[00:00:00] Speaker 01:
The next case for argument is 24-2149, Morgan v. Collins.

[00:00:09] Speaker 01:
We're ready whenever you are, if you want to get settled.

[00:00:11] Speaker 01:
Everybody settled?

[00:00:13] Speaker 01:
OK, proceed, Mr. Jones.

[00:00:17] Speaker 04:
May it please the court?

[00:00:19] Speaker 04:
I represent Mr. Morgan here.

[00:00:23] Speaker 04:
And what we have here is a clear and unmistakable error claim.

[00:00:29] Speaker 04:
that we filed from a 1986 board decision.

[00:00:34] Speaker 04:
And essentially, the error was that the veteran in 1981 had filed a claim for arthritis in both of his joints, claiming it was secondary to a service-connected co-ceomidosis.

[00:00:49] Speaker 04:
A C&P exam was done at the time.

[00:00:52] Speaker 04:
They confirmed that the veteran had arthritis.

[00:00:55] Speaker 04:
And in the veteran's history, he said that his arthritis began

[00:00:59] Speaker 04:
1967, which would be whenever he would be in the service.

[00:01:05] Speaker 04:
The regional office denied the claim.

[00:01:07] Speaker 01:
He thought.

[00:01:07] Speaker 01:
I appreciate that.

[00:01:08] Speaker 01:
But trust me, we've read the briefs.

[00:01:10] Speaker 01:
So let me just ask you.

[00:01:12] Speaker 01:
As you know, we have a limited standard of review.

[00:01:16] Speaker 01:
What are the legal standards?

[00:01:17] Speaker 01:
issues you're raising in this case.

[00:01:19] Speaker 01:
OK.

[00:01:20] Speaker 04:
Yes.

[00:01:20] Speaker 04:
Yes.

[00:01:21] Speaker 04:
What we're talking about here is there's this line of cases that we cited in our brief.

[00:01:32] Speaker 04:
essentially gets down to whether or not a more sympathetic reading would be required.

[00:01:37] Speaker 04:
Because in the cases that we cited in our briefs, say like in the Moody case that we cited, which is a case from this court in 2003, what the court had said was that when you have a pro se veteran like this veteran here, and when there was a question about whether or not he raised a claim or not,

[00:01:59] Speaker 04:
The court said a sympathetic reading would be required, and that would be even applicable in the context of even clear and unmistakable error claims.

[00:02:07] Speaker 04:
And there was also a subsequent case.

[00:02:14] Speaker 04:
I think it's Richardson, where they applied the same standard the Court of Appeals Veterans claims.

[00:02:19] Speaker 01:
I mean, we have cases, and you refer to them, I think, that our cases say there has to be undebatable error, right?

[00:02:26] Speaker 01:
nor do we establish a CUE.

[00:02:29] Speaker 01:
So are you suggesting that our case law is different, or are you suggesting that you're just looking for the definition of undebatable?

[00:02:39] Speaker 01:
You're accepting the standard of undebatable, but you're just saying the gloss on that undebatable has to be sympathetic.

[00:02:48] Speaker 04:
I think it's some of both.

[00:02:52] Speaker 04:
I think that number one is that

[00:02:57] Speaker 04:
There are probably reasons as to why a little bit more sympathetic reading should be granted considering one, Beverly versus Nicholson also seems to apply more sympathetic reading is required when you involve legal theories of service connection.

[00:03:19] Speaker 04:
And in this particular case is a little bit unique because of

[00:03:26] Speaker 04:
Because of the fact this was a claim, a legal theory that was not raised up by the veteran, the evidence from the C&P exam raised up a question of whether or not the veteran should be considered to be presumptively service-connected.

[00:03:42] Speaker 04:
Because under 3.309 and 3.307, arthritis is one of those chronic conditions that if it either began in service or within one year of service, there's then a presumption that it

[00:03:56] Speaker 04:
that it's related to service.

[00:03:58] Speaker 04:
And that was the basis of our error.

[00:04:01] Speaker 04:
Problem is, in this particular case, the veteran didn't even raise that at all.

[00:04:05] Speaker 04:
It was just the board, in 1986, said there is no objective medical evidence, which, of course, as we outlined in our briefing.

[00:04:14] Speaker 03:
You may have already answered this question.

[00:04:15] Speaker 03:
I'm responding to Judge Pearls.

[00:04:16] Speaker 03:
But I'm not sure if I caught the answer.

[00:04:18] Speaker 03:
So let me just ask this.

[00:04:21] Speaker 03:
Do you agree?

[00:04:23] Speaker 03:
that there needed to be a showing of undebatable error or do you disagree with that?

[00:04:28] Speaker 03:
I'm sorry, I didn't quite get that.

[00:04:30] Speaker 03:
Yes.

[00:04:30] Speaker 03:
Do you agree that there would need to be a showing of undebatable error or do you disagree with that statement?

[00:04:36] Speaker 04:
Do I agree about whether or not there was an undebatable error?

[00:04:40] Speaker 03:
That there would be a showing required of undebatable error.

[00:04:43] Speaker 03:
Do you agree with that or do you disagree?

[00:04:47] Speaker 04:
I think it depends upon whether or not how you define what is undebatable.

[00:04:54] Speaker 04:
And particularly because I had this particular, and I was going to talk about this particular case.

[00:05:00] Speaker 04:
There's a case called Baker v. McDonough, which was raised up.

[00:05:04] Speaker 04:
The last Q argument that I had, the docket number was 2023-1972.

[00:05:08] Speaker 04:
That decision was dated December 19, 2024.

[00:05:13] Speaker 03:
So are you saying that a sympathetic reading is required instead of an undebatable error?

[00:05:18] Speaker 03:
Or do you also think an undebatable error is required?

[00:05:21] Speaker 03:
I'm just trying to parse that out.

[00:05:23] Speaker 04:
OK.

[00:05:26] Speaker 04:
I think a more sympathetic reading is required.

[00:05:31] Speaker 04:
But you also then have to take a look.

[00:05:34] Speaker 04:
And this is what the Baker v. McDonough case said, too.

[00:05:37] Speaker 02:
Council, I read your brief to repeatedly say

[00:05:41] Speaker 02:
that the issue here is whether the board had to give a sympathetic reading instead of apply undebatable error.

[00:05:50] Speaker 02:
So the answer, I think, to what Judge Cunningham was asking is yes, it's instead of, right?

[00:05:56] Speaker 04:
Yes, yes.

[00:05:57] Speaker 04:
Yes, exactly.

[00:05:57] Speaker 02:
Yes, yes.

[00:05:58] Speaker 02:
And that's the question of law you're putting in front of us.

[00:06:01] Speaker 02:
That's correct.

[00:06:02] Speaker 04:
Yes, sir.

[00:06:02] Speaker 04:
Yes, sir.

[00:06:03] Speaker 02:
Yes, sir.

[00:06:03] Speaker 02:
What if any authority do you have

[00:06:06] Speaker 02:
that would support the proposition that instead of un-debatable error, the board should have been just giving it.

[00:06:12] Speaker 04:
Yeah.

[00:06:13] Speaker 04:
I think that you have the Moody v. Principe case where this court said, in the context even of clear and unmistakable error, that when you're talking about claims that have to be claims that were

[00:06:29] Speaker 04:
reasonably raised by the record that the court, even in the board, even in the context of Q, has to give a sympathetic reading to that.

[00:06:41] Speaker 02:
But I don't think, but correct me if I'm wrong, I don't think there's anything in Moody where we say or suggest you don't also apply the undebatable error standard.

[00:06:51] Speaker 04:
I mean, do you agree with that?

[00:06:55] Speaker 04:
Well, they remanded it back saying, I think that maybe the more proper question, and this may be where the Baker case maybe could help.

[00:07:06] Speaker 04:
Because the court in that particular case said the standard was whether or not, so in the Baker case,

[00:07:15] Speaker 04:
You had a question of whether or not it was undebatable that the veteran had a definitive diagnosis of multiple sclerosis.

[00:07:21] Speaker 04:
And this court has said, no, the standard is whether or not it's undebatable that the evidence is an equipa.

[00:07:28] Speaker 04:
And if that answer is yes, then Q would be warranted.

[00:07:32] Speaker 04:
And so I think the question would be that you have to give a sympathetic reading.

[00:07:45] Speaker 04:
as to this legal theory.

[00:07:48] Speaker 04:
Number two is also think that you have to also then consider whether or not it is undebatable that the evidence was in actual equipa.

[00:07:59] Speaker 04:
And that could then make then a difference in how that's analyzed.

[00:08:04] Speaker 04:
Because say like in this particular case, you have a lay history.

[00:08:11] Speaker 04:
you have a lay history.

[00:08:12] Speaker 04:
All the board did in 1986 said there's no objective medical evidence.

[00:08:16] Speaker 04:
And we argued in our brief that's not the proper standard to be applied.

[00:08:22] Speaker 04:
We don't have like any, you know, the board in this particular case, I think, tried to argue that there could maybe be some factual issues about when the veteran actually started to say that he actually had arthritis, which would affect whether or not the presumption would apply.

[00:08:39] Speaker 04:
And I think that the

[00:08:41] Speaker 04:
that, especially when you consider the Baker v. McDonough case, it would be- Let me ask you, did you cite that?

[00:08:47] Speaker 04:
Let's not come up with- Yeah, yeah.

[00:08:49] Speaker 04:
I'm sorry.

[00:08:49] Speaker 04:
I'm sorry.

[00:08:50] Speaker 04:
And the reason I bring it up, this is a case that was decided after the briefing was done in this case.

[00:08:55] Speaker 04:
And in the last oral argument I had in clear and unmistakable, the court

[00:09:00] Speaker 04:
addressed it on its own.

[00:09:02] Speaker 04:
So that's why.

[00:09:02] Speaker 01:
We have something called the 28-J letter, where if you think a precedent is relevant and it follows the briefing, you usually submit it to the court.

[00:09:11] Speaker 01:
I'm still not understanding the answer to Judge Stark's question.

[00:09:18] Speaker 01:
If you're asking us to overturn the undebatable standard, then we can't do that as a panel.

[00:09:24] Speaker 01:
You would agree with that, right?

[00:09:25] Speaker 01:
The full court would have to overturn

[00:09:29] Speaker 01:
the cases that have relied on that standard, correct?

[00:09:33] Speaker 04:
I think that would probably would be correct.

[00:09:37] Speaker 04:
I think that kind of like what I mean by when you determine, when you read undebatable standard, you have to consider it in a more sympathetic light.

[00:09:49] Speaker 01:
So where does that get you in this case?

[00:09:55] Speaker 01:
You want us to remand it?

[00:09:58] Speaker 01:
to the CAVC and then to the board to say, you have to apply a more sympathetic standard?

[00:10:05] Speaker 04:
That's correct.

[00:10:05] Speaker 04:
Plus, also, I think under the Baker v. McDonough, it would not be undebatable in terms.

[00:10:13] Speaker 04:
It would be undebatable about whether or not the evidence is an equipa or not, which is a different question than.

[00:10:21] Speaker 01:
Was the Baker case a CUE case?

[00:10:24] Speaker 04:
What?

[00:10:24] Speaker 01:
Was Baker a CUE case?

[00:10:25] Speaker 04:
Yes, he was.

[00:10:27] Speaker 04:
Yes, it was.

[00:10:28] Speaker 04:
It was a CUE case.

[00:10:30] Speaker 03:
Do you have a citation for us?

[00:10:31] Speaker 03:
You've been quoting it to us.

[00:10:32] Speaker 03:
Do you have a citation for us?

[00:10:35] Speaker 04:
It is, unfortunately.

[00:10:40] Speaker 04:
I don't think it's not a published opinion, the docket.

[00:10:43] Speaker 01:
It's a non-precedential opinion?

[00:10:44] Speaker 04:
That's correct.

[00:10:45] Speaker 01:
Well, that makes a difference, too.

[00:10:47] Speaker 04:
Yeah.

[00:10:49] Speaker 04:
And the only reason I brought it up is because the last CUE case that I had here in March

[00:10:54] Speaker 04:
the court brought up that particular case to us and hoarded supplemental briefing on that.

[00:10:59] Speaker 01:
So you're saying you want us to remand it to say that you have to apply a more sympathetic reading and your definition of more sympathetic would be if the evidence is an equipoise, the veteran wins?

[00:11:14] Speaker 04:
That's correct, yes.

[00:11:21] Speaker 01:
How does this issue that we've been talking about, the other issue you kind of refer to is, and I want to understand if they're separate or if they're among them, which is that they should have credited your client's testimony.

[00:11:38] Speaker 01:
You're arguing under some regulation or whatever that they're required to consider lay testimony?

[00:11:45] Speaker 04:
Right, right, right.

[00:11:46] Speaker 04:
I think that there is a 3.307 that says that lay evidence alone is sufficient.

[00:11:57] Speaker 04:
And that's kind of it.

[00:12:01] Speaker 04:
Is that really what it says?

[00:12:03] Speaker 01:
The factual basis may be established by medical evidence, competent laid evidence, or both.

[00:12:10] Speaker 01:
Medical evidence should set forth so you think

[00:12:14] Speaker 01:
That means that you can't consider the medical evidence.

[00:12:17] Speaker 04:
You can only consider the medical evidence.

[00:12:21] Speaker 04:
So basically what the board did in 1986 was they said, you must have objective medical evidence.

[00:12:30] Speaker 04:
That's all the board said.

[00:12:31] Speaker 04:
That's all we have.

[00:12:33] Speaker 04:
So there's no like finding, hey, the veteran's not credible or something like that.

[00:12:38] Speaker 04:
And what we are saying is under 38 CFR 3.307b, lay evidence alone is permitted to establish continuity of symptomology under 3.303b to establish a nexus.

[00:12:52] Speaker 02:
Are you saying the board has to ignore all the other evidence in the record if there is lay evidence?

[00:12:59] Speaker 04:
Well, they don't.

[00:13:03] Speaker 04:
I think in this particular case, the way that I read the board decision is the board is wrong to require that in order to establish a nexus.

[00:13:18] Speaker 03:
The board is wrong to require what?

[00:13:20] Speaker 03:
You said that.

[00:13:20] Speaker 04:
Oh, I'm sorry.

[00:13:22] Speaker 04:
All the board said was that

[00:13:26] Speaker 04:
The veteran did not submit objective medical evidence that he suffered from arthritis within service or within a year of service.

[00:13:33] Speaker 04:
And that's all the board said.

[00:13:35] Speaker 04:
And what we're saying is that lay evidence alone is permissible.

[00:13:40] Speaker 04:
And so the board erred in requiring the veteran to submit that objective medical evidence.

[00:13:49] Speaker 04:
And I think it's particularly relevant in this case, because there's no dispute that the veteran did have arthritis.

[00:13:56] Speaker 04:
Because obviously, you would need to have medical evidence to establish a diagnosis.

[00:14:01] Speaker 04:
But he does have a diagnosis, and the board acknowledged that at that time.

[00:14:06] Speaker 04:
So that's not an issue there.

[00:14:08] Speaker 04:
What we're talking about here is the established continuity of symptomology under 3.303b.

[00:14:18] Speaker 01:
OK.

[00:14:18] Speaker 01:
We're into your rebuttal, so why don't we hear from the other side.

[00:14:21] Speaker 01:
OK.

[00:14:22] Speaker 04:
OK.

[00:14:30] Speaker 01:
Good morning.

[00:14:31] Speaker 00:
Good morning, Your Honors, and may it please the court.

[00:14:34] Speaker 00:
Mr. Jones and I were here about a year ago, almost exactly, debating this very same issue in which he was arguing that Q and a sympathetic reading should somehow be combined or similar.

[00:14:47] Speaker 00:
The case was called Williams v. Collins.

[00:14:49] Speaker 00:
It was a non-precedential decision.

[00:14:51] Speaker 00:
But this court declined to alter the Q standard in favor of a sympathetic reading.

[00:14:57] Speaker 00:
And I believe that there's no reason that the court should not follow that.

[00:15:03] Speaker 00:
concept here.

[00:15:04] Speaker 01:
Do you want to respond to Moody and Baker, if you wish?

[00:15:08] Speaker 00:
Sure.

[00:15:09] Speaker 00:
I'm not familiar with the Baker case, as it was not cited in any of the briefs.

[00:15:13] Speaker 00:
But in terms of Moody, Moody doesn't say that a sympathetic reading overrides the Q standard.

[00:15:21] Speaker 00:
What Moody explains is that a sympathetic reading should be given to the original pleadings when considering whether there was Q. So in this case,

[00:15:32] Speaker 00:
We're talking about the original claim, 1981, 1982, when the veteran claimed arthritis as secondary to the valley fever.

[00:15:41] Speaker 00:
What I believe he was asking, in terms of a sympathetic reading, that it not be read as just a secondary service connection claim, but also as

[00:15:52] Speaker 00:
presumptively service-connected because he alleges there was some evidence that the arthritis arose within a year of service.

[00:16:00] Speaker 00:
And we don't disagree that a sympathetic reading should have been given to those original pleadings and was given to those original pleadings because the board in 1986 considered both the secondary service connection related to the Valley Fever

[00:16:15] Speaker 03:
the concept of presumptive service connection and just determine that the evidence didn't support that there was any arthritis present in Within a year of service, so I think in terms of relief you are seeking Dismissal or in the alternative affirmance, but based on what we're talking about Do you think that there should be different treatment for the two different issues that were raised by opposing counsel, so there's

[00:16:42] Speaker 03:
the first issue that we talked, I think, quite a bit about, and then kind of the secondary issue that I want to say Judge Prost talked with them about.

[00:16:50] Speaker 03:
Do you think one claim should be dismissed, one should be affirmed, or what's your overall take?

[00:16:56] Speaker 00:
Both should be dismissed because both were a mere application of existing law by the Veterans Court to the case.

[00:17:03] Speaker 00:
So in the sense of sympathetic reading and cue, as we just talked about,

[00:17:08] Speaker 00:
sympathetic reading was applied to the actual pleadings.

[00:17:12] Speaker 00:
And then the Q standard for un-debatable error that would change the outcome was just applied to the facts here.

[00:17:19] Speaker 00:
And there was frankly no error found at all, let alone an un-debatable error, because as I pointed out, the board did consider all potential theories of service connection.

[00:17:29] Speaker 00:
So there was no reasonably raised claim that

[00:17:31] Speaker 00:
wasn't considered.

[00:17:32] Speaker 01:
I think the problem is that maybe you and your friend would define sympathetic reading differently.

[00:17:38] Speaker 01:
So that leaves us with a question.

[00:17:40] Speaker 01:
But can I ask you about the second piece of this, about which I'm not really understanding?

[00:17:45] Speaker 01:
What is your understanding of this lay witness issue?

[00:17:49] Speaker 00:
My understanding of the issue that's being raised is that Mr. Morgan is asserting that the lay evidence had

[00:17:59] Speaker 00:
to be considered over the medical evidence or if there's lay evidence it should be ignored.

[00:18:05] Speaker 00:
We don't dispute that 3.307 requires the VA to look at lay evidence and that lay evidence

[00:18:12] Speaker 00:
can be a factor in determining whether a condition is presumptively serviceable or not.

[00:18:16] Speaker 01:
But what happens as a practical matter is, was there medical evidence below?

[00:18:20] Speaker 01:
Or did they say, no, you haven't put any medical evidence in.

[00:18:25] Speaker 01:
You've just put in lay evidence.

[00:18:26] Speaker 01:
And in that case, all you have is lay evidence.

[00:18:29] Speaker 00:
No, there was medical evidence and lay evidence.

[00:18:32] Speaker 00:
There was medical evidence that conflicted with the lay evidence.

[00:18:36] Speaker 00:
The VA found that that medical evidence outweighed the lay evidence.

[00:18:40] Speaker 00:
The board, even back in 1986, took into account that there was testimony in the record from Mr. Morgan about when his arthritis started.

[00:18:49] Speaker 00:
But the board weighed the evidence and determined that the medical evidence against that testimony was more persuasive.

[00:18:57] Speaker 00:
And that fact-finding role, that weighing of evidence, is exclusively relegated to VA.

[00:19:03] Speaker 00:
And this court lacks jurisdiction to reweigh that.

[00:19:05] Speaker 01:
It's half a dozen.

[00:19:07] Speaker 01:
I could craft it as a legal question, and you win on that point, but whether the regulation really means that if you have lay evidence, you have to consider that to the exclusion of medical evidence.

[00:19:21] Speaker 00:
Sure, yes.

[00:19:22] Speaker 00:
That could be construed as a legal question.

[00:19:24] Speaker 00:
But the regulation, as you said, does not support the concept that only lay evidence can be included if there is lay evidence.

[00:19:31] Speaker 00:
And that's the end of the matter.

[00:19:32] Speaker 02:
I understood Mr. Jones to be telling us that at least at some point in Mr. Morgan's process, at some level, maybe the board said, you definitely need objective medical evidence.

[00:19:46] Speaker 02:
I don't know if you heard he said something to that effect, or at least I thought he did.

[00:19:50] Speaker 02:
Did that happen at some stage of this process?

[00:19:53] Speaker 00:
I don't recall seeing anywhere in the record where the board specifically said objective medical evidence.

[00:20:00] Speaker 00:
It was just a weighing of the evidence.

[00:20:02] Speaker 00:
It wasn't a disregarding of lay evidence.

[00:20:06] Speaker 02:
And on the first issue that he raised, if I understand the issue to be whether the board should have applied a sympathetic reading

[00:20:16] Speaker 02:
instead of, so to the exclusion of the undebatable error standard, I think that would be a question of law, wouldn't it?

[00:20:26] Speaker 00:
That potentially could be a question of law if we're talking about the proper legal standard that the Board and Veterans Court should have.

[00:20:36] Speaker 02:
And I'm not familiar with the Williams case you started with.

[00:20:40] Speaker 02:
Did we address that question in the way I've sort of articulated it in that case?

[00:20:45] Speaker 02:
Do you know?

[00:20:45] Speaker 02:
I haven't looked at that.

[00:20:46] Speaker 00:
It was not a dismissal.

[00:20:48] Speaker 00:
So the court did address the question on the merits.

[00:20:51] Speaker 00:
It was a little bit different in that Mr. Jones was arguing that the presumption of soundness played into this and that the presumption of soundness, I think, combined with the sympathetic reading, kind of suggested

[00:21:06] Speaker 00:
The un-debatable error standard should be lesser at some level.

[00:21:11] Speaker 00:
I'm not sure he articulated in that case, as he hasn't really in this case what specifically it should be.

[00:21:18] Speaker 00:
But this court declined to change the Q un-debatable error standard.

[00:21:23] Speaker 00:
And that's consistent with this court's decision in SEMRAJ, where it addressed the sympathetic reading, but explicitly said that sympathetically reading the underlying pleadings does not change anything about the Q standard.

[00:21:38] Speaker 00:
Thank you.

[00:21:41] Speaker 01:
We can enjoy two minutes of rebuttal if you need it.

[00:21:47] Speaker 04:
I guess the question was asked, I guess, where was the objective medical evidence, I guess, statement in the board decision in 1986.

[00:22:00] Speaker 04:
And if you go back to appendix 29,

[00:22:03] Speaker 04:
under the findings of fact number four.

[00:22:06] Speaker 04:
It said a musculoskeletal disorder was not objectively demonstrated in service or within one year of separation.

[00:22:12] Speaker 04:
It is not etiologically related to a service-connected disease or injury.

[00:22:16] Speaker 04:
So that's where we've got that from.

[00:22:18] Speaker 01:
Thank you.

[00:22:20] Speaker 01:
This was a long time ago.

[00:22:22] Speaker 01:
Boy, this stuff reads differently now, because we've got the different statutory regime and the review that we didn't have then, right?

[00:22:30] Speaker 04:
Yeah.

[00:22:31] Speaker 01:
as an observation unit?

[00:22:34] Speaker 04:
Yeah, it's a real issue because, number one, the veteran himself only raised up the issue of being at secondary to scosomidosis.

[00:22:46] Speaker 04:
So all of the medical evidence, all of the C&P exams, that's the only questions they ever asked.

[00:22:51] Speaker 04:
The only reason it was brought up is because the veteran in his history stated,

[00:22:57] Speaker 04:
It began in 1967, but the C&P exam, I guess, did not give an opinion because they wasn't asked at the time because he only made a claim for secondary service connection.

[00:23:08] Speaker 04:
And then he files an appeal.

[00:23:09] Speaker 04:
He never makes any arguments about saying it's direct service connection.

[00:23:13] Speaker 04:
And then the board puts this finding a fact.

[00:23:18] Speaker 04:
And so I think that's probably why we're trying to see if we could get a little bit more sympathetic reading, and especially considering the fact

[00:23:26] Speaker 04:
that at the time, there's no appellate rights for the veteran at all, because the court hadn't been created yet.

[00:23:40] Speaker 04:
And then another issue, too, is that the board is coming back, and the board is making some findings about whether or not did he say

[00:23:55] Speaker 04:
It was in 1967.

[00:23:57] Speaker 04:
And no, maybe it was 1970.

[00:23:58] Speaker 04:
No, maybe it was 1982.

[00:24:01] Speaker 04:
And the problem is that the board in 1986, because it was something he didn't raise at all, didn't really even talk about that at all, because it was just an issue.

[00:24:10] Speaker 04:
It was just a theory that was not raised by him at all.

[00:24:16] Speaker 04:
And so we appreciate your time.

[00:24:22] Speaker 04:
Thank you very much.

[00:24:23] Speaker 04:
Thank you.

[00:24:24] Speaker 01:
You have a good day.