April 29, 2025 Bankruptcy Court Hearing (The Dolphin Company/Leisure Investments Holdings LLC, et al.)

Please rise. Please be seated.

Good morning, your honor.

Mister Brady.

Robert Brady on behalf

of Leisure Investments Holdings LLC at all. We thank the court for hearing us, this morning on some important motions. As we've done the last few hearings, I'd like to start

with just a brief status report on our efforts.

These are the debtors' efforts to obtain control over the debtor's operations, books and records, protect the animals and other state assets, and, develop our strategy to reorganize these companies. The debtors have hired an animal welfare expert, who is now on board. In fact, he's currently handling a move of sea lions. Regulatory bodies in Florida forced the closure of a sea lion pen at the golf world facility, in contemplation of needed maintenance. So we, using our animal welfare expert, are moving those sea lions to a different location.

He's also actively conducting diligence on the animals and the conditions at the various facilities that we have access to. The debtors have hired an investment banker. That motion becoming Greenhill was the selected banker, after interviewing five different banking firms. And we've hired a real estate consultant, Keane Summit. Of course, I'm sure very familiar with Keane Summit.

We've had kickoff calls with both of those advisers, to get that process started. We have, completed the governance changes in Italy. As a result, Riveron is leaving for Italy tomorrow. Since my schedule freed up a bit this week, your honor, I might join them. But, they're going there to conduct necessary diligence and meet with the management team, in Italy.

We've had several meetings with, the mayor of Miami, on the Miami Seaquarium, litigation, animal welfare, and looking for a potential path forward for that valuable property. We've retained regulatory counsel to assist with our dealings and discussions with United States Department of Agriculture. So they're on board and we continue to make progress on affecting the governance changes throughout the corporate structure. As you'll learn today, you're under one area that we've struggled to make progress, despite a significant amount of work and effort, and that is in Mexico. And it comes down to, in our opinion, mister Albor's refusal, to honor the automatic stay in this court's turnover order.

So you don't have to take my word for it, your honor. We have three witnesses, available today, that we would proceed with. We think it makes sense to just start with that motion since it is so, vital to our efforts. Thank you.

Before we start with the motion, if you would like to make some statements.

Thank you, your honor. James Moon, m o o n, on behalf of Eduardo Alvor. Also with me is our local counsel, Michael Busenkow. Thank

you. Let me ask this. I saw in the responsive papers an overture to work toward a resolution? Has there been discussions?

Your honor, as soon as mister Moon was retained, we did have a conversation. I think they were careful in the in the papers to talk about giving us access to u information on The US entities. We really need I mean, as you heard on the first day, the company stopped sending financial statements to the banks, stopped doing any reporting, almost a year before, the bankruptcy. And that's really why mister Albor was replaced, that they were in default, and the banks were getting none of their necessary reporting. We need access to those financial statements, the books and records.

We understand, and you'll hear today, mister Alvor, challenges, of the, mister Strom's position. Mhmm. But I think you'll learn today that as of now, mister Straum is the valid corporate governance of control of the door dolphin while litigation is pending. He is the sole director, and of control of Door Dolphin. So we're entitled to that information, and it's necessary.

Again, they have no access to any liquidity. So I don't know how the the Mexican entities are spending the bank's cash collateral, the lender's cash collateral, but they are. They are operating the business in default, utilizing the lender's cash collateral, which we think is impermissible. But we need access to that information to make sure the animals are being cared for. We understand the financials, and we can start the process of determining the best way to reorganize these businesses.

Okay. Thank you. Mister Mann,

Just on that briefly, your honor. So, yes, actually, as soon as we made our appearance, your honor, the first thing that we did was called debtors council. Been doing this a long time. We don't sandbag, and we wanted to make sure that we reached out to find out, is there a way that we can work with this? And we got some really hard practical issues here.

The first, obviously, is that mister Albor does not want to offend this court. He is a business Now they say that it's completely resolved. We say that it isn't. And, you know, from my view, your honor, the fact that they're asking for another $300,000 retainer for Mexican counsel tells you it's not resolved, and it's not gonna be resolved necessarily fairly quickly. We have conflicting orders from the very same court, the very same judge.

We have different orders from Cancun, from Mexico City, from the Concursa Mercantile Court, which are all under review. And those are gonna have to be resolved pursuant to Mexican law. We have to remember, your honor, that these particular entities filed well before entities any entities actions were taken on March 28 with respect to the Mexican entities. There was as you saw in the papers from both sides, there were precautionary measures entered. And your honor, I don't know if this is the right time to do it, but we did see that there had been a declaration filed late, yesterday from their Mexican counsel.

We felt the need to respond with ours. I have a copy of it because I didn't know if you had a chance to look if I may approach her on it. You may.

Thank you.

So the point of it, your honor, and I'm sure you'll get a chance to read it, is that, and this is not to disparage any lawyer or any position, but advocates advocate. You're hearing two different sides from two very well entrenched, respected legal teams that are dealing with this, that are fighting tooth and nail in Mexico to deal with what they both believe are their rights under the documents. The problem is because this was initiated in Mexico, these orders originated in Mexico. The appellate procedures are in Mexico. The imparo proceedings are in Mexico.

Mexican courts need to deal with this. And the problem is courts need to deal with this. And the problem is if you interfere with that, two things have happened. One, you may issue an order that conflicts with those orders, and now we have a problem of international comedy. Because what is the Mexican court to do?

They've actually if you look at the April 10 order, you'll see that they were they talked about issuing a letter or regulatory to this court to let you know what's going on. They're not hiding. They're trying to tell you this is what's going on. The other issue, your honor, is it it looks to me from the papers, there's this clear, intent to try to make it look like the April 5 order is somehow better or more validity in effect than the April 10 order, which did not supersede it but postdated it. It's not true, your honor.

Both of those honors both of those orders were entered ex parte provisionally in this exact same manner, your honor. And the April 28 order, which you will see an actual certified translation of that order attached to mister Barajas' declaration, that makes very clear, and mister Barajas points out, nothing has changed. The only thing that's happened is that there's been a motion to accommodate or accumulate. A motion to accumulate those orders because the same judge that issued them needs to figure out what to do with these two orders. And he will do that, and my guess is fairly soon, but that process has got to play out.

In the meantime, what are we to do? Well, we obviously don't want the dolphins to go without food or being cared for, and we certainly want employees to get paid. So the issue from our perspective is, number one, they are very convinced that they had a right to enter mister Elbor's building. We have shown that they did not. We've actually attached, the proof that he was able to provide just one of the documents to the district attorney in Cancun, which showed that this is mister Albor's building.

It's not any of the Dolphin Group entities buildings. There is no possessory interest in that building, which means that if you want access to those books and records, which we're saying we're willing to work with you to get them, we need a protocol on how to do that. And I think that's reasonable, and I've been doing this quite a while. Normally, the parties are able to talk to each other and figure this out. And where we don't agree, we can come back to the court and have that decided.

But the second problem you have is that if you issue an order that force that says he's either you turn over those records by x date. If he and his legal team in Mexico are telling him under Mexican law that he has a right under his due process rights in Mexico not to comply with it, he will not because he can't. The issue here is not that he's it's not that he's just entitled to avail himself of Mexican law. You'll see in our papers, we talk about the fact that he has a requirement to do so. Mister Barajas actually puts that in his declaration as well from his legal counsel.

So, you know, this is a very sticky problem. And if this were a law school exam problem, it would would be interesting, I suppose. But for us, we have to think about practically how do we deal with the situate the situation in front of us without violating due process rights of those that are entitled to avail themselves of it. The other issue we we have, your honor, is if think about it. We came in, I think, on April 17.

I think by that time, by the the terms of the interim order, he was already, not in compliance with that order assuming the service was correct. Assuming that the service by his last known email address was correct, which may not even have happened because they even talked about the fact that some of the emails got blocked. But even if it didn't, in Mexico, their position is that they're entitled to process via service through The Hague because they're a Hague signatory. I realize all the issues in the case law about alternative service, but, you know, the issue is not ultimately at the end of the day, which I think they wanna try to prove today, which I would think would be grossly inappropriate, that they now control the company. That is disputed under Mexican law.

Okay? And the issue is not did they have a right to execute a board flip. The issue is did they do it properly, and did they do it when there were actually injunctive measures in place by the Mexican court, which we argue they were. That's precisely why you have the April 10 order saying that those were suspended. And, you know, I I encourage you and I'm sorry for the late time.

It's just I was traveling on a plane yesterday. I was dealing with this at 12:00 last night to try to get you something to respond so that you understand if you're getting just one side of an advocate in a legal proceeding in Mexico, you're not getting the full story about what it is. But even if you have both sides, your honor, is it this court's job to determine what a Mexican court should be doing with the Mexican court's order? I don't think so. So that leaves us with practically what do we do.

I think, as I said day one, tell us exactly what it is you need. Right? Because number one, as you're hearing, they're in charge of a lot of properties apparently in Italy now. They're obviously in charge of the properties, in The States. There are some kinds of books and records there.

I understand that some are not, but I don't know what they are because they haven't told me. We've asked for a list. What exactly is it that you think that you need from this Headquarters building as you call it? We're saying it's mister Albor's building, which it is where there are some records, of Dolphin. The second thing is your honor, if the issue is is related to financial documents, it would be surprising to me that this company doesn't have electronic books and records, which means that we would need a protocol for giving you stuff or access to stuff that satisfies the issues with respect to what you need for the entities you control that do not invade mister Albor's personal records or non debtor company records, and also with the understanding that some of those are going to be protected right now because of the Mexican, entities of the Dolphin Group.

So I'm just trying to resolve this practically, your honor, because I'm trying to I'm putting my I'm trying to put my head to how does this court tell someone that is actively engaged in the legal process, availing themselves of their due process rights in Mexico, you can't do that. I'm saying that Mexican law doesn't apply to that. I just don't think you can, your honor. And so let's try to work practically to fashion something in the interim where the animals are taken care of, employees are paid with respect to the entities that they have, and I have not heard heard yet with respect to this hearing that we're having in three business days before the, you know, the, the May 5 hearing. What was the emergency?

Seems to me from what I see in the papers, the emergency has to do with mister Wagstaff basically trespassing and illegally seizing mister Albor's building. And keep in mind, mister Albor did not come and throw these people out with a group of thugs as they suggest with their Cancun. I

hate to interrupt counsel, but he has testified now for ten minutes. We have evidence today. We have evidence. We have witnesses in the courtroom available for cross I don't believe he has anybody here. So these declarations can't come in.

Mister Brady, let me ask you a question. Mister Brady, the, mister Moon is raising issues that I have been thinking about in preparation for this hearing, which is what is happening in Mexico? What should I be doing with respect to these entities surface, appear to be contradictory, which a judge has in front of him in Mexico. And what should I be doing in that context?

Well, your honor, looking at the the declaration they filed this morning, paragraph four, they acknowledge that the April 28 order states that the March 28 resolutions, those are the resolutions that put mister Straum in place, shall be considered valid until the court rules on the motions to accumulate. So they admit in their own declaration that right now, mister Straum is in charge until further notice. The council, we did have a conversation. We he's not provided a single document to us. Not a single document since April 16.

We asked for the electronic books and records. We asked for access to the, corporate, servers for Dolphin, and we've received nothing. So I it's it sounds nice that they wanna be practical and provide us with information, but they haven't. And that's why we're here. We're here to make clear that the automatic stay and your honor's turnover order requires them to provide us with the company's books and records.

I don't know what they're hiding. I don't know why it should be this hard, but they have not provided us a single document. Nothing. We have the orders. We're asking them to comply.

Then they ask us, well, what do you want? We want the company's books and records. We're entitled to them, and we think your honor can can enter an order that confirms that the automatic stay covers the debtor's property that includes the books and records of the debtors, and we're entitled to them.

Okay. I'll I'll I will hear the evidence. I will need, to read the declaration that was submitted, and I will have questions about the status of the orders in Mexico. Because to me, they look like they were, provisional in nature, akin to a preliminary injunction kind of equivalent, not final orders, which is what the blurbs for the cases that I received from counsel were talking about final orders. And it didn't appear to me, the nonexpert in Mexican law, that these were final orders.

So I need to understand more. So I'll hear the evidence, and we'll go from there.

Thank you, your honor. Hi, Igor. Good morning. Michael Nyberg from Young Conaway on behalf of the debtors. Just one quick table setting thing, your honor, because it it was confusing to me at first.

So there are two proceedings in Mexico. Yeah. And and the motion to accumulate that was filed by the debtors is to consolidate, essentially. The April 28, there's two April 20 eight orders, and that's that's confusing. The one k.

That the debt current for mister Albert talks about one in the proceeding that he commenced. Okay. The April 28 order that's attached and discussed by mister Reyes Espinone is in the proceeding which the motion to accumulate was filed. And it's that order. It's the one that their declarant concedes in paragraph four.

Says, those that the provisional orders are parked until I rule on the motion to accumulate. The March 28 resolutions that appointed mister Strom as sole director of all the Mexican entities in the Dolphin Group remains valid. And it's the same resolutions that kicked out mister Albor and the other directors. So as the table sits currently, the Mexican court, the one that's deciding everything, has said, those resolutions

or whatever the Mexican bankruptcy proceeding?

I I believe your honor, that was dismissed. And I I understand that the dismissal is subject to, some appellate type relief. Okay. But as things stand, it it was dismissed.

Your honor, if I may, I can clear that up a little bit. There are a couple of motions to reconsider that have been filed with respect to the dismissal. There is an Amparo direct proceeding that's been filed and has been accepted. There's an indirect Amparo proceeding that has been filed and is pending acceptance, your honor. So it gets even more complicated.

And what's an an Amparo proceeding? So, your honor, we do have next

I can't see them, but we do have some of our Mexican counsel on the line as well that can tell you. My understanding of it I dropped it in a footnote as well that they said was okay. It's akin to a constitutional like, my constitutional rights have been violated. It's not an appeal. It's something a little different.

It's saying you violated my constitutional rights by ending entering this order, and it needs to be undone, but it's not necessarily an appeal. That's a separate proceeding. And appeals are also the accurate way to go about both the April 4, and the April 10 order. And, also, with respect to what they're referring to in here, keep reading the declaration because, also, accumulation. Thank you.

Okay. Mister Nyberg.

Thank you, your honor. So just to show the path forward, the debtors will seek to admit three declarations. We'll take them in order. The first is the declaration of mister Strom. It's the first day declaration, your honor.

Docket number 10, mister Strom, you met on the at the first day hearing. He is here in the courtroom.

Is there any objection to his declaration coming in subject to cross?

Sir, your honor, my only issue with that, I have no problem with the declaration coming in for the fact that it was filed. I have not had the chance to ever meet him. I have not had the chance to oppose him. And especially on an on an expedited hearing like this, I've had absolutely no opportunity to prepare for a cross. It would be severely prejudicial if these are brought in for truth of the matters that are raised therein.

I have no problem with the fact that they're there, and you can see what he said. That's what he said. We have, on the other side, our verified response, and you can accept that, determine what you think about the veracity of the parties. But it's it's ridiculous for me to try to cross somebody at this at this juncture, your honor.

Your honor, I'll just if you may I respond briefly? Yes. Your honor, the the declaration has been on the docket since 05/01/2025. Debtors filed their motion over a week ago. I understand that mister Moon has been retained for for at least a week.

If there are any particular factual assertions in the declaration to which they disagree, there's plenty of time to perhaps short cross.

Well, I've got an objection to the declaration coming in, and it's, out of court statement. So, you can put them on the stand, but I'm not not gonna accept the

declaration.

Your honor, maybe if I could ask mister Moonwood the purpose that he would say the declaration is admitted. Does that mean mister Griescher could make arguments based upon statements that were made in the declaration to the extent necessary?

I'll take a break and let y'all talk. Okay. This is what I'm gonna do. We're in recess.

Thank, debtors and counsel from mister Abba Roussa resolution in terms of, introducing the declarations. The debtors will seek the introduction of the strong declaration as well as your honor. We ask that the court take judicial notice of the chapter 11 petitions and the resolutions that are attached to them that are on the court's docket. I think, mister Moon may have some clarifying language in terms of, the view as to the purposes for which declarations will

be admitted. Okay. Okay. My point may seem like a picketing point, your honor, but I have no problem with Proffer of his testimony that that was his declaration that he filed as a first day motion with respect to his authority and all that. That.

We're here on a motion to enforce an automatic stay with specific relief finding that mister Albor has violated that. That declaration does not speak in large part to any of that. So my only issue is, did he file that declaration? Yes. He did.

I have no problem with that. That's what he says his corporate authority is. Your honor also understands from the contrary, we dispute that. So, yes, he said that, and, yes, he filed that declaration, but it's not really pertinent in the large in large part with respect to the relief requested today. So if you do proper that, I have no objection to that.

He did file that declaration, and at some point, your honor, we'll be able to look at that, assume that it's true. You and, hopefully, you'll be able to look at stuff that was filed under penalty or perjury on our side and determine that at the appropriate time as well with some of the documents that we have, your honor. That was my only point.

Okay. Thank you. Submitted at that discussion.

Thank you, your honor. Next, the debtors will seek to introduce and admit the declaration of mister Wagstaff. Your honor, it was filed, as exhibit b to the debtors' stay enforcement motion.

Okay. And

your honor, I don't know if there's a need for a proffer, but apologies, your honor. May I approach to be of the debtor's exhibit finder?

Yes. Please. Thank you.

So your honor, the, the declaration of mister Wagstaff references and lays the foundation for what has been, identified as debtors exhibits three to eight in the binder. Let me just, through the declaration, seek the introduction of those documents into the record.

Is there any objection? Objection. You're admitted.

Thank you, your honor. And then next, if necessary, I could offer a short proffer, about the documents that, are at tabs 14 a through d. Your honor, these are letters that mister Waxaff received in his capacity as the debtor's chief restructuring officer. There are letters sent or emails sent by her on behalf of mister Albor or counsel representing him. We just need to introduce those documents.

No objection, your honor. They're admitted.

Thank you, your honor. Thank you. And then, lastly, your honor, for the debtor's evidentiary presentation, seek to admit, the declaration of mister Reyes Escandon, which was docket number 91. That's fine, your

honor. Okay. Then both of those declarations are admitted.

Thank you, your honor. With that, the debtor's evidence, is all in.

Okay. Mister Moon, I take it you have nothing no evidence?

Just just my verified responses. They are declarations under penalty of perjury of the laws of The United States Of America, Your Honor. Any objection? Your honor, I

I think in terms of the verified response, we do object. It's it's not like a declaration where there's identifiable facts. It's it's law and facts. Next, under federal procedure 43 a, press the call is shown why the witness is not present. He's not even present remotely.

So as of right now, it's just someone signed a one page slip of paper and representing that everything stated response is true. Well, in fact, we we just think that at the very least, it should have been on Zoom. It should have been here. All our all the debtors' witnesses are here. So we just object to the court taking in the response as evidence because it's not evidence.

Excuse me. First off, I actually have a group of people that

I think are on Zoom right now. I don't think we can see it.

I would like to. Who were we looking for?

I'm getting messages. I we should have a few Mexican counsel. Mister Albor was going to be on. My, partner, Dan Gonzalez. Mister Barajas, I think, was gonna be on.

Perhaps I've got a whole list here, but I wasn't sure who was gonna be attending. I just figured I'd see them on Zoom.

Yes, we are here. Mr. Barajas is also in the call.

I'm going to, consider the verified response admitted with respect to facts

that are in it, not legal argument. Thank you, your honor. We wouldn't suggest that you specify the law.

And I'm doing that because, obviously, this was a short notice hearing. And given that everything's coming in by declaration, I think it's appropriate and fair.

Your honor, I'm not sure. I I don't know. I don't see mister Alber on the screen. Is he available for cross examination to the extent that the debtors wish to do that? Do you wish to?

I have to confer with counsel. Okay. Well, confirm. I haven't heard confirmation that mister Albert is in one of those offices. I'm actually trying to

find out, if is it okay if I ask?

We're gonna recess for ten minutes and you can ask.

Thank you, your honor.

Apologies, your honor.

Hey, Alfonso?

Yeah.

Please be seated. Mister Greacher.

Hello. Your honor, Sean Greacher from Young Conaway. Thanks for giving us some time this morning, to figure things out. I think we've agreed on

a a

path forward for this hearing and also the hearing that, is scheduled for next week on, the section five forty two e order. Parties intend to proceed with depositions of the various witnesses. Those those depositions will take place in person in lovely Miami, lovely Wilmington, Delaware, with, again, witnesses of lovely Wilmington, Delaware, with, again, witnesses appearing in person to to address the court in connection with those two motions.

Need to talk with miss Johnson. Need to talk to miss Johnson about a couple things on this schedule. So let me do that. So is the idea that we will continue this hearing? We'll continue the hearing next week.

And in the meantime, is there some agreement

the debtors have a very different view of the status quo and the implications of We will take up, counsel, mister Alborz's counsel on, the offer and proposal to provide, necessary documents and information. We'll work with the the Riveron team to assemble that that that list, just to off the top of the head, the the one piece of information that we would we would ask for in particular is, information regarding cash payments made within the next two week period. Obviously, our view is that there is there is there is not a meeting of the minds, and and, obviously, we we

need

court court intervention to help resolve it. But we certainly don't wanna be in a position where to the extent, our our position is successful that funds are no longer to be found in the company.

Are the funds that you're talking about, are they park receipts? What are they? What are the funds? They they

would be they would be park receipts related to member, visitors who are who are attending the parks, as we understand it. The company was likely in a in a cash positive position over the past couple of weeks given the Semana Santa Holy Week, in Mexico. So we believe that there ought to be cash in the accounts. And so, you know, again, not asking for parties to to surrender any of their substantive rights. We're just simply asking for the information.

Obviously, I'm, you know, I I'm putting mister Moon on on the spot with respect to that request, but there will be a handful of of other requests that we will work with him, to to make sure that we, understand what's going on over the next two weeks. Okay.

Sorry. Just briefly, your honor, because we didn't get a chance to do it earlier, mister Albore is on the Zoom. He's at the back of the boardroom that you see there. His camera zooms in on him, I guess, when he talks, but he is here, and he does respect this court. The issue that we're trying to work out, your honor, just from our perspective, is we have to be very careful with respect to the jurisdiction of American Mexican courts and what he he can agree to.

Not that he doesn't want to or wants to be, cooperative. He's gonna definitely try to be as we as I was directed to do as soon as I got into the case, your honor.

So we just wanted to make that representation. Okay. Well, I'm hoping there's a sharing of at least management governance dispute, is out there. And I recognize that may mean that, that that split, that the whoever is actually on the ground handling things is split. Some is, the debtor's team, and and some is, and particularly, I guess, in Mexico, is mister Alberts' team.

So we need to make certain that notwithstanding the the governance issues that that regulatory concerns, safety concerns, people are being paid. But I would hope information could flow and that there wouldn't be a violation of any order that's been entered in Mexico to share information. So thank you. Thank you, your honor.

Good afternoon, your honor. Paul Keenan from Baker McKenzie on behalf of the Prudential Insurance Company of America, Prudential Legacy Insurance Company of New Jersey, and Cigna Health and Life Insurance Company, which I'll just refer to as the, first lien lenders. The first lien lenders are are happy and pleased that the court has set a schedule for depositions and for a continuation of this hearing. I'd be remiss if I did not inform the court that the first lien lenders do have grave concerns about the lack of oversight and the lack of transparency during this interim period. The first lien and second lien debt, total amount outstanding at this point, is approximately $225,000,000 The debtors have been paid payment default for well over a year.

The debtors have not provided the required financial reports under the documents since the fourth quarter of twenty twenty three. As, debtors counsel mentioned, the last couple of weeks were very busy weeks for all the parts worldwide due to the Easter holidays. Presumably, the debtors are flushed with cash at this moment in in Mexico. And the debtors' view, excuse me, the secured lenders' view is that that is our cash collateral. So we would be very keen and insist, quite frankly, upon some kind of transparency over the lump during the interim period during these few weeks.

Just to add to that, we, at a minimum, we're gonna ask that they control the door dolphin start sending the reports that required to under the loan agreement. We can't see how that could possibly violate anything. They are part of the loan agreement, and the lenders are entitled to the reports that they've been denied for over a year. So that'll be part of our request over these

two weeks. Okay. Thank you. Okay. I need another minute now to see when I can fit you in.

So we're in recess. Please be seated. Okay. I'm gonna give you the twenty first at ten.

Very good, your honor. Thank you very much. So I think then we can turn. We had a second motion on, it's uncontested. It's the motion to authorize payments in advance retainers to Mexican counsel for the reasons that we set forth in the, in the motion, and I guess you've gotten a flavor of today.

Our Mexican counsel are working extremely hard to address various issues that have arisen and continue to arise in in Mexico in recognition of that and in recognition of the significant departure from, ordinary Mexican practice, that the firms in Mexico are being, exposed to in in in the United States bankruptcy court. We've requested authority to, pay advanced retainers to those firms. We did speak with mister Hackman. He did provide one, revision to the form of order. If I may approach, I can hand that to you.

Yes. The the changes in paragraph two, and it's a statement that says provided, however, advance for obtainers shall be not not be earned upon receipt in any amounts funded pursuant to the order shall be subject to clawback in the event that Mexican counsel's retention is not approved in the chapter 11 cases. With that, the US Trustee was comfortable with this order, and we would request that

it be entered. Okay. No one wish to be heard. I hear no one. I reviewed it.

I think the change is appropriate. If you upload that revised order, I will sign it.

We will, your honor. Nothing further from the debtors today, but thank you very much for your time.

Thank you. We're we're adjourned. Thank you, your honor.