PN1

THE COMMISSIONER: All right, so in Melbourne I have got Mr Pegg from the National Disability and Ms Liebhaber and then in Sydney I have got Mr Robson from the ASU.

PN2

MR N ROBSON: Yes, sir.

PN3

THE COMMISSIONER: Mr Bull from United Voice.

PN4

MR S BULL: Correct.

PN5

THE COMMISSIONER: Mr Ferguson from AiG.

PN6

MR B FERGUSON: Yes. Yes, Commissioner.

PN7

THE COMMISSIONER: Ms Lowe from AFEI.

PN8

MS S LOWE: Yes, Commissioner.

PN9

THE COMMISSIONER: Then on the phone I have got Mr Scott and Ms Tideman, ABI.

PN10

MR K SCOTT: Yes, Commissioner.

PN11

THE COMMISSIONER: Can you hear me okay?

PN12

MR SCOTT: Yes, thank you, Commissioner.

PN13

THE COMMISSIONER: Thank you. All right, so I have received a timetable from Ms Tideman 2.03 pm today setting out a proposed program. Is there anyone not in agreement with that? Is everyone - firstly, is there anyone who hasn't got a copy of that?

PN14

MR ROBSON: I must confess I am looking at a slightly earlier version but I am looking at Mr Bull's now.

PN15

THE COMMISSIONER: All right. Is there anyone who is not in agreement that that is the proposed timetable?

PN16

MR PEGG: Commissioner, I have a correction to that.

PN17

THE COMMISSIONER: Yes, yes.

PN18

MR PEGG: Mr Miller on Thursday will need to be in Brisbane by video conference.

PN19

THE COMMISSIONER: Right. Brisbane by video.

PN20

MR PEGG: I also have a question regarding Emily Flett. She was originally a witness that we were going to require. We no longer do but I have not been able to confirm if any of the other employers want to keep her on.

PN21

THE COMMISSIONER: All right. We might just come back to that but the substantial question is, is there anyone disagree that this is the timetable subject to any tweaks that anyone needs to make?

PN22

MR BULL: Commissioner, it's Bull in Sydney.

PN23

THE COMMISSIONER: Yes.

PN24

MR BULL: The only - we agree. This has been a document which has been worked up by the group. The only point which we have, and I think I can speak for the three unions, is that perhaps on Friday we - we're endeavouring to limit cross-examination so we are working in a co‑ordinated manner to make - we don't ask the same question three times, et cetera, but even if we do it in a minimalist fashion we are likely to probably need 45 minutes with the employers' witnesses so I note Friday's quite a busy day, so - - -

PN25

THE COMMISSIONER: Sure. Well we will sit late if need be.

PN26

MR BULL: I'm just warning the Commission.

PN27

THE COMMISSIONER: Sure, doesn't worry us. We'll sit until we finish.

PN28

MR BULL: Okay, well I just - I didn't want to - and as I say we're going to make an effort to keep it sharp and focussed.

PN29

THE COMMISSIONER: Sure, okay, but thanks for that. Any other - I'm taking it then that this is - we do have agreement that this is the schedule that we will until(sic). Just returning to the Emily Flett. That's an ASU witness. She's on at 10 o'clock in Melbourne on Friday so the query is, Mr Pegg, whether - - -

PN30

MR PEGG: Whether any of the other employers require her for cross-examination.

PN31

THE COMMISSIONER: Because you - - -

PN32

MR PEGG: We put her on the list originally. We've taken her off.

PN33

THE COMMISSIONER: But you don't want to cross-examine her.

PN34

MR PEGG: We don't want her now.

PN35

THE COMMISSIONER: All right. Does anyone else want to cross-examine Ms Flett?

PN36

MR SCOTT: Commissioner, it's Mr Scott on the phone. We've raised some objections to a number of the statements including Ms Flett's statement. We're hoping to able to resolve those objections with the ASU so pending where we land on the objections, I think it's sensible to keep her in marked for cross-examination.

PN37

THE COMMISSIONER: Okay, but she might come out.

PN38

MR SCOTT: Yes, and that's the case for quite a number of the witnesses where we're waiting back from two of the three unions in respect of those objections.

PN39

THE COMMISSIONER: All right. Thanks for that.

PN40

MR FERGUSON: Commissioner, it's Mr Ferguson. I anticipate Kinshen will not be required. I've just got to get confirmation from an employer on one point. I have told the union.

PN41

THE COMMISSIONER: Not be required for cross-examination by AiG?

PN42

MR FERGUSON: That's right, so just in case anybody else wants to I thought I should raise that now.

PN43

THE COMMISSIONER: Well does anyone else want to - - -

PN44

MR FERGUSON: I might - - -

PN45

THE COMMISSIONER: Anyone else want to cross-examine Kinshen? No?

PN46

MR SCOTT: No.

PN47

THE COMMISSIONER: We can strike her off the list?

PN48

MR FERGUSON: No. I'll just confirm. I've got to make one phone call to the employer. I just a message and I'm acting on that and I'll just confirm straight after this and advise the union and the Commission.

PN49

THE COMMISSIONER: All right.

PN50

MR FERGUSON: The only other comment I might make is although these are the nominated times, I anticipate from discussions with the employers that some of the cross‑examination could be relatively short and it probably prudent for the witnesses to be available at least some period before the nominal time just so that we don't lose a lot of time waiting 20 minutes here, 20 minutes there for the next witness. That's - - -

PN51

THE COMMISSIONER: Sure. There's only a certain extent to which, from here, this can be linear programmed. To a certain extent it's up to the parties to be in constant communication, as it is with these big cases, such as it was in the penalty rates and so on, so you'd need to be speaking every day about where you're at and absolutely making sure, Mr Ferguson, that all the witnesses are available ahead of schedule in case we pick up speed.

PN52

MR FERGUSON: Yes. It's just in a lot of these cases where people have come just at that time we've lost a lot of time, or the Bench has lost a lot of time, rising for 10 minutes ‑ ‑ ‑

PN53

THE COMMISSIONER: Absolutely.

PN54

MR FERGUSON: - - - and it just - people could be there an hour before or at lunch, everyone after lunch could be there or available.

PN55

THE COMMISSIONER: Well look as a general rule, can we have witnesses there an hour before their scheduled time? That was a rhetorical question. Let's have them there an hour before their scheduled time.

PN56

MR BULL: Just to - sorry.

PN57

THE COMMISSIONER: No, you go.

PN58

MR BULL: Just to - I can talk to Kyle or Madeleine about this but I am just saying it may be useful if we can put some of the - Jarred Marks is a witness who's easy for us to move anywhere because he's an industrial officer in our Queensland branch so we could move him to the Wednesday. It's just the reality of these cases is the employee witness, the lay employee witnesses, tend to be quicker than the employer. It just seems would be useful to move some of Friday to Wednesday if we can.

PN59

THE COMMISSIONER: Sure.

PN60

MR BULL: I'll talk to my friends about that.

PN61

THE COMMISSIONER: Yes, keep the conversations going. It doesn't matter, we just need a program to get started with and if you decide that - you're right, Mr Bull, Friday's pretty heavily loaded so you want to avoid being there until late in the evening, all of us, then, yes, you might be able to move some people early in the week. Couple of things I wanted to just clarify. Other than the witnesses that have just been mentioned today as possibly not being required for cross-examination, in my tick off of the list witnesses that are not required to appear, it would appear, are Richard Rathbone, Judith Wright, Fiona Macdonald, Pamela Wilcock, Thelma Thames, Bernie Lobert, David Moody and Melissa Kode.

PN62

MR BULL: With Melissa Kode, there's still a little bit of negotiation but I'm optimistic that we're not going to - we were able to agree to what the employers want. The problem with that, Ms Kode, is that she's on leave at the moment and it's a bit difficult to re-execute her statement.

PN63

THE COMMISSIONER: All right, so she's a maybe but other than that there's no contention that the rest of them are not going to be required?

PN64

MR BULL: Well that's what I've asked, she's on that list.

PN65

THE COMMISSIONER: All right.

PN66

MS LIEBHABER: Commissioner, just in relation to Fiona Macdonald, I advised in an email earlier that we propose to make her available on the Thursday in case there are any questions from the Bench and - - -

PN67

THE COMMISSIONER: Sure. Yes, I appreciate that, yes, good point. Look the - - -

PN68

MR BULL: The expectation is that the ones that aren't required, that their statements are going to be tendered.

PN69

THE COMMISSIONER: Yes, of course, I understand. All right.

PN70

MR SCOTT: Commissioner, can I just raise one other matter?

PN71

THE COMMISSIONER: Yes.

PN72

MR SCOTT: There's two witnesses on the schedule for Thursday, Scott Quinn and James Eddington, for which I'm not sure, we certainly haven't indicated we want them for cross-examination and I'm not aware that any other employer party have requested them for cross-examination so it may be that they can come off the list but there may be other employer parties want to speak to that if they do want.

PN73

THE COMMISSIONER: Well they could - we can resolve that now. Is there any employer party that wants to cross‑examine Scott Quinn?

PN74

MR FERGUSON: No.

PN75

MS LOWE: No, Commissioner.

PN76

THE COMMISSIONER: No, well we can take him off the list.

PN77

MR BULL: I note David Moody's also on the list for Thursday.

PN78

THE COMMISSIONER: Can I just go to James Eddington next.

PN79

MR BULL: Sorry, sir.

PN80

THE COMMISSIONER: Is there any employer party that wants to cross-examine James Eddington?

PN81

MR FERGUSON: No.

PN82

MS LOWE: No, Commissioner.

PN83

THE COMMISSIONER: No, we'll take him off the list.

PN84

MS LIEBHABER: Commissioner, I put him on the list because there was some correspondence from ABI about some objections to James Eddington's statement and a request about the transcript from the part-time casual case being admitted in relation to Scott Quinn's evidence and we haven't had a chance to reply yet so I've just included them in case those issues aren't resolved so but that's just - - -

PN85

THE COMMISSIONER: Mr Scott, did you hear that?

PN86

MR SCOTT: I did. In respect of Mr Quinn that's correct and I'll just deal with that in a minute. In respect of Mr Eddington, that's not the case. We have indicated that he's not required by us for cross-examination and we haven't raised any objections in respect of Mr Eddington's statement. In respect of Mr Quinn, my memory is that he's given two statements in these proceedings, or there's been two statements filed.

PN87

The first statement that was filed is from 2015 which was a statement that was filed in the common issues casual part‑time proceedings and Mr Quinn gave evidence in those proceedings and was cross-examined and so we'd indicated to the HSU that if it's their intention to rely on that statement from 2015, then we will wish to tender the relevant parts of the transcript where he was cross‑examined in respect of that statement because it just seems to be the most efficient course because otherwise we'll effectively have a dress rehearsal or we'll be re‑doing cross‑examination from 2015 that's already on transcript.

PN88

THE COMMISSIONER: Yes, okay, I see.

PN89

MR SCOTT: It may be that the HSU want to consider that and whether they may object to the transcript being tendered but that's our intention.

PN90

THE COMMISSIONER: All right. Shall we leave Scott Quinn there for the moment then while you have some discussions about that?

PN91

MR SCOTT: Yes, we have no objection to that.

PN92

THE COMMISSIONER: All right.

PN93

MR FERGUSON: Just one point of clarification then, I think this relates to Eddington but others as well. I think Mr Eddington's statement was one that's already been tendered in the first tranche of proceedings and significant amounts of that have been struck out due to objections that we raised. I assume that it's that evidence as already tendered that's being relied upon, I think a clean version might be in the court book, but we're not crossing because we understand that the objections have already been ruled on.

PN94

THE COMMISSIONER: Sure. That be the case?

PN95

MS LIEBHABER: Yes, Commissioner, I believe that was the decision.

PN96

THE COMMISSIONER: Yes.

PN97

MR FERGUSON: I just wanted to make sure there was no ‑ yes.

PN98

THE COMMISSIONER: Well that was a affirmative from Ms Liebhaber.

PN99

MR FERGUSON: Yes.

PN100

THE COMMISSIONER: Anything else? Any other points of clarification around the schedule?

PN101

MR BULL: I just noticed David Moody's on the Thursday and he can be removed.

PN102

MR ROBSON: No, he's off the most recent one.

PN103

MR BULL: I've got an old one then, sorry.

PN104

THE COMMISSIONER: Anything else?

PN105

MR SCOTT: Commissioner, can I just - it's Mr Scott here. Can I just raise one other matter?

PN106

THE COMMISSIONER: Yes.

PN107

MR SCOTT: There's a witness listed for Wednesday, Rob Steiner, who's an ASU witness. We've have some recent discussions with Mr Robson about his statement. We understand there's a complexity to this evidence in light of the fact that we understand that he's executed a deed of release as part of a confidential settlement with his former employer and so we're kind of grappling with that at the moment in terms of it may be the case that if he intends to affirm the contents of his statement, he may well find himself in breach of a deed that he's entered into so we're having some discussions with Mr Robson and waiting for him to indicate what their intention is in relation to him so it may be that we can update the Commission on Tuesday morning as to the status of his statement.

PN108

THE COMMISSIONER: Sure. Thanks for that, Mr Scott. Anything else from anyone? I'll just run through a few other issues. Reminders, of course, that for Bundaberg it'll be 9 am Queensland time for Trish Stewart as currently scheduled and 9.30 am for Deon Fleming.

PN109

MR BULL: I appreciate that, Commissioner.

PN110

THE COMMISSIONER: Just make sure you're all across that. Confirm that the - look the other thing I should mention, just while there's further discussions going on about the programming and there might be some changes to this schedule, I don't think my colleagues on the Bench will be upset if I indicate that we'd be happy to start at 9 o'clock in the morning so you can have people slotted in earlier rather than just looking to find spaces for them later in the day, okay.

PN111

I can confirm we've got video available in Newcastle or phone for witnesses appearing there which - well maybe Rob Steiner, maybe not and then there was the query about Tracey Kinshen as well but if either of those are appearing in Newcastle then you just need to advise us whether you want phone or video. In terms of personnel in Newcastle, there is only Saunders DP and his associate. If they're around at the time they may be able to assist but basically I just can't give you any guarantee of that.

PN112

If they're engaged in proceedings and are unable to be available then there won't be any personnel there. I can confirm that for Coffs Harbour, Bundaberg and Albany, because they are through the local district courts, magistrates courts, they just don't assist at all so we don't have any personnel there, so if there's things that you want to do in terms of putting things in front of the witnesses you'll need to make some sort of prior arrangement to get that material in front of them.

PN113

MR FERGUSON: We're trying to work through that now, Commissioner.

PN114

THE COMMISSIONER: Yes.

PN115

MR BULL: We were going to have our organiser accompanying our witnesses in North Queensland so if anyone wants to show either the Bundaberg witnesses material, can they get it to me - - -

PN116

MR FERGUSON: As soon as possible.

PN117

MR BULL: - - - well really Monday and I can get it to the organiser and it'd be - I'd appreciate it if it could be in a bundle with a label on it and paginated preferably.

PN118

MR ROBSON: It won't be much.

PN119

THE COMMISSIONER: But that's in the hands of the parties to organise. I'm just being clear about that. I can say that Albany is confirmed as a venue and where else am I confirming? I'm confirming Newcastle and Bundaberg, or is it that? Yes, Albany, Bundaberg and Newcastle, they're all good to go. Coffs Harbour local court, we haven't spoken to them yet but we will now we have confirmation that those two witnesses are still needed there. That's all I needed to cover.

PN120

We have, that's the other point, we have a full copy of the court book to show to witnesses in Sydney but we've not done that in Brisbane or Melbourne, so if you want particular things prepared for witnesses in those places to be shown, let us know but given the enormous volume it didn't seem really a sensible use of resources to cut down another two forests, having already cut down one, to do that so if you can provide some guidance to us if there's any particular material that you want put in front of witnesses in those places, let us know. That won't become an issue until Mark Farthing later on the day on Tuesday. All right?

PN121

MR BULL: It may just be a statement of the obvious but could all the witnesses have their statement with them when they give evidence?

PN122

THE COMMISSIONER: Yes, thanks for mentioning that, Mr Bull. That would be - it is a statement of the obvious but it doesn't necessarily follow so let's just make sure that that is the case, all of you. In terms of information on what parts of the evidence relate to which claims, the United Voice and the ASU have done their homework on that, thank you. No-one else has. I think I asked for that by the end of today so please make sure that's completed. When we have all of that in, we'll populate the schedule so that that's clear for all of us as to what each witness is directed towards giving evidence about.

PN123

Look probably the last thing to say on the schedule is the Bench is determined to get through all of the evidence next week but we'll be flexible within the week, as I say in terms of earlier starting and later running but that's the way you need to think about it in terms of programming not thinking about it in terms of it's too hard, we'll want to do this in some other time. We want to get through all of the evidence next week. Clear enough?

PN124

MR FERGUSON: Yes.

PN125

THE COMMISSIONER: The second last thing from me was, United Voice, you've put in a form F51.

PN126

MR BULL: That's correct.

PN127

THE COMMISSIONER: I just wasn't sure - just let me find it. Both Ms Sinclair and Ms Fleming are employees and those from the Commission requiring their attendance will assist with ensuring their employers permit them time off to give evidence. I mean, is there any - - -

PN128

MR BULL: It's essentially - sorry.

PN129

THE COMMISSIONER: No, no.

PN130

MR BULL: Sorry, Commissioner. Both of these witnesses are permanent part-time employees. It will assist in the sense that we're still negotiating with the employers. They are available but the terms, I suppose, are the nature of being released for the day, so an order like this will assist us in clarifying to the employer that they're taking the day off, so to speak, for a proper purpose. Our preferred position is that they're released on pay and an order will ‑ ‑ ‑

PN131

THE COMMISSIONER: I'm just loathe to issue a notice in circumstances where the employer can simply be told where it is that they're going. Are they both with the same employer?

PN132

MR BULL: I think they are. I don't have their statements in front of me.

PN133

MR FERGUSON: I can undertake to tell the employer. I think it's - - -

PN134

THE COMMISSIONER: What's that, sorry?

PN135

MR FERGUSON: I can undertake to tell the employer. I think it's Live Better.

PN136

THE COMMISSIONER: That's where I was heading - - -

PN137

MR FERGUSON: Yes, and it's not - - -

PN138

THE COMMISSIONER: - - - heading, Mr Ferguson.

PN139

MR FERGUSON: We don't want - - -

PN140

THE COMMISSIONER: If they're a member of any of the - - -

PN141

MR FERGUSON: Yes, I can't speak to their preparedness to pay but I can undertake to confirm their involvement in the proceedings.

PN142

THE COMMISSIONER: Yes.

PN143

MR BULL: Well the issue for us is it does - my experience has been that it is easier to justify releasing an employee on pay if one of these orders is available and I would urge the Commission to make the order.

PN144

THE COMMISSIONER: All right. Well are there any views from other parties as to whether I should issue an order? Ms - - -

PN145

MS LIEBHABER: Just from our experience, we have had a bit of push back from some employers with - even though they have - we have managed to get our members released from duty that some employers have commented that it's very last minute notice, et cetera, so - - -

PN146

THE COMMISSIONER: I'm really interested in these particular people.

PN147

MS LIEBHABER: Well - - -

PN148

THE COMMISSIONER: I mean orders are not - I'm not interested in what generally happens, Ms Liebhaber.

PN149

MS LIEBHABER: I think given that there's been such late notice of whether and when the witnesses are required, we think that's relevant - - -

PN150

THE COMMISSIONER: Well that's going to be the case for all of them. I'm not issuing notices for everybody. What ‑ ‑ ‑

PN151

MR BULL: There's also an additional - sorry.

PN152

THE COMMISSIONER: I was actually interested in - - -

PN153

MR FERGUSON: I just - - -

PN154

THE COMMISSIONER: - - - what the employers might want to say about it.

PN155

MR FERGUSON: I don't have instruction as to whether or not the employer is actually opposing it but I thought I apprehended from what Mr Bull said is that there is no opposition from the employer to their attending. It's just that the union wants to pursue it as some sort of justification for getting paid which I'm not sure why that would be necessary.

PN156

MR BULL: That's one reason. There's another reason and it's perhaps - may sound vague but it does seem to give the witness some comfort when they appear that there is this order and both these witnesses we've recently conferenced and they're ready, willing and able but they do express, which is commonplace, anxiety about the process and so forth and - - -

PN157

THE COMMISSIONER: But they are - - -

PN158

MR BULL: - - - it's our experience that - - -

PN159

THE COMMISSIONER: Sorry.

PN160

MR BULL: Sorry.

PN161

THE COMMISSIONER: Sorry, keep going. I cut you off.

PN162

MR BULL: It is helpful, we find, to have one of these orders. It gives them - frankly it also gives them greater motivation to turn up and it's also - it just clarifies beyond doubt with the employer that the reason they're not there working one day is because of an attendance at an august place like this and in relation - it's not about money, and we cover witness expenses in some situations and we're considering doing it with these two members, but there is a number of considerations where we've determined that it would be of assistance to have this order only in relation to these two witnesses.

PN163

THE COMMISSIONER: All right.

PN164

MR FERGUSON: There isn't any opposition from ourselves.

PN165

THE COMMISSIONER: To them attending?

PN166

MR FERGUSON: To the application for the order. I just ‑ seeing as I've made a comment before, I just didn't want that to be taken as saying that I was opposed to the order.

PN167

THE COMMISSIONER: You're not opposed?

PN168

MR FERGUSON: No, but as I said I don't act for the employer, just because I weighed in.

PN169

THE COMMISSIONER: Well look I'd rather deal with this way, Mr Ferguson, can you make a call to - the employer is a member of yours are they?

PN170

MR FERGUSON: No, we're engaging with them in relation to the proceedings. I can make a call this afternoon to them.

PN171

THE COMMISSIONER: All right. Can I ask you to call them and then advise them that well they're expected to attend these proceedings - - -

PN172

MR FERGUSON: Yes.

PN173

THE COMMISSIONER: - - - and just ascertain that if there's going to be any difficulties.

PN174

MR FERGUSON: Yes, yes.

PN175

THE COMMISSIONER: If you think that there will be, I'll issue the order but I think that's probably the better way to proceed.

PN176

MR FERGUSON: I'll do it as an urgency straight after.

PN177

THE COMMISSIONER: Okay, Mr Bull?

PN178

MR BULL: Thanks, Commissioner. Then one further matter, sorry.

PN179

THE COMMISSIONER: Yes.

PN180

MR BULL: I'm talking with Ms Doust, who is counsel for the HSU and also Mr Robson, in terms of trying to focus cross‑examination, one issue is objections to evidence. There is material which, in maybe all the statements, we say there's a balance of it in the employer evidence, which is objectionable. We were proposing to have a list of objections completed by Monday and it might be useful to deal with that. We can deal with it two ways, we can go through each statement and have arguments about paragraphs and so forth and that will be time consuming.

PN181

If it's done when the witness appears, it'll inevitably consume a lot of the cross-examination time. We can deal with it three ways but we can deal with that issue on Monday, and I suppose the third alternative is what occurred in the children services review where everything went in and there was then an opportunity to make statements about weight and so forth.

PN182

THE COMMISSIONER: Yes, well you can raise it on Monday but what you need to do, would have been better to have done it before now, but as soon as possible you need to put to the employers what it is that you're objecting to and it might be that they concede to remove it and if you want to press on with the objection well then we'll deal with it, the Bench will deal with it.

PN183

MR BULL: Okay.

PN184

THE COMMISSIONER: All right?

PN185

MR BULL: Well we'll endeavour to have a list by Monday which is available to everyone.

PN186

THE COMMISSIONER: Yes. Is there anything else? Anything else from anyone else?

PN187

MR SCOTT: Commissioner, Mr Scott here via telephone.

PN188

THE COMMISSIONER: Yes.

PN189

MR SCOTT: Can I just note under the directions, we had a ‑ our client had a requirement to file reply submissions by yesterday in relation to the claims that our clients are advancing, so they're in reply to the unions' response submissions to our claim. Just because of the amount of work that's gone into reviewing the court book and so forth over the last few days we haven't yet been in a position to file that. We intend to file that submission and seek the leave of the Commission to do so in the next kind of 24 hours so I just wanted to flag that, that we haven't yet filed those submissions. I don't anticipate that they will be in any way extensive but we seek leave of the Commission to be able to file those over the course of the weekend, if not by the end of today.

PN190

THE COMMISSIONER: All right. Anyone want to be heard on that?

PN191

MR BULL: No.

PN192

THE COMMISSIONER: No, well I will let that - - -

PN193

MR BULL: One final matter which I'll just put on record ‑ ‑ ‑

PN194

THE COMMISSIONER: Hang on. Is there anything you want to say about that? I'm just about to deal with it.

PN195

MR BULL: Sorry. No, sorry.

PN196

THE COMMISSIONER: No. That's fine, Mr Scott. You can file that in the next 24 hours period.

PN197

MR SCOTT: Thank you, Commissioner.

PN198

THE COMMISSIONER: Mr Bull.

PN199

MR BULL: Just I was going to note that we haven't actually sought any orders for production of documents but there has been an exchange where material's going to be provided to us voluntarily. I understand we're going to get that material sometime this afternoon and it's unlikely we're going to have to prevail upon the Commission to assist in the production of that material.

PN200

THE COMMISSIONER: All right, all right. Anything else? All right. Thanks for your efforts. See you next week.

ADJOURNED UNTIL MONDAY, 14 OCTOBER 2019 [3.09 PM]