1 00:00:00,000 --> 00:00:24,800 We're ready, Kea? 2 00:00:24,800 --> 00:00:25,800 Good morning. 3 00:00:25,800 --> 00:00:27,100 This is Judge Kaplan. 4 00:00:27,100 --> 00:00:37,920 We will start our omnibus, albeit reduced omnibus, BlockFi hearing, set of hearings. 5 00:00:37,920 --> 00:00:38,920 Good morning, counsel. 6 00:00:38,920 --> 00:00:41,920 Let me have appearances, please. 7 00:00:41,920 --> 00:00:42,920 Good morning, Your Honor. 8 00:00:42,920 --> 00:00:46,920 Richard Canowitz, Haynes & Boone, proposed counsel for the debtors and debtors in possession. 9 00:00:46,920 --> 00:00:49,920 Along with me is Jordan Chavez of Haynes & Boone. 10 00:00:49,920 --> 00:00:50,920 All right. 11 00:00:50,920 --> 00:00:54,920 I'll take other appearances as counsel rise to speak. 12 00:00:54,920 --> 00:00:56,680 Your Honor, you are right. 13 00:00:56,680 --> 00:01:01,880 Today should be a rather straightforward day, and we would ask to proceed down the agenda 14 00:01:01,880 --> 00:01:03,400 in order. 15 00:01:03,400 --> 00:01:07,800 We are thankful for the constructive comments and resolution of matters by the Office of 16 00:01:07,800 --> 00:01:13,200 the United States Trustee, as well as the Official Committee of Unsecured Creditors. 17 00:01:13,200 --> 00:01:18,600 You'll see many, many red lines, but we are all in agreement that, subject to Your Honor's 18 00:01:18,600 --> 00:01:22,000 approval, these motions should be granted in accordance with those orders. 19 00:01:22,000 --> 00:01:23,000 That's fine. 20 00:01:23,000 --> 00:01:28,840 I appreciate the work of everybody through this morning, possibly. 21 00:01:28,840 --> 00:01:33,720 On the Zoom today is Mr. Mark Renzi. 22 00:01:33,720 --> 00:01:37,200 He was going to appear in person, but weather has trapped him in Boston. 23 00:01:37,200 --> 00:01:42,580 So we appreciate, Your Honor, allowing him to testify, if necessary, through Zoom. 24 00:01:42,580 --> 00:01:47,240 We don't anticipate any cross-examination, but for the record, he did have a second-day 25 00:01:47,240 --> 00:01:51,000 declaration that we'd ask to be submitted under. 26 00:01:51,000 --> 00:01:54,720 It supports various motions that we've made on the second day. 27 00:01:54,720 --> 00:01:56,200 I've read through the declaration. 28 00:01:56,200 --> 00:01:59,280 I'll accept counsel's proffer. 29 00:01:59,280 --> 00:02:04,800 I welcome Mr. Renzi's examination, Mr. Renzi, if needed. 30 00:02:04,800 --> 00:02:05,800 Let's see how we proceed. 31 00:02:05,800 --> 00:02:10,240 Thank you, Your Honor, and at this time, I would cede the podium to Ms. Chavez. 32 00:02:10,240 --> 00:02:11,720 All right. 33 00:02:11,720 --> 00:02:13,720 Good morning, Ms. Chavez. 34 00:02:13,720 --> 00:02:16,200 Good morning, Your Honor. 35 00:02:16,200 --> 00:02:22,400 For the record, Jordan Chavez with Haynes & Boone on behalf of the debtors. 36 00:02:22,400 --> 00:02:27,040 As Mr. Canowitz mentioned, we'd just like to highlight some of the changes we've made 37 00:02:27,040 --> 00:02:31,520 to the orders for Your Honor with the constructive comments we've received from the Committee 38 00:02:31,520 --> 00:02:33,840 and the U.S. Trustee. 39 00:02:33,840 --> 00:02:39,200 I do have copies of revised proposed orders for Your Honor for matters one through six 40 00:02:39,200 --> 00:02:42,600 on the agenda, if I may approach and provide those to you. 41 00:02:42,600 --> 00:02:43,600 Yes, please. 42 00:02:43,600 --> 00:02:54,360 Thank you. 43 00:02:54,360 --> 00:02:58,600 Your Honor, beginning on item number one of the agenda that we filed at docket number 44 00:02:58,600 --> 00:03:03,700 294 is our tax motion that we filed at docket number nine. 45 00:03:03,700 --> 00:03:09,800 We filed a notice of revised proposed order for the tax motion at docket number 267. 46 00:03:09,800 --> 00:03:15,200 The main changes to this order are on page three, we've just clarified that the debtors 47 00:03:15,200 --> 00:03:21,400 are authorized but not directed to also pay penalties that may have been incurred pre-petition 48 00:03:21,400 --> 00:03:22,880 for some taxes. 49 00:03:22,880 --> 00:03:28,600 And then paragraph six just adds the requested language from the SEC that was in the interim 50 00:03:28,600 --> 00:03:31,360 order that has been carried over to the final order. 51 00:03:31,360 --> 00:03:36,840 We did not receive any other comments from the Committee or the Trustee on this particular 52 00:03:36,840 --> 00:03:37,840 final order. 53 00:03:37,840 --> 00:03:42,520 We would ask that Your Honor grant the motion on a final basis and enter the proposed final 54 00:03:42,520 --> 00:03:44,400 order after the hearing. 55 00:03:44,400 --> 00:03:45,400 All right. 56 00:03:45,400 --> 00:03:50,480 As far as going forward this morning, Mr. Sponder, to the extent you have a specific 57 00:03:50,480 --> 00:03:55,460 concern that hasn't been addressed and you're working out the language or you want to apprise 58 00:03:55,460 --> 00:04:01,480 the Court of any specific issues, I'll just wait for you to come and approach the podium. 59 00:04:01,480 --> 00:04:08,080 Otherwise, I'll assume that the U.S. Trustee has signed off or has viewed the language 60 00:04:08,080 --> 00:04:09,080 in the proposals. 61 00:04:09,080 --> 00:04:10,080 Good morning, Your Honor. 62 00:04:10,080 --> 00:04:13,000 Jeff Sponder from the Office of the United States Trustee. 63 00:04:13,000 --> 00:04:17,360 To make it easy, the United States Trustee has signed off on all of these orders that 64 00:04:17,360 --> 00:04:19,840 are being presented today, Your Honor. 65 00:04:19,840 --> 00:04:21,120 Can't be easier than that. 66 00:04:21,120 --> 00:04:26,120 I was going to say the same for the Committee. 67 00:04:26,120 --> 00:04:30,080 Your Honor, Kenneth Allett of Brown-Rudnick proposed counsel for the Committee. 68 00:04:30,080 --> 00:04:36,400 The Committee likewise has signed off on all of the proposed orders for today. 69 00:04:36,400 --> 00:04:38,120 Is the result of all this acquiescence? 70 00:04:38,120 --> 00:04:41,320 Everybody was just busy watching football this weekend? 71 00:04:41,320 --> 00:04:42,320 Yeah. 72 00:04:42,320 --> 00:04:43,320 Go ahead. 73 00:04:43,320 --> 00:04:47,480 Please note the number of trees killed, please. 74 00:04:47,480 --> 00:04:48,480 All right. 75 00:04:48,480 --> 00:04:52,640 We had everything resolved before last night. 76 00:04:52,640 --> 00:04:54,840 Item number two on the agenda. 77 00:04:54,840 --> 00:04:56,440 Just a quick question, then. 78 00:04:56,440 --> 00:05:04,400 Will we be getting final orders, complete ones, later this morning? 79 00:05:04,400 --> 00:05:08,000 We're happy to submit that to Chambers if that's the easiest way for you, Your Honor. 80 00:05:08,000 --> 00:05:09,000 I think that's easiest. 81 00:05:09,000 --> 00:05:10,000 Sure. 82 00:05:10,000 --> 00:05:11,000 All right. 83 00:05:11,000 --> 00:05:12,000 Thank you. 84 00:05:12,000 --> 00:05:13,000 After the hearing, we'll submit all the proposed orders. 85 00:05:13,000 --> 00:05:14,000 Right. 86 00:05:14,000 --> 00:05:15,000 So we'll mark it granted in order to be submitted. 87 00:05:15,000 --> 00:05:16,900 Thank you, Your Honor. 88 00:05:16,900 --> 00:05:20,960 Number two is the utility motion that we filed at Dock at number 10. 89 00:05:20,960 --> 00:05:27,080 We did receive some informal comments from the United States Trustee, and we did add 90 00:05:27,080 --> 00:05:29,000 the Committee as a notice party. 91 00:05:29,000 --> 00:05:34,560 So the main changes for this order are in the Notice of Revised Proposed Order that 92 00:05:34,560 --> 00:05:38,120 we filed at Dock at number 293. 93 00:05:38,120 --> 00:05:43,440 Paragraph three is just clarifying the amount of adequate assurance deposit rather than 94 00:05:43,440 --> 00:05:47,440 just referencing 50% of the monthly amount. 95 00:05:47,440 --> 00:05:50,680 Again, added the Committee as a notice party. 96 00:05:50,680 --> 00:05:58,560 We imposed a duty on the debtors to set a hearing if there's delinquency notices that 97 00:05:58,560 --> 00:06:01,720 we cannot resolve or objections filed. 98 00:06:01,720 --> 00:06:06,480 And then paragraph eight just provides a service deadline of two days upon entry of the order 99 00:06:06,480 --> 00:06:08,880 to all of the utility parties. 100 00:06:08,880 --> 00:06:12,400 And then paragraph 11 is the SEC's requested language. 101 00:06:12,400 --> 00:06:18,400 Again, no objections were received to the utility motion, and we'll ask this Court 102 00:06:18,400 --> 00:06:22,040 to grant it on a final basis. 103 00:06:22,040 --> 00:06:27,680 All right, I'm just looking at the SEC language. 104 00:06:27,680 --> 00:06:29,880 We'll reserve that fun issue for another day. 105 00:06:29,880 --> 00:06:33,920 All right, again, we'll mark it in order to be submitted. 106 00:06:33,920 --> 00:06:34,920 Thank you, granted. 107 00:06:34,920 --> 00:06:36,600 Thank you, Your Honor. 108 00:06:36,600 --> 00:06:42,480 Item number three is the insurance motion that we filed at Dock at number 11. 109 00:06:42,480 --> 00:06:46,760 We did receive some informal comments from the Committee, from the Trustee, and from 110 00:06:46,760 --> 00:06:49,880 some of the insurance and sorority bond providers. 111 00:06:49,880 --> 00:06:54,960 We filed a notice of revised proposed order at Dock at number 268. 112 00:06:54,960 --> 00:06:59,040 The notable changes in that order, Your Honor, are paragraph five. 113 00:06:59,040 --> 00:07:03,160 We've agreed to give the Committee consent rights for payments that are proposed above 114 00:07:03,160 --> 00:07:05,200 $50,000. 115 00:07:05,200 --> 00:07:10,720 And the rest of the order is just clarifications from the insurance and bond providers and 116 00:07:10,720 --> 00:07:15,160 the carryover language from the interim order that it does not impact money transmitter 117 00:07:15,160 --> 00:07:16,160 bonds. 118 00:07:16,160 --> 00:07:20,560 No formal objections were received, and we'll ask the Court to grant this motion as well 119 00:07:20,560 --> 00:07:21,960 on a final basis. 120 00:07:21,960 --> 00:07:24,640 All right, granted, order to be submitted. 121 00:07:24,640 --> 00:07:25,640 Thank you. 122 00:07:25,640 --> 00:07:26,640 Thank you, Your Honor. 123 00:07:26,640 --> 00:07:35,200 Number four is the claimants motion or critical vendor motion that was filed originally on 124 00:07:35,200 --> 00:07:37,640 the first day at Dock at number 13. 125 00:07:37,640 --> 00:07:43,080 We filed a revised proposed order at Dock at number 292 after comments were received 126 00:07:43,080 --> 00:07:49,400 from the U.S. Trustee and the Committee, and we've agreed to include on page five of the 127 00:07:49,400 --> 00:07:53,000 order some reporting requirements and objection rights. 128 00:07:53,000 --> 00:07:57,560 So upon entry of the order, we will provide the Committee and the Trustee within 30 days 129 00:07:57,560 --> 00:08:04,480 just an updated report on the spending that's proposed in the critical vendor order, and 130 00:08:04,480 --> 00:08:09,560 of course the SEC language we've carried over from the interim order. 131 00:08:09,560 --> 00:08:13,560 We've received no formal objections to the critical vendor motion and would ask Your 132 00:08:13,560 --> 00:08:16,680 Honor to grant that on a final basis as well. 133 00:08:16,680 --> 00:08:17,880 All right. 134 00:08:17,880 --> 00:08:18,880 Thank you. 135 00:08:18,880 --> 00:08:21,400 Will market granted order be submitted? 136 00:08:21,400 --> 00:08:25,240 For counsel who are appearing remotely, I haven't forgotten about you all. 137 00:08:25,240 --> 00:08:28,960 If you wish to be heard, please just use the raise hand function. 138 00:08:28,960 --> 00:08:32,780 Otherwise, we'll just keep on proceeding. 139 00:08:32,780 --> 00:08:33,780 Thank you. 140 00:08:33,780 --> 00:08:34,880 Thank you, Your Honor. 141 00:08:34,880 --> 00:08:40,800 Item number five is a new motion that we filed, so we're moving on now to our second, some 142 00:08:40,800 --> 00:08:46,640 of our second day motions, and this was to set up procedures for rejection of executory 143 00:08:46,640 --> 00:08:49,040 contracts and unexpired leases. 144 00:08:49,040 --> 00:08:52,200 This was filed at Dock at number 122. 145 00:08:52,200 --> 00:08:57,120 We did receive some informal comments that we incorporated into the proposed order that 146 00:08:57,120 --> 00:09:01,720 we revised and filed at Dock at number 290. 147 00:09:01,720 --> 00:09:07,840 The main changes in the procedures after receiving comments are that we received language from 148 00:09:07,840 --> 00:09:12,960 the U.S. Trustee that clarifies the procedures and adds the committee as a notice party. 149 00:09:12,960 --> 00:09:16,660 We agreed to give some consent rights to the committee for rejections, creating claims 150 00:09:16,660 --> 00:09:23,400 over a million dollars, and paragraph 2E adds the debtor's duty to set a hearing if we receive 151 00:09:23,400 --> 00:09:29,360 objections and provide at least seven days notice of such a hearing. 152 00:09:29,360 --> 00:09:39,240 And just to clarify, rejection dates for both personal property leases and real estate are 153 00:09:39,240 --> 00:09:43,400 all as of the initial notice date, unless there's an objection? 154 00:09:43,400 --> 00:09:48,800 Yes, Your Honor, and there's a really limited amount of real property leases, but to the 155 00:09:48,800 --> 00:09:55,000 extent we were requesting retroactive rejection as of the notice, that would, of course, be 156 00:09:55,000 --> 00:10:01,960 if the keys are turned over and the property's been returned to the applicable landlord. 157 00:10:01,960 --> 00:10:02,960 Thank you. 158 00:10:02,960 --> 00:10:05,960 Again, granted, OTBS. 159 00:10:05,960 --> 00:10:08,640 Thank you, Your Honor. 160 00:10:08,640 --> 00:10:13,840 My last item is number six, which is our administrative fee procedures. 161 00:10:13,840 --> 00:10:16,840 We filed this at Dock at number 123. 162 00:10:16,840 --> 00:10:21,080 We received some comments from the Trustee and the committee that we incorporated and 163 00:10:21,080 --> 00:10:25,800 filed a notice of revised proposed order at Dock at number 269. 164 00:10:25,800 --> 00:10:30,520 The main changes to the order are, of course, adding in the committee once they were appointed 165 00:10:30,520 --> 00:10:35,640 and all the requested language from the U.S. Trustee just to clarify the procedures if 166 00:10:35,640 --> 00:10:40,840 they were to want to object to any of the fees. 167 00:10:40,840 --> 00:10:45,200 And there were no other formal objections received to those procedures, and we would 168 00:10:45,200 --> 00:10:48,960 ask the Court to grant the order on a final basis. 169 00:10:48,960 --> 00:10:50,680 All right. 170 00:10:50,680 --> 00:10:55,760 Granted, consistent with prior orders on these matters that the Court has approved. 171 00:10:55,760 --> 00:10:56,920 All right. 172 00:10:56,920 --> 00:10:58,520 Granted an order to be submitted. 173 00:10:58,520 --> 00:10:59,520 Thank you, Counsel. 174 00:10:59,520 --> 00:11:00,520 Thank you, Your Honor. 175 00:11:00,520 --> 00:11:04,520 I'll turn the podium back over to Mr. Canowitz to handle items seven and eight. 176 00:11:04,520 --> 00:11:05,520 Okay. 177 00:11:05,520 --> 00:11:11,000 Again, for the record, Richard Canowitz, Haines & Boone, proposed counsel to debtors 178 00:11:11,000 --> 00:11:12,000 and debtors in possession. 179 00:11:12,000 --> 00:11:17,000 Your Honor, I'm handling what is known as the Ordinary Course Professional Motion as 180 00:11:17,000 --> 00:11:18,480 well as the Loan Servicing Motion. 181 00:11:18,480 --> 00:11:21,280 I have copies of the redlined orders if you would like. 182 00:11:21,280 --> 00:11:22,280 Yes, please. 183 00:11:22,280 --> 00:11:23,280 Absolutely. 184 00:11:23,280 --> 00:11:24,280 Thank you. 185 00:11:24,280 --> 00:11:25,280 Thank you. 186 00:11:25,280 --> 00:11:37,600 The Ordinary Course Professional Motion, Your Honor, at Docket 124, standard fare in these 187 00:11:37,600 --> 00:11:42,960 type of proceedings, much of the language can be found in other orders that you approved 188 00:11:42,960 --> 00:11:45,480 in the LTL case, for example. 189 00:11:45,480 --> 00:11:49,440 It's heavily marked by the U.S. Trustee's Office, not because it was deficient, but 190 00:11:49,440 --> 00:11:53,240 rather because we wanted some clarification on certain things. 191 00:11:53,240 --> 00:11:57,600 Two points to note that I would say is a takeaway that may be different. 192 00:11:57,600 --> 00:12:02,160 One here, we are asking for the authority to give post-petition retainers to certain 193 00:12:02,160 --> 00:12:03,160 professionals. 194 00:12:03,160 --> 00:12:08,960 For example, Linworth Johnson in Antigua requested a $20,000 retainer in connection 195 00:12:08,960 --> 00:12:10,920 with the proceedings down there. 196 00:12:10,920 --> 00:12:14,760 It was a foreign representation. 197 00:12:14,760 --> 00:12:17,040 He is not familiar with the proceedings here. 198 00:12:17,040 --> 00:12:18,040 He asked for it. 199 00:12:18,040 --> 00:12:19,840 We agreed, subject to your honor, approving. 200 00:12:19,840 --> 00:12:20,840 Okay. 201 00:12:20,840 --> 00:12:25,240 That's the only one we anticipate actually providing, but the motion is flexible that 202 00:12:25,240 --> 00:12:29,080 the extent someone else comes forward, we will do that on notice. 203 00:12:29,080 --> 00:12:32,980 So that's one takeaway that you might not see in other types of Ordinary Course Professional 204 00:12:32,980 --> 00:12:34,720 Motions. 205 00:12:34,720 --> 00:12:39,200 The second big picture item is the fact that after six months, we're going to look at 206 00:12:39,200 --> 00:12:40,640 the aggregate cap. 207 00:12:40,640 --> 00:12:45,920 We probably may have to come back to expand it, but the trustee wanted us to have a revisit 208 00:12:45,920 --> 00:12:48,480 of where we are after six months. 209 00:12:48,480 --> 00:12:52,560 So to the extent we think we're going to go above the aggregate cap, we need to enhance 210 00:12:52,560 --> 00:12:55,880 it, increase it, we'll come back and we'll deal with those issues. 211 00:12:55,880 --> 00:12:56,880 In advance. 212 00:12:56,880 --> 00:12:57,880 In advance, right. 213 00:12:57,880 --> 00:12:58,880 No retroact. 214 00:12:58,880 --> 00:13:03,360 If any professional goes over the aggregate cap or monthly cap for three months in a row, 215 00:13:03,360 --> 00:13:06,600 they're supposed to make application and get retained. 216 00:13:06,600 --> 00:13:10,920 All of the typical procedures that you would see that to the extent that a party is actually 217 00:13:10,920 --> 00:13:15,320 handling large matters, case administration issues, we'll come back and the appropriate 218 00:13:15,320 --> 00:13:17,520 retention applications if necessary. 219 00:13:17,520 --> 00:13:18,520 All right. 220 00:13:18,520 --> 00:13:24,640 So we ask that the court grant that motion and we will submit it as Nishada said after 221 00:13:24,640 --> 00:13:25,640 court. 222 00:13:25,640 --> 00:13:26,640 Thank you. 223 00:13:26,640 --> 00:13:27,640 We'll mark it. 224 00:13:27,640 --> 00:13:30,440 Again, granted, order to be submitted. 225 00:13:30,440 --> 00:13:33,720 The next motion, your honor, that I will handle is on docket 125. 226 00:13:33,720 --> 00:13:36,920 That's what's known as the loan servicing motion. 227 00:13:36,920 --> 00:13:40,400 This is for institutional loan portfolio only. 228 00:13:40,400 --> 00:13:43,600 This is not for retail clients as we make clear. 229 00:13:43,600 --> 00:13:48,120 The aggregate amount of potential institutional loans is north of 900 million. 230 00:13:48,120 --> 00:13:52,560 So we're talking about a large portfolio that the debtor deals with on a day-to-day 231 00:13:52,560 --> 00:13:54,000 basis. 232 00:13:54,000 --> 00:13:59,280 As you can see, there's typical loan servicing types of things in there such as collections, 233 00:13:59,280 --> 00:14:06,000 forbearance, extensions, workouts, to the extent that we want to ultimately take a haircut, 234 00:14:06,000 --> 00:14:07,560 if you will, on any of the loans. 235 00:14:07,560 --> 00:14:10,960 There's procedures to give notice based on the threshold. 236 00:14:10,960 --> 00:14:14,240 Under a million dollars, pretty much do what you want. 237 00:14:14,240 --> 00:14:19,400 Million to five million, we're giving notice for people to respond, especially the committee, 238 00:14:19,400 --> 00:14:21,000 see if we have an objection. 239 00:14:21,000 --> 00:14:24,640 And then, of course, if there are any objections, about five million, put it out on notice for 240 00:14:24,640 --> 00:14:27,640 a hearing before your honor, if necessary. 241 00:14:27,640 --> 00:14:33,120 But this will allow the debtor to have flexibility to do things in the ordinary course. 242 00:14:33,120 --> 00:14:37,720 As you can imagine, many of the counterparties are distressed themselves, and we want to 243 00:14:37,720 --> 00:14:42,880 realize the highest value without litigation and court costs if possible. 244 00:14:42,880 --> 00:14:45,440 But to the extent we have to, we will come back to court. 245 00:14:45,440 --> 00:14:47,520 Loan servicing is all undertaken in-house? 246 00:14:47,520 --> 00:14:48,520 Yes. 247 00:14:48,520 --> 00:14:53,680 The debtor has extensive both financial and legal capabilities. 248 00:14:53,680 --> 00:14:58,480 And they've been doing this without us, without us bankruptcy lawyers. 249 00:14:58,480 --> 00:15:04,000 So this motion is just really a handoff back to them of what they've been doing, and doing 250 00:15:04,000 --> 00:15:07,240 it competently and well, for the benefit of the estate. 251 00:15:07,240 --> 00:15:14,000 So counsel that would be pursuing collection remedies or workouts or other efforts are 252 00:15:14,000 --> 00:15:17,560 part of the ordinary course professionals, for the most part? 253 00:15:17,560 --> 00:15:22,240 To the extent that we might need a specific collection lawyer in a specific jurisdiction, 254 00:15:22,240 --> 00:15:25,720 we would add that to the ordinary course professional. 255 00:15:25,720 --> 00:15:26,720 That's my contemplation. 256 00:15:26,720 --> 00:15:30,480 If it becomes something much larger, of course we'll come back to court if we believe that 257 00:15:30,480 --> 00:15:34,800 it runs afoul of any of your honors orders. 258 00:15:34,800 --> 00:15:40,680 The other thing to note about this motion is BlockFi International has some institutional 259 00:15:40,680 --> 00:15:41,680 loan portfolios. 260 00:15:41,680 --> 00:15:47,560 The JPLs out of Bermuda were hesitant in connection with this motion. 261 00:15:47,560 --> 00:15:51,200 That's why you'll see throughout the motion and the order there are certain carve-outs. 262 00:15:51,200 --> 00:15:56,040 And likewise, that we agree that they must seek orders in their court so that they become 263 00:15:56,040 --> 00:16:01,200 comfortable with what we're doing if it impacts BlockFi International loan. 264 00:16:01,200 --> 00:16:04,200 We don't believe there are many loans that fall into that bucket, but notwithstanding 265 00:16:04,200 --> 00:16:08,760 that fact, we want to make one motion, put it before your honor, to cover the enterprise 266 00:16:08,760 --> 00:16:11,040 as opposed to separate debtors. 267 00:16:11,040 --> 00:16:16,800 And again, just for clarification, maybe for the participants who are watching, this does 268 00:16:16,800 --> 00:16:19,360 not concern the retail customers? 269 00:16:19,360 --> 00:16:20,360 Nope. 270 00:16:20,360 --> 00:16:21,360 Correct. 271 00:16:21,360 --> 00:16:24,080 It's made clear in the motion and the wrap. 272 00:16:24,080 --> 00:16:25,080 All right. 273 00:16:25,080 --> 00:16:26,080 Thank you. 274 00:16:26,080 --> 00:16:27,080 Thank you, your honor. 275 00:16:27,080 --> 00:16:28,080 And now it's... 276 00:16:28,080 --> 00:16:29,080 The motion will be granted, order to be submitted. 277 00:16:29,080 --> 00:16:30,080 Thank you, your honor. 278 00:16:30,080 --> 00:16:31,080 I'll see the podium. 279 00:16:31,080 --> 00:16:32,080 Good morning. 280 00:16:32,080 --> 00:16:33,080 Good morning, your honor. 281 00:16:33,080 --> 00:16:40,080 Francis Petrie of Kirkland, Post-Council for the Debtors. 282 00:16:40,080 --> 00:16:47,960 I'll be taking us through the next few items on the agenda, all of which bring us back 283 00:16:47,960 --> 00:16:52,540 to final orders for relief that was already granted on the first day of these cases. 284 00:16:52,540 --> 00:16:56,960 We filed revised proposed orders on the docket approximately 48 hours ago. 285 00:16:56,960 --> 00:16:58,560 The orders have not changed since then. 286 00:16:58,560 --> 00:17:02,960 However, I do have red lines to the forms of final order that we filed with the original 287 00:17:02,960 --> 00:17:03,960 motions for convenience. 288 00:17:03,960 --> 00:17:04,960 May I approach? 289 00:17:04,960 --> 00:17:05,960 Yes, please. 290 00:17:05,960 --> 00:17:06,960 Thank you. 291 00:17:06,960 --> 00:17:07,960 Okay. 292 00:17:07,960 --> 00:17:23,640 Your honor, so the first item is the order on NOLs or equity trading procedures. 293 00:17:23,640 --> 00:17:28,520 There have been no material updates to the language of this order from the interim stage. 294 00:17:28,520 --> 00:17:31,680 This has been circulated to the U.S. Trustee and the committee, and they are signed off 295 00:17:31,680 --> 00:17:32,680 on it as represented. 296 00:17:32,680 --> 00:17:38,120 In addition, I can confirm to address your concerns at the first day hearing that the 297 00:17:38,120 --> 00:17:41,840 equity holders that are implicated by this order were all served with the motion and 298 00:17:41,840 --> 00:17:47,440 the interim order on December 1st and had notice of this final hearing. 299 00:17:47,440 --> 00:17:49,680 Nobody spoke up or provided comments. 300 00:17:49,680 --> 00:17:53,000 So unless your honor has any questions, I respectfully ask you to enter this order on 301 00:17:53,000 --> 00:17:54,080 a final basis. 302 00:17:54,080 --> 00:17:55,560 Just a quick question. 303 00:17:55,560 --> 00:18:06,680 The order contemplates sending out advance notice of the procedures to all equity holders, 304 00:18:06,680 --> 00:18:07,680 correct? 305 00:18:07,680 --> 00:18:09,960 Not just the ones who are currently 4.5%? 306 00:18:09,960 --> 00:18:10,960 Yes. 307 00:18:10,960 --> 00:18:15,200 Then, in the back of my mind, it's not on for today. 308 00:18:15,200 --> 00:18:24,280 When we had one of the motions with respect to redaction, it was to limit notice to equity 309 00:18:24,280 --> 00:18:27,280 holders, was it not? 310 00:18:27,280 --> 00:18:32,120 I thought there was a pending motion, and it seemed inconsistent, that it would be too 311 00:18:32,120 --> 00:18:37,040 burdensome on the debtor to notice all equity holders because you were not sure who's holding 312 00:18:37,040 --> 00:18:39,920 the stock on a specific date. 313 00:18:39,920 --> 00:18:46,760 I was wondering if it's too burdensome then, why are we able to do it now? 314 00:18:46,760 --> 00:18:48,200 Unless I have that other motion wrong. 315 00:18:48,200 --> 00:18:51,600 Your Honor, Jordan Chavez for the record. 316 00:18:51,600 --> 00:18:57,800 On the first day, we filed a motion to waive the requirement to file an equity holder list. 317 00:18:57,800 --> 00:19:01,800 So that was the relief we were seeking in addition to consolidation and redaction. 318 00:19:01,800 --> 00:19:07,280 I thought there was a requirement, too, to waive the notice of requirement of future 319 00:19:07,280 --> 00:19:13,760 events that occurred during the bankruptcy, from financing to disclosure on equity holders. 320 00:19:13,760 --> 00:19:14,760 Do I have it wrong? 321 00:19:14,760 --> 00:19:20,160 Your Honor, I'd have to go back and look at the language, but I think what Mr. Petrie 322 00:19:20,160 --> 00:19:24,600 is saying through the NOL motion, and now that the dust has settled, I think we are 323 00:19:24,600 --> 00:19:30,640 able to serve the equity holders with this type of notice in order to get this relief 324 00:19:30,640 --> 00:19:32,920 that is very much needed for the debtors. 325 00:19:32,920 --> 00:19:36,480 Maybe we just revisit that other motion. 326 00:19:36,480 --> 00:19:38,440 I thought it was more expansive. 327 00:19:38,440 --> 00:19:44,000 I thought it referenced how difficult and cumbersome it would be to serve all equity 328 00:19:44,000 --> 00:19:47,600 holders, and it seemed inconsistent. 329 00:19:47,600 --> 00:19:50,120 So we can revisit that. 330 00:19:50,120 --> 00:19:51,980 That's obviously being deferred. 331 00:19:51,980 --> 00:19:54,120 So we can revisit that at a later point. 332 00:19:54,120 --> 00:19:55,960 I definitely revisit that in the order. 333 00:19:55,960 --> 00:19:59,280 As you can imagine, we're in less of a scramble now than we were when we were initially filing 334 00:19:59,280 --> 00:20:00,280 this case. 335 00:20:00,280 --> 00:20:03,520 So we'll discuss the actual terms of that form of order going forward. 336 00:20:03,520 --> 00:20:04,520 All right. 337 00:20:04,520 --> 00:20:07,160 So this motion will be granted, order to be submitted. 338 00:20:07,160 --> 00:20:11,160 Thank you, Your Honor. 339 00:20:11,160 --> 00:20:17,680 Okay, so next is the debtor's final wages order. 340 00:20:17,680 --> 00:20:20,480 Again, there's no significant changes from the interim stage. 341 00:20:20,480 --> 00:20:24,880 The red line changes all reflect from forming edits to the entered order – the entered 342 00:20:24,880 --> 00:20:26,280 interim order. 343 00:20:26,280 --> 00:20:29,480 We discussed this order with parties in interest, the U.S. Trustee, and the committee, and they've 344 00:20:29,480 --> 00:20:30,560 all signed off. 345 00:20:30,560 --> 00:20:34,080 So unless Your Honor has any questions, again, we respectfully ask that you grant the relief 346 00:20:34,080 --> 00:20:35,760 requested on a final basis. 347 00:20:35,760 --> 00:20:38,680 I do not review it initially. 348 00:20:38,680 --> 00:20:41,840 The motion will be granted. 349 00:20:41,840 --> 00:20:46,200 I would say just even if there's been no changes to the order, send us down all the 350 00:20:46,200 --> 00:20:50,240 orders from today's hearings in one package so we have clarity. 351 00:20:50,240 --> 00:20:55,240 We'll be sure to do that, Your Honor. 352 00:20:55,240 --> 00:20:57,240 Thank you. 353 00:20:57,240 --> 00:20:59,600 All right. 354 00:20:59,600 --> 00:21:02,320 And so next is the debtor's final cash management order. 355 00:21:02,320 --> 00:21:07,000 The changes reflected in this red line show comments from certain cash management banks 356 00:21:07,000 --> 00:21:11,160 that wanted to clarify their relationships with the debtors, comments from the committee 357 00:21:11,160 --> 00:21:15,680 about the ability to move crypto externally outside of the ordinary course wallets and 358 00:21:15,680 --> 00:21:20,080 custodians that the company currently does things with, and comments from the United 359 00:21:20,080 --> 00:21:21,400 States Trustee. 360 00:21:21,400 --> 00:21:24,720 Some of these are conforming changes from the interim order, as discussed, but others 361 00:21:24,720 --> 00:21:29,080 are updating the order for the current state of affairs with regards to complying with 362 00:21:29,080 --> 00:21:35,160 the 345B guidelines and the debtor's post-petition obligations. 363 00:21:35,160 --> 00:21:39,480 I'd like to note that the U.S. Trustee did file a formal objection to this order, but 364 00:21:39,480 --> 00:21:44,200 we believe we've resolved that objection by adjusting the requested super priority status 365 00:21:44,200 --> 00:21:46,640 of the intercompany loans to administrative priority. 366 00:21:46,640 --> 00:21:50,720 I spoke to Mr. Sponder of the Office of the U.S. Trustee, and he's comfortable believing 367 00:21:50,720 --> 00:21:54,360 that we have resolved this objection with this form of order. 368 00:21:54,360 --> 00:21:57,760 So unless, Your Honor, there's any questions with this being consensual, we ask that you 369 00:21:57,760 --> 00:21:59,760 grant the relief sought here on a final basis. 370 00:21:59,760 --> 00:22:00,760 All right. 371 00:22:00,760 --> 00:22:05,360 So, Mr. Sponder, it does address the concern on the super priority nature of intercompany 372 00:22:05,360 --> 00:22:07,360 loans that you had? 373 00:22:07,360 --> 00:22:09,360 Good morning again, Your Honor. 374 00:22:09,360 --> 00:22:11,280 Jeff Sponder from the Office of the United States Trustee. 375 00:22:11,280 --> 00:22:12,280 It does. 376 00:22:12,280 --> 00:22:13,280 Okay. 377 00:22:13,280 --> 00:22:18,720 Then I'll – will mark it granted with the limited objection the U.S. Trustee was – having 378 00:22:18,720 --> 00:22:19,720 been resolved. 379 00:22:19,720 --> 00:22:22,400 Thank you, Your Honor, and we'll submit all of these to chambers after the hearing. 380 00:22:22,400 --> 00:22:23,400 Thank you. 381 00:22:23,400 --> 00:22:26,400 With that, I'll turn the podium over to committees' counsel. 382 00:22:26,400 --> 00:22:29,400 All right. 383 00:22:29,400 --> 00:22:33,200 Good morning, Your Honor. 384 00:22:33,200 --> 00:22:38,440 Again, Kenneth Allett of Brown-Rudnick, proposed counsel to the committee. 385 00:22:38,440 --> 00:22:46,120 I am joined by Don Clark of Genova-Burns, proposed local counsel to the committee. 386 00:22:46,120 --> 00:22:50,280 With me also in the courtroom is a member of the committee, Corey Grossman. 387 00:22:50,280 --> 00:22:56,240 I just wanted to note that Mr. Stark, my partner, spoke a lot at the previous hearing about 388 00:22:56,240 --> 00:23:02,280 how diligent the committee is, and even though this is a fully consensual hearing today, 389 00:23:02,280 --> 00:23:06,760 the committee still felt it was important, and Mr. Grossman is here. 390 00:23:06,760 --> 00:23:07,760 And Mr. Grossman is – 391 00:23:07,760 --> 00:23:08,760 Good morning, Your Honor. 392 00:23:08,760 --> 00:23:09,760 Good morning. 393 00:23:09,760 --> 00:23:10,760 Welcome. 394 00:23:10,760 --> 00:23:12,760 Thank you. 395 00:23:12,760 --> 00:23:18,160 As discussed, the committee does not object to any of the second-day motions that are 396 00:23:18,160 --> 00:23:19,840 being entered today. 397 00:23:19,840 --> 00:23:24,440 We appreciate the ability to get our informal comments on those resolved. 398 00:23:24,440 --> 00:23:30,120 The only thing for the committee today is, if Your Honor is prepared, we have a consent 399 00:23:30,120 --> 00:23:33,120 order on the committee's motion to intervene in the next meeting. 400 00:23:33,120 --> 00:23:34,120 I did see that. 401 00:23:34,120 --> 00:23:36,120 It was submitted to chambers this morning. 402 00:23:36,120 --> 00:23:37,120 Yeah, I looked through it. 403 00:23:37,120 --> 00:23:38,120 I have no objection to it. 404 00:23:38,120 --> 00:23:39,600 We'll be entering that order. 405 00:23:39,600 --> 00:23:40,600 Okay. 406 00:23:40,600 --> 00:23:42,600 And that's all for the committee, Your Honor. 407 00:23:42,600 --> 00:23:43,600 Thank you. 408 00:23:43,600 --> 00:23:44,600 All right. 409 00:23:44,600 --> 00:23:45,600 Thank you. 410 00:23:45,600 --> 00:23:46,600 Mr. Canowitz. 411 00:23:46,600 --> 00:23:47,600 Yes, Your Honor. 412 00:23:47,600 --> 00:23:50,800 Dan Richard Canowitz, Hansen-Buhn, proposed counsel of debtors and possession. 413 00:23:50,800 --> 00:23:55,120 I think, given the committee intervention, I think it's good to circle back from our 414 00:23:55,120 --> 00:23:57,480 last hearing just to give you a status update of where we are. 415 00:23:57,480 --> 00:23:59,800 I'm not going to talk about anything on the merits. 416 00:23:59,800 --> 00:24:04,320 No party has to worry about what I'm going to say, but if they want to chime in, if to 417 00:24:04,320 --> 00:24:07,440 the extent they're on Zoom, so be it. 418 00:24:07,440 --> 00:24:12,280 Coming out of last hearing, Your Honor made certain, I would say, admonishments, directions. 419 00:24:12,280 --> 00:24:15,880 I hope that the parties and parties in interest heard them. 420 00:24:15,880 --> 00:24:21,960 I can tell you that the FTX debtors have requested from Judge Dorsey has been granted to mark 421 00:24:21,960 --> 00:24:24,480 off without date their motion to stay. 422 00:24:24,480 --> 00:24:27,000 We'll be in contact with them in due course. 423 00:24:27,000 --> 00:24:33,880 Likewise, our motion to preclude certain testimony in that proceeding in connection with their 424 00:24:33,880 --> 00:24:36,880 stay motion was also adjourned without date. 425 00:24:36,880 --> 00:24:42,480 So we are not facing a January 20th motion in Judge Dorsey's courtroom. 426 00:24:42,480 --> 00:24:49,000 Because two, the JPLs in Antigua are proceeding on the petition, the windup petition there 427 00:24:49,000 --> 00:24:51,840 on January 27th. 428 00:24:51,840 --> 00:24:57,760 We were compelled to file papers by January 9th in connection with that proceeding. 429 00:24:57,760 --> 00:25:00,520 Our papers are very straightforward. 430 00:25:00,520 --> 00:25:03,220 We don't object to the windup per se. 431 00:25:03,220 --> 00:25:08,520 We object to the language in direction 4.3 that was pointed out in prior pleadings filed 432 00:25:08,520 --> 00:25:12,880 in this court that would touch upon the pledge issue. 433 00:25:12,880 --> 00:25:17,840 We've asked for a stay of that portion of that windup petition to the extent they could 434 00:25:17,840 --> 00:25:23,400 do that, or alternatively a forum nonconvenience argument since the pledge agreement has arbitration 435 00:25:23,400 --> 00:25:25,400 in New York under Delaware law. 436 00:25:25,400 --> 00:25:27,760 We do not know what's going to happen down there. 437 00:25:27,760 --> 00:25:29,600 On the 27th, it may go forward. 438 00:25:29,600 --> 00:25:31,120 It may be assigned to another judge. 439 00:25:31,120 --> 00:25:35,200 We will report back once we know what the outcome is there. 440 00:25:35,200 --> 00:25:40,960 We've also had discussions with all the various parties about the proposed amended complaint 441 00:25:40,960 --> 00:25:43,120 that we are going to be filing. 442 00:25:43,120 --> 00:25:48,240 At this time, it was our goal to file the amended complaint by January 20th. 443 00:25:48,240 --> 00:25:50,220 We have a draft in process. 444 00:25:50,220 --> 00:25:52,640 It may be delayed for the following reason. 445 00:25:52,640 --> 00:25:57,000 We had a very, from my perspective, productive call with the Department of Justice, both 446 00:25:57,000 --> 00:26:01,660 the criminal side as well as the civil side, and their bankruptcy counsel as well. 447 00:26:01,660 --> 00:26:05,320 They would like to take a look at our amended complaint. 448 00:26:05,320 --> 00:26:08,160 Clearly they have the seizure and forfeiture in mind. 449 00:26:08,160 --> 00:26:12,520 We are not making the government a defendant in the adversary proceeding. 450 00:26:12,520 --> 00:26:19,000 In fact, we're not making the FTX debtors a defendant in the adversary proceeding. 451 00:26:19,000 --> 00:26:24,440 This amended complaint will address emergent, and whoever speaks for emergent will come 452 00:26:24,440 --> 00:26:26,960 to court and speak for emergent in this court. 453 00:26:26,960 --> 00:26:32,920 Likewise, again, it's MARICS, and it will explain in further detail all of the relief 454 00:26:32,920 --> 00:26:35,400 we seek in that amended complaint. 455 00:26:35,400 --> 00:26:40,080 We got on the phone before we spoke with the DOJ, with the defendants, among others, in 456 00:26:40,080 --> 00:26:44,960 connection with the intervention motion, if you will, by the committee, because it led 457 00:26:44,960 --> 00:26:47,560 to a natural discussion. 458 00:26:47,560 --> 00:26:49,920 We agreed that we're filing the amended complaint. 459 00:26:49,920 --> 00:26:51,960 We're not going to try to jam anyone. 460 00:26:51,960 --> 00:26:57,040 The only under your honor's scheduling order was February 15th to respond to the complaint. 461 00:26:57,040 --> 00:26:59,520 We agreed to move that back to March 15th. 462 00:26:59,520 --> 00:27:08,080 To the extent that the DOJ and the state is discussing the amended complaint for the purposes 463 00:27:08,080 --> 00:27:13,800 of, again, your honor, to try to limit litigation and to not step on toes, we're respectful 464 00:27:13,800 --> 00:27:16,600 of their process and hopefully they're respectful of our process. 465 00:27:16,600 --> 00:27:21,680 But to the extent that we need to move forward on the amended complaint, we're going to try 466 00:27:21,680 --> 00:27:23,080 to work things out with the DOJ. 467 00:27:23,080 --> 00:27:24,480 If not, we'll file it. 468 00:27:24,480 --> 00:27:28,680 But as to the defendants, we'll give them whatever time they need to respond. 469 00:27:28,680 --> 00:27:34,000 So right now, the goal is hopefully to file this by January 20th, if it gets pushed a 470 00:27:34,000 --> 00:27:35,000 little. 471 00:27:35,000 --> 00:27:39,200 Likewise, the response date is from February 15th to March 15th. 472 00:27:39,200 --> 00:27:43,280 And I believe we should come before your honor, hopefully on January 30th, with a request 473 00:27:43,280 --> 00:27:46,000 to amend your honor's order for the pre-trial schedule. 474 00:27:46,000 --> 00:27:47,580 And it was really straightforward. 475 00:27:47,580 --> 00:27:52,760 And then, of course, adjourn the pre-trial conference that's on for some time later anyway. 476 00:27:52,760 --> 00:27:57,640 So we're not going to trip any deadlines in this court, but I want to give parties an 477 00:27:57,640 --> 00:27:59,840 understanding of what's at play here. 478 00:27:59,840 --> 00:28:04,480 The government has requested certain things, and I think it's incumbent upon us to at least 479 00:28:04,480 --> 00:28:08,720 discuss with them their concerns, if any, in connection with the amended complaint. 480 00:28:08,720 --> 00:28:09,720 Fair enough. 481 00:28:09,720 --> 00:28:10,720 I appreciate the update. 482 00:28:10,720 --> 00:28:13,920 I think others listening in also benefit by it. 483 00:28:13,920 --> 00:28:14,920 Thank you. 484 00:28:14,920 --> 00:28:15,920 Thank you, Gary. 485 00:28:15,920 --> 00:28:20,880 And then the last is just really to tie up the loose ends in connection with the adjournment 486 00:28:20,880 --> 00:28:21,880 of the two motions. 487 00:28:21,880 --> 00:28:22,880 Yeah. 488 00:28:22,880 --> 00:28:25,360 That's what I wanted to go over our upcoming schedule a bit. 489 00:28:25,360 --> 00:28:26,360 Yeah. 490 00:28:26,360 --> 00:28:31,320 So the reduction of the PII, which is docket four, and the sealing of confidential parties, 491 00:28:31,320 --> 00:28:37,240 which is docket 127, those have been carried to the March omnibus hearing date, your honor, 492 00:28:37,240 --> 00:28:38,240 to March 13th, I believe. 493 00:28:38,240 --> 00:28:39,240 I'm sorry. 494 00:28:39,240 --> 00:28:43,080 So docket number four, which was the reduction of the, oh, 127? 495 00:28:43,080 --> 00:28:44,080 Yes. 496 00:28:44,080 --> 00:28:45,080 Okay. 497 00:28:45,080 --> 00:28:50,800 And notwithstanding those adjournments, your honor, to the extent that the Office of the 498 00:28:50,800 --> 00:28:56,360 United States of the Trustee has an objection to professional retention applications, and 499 00:28:56,360 --> 00:29:02,280 their deadline is the 23rd of January, notwithstanding that those motions haven't been heard, nothing 500 00:29:02,280 --> 00:29:07,200 will prohibit the court from entering orders retaining the professionals. 501 00:29:07,200 --> 00:29:08,920 So it's sort of like a subject, too, right? 502 00:29:08,920 --> 00:29:09,920 Right. 503 00:29:09,920 --> 00:29:10,920 You'll enter the order, hopefully. 504 00:29:10,920 --> 00:29:12,880 Hopefully, there won't be any objections, and we'll submit the order. 505 00:29:12,880 --> 00:29:17,400 But to the extent we have a hearing, and you overrule objections, these objections will 506 00:29:17,400 --> 00:29:23,160 be still outstanding, subject to your honor's ruling on these motions when and if we'll 507 00:29:23,160 --> 00:29:28,480 deal with disclosures that must be required to be done after that ruling. 508 00:29:28,480 --> 00:29:33,120 So if we could work it out with you, as trustee, in connection with these motions, you won't 509 00:29:33,120 --> 00:29:34,400 have a motion to be heard. 510 00:29:34,400 --> 00:29:39,400 If we can't, one day you will decide it, and we will apply accordingly your honor's ruling 511 00:29:39,400 --> 00:29:41,160 to whatever disclosures we made. 512 00:29:41,160 --> 00:29:45,440 But the retentions will have been hopefully granted before that. 513 00:29:45,440 --> 00:29:48,960 Essentially, reservation of rights. 514 00:29:48,960 --> 00:29:53,120 I'll leave it to the U.S. trustee to explain their thought process on what's going on with 515 00:29:53,120 --> 00:29:57,160 the process, but it really was we couldn't be in a cash 22 where we adjourn something, 516 00:29:57,160 --> 00:30:01,760 and then the retention applications get held up pending determination. 517 00:30:01,760 --> 00:30:02,760 It's similar. 518 00:30:02,760 --> 00:30:07,640 We had an LTL, and the U.S. trustee's office was very effective in working out an arrangement 519 00:30:07,640 --> 00:30:12,480 to reserve rights pending the court having a chance to look at the issue. 520 00:30:12,480 --> 00:30:13,480 So that's fine. 521 00:30:13,480 --> 00:30:17,440 So unless anybody has come, including U.S. trustee, I think that captures the intent 522 00:30:17,440 --> 00:30:21,120 of the parties with the adjournment and how it relates to the retention apps. 523 00:30:21,120 --> 00:30:29,760 As far as, let me just double check, because we have two dates coming up in January, the 524 00:30:29,760 --> 00:30:32,000 24th and the 30th. 525 00:30:32,000 --> 00:30:45,240 The 24th, from what I could tell, is the wallet issue and the retention program. 526 00:30:45,240 --> 00:30:48,800 Those are still planned on the 24th, or are we moving to the 30th? 527 00:30:48,800 --> 00:30:53,720 I didn't know if you all want to consolidate the 24th and 30th, or how you want to proceed. 528 00:30:53,720 --> 00:30:57,280 No, we've still got two court dates between now and the 30th. 529 00:30:57,280 --> 00:30:59,880 We're still in discussions with all parties about what will be heard on each of those 530 00:30:59,880 --> 00:31:03,800 dates, but we've been working with your chambers, who have been very accommodating to us. 531 00:31:03,800 --> 00:31:07,520 So we'll work out scheduling as soon as possible. 532 00:31:07,520 --> 00:31:08,520 That's fine. 533 00:31:08,520 --> 00:31:18,720 Just to let you all know, I just had a calendar issue, if I could find it. 534 00:31:18,720 --> 00:31:21,600 I am speaking at a town hall. 535 00:31:21,600 --> 00:31:26,040 Welcome to attend remotely, 12 to 1 o'clock on the 30th. 536 00:31:26,040 --> 00:31:30,720 So if you don't think we have enough time to handle the matters in the morning before 537 00:31:30,720 --> 00:31:36,040 the 12 to 1, I would do it in the afternoon when we have more time, on the 30th, from 538 00:31:36,040 --> 00:31:38,600 1.30 on to the afternoon. 539 00:31:38,600 --> 00:31:43,760 So take a sense of the time you'll need and add more. 540 00:31:43,760 --> 00:31:46,240 So all right. 541 00:31:46,240 --> 00:31:49,480 Then I think this was relatively straightforward. 542 00:31:49,480 --> 00:31:57,320 Anyone remote attending through Zoom wish to be heard on any issues? 543 00:31:57,320 --> 00:31:58,320 Your Honor, it's Robert Starr. 544 00:31:58,320 --> 00:31:59,320 Yes. 545 00:31:59,320 --> 00:32:04,720 I just wish to apologize for not being in the courtroom and thanking your Honor and your 546 00:32:04,720 --> 00:32:11,120 staff for allowing me to provide some of my medical issues. 547 00:32:11,120 --> 00:32:12,120 Not a problem. 548 00:32:12,120 --> 00:32:13,120 This was easy and straightforward. 549 00:32:13,120 --> 00:32:15,800 As easy as extra points in football. 550 00:32:15,800 --> 00:32:16,800 All right. 551 00:32:16,800 --> 00:32:18,160 So thank you all. 552 00:32:18,160 --> 00:32:19,160 And we're adjourned. 553 00:32:19,160 --> 00:32:19,920 Thank you, Your Honor.