EFTA00610108.pdf

3 IX THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM REACH COUNTY, FLORIDA CASE NO. 502009CAOSOSOOXXXXXRAG JEFFREY EFSTEIN. Plaintiff, :077 ROTHSTEIN, INDIVIDUALLY. i.RADLEY J. EDWARDS, INDIVIDUALLY, AND L.N., INDIVIDUALLY, Defendants. HEARING BEFORE THE HONORABLE DAVID CROW Monday, March 11, 2013 9:05 a.m. - 9:17 a.n. PALM BEACH COUNTY COURTHOUSE, COURTROOM 9C 205 north Dixie Highway Wilt Palm Beach, Florida Stenographically Reported By: Paola McGuirk, RPR, FPR Registered Professional Reporter Florida Professional Reporter PROCEEDINGS 2 3 THE CLERK: Epstein vs. Rothstein. 4 MR. SCAROLA: Good morning. Jack Scarola on 5 behalf of Bradley Edwards. 6 THE COURT: Give me one second, please. 7 MR. SCAROLA: Absolutely. 8 THE COURT: Okay, what do we have? 9 MR. SCAROLA: Your Honor, this is the 10 Counter-Plaintiff, Bradley Edwards. motion to strike 11 untimely objections, and if I may approach the Court. 12 I have a time line that I hope will be of help to 13 Your Honor. 14 THE COURT: Okay. 15 MR. SCAROLA: Your Honor, this motion relates 16 to net worth interrogatories propounded after Your 17 Honor permitted the amendment of this complaint to 18 assert a claim for punitive damages. We served 19 discovery relating to Mr. Epstein's financial 20 circumstances on December 21, '12 following that 21 order, and pursuant to the provision of Rule 1.340 22 and the 1.350 responses to both of those, discovery 23 requests were due within 30 days. 24 Within 30 days rather than filing responses, 25 what we received was a motion for protective order. 2 APPEARANCES: On behalf of the Plaintiff: LAW OFFICES OF TONJA HADDAD COLEMAN. P.A. BY: TONJA HADDAD COLEMAN. ESQUIRE On behalf of the Defendants: SEARCY. DENNEY. SCAROLA. BARNHART & SHIPLEY. PA. 9 10 BY: JACK SCAROLA. ESQUIRE 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 The motion for protective order raised a variety of 2 objections to the discovery. Included among those 3 objections was that the discovery was propounded for 4 purposes of harassment, oppression and embarrassment. 5 Your Honor considered that motion and entered an 6 order on January 29th denying the motion for 7 protective order. That particular order included no 8 time for the provision of the discovery, and we 9 brought that matter -- that is I. on behalf of 1 0 Mr. Edwards. brought that matter to the Court's 11 attention, and Your Honor entered an order on 12 February 4th compelling responses to the discovery 13 within 20 days. 14 Within 20 days. mther than receiving discovery 15 responses. what we received front the opposing party 16 were more objections. In fact, there is nothing but 17 objections to the discovery. and there is not -- 8 apart from Mr. Epstein's name -- there is not a 19 single substantive response to any of the questions 0 that were asked with regard to his financial 1 circumstances. 2 2 It is our position that all of the objections 2 3 that were raised after the initial 30 days for filing 4 of objections or responses to the interrogatories are 2 5 untimely. and that those objections need not be 4 1 (Pages 1 to 4) EFTA00610108 5 7 1 addressed substantively. 1 is raising a motion for protective order because, and 2 We are not before Your Honor this morning to 2 I quote. This follows from the fact that 3 ask the Court to consider the substance of the 3 Rule 1.280(c) refers to issuance of protective order 4 objections. but to strike all objections, except for 4 only to protect a party or person from annoyance. 5 the Fifth Amendment privilege assertion, on the basis 5 embarrassment, oppression or undue burden or 6 that those objections are untimely. The significance 6 expense." It does not refer to privilege. 7 of striking all of the objections. other than the 7 We think the omission was intentional and. 8 Fifth Amendment privilege objection, is that other 8 therefore, the word objectionable in Rule 1.380(d), 9 objections cannot be commented upon in the presence 9 therefore, should be construed as referring only to 10 of the jury. If there are valid legal objections to 10 items which are within the scope of discovery; that 11 not providing the information. obviously we cannot 11 is. not privileged. 12 draw adverse inferences from those other objections, 12 As such, Judge. once you denied our motion for 13 nor can we comment upon those other objections. 13 protective order, we were still well within ow legal 14 However, the Defendant's failure to respond to 14 rights -- our client's legal rights -- to raise any 15 this financial discovery on the basis of the Fifth 15 objections that were not raised in the motion for 16 Amendment privilege assertion is obviously something 16 protective order. This case supports that position. 17 that can be raised in the presence of the jury. and 17 We timely filed our objection. 18 we can draw adverse inferences from his refusal to 18 THE COURT: As I understand it. he is not 19 provide any financial information whatsoever. That's 19 asking me to rule on privilege objections. 20 the purpose of this motion. 20 MS. COLEMAN: Those are all the objections. 21 THE COURT: Yes. 21 There are various -- 22 MS. COLEMAN: Good morning, Judge. Tonja 22 THE COURT: You got overbroad. burdensome, not 23 Haddad Coleman on behalf of Mr. Epstein. First, I'm 23 calculated to lead to admissible evidence. 24 really not quite sure how to respond to this since 24 MS. COLEMAN: Judge. I don't know because he 25 Mr. Scarola has yet, again, filed a motion that 25 didn't provide, as one does, the copies of the 6 8 1 contains not one rule or case on which he's relying. 1 answers to which he is objecting. He's asking you to 2 So. I'll address each allegation in turn. 2 strike all of them. I don't know which ones he wants 3 First, all he states is that our objections are 3 stricken. We raised the privileges. 4 untimely. This Court ordered that we respond. Not 4 THE COURT: Okay. I'm just listening to what 5 answer, but respond to the discovery requests within 5 he said. He said he wants me to strike everything 6 20 days of the order. The order was entered 6 except the privilege objections. 7 February 4th. As such, our response was due on or 7 MS. COLEMAN: Well, they're not here. The 8 before Monday. February 25th. since February 24th was 8 rules -- my understanding of the rules -- 9 a Sunday. We timely responded to all discovery 9 THE COURT: Excuse me. What's not here? I'm 10 requests on Friday. February 22nd. actually. making 10 sorry. 11 them early. 11 MS. COLEMAN: The discovery. There's no copy 12 Furthermore. with respect to the motion for 12 of the request in the objections. He wants you to 13 protective order. the law is very clear that the 13 strike everything. What is everything? 14 issues that you must raise in a protective order, and 14 THE COURT: He just gave me a copy of it here. 15 the only issues we raised in our motion for 15 MS. COLEMAN: Well, he didn't give me a copy. 16 protective order were on the grounds of annoyance. 16 THE COURT: Well. it's your responses. 17 embarrassment. oppression. undue burden. We've only 17 MS. COLEMAN: I know it's my responses. Judge. 18 raised issues as delineated in Rule 1.380. 18 It wasn't attached to his motion, and it wasn't 19 However, within our responses to the discovery 19 provided to us. 20 we did raise many objections. including privilege. 20 THE COURT: Okay. 21 and I have a case right on point for the Court, and 21 MS. COLEMAN: His motion doesn't say anything. 22 which I've taken the time to actually highlight the 22 THE COURT: For example. the first one says 23 relevant portions, if I may approach. I have a 23 please produce financial statements to any lender 24 Fourth DCA case in which it says. "A timely objection 24 within the past five years. You have your privilege 25 is not required to claims to be privileged when one 25 objection. and then you say vague. unartfully 2 (Pages 5 to 8) EFTA00610109 9 11 1 drafted, unable to file a response. I don't know how 1 will have to look at it today. By the way. is your 2 it would be work product. The accountant privilege 2 father an attorney, or is that your brother that's an 3 would not be applicable. So your position is that 3 attorney? 4 you have not waived any -- certainly not waived any 4 MS. COLEMAN: Me? 5 privilege objections. I understand that. Your claim 5 THE COURT: Yeah. Haddad. 6 is that you have not waived any objections? 6 MS. COLEMAN: Yes. 7 MS. COLEMAN: Yes. Your Honor. we never raised 7 THE COURT: Are you related? 8 any issue of overly burdensome. We raised the three 8 MS. COLEMAN: I'm related to a lot of 9 grounds one can raise in a protective order. We did 9 attorneys. I don't know which Haddad you're 10 not raise, in our objection to his discovery 10 referring. 11 requests. any grounds that you had already ruled upon 11 THE COURT: No, I'm sorry. I -- 12 in your motion for protective order. As such. 12 MR. SCAROLA: Mr. Haddad has actually entered 13 they're timely objections. 13 an appearance in this case, Your Honor. 14 THE COURT: I honestly don't remember what I 14 THE COURT: Is he related to you? 15 ruled or didn't role. 15 MS. COLEMAN: Yes, he is. 16 MS. COLEMAN: I have a copy of your order right 16 THE COURT: Oh. okay. I just wondered. It's 17 here. It's attached to our response to his motion. 17 interesting. Do you have a relative that works in 18 THE COURT: It says -- you've got here 18 the Court? We have a clerk an attorney. 19 overbroad. 19 THE CLERK: Monica. 20 MR. SCAROLA: Would Your Honor like a copy of 20 THE COURT: Monica Haddad. Is she related? 21 the order? 21 MS. COLEMAN: No. 22 THE COURT: Yes. I don't have the motions. so 22 THE COURT: Because that's not unusual. I 23 I don't know what you raised in the motions, but. 23 mean, it's kind of like a Smith. Jones kind of -- 24 okay. yes. sir, you want to respond? 24 MS. COLEMAN: Which is why for the last decade 25 MR. SCAROLA: I would like to respond. Your 25 I've tried using my married name, but it doesn't seem 10 12 1 Honor. The Fourth DCA case, which opposing counsel 1 to take. 2 handed me when she handed it to the Court. 2 THE COURT: Okay. I don't mean to — you know. 3 specifically addresses attorney/client privilege, and 3 I was just interested because it's a -- 4 says that attorney/client privilege objections are 4 MS. COLEMAN: Yes. 5 not waived as a consequence of having raised a motion 5 THE COURT: Okay. thank you. 6 for protective order. The motion expressly states 6 MR. SCAROLA: Thank you very much. Your Honor. 7 that we are not seeking this Court's ruling on the 7 THE COURT: And did I see something come back 8 assertion of Fifth Amendment privilege. We are 8 from the Fourth? Y'all filed something against me. 9 seeking to strike all other objections as untimely. 9 right? 10 and it seems strange that the law would develop m a 10 MR. SCAROLA: Yes. they filed a petition for 11 point where no objection is raised substantively. 11 writ of certiorari challenging Your Honor's granting 12 With regard to these requests for financial 12 of leave to amend to assert a claim for punitive 13 information, a motion for protective order is filed. 13 damages. 14 It raises substantial grounds. including harassing. 14 THE COURT: Well. I thought there was something 15 oppressive. embarrassing. and, as counsel has said in 15 like somebody tried to recuse -- not recuse — in 16 her argument. overbroad. and then serially permit 16 fact, the reason I thought it was because I saw it 17 other objections to be raised far after the 30-day 17 come through. Mr. Haddad. somebody tried to get hint 18 deadline for response has passed. 18 kicked off the case. Didn't the Appellate Court say 19 We would ask the Court to grant this motion. 19 I actually did it right? Ant I wrong? 20 strike all objections. except those as to privilege. 20 MS. COLEMAN: Yes, we didn't appeal that. 21 and with regard to any privilege objection. other 21 Judge. because — 22 than attorney/client privilege, we will raise that by 22 MR. SCAROLA: That was not appealed. 23 separate motion. 23 THE COURT: Oh, okay. 24 THE COURT: Okay. I'm going to have to take a 24 MR. SCAROLA: No. the issue that was appealed 25 look at this. The responses are 17 pages long, and I 2 5 was the propriety of Your Honor's order granting 3 (Pages 9 to 12) EFTA00610110 13 1 leave to assert a claim for punitive damages. The 2 petition for writ of coition was denied as to that 3 matter. 4 THE COURT: Okay. 5 MR. SCAROLA: There was a recent opinion that 6 related to an effort to recuse Attorney Keitel that 7 was just addressed by the Fourth DCA in another 8 matter, so that may have been what Your Honor was 9 seeing. 10 THE COURT: Okay. thank you. guys. 11 MR. SCAROLA: Thank you. Your Honor. 12 MS. COLEMAN: Thank you. Judge. 13 (The hearing concluded at 9:16 a.m.) 14 15 16 17 18 19 20 21 22 23 24 25 14 1 CERTIFICATE OF REPORTER 2 . . . 3 I, Paula McGuirk, Registered Professional 4 Reporter. Florida Professional Reporter, certify that I 5 was authorized to and did stenographically report the 6 foregoing proceedings and that the transcript, pages 1 7 through 13. is a true and complete record of my 8 stenographic notes. 9 10 Dated this 13th day of March. 2013. 11 12 13 14 15 16 Paula M 17 Registered Professional Reporter Florida Professional Reporter 18 19 20 21 22 23 24 25 4 (Pages 13 to 14) EFTA00610111 Page 1 A Absolutely 3:7 accountant 9:2 address 6:2 addressed 5:1 13:7 addresses 10:3 admissible 7:23 adverse 5:12,18 allegation 6:2 amend 12:12 amendment 3:17 5:5,8 5:16 10:8 annoyance 6:16 7:4 answer 6:5 answers 8:1 apart 4:18 appeal 12:20 appealed 12:22,24 appearance 11:13 APPEARANCES 2:1 Appellate 12:18 applicable 9:3 approach 3: I I 6:23 argument 10:16 asked 4:20 asking 7:19 8:1 assert 3:18 12:12 13:1 assertion 5:5,16 10:8 attached 8:18 9:17 attention 4:11 attorney 11:2,3,18 13:6 attorneys 11:9 attorney/client 10:3,4 10:22 authorized 14:5 a.m 1:16,16 13:13 B back 12:7 BARNHART 2:8 basis 5:5,15 Beach 1:1,17,18 2:8,9 behalf 2:2,7 3:5 4:9 5:23 Boulevard 2:8 Bradley 1:8 3:5,10 brother 11:2 brought 4:9,10 burden 6:17 7:5 burdensome 7:22 9:8 C calculated 7:23 case 1:2 6:1,21,24 7:16 10:1 11:13 12:18 certainly 9:4 CERTIFICATE 14:1 certify 14:4 certiorari 12:11 certiori 13:2 challenging 12:11 CIRCUIT 1:1,1 circumstances 3:20 4:21 claim 3:18 9:5 12:12 13:1 claims 6:25 clear 6:13 clerk 3:3 11:18,19 client's 7:14 Coleman 2:3,6 5:22,23 7:20,24 8:7,11,15,17 8:21 9:7,16 11:4,6,8 11:15,21,24 12:4,20 13:12 come 12:7,17 comment 5:13 commented 5:9 compelling 4:12 complaint 3:17 complete 14:7 concluded 13:13 consequence 10:5 consider 5:3 considered 4:5 construed 7:9 contains 6:1 copies 7:25 copy 8:11,14,15 9:16,20 counsel 10:1,15 Counter-Plaintiff 3:10 COUNTY 1.1,17 Court 1:1 3:6,8,11,14 5:3,21 6:4,21 7:18,22 8:4,9,14,16,20,22 9:14 9:18,22 10:2,19,24 11:5,7,11,14,16,18,20 11:22 12:2,5,7,14,18 12:23 13:4,10 COURTHOUSE 1:17 COURTROOM 1:17 Court's 4:10 10:7 CROW 1:13 D damages 3:18 12:13 13:1 Dated 14:10 DAVID 1:13 day 14:10 days 3:23,24 4:13,14,23 6:6 DCA 6:24 10:1 13:7 deadline 10:18 decade 11:24 December 3:20 Defendants 1:9 2:7 Defendant's 5:14 delineated 6:18 denied 7:12 13:2 DENNEY 2:8 denying 4:6 develop 10:10 discovery 3:19,22 4:2,3 4:8,12,14,17 5:15 6:5 6:9,19 7:10 8:11 9:10 Dixie 1:17 drafted 9:1 draw 5:12,18 due 3:23 6:7 E early 6:11 Edwards 1:8 3:5,10 4:10 effort 13:6 embarrassing 10:15 embarrassment 4:4 6:17 7:5 entered 4:5,11 6:6 11.12 Epstein 1:4 3:3 5:23 Epstein's 3:19 4:18 ESQUIRE 2:6,10 evidence 7:23 example 8:22 Excuse 8:9 expense 7:6 expressly 10:6 F fact 4:16 7:2 12:16 failure 5:14 far 10:17 father 11:2 February 4:12 6:7,8,8 6:10 FIFTEENTH 1:1 Fifth 5:5,8,15 10:8 file 9:1 filed 5:25 7:17 10:13 12:8,10 filing 3:24 4:23 financial 3:19 4:20 5:15 5:19 8:23 10:12 first 5:23 6:3 8:22 five 8:24 Florida 1:1,18,25 2:4,9 14:4,17 following 3:20 follows 7:2 foregoing 14:6 Fort 2:4 Fourth 6:24 10:1 12:8 13:7 FPR 1:23 Friday 6:10 Furthermore 6:12 G give 3:6 8:15 going 10:24 Good 3:4 5:22 grant 10:19 granting 12:11,25 grounds 6:16 9:9,11 10:14 guys 13:10 H Haddad 2:3,6 5:23 11:5 11:9,12,20 12:17 handed 10:2,2 harassing 10:14 harassment 4:4 hearing 1:13 13:13 help 3:12 highlight 6:22 Highway 1:17 honestly 9:14 EFTA00610112 Page 2 Honor 3:9,13,15,17 4:5 4:11 5:2 9:7,20 10:1 11:13 12:6 13:8,11 HONORABLE 1:13 Honor's 12:11,25 hope 3:12 I included 4:2,7 including 6:20 10:14 INDIVIDUALLY 1:7,8 1:8 inferences 5:12,18 information 5:11,19 10:13 initial 4:23 intentional 7:7 interested 12:3 interesting 11:17 interrogatories 3:16 4:24 issuance 7:3 issue 9:8 12:24 issues 6:14,15,18 items 7:10 J J 1:8 Jack 2:10 3:4 January 4:6 JEFFREY 1:4 Jones 11:23 2:10 Judge 5:22 7:12,24 8:17 12:21 13:12 JUDICIAL 1:1 jury 5:10,17 K Keitel 13:6 kicked 12:18 kind 11:23,23 know 7:24 8:2,17 9:1 9:23 11:9 12:2 L Lakes 2:8 Lauderdale 2:4 law 2:3 6:13 10:10 lead 7:23 leave 12:12 13:1 legal 5:10 7:13,14 lender 8:23 line 3:12 listening 8:4 long 10:25 look 10:25 11:1 lot 11:8 L.M 1:8 making 6:10 March 1:15 14:10 married 11:25 matter 4:9,10 13:3,8 McGuirk 1:23 14:3,16 mean 11:23 12:2 Monday 1:15 6:8 Monica 11:19,20 morning 3:4 5:2,22 motion 3:10,15,25 4:1,5 4:6 5:20,25 6:12,15 7:1,12,15 8:18,21 9:12,17 10:5,6,13,19 10:23 motions 9:22,23 N name 4:18 11:25 need 4:25 net 3:16 never 9:7 North 1:17 notes 14:8 0 objecting 8:1 objection 5:8 6:24 7:17 8:25 9:10 10:11,21 objectionable 7:8 objections 3:11 4:2,3 4:16,17,22,24,25 5:4,4 5:6,7,9,10,12,13 6:3 6:20 7:15,19,20 8:6 8:12 9:5,6,13 10:4,9 10:17,20 obviously 5:11,16 OFFICES 2:3 Oh 11:16 12:23 okay 3:8,14 8:4,20 9:24 10:24 11:16 12:2,5,23 13:4,10 omission 7:7 once 7:12 ones 8:2 opinion 13:5 opposing 4:15 10:1 oppression 4:4 6:17 7:5 oppressive 10:15 order 3:21,25 4:1,6,7,7 4:11 6:6,6,13,14,16 7:1,3,13,16 9:9,12,16 9:21 10:6,13 12:25 ordered 6:4 overbroad 7:22 9:19 10:16 overly 9:8 P pages 10:25 14:6 Palm 1:1,17,18 2:8,9 particular 4:7 party 4:15 7:4 passed 10:18 Paula 1:23 14:3,16 permit 10:16 permitted 3:17 person 7:4 petition 12:10 13:2 Plaintiff 1:5 2:2 please 3:6 8:23 point 6:21 10:11 portions 6:23 position 4:22 7:16 9:3 presence 5:9,17 privilege 5:5,8,16 6:20 7:6,19 8:6,24 9:2,5 10:3,4,8,20,21,22 privileged 6:25 7:11 privileges 8:3 proceedings 3:1 14:6 produce 8:23 product 9:2 Professional 1:24,25 14:3,4,17,17 propounded 3:16 4:3 propriety 12:25 protect 7:4 protective 3:25 4:1,7 6:13,14,16 7:1,3,13,16 9:9,12 10:6,13 provide 5:19 7:25 provided 8:19 providing 5:11 provision 3:21 4:8 punitive 3:18 12:12 13:1 purpose 5:20 purposes 4:4 pursuant 3:21 P.A 2:3,8 questions 4:19 quite 5:24 quote 7:2 R raise 6:14,20 7:14 9:9 9:10 10:22 raised 4:1,23 5:17 6:15 6:18 7:15 8:3 9:7,8,23 10:5,11,17 raises 10:14 raising 7:1 really 5:24 reason 12:16 received 3:25 4:15 receiving 4:14 record 14:7 recuse 12:15,15 13:6 refer 7:6 referring 7:9 11:10 refers 7:3 refusal 5:18 regard 4:20 10:12,21 Registered 1:24 14:3,17 related 11:7,8,14,20 13:6 relates 3:15 relating 3:19 relative 11:17 relevant 6:23 relying 6:1 remember 9:14 report 14:5 Reported 1:22 Reporter 1:24,25 14:1 14:4,4,17,17 EFTA00610113 Page 3 request 8:12 requests 3:23 6:5,10 9:11 10:12 required 6:25 respect 6:12 respond 5:14,24 6:4,5 9:24,25 responded 6:9 response 4:19 6:7 9:1 9:17 10:18 responses 3:22,24 4:12 4:15,24 6:19 8:16,17 10:25 right 6:21 9:16 12:9,19 rights 7:14,14 Rothstein 1:7 3:3 RPR 1:23 rule 3:21 6:1,18 7:3,8 7:19 9:15 ruled 9:11,15 rules 8:8,8 ruling 10:7 S saw 12:16 says 6:24 8:22 9:18 10:4 Scarola 2:8,10 3:4,4,7,9 3:15 5:25 9:20,25 11:12 12:6,10,22,24 13:5,11 scope 7:10 SCOTT 1:7 SEARCY 2:8 second 3:6 see 12:7 seeing 13:9 seeking 10:7,9 separate 10:23 serially 10:16 served 3:18 Seventh 2:3 SHIPLEY 2:8 significance 5:6 single 4:19 sir 9:24 Smith 11:23 somebody 12:15,17 sorry 8:10 11:11 Southeast 2:3 specifically 10:3 statements 8:23 states 6:3 10:6 stenographic 14:8 stenographically 1:22 14:5 strange 10:10 Street 2:3 stricken 8:3 strike 3:10 5:4 8:2,5,13 10:9.20 striking 5:7 substance 5:3 substantial 10:14 substantive 4:19 substantively 5:1 10:11 Suites 2:4 Sunday 6:9 supports 7:16 sure 5:24 T take 10:24 12:1 taken 6:22 thank 12:5,6 13:10,11 13:12 think 7:7 thought 12:14,16 three 9:8 time 3:12 4:8 6:22 timely 6:9,24 7:17 9:13 today 11:1 Tonja 2:3,6 5:22 tonja@tonjahaddad.... 2:5 transcript 14:6 tried 11:25 12:15,17 true 14:7 turn 6:2 U unable 9:1 unartfully 8:25 understand 7:18 9:5 understanding 8:8 undue 6:17 7:5 untimely 3:11 4:25 5:6 6:4 10:9 unusual 11:22 V vague 8:25 valid 5:10 variety 4:1 various 7:21 vs 1:6 3:3 W waived 9:4,4,6 10:5 want 9:24 wants 8:2,5,12 wasn't 8:18,18 way 11:1 West 1:18 2:9 We've 6:17 whatsoever 5:19 wondered 11:16 word 7:8 work 9:2 works 11:17 worth 3:16 writ 12:11 13:2 wrong 12:19 Yeah 11:5 years 8:24 Y'all 12:8 1 1 14:6 1.280(c) 7:3 1.340 3:21 1.350 3:22 1.380 6:18 1.380(d) 7:8 11 1:15 12 3:20 13 14:7 13th 14:10 17 10:25 2 20 4:13,14 6:6 2013 1:15 14:10 205 1:17 213:20 2139 2:8 22nd 6:10 24th 6:8 25th 6:8 29th 4:6 3 30 3:23,24 4:23 30-day 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