February 26, 2013
Operator: Ladies and gentlemen thank you for standing by. Welcome to the ATFA briefing on the NML versus Argentina conference call. If at any time during the conference you need to reach an operator please press star 0.
As a reminder this conference is being recorded Tuesday, February 26, 2013. I would now like to turn the conference over to Robert Raben, Executive Director of American Task Force Argentina. Please go ahead Sir.
Robert Raben: Thank you very much, we deeply, deeply appreciate you all coming together on this telephonic briefing.
There's a lot going on and we started a little late due to the tremendous volume of people who said they wanted to participate in this call. We had to queue them in, so I wanted to acknowledge that. We appreciate your continued attention this important matter, the litigation that will be - have another important step tomorrow in the courts of New York.
On this call we will quickly overview developments in the pari passu case and discuss possible turns, what you might expect in the next - in the coming days. We are interested in clarifying a very complicated federal judicial process and point to possible outcomes that we think are likely and rule out others that we think are speculative.
I'm joined by very esteemed professionals on today's call.
Richard Samp, whom you will hear from first, briefly is the Chief Counsel of the Washington Legal Foundation, an important not-for-profit public interest law firm that litigates in the United States in support of individual rights and the free enterprise system, and importantly against excessive government regulation. He practices regularly before the United States Supreme Court and other federal courts.
After Mr. Samp speaks I will introduce you to Bruce Wolfson, who is an experienced attorney with the law firm of Bingham McCutchen.
But let me go ahead and have attorney Samp bring you up to date on the court case. Thanks so much, Richard.
Richard Samp: Thank you Robert. What I am planning to do is to go over for a few minutes the background of the case beginning last October 26th, when the Second Circuit issued its last ruling in this case. And then Bruce will perhaps discuss more of what is likely to happen at tomorrow's hearing and thereafter.
The October 26 decision was by a unanimous three judge panel. There are 13 judges on the U.S. Court of Appeals for the Second Circuit, and three judges were randomly chosen to hear the case. And those same three judges will be hearing the case tomorrow.
Now those three judges are Rosemary Pooler, Barrington Parker and Reena Raggi, and she is the one conservative on the panel. She was appointed by President George W. Bush.
The other two on the panel are liberals. Judge Pooler was appointed by President Clinton, and Judge Parker was also initially appointed by President Clinton, although he was promoted as part of a compromise deal during the Bush Administration.
The reason I mention all of this is that this is what I would consider a fairly ideologically diverse panel that represents all segments of the court. And when you get a unanimous panel decision that is coming from a broad group of judges it is less likely perhaps that the other ten judges on the court will want to second guess what they have done, because they will think it's probably a balanced decision.
So that while it is generally very unlikely that the Court of Appeals ever grants a rehearing in the case, I think it's unlikely that whatever finally gets decided after tomorrow's hearing it's particularly unlikely that there will be a rehearing en banc in the case simply because this panel is well respected and is quite diverse.
Now when that decision was issued last October 26, there were several important things that were decided. And what's important to remember is once those issues are decided the panel is not going to reconsider them. There are other issues to be heard tomorrow. But the issues that are already been decided, basically are going to remain decided.
So that even though many of the briefs that were filed over the course of the last two months in the Second Circuit are asking the panel to reconsider its prior decision it's very, very unlikely that the three judges will do so.
Furthermore, although this is a federal court that is hearing the case many of the issues that arise are being decided as questions of New York State law. And the reason that that is important is that the U.S. Supreme Court almost never agrees to hear a case in which the issues are state law issues.
Now the bond agreement that was entered into by Argentina stipulated that New York State law would apply. And in particular, New York State law governs the interpretation of provisions of the bond agreement and how it is to be enforced. So the bond agreement has something called the Equal Treatment Clause, which is one subsection of the pari passu clause in the bond agreement.
And what the three judge panel held was that the Equal Treatment Provision requires Argentina to make payments to all bondholders if it makes them to any bondholder say, "It has to treat them equally." And that was decided as a question of New York State law, which means that that issue almost surely would never be reviewed by the U.S. Supreme Court.
Furthermore, the court said that, "It is proper to, under the terms of the agreement, to grant an injunction that requires Argentina to comply with the provisions of the Equal Treatment Clause." And again, that is a question of New York State law that would not be reviewed by the Supreme Court.
The third issue that the court decided was under a federal law called the FSIA, the Foreign Sovereign Immunities Act. Argentina had argued that injunctive relief was never proper. Now that is a federal issue and that is one therefore that could conceivably be decided by the Supreme Court.
And what the Second Circuit held was that the FSIA, while it prevents the attachment of the property of foreign governments in certain situations that what is being ordered here by the district court is - does not constitute the attachment of property.
Now the case went back to the district court, which decided two issues that are subject to the appeal now, and those two issues were explicitly left open by the Second Circuit: Number 1, who precisely is to be bound by the injunction; and Number 2, how are the - how is the ratable payment system to be done in this particular case?
And the Second Circuit - excuse me, and the district court said that, in particular, "That the Bank of New York is bound by the injunction so that they may not process payments coming from Argentina and to give them to the Exchange bondholders unless they have some assurances that the plaintiffs are also being paid."
The case was then immediately appealed after the district judge issued its decision, and that's what we're going to be hearing oral arguments in tomorrow.
Now the one, perhaps glimmer of hope that the defendants have in case is that a stay pending appeal was granted on November the 27th or the 28th of last year by the Second Circuit. So that may be some indication that it's a little bit, at least somewhat sympathetic to some of the arguments being raised by the defendants on this appeal.
However, it also could well be an indication of what is called a Balancing of the Equities, whereby they may have figured that a slight delay being suffered by the plaintiffs is not a huge injury to them. And if the alternative is that if no delay was granted, that there would have been a default on the bonds in December, that that was perhaps a reason to put off the decision of the district court until there had been a chance for the appeal to be heard.
As I mentioned, there were briefs filed not only on the Argentina side by Argentina, but also by the Bank of New York as well as by numerous groups of bondholders. And the interesting thing is that many of the issues raised in those briefs really don't go to the two issues that are to be decided tomorrow.
They basically tried to re-argue the interpretation of the pari passu clause. They tried to re-argue the Foreign Sovereign Immunities Act issue. And they also in the case of the bondholders argued, "We ought to reopen the whole case because it's not fair to us because Argentina may default on its payments to us if the district court's decision is affirmed."
So although the seventh circuit - excuse me, the Second Circuit has allowed seven minutes of argument time for the Exchange bondholders, I think it's quite unlikely that the Second Circuit is really going to listen carefully to any arguments that it ought to reopen the entire issue of injunctive relief.
On the other hand, the Bank of New York is also getting seven minutes of argument time tomorrow and it's conceivable that they may prevail on their issue. Because after all, one of the issues that the Second Circuit left open was, "Who is bound by the injunction?" And the Bank of New York has raised argument as to why they should not be bound.
The plaintiffs have come up with some good arguments as to why in fact it is proper under Rule 65 of the Federal Rules of Procedure that they should be bound, but that will be, I'm sure, a major focus of the arguments tomorrow.
Importantly, the United States government has not participated in the briefing leading up to tomorrow's argument. They have filed a brief in support of the rehearing en banc petition.
But even in that particular brief they've made it clear they really don't fully support Argentina. As far as the United States is concerned the fact that Argentina passed what's been known as the Lock Law means that it really - the United States is not giving its full support to Argentina.
So with that, I will conclude and let Bruce tell you a little bit more about what he thinks is going to happen tomorrow.
Robert Raben: Thank you very much. Bruce, this is Raben, thank you very much Attorney Samp. We appreciate that.
People should note Bruce - Attorney Wolfson is actually in Buenos Aires today. Yesterday he lead a panel which some of you may have covered, a discussion on the case with a forum sponsored by the Emerging Markets Trade Association.
Mr. Wolfson is an Attorney with Bingham McCutchen and he has been involved with financing and restricting emerging market debt for more than 30 years - restructuring of emerging market debt for more than 30 years.
He was a partner and General Counsel at the Rohatyn Group and a senior managing director at Bear Stearns and Company. He has advised regulators in the emerging markets of Latin America and Asia on a number of foreign investment rules. And I've asked him to speak for a few minutes today on arguments and possible outcomes of the case.
After a few minutes from him we will open it up to your questions. Thank you so much Attorney Wolfson.
Bruce Wolfson: Thank you. Just to tie up a couple of the critical points that you just heard, because they're an important basis for what is likely to happen.
I can't emphasize this enough, there were two issues that the Second Circuit remanded to the district court for consideration, and that are now back up on appeal. And those are only the question of the ratability scheme and the reach of the injunction under Rule 65. Those are the only two issues up on appeal.
Now while the Second Circuit has some discretion to go beyond that it would be unusual and there's no reason to think that they will address other issues. That speculation has come about because of the breadth of the brief and not because there's any substantive basis to think that they will address those.
So for the first questions into what is likely to happen tomorrow is that the court may listen to broader oral arguments because they'd be giving people a chance to speak. But is highly unlikely that the court will, in its ruling, go beyond the two points before it.
The arguing - the arguments, continued arguments, about pari passu, as you heard the right way to address that would be through a rehearing petition for a rehearing en banc, which has been filed. So not only is that not before this court, but it is before another court on another petition. That's not going to be addressed. The Foreign Sovereign Immunities Act, as you heard, is unlikely to be addressed.
"Will there be a petition for Cert to the Supreme Court?" It's speculative as to whether Argentina would do that. It certainly could lead to a bit more of a delay if they did. The likelihood of the Supreme Court granting Cert on this issue, I think is generally seen and is seen by me, as remote.
Then the bond holder argument about denial of due process, I think just the way you heard the argument framed gives you some sense of the strength of that argument. The Exchange bondholders are speculating that upholding this judgment might cause Argentina to refuse to pay and suggesting somehow that the possibility that if Argentina refused to pay, that that was a result of the action of the court and that that court action denies them due process.
My view of that is that that argument is not terribly persuasive. That the court is not arguing Argentina not to pay the Exchange bondholders. On the contrary it is saying, "They should pay the Exchange bondholders and the holdout bondholders ratably," and certainly have not acted in a way that seems to me to raise a constitutional argument of substance.
So that's what's likely not to happen tomorrow; what may then happen? Well, one of the things you've heard is that the pari passu clause as it's reaffirmed may cause significant repercussions, because future restructurings would be put into doubt and may even impact the status of New York as a favorable jurisdiction for financial transactions.
I'm not persuaded by those arguments. I'm not persuaded by those arguments for two principle reasons.
One is that what makes New York a great center for financial transactions and financial jurisdiction for legal proceedings is that New York understands and enforces contract rights and the rule of law is respected there, and that's important. And this ruling that is interpreting a contract and enforcing a contract can only reinforce New York's standing.
Secondly, it's very, very important, very important to understand, that what the court has done here is not to interpret what pari passu means in all cases for all times and in all circumstances in a way that will prejudice other restructuring. What the court has interpreted is a particular pari passu clause in the context of a particular series of actions, conduct by the borrower. And the court was very clear about that.
This pari passu clause explicitly talks about priority and payment right. And this pari passu clause is being interpreted in a context in which the court has specifically noted that the borrower has gone to great lengths to avoid paying certain creditors and to prejudice certain creditors' rights through a series of actions including legislation in Argentina. And all of those facts are specific to a context that we simply haven't seen in other restructurings.
And I think that people in the market will tell you that the decision to lend to sovereigns, and the discussions about restructuring sovereign debt, generally turn around the sovereigns ability to pay and the perceived willingness of the sovereign to pay or to negotiate, and not the likelihood of recovery before a court of law.
These - the resort to judicial remedies is highly unusual, there are very few cases. And most sovereign lending is not based upon the confidence that one can collect in court, but rather that one won't have to go to court. And I think that the reaction of the markets in some of the restructurings that have been carried out, including the recent restructuring in Belize in the wake of this ruling, support that notion.
So the only other point that I think that I would touch on where there's been speculation is, what might happen if as Richard said, "The one point that does seem to be of interest in this hearing and on which there could be argument and there is not as much confidence as to the outcome, is the breadth of the application of the injunction."
Does it in fact apply to Bank of New York, which has argued in its brief, that this could be prejudicial to other banks willing to serve in the role of a fiscal agent or trustee, and does it reach the payment systems in ways that have been predicted to be quite significant?
I think at this point all of that is speculation. If in fact the court were to limit the application of the injunction, what seems clear to me and I think to most commentators is that that would not change the fact that Argentina, if it made a payment to the Exchange bondholders and didn't ratably pay the holdout bondholders, would be in violation of the court's order and in contempt. And I think the speculation that bondholders and financial institutions will immediately rush to assist Argentina to do that, is premature.
I think I'll stop there for the time being.
Robert Raben: Thank you, very much Attorney Wolfson and Samp, we deeply appreciate your contributions. We know it's a busy time for everybody. We will open it up for questions operator.
I'll just comment as the Executive Director of ATFA, who is not practicing a lawyer on the litigation. It sounds to me, and it's amazing to me, that Argentina over-argues in its cases and its briefs similar to the way that it does in front of the Congress of the United States and the Executive branch. And it's really lamentable.
Operator we'll take questions at this point.
Operator: Thank you. Ladies and Gentlemen if you would like to register a question please press the 1 followed by the 4 on your telephone. You will hear a three-tone prompt to acknowledge your request.
If your question has been answered and you would like to withdraw your registration, please press the 1 followed by the 3. If you are using a speakerphone please lift your handset before entering your request. One moment please for the first question.
And the first question comes from the line of (Ana Barron) with (Clarin). Please proceed with your question.
(Ana Barron): Yes, I am Ana Barron from Clarin in Argentina. I just wanted to know about the possibility, it seems that everybody is very directed at what could happen with the Bank of New York, and I wanted to know if you can visage any scenario where the Bank of New York is completely disengaged or not considered, you know, part of these possible sanctions if Argentina doesn't want to pay to the holdouts?
Richard Samp: This is Richard Samp. I'm not sure I fully understand the question.
In its brief the Bank of New York has made clear that its principle concern is it does not want to end up being liable to somebody else. In other words, what they are fearful of is that if the court orders them not to pass on payments from Argentina without an assurance that the plaintiff had been paid, are they going to get then sued by bondholders who say that they are - they, the Bank of New York, are breeching their responsibility to pass along payments.
So I think what the Bank of New York wants more than anything else is instructions from the court as to what to do. And it would be quite happy if the court said, "Don't accept payments, and if you do get payments, do not forward them on, and therefore you won't be" - they can point to that as a reason not to be held liable. I mean obviously they don't want to be held - get stuck in the middle of this situation.
(Ana Barron): Okay, thank you.
Bruce Wolfson: I think I might add to that, that if absent that guidance, if there were a ruling that said that Bank of New York is not bound, but didn't give Bank of New York specific instruction, I think that Bank of New York might very well have an interest in getting that instruction.
I think speculation as to what Bank of New York will do, and certainly reaching the conclusion that if Bank of New York is removed from the scope of the injunction that that puts the matter to rest and frees Argentina to make payments through Bank of New York is premature.
Operator: And the next question comes from the line of Michael Warren with the Associated Press, please proceed with your question.
Michael Warren: Hi. NML is requesting payment of $1.3 or $1.4 billion at this point, but Paul Singer's organizations actually have outside of this pari passu case another $1.53 billion, and also in addition to that another $87 million in face amount of bonds that are not part of these proceedings.
If you put all that together it's more than they're asking for in this case, they've got hanging out there in similar cases that could come for collection related to this ruling.
And then there's this universe of about $10 billion in holdout debt that is very similar to this debt. And we've got Kenneth Dart's company, EM Limited, filing a brief that get clear and a note to the court that anything that NML gets in this judgment it's going to seek to collect as well under the same terms.
So how can you guys really say that this is just about $1.3 billion? None of this else applies if the same plaintiffs have a lot of other money hanging out there that's similar.
Richard Samp: There obviously will be other litigation beyond this lawsuit, and it may be more than $1.3 billion at the end of the day. The important thing is that the Second Circuit has already looked at this question and has determined that Argentina has more than sufficient foreign reserves to pay everybody.
So that this is not a question of a debtor who is bankrupt and is being hounded by people to make payments that they cannot make, rather this is a question of a country which has sufficient assets to pay everybody but has refused to do. Now if it believes that the Second Circuit's finding is incorrect, that it has sufficient assets, it can make that argument to the court. But that issue has already been determined.
Michael Warren: Well okay, I'll let it go on to the next question.
Operator: And the next question comes from the line of Jude Webber with the Financial Times. Please proceed with your question.
Jude Webber: Thank you. Well I had that same question that Mike's just asked, which I'm not quite sure that - that I mean, it would still, regardless of what you say in the Second Circuits, determine that the - that Argentina has the money. But I mean, it still seems to me that this would open the floodgates of litigation so. I mean that was just one thing.
The second question I wanted to ask you is really, "Do you think it's - do you think the most likely outcome then is - what we're going to get here is some kind of abstract ruling where Argentina loses the interpretation of pari passu, has already lost in fact, but there's no way of enforcing the remedy?" There's no way of handing down a remedy that can be enforced without hurting either the Bank of New York irreparably or the Exchange bondholders.
Bruce Wolfson: I think if - you perhaps took a leap that I'm not sure I'm prepared to take.
I think the first part is that if there are other bondholders, be they affiliates of NML or others, who hold the same bonds under the same fiscal agency agreement that was interpreted here and that otherwise have identical standing, I think that the ruling that has been issued would appear to apply to them and they would most likely seek enforcement in the courts and the courts would determine whether their standing is identical and they should be paid.
I don't - I'm not sure that I understand why that is necessarily a bad outcome if one accepts that the court's ruling is correct. If the court's ruling is correct then bondholders who have a right to payment should all be paid.
The second piece is that you assume that there is irreparable harm and the court is going to look at that. And I don't think the fact that one submits a brief saying that there will be irreparable harm necessarily means that there will be irreparable harm.
The court is going to examine both the legal applicability of the injunction, what parties does it reach under the rules of the court with respect to injunctive relief, and the impact of it. And so the assumption that the court will make a ruling that is going to irreparably harm Bank of New York or anybody else, I think probably is also speculative. I don't agree with that conclusion.
And finally, I think that the outcome - the assumption that the outcome will create greater uncertainty is again premature. It's possible as Richard said, "That the court will give very explicit directions as to what the parties do." And until we read their ruling and know exactly what they've said, it could bring clarity, it could set the stage for further interpretation. And we won't know that until after we see the judgment.
Richard Samp: With respect to the question of whether the exchange bond holders would be irreparably damaged by other decision, I think that's demonstrably untrue. There is nothing that would prevent Argentina to continue to make all the payments that it has been making to exchange bondholders in the future.
If Argentina voluntarily decides to default on its obligations to the Exchange bondholders, that certainly is not something that can be attributable to anything that the court says. That is simply a decision that Argentina may or may not make on its own.
And indeed, at any time it could decide to default on its bond payments, as it has done in the past. But to say that that would be somehow the fault of the court, I'm not sure I understand.
Operator: Ladies and Gentlemen as a reminder, to register for a question press 1, 4 on your telephone. And the next question is a follow-up from the line of Michael Warren with the Associated Press. Please proceed with your question.
Michael Warren: Hi, another argument that the Exchange bondholders have made is that actually Argentina has a lot less in its reserves than - well currently, today they declare about $41 billion, after about $1 billion in capital flight over the last 30 days.
But the exchange bondholders argued that when it comes down to it only less than $19 billion of that is even available given all the commitments that that money has been, you know, lent out or owed to or this that and the other thing.
And that actually when you look at the money that Argentina already owes in terms of judgments and everything else that's very similar, it gets up above $50 billion, that there's no possible way that Argentina can pay cash in full plus interest to any creditor in a fair way.
And this is both a technical question and an ethical one. I mean you guys are appealing to fairness, but there's a lot of unpaid Argentine debt holders out there. How can you put yourself at the front of the line?
Richard Samp: I am not a creditor of Argentina, so I'm nowhere in the line.
I can say that, "It's somewhat rich that we are getting arguments about fairness from the Exchange bondholders." Because of course they want to be able to continue to get payments while many other people, including many individual citizens in Argentina are getting nothing whatsoever. So I'm not sure why that is fair.
Also I think it's pretty clear that all of these arguments that the Exchange bondholders are raising are going to be deemed irrelevant by the court. And the reason is that the court has already interpreted the equal treatment clause as saying that, "Some kind of ratable payment is required."
Now it's open for discussion on appeal as to whether or not the district court shows the right payment system. But really what the Exchange bondholders are saying is that, "We don't think that any ratable payment system would be fair because any requirement of payment to the holdouts will likely cause Argentina to default and then we will get nothing."
So it really doesn't from their standpoint, make any difference what the ratable payment formula is, they want to have all holdouts get nothing while they continue to get quite a bit. It's not what they originally bargained for, but it's still quite a bit.
Michael Warren: If I can just interject right there, they actually don't argue that at all. They - they're happy for the holdouts to get the terms of the new exchange that would be what they got, except only a lot better. Because at this point it's not so much pennies on the dollar, but ever closer to a dollar.
And if NML would settle with Argentina for similar terms, then those bonds would quickly get up, according to just market dynamics, to 100% or more.
Richard Samp: Well you're...
((Crosstalk))
Michael Warren: That's their argument.
Richard Samp: Go ahead Bruce.
Bruce Wolfson: I'm sorry. But Michael first of all I'm a lawyer, I'm not a bondholder, I'm not representing any bondholder. But I do think that that's worth noting.
Secondly, you - the argument you've just made is, "That a court of law should determine to restructure the bonds of the holdouts on terms that the Exchange bondholders think are fair," and enforce that. And that that's the right answer.
As a lawyer, I don't think that that is the right answer. And I think that the notion somehow that a court enforcing contract rights that these bondholders have is somehow depriving others of fairness, is not correct. I think that there may very well be a need for further discussions on Argentine debt. I don't know enough to know the answer to that question.
But the forum in which one negotiates restructurings and partial payments is not where one group of bondholders asks a court of law to either deny other bondholders the right to payment, or to impose upon a scheme of payment that other bondholders think is appropriate. That's not the right way to restructure debt.
And if we're worried about precedents that could be prejudicial to future restructurings and the standing of New York as a financial center, I think that kind of result would be very troubling.
((Crosstalk))
Michael Warren: I mean what it posits is a sort of a creative solution that could really resolve this overall overarching problem versus a very narrow solution that would perhaps bring some satisfaction to part of the debt held by some of the plaintiffs but - and not take responsibility for what happens beyond this case.
Bruce Wolfson: And nothing has prohibited Argentina from making proposals to open conversation to come to agreements if they in fact don't have the resources. But the - a court ordering; that is not the right way to negotiate a restructuring.
Richard Samp: Yes, I agree with - completely with Bruce. I mean that's really not in the cards. Courts don't engage in negotiation sessions like that, they are asked to decide issues of law, not to try to come up with some sort of grand bargain.
I also think that the Exchange bondholders perhaps are losing a little bit of credibility when they're coming in now, after the fact -- they were not involved in the case until after the October 26 ruling -- and making this proposal. Well they're making their proposal after the court has already said that the plaintiffs win and that they are entitled to ratable payments.
So that this is perhaps not the most credible time for them to be making that sort of offer.
Michael Warren: One final question, unless someone else wants to jump in. There's a proposal that was put out by one analyst which I thought was kind of interesting, the idea that Argentina losing this case, as it is likely to do, will make a fresh offer to the Exchange bondholders, "You can keep getting paid, but in Argentina, anybody who doesn't want that deal can see their money held in escrow in New York."
What do you think about that possibility? I'm boiling it down to - I'm being overly simplistic, but that's the gist of it.
Bruce Wolfson: I admire your creativity. I (unintelligible)...
Michael Warren: It's not mine, it's what this fund analyst suggested.
Bruce Wolfson: I admire his or her creativity, forgive me. But I think - again I think there are - there is ample room for speculation as to deals that might be reached, that might be fair, that might balance equities. All of those conversations may take place.
This is a court of law hearing and action under a contract interpreting that contract and interpreting remedies with respect to a judgment that was entered, an injunction that was issued. And so I think I can't emphasize enough what Richard said which is that, "In this forum, that's not a possible or an appropriate outcome."
We're trying to create almost a sovereign workout or restructuring vehicle in an appeal to the Second Circuit court of appeals; that's just not the way to do it.
Richard Samp: Let me add one thing. If Argentina were to do as you suggest, they would then almost immediately be held in contempt of court.
Now there is - it's certainly a good question to ask exactly what a court can do to a foreign sovereign once they have been held in contempt of court. And the answer may be that there really isn't a whole lot that can be done.
On the other hand I suspect that Argentina would like if possible, to eventually get back into good graces with financial markets and be in a position where it can have access to future lines of credit. And getting yourself held in contempt of American courts is probably not the best way to go about doing that.
Michael Warren: Okay.
Operator: And there are no further questions at this time. I will now turn the presentation back to the speakers.
Robert Raben: Thank you very much. I don't know if any of the attorneys have any closing remarks they'd like to make. I am deeply appreciative of your attention and the good questions that we've heard. Mr. Samp or Mr. Wolfson, is there anything you wanted to add?
Richard Samp: Not I.
Bruce Wolfson: Nor I, thank you.
Robert Raben: Thank you. We...
Bruce Wolfson: Thank you.
Robert Raben: ...deeply appreciate you coming together and look forward to your - for your questions or thoughts in the coming days. Thank you.
Operator: Ladies and Gentlemen, that does conclude today's conference call. We thank you for your participation and ask that you please disconnect your line.
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