Welcome to your weekly Title III update for June 25, 2018. Not much happened this week in the case or outside the case.

As I said, not much happened but the controversies that developed centered on a request that at first seemed so innocuous, so I decided not to include it in last week’s report.

On June 14, 2018, the UCC filed an Urgent Motion, Pursuant To Bankruptcy Code Section 105(A) and Bankruptcy Rule 9019, for the Order Establishing Procedures Governing 5.5% SUT Revenues Collected on or after July 1, 2018. The specific relief requested was:

In particular, by this Urgent Motion, the Commonwealth Agent requests entry of the Proposed Order, establishing the following procedures governing the Post-July 1, 2018 Funds:

(a) BONY shall separately account for (i) all 5.5% SUT revenues currently in BONY accounts or received on or before June 30, 2018 (i.e., the Pre-July 1 2018 Funds) and (ii) all 5.5% SUT revenues received by BONY on or after July 1, 2018 (i.e., the Post-July 1, 2018 Funds), so as to ensure that the two pools of funds (and proceeds from investment of such funds) are clearly identifiable;

(b) Upon the effective date of the settlement, the Post-July 1, 2018 Funds shall be allocated and released to the Commonwealth and COFINA in accordance with the percentage shares of the PSTBA set forth in the settlement agreement (i.e., 53.65% for COFINA, which would be the first dollars of the 5.5% SUT, and 46.35% for the Commonwealth) (as it may be modified by a settlement agreement or order of this court, including an order confirming a plan of adjustment for COFINA or an order authorizing such settlement agreement pursuant to Rule 9019 in the Commonwealth’s Title III case); and

(c) In the event that either (x) the Agents do not execute a settlement agreement by August 4, 2018 or (y) the effective date of COFINA’s Title III plan of adjustment approving and incorporating the settlement does not occur within 200 days after the Commonwealth Agent and the COFINA Agent have executed the settlement agreement (as such deadlines may be extended pursuant to the terms of the Agreement in Principle), then the court’s eventual ruling on the ownership of 5.5% SUT not yet collected by the Commonwealth (as of June 30, 2018) shall govern the disposition of the Post-July 1, 2018 Funds (it being understood that neither party is waiving any appellate rights with respect to such determination).

At first glance, this seems like a fairly straightforward way of clarifying how the post July 1 COFINA funds would be distributed in case the settlement is approved.. The ensuing motions, however, show a more profound problem. AAFAF responded and said:

AAFAF does not object to the relief sought in the Urgent Motion, provided that the Proposed Order fully reflects the narrow scope of the relief sought and AAFAF and the Government of Puerto Rico’s (the “Government”) full reservation of all of their rights.

First, and foremost, it is imperative that the Government’s sovereignty and rights to control its instrumentalities not be affected by granting the relief sought in the Urgent Motion. PROMESA section 303 protects the Government’s political and governmental power over itself and its territorial instrumentalities, including COFINA. Those rights should remain exactly as they currently exist. The Commonwealth and AAFAF expressly reserve those rights, including, but not limited to, the exercise of those rights in relation to COFINA, its structure, and the treatment and handling of SUT revenue, as well as the right to oppose or seek modification of the Agreement in Principle or the settlement described therein.

Second, it must be made clear that nothing in the Proposed Order affects in any way the treatment of—including but not limited to collection, deposit, and distribution—the 5.5% SUT collected after the PSTBA is fulfilled in each Fiscal Year, starting with Fiscal Year 2019, beginning on July 1, 2018, and going forward. Those Commonwealth funds are wholly outside the reach of the Commonwealth-COFINA Dispute

Third, it must be clarified that entry of the Proposed Order does not constitute a breach of the COFINA Amended and Restated Sales Tax Revenue Bond Resolution adopted on July 13, 2007, as amended on June 10, 2009.

Fourth, the expeditious resolution of the Commonwealth-COFINA Dispute continues to be of paramount importance to the Government because there is an urgent need to determine whether the Commonwealth or COFINA owns the PSTBA. The Court has already given the Agents until August 4, 2018, to finalize a settlement and the procedural concerns raised in the Urgent Motion should not be used to unreasonably delay the resolution of the Dispute. Thus, the parties in interest must be able to object to any extension of time and to move to modify or terminate the Proposed Order.

Lastly, the Commonwealth-COFINA Dispute only concerns the ownership of the PSTBA and will not resolve issues antecedent to the question of ownership. Accordingly, the Proposed Order should make clear that the Court’s eventual ruling on the ownership of the Post-July 1, 2018 Funds is subject to the resolution of any rights, claims and counterclaims to the disposition of those funds that are antecedent to the ownership question.

Two important things come from this filing. First, AAFAF wants to complete the settlement by August 4, 2018 and may very well object to any extension to this date, meaning that it better be included in the settlement negotiations. Second, even if the settlement is reached, it wants “the resolution of any rights, claims and counterclaims to the disposition of those funds that are antecedent to the ownership question.” Hence, the settlement will not end the Commonwealth-COFINA dispute.

The COFINA Senior Stakeholders took umbrage of AAFAF’s motion and filed a response in support of the UCC motion stating:

However, in light of the response to the Account Motion filed by the Puerto Rico Fiscal Agency and Financial Advisory Authority (“AAFAF” and its response, the “AAFAF Response”) (Dkt. 501), the COFINA Senior Stakeholders wish to bring the following points to the Court’s attention: (1) the Commonwealth’s sovereign immunity in the form of control over “COFINA, its structure, and the treatment and handling of SUT revenue” ceased to be “unfettered” upon voluntary issuance of COFINA bonds with a grant of property rights and a non-impairment covenant made for the benefit of COFINA and its bondholders consistent with the U.S. and Puerto Rico constitutions; (2) the alleged reservation of sovereign power was waived by the Financial Oversight and Management Board for Puerto Rico (the “Oversight Board”), as the representative of COFINA in the title III case, pursuant to the Protocol to the extent necessary to achieve the Agent-led framework; (3) the Court explicitly expanded the authority of the Agents, with the consent of the Oversight Board, for settlement purposes to encompass the final resolution of all claims against or entitlements to COFINA property; (4) the Agreement in Principle contemplates a global settlement of all claims, including claims by COFINA Bondholders against the Commonwealth and AAFAF arising under the U.S. and Puerto Rico constitutions for the impairment of contracts and taking of property—issues clearly within the expanded settlement authority; and (5) AAFAF’s request for an order declaring that no breach of the COFINA bond resolution occurs by virtue of the Account Motion was not part of the Commonwealth Agent’s request, is not properly before this Court, and is in any event beyond the scope of the claims asserted in the Commonwealth-COFINA Dispute.

First, AAFAF is not the proper party to file a response on behalf of the Commonwealth to the Account Motion. Section 315 of PROMESA makes clear that the Oversight Board is each Debtor’s representative in these title III cases. PROMESA § 315 (“The Oversight Board in a case under this title is the representative of the debtor.”). The Oversight Board consented to the Court’s jurisdiction over the authority delegated to the Agents in the Stipulation and Order Approving Procedure to Resolve Commonwealth-COFINA Dispute, Case No. 17-3283-LTS (Dkt. 996) (the “Protocol”), thereby waiving its and the Commonwealth’s rights under Section 305 of PROMESA to challenge that jurisdiction now. See Protocol ¶ 2 (“Solely to the extent, if any, that section 305 of PROMESA serves as a limitation on judicial power over the authority delegated to the Agents, the Oversight Board hereby consents.”). By its response, AAFAF now seeks to encroach upon the authority that Congress granted to the Oversight Board under PROMESA, and insert itself into a dispute for which Congress granted it no authority. Simply put, AAFAF’s right to be heard in the Commonwealth-COFINA Dispute does not empower it with the ability to infringe upon the Agents’ responsibilities under the Protocol or the Oversight Board’s powers under PROMESA. Consequently, to the extent AAFAF seeks to limit the Court’s jurisdiction over the Agents’ disposition of COFINA property in a manner inconsistent with the authority delegated to the Agents as part of a negotiated settlement, that power has been waived.

Second, AAFAF incorrectly asserts that “the Commonwealth-COFINA Dispute only concerns the ownership of the PSTBA and will not resolve issues antecedent to the question of ownership.” AAFAF Response at 4. This assertion completely ignores the Court’s express expansion of the Agents’ authority to mediate and settle all of the “causes of action, claims and counterclaims” that the Court had previously dismissed as out-of-scope. See Order Granting Joint Urgent Motion of the Financial Oversight and Management Board for Puerto Rico, the Commonwealth Agent, and the COFINA Agent for an Order Expanding for Mediation Purposes Only Authority and Immunity Protections (the “Expanded Immunity Order”) (Dkt. 284). Prior to granting the Expanded Immunity Order, the Court heard AAFAF’s objection to that motion (Dkt. 279), based on the same arguments it now makes in the AAFAF Response, and overruled the objection. See Expanded Immunity Order at 6-7 (“PROMESA’s statutory structure thus provides that the Oversight Board, when exercising authority granted to it by PROMESA, is acting as a Commonwealth governmental authority. . . . AAFAF’s objections to the Motion are therefore overruled.”). AAFAF cannot now seek to collaterally attack the Expanded Immunity Order or otherwise narrow the scope of the Agents’ settlement authority.

Third, any concerns regarding the infringement of AAFAF’s sovereignty over COFINA and the SUT are misplaced. The Agreement in Principle contemplates a global settlement of all claims relating to COFINA, including any potential claims against the Commonwealth for exercising its “sovereignty” in violation of, inter alia, the constitutions of the United States and Puerto Rico. There is no violation of sovereignty in settling a dispute regarding the ownership of property and then preventing the government from violating attendant constitutional private rights arising from that settlement to be approved by a federal court.

Finally, AAFAF’s inclusion of purported “clarifying” language as to the Agreement in Principle’s impact on the COFINA bond resolution is procedurally and substantively improper. AAFAF is not party to the Agreement in Principle and therefore has no standing to seek “clarification” of someone else’s intentions. Moreover, the issue of whether the manner in which revenues pledged to COFINA bondholders are being held at BNYM constitutes a breach of the COFINA bond resolution is an intra-COFINA creditor issue that is entirely outside the scope of the Commonwealth-COFINA Dispute. As the Court is aware, these issues have already been thoroughly briefed in a different adversary proceeding before this Court. (emphasis supplied)

Bettina Whyte supported the UCC’s motion and also objected to AAFAF’s motion

It is inappropriate to pre-litigate objections that AAFAF believes it may have to the proposed settlement prior to its final documentation and the submission of a COFINA plan of adjustment that incorporates that settlement as contemplated by the Stipulation and Order. See AAFAF’s Response to the Commonwealth Agent’s Urgent Motion, Pursuant to Bankruptcy Code Section 105(a) and Bankruptcy Rule 9019, for Order Establishing Procedures Governing 5.5% SUT Revenues Collected on or After July 1, 2018 [Adv. Pro. Dkt. No. 501]. The Commonwealth Agent’s Motion only seeks an order dealing with the narrow issue of the procedures for handling post-July 1, 2018 SUT collections pending the parties’ final documentation of the proposed settlement and the Court’s consideration of the plan of adjustment to be submitted pursuant thereto, and the Court should not consider AAFAF’s procedurally improper attempt to seek declaratory relief on other aspects of the Agreement in Principle.

AAFAF was quick to respond to its critics and filed a sur-reply to the COFINA Seniors:

First, the Stakeholders incorrectly assert that AAFAF’s Response encroaches on the Oversight Board’s powers under PROMESA. See Stakeholders’ Response at 3. Not so. AAFAF’s Response requests only that AAFAF’s and the elected Government’s “rights [under PROMESA] should remain exactly as they currently exist.” AAFAF’s Response at 3. This is wholly consistent with the Stipulation and Order Approving Procedure to Resolve Commonwealth-COFINA Dispute (the “Stipulation and Order”) [Case No. 17-03283, Dkt. No. 996], which expressly reserves AAFAF’s and the Government’s rights and powers under PROMSEA section 303. Stipulation and Order ¶¶ 4.g, 11.

4. Further, the Stipulation and Order clearly provides that the Government, through AAFAF, has a right to participate in the settlement process:

To the extent it is necessary or desirable to link a settlement to the treatment of creditors’ claims in a title III plan of adjustment, the Oversight Board and AAFAF may participate in the negotiations and Mediation in an effort to reach such a settlement, . . . . . [and] [a]ll parties in interest, including the Oversight Board and AAFAF, may appear and be heard with respect to any proposed settlement; provided, however, that neither the Oversight Board nor AAFAF shall have any right to contest any judgment made by the Agents pursuant to subparagraph f. Stipulation and Order ¶¶ 4.h and k. Far from seeking to expand the Government’s rights, or in any way “encroach upon” the Oversight Board’s authority, AAFAF’s Response requests the preservation and reservation of rights the Court has already recognized. (emphasis supplied)

5. Second, the Stakeholders mistakenly claim that in requesting confirmation that “the Commonwealth-COFINA Dispute only concerns the ownership of the PSTBA and will not resolve issues [separate from] the question of ownership,” AAFAF is attempting a collateral attack on the Court’s prior order expanding the Agents’ authority to negotiate a settlement. Stakeholders’ Response at 4, quoting AAFAF’s Response at 4. But AAFAF’s request has nothing to do with settlement negotiations. Rather, it simply seeks confirmation of the Dispute’s scope in the event that the settlement process fails, in which case the Agents’ expanded authority to mediate and settle the Dispute is inapplicable. Because AAFAF’s request for clarification concerns a situation that will only arise if the Agreement in Principle is not consummated, it cannot possibly “attack the Expanded Immunity Order or otherwise narrow the scope of the Agents’ settlement authority.” Stakeholders’ Response at 4 (emphasis added). Indeed, far from prejudicing the Stakeholders, AAFAF’s request sought to protect rights, claims, and counterclaims of all the interested parties, including the Stakeholders.

6.Third, the Stakeholders again miss the point in asserting that AAFAF’s “concerns regarding infringement of [its] sovereignty over COFINA and the SUT are misplaced” because neither a court-approved settlement, nor the Court’s enforcement of constitutional private rights will violate its sovereignty. Stakeholders’ Response at 5. The Urgent Motion only seeks to put in place interim procedures pending the settlement of the Commonwealth-COFINA Dispute or the Court’s eventual ruling in the litigation. See Urgent Motion at 1-5. As previously stated, AAFAF filed its Response and Proposed Order to provide clarifications ensuring—among other things—that its rights under PROMESA were not prejudiced or waived by the interim relief sought. The scope and legitimacy of the proposed settlement are not at issue here. Indeed, both the Commonwealth Agent’s and AAFAF’s respective Proposed Orders reserve the rights of the parties in interest to “oppose the settlement described in the Agreement in Principle” or “object to entry of any order implementing the settlement . . .” Commonwealth Agent Proposed Order ¶ 8; AAFAF Proposed Order ¶ 11.

7. Fourth, and finally, the Stakeholders wrongly assert that AAFAF “has no standing to seek ‘clarification’” regarding “the Agreement in Principle’s impact on the COFINA bond resolution.” Stakeholders’ Response at 5. This assertion is directly contradicted by the Stipulation and Order, which, as noted above, gives AAFAF standing to appear, participate, and be heard in regard to the settlement process. Stipulation and Order ¶¶ 4.h and k. Paragraphs 4.h and k were ordered by the Court and agreed to by the Stakeholders.4 Further, the Court has held that AAFAF has standing to be heard with regard to the Commonwealth-COFINA Dispute. See Order Approving COFINA Agent’s Motion Pursuant to 48 U.S.C. § 2161 and 11 U.S.C. § 105(a) for Order: (I) Confirming that 48 U.S.C. § 2125 Applies to COFINA Agent; (II) Confirming Retention of Local Counsel; and (III) Clarifying Payment of Fees and Expenses of COFINA Agent and Her Professionals [Case No. 17-03283, Dkt. No. 1612] (“Section 105 Order”) at 2 (finding that AAFAF had “standing to be heard”).

8. AAFAF’s request for clarification that entry of an interim order will not constitute a breach of the COFINA bond resolution is also consistent with the Section 105 Order. That order expressly addressed the issue of a court order potentially breaching the COFINA bond resolution. See id. at 4 (“provided, however, that any payment of the Agent/Professional Fees . . . from the COFINA Custody Account . . . at Banco Popular shall not be deemed to be a breach of any of the relevant COFINA bond resolutions or provision of Puerto Rico law.”). Thus, AAFAF has standing to make its request for clarification, and the Court has jurisdiction to clarify the interim order’s impact on the COFINA bond resolution.

The GO Group supported the UCC’s motion but stated:

The GO Group’s joinder in the Motion does not change the GO Group’s position on the Agents’ agreement in principle as currently drafted. As explained in the GO Group’s response to the motion to hold summary judgment in abeyance (No. 17-257-LTS Dkt. 488), the agreement in principle is fatally flawed, and the GO Group expects to work constructively with all parties in interest during the abeyance period to fix the agreement’s flaws in an effort to achieve a consensual resolution. Without adjustments to remedy those flaws, however, a settlement based on the Agents’ agreement in principle cannot and should not be approved.

In its Omnibus motion to reply to oppositions, the UCC discussed AAFAF’s requested language and stated:

Notwithstanding the Commonwealth Agent’s acknowledgement that AAFAF’s rights (if any) should be (and are) preserved, it is at least questionable whether the specific rights AAFAF seeks to “preserve” here are rights that AAFAF actually possesses under the Stipulation. Accordingly, the Commonwealth Agent cannot agree to the language proposed by AAFAF in its revised proposed order 24 as the scope of AAFAF’s (and any other party’s) rights under the Stipulation should not be litigated in the context of the Urgent Motion.

15. Specifically, AAFAF asserts that the sovereign rights it seeks to “preserve” in connection with section 303 of PROMESA include rights over the “structure” of COFINA, the “treatment and handling of SUT revenue,” and the right to “seek modification of” the Agreement in Principle. Whether the Stipulation grants AAFAF such rights is questionable, given that the Stipulation (i) includes an express waiver of the sovereign protections of section 305 of PROMESA and (ii) is clear that negotiation of a settlement is left to the Agents, and will be “effective upon” the Commonwealth upon the satisfaction of certain conditions, none of which require the Commonwealth or AAFAF’s consent, and, in fact, expressly prohibits AAFAF from “contest[ing] any judgment made by the Agents pursuant to subparagraph f.”

16. Stated otherwise, AAFAF’s rights regarding the Commonwealth-COFINA Dispute and the Agreement in Principle are set forth in the Stipulation and are neither impaired nor affected by the Urgent Motion. Determination of the exact extent of AAFAF’s rights (or any other party’s rights) under the Stipulation are not the subject of the Urgent Motion—which expressly leaves all such rights undisturbed—and can be determined (if necessary) at a later time. Moreover, AAFAF’s request that the order state that it does not affect any SUT revenues collected after the PSTBA is first reached for each fiscal year is unnecessary, as the Revised Proposed Order already clarifies that it does not affect “the collection, transfer, or deposit of SUT revenues that are not deposited with BONY.” (emphasis added)

17. Separate from its demand for a reservation of rights, AAFAF also states that it does not object to the Urgent Motion “provided that the Proposed Order fully reflects the narrow scope of the relief sought.” While benign in theory, AAFAF’s formulation of the narrow scope of the Urgent Motion is not only beyond the scope of the relief sought in the Urgent Motion, it actually would inappropriately expand the scope of the Commonwealth-COFINA Dispute. In particular, AAFAF demands that any order granting the Urgent Motion make clear that its entry does not constitute a breach of the COFINA Amended and Restated Sales Tax Revenue Bond Resolution adopted on July 13, 2007. However, the question of what is a breach of the COFINA resolution is a purely intra-COFINA creditor dispute not properly before the court in this adversary proceeding. As the court knows well, the question of whether there has been a breach of the COFINA resolution is the subject of the interpleader action commenced by BONY separately pending before the court, in which neither of the Agents is a party.

18. Finally, AAFAF states that “the Commonwealth-COFINA Dispute only concerns the ownership of the PSTBA and will not resolve issues antecedent to the question of ownership,” and demands that any order granting the Urgent Motion clarify that any ruling on ownership of the SUT revenues is subject to these “antecedent” issues. The question of exactly what issues are within the “scope” of the Stipulation and can be settled by the Agents is already the subject of multiple court orders; it is wholly inappropriate to use the Urgent Motion to relitigate these issues, and the court should therefore reject AAFAF’s requested language (which is, in any event, ambiguous). Moreover, the Revised Proposed Order now clarifies that the court’s ruling will only determine the ownership issues as between the Commonwealth and COFINA (in contrast to the relationship between COFINA and its creditors), which should more than address the AAFAF’s concern. (emphasis supplied)

From this discussion, it is obvious that the Commonwealth and the GO’s want to participate in the settlement discussions but neither Bettina Whyte nor the UCC want them there. That is why the new proposed order states that the ownership issues of the Court ruling will only be about ownership issues between the Commonwealth and COFINA, which leaves the GO’s out, as well as AAFAF, since the UCC has been designated by the Board as its representative.

In essence, the UCC, COFINA Agent and COFINA bondholders want to make a deal only between them. A deal that cannot be challenged by the Commonwealth or the GO bondholders. That however, will not happen since these two parties have been very clear they want to participate and if their objections are not addressed, they will object to the settlement. Judge Swain will likely look askance at a settlement pertaining to the SUT that does not include the Commonwealth or the GO’s. This will only delay the filing of the Plan of Adjustment for COFINA and the Commonwealth. And, the clock is ticking.

The Bank of New York Mellon, the COFINA trustee, also objected to the UCC’s motion, “on the basis that the Proposed Order does not preserve the status quo but instead alters it in favor of the Commonwealth.” The UCC replied:

As explained in the Urgent Motion, it is possible that, if the settlement were to fail, the court eventually could issue a “split ruling” on the merits of the Commonwealth-COFINA Dispute, pursuant to which the Commonwealth would be held to own all future SUT revenues, but COFINA would be held to own SUT revenues already deposited in the BONY  accounts. A confluence of factors — the possibility of such a “split ruling,” the upcoming resumption on July 1, 2018 of the deposit of SUT revenues into accounts with BONY, and the Abeyance Order — means that the mere passage of time could inequitably improve COFINA’s position. Thus, in the event of a “split ruling,” the daily collection and transfer of SUT would cause the steady erosion of the Commonwealth’s position beginning on July 1, 2018, and the simultaneous and corresponding improvement of COFINA’s position.

In addition, the Mellon Bank requested intervention in the Commonwealth-COFINA dispute and, surprise, surprise, the UCC objected, except to a very limited aspect, to wit:

Notwithstanding its focus on BONY’s asserted need to protect the (alleged)

interests of an amorphous group of “Beneficial Holders” (which need, as described above, is illusory), the BONY Intervention Motion (and the Proposed BONY Objection) also identifies a few procedural matters that are applicable solely to BONY:

 BONY asserts an interest in ensuring that any order granting the Urgent Motion clarifies that BONY will not be liable for complying with such order;

 BONY asserts a right to be heard with regard to the specific procedures to be put in place by an order granting the Urgent Motion, to ensure that such procedures are not unduly burdensome to BONY; and

 BONY asserts a right to payment from SUT revenues it holds for its fees and expenses and indemnification that has priority over all payments to COFINA bondholders.

The Commonwealth Agent acknowledges that BONY’s interests with respect to these limited issues are not adequately represented by the existing parties, and has no objection to BONY being heard on these limited issues.8 However, the Commonwealth Agent believes that the modifications reflected in the Revised Proposed Order should fully address BONY’s concerns.

The Puerto Rico Senate officially refused to repeal Law 80 and the insult filled exchange between its President, Thomas Rivera Schatz, and the Governor, was epic. Seems to me that Rivera Schatz is betting the Board will not impose draconian budget cuts and even if it does, he has said he will go to Court. Representative Luis Vega Ramos has publicly stated that if the Board does not respect Puerto Rico’s budget, he will also go to go to Court. Even if they lose, which they probably will, they can claim they are the true leaders of the opposition to PROMESA and the Board. Again, this type of litigation will only delay the filing of the Plan of Adjustment to the detriment of the People of Puerto Rico. Let’s see what happens.

Other developments far from Puerto Rico will have an impact on PROMESA. On June 21, 2018, the Supreme Court of the United States decided the case of Lucia v. Securities and Exchange Commission. In it, the Court determined that the ALJ of the SEC wielded substantial power based on federal statutes and therefore were subject to the Appointments Clause of the US Constitution. This is precisely the question presented to Judge Swain in by Aurelius and Utier. The oral arguments were on January 10, 2018 but Judge Swain has not ruled yet. It would seem the Judge really does not want to rule on it since it could derail the whole PROMESA proceedings. However, with the ruling by SCOTUS, how much longer can Judge Swain hold off from addressing the question before the Court?  We already know what parties will do next regardless of her ruling.

This summary is merely what I believe are the more salient motions and decisions in the cases. I receive an average of 20 filings each day so it would be impossible to summarize everything. If you have legal interest in these cases, I urge you to hire an attorney to represent you.