-: SJC one three zero two eight Cobble Hill Center, LLC
Somerville Redevelopment Authority.
-: Good morning your honors.
May it please the court.
My name is George McGlaughlin
and I along with Joel Faller
represent the appellant in this case,
Cobble Hill Center LLC.
As the court knows, and as the court has noted,
the power of eminent domain
is the government's most awesome civil power.
In fact, this court in Divine
versus the town of Nantucket 449 Mass 499 stated
and I quote "the taking of land
"from a private owner against his will for a public use
"Under eminent domain is an exercise of one
"of the highest powers of government"
period close quote.
The Divine Court, consequently went on to state
and hold that eminent domain statutes
are strictly interpreted to protect citizens
from encroachments on their property rights.
So-- -: So can I stop you?
Why is this not a demonstration?
Just cut to the chase,
Why doesn't 46 F apply here?
-: All right, well,
your honor, first of all
I would say to the court,
what is a demonstration?
Somerville goes to great lengths
to talk about 46 F
having all of these great powers
but a demonstration is not even defined
in the definition section
-: Right, and that often happens in statutes
and so we look at the plain and ordinary meaning
why is this not a demonstration?
-: Well, I think if it is a demonstration
if
demonstration as we discussed is not defined
I don't know what a demonstration is
but if you assume a demonstration
is a kind of taking then--
-: Well no, it's just being
that it has its ordinary meaning, which is proof of concept.
-: Fine, your honor.
Then what I would say is
they can
if we accept that, I don't accept that
but if argue window, I accept your premise--
-: Well, I'm here to hear your argument.
What is your argument
as to what is a demonstration and why this does not fit?
-: Your honor, I do not know what a demonstration is.
I think it's not--
-: So how do we know, given your absence of knowledge
as to what a demonstration is that this is not one?
I suggest you take a position.
-: Fine, my position is
that the word demonstration is incomprehensible.
It's not defined, there's no case law on it.
I don't know what a demonstration is,
but assuming they can make a demonstration.
The problem I have with what Somerville has done is
they haven't gone through the procedures,
the legislative safeguards spelled out
in section 47 and 48.
Somerville position has been
we have this great power and under 46 F
that is not defined.
And we can take under section 11 D
and we don't have to get approval from anyone.
We can just decide, we want to take this property.
So they take my clients
four acre multimillion dollar property,
which they're then gonna cut in half--
-: But counsel, I guess I'm wondering
given section 46 has various provisions
some of which are tied to urban renewal plans
and Urban Renewal Projects.
But section F is not,
how do we square your position?
That sections 48 and 48,
48 and 49 govern 46 F
when 46 F makes no mention
of urban renewal projects or plans?
-: Well, I think what you have to do
in Somerville ironically urges the court to do this
is you have to read all of these statutes together.
You can not read 46 F and 11 D in isolation.
And when you read them together, your honor,
you see that they're limited.
For example, if you look at 46, it starts out by saying
that in Urban Renewal Agency
shall have all the powers necessary
or convenient to carry out and effectuate the purposes
of the relevant provisions.
I'll skip a little granted
in section 11
then we go to section 11 and
section 11 refers at the bottom in D
to the provisions of chapter 79.
Then when you go to chapter 79, section one,
it States in section 79, as you know,
is the eminent domain statute.
It States quote "the taking of real estate
"or any interest there on by right of eminent domain
"but if maybe affected in the following manner period
"a board of officers upon whom authority to take real estate
"by eminent domain on behalf of any body politic
"or corporate has been conferred by law.
""Having first complied with all the quote preliminary
"requirements prescribed by the law"
close quote.
So I suggest, and I urge the court to find
that those preliminary requirements
prescribed by law are the constitutional safeguards
that this court talked about in the opinion
of the justices regarding the stadium case.
And those are the--
-: The problem with that case,
is it specifically excludes
I mean, that was a case about whether or not
you can take property to build a stadium, right?
And in connection with analyzing whether or not
you can take property to build a stadium,
the justices in that case, specifically compared it
to something like that,
what's at issue in this provision
which is eliminating blight and slums.
And it said in that case, you know
when you're eliminating blight and slums
of course there's a public purpose.
And of course you can take land
for stadiums we're not so sure.
-: I understand your honor,
but in the opinion of the justices,
they specifically
say the constitutional limitations requiring public property
being taken by eminent domain
to be used by private parties
must be subject to legislative standards and principles.
And the legislative standards and principles
that they were talking about
in that case are sections 47 and 48.
-: Mr McLaughlin you know,
that case is not a opinion of justice
and this is not an urban renewal case
but let me suggest a different interpretation
of the statutes.
So 46 F calls to the elimination
of
blight
and then you have of blight
and then you have
chapter 112 B Section 1
Urban Renewal Project,
again, prevent the light.
And then you have that section 11,
that allows the taking to carry out any of the purposes
of section 45 and section 45 includes blight as well.
So why is Mass statutory interpretation work?
-: I think it does your honor
but I think when you look at section 45
you have to look at the last section of 45,
in there, the legislature expressly limits
the legislative finding of necessity
to urban renewal projects.
The language is clear.
It says, quote, "the necessity in the public interest
"for the provisions of this chapter
"relating to urban renewal projects
"is hereby declared as a matter
"of legislative determination".
So what they're saying--
-: But aren't you ignoring the first paragraph of section 45
when you jumped to the bottom? -: No.
-: The first paragraph of section 45
says the redevelopment of land
in blighted open squares
in accord with a comprehensive plan is necessary.
-: I understand that, your honor.
It also says that--
-: Didn't say a comprehensive urban renewal plan, does it?
-: No it does not,
but again, when you look at 45,
the last sentence clearly talks about
urban renewal plans and--
-: Absolutely, you're ignoring the other two paragraphs.
-: Well then your honor, I would turn to section 47.
And I think this is a very important section
that ties all of these together.
When you look at the first line of 47,
it says, quote
"not withstanding any provision of this chapter
"and Urban Renewal Agency
"may with the consent of the department
"and Municipal officers and after a temporary loan contract
"for the purpose has been executed
"under the Federal Housing Act of 1949 as amended
"take by eminent domain as provided in clause D
"of section 11".
So your honor, my position is this
here is a specific reference
to section 11 D why is this authorization necessary?
If section 11 D give Somerville a blanket authority
to take by eminent domain
without complying with section 47 or 48?
I think here section 47
and consequently 48 are unavoidably tied to a 46 and 11 D.
So what it's basically saying, and it makes sense is
if you wanna do a taking, if we assume you can do
a demonstration project under 46 F, and if you have
the power of eminent domain granted under 11 D you have to
comply with the procedures set up in section 47.
And that makes sense your honor,
because if you think of the bigger picture here,
what's going on.
If we don't have a check and balance
which is what the
I sight the opinion of the Justice's case for,
we have a very important check and balance going on here.
If you let local authorities just decide,
we're gonna take this property,
we're not gonna do anything,
we're just gonna decide it's a public purpose,
blight whatever the reason is,
we're gonna reach out and take it.
And then if that's not bad enough,
without going through any check and balance
they give half of it to a private citizen--
-: What are you...
Just so, this is at a level of specificity
that is difficult to follow,
but what does 46 F allow to happen then?
46 F has to have some purpose.
I know you wanna read it all back
into the urban renewal plan
and sort of the standard procedures
and standards are,
what does 46 F allow the Redevelopment Authority
to do in your view
that's different from the rest of the statute
cause it's gotta be in there for a reason?
-: I think your honor
and I've thought long and hard about this.
And I know you don't like my answer,
that it's incomprehensible.
And to an extent--
-: We're not allowed to say the legislature rights gibberish
we've got a fine...
They've got to be doing something here.
So what is it that they're doing
that's legal here?
-: I have stranger your honor.
And I think assuming that
let's read some meaning in here, and again
we're way beyond the plain meaning of the words.
I think that what this may be getting at
is minor situations
such as what the court dealt with in Marchese
and the trial court dealt with in Tremont
and what the BAR talks about
and it's Amicus brief, very minor--
-: Okay, but and I get that Mr. McLaughlin,
and you and Mr. Masterman
had been fighting these issues for 500 years.
So the rest of us have to catch up to you.
But if that's the case,
then you have a taking
you can use the taking power in this limited way,
you're back to justice
Wendlandt's original question about what,
you know what is allowed under a demonstration project.
It sounds like your backup plan is, yeah
you can use the taking power
as long as it's for this kind of narrow project
that really is a classic demonstration project
like ya'll give way. -: Right.
-: Is that your backup position?
I'm also troubled by Mr. Masterman,
which is basically anything goes under 46 F
because we can trust these people to be good fiduciaries.
That can't be right either.
So I'm trying to figure out
what an enforceable
substantive limited 46 F clause does.
So it would help me if you give me
what your view of that is.
-: My view is that
it allows you to be nimble
and make small takings to demonstrate a certain issue
like in, I think the Marchese case is the perfect case.
I think that go through a whole urban renewal plan
and an urban renewal project to achieve the goal
of simply taking easement.
So that Fenway Park could use Yawkey Way--
-: Okay so, Why is that?
And again I'm not saying you're wrong here,
but I'm just trying...
Why is the Marquez, Yawkey way,
why is that a demonstration project?
(murmurs) statute and this legislator and this,
cause there's a language at the end of this, right,
where they throw in this sentence could provide..
The proposed development program includes
a new municipal public safety complex
integrated into a comprehensive reuse plan
which could provide a useful example
for other communities throughout the Commonwealth, right.
That's the only words of demonstration
in this project, right?
Why is that different
from converting part of our pathway on a row?
Why are they different under the statute?
Why is one a demonstration project?
The other not?
-: I think it goes to scope your honor,
but let me say this.
I think that regardless of whether it's a demonstration
or a full blown project, as you say,
you have to go...
You have to proceed under Section 47.
That's the check and balance.
So if as the BRA and a Somerville argues,
hey we have to be nimble
and 46 F allows us to be nimble,
yes, but 46 F allows you to be nimble
but you still have to go to the Department
of Housing and Community Development under Section 47
because what 47 says, and it's very important.
And it relates back to 11 D,
47 allows you to go
to the Department of Housing and Community Development
and get their approval
before you go through the whole
Urban Renewal Project process.
And so all Somerville had to do in this case
is go to the Department of Housing and Community Development
and get their approval under this--
-: And the particular words
in 46 F that cross-reference 47 are what?
Cause like I thought you were gonna argue
that the word plan in 46 F
must be an Urban Renewal Plan
and that justice Botsford was wrong and Tremont,
but you're not making that argue...
Well, you may be making that argument
but this one I've not heard before,
is there some language in 46 F
that cross-references 47 in a direct way?
-: Yes, your honor
I see that my time is coming up
and this will take a little bit of a minute
but I think it's very important.
Cause I think you are
you know, you're onto something here,
46 F
46 F says at the beginning,
it refers to section 11
and it basically says,
you know what 46 F does is these are eight powers
that Urban Renewal Agencies have.
And then it refers back to section 11
and
there is no...
The word plan, your honor is not used in 46 F
and I think that's important for the court to note,
but also as I started to say 46 refers back to 11,
11 says that you can do a taking under Chapter 79,
Chapter 79 Section 1
says that
you have to comply with preliminary requirements
prescribed by law.
And I think that takes us back to 47
and 47 specifically refers to section 11 D
of the statute.
So again, if Somerville has this awesome power
they say they have,
and all they have to do is do a demonstration
on a 46 F and then they can take under 11 D,
why did the legislature
make the authorization
of 47 necessary?
They're all linked together--
-: I think Mr. Massman is gonna come and say they didn't.
And 47 has nothing to do with 46 F,
but I'll let him,
I'm sure Justice Budd will decide
when he gets to talk but.
-: I think this is the time.
(all laughing)
Okay Mr. Masterman.
-: Thank you, Madam Chief Justice,
may I please the court James Masterman
with James Pawns Seto
for the Appellee Summer Hill Redevelopment Authority.
I had a brilliant oral argument here set
but I think what I wanna start with--
-: Counsel can I interrupt it then?
Sorry. (all laughing)
So just to cut to the chase,
what are the limits to a demonstration?
-: I was gonna say--
-: Cause I am troubled by the notion
that Redevelopment Authority can do an end run
around these very specific Urban Renewal Plan
and project requirements
of 47 and 48 or 48 and 49.
And not have to comply with those very
public processes for getting approval for Urban Renewal
Plans and projects through a demonstration,
which as your counsel, your brother
noted is not defined in the statute.
So what are the limits?
-: Yes thank you, your honor
and I was gonna say
I'll try to answer justice weapons questions together
with justice Scott there and that is
what the city of Somerville
or Somerville Redevelopment Authority
were confronted with in 2020 or 2019
was not widespread blight.
There was blight and it's admitted blight
but it was concentrated in a particular area.
And they had options
as the courts have said since the Alvaton case in 1939
when the local authorities
that have specialized knowledge of their locale
deem that some action is necessary,
they opt for among the various powers that they had
to fix that problem to alleviate the blight,
to eliminate it and to prevent its occurrence.
They had the option at that point
to decide as they did back in 1968
when they have a large-scale Inner Belt Urban Renewal Plan,
whether to encompass an enormous area
with all of the controls
that come with urban renewal areas
and the duration of an Urban Renewal Plan
that tends to go more than 20 years.
As we've seen outside the courtroom warehouse
with government center, the West end or the South end
they had a different urban renewal problem.
It was concentrated.
It was not widespread.
It was causing the same deleterious impacts
on the surrounding area.
An area that had been studied by the city of Somerville
and summer vision and the inner belt master plan.
But the question in front of the SRA at that point
or the entire city,
because the mayor and the city council were both involved,
what do we do about this particular problem
confined to this one area
to this one property,
which is having similar impacts,
negative impacts on the surrounding neighborhood?
And the decision was, you know,
could it be demonstrated that if there were a surgical
targeted intervention by the public authority
where private enterprise alone was not working
could that actually eliminate the blight
and with a comprehensive redevelopment plan
prevent its recurrence?
And that is what the demonstration project is all about.
The courts, again, since Alvaton in 39
and Papa Dennis in 1954
from Berman view a Supreme Court
all the way through Hilo in 2005 have indicated
that when the local authorities
deemed there to be a blight problem,
and that's the predicate of a public purpose
that there is blight or decadence
or substandard housing,
then the courts tend to defer
to the local authority to determine what remedies
would most effectively eliminate the blight--
-: Anytime, anywhere there's blight,
it's not within the urban renewal plan,
a 46 F project can occur
even if it's nothing special about it
or is there some additional requirement?
Cause blight is...
I mean redevelopment authorities have no authority
outside of blight, right?
I mean,
that's their big purpose.
So
is there something more to 46 F
than there needs to be a blight finding?
-: Not in terms of the validity of a public purpose
in terms of the taking
so long as there's a foundational credit
defining a blight,
then the plan that is implemented
by the Urban Redevelopment Authority to eliminate it
and to prevent its occurrence is well ground.
The question that just captured--
-: I'm confused Mr. Masterman so
I'm a poor person,
I can't repair my house and it looks lousy.
I'm taking, take my house with a demonstration project,
it just, it gotta be more to a demonstration project
that it looks, the place looks blighted.
It isn't there?
-: Certainly, yes, your honor,
the Redevelopment Authority
is not gonna target a particular house.
The question is whether that
influence. -: Why not?
-: Whether that blighting influence has a deleterious impact
on the surrounding neighborhood,
does a redevelopment of that area.
Is it consistent with a broader community base
planning plan, like summer vision or any comprehensive plan?
There is both parts of it,
the predicate of the demonstration project
and all of the actions of the Urban Renewal Authority
must be a finding of the blight,
but blight isn't necessarily concentrated
on one small house.
It is a determination that the area itself
that this particular property
in and of itself has some impact
on the remaining area outside.
But in some ways, your honor, that finding what blight--
-: Is it an important for us to know
the definition of a demonstration?
Because it seems to me
that you could target
a house that you consider not to be up to snuff,
to its neighbors,
and that would be a targeted taking,
but you would have to in addition,
show that the redevelopment
of that parcel was a quote demonstration.
-: Yes your honor, we underline--
-: I guess that's the other limit to this 46 F power.
And what does that mean?
-: That without a Section 47
Urban Renewal Plan in place
that without a Waterstock urban new area
that the same type of remedial impact remedial effects
of an Urban Renewal Authority
can in fact be used for a targeted intervention
to demonstrate whether that would work
or must it be this much larger longer--
-: To demonstrate what?
I think that's Justice Wendlandt
and I are asking the same question
to demonstrate that blight will be eliminated?
Of course that's gonna happen
cause you're gonna put something nicer in
or just knock it down.
Don't you have to demonstrate something
innovative.
I mean, to me
a demonstration project is a pilot program
that teaches us how to do something
that we've not done before
or that it's novel,
so that we have to make a special exception
and give him a lot of power.
It's a big deal, but it can't just be
because there's blight out there
because then why have Urban Renewal Plan?
We can just do this with a demonstration project.
-: If every property within an urban renewal area
is blighted or decadent or substandard
then I think your honor is correct.
You could have a huge demonstration project.
The onus on with government in this situation is greater
because it must demonstrate that every property
within the demonstration project is blighted.
And then there is this notion
that the demonstration has to be achieved
by the taking and the elimination.
No, it does not.
There has to be a plan in place
that demonstrates that is this property
worth to be taken?
And its stead comes something that
the Urban Renewal Authority believes to be better
for the community, fully more integrated
has the immediate impacts that are desired
that you don't have to have a 50 acre Urban Renewal Plan
with all of its controls over the next 40 years.
That's what the city of Boston--
-: So just, I mean
cause I don't wanna weave this because this is a big deal
and we haven't answered this question,
but again what I get out of what you just said is
that there needs to be blight
and
we need
to have something better come out of it for the community.
Is that your standard for a demonstration project?
Outside of there needs to be blight in the entire area
that's 46 acres of plying to,
and that it needs to produce something better
for the community that
all that's required to be a demonstration project.
Cause that's a pretty powerful taking power
for an elected officials to have.
And none of those political controls that come into play
on urban renewal plans, right?
-: There's a lot there in that question.
You're on to unpack number one.
Yes I think that's the heart of urban renewal.
The heart of urban renewal is to identify substandard
housing, decadence and urban blooded open areas
and work like private enterprise alone.
It was not being alleviate that to come in there
with an extraordinary power.
We understand that that Mr. McLaughlin indicated
the awesome power in the domain
but the eminent domain power has always been a means to
achieve a public purpose.
And that is the elimination
of life in the implementation of a plan.
And the difference--
-: So let me try this again,
urban renewal projects and plans
are designed to eliminate blight, correct?
-: Yes in part.
-: Now you're saying the demonstrations
are also designed to eliminate blight, right?
-: Yes.
-: Okay, so what is the difference?
Doesn't it have to come from how we define a demonstration?
because otherwise I can take an Urban Renewal Plan
and just divided up into smaller parcels
however you that and say each one is going to be taken
without all the process that I need all the bother
of the public hearings and the approval of everybody else.
I'm just gonna take my urban renewal plan
and I'm gonna divide it up into four acre parcels.
And each one I'm gonna take
as a quote unquote demonstration
because it's gonna eliminate blight.
-: I don't think so, your honor
if each of those four parcels--
I'm just asking you--
-: I don't think Urban Renewal Authority can go around
and decide that every four acres is blighted
unless there is the foundational concept of blight
you could have experienced it
in the Commonwealth and across the nation
where acres and acres and acres of degradation
couldn't track support that kind of approach.
But in the demonstration project is targeted.
It is targeted, not geographically necessarily
but where the light is found.
And once that blight is found--
-: I think you're putting a lot in targeted
to me prevention and elimination of slums and urban blight.
That's what the demonstration is gonna be able to carry out.
Something that is unique is just as Kafker said,
the pilot project
looking at what we're doing over here, Alington
see how this works or Cambridge, see how this worked?
We were able to do this in this way
and you can take this demonstration
and deal with your blight in this unique way
and that way because this is so unique
and it's going to help this a matter
of how to address blight that we're going to
let you avoid all the procedure that you need to avoid.
Otherwise for most urban renewal projects,
it doesn't matter what demonstration common sense
colloquially mean.
-: I think that's right.
Just as--
-: So what is it? -: The city is,
the city of Somerville has in fact said
we're not going to adopt a broad comprehensive
Urban Renewal Plan,
which we had once before in this area.
That's not what is necessary here.
That particular area is blighted
and yes, Alington Springfield Chickopee take a look
at this idea.
We are going to focus on the blight
that might have this deleterious impact
on this neighborhood.
And we're going to say, this is how we're gonna do it.
We're gonna acquire this land.
Here's the plan.
It was fully vetted publicly.
It was approved by the city council.
It was approved by the mayor
and we are not going to keep our land use controls there
for the next 30 years.
You're gonna get in eliminate the blight
allow us to implement this public safety building.
If there was a private party to achieve this
public purpose that will assist us
in eliminating the blight and preventing its occurrence,
we will do as Urban Renewal Authorities have done
from the very beginning and we will with contract them
and do so.
And then we're done that project is over.
There's no further controls in place
and they go about their business.
-: So it sounds like
you're saying the urban renewal plans allow us to
take a giant area, only parts of which are blighted.
And we go by all the procedures in the Urban Renewal Plan
but we can also just ignore this
for everywhere else in Somerville.
And so, and we have the ability under 46 F,
if a particular area is blighted
we can take it and clean it up.
Doesn't matter what we do there
as long as we make it better
am I summarizing your argument correctly
or my misinterpreting?
-: I think that's right, your honor.
I think there's
the public official in the local, in the city
as you indicated in his fiduciary capacity
can look at the problems
of what that particular city is encountering
and address it in a number of ways.
One of the ways to address it
is to adopt a demonstration project
that in this one is the court has seen
then you can't experience thorough.
It is well drafted and
is basically looking like an Urban Renewal Plan
what otherwise looked like
and it addresses this one particular area--
-: If we disagree, Mr. Masterman,
that there's an additional requirement
of a demonstration project,
not just that it's blight produces an improvement,
but that it also has to be something more novel
or innovative.
There's some substantive aspect to demonstration project.
Can you still win under 12 C here?
If we believe that this it's
the power is not quite as broad as you do
that we think demonstration has a meaning
of innovation and example of some sort.
You still win under 12 C?
-: If it requires some innovative approach,
I would believe that in this particular case,
it has satisfied--
-: And how has it satisfied it here?
What is innovative here besides that
You've again, we think there's an additional requirement.
I'm not saying we do.
I'm just posing this,
that we think that something beyond blight
and you're gonna make the blight go away.
Isn't that 46 F has something else to it?
-: Yes, your honor.
It is demonstrated to every other city in town
in the Commonwealth
that in fact you can target this particular property
a property and use the tools in the Urban Renewal Statute
to implement a plan
to prevent the occurrence of blight.
That that is not something as the cases have said all
along the courts have allowed
the adaption with the cities can adapt
to the problems that the report
we're not dealing with widespread blight in our cities
thankfully, we're dealing with pockets of blight
that must be remediated.
And in this situation, what is being demonstrated
in a use of the power that has been embedded
in the statute from its beginning
is that you can use it
in this more surgical, targeted and strange area.
That's the demonstration--
-: It sounds like something like spot zoning or something.
It just, is that what you're describing that the ZB, I mean
the redevelopment authority
can go in and sort of
just do this kind of, I don't know
but your point is that the demonstration is we
can demonstrate solutions to targeted blight.
That's what you view demonstration means
that we demonstrate how to fix
a isolated blighted spot.
-: That's correct.
And it would be in courts would would say
that the public official may be the best party to know
which among the various powers within 121 B to use
that at this time, when we don't have these broad, large
widespread areas of blight that we've encountered
for 80 years in the Commonwealth
we don't have that at this point yet.
Blight continues to be a persistently vexing problem.
-: Counsel, can I stop you for a second?
So you're not relying in any way
on the plan itself
that there was gonna be this public safety complex
with these other parts of the parcel to be used, you know
the four phases you're not relying
on the actual plan itself.
You're saying the demonstration
is that we can take this mini parcel and fix it.
-: And beyond that, your honor, we simply cannot
just eliminate the blight.
We've gotta demonstrate in the demonstration plan
that the redevelopment of it that had not occurred
by private enterprise alone
would in fact prevent the recurrence of blight.
So yes, the early development plan is a
an important component of this.
We just can't...
Otherwise you can just take the land
and leave it shallow.
That's not what's required here.
What's required is a true plan of redevelopment
and demonstrating that in fact,
if one does it in this targeted way
and you put a public safety building or you bring it
a private party, that would not only eliminate the blight
with the taking, but in fact would prevent its recurrence
on a going forward basis.
-: Is there any legislative history on 46 F?
Is there anything we can turn to,
for guidance that explained
What demonstration meant to them?
Is there anything you've seen on this that we can
and I would request chief justice Budd
if there is anything that they're aware of
that they submit a 16 L letter,
that was really not a focus of (murmurs).
-: That sounds good,
If you guys have anything, you can submit it
by way of the 16 L letter.
-: Sure we are. -: Arguments
and we're gonna move on to the next case.
-: Thank you your honor.