[00:00:00] Speaker 02:
Our next case for argument is 24-1185, Larson versus HHS.

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

[00:00:06] Speaker 04:
John McHugh from 305 Broadway, New York, New York for Ms.

[00:00:12] Speaker 04:
Larson.

[00:00:14] Speaker 04:
This case is relatively simple.

[00:00:16] Speaker 04:
It's a matter of not reading the entire record and relying only on the doctors.

[00:00:23] Speaker 04:
The issue here is we have the doctor who was first diagnosed for having

[00:00:28] Speaker 04:
likely GBS, GM Baird Syndrome, in Wisconsin.

[00:00:37] Speaker 04:
He said that she had facial dysplasia.

[00:00:41] Speaker 04:
Facial dysplasia is essentially an inability to control the muscles of the face.

[00:00:46] Speaker 04:
They black tone them.

[00:00:49] Speaker 00:
And is it something that occurs intermittently?

[00:00:54] Speaker 00:
No.

[00:00:54] Speaker 00:
Is it a one-off, or is it kind of a permanent, ongoing thing?

[00:00:58] Speaker 00:
It's permanent.

[00:01:00] Speaker 04:
It stays there as long as the disease is going full force.

[00:01:04] Speaker 04:
It disappears after a while, and that's one of the problems.

[00:01:07] Speaker 04:
But here, we have the doctor who diagnosed it was

[00:01:11] Speaker 04:
didn't have the proper equipment to deal with a case of GBSDSA.

[00:01:15] Speaker 00:
No, but can you, I'm sorry, can I just get a more fulsome answer?

[00:01:18] Speaker 00:
So you say it disappears when the disease goes down.

[00:01:22] Speaker 00:
I mean, your client, in this case, has been going on for 10 years.

[00:01:26] Speaker 00:
Is this a, I don't want to go outside the record, but just understanding what the effects of this is.

[00:01:33] Speaker 00:
Does this last forever, as long as the client does have?

[00:01:37] Speaker 04:
The facial dysplasia,

[00:01:39] Speaker 04:
might be lasting forever.

[00:01:40] Speaker 04:
In her case, she says her smile is not the way it was.

[00:01:45] Speaker 04:
Her face doesn't look the same when she smiles.

[00:01:47] Speaker 04:
Otherwise, pretty much, it started in December, and it was pretty much gone by March.

[00:01:55] Speaker 04:
But when you look at it from the outside, her view is when she looks in the mirror, she doesn't look right.

[00:02:03] Speaker 04:
And that's continued.

[00:02:07] Speaker 04:
But in this case,

[00:02:08] Speaker 04:
We have the doctor diagnosed at SUT.

[00:02:11] Speaker 04:
He put her in an ambulance to go to a better hospital in Milwaukee because he didn't have the proper control, the proper equipment to control if she stopped breathing.

[00:02:20] Speaker 04:
So he had to get her to a respirator.

[00:02:23] Speaker 04:
The doctor who took over when she got to St.

[00:02:26] Speaker 04:
Luke's Hospital in Milwaukee didn't note the, he didn't see the spatial displacement.

[00:02:33] Speaker 02:
Well, can I ask, that's Dr. Ravichitran?

[00:02:37] Speaker 02:
I don't know if I'm saying his name right.

[00:02:39] Speaker 02:
Ravichitran?

[00:02:41] Speaker 04:
Yes.

[00:02:42] Speaker 04:
Ravichitran, yes.

[00:02:44] Speaker 04:
OK.

[00:02:44] Speaker 02:
Well, in any event, did he note an absence of facial dysplasia?

[00:02:51] Speaker 02:
Did he actually say, quote, no, plagia, whatever it is?

[00:02:56] Speaker 02:
I mean, the reason I ask is because the page in the record where supposedly

[00:03:00] Speaker 02:
That quote appears was not given to us in the appendix.

[00:03:03] Speaker 02:
And I couldn't get it online because it's confidential medical information.

[00:03:06] Speaker 02:
So I wasn't able to verify.

[00:03:08] Speaker 02:
Did he actually, what I'm trying to figure out is, did that doctor simply remain silent and not speak about facial dysplasia at all because he was focused on the respiratory symptoms?

[00:03:19] Speaker 02:
Or did he actually have a notation in the record, no facial dysplasia?

[00:03:24] Speaker 04:
Well, I must agree with you.

[00:03:25] Speaker 04:
I have not seen such a record.

[00:03:27] Speaker 04:
I've seen it referred to by the attorneys on the other side, but I have never seen it.

[00:03:33] Speaker 04:
And so I don't know.

[00:03:35] Speaker 04:
But I do know that I've seen him quoted as having given notes three times.

[00:03:42] Speaker 04:
Every day she was there.

[00:03:44] Speaker 04:
But the fact of the matter is, he's the doctor.

[00:03:48] Speaker 04:
He's a neurologist.

[00:03:49] Speaker 04:
He should know.

[00:03:50] Speaker 04:
But we have another source.

[00:03:52] Speaker 04:
We have the nurses.

[00:03:54] Speaker 04:
The nurses in the neurology department look at the patients every few hours and they take notes.

[00:04:00] Speaker 04:
And their note for the entire term that she was there was she had the symptoms of facial dysplasia, which is the inability to control the face.

[00:04:12] Speaker 04:
And also, she had an inability to feel.

[00:04:16] Speaker 04:
Her face was numb.

[00:04:18] Speaker 04:
And she also had a speech problem.

[00:04:21] Speaker 04:
And all those things are contained time and time again in the nurse's notes.

[00:04:27] Speaker 04:
So we have Dr. Pidgeon up in Lakeland Hospital saying she had it when it started.

[00:04:33] Speaker 04:
And he thought it was a serious emergency because she was deteriorating as she walked at that time.

[00:04:41] Speaker 04:
And that's why she was shipped off before anything else was done in Lakeland.

[00:04:48] Speaker 04:
But we have the nurse's notes.

[00:04:50] Speaker 04:
that are consistent, but it's still there.

[00:04:53] Speaker 02:
Can I ask you to look at appendix page 410?

[00:04:57] Speaker 02:
So appendix page 410, these are the intake notes

[00:05:20] Speaker 02:
from the hospital, and that's the doctor whose name I was having trouble pronouncing, Ravichandran.

[00:05:27] Speaker 02:
And at the top, you see there's what looks like a bait stamp, and it says page 78 of 101.

[00:05:34] Speaker 02:
Do you see that?

[00:05:36] Speaker 04:
Yes.

[00:05:37] Speaker 02:
OK.

[00:05:37] Speaker 02:
Well, the special master found that on page 77 of 101 is where this exact medical record

[00:05:48] Speaker 02:
has the quote, no plagia.

[00:05:51] Speaker 02:
So unfortunately, you see that's just not in our appendix.

[00:05:54] Speaker 02:
You see how it goes from page 400 on the one hand to 410 on the other.

[00:05:58] Speaker 04:
I see that, yes.

[00:06:00] Speaker 02:
So when you say you've never seen it or you've never had it, you have the record.

[00:06:04] Speaker 02:
You participated in putting this appendix together, correct?

[00:06:07] Speaker 02:
I did, yes.

[00:06:09] Speaker 02:
So does that mean you probably somewhere have the proceeding page?

[00:06:13] Speaker 04:
Oh, I absolutely would.

[00:06:16] Speaker 04:
Oh, OK.

[00:06:16] Speaker 02:
How about this?

[00:06:17] Speaker 02:
You say you never saw it.

[00:06:18] Speaker 02:
Do you dispute the special master's finding that on the proceeding page, not this page, the proceeding page, which is not in our appendix, but which you clearly must have, that that quote is present there?

[00:06:30] Speaker 04:
I've been dealing with that quote as being that he said he didn't see it.

[00:06:34] Speaker 02:
Do you agree that the quote is present on the medical record on the page preceding what was included there?

[00:06:39] Speaker 02:
That's right.

[00:06:40] Speaker 02:
OK, that's what I need to know.

[00:06:41] Speaker 04:
What I'm saying is that he was one witness

[00:06:44] Speaker 04:
But we have nurses who are recording her condition every few hours for the entire period she was in that hospital.

[00:06:51] Speaker 04:
And they record this facial problem.

[00:06:53] Speaker 04:
They don't call it facial dysplasia.

[00:06:55] Speaker 04:
They just give it the symptoms, which is the inability to control the face.

[00:06:59] Speaker 00:
And is it clear?

[00:07:00] Speaker 00:
Excuse my ignorance, because I don't have a medical degree.

[00:07:02] Speaker 00:
Is it clear that facial dysplasia is not anywhere near a symptom of fibromyalgia?

[00:07:11] Speaker 04:
That is very clear, because their experts said that.

[00:07:14] Speaker 04:
Our expert also said it, but he said it emphatically.

[00:07:18] Speaker 04:
No, no, no.

[00:07:21] Speaker 04:
So we have a situation where they relied on the doctor's notes.

[00:07:26] Speaker 04:
They didn't check with the nurses.

[00:07:28] Speaker 04:
And then when she gets back to Dr. Pidgeon a few days after she gets out of the hospital, she's still got it.

[00:07:34] Speaker 02:
And they were caught as... So, counsel, if I agree that the special master erred on that one fact finding, the fact finding was the transients.

[00:07:44] Speaker 02:
The fact that the special master didn't disagree with all of what you're saying about the doctor before, and all the nurses after noted it.

[00:07:52] Speaker 02:
The special master agreed with all that.

[00:07:54] Speaker 02:
But the special master then sided with the government's expert, Dr. Artinian, who said facial dysplasia is simply not transient in this way.

[00:08:04] Speaker 02:
And the special master ended up accepting that.

[00:08:06] Speaker 02:
So what you're saying is that that fact finding was not accurate.

[00:08:10] Speaker 04:
It was not accurate.

[00:08:12] Speaker 02:
But even if I agree with you, that finding is not accurate.

[00:08:15] Speaker 02:
The problem is that's not enough to get you to a reversal.

[00:08:18] Speaker 02:
Because the special master in this case found that was just one of three aspects of the clinical presentation.

[00:08:26] Speaker 02:
And each of those three aspects made it clear that she did not clinically present with GBS.

[00:08:34] Speaker 02:
He went through the other two aspects being, I think, her reflexes.

[00:08:39] Speaker 02:
and the monophastic nature of the disorder not being present.

[00:08:43] Speaker 02:
So the problem is there's still substantial evidence for his overall fact finding that the clinical presentation doesn't support GBS, even if you're right that she had consistent facial dysplasia.

[00:08:58] Speaker 02:
So I don't know what to do, because that doesn't get you to it.

[00:09:02] Speaker 02:
It's a fact in your favor, but I review the fact finding for substantial evidence.

[00:09:07] Speaker 02:
And there's all these other fact findings.

[00:09:09] Speaker 04:
Well, Special Master in her decision listed, if she has this, it should be very rare, because she has a lot of things that only appear in a few cases of GBS, not all of them.

[00:09:22] Speaker 04:
And nothing appears in all of them.

[00:09:25] Speaker 04:
She had a very strange, mild case of GBS.

[00:09:30] Speaker 04:
It rang all the bells, except it was inconsistent with what was normal.

[00:09:35] Speaker 04:
And we knew it was that.

[00:09:36] Speaker 04:
It is not normal.

[00:09:38] Speaker 04:
But it had all the symptoms, and she was badly crippled for a very long period of time.

[00:09:43] Speaker 04:
Because even though all the symptoms of the facial dysplasia disappeared by March, she had a relapse later on.

[00:09:51] Speaker 04:
And one of the symptoms that really- How did they disappear by March, though?

[00:09:56] Speaker 02:
Because she didn't have the infusions that are normally required in order to cause the GBS to abate.

[00:10:03] Speaker 04:
She went to St.

[00:10:04] Speaker 04:
Luke's.

[00:10:05] Speaker 04:
on the theory that she was about to stop breathing.

[00:10:08] Speaker 04:
Instead, basically, a lot of these symptoms had dampened way down.

[00:10:12] Speaker 04:
And so basically, they didn't do anything because they thought she basically was either misdiagnosed or cured.

[00:10:19] Speaker 04:
But at any rate, it didn't stop.

[00:10:22] Speaker 04:
It just kept going.

[00:10:23] Speaker 03:
Did you ever tell the special master your view was she had a, I think you described it as a mild

[00:10:29] Speaker 03:
unusual case of GBS?

[00:10:31] Speaker 03:
I may have missed that.

[00:10:33] Speaker 04:
Well, that was in there.

[00:10:34] Speaker 04:
Dr. Kingsborne said it was a mild case.

[00:10:37] Speaker 04:
He said it was a very mild case on onset.

[00:10:41] Speaker 04:
It wasn't mild on the balance.

[00:10:45] Speaker 03:
So essentially... Well, what are you telling us?

[00:10:47] Speaker 03:
Because it appears the special master found it wasn't GBS, but if it looked like GBS, it only even looked like GBS for a little bit of time.

[00:10:58] Speaker 04:
It did look like GBS for a little bit of time, an initiative that it came on like an express train.

[00:11:04] Speaker 04:
And then it just sort of, there was an ambulance ride and they were about an hour.

[00:11:09] Speaker 04:
And by the time she got out of the ambulance, she was greatly improved, apparently, according to her.

[00:11:14] Speaker 04:
But she didn't, she didn't lose all these symptoms for months.

[00:11:19] Speaker 04:
And so she was, she was unable to work for months.

[00:11:23] Speaker 04:
And it wasn't until the next year really that she, she got back to work.

[00:11:26] Speaker 02:
Should we save some of your time for rebuttal?

[00:11:28] Speaker 02:
I want you to have a chance to respond to whatever the government says.

[00:11:31] Speaker 02:
I certainly will.

[00:11:32] Speaker 02:
Thank you.

[00:11:55] Speaker 01:
Good morning.

[00:11:55] Speaker 01:
May it please the court?

[00:11:57] Speaker 01:
My name is Alex Sachs.

[00:11:58] Speaker 01:
I represent and respond in appellate secretary of health and human services in this matter.

[00:12:02] Speaker 01:
The special master correctly determined that Pishner failed to establish by preponderant evidence

[00:12:06] Speaker 01:
that she suffered from a claimed injury of Keown-Barrie syndrome, and that as a result she was not entitled to compensation under the Vaccine Act.

[00:12:13] Speaker 01:
Because petitioner was required to establish as a threshold matter that she suffered from the condition for which she sought compensation and failed to do so, the special master was now required to conduct a causation analysis under Alvin, and petitioner could not prevail on entitlement.

[00:12:26] Speaker 02:
So I guess one question I have for you.

[00:12:28] Speaker 02:
Facial dysplasia appears to be, according to all the experts, one of the key indications of GBS, especially early

[00:12:36] Speaker 02:
indications.

[00:12:37] Speaker 02:
Now, of course, there's other things, spinal tap, there's other things that can confirm whether it's GBS.

[00:12:41] Speaker 02:
But so she, it looks like she had the facial dysplasia.

[00:12:45] Speaker 02:
I mean, it's, it's throughout the record.

[00:12:48] Speaker 02:
So what, I mean, what are we doing when she had a vaccine, she then had facial dysplasia.

[00:12:54] Speaker 02:
I mean,

[00:12:55] Speaker 02:
You know, a bad back doesn't result in facial dysplasia, right?

[00:12:58] Speaker 02:
So something happened to this lady.

[00:13:00] Speaker 02:
Something happened.

[00:13:01] Speaker 02:
I mean, your face doesn't just get droopy and paralyzed overnight for no reason.

[00:13:05] Speaker 02:
At least, God, I hope not.

[00:13:07] Speaker 02:
So what do we do about that?

[00:13:09] Speaker 02:
What does the government do about that?

[00:13:10] Speaker 02:
What does the vaccine act do about this when somebody has a reaction that is temporally linked to the vaccine and is very serious?

[00:13:18] Speaker 01:
What happens?

[00:13:19] Speaker 01:
Well, just one point of correction.

[00:13:20] Speaker 01:
This is dysplasia.

[00:13:21] Speaker 01:
It's a little different from dysphasia.

[00:13:25] Speaker 01:
similar in that it's a paralysis or bilateral.

[00:13:28] Speaker 01:
You could characterize it as drooping of the face.

[00:13:30] Speaker 01:
But in any regard, the special master's finding was wholly possible that it was transient.

[00:13:36] Speaker 01:
She articulated rational reasons for why.

[00:13:38] Speaker 01:
That was the petitioner's outpatient doctor, the neurologist Dr. Pigeon, noted it on that day that he encouraged her to go to the ER.

[00:13:47] Speaker 01:
on December 27, 2013.

[00:13:50] Speaker 01:
Later that day though, as my colleague was discussing, the hospital's neurologist expressly noted the absence of that symptom.

[00:13:56] Speaker 01:
No plegea that same day.

[00:13:58] Speaker 02:
Was he a neurologist?

[00:14:00] Speaker 02:
He's a neurologist, Dr. Aria.

[00:14:03] Speaker 02:
We don't actually have that record.

[00:14:06] Speaker 02:
Have you seen that record?

[00:14:07] Speaker 01:
I've seen that record.

[00:14:07] Speaker 02:
And it really says that?

[00:14:08] Speaker 01:
It really says that, and he says it again in subsequent days.

[00:14:11] Speaker 02:
He didn't disuse it.

[00:14:12] Speaker 02:
So, dispute it.

[00:14:13] Speaker 02:
But ultimately, it wasn't in here, so I was struggling.

[00:14:16] Speaker 01:
Yeah, I understand.

[00:14:17] Speaker 01:
I apologize for that, Your Honor.

[00:14:19] Speaker 01:
And that is the rational basis in the record that gives rise to, again, this is not a wholly implausible determination by the special master.

[00:14:26] Speaker 01:
She notes that the symptom is

[00:14:27] Speaker 01:
noted by one doctor early in the day and then not the next day.

[00:14:31] Speaker 02:
And in addition to that, she credited the- Well, but noted by all the nurses over and over again.

[00:14:35] Speaker 01:
Well, the nurses do know facial weakness.

[00:14:37] Speaker 01:
Again, the special master considered all the evidence.

[00:14:41] Speaker 01:
She noted that.

[00:14:41] Speaker 01:
This court president presumes that the special master considered all the evidence, unless she expressly stated that she didn't.

[00:14:48] Speaker 01:
She did not weigh it as heavily.

[00:14:50] Speaker 01:
And that's a matter of fact finding.

[00:14:52] Speaker 01:
And obviously, as this court is aware, that's subject to the arbitrary and capricious standard of review.

[00:14:56] Speaker 01:
So the finding is, again.

[00:14:58] Speaker 02:
But even if I had a problem with that fact finding, as I explained to counsel on the other side, it's still very hard to get to a reversal because of all of the other fact findings just on the clinical presentation, not to mention the spinal fluid and the E, whatever the other thing.

[00:15:13] Speaker 01:
Yes, Your Honor.

[00:15:14] Speaker 01:
And it wasn't even really the critical of the one of three within the category of four other categories.

[00:15:19] Speaker 01:
of the clinical presentation.

[00:15:21] Speaker 01:
Again, there was the fact there were no absent or decreased reflexes, which is very pathogenic of GBS.

[00:15:27] Speaker 01:
The fact that she recovered without very standard, gold standard treatment, immunotherapies, IVIG, and plasmapheresis.

[00:15:36] Speaker 02:
It is unusual, though.

[00:15:37] Speaker 02:
I don't know.

[00:15:38] Speaker 02:
We don't usually get a case in the vaccine act space where the question is, did she or did she not actually have a condition?

[00:15:47] Speaker 02:
You know, the cases are more causation related.

[00:15:49] Speaker 02:
They're more about maybe damages even, but not about did the person have it.

[00:15:55] Speaker 02:
And it also seems really unusual when she actually did have three experts that testified that she did have it.

[00:16:01] Speaker 02:
That's really hard.

[00:16:03] Speaker 02:
I mean, I'm, I'm going to be honest, I'm surprised the special master came out the way she did.

[00:16:09] Speaker 02:
Very unusual.

[00:16:10] Speaker 02:
I've never seen a case where you have what is now a table injury.

[00:16:15] Speaker 02:
With certain criteria, I'm not sure.

[00:16:17] Speaker 02:
It wasn't at the time, but it is now.

[00:16:19] Speaker 02:
You have somebody that's presenting with some symptoms, and even the neurologist said high suspicion for GBS.

[00:16:26] Speaker 02:
That's what the neurologist said.

[00:16:27] Speaker 02:
He didn't rule it out.

[00:16:28] Speaker 01:
But he never confirmed it, Your Honor.

[00:16:30] Speaker 02:
He didn't confirm it, but he said high suspicion for GBS.

[00:16:34] Speaker 01:
And then later on, the subsequent neurologist who evaluated her determined that

[00:16:38] Speaker 01:
She didn't present with a clinical presentation or objective evidence of a GBS diagnosis.

[00:16:42] Speaker 01:
Exactly.

[00:16:42] Speaker 02:
She sat her down and said, I don't know how many hours I have to spend with this person.

[00:16:45] Speaker 02:
I'm telling her she doesn't have GBS.

[00:16:47] Speaker 02:
Like, I keep telling her she doesn't.

[00:16:49] Speaker 02:
No, I get it.

[00:16:49] Speaker 02:
The record has a lot in it.

[00:16:52] Speaker 02:
But I don't usually see cases where there's three experts saying the person has GBS.

[00:16:56] Speaker 02:
And the master concludes you.

[00:16:58] Speaker 01:
Well, we have a fair amount of cases in the vaccine program that actually go to diagnosis as a threshold issue.

[00:17:04] Speaker 01:
Obviously, that is a threshold issue before

[00:17:06] Speaker 01:
the often causation analysis.

[00:17:08] Speaker 01:
It's a petitioner's burden to establish that by pondered evidence prior to the analysis.

[00:17:13] Speaker 00:
Well, that's interesting to me that you do have quite a number of cases, because I don't think I've ever seen one on appeal.

[00:17:18] Speaker 00:
Do you have a sense that those don't get appealed to us?

[00:17:21] Speaker 00:
Is that also your sense?

[00:17:23] Speaker 01:
I don't want to give an incorrect answer.

[00:17:25] Speaker 01:
I think you're probably right, Your Honor,

[00:17:27] Speaker 01:
appealed less often.

[00:17:29] Speaker 01:
But there have been appeals on the issue of diagnosis and whether it's established.

[00:17:33] Speaker 01:
I mean, the precedent that we have, it's been a while, but Brokawshin, Lombardi, Hibbard all established this line of cases of a particular inability to meet her burden or his burden of establishing a diagnosis and how that is a prerequisite for the causation analysis.

[00:17:49] Speaker 00:
What does the table have?

[00:17:51] Speaker 00:
I haven't seen it in a long time.

[00:17:52] Speaker 00:
It's got the diagnosis, and then it's got usually the time for onset.

[00:17:56] Speaker 01:
The time frame for onset for GBS, it's 0 to 42 days.

[00:17:59] Speaker 00:
And then is there a third category?

[00:18:02] Speaker 01:
I should know.

[00:18:03] Speaker 01:
There are various clinical aspects of it that must be met, but not off the top of my head.

[00:18:14] Speaker 02:
Anything further?

[00:18:14] Speaker 01:
I have nothing further.

[00:18:17] Speaker 01:
Court affirmed the decision of the special master in the court of federal claims.

[00:18:20] Speaker 01:
Thank you.

[00:18:34] Speaker 04:
You're actually right.

[00:18:35] Speaker 04:
She got a vaccine.

[00:18:37] Speaker 04:
She had a reaction to it.

[00:18:38] Speaker 04:
As the table would dictate for GBS with the backache, it can't be nothing.

[00:18:44] Speaker 04:
statute forbids an idiopathic cause of something like this.

[00:18:49] Speaker 04:
It fits all the criteria for GBS.

[00:18:52] Speaker 04:
It was diagnosed several times as GBS.

[00:18:54] Speaker 04:
Everybody attributed to the vaccine except for their expert.

[00:18:57] Speaker 04:
And it can't be nothing.

[00:19:00] Speaker 04:
The statute doesn't allow an idiopathic or non-clause, something out of space.

[00:19:06] Speaker 04:
And that's all we do.

[00:19:08] Speaker 04:
We all have the same problem.

[00:19:09] Speaker 04:
This is a very unusual case.

[00:19:11] Speaker 04:
That's why it's here.

[00:19:14] Speaker 04:
Three experts, you're absolutely right.

[00:19:16] Speaker 04:
Three experts said something happened here.

[00:19:18] Speaker 04:
And they thought it was that.

[00:19:20] Speaker 04:
And we can't go to zero.

[00:19:23] Speaker 04:
So I think that even though there may be questions about the diagnosis, there is a diagnosis.

[00:19:29] Speaker 04:
And there may be things that don't fit.

[00:19:33] Speaker 04:
But we have a vaccine.

[00:19:34] Speaker 04:
We have an injury.

[00:19:35] Speaker 04:
The timing is right.

[00:19:37] Speaker 04:
And the injury is one that is basically in the table.

[00:19:43] Speaker 04:
And I thank you very much.

[00:19:44] Speaker 02:
Okay, thank both counsels.

[00:19:46] Speaker 02:
Case is taken under submission.