteran who gets a remand from the veterans court could give us an appellate jurisdiction if they simply state that the question they want reviewed is whether remand was permissible as opposed to reversal being required.

[00:03:09] Speaker 02:
That's the question you're asking us to review in this case and it seems to me every veteran who gets a remand order could ask the same question.

[00:03:17] Speaker 02:
Is that right?

[00:03:18] Speaker 01:
Not exactly, because this only applies to rating reduction cases.

[00:03:22] Speaker 01:
That's the exception.

[00:03:24] Speaker 01:
And I'm trying to make it specific to rating reduction cases, not in every case where remand is warranted.

[00:03:31] Speaker 02:
Well, then at minimum, you're conceding that every rate reduction case where there is a remand order

[00:03:40] Speaker 02:
is we will have to treat that as a final order if the veteran wants us to review simply the question of whether a reversal was mandated.

[00:03:50] Speaker 01:
I think the jurisdictional question is right.

[00:03:52] Speaker 01:
But I also think that specifically as it applies to this case, if the court doesn't have jurisdiction, it would never reach the issue of whether or not remand is the appropriate remedy.

[00:04:04] Speaker 04:
Your position, as I understand it, is that if there has been a procedural flaw,

[00:04:10] Speaker 04:
before the board, and the remedy in the Court of Appeals for Veterans Claims is that it must reverse and render, not that it may remand, at least in this category of cases.

[00:04:26] Speaker 01:
That's correct.

[00:04:27] Speaker 04:
So you're saying that if you're right on that, because I understand your position, then for us not to address that question,

[00:04:38] Speaker 04:
would mean that your legal position would never get reviewed.

[00:04:42] Speaker 01:
That's correct.

[00:04:43] Speaker 04:
Is that essentially your position?

[00:04:47] Speaker 02:
That's correct.

[00:04:48] Speaker 02:
Yes.

[00:04:49] Speaker 02:
Are there ratings decisions that the Veterans Court reaches where it has discretion whether to reverse or to remand or to all ratings decisions appeals that the Veterans Court fall into a category of either they must reverse or I guess affirm?

[00:05:06] Speaker 01:
No, the veteran's court's jurisdiction is to set aside or to reverse.

[00:05:13] Speaker 01:
And when it's evaluating, for example, finding a fact on a disability, if it finds that there's clear error, it may reverse.

[00:05:23] Speaker 01:
It's discretionary.

[00:05:23] Speaker 01:
It may reverse, but it also may remand if the record's incomplete.

[00:05:30] Speaker 02:
And in that situation, could the veteran take a deal to us?

[00:05:36] Speaker 01:
if they if they may reverse or they may remand and they choose to remand is that a final order for us uh... only only with the exception only exception if reversal the denial of reversal would have had an effect upon the proceedings below

[00:05:55] Speaker 01:
So in general, and this is the exception, this is why the general rule is that remands should not be, the court doesn't have jurisdiction over cases that are remanded, they're non-final decisions.

[00:06:07] Speaker 01:
But in this matter, for this specific case, for a rating reduction case of this category,

[00:06:12] Speaker 01:
If the board fails to support its conclusion that a rating reduction decision was made in accordance with law, reversal is the only remedy.

[00:06:26] Speaker 01:
The rating reduction is void ab initio.

[00:06:30] Speaker 01:
It's akin to a criminal trial where a defendant is acquitted.

[00:06:36] Speaker 01:
And on appeal, the prosecution argues that their own mistake caused a problem with the procedures.

[00:06:41] Speaker 01:
and a higher tribunal reverses and orders a new trial.

[00:06:47] Speaker 01:
In this case, and that's the analogy I think about this, the secretary has the burden of proof and persuasion.

[00:06:54] Speaker 01:
I realize I'm getting at the merits rather than jurisdiction.

[00:06:56] Speaker 01:
Thanks.

[00:06:57] Speaker 04:
Hi.

[00:06:58] Speaker 04:
Well, to follow up on Judge Stark's question, suppose that somebody in a case other than a reduction case came in and said,

[00:07:09] Speaker 04:
the Veterans Court remands in many cases.

[00:07:12] Speaker 04:
It's a very common procedure in a variety of states.

[00:07:16] Speaker 04:
However, I think that that process is just dead wrong.

[00:07:20] Speaker 04:
And I believe, as a matter of section, no, it's a silly argument.

[00:07:23] Speaker 04:
We can all agree to that.

[00:07:24] Speaker 04:
But if they made that argument, came in here and said, I have a legal right any time the board makes an error that would otherwise require a remand to a disposition in my favor from the Court of Appeals for Veterans Claims, and made that argument,

[00:07:39] Speaker 04:
we would have jurisdiction as I understand your argument in order to address that argument.

[00:07:44] Speaker 04:
Even though we would.

[00:07:46] Speaker 01:
No.

[00:07:47] Speaker 01:
I would concede you wouldn't have jurisdiction if it's optional to remand or reverse.

[00:07:51] Speaker 01:
What I'm saying is in the category rating reduction cases, which is very specific because rating reduction cases are the only types of cases where the secretary has the burden of proof, not the appellant, not the claimant, not the veteran.

[00:08:03] Speaker 01:
In rating reduction cases, the secretary has the burden of proof and persuasion that a rating reduction is proper and in accordance with law.

[00:08:12] Speaker 04:
I understand that.

[00:08:12] Speaker 04:
But if someone came up,

[00:08:14] Speaker 04:
I insist that the law requires an actual rendering in my client's favor.

[00:08:26] Speaker 04:
We would have jurisdiction, as I understand what you're saying, to address that question.

[00:08:32] Speaker 01:
No, I don't think that you would have jurisdiction.

[00:08:34] Speaker 01:
There's no Williams exception.

[00:08:36] Speaker 01:
And what I'm trying to point out is that there is a Williams exception for these cases.

[00:08:40] Speaker 01:
But I agree with you.

[00:08:41] Speaker 01:
And generally, in cases where the Veterans Court can either remand or reverse, and there's a remand, then it's a non-final decision.

[00:08:49] Speaker 01:
And this court lacks jurisdiction.

[00:08:51] Speaker 01:
But this is not the case that's before you.

[00:08:53] Speaker 01:
The case before you is very distinct.

[00:08:56] Speaker 02:
and concerned to about the merits of we reach the merits uh... i don't see any indication that the veterans court was passing on the sufficiency of the evidence here is showing uh... that the secretary made they seem very clearly just a second used we can't do our judicial review let's get a better explanation what's wrong with that reading of their opinion the secretary has

[00:09:23] Speaker 01:
the burden of proof of persuasion to prove that a rating reduction was made in accordance with law.

[00:09:30] Speaker 01:
When the board fails to support its conclusion that a rating reduction was made in accordance with law, that's it.

[00:09:38] Speaker 01:
the rating reduction is void ab initio it has to be reinstated that's all true but where do you see the veterans court saying that that the the secretary failed to do that in the court's decision the court said we cannot we cannot decide because it's apparent that the board

[00:09:57] Speaker 01:
considered evidence which was developed after the rating reduction, which is a violation of 38 CFR 3.340e and 3.343.

[00:10:08] Speaker 02:
Are you saying there's no proper purpose for considering that later arising evidence?

[00:10:15] Speaker 02:
I thought the point here was there are some proper uses and some improper uses and the Veterans Court couldn't tell which side of that line

[00:10:22] Speaker 01:
No, that would be a misinterpretation of 3.304e.

[00:10:25] Speaker 01:
3.304e specifically says that rating reductions are based on the record.

[00:10:32] Speaker 01:
I could read it to you.

[00:10:33] Speaker 01:
I mean... You don't need to use your time to do that.

[00:10:37] Speaker 01:
Okay.

[00:10:38] Speaker 01:
I see my time has expired.

[00:10:41] Speaker 03:
Well, if you were coming upon, you could continue or save it, as you wish.

[00:10:45] Speaker 01:
I'll save it.

[00:10:56] Speaker 00:
Thank you, Your Honors.

[00:10:57] Speaker 00:
May it please the Court.

[00:10:59] Speaker 00:
The Court lacks jurisdiction over this appeal because this is a challenge to a remand decision, and the Williams exception does not apply here.

[00:11:07] Speaker 00:
This Court has had many, many opportunities to evaluate cases like this where the decision being challenged is the remand itself.

[00:11:13] Speaker 04:
Why isn't this a lot like that?

[00:11:16] Speaker 00:
Oh, Your Honor, I think it is different than Adams and Stevens, which Your Honor participated in those panels.

[00:11:24] Speaker 00:
And I would direct the court to the language, in Stevens in particular, at page 817.

[00:11:30] Speaker 00:
where the court summarized that in both Adams and Stevens, there was an allegation, at least made in the appeal, that the remand was provided for a prohibited purpose.

[00:11:40] Speaker 04:
Right.

[00:11:40] Speaker 04:
And that's exactly the position Mr. Reynolds is taking here, saying that there is not permitted, that CABC is not permitted to remand under the circumstances of this case.

[00:11:53] Speaker 04:
Now, he may be wrong.

[00:11:54] Speaker 04:
But why isn't that an argument he's entitled to make to this court, and which, if he's not entitled to make to this court, he can't ever raise?

[00:12:04] Speaker 00:
So Your Honor, we're relying on the language of Stevens in particular, which explained what the kind of prohibited purpose might be, which is giving the board a second opportunity to potentially rehabilitate its decision in a way that the Court of Appeals or Veterans' Plan found was flawed.

[00:12:19] Speaker 00:
And that is not the situation that we have here.

[00:12:23] Speaker 00:
And we're also relying on some of the further summaries provided in Ebel and in Deloach later on in this course, jurisprudence on this area, and separating that line between has the Veterans Court made a decision about its authority to remand, that it's required or prohibited, or that it's directing the board to do something impermissible.

[00:12:43] Speaker 04:
Let's assume that Mr. Redmond's legal argument is correct.

[00:12:48] Speaker 04:
that the CDC may not remand under circumstances in which they're not satisfied that the process before the board was proper, but they are not sure whether it was impartial.

[00:13:03] Speaker 00:
That's where you are.

[00:13:04] Speaker 00:
I understand your honest question.

[00:13:06] Speaker 04:
When, if we dismiss, when can Mr. Reagan ever get review of that legal issue?

[00:13:14] Speaker 04:
Or is it just not reviewable?

[00:13:16] Speaker 00:
And Your Honor, I think the issue I take is that he is misreading what the Veterans Court said.

[00:13:21] Speaker 00:
I think under Your Honor's hypothetical, if the Veterans Court had said the evidence was insufficient and so we're going to remand to evaluate further.

[00:13:30] Speaker 04:
Let's assume that he's correctly reading the CABC's opinion to say exactly the way I characterize it, to say that they're sending it back

[00:13:45] Speaker 04:
because it's unclear what the board was relying on.

[00:13:50] Speaker 04:
And he's coming in here and saying, that's contrary to law.

[00:13:54] Speaker 04:
You can't do that, CABC.

[00:13:56] Speaker 04:
When can you get review, in your view, of that legal question?

[00:14:01] Speaker 00:
I think if the court interprets his position here to be how your honor described it, the court would have jurisdiction over that question.

[00:14:07] Speaker 00:
I don't understand him to be saying that here before this court today.

[00:14:11] Speaker 04:
You don't understand him to be saying that the CABC

[00:14:15] Speaker 04:
heard by sending this case back to the board for clarification, and that that's not permitted?

[00:14:23] Speaker 00:
That's not my understanding of his argument.

[00:14:24] Speaker 00:
My understanding of his argument, Your Honor, is that the Veterans Court held the board erred by having an inadequate basis for its decision.

[00:14:32] Speaker 00:
That's the way he explained it in his briefing.

[00:14:34] Speaker 00:
And I think as Mr. Raven explained at the podium here,

[00:14:37] Speaker 00:
The problem as he sees that is if there's inadequate evidence then the secretary has failed to meet their burden and then there is this principle that the Veterans Court has established that potentially the underlying decision is void of an issue.

[00:14:57] Speaker 04:
Court heard because reversal is warranted when VA does not observe regulatory procedures for rating reductions.

[00:15:04] Speaker 04:
He is saying that in this case, there was a procedural flaw in what the board did.

[00:15:10] Speaker 04:
And therefore, his argument is, the CABC cannot remand.

[00:15:15] Speaker 04:
And you're saying under facts like that, we wouldn't have jurisdiction?

[00:15:22] Speaker 00:
So Your Honor, the way I understand his argument, including on page 14, is that the error that the board made.

[00:15:27] Speaker 00:
was that it failed to identify sufficient evidence to support the rating reduction.

[00:15:33] Speaker 00:
It failed to explain what was the evidence that supported the rating reduction.

[00:15:37] Speaker 00:
And that is not what the Court of Appeals for Veterans Claim held.

[00:15:40] Speaker 00:
The Court of Appeals for Veterans Claim said there was ample evidence that might have supported this.

[00:15:46] Speaker 00:
In some cases, the problem may have been there was too much evidence cited in the record.

[00:15:49] Speaker 00:
The problem for the Veterans Court was that it could not permissively review

[00:15:55] Speaker 00:
the argument he was making on that point because the decision itself was not exactly clear about which of the evidence the board was relying on or which it was just discussing.

[00:16:05] Speaker 04:
I understand what you said a moment ago.

[00:16:08] Speaker 04:
If we interpret his argument as being if there's a procedural flaw in what happened before the board, the CABC cannot be banned.

[00:16:17] Speaker 04:
If that's his argument,

[00:16:18] Speaker 04:
in whole or in part, that we can hear it.

[00:16:21] Speaker 00:
I would agree with that, Your Honor.

[00:16:23] Speaker 00:
If that is his argument, then I would agree that this Court has jurisdiction to consider it.

[00:16:27] Speaker 00:
I just do not agree that that is what Mr. Chavez is presenting to this Court.

[00:16:31] Speaker 02:
I appreciate that.

[00:16:32] Speaker 02:
That clarification is helpful for me, too.

[00:16:34] Speaker 02:
What do you make of, at page eight, the Veterans Court says remand is required.

[00:16:41] Speaker 02:
Are they saying we, under the circumstances we find here,

[00:16:46] Speaker 02:
We're required.

[00:16:47] Speaker 02:
We have no discretion but to remand.

[00:16:49] Speaker 00:
I do not agree that that is what the Veterans Court is saying there.

[00:16:53] Speaker 00:
I think both this court and the Supreme Court have said multiple times we don't necessarily parse judicial decisions the same way we do statutes word by word, line by line.

[00:17:01] Speaker 00:
We have to read it holistically.

[00:17:03] Speaker 00:
And as I read pages appendix seven and appendix eight together,

[00:17:07] Speaker 00:
What the Veterans Court is saying is that there is a multitude of evidence that the board reviewed and considered.

[00:17:13] Speaker 00:
The board cited all of it in its evaluation as to whether Mr. Chavez's condition improved.

[00:17:18] Speaker 00:
Mr. Chavez has made the argument that it was improper to consider evidence predating the reduction proposal in 2008.

[00:17:26] Speaker 00:
The way the board discussed the evidence, it's unclear whether it was in fact relying on evidence post-stating that or simply discussing it and acknowledging its existence.

[00:17:35] Speaker 00:
And without that parsing of the evidence by the board, the Veterans Court simply did not have a decision and a record that would permit it to evaluate the legal arguments he was presenting.

[00:17:45] Speaker 00:
And so in that circumstance, the appropriate remedy was to remand.

[00:17:49] Speaker 02:
Did they have the discretion to reverse under those circumstances?

[00:17:53] Speaker 00:
So Your Honor, I agree with what Mr. Robbins said that the Veterans Court recently explained in Stern that there are a multitude of situations where remand might be required or reversal, or I'm sorry, reversal might be required.

[00:18:07] Speaker 00:
What the Stern decision said, though, is that it tends to be very fact specific.

[00:18:10] Speaker 00:
You have to consider the particulars of the claim, the particulars of the board decision, in order to decide whether this threshold showing that the Secretary does have the burden to make has been met or whether it is defective.

[00:18:22] Speaker 00:
Now it's possible, very likely, that once the board clarifies the scope of the evidence it's relying on, the Veterans Court will address that issue with respect to Mr. Chavez.

[00:18:32] Speaker 00:
And in light of the Stern decision, it just hasn't reached that point yet.

[00:18:35] Speaker 00:
And so to that point, whether the court exercises jurisdiction or not, our position is that remit is perfectly appropriate in this case because

[00:18:42] Speaker 00:
As the court itself expressly states at the bottom of appendix eight, the court is declining to address any of the legal arguments here that Mr. Chavez presented to it.

[00:18:53] Speaker 00:
What the court is saying is that

[00:18:55] Speaker 00:
There is evidence in the record that spans this dividing line Mr. Chavez contends is relevant.

[00:19:01] Speaker 00:
It's unclear how the board was treating the evidence on either side of that line.

[00:19:05] Speaker 00:
And so in order to properly address his argument, the court didn't even necessarily accept his argument that it is per se impermissible to consider post-proposal reduction evidence, in part because Mr. Chavez himself presented such evidence to the board and asked that it be considered.

[00:19:21] Speaker 00:
So without knowing how the board was treating that evidence, was it considering the post-reduction evidence as relevant, or was it simply acknowledging and rebutting his submission, explaining that, yes, you have presented evidence that post-stated the record, but we don't believe it changes our analysis, because it also shows evidence of improvement.

[00:19:40] Speaker 00:
It's just not clear from the board's decision how it was treating that information.

[00:19:45] Speaker 03:
Counsel, which of the three Williams exceptions are not met here?

[00:19:51] Speaker 00:
Your Honor, our argument is it's the first factor, that the Veterans Court has not made a final decision on any legal issue that provides this court with jurisdiction.

[00:20:00] Speaker 00:
We acknowledge in this long line of precedent that this court has stated, generally speaking, when a remand order itself is challenged, if there is a legal decision within that remand order that this court has jurisdiction to consider, then the second and third Williams Factors are ordinarily present, and we have not addressed those in our briefing.

[00:20:18] Speaker 00:
We focused exclusively on the first factor.

[00:20:24] Speaker 00:
So Your Honors, unless there are any other questions, we'll ask the court either reverse or man.

[00:20:27] Speaker 00:
I'm sorry.

[00:20:28] Speaker 00:
Dismiss or reverse.

[00:20:30] Speaker 03:
Thank you, counsel.

[00:20:31] Speaker 00:
Thank you.

[00:20:33] Speaker 03:
Mr. Raven has some proposals on it.

[00:20:35] Speaker ?:
Thank you.

[00:20:44] Speaker 01:
I apologize, the court, but I had miscited the regulation.

[00:20:48] Speaker 01:
It's 38 CFR, 3.105,

[00:20:53] Speaker 01:
I2, which talks about the record, about the evidence of the rating reduction must be based on the evidence of record before the rating reduction decision or after any new evidence is submitted after a rating reduction hearing.

[00:21:08] Speaker 01:
With regards to what counsel for the secretary has just said, the Veterans Court did recently issue its decision in Stern

[00:21:20] Speaker 01:
And in Stern, it held that, sorry, it held specifically that they were concluding as a matter of law that reversal was required when the board provided no reasons or bases.

[00:21:35] Speaker 01:
And it's on Stern page 59, 34 of that app at 59, and on reading from page 287 in the joint appendix.

[00:21:43] Speaker 01:
And in the middle of the page, although the court's reversal case law has generally been limited to the circumstances discussed above, the court now concludes that the board's failure entirely to address as required by Brown, whether an improvement in the disability reflects an improvement in the ability to function under the conditions of life and work, also requires a reversal of a rating deduction as a conclusion of law.

[00:22:05] Speaker 01:
If this court dismisses for lack of jurisdiction, this issue will never be addressed by the Federal Circuit.

[00:22:12] Speaker 01:
On remand back to the board, the board will simply delete from its decision any references to post-decision evidence and be issuing a new decision, which will then be subject to review by the court.

[00:22:25] Speaker 01:
But then that issue will now disappear.

[00:22:29] Speaker 04:
So in his argument, Mr. Minister said he did not understand

[00:22:35] Speaker 04:
your argument to be what I characterized as at least part of your argument.

[00:22:42] Speaker 04:
You recall me interchanging and exchanging.

[00:22:46] Speaker 04:
Was I mischaracterizing your argument at least in part?

[00:22:50] Speaker 01:
No, you were not mischaracterizing my argument.

[00:22:52] Speaker 01:
You were spot on.

[00:22:56] Speaker 01:
If this court dismisses for lack of jurisdiction, the issue will never reach this level, will never reach the appellate court, because this court will never have jurisdiction over the question whether or not reversal is appropriate.

[00:23:07] Speaker 03:
Well, we're not interested in issues and questions.

[00:23:09] Speaker 03:
We're interested in cases, petitioners, appellates of a case who want to win or lose.

[00:23:20] Speaker 03:
They're not interested in issues per se.

[00:23:24] Speaker 01:
OK.

[00:23:25] Speaker 01:
On remand back to the board, the board will simply rewrite its decision, take out the offending sections.

[00:23:32] Speaker 01:
But that's not what the law is about.

[00:23:34] Speaker 01:
They have one chance under the burden of proof to get it right.

[00:23:38] Speaker 01:
When they get it wrong, as a consequence, the rating reduction is voided.

[00:23:43] Speaker 01:
And the pre-reduction rating has to be reinstated.

[00:23:46] Speaker 01:
If they wish to reduce the rating, they have to start over and follow the regulations.

[00:23:50] Speaker 01:
They can't get another chance at that every time they make a mistake.

[00:23:55] Speaker 04:
And when you say get it wrong, you mean not do everything according to the right procedures that lead them to conclude that the rating reduction is justified.

[00:24:10] Speaker 01:
Correct.

[00:24:10] Speaker 01:
When the rating reduction is not made in accordance with law, they have to reinstate the rating.

[00:24:15] Speaker 01:
They can't remand it for a new decision.

[00:24:19] Speaker 01:
When the veteran's rating is reduced, they get a reduction in benefits.

[00:24:23] Speaker 01:
That means that they lose monthly benefits and the monthly amount that they get.

[00:24:27] Speaker 01:
When a rating reduction is found to be void, that rating reduction is voided, and their pre-reduction rating is restored.

[00:24:35] Speaker 01:
And they get paid all the money and all the benefits that they were supposed to get from the invalid rating reduction.

[00:24:43] Speaker 01:
I don't have anything further, but I would just ask, Your Honor, to just reverse the Veterans Court.

[00:24:49] Speaker 01:
Thank you very much.

[00:24:50] Speaker 03:
Thank you.