1 00:00:00,000 --> 00:00:24,960 Well camera isn't on so we'll see when it comes up. 2 00:00:24,960 --> 00:00:31,960 I like to see myself when I'm talking, it's very strange. 3 00:01:24,960 --> 00:01:35,960 Good morning this is Judge Dorsey, we're on the record in FTX Trading Limited case number 22-11068. 4 00:01:35,960 --> 00:01:46,960 Before we begin let me just remind everyone that even though this hearing is remote it is a formal court hearing. 5 00:01:46,960 --> 00:01:55,960 So if you are not speaking or not presenting please keep your camera off and your lines muted. 6 00:01:55,960 --> 00:02:04,960 Interruptions will not be tolerated and you will be removed if you interrupt the proceeding and not be allowed back in. 7 00:02:04,960 --> 00:02:19,960 So with that I requested this hearing on the motion to shorten that was filed by joint liquidators in the Bahamian proceeding. 8 00:02:19,960 --> 00:02:31,960 Ordinarily I wouldn't hold a hearing on a motion to shorten but I wanted to take the opportunity to talk to the parties about where we are in this case and what's going on. 9 00:02:31,960 --> 00:02:42,960 And it seems to me, I understand that there's a lot of heated debate between the parties here over what's happening. 10 00:02:42,960 --> 00:02:51,960 But I do believe that there must be some path forward here to resolve the concerns of everybody involved. 11 00:02:51,960 --> 00:03:09,960 I think everyone would agree, Mr. Praml they'll give you a chance to tell me I'm wrong if I'm wrong, but I think everyone agrees that the joint liquidators are entitled to the data and information that relates to their debtor entity. 12 00:03:09,960 --> 00:03:17,960 That's in liquidation in the Bahamas. Is there any dispute about that issue Mr. Praml? 13 00:03:17,960 --> 00:03:19,960 Yes, there is. 14 00:03:19,960 --> 00:03:22,960 I'm sorry, there is a dispute or no there isn't? 15 00:03:22,960 --> 00:03:23,960 Yes, there is a dispute. 16 00:03:23,960 --> 00:03:28,960 Okay, over whether they're entitled to their own information? 17 00:03:28,960 --> 00:03:39,960 Well, the requests are not just for information, Your Honor. The requests are probably for dynamic access to live systems and we believe that that is inappropriate. 18 00:03:39,960 --> 00:03:50,960 So in terms of static information, we are certainly happy to sit down and talk about that. Dynamic access we believe should not be permitted. 19 00:03:50,960 --> 00:04:00,960 How are they going to run their case in the Bahamas if they don't have access, dynamic access to at least their own information? 20 00:04:00,960 --> 00:04:13,960 And I separate this out. Is there a distinction? Are you telling me there's an issue with regard to that the only way to provide this information is to provide them access to the entire system and there are some concerns about that? 21 00:04:13,960 --> 00:04:21,960 Or is there a way to provide just dynamic access to their own information? 22 00:04:21,960 --> 00:04:33,960 I think there's a way, Your Honor, at this point to provide static information and we're happy to sit down and have a meeting and confer about how that static information might be able to be provided. 23 00:04:33,960 --> 00:04:47,960 The concern we have with respect to dynamic access to live systems is that we believe that any dynamic access will be provided immediately to the government of the Bahamas and in particular the Securities Commission. 24 00:04:47,960 --> 00:04:59,960 And to date, any access that the Securities Commission has had to our systems has led to the relief from the debtors of digital assets and we do not believe that that should be permitted. 25 00:04:59,960 --> 00:05:18,960 We do not believe that there is a separation between the JPLs and the Securities Commission at this point in time. Certainly no separation that provides the debtors with comfort that whatever is provided to the JPLs will not be provided immediately to the Securities Commission. 26 00:05:18,960 --> 00:05:28,960 Mr. Schor, what's the relationship between the JPLs and the Securities Commission in the Bahamas? 27 00:05:28,960 --> 00:05:32,960 You're muted, Mr. Schor. 28 00:05:32,960 --> 00:05:39,960 I'd like to at some point speak to the larger issues Your Honor is referencing and certainly respond to what Mr. Bromley is saying. 29 00:05:39,960 --> 00:05:46,960 But in response to your question, the JPLs are the analog would be a Chapter 11 trustee. 30 00:05:46,960 --> 00:05:50,960 The Commission's analog is the SEC. 31 00:05:50,960 --> 00:05:58,960 So no more than Mr. Bromley can be claimed for or be accused of being an arm of the SEC. 32 00:05:58,960 --> 00:06:06,960 The JPLs are a court created trustee liquidating FTX digital. 33 00:06:06,960 --> 00:06:09,960 Well, is there any? 34 00:06:09,960 --> 00:06:11,960 Let me just get to my point. 35 00:06:11,960 --> 00:06:21,960 Is there any use in my ordering the parties to mediate this issue or at least sit down and talk to each other about this issue? 36 00:06:21,960 --> 00:06:31,960 Or is are we to the point where I'm going to have to have a full evidentiary hearing on these issues and make a decision? 37 00:06:31,960 --> 00:06:34,960 I'd like to think that the parties can work it out. 38 00:06:34,960 --> 00:06:58,960 The one situation we can't be held in into or put into is having that meet and confer, having the debtors raise these sort of issues and essentially set the bar as being the JPLs must prove that there was no collusion between the Commission and SBF before they can get dynamic access to the information and then have everybody disappear for the holidays. 39 00:06:58,960 --> 00:07:00,960 So essentially we get timed out. 40 00:07:00,960 --> 00:07:07,960 So if what is going to happen here, which is what I was going to propose, is that the court set this hearing for Friday, Monday. 41 00:07:07,960 --> 00:07:24,960 I know your honor has travel plans, but at least some control date so that if we don't get to resolution, you can at least come back to your honor with with discrete issues to be resolved. 42 00:07:24,960 --> 00:07:31,960 So, for example, we have made very clear to the Solomon Cromwell team. How about just getting us a clone of the system? 43 00:07:31,960 --> 00:07:35,960 We don't need dynamic information right now. We can get back their access right now. 44 00:07:35,960 --> 00:07:37,960 Can't you just get us a clone? 45 00:07:37,960 --> 00:07:46,960 And Mr. Bromley saying what I want to do is sit down with Mr. Schor, have our respective teams sit down and they can discuss the shape of a clone. 46 00:07:46,960 --> 00:07:48,960 That's not going to work. 47 00:07:48,960 --> 00:07:56,960 He can't appear in court today and say we have no problem giving the clone, but but they just need to sit down and talk to us about what that clone is going to look like. 48 00:07:56,960 --> 00:08:01,960 It's got to be resolved in the next couple of days, not weeks, certainly not months. 49 00:08:01,960 --> 00:08:05,960 Your honor, that that is that's a conclusion, not an argument. 50 00:08:05,960 --> 00:08:10,960 Mr. Schor has given no indication as to why there's anything that needs to be done in the next couple of days. 51 00:08:10,960 --> 00:08:18,960 First of all, and second, Mr. Schor and his colleagues have not simply said we are willing to take a clone of static information. 52 00:08:18,960 --> 00:08:32,960 Their motion asks for live, dynamic access and the information that we provided to the court and we provided yesterday to Congress for Mr. Ray's testimony indicates that the Securities Commission of the Bahamas has already 53 00:08:32,960 --> 00:08:41,960 collaborated with the JPLs to obtain access to digital assets and to mint tokens. 54 00:08:41,960 --> 00:08:44,960 The JPLs have been involved in that. 55 00:08:44,960 --> 00:08:51,960 The JPLs went to court after the fact to get approval to approve violations of the automatic stay that occurred. 56 00:08:51,960 --> 00:08:53,960 Mr. Schor can shake his head all he wants. 57 00:08:53,960 --> 00:08:55,960 That's what the evidence shows. 58 00:08:55,960 --> 00:08:57,960 So we're happy to sit down. 59 00:08:57,960 --> 00:08:58,960 We're happy to have a mediation. 60 00:08:58,960 --> 00:09:02,960 We're happy to talk about providing static information. 61 00:09:02,960 --> 00:09:07,960 But I will tell you, your honor, with respect to dynamic information, we can have a hearing on Friday. 62 00:09:07,960 --> 00:09:15,960 We will go immediately and if the ruling is against us, we will go immediately on appeal and seek a pending appeal. 63 00:09:15,960 --> 00:09:17,960 This is dangerous information. 64 00:09:17,960 --> 00:09:20,960 We do not trust the Bahamian government. 65 00:09:20,960 --> 00:09:32,960 And because of the evidence we have in terms of the actions to date of the JPLs, we simply don't trust that the JPLs will be able to hold this information and not provide it to the Bahamian government. 66 00:09:32,960 --> 00:09:33,960 All right. 67 00:09:33,960 --> 00:09:45,960 Your honor, while I appreciate your desire to shortcut this, can we just maybe get into the hearing because what was just said is exactly what a Chapter 15 is not supposed to be. 68 00:09:45,960 --> 00:09:48,960 And we don't have a Chapter 15 approval yet either. 69 00:09:48,960 --> 00:09:49,960 All right. 70 00:09:49,960 --> 00:09:51,960 Well, here, hold on, hold on. 71 00:09:51,960 --> 00:09:55,960 All right. 72 00:09:55,960 --> 00:09:57,960 I'm not going forward with the hearing today. 73 00:09:57,960 --> 00:09:59,960 It's not going to be Friday either. 74 00:09:59,960 --> 00:10:05,960 Probably not going to be before next year because this is going to be a full evidentiary hearing. 75 00:10:05,960 --> 00:10:07,960 And for an evidentiary hearing, it's live. 76 00:10:07,960 --> 00:10:16,960 I expect witnesses in the courtroom and present it live before me so I can judge credibility. 77 00:10:16,960 --> 00:10:24,960 And that's not something that can happen Friday or Monday or even before the Christmas holiday. 78 00:10:24,960 --> 00:10:34,960 So if we are going to have to go forward with a hearing, it's going to be in January. 79 00:10:34,960 --> 00:10:39,960 And I can give the parties 80 00:10:39,960 --> 00:10:47,960 January 6th beginning at 930 a.m. 81 00:10:47,960 --> 00:10:50,960 As I said, it will be a live hearing. 82 00:10:50,960 --> 00:10:52,960 And these are serious allegations. 83 00:10:52,960 --> 00:11:09,960 Obviously, this is a gating issue that I'm going to have to resolve before we can move forward with how to proceed with the dynamic between the Bahamian proceeding and this proceeding. 84 00:11:09,960 --> 00:11:15,960 And I'm hoping there's still some way to resolve this before we get to January 6th. 85 00:11:15,960 --> 00:11:24,960 I would highly encourage the parties to talk to each other and if you think it would be productive to find a mediator to help mediate that issue as well. 86 00:11:24,960 --> 00:11:40,960 And I don't know if there's a way to fashion an order, Mr. Bromley, that would limit the ability of JPLs similar to what you might have in a 502 motion order that limits the ability of JPLs to share that information. 87 00:11:40,960 --> 00:11:45,960 They can share it with their advisors, obviously, and themselves. 88 00:11:45,960 --> 00:11:49,960 Maybe that's a possibility of a way to move forward. 89 00:11:49,960 --> 00:11:54,960 But I will leave that to the parties to see if you can work something out. 90 00:11:54,960 --> 00:11:59,960 And if not, I'll hear everybody on the 6th. 91 00:11:59,960 --> 00:12:10,960 Your Honor, if I may be heard for a little bit on this because I think there is a other perspective to this and I think Mr. Bromley is wrong when he says this is not a Chapter 15 yet. 92 00:12:10,960 --> 00:12:13,960 We filed, we've come and asked for provisional relief. 93 00:12:13,960 --> 00:12:26,960 And ultimately, what I'm going to ask your Honor, what you were mentioning is I'd like you to keep a control date on Friday to see if your Honor can't resolve not issues about whether the Bahamian government was in cahoots with SBF, 94 00:12:26,960 --> 00:12:39,960 which I agree would be an evidentiary hearing, but rather whether or not we can fashion an order that provides protection for the legitimate concerns that Mr. Bromley has raised. 95 00:12:39,960 --> 00:12:54,960 Well, because I've got to say, in the last 30 years, I've seen a lot of mega cases go off the rails where accusations like this fly and every hearing turns into a charged referendum on the case. 96 00:12:54,960 --> 00:12:59,960 And it becomes overly expensive, burdensome on the court, and value destructive. 97 00:12:59,960 --> 00:13:09,960 And so when the CRO of the debtor appears in and testifies in front of Congress with respect to what the debtor is doing, the investigations that are going on, 98 00:13:09,960 --> 00:13:19,960 and that a foreign government has colluded with somebody who is jailed right now, we're at least tilting on the rails. 99 00:13:19,960 --> 00:13:29,960 And I just on behalf of my client, it may come to that, but it's way too early in our case, in this case, to devolve. 100 00:13:29,960 --> 00:13:40,960 And I agree with your Honor, there has got to be a way the professionals can work this out without getting into the kind of accusations that are flying. 101 00:13:40,960 --> 00:13:52,960 To be clear, we filed a pleading this morning, Your Honor, that attaches a declaration that Mr. Ray could not have seen, nor counsel could have seen, 102 00:13:52,960 --> 00:13:59,960 which belies this notion that what the commission was doing was working with SBF. 103 00:13:59,960 --> 00:14:02,960 In fact, the email they attached where SBF says- 104 00:14:02,960 --> 00:14:05,960 Well, I'm not going to get into the marizote at this point, Mr. Short. 105 00:14:05,960 --> 00:14:07,960 We'll talk about that on the 6th if we get to it. 106 00:14:07,960 --> 00:14:10,960 Let's talk about the- 107 00:14:10,960 --> 00:14:11,960 Okay, but recognize- 108 00:14:11,960 --> 00:14:12,960 Hold on, Mr. Short. I want to move on. 109 00:14:12,960 --> 00:14:15,960 Let's talk about the 16th. 110 00:14:15,960 --> 00:14:23,960 We have the motion objecting to the seal by the U.S. trustee. 111 00:14:23,960 --> 00:14:25,960 Is U.S. trustee on the line? 112 00:14:25,960 --> 00:14:29,960 Someone from the U.S. trustee? 113 00:14:29,960 --> 00:14:33,960 Yes, Your Honor. Juliet Sarkeesian for the U.S. trustee. 114 00:14:33,960 --> 00:14:42,960 Ms. Sarkeesian, I have some concerns about that hearing going forward on Friday from a number of perspectives. 115 00:14:42,960 --> 00:14:54,960 Number one, the motion implicates individual creditors, and there's no creditors committee yet. 116 00:14:54,960 --> 00:15:00,960 I think the creditors committee would want to weigh in on that motion. 117 00:15:00,960 --> 00:15:04,960 Do we know yet when the committee will be formed? 118 00:15:04,960 --> 00:15:10,960 Your Honor, first, I- I apologize. It's not the right word. 119 00:15:10,960 --> 00:15:14,960 We had hoped to have a committee formed by this time. 120 00:15:14,960 --> 00:15:19,960 We had a tremendous response, and people are located all over the world. 121 00:15:19,960 --> 00:15:24,960 Unfortunately, it becomes a little bit difficult when people are in very different time zones, 122 00:15:24,960 --> 00:15:28,960 and there's a lot of complicated information, as I'm sure Your Honor can imagine. 123 00:15:28,960 --> 00:15:42,960 So we are moving as expeditiously as possible, you know, and we hope to be filing a notice of appointment very soon. 124 00:15:42,960 --> 00:15:46,960 I can't say anything more than that, other than very soon. 125 00:15:46,960 --> 00:15:52,960 I do have concerns. You know, they obviously have to choose counsel, 126 00:15:52,960 --> 00:16:00,960 and so, you know, I think there's certainly a reasonable possibility that they might not have counsel by Friday, 127 00:16:00,960 --> 00:16:06,960 or maybe they have it by Thursday, but there's not, you know, as much time as one would like for them to have. 128 00:16:06,960 --> 00:16:11,960 So, I mean, Your Honor certainly brings up a valid concern. 129 00:16:11,960 --> 00:16:15,960 We had hoped it would be different. We had hoped that we would have a committee formed by this time, 130 00:16:15,960 --> 00:16:21,960 but the reality is, due to circumstances outside of our control, it has not yet happened. 131 00:16:21,960 --> 00:16:29,960 I also, I noticed that the Trustee also objected to consolidate a creditor matrix on similar grounds 132 00:16:29,960 --> 00:16:33,960 on the production of the creditor information, I believe. 133 00:16:33,960 --> 00:16:36,960 Oh, Your Honor, that was the motion I was talking about. 134 00:16:36,960 --> 00:16:41,960 So there was two motions, seal motions. 135 00:16:41,960 --> 00:16:46,960 One of them relates to the indemnification slash exculpation motion, 136 00:16:46,960 --> 00:16:51,960 allow debtor to address that, but my understanding, based on discussions as well as the agenda, 137 00:16:51,960 --> 00:16:55,960 is that they are agreeing for that to be unsealed. 138 00:16:55,960 --> 00:16:57,960 Okay. 139 00:16:57,960 --> 00:17:04,960 With respect to the other motion relates to the creditor matrix, schedules and statements, top 50 list, 140 00:17:04,960 --> 00:17:13,960 pretty much any document in the case that would have names or addresses of creditors or customer slash creditors. 141 00:17:13,960 --> 00:17:14,960 Okay. 142 00:17:14,960 --> 00:17:20,960 So that's the motion I was discussing that we did file an objection to. 143 00:17:20,960 --> 00:17:21,960 Okay. 144 00:17:21,960 --> 00:17:25,960 We have not technically filed an objection to the other motion, but that, because they said effectively, 145 00:17:25,960 --> 00:17:30,960 they're, I don't know if withdraw is the right word, but they're not going to pursue that relief on a final basis. 146 00:17:30,960 --> 00:17:39,960 Okay. I also have the motion to intervene, followed by members of the media. 147 00:17:39,960 --> 00:17:42,960 I don't know if anyone plans on objecting to the motion to intervene, 148 00:17:42,960 --> 00:17:50,960 but I certainly want to give the media the opportunity to participate in that hearing as well. 149 00:17:50,960 --> 00:17:57,960 So, Ms. Sarkeesian, should we, should I set another date now in January, 150 00:17:57,960 --> 00:18:00,960 or do you want to wait to see when the committee is formed and retains counsel 151 00:18:00,960 --> 00:18:06,960 and has an opportunity to talk to you about how to go forward? 152 00:18:06,960 --> 00:18:13,960 So, Your Honor, I just want to be clear, so Your Honor is asking that the hearing on Friday on the motion 153 00:18:13,960 --> 00:18:19,960 to seal the creditor matrix be put off until after the committee is formed? 154 00:18:19,960 --> 00:18:20,960 Yes. 155 00:18:20,960 --> 00:18:21,960 Okay. 156 00:18:21,960 --> 00:18:28,960 I think, Your Honor, okay, so you want a date in January. 157 00:18:28,960 --> 00:18:35,960 I guess my feeling is it would probably be best if we could schedule that now, 158 00:18:35,960 --> 00:18:42,960 and I mean I think a committee is going to be formed in very short order. 159 00:18:42,960 --> 00:18:48,960 We're not going to be in a situation, I pray, that we're in January and don't have a committee. 160 00:18:48,960 --> 00:18:52,960 So I think that scheduling it now would actually be very helpful. 161 00:18:52,960 --> 00:19:04,960 Okay. My first week of January is booked because I have a two-day evidentiary hearing 162 00:19:04,960 --> 00:19:08,960 and another Chapter 15 on recognition for the fourth and the fifth. 163 00:19:08,960 --> 00:19:17,960 I just scheduled the sixth for a hearing on the relief from stay from the liquidators. 164 00:19:17,960 --> 00:19:23,960 So it would have to be pushed into the week of January 9th. 165 00:19:23,960 --> 00:19:28,960 If you do have a hearing covered already scheduled for the 11th, our second day hearing, we put it on that. 166 00:19:28,960 --> 00:19:30,960 I do see that, yes. 167 00:19:30,960 --> 00:19:36,960 All right. Does that work, Ms. Arcee, to add it to the agenda for the second day hearing? 168 00:19:36,960 --> 00:19:41,960 I believe so, Your Honor. I don't see any problem with respect to that. 169 00:19:41,960 --> 00:19:49,960 I don't know what the debtors intend, if they intend to put any witnesses on, but I don't expect. 170 00:19:49,960 --> 00:19:55,960 My hope would be that it would not be, if there is testimony, that it will not be extensive. 171 00:19:55,960 --> 00:20:03,960 So hopefully that would fit into, if I could just ask, Your Honor, how much time you have on the 11th? 172 00:20:03,960 --> 00:20:04,960 Well, I have— 173 00:20:04,960 --> 00:20:13,960 If it was only two hours, that might be a problem. 174 00:20:13,960 --> 00:20:18,960 I have it scheduled beginning at 10 for the second day hearing. 175 00:20:18,960 --> 00:20:25,960 I have three other hearings in the afternoon. 176 00:20:25,960 --> 00:20:28,960 Probably can't. They're not going to come off. 177 00:20:28,960 --> 00:20:33,960 At least two of them are not going to come off, because they're contested hearings. 178 00:20:33,960 --> 00:20:36,960 So we would probably have—I can move it. 179 00:20:36,960 --> 00:20:43,960 We could start at 9 a.m., and you'd have until 1230. 180 00:20:43,960 --> 00:20:53,960 I don't know what other objections might be raised at that time to any of the motions that were presented at the first day hearing. 181 00:20:53,960 --> 00:21:00,960 I assume, Mr. Bromley, you're going to be calling witnesses for the sealed motion. 182 00:21:00,960 --> 00:21:11,960 Well, we will have a declarant, Your Honor, and that's assuming that we're not able to resolve the issues with the Predators Committee once the point is made. 183 00:21:11,960 --> 00:21:15,960 So if there's going to be a cross, the witness will have to be here, even if it's a declarant. 184 00:21:15,960 --> 00:21:20,960 Correct. 185 00:21:20,960 --> 00:21:31,960 All right. So let's move—we're going to move that hearing, then, Ms. Sarkisian and Mr. Bromley, to the second day hearing on January 11th. 186 00:21:31,960 --> 00:21:41,960 And Ms. Bromley, circling back on what Ms. Sarkisian said about the demarcation motion, are we in agreement on that one? That's going to be unsealed? 187 00:21:41,960 --> 00:21:43,960 Yes, we are, Your Honor. 188 00:21:43,960 --> 00:21:44,960 Okay. 189 00:21:44,960 --> 00:21:47,960 Your Honor, if I could just ask a favor. 190 00:21:47,960 --> 00:21:49,960 Could we start time for the hearing? 191 00:21:49,960 --> 00:21:55,960 I'm thinking—and Mr. Bromley can indicate otherwise—I'm thinking that three hours should be enough. 192 00:21:55,960 --> 00:22:02,960 And just based on my schedule, it would be much easier if we started at 930, if that did not inconvenience the court. 193 00:22:02,960 --> 00:22:03,960 Oh, we— 194 00:22:03,960 --> 00:22:04,960 Go ahead, Mr. Bromley. 195 00:22:04,960 --> 00:22:10,960 Do you have other—I'm sorry, Your Honor. We do have—it is our second day hearings. We do have a fair amount on the calendar for that day. 196 00:22:10,960 --> 00:22:21,960 We're obviously going to work to resolve all of the issues. And I do respect Ms. Sarkisian's time concerns, but— 197 00:22:21,960 --> 00:22:27,960 That's okay. That's okay. If there's any issue, we'll start at 9. I'll make the arrangements. 198 00:22:27,960 --> 00:22:33,960 Okay. We'll continue to work to resolve the issues, just like we resolve the issues for the ceiling on Friday. 199 00:22:33,960 --> 00:22:45,960 All right. The other possibility is we can always—I can try to rearrange and move my other hearings in the afternoon to the 12th the next day. 200 00:22:45,960 --> 00:22:56,960 I will ask my chambers to do that so that that would free up the entire day for this case, because I do have time. 201 00:22:56,960 --> 00:23:05,960 The other option is if we can't move any of those off from the 11th, I have time on the 12th in the afternoon. 202 00:23:05,960 --> 00:23:12,960 We can always continue the second day hearing on the 12th in the afternoon. 203 00:23:12,960 --> 00:23:18,960 I mean, Your Honor, from my perspective, I—again, even with the other motions that are on for that day, 204 00:23:18,960 --> 00:23:24,960 I don't really expect this would take more than three hours or three and a half hours. 205 00:23:24,960 --> 00:23:28,960 I would not want an inconvenience, again, before it was trying to move the afternoon hearings. 206 00:23:28,960 --> 00:23:37,960 But I also don't know what other motions or applications the debtors might be filing that—you know, retention applications and whatnot that could be scheduled. 207 00:23:37,960 --> 00:23:47,960 So if the debtors feel that it's helpful for the court to try to move those afternoon hearings, I don't object. 208 00:23:47,960 --> 00:23:51,960 I don't want an inconvenience to other people if it's not necessary. 209 00:23:51,960 --> 00:24:01,960 All right. Well, that brings me to the next issue, which is the liquidator's motion to dismiss that was filed on Monday and set for a hearing on the 11th, 210 00:24:01,960 --> 00:24:09,960 which, Mr. Schor, in the future, if you—that was not a nominative state. 211 00:24:09,960 --> 00:24:15,960 That's a second-day hearing. So it was not an open invitation to schedule something. 212 00:24:15,960 --> 00:24:21,960 You need to contact chambers to request a date for—particularly a motion like a motion to dismiss. 213 00:24:21,960 --> 00:24:23,960 I mean, that's going to be an evidence-sharing hearing. 214 00:24:23,960 --> 00:24:24,960 Understood. Understood, Your Honor. 215 00:24:24,960 --> 00:24:32,960 We'll do that in the future, and we'll discuss it with Soloman about when that can go forward. 216 00:24:32,960 --> 00:24:40,960 Okay. Yeah, let's find another date to handle that one. All right. 217 00:24:40,960 --> 00:24:44,960 That brings me to—I wanted to ask about the motion for recognition. 218 00:24:44,960 --> 00:24:50,960 Where are we on that, Mr. Schor? Are we going forward? What's happening? 219 00:24:50,960 --> 00:24:54,960 We're still trying to see if we couldn't resolve that. 220 00:24:54,960 --> 00:25:03,960 I think that's going to be part of a package of discussions that have to occur kind of now to see how we're proceeding. 221 00:25:03,960 --> 00:25:10,960 All right. Well, let's try to get that resolved as well here. 222 00:25:10,960 --> 00:25:30,960 So let me circle back then to the request by Mr. Schor to have the 16th as—I guess it would be kind of a status conference on where the parties are on the issue of the relief from stay. 223 00:25:30,960 --> 00:25:38,960 Mr. Brownlee, do you have a position on that? Everyone was going to be available anyway, so I assume everyone is available. 224 00:25:38,960 --> 00:25:46,960 We are available, Your Honor, and we would like to have the opportunity to meet with the folks from Whiten Case. 225 00:25:46,960 --> 00:25:55,960 We would also like to include in that conversation the Securities Commission of Bahamas, who we think is an essential party to this conversation. 226 00:25:55,960 --> 00:26:06,960 So look, I think our view is that we would be amenable to mediation. We believe that before you go to mediation, you should at least sit down and try to talk about it. 227 00:26:06,960 --> 00:26:18,960 We know that the commission has U.S. counsel because they have contacted us on other matters, and we believe that there hopefully now with Mr. Franklin's freedom of custody in the Bahamas, 228 00:26:18,960 --> 00:26:26,960 there might be a way forward that we can move along with a cooperative relationship. 229 00:26:26,960 --> 00:26:36,960 If this is going to be an attempt to seize control of these debtor's cases and movements of Bahamas, we will fight them with all our strength. 230 00:26:36,960 --> 00:26:46,960 Let me ask, is there anyone on the call from the Bahamian Securities Commission just by chance? 231 00:26:46,960 --> 00:26:50,960 Yes, Your Honor. This is Blair Rennie from Brown-Redneck. 232 00:26:50,960 --> 00:26:54,960 And this is Kenneth Ouellette also from Brown-Redneck, Your Honor. 233 00:26:54,960 --> 00:26:58,960 You can turn your cameras on so I can see you, please. 234 00:26:58,960 --> 00:27:13,960 And just to be clear, Your Honor, while we're attending the hearing, to observe, we are not entering a appearance, and the Bahamas Security Commission is not consenting to personal jurisdiction in this court. 235 00:27:13,960 --> 00:27:23,960 Well, I was only going to ask if you were willing to sit down with the joint liquidators and the debtors here to talk about a path forward. 236 00:27:23,960 --> 00:27:29,960 Your Honor, we will take it back to our client. We are always happy to discuss. 237 00:27:29,960 --> 00:27:37,960 Okay. I think it would be helpful, might help resolve some of the concerns that the debtors here have, if they can talk to the Commission. 238 00:27:37,960 --> 00:27:45,960 So I would highly recommend doing that and encourage the Commission to participate in that discussion. 239 00:27:45,960 --> 00:28:04,960 All right. So I'll leave the 16th on then as a status conference to see where we are on this issue, on the motion to – our motion for release from the automatic stay and the turnover of the records. 240 00:28:04,960 --> 00:28:11,960 And we'll go from there. We'll discuss – I didn't set a date – did I set a date for that one? I didn't set a date. 241 00:28:11,960 --> 00:28:20,960 We'll talk about that on Friday, I guess, when that would – or did I set it for – that's what I set for the 6th, right? January 6th. Yes. Okay. 242 00:28:20,960 --> 00:28:34,960 So that's set for the 6th. And we'll discuss on Friday, see where we are, and see if it's necessary to go forward on the 6th, or if there's something else I can do to help accommodate the party's attempts at mediation. 243 00:28:34,960 --> 00:28:37,960 Good. What time on Friday, Your Honor? 244 00:28:37,960 --> 00:28:41,960 It is currently scheduled at 10 a.m. And we'll just leave it at 10. 245 00:28:41,960 --> 00:28:43,960 Very good. Okay. 246 00:28:43,960 --> 00:28:44,960 All right. 247 00:28:44,960 --> 00:28:46,960 And we'll be busy between now and then. 248 00:28:46,960 --> 00:28:51,960 I'll bet. Anything else? Mr. Landis, you turned your camera on. Do you have anything else? 249 00:28:51,960 --> 00:29:05,960 Yes, I did, Your Honor. I just wanted to note for the record that Adam Landis, Landis Raffin, Co-Counsel to the Debtors, we will file an amended agenda reflecting Your Honor's rulings in the moving of the various hearings. 250 00:29:05,960 --> 00:29:09,960 We'll get that on the file as soon as possible. Okay. Great. Thank you. I appreciate that. 251 00:29:09,960 --> 00:29:13,960 Okay. Anything else before we adjourn? 252 00:29:13,960 --> 00:29:23,960 Well, thank you, everybody. I appreciate everyone getting on the call on short notice, and hopefully we can continue to talk and move these things forward. 253 00:29:23,960 --> 00:29:26,960 Until then, I'll see everybody on Friday morning. 254 00:29:26,960 --> 00:29:27,960 Thank you very much, Your Honor. 255 00:29:27,960 --> 00:29:37,960 We're adjourned.