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1 DAVID SKEEL

2 A The difference between what

3 National recovers under the plan as it's

4 currently written and what the

5 non-settling bondholders and monolines

6 recover is meaningful. Again, it would

7 depend on what the CVI possibility is.

8 Q In the 2019 RSA that we

9 looked at, the other monolines, besides

1 0 National and the ad hoc group, the

1 1 bondholders all got the same exchange

1 2 rate; right?

1 3 A I believe that is correct.

1 4 Q Is it your view as a board

1 5 member that National's different

1 6 treatment from other bondholders and

1 7 monolines is necessary to PREPA's

1 8 reorganization?

1 9 A I don't know whether -- I

2 0 would say necessary because that involves

2 1 speculation about different possibilities

2 2 for reorganization. What I will say is,

2 3 it is an important piece of what we think

2 4 is a confirmable plan of adjustment.

2 5 Q Why do you say that?

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1 DAVID SKEEL

2 A Why do I say it's an

3 important piece?

4 Q Yes.

5 A Because National is one of

6 the largest creditors. All told, they're

7 owed about a billion dollars when you

8 consider all of their claims. And as a

9 result of this settlement, they are

1 0 agreeing to give up their -- they've

1 1 agreed to give up their claims, that they

1 2 were fully secured, that they were

1 3 entitled to not just 100 cents on the

1 4 dollar, but 100 cents plus accrued

1 5 interest. They agreed to give all of

1 6 that up. And they agreed to take

1 7 significantly less. They agreed to

1 8 support the plan. They agreed to vote in

1 9 favor of the plan, all of which are very

2 0 attractive benefits to us.

2 1 Q Is the reorganization

2 2 contemplated by the plan unworkable in

2 3 the absence of the National settlement?

2 4 MR. FIRESTEIN: Objection,

2 5 vague.

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1 DAVID SKEEL

2 A That's very speculative.

3 There are lots of different possible

4 confirmable plans of adjustment.

5 Q Under the plan of

6 adjustment, the National settlement is

7 not offered to the other bondholders and

8 monolines; correct?

9 MR. FIRESTEIN: I'm sorry.

1 0 Let me just read the question. I had

1 1 asked for realtime. But I didn't get

1 2 one.

1 3 MR. ORSECK: I'll say it

1 4 again.

1 5 Q Under the plan of

1 6 adjustment, the term of the National

1 7 settlement is not provided to the other

1 8 bondholders or monolines; correct?

1 9 A That is correct. The plan

2 0 of adjustment -- the current plan of

2 1 adjustment does not provide the same

2 2 terms for other monolines or bondholders.

2 3 Q Was the same exchange rate

2 4 or the same deal reached with National

2 5 offered at some point to other

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1 DAVID SKEEL

2 bondholders; right?

3 MR. NATBONY: Yes.

4 A There is -- there are

5 reasons why the fuel line lender recovery

6 looks like what -- looks the way it

7 looks, is what it is.

8 Q What do you mean by that?

9 A There were negotiations that

1 0 led to the agreement with the fuel line

1 1 lenders. And the negotiations were very

1 2 much specific to the attributes of the

1 3 fuel line lenders' claim, which is quite

1 4 different from the bondholders' claim.

1 5 And the argument that the fuel line

1 6 lenders made was that they were entitled

1 7 to current expense treatment. And they

1 8 were entitled to 100 cents on the dollar.

1 9 And they had a number of reasons for that

2 0 argument.

2 1 And we settled it. And we

2 2 concluded that the settlement we reached

2 3 was appropriate, given the arguments that

2 4 they had, the benefits that we would get

2 5 from the settlement and the overall

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1 DAVID SKEEL

2 structure of the settlement.

3 Q What was the benefit -- what

4 were the benefits that you believe that

5 the board and PREPA would have gotten by

6 entering into that settlement?

7 A The benefits were that they

8 compromised their claim at less than 100

9 cents on the dollar. And we thought it

1 0 was a pretty strong claim. They are a

1 1 sizable claim that is now supportive of

1 2 the plan and will vote in favor of the

1 3 plan of adjustment and will not object to

1 4 the plan of adjustment. And all of those

1 5 were attractive benefits.

1 6 Q And can you identify what in

1 7 particular swayed the board to accept an

1 8 84 percent recovery rate?

1 9 MR. FIRESTEIN: I think the

2 0 form of your question seeks

2 1 deliberative process. I'll instruct

2 2 the witness not to answer. He's

2 3 already told you what his

2 4 understanding was of it. You can

2 5 reframe, if you wish.

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1 DAVID SKEEL

2 Q With respect to you as a

3 voter on the -- let's start with this.

4 The board did vote and

5 approve the PSA for the fuel line

6 lenders; correct?

7 A Yes. The board did.

8 Q And in your view, what

9 argument presented by the fuel line

1 0 lenders in particular swayed you to

1 1 approve the PSA?

1 2 A I don't know that there was

1 3 a single argument that swayed me to vote

1 4 yes. I will say that they had and have a

1 5 couple fairly strong arguments for

1 6 current expense treatment that other

1 7 creditors didn't have. One of those

1 8 arguments is that they are specifically

1 9 mentioned in the trust indenture.

2 0 Another is that they claimed

2 1 that there are more than one contract

2 2 with PREPA where PREPA said that they are

2 3 current expense claimants. And we oppose

2 4 those arguments. And we took litigation

2 5 positions against those arguments. But

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Exhibit B Page 7 of 29
1 DAVID SKEEL

2 Are you able to look at this

3 trust agreement and point to me where

4 there is a current expense definition

5 that includes the fuel line lender

6 claims?

7 MR. FIRESTEIN: It's 124

8 pages.

9 MR. NATBONY: The

1 0 interrogatories said that it's in

1 1 there. I'm asking him to point to

1 2 where it is.

1 3 MR. FIRESTEIN: The

1 4 interrogatory is a response made on

1 5 behalf of the entity. You know the

1 6 difference between what someone's

1 7 personal knowledge is and what an

1 8 interrogatory response is. And

1 9 putting a 124-page --

2 0 MR. KIRPALANI: You're

2 1 chewing up a lot of our time with

2 2 these speaking objections.

2 3 MR. FIRESTEIN: Can I tell

2 4 you, Susheel? What's chewing up a

2 5 lot of our time is asking about

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Exhibit B Page 8 of 29
1 DAVID SKEEL

2 questions pertaining to pleadings

3 that were filed four years ago.

4 We've gone through it over and over

5 again.

6 MR. NATBONY: I'll rephrase

7 the question.

8 Q Mr. Skeel, do you know where

9 in the trust agreement, there is a

1 0 definition showing that the fuel line

1 1 lender expenses are current expenses?

1 2 A I am not particularly

1 3 familiar with the terms of the trust

1 4 agreement. So I would have difficulty

1 5 finding particular provisions.

1 6 Q Are you aware whether in the

1 7 trust agreement, current expenses are

1 8 defined in a manner that makes

1 9 post-petition interest senior to

2 0 bondholder claims?

2 1 MR. FIRESTEIN: Calls for a

2 2 legal conclusion, lacks foundation.

2 3 A I don't know, one way or

2 4 another.

2 5 Q Are you familiar at all

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1 DAVID SKEEL

2 whether -- strike that.

3 MR. NATBONY: Let's put that

4 aside.

5 Q There's a current plan in

6 place for PREPA; correct?

7 A That is correct.

8 Q And under the plan, new

9 bonds are going to be issued by PREPA;

1 0 right?

1 1 A That is correct. New bonds

1 2 will be issued.

1 3 Q Do you know whether under

1 4 that plan, bondholders have any recourse

1 5 to compel PREPA to pay back principal and

1 6 interest?

1 7 MR. FIRESTEIN: Calls for a

1 8 legal conclusion.

1 9 A What do you mean by compel

2 0 creditors to pay back?

2 1 Q Well, for instance, are you

2 2 familiar with the concept of an interest

2 3 rate covenant?

2 4 A Yes, I am.

2 5 Q And that's different than a

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Exhibit B Page 10 of 29
1 DAVID SKEEL

2 that the fuel line lenders' argument,

3 that they are entitled to current expense

4 priority, would give them priority over

5 the claims only of the bondholders and

6 not other creditors?

7 MR. FIRESTEIN: I'm sorry.

8 Hold on one second. Lacks

9 foundation, calls for a legal

1 0 conclusion. You can answer if you

1 1 know.

1 2 A What I would say is I would

1 3 need more to the question. It would give

1 4 them priority over the bondholders. I

1 5 don't know that it would give them

1 6 priority over everybody. It would depend

1 7 on who those other creditors are.

1 8 Q Well, are you aware of any

1 9 basis on which the fuel line lenders

2 0 could claim priority over creditors,

2 1 other than the bondholders?

2 2 MR. FIRESTEIN: Hold on.

2 3 I'm going to object to the question

2 4 and direct you that if your source of

2 5 information is anything other than

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1 DAVID SKEEL

2 what you've communicated with your

3 lawyers, you could speak to that. If

4 it's based on communications with

5 your lawyers, I'll instruct you not

6 to answer. With that admonition, can

7 you answer the question?

8 THE WITNESS: I'm not sure.

9 A Can you ask the question

1 0 again?

1 1 Q The question was, I asked

1 2 you if you were aware of any basis on

1 3 which the fuel line lenders could claim

1 4 priority over creditors, other than the

1 5 bondholders.

1 6 A What I could say is their

1 7 principal argument for special treatment

1 8 is their current expenses argument. I

1 9 can't say more than that.

2 0 Q You don't know whether that

2 1 current expense argument would give them

2 2 priority over creditors, other than the

2 3 bondholders?

2 4 MR. FIRESTEIN: Same

2 5 objection.

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1 DAVID SKEEL

2 A I don't know the precise

3 parameters of how far that goes, no.

4 Q You believe, Mr. Skeel,

5 that -- Professor Skeel that it's

6 reasonable that the fuel line lenders

7 receive a better recovery under the plan

8 than general unsecured creditors?

9 A Well, I'm going to push back

1 0 a little bit on the terms of the question

1 1 because it is possible for the unsecured

1 2 creditors to be paid 100 cents on the

1 3 dollar, depending on happens in the

1 4 litigation.

1 5 Q Assuming that the scenario

1 6 that we talked about earlier?

1 7 A Full 8 and a half billion?

1 8 Q Full 8 and a half billion

1 9 and $800 million in claims, in that

2 0 situation, it's reasonable in your view

2 1 for the fuel line lenders to receive a

2 2 higher recovery than unsecured creditors?

2 3 A I do believe it's

2 4 reasonable, yes.

2 5 Q How can you say that's

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Exhibit B Page 13 of 29
1 DAVID SKEEL

2 reasonable without having an

3 understanding of whether the fuel line

4 lenders have any argument that they're

5 entitled to priority over general

6 unsecured creditors?

7 A I can say it relying on my

8 lawyers.

9 MR. FIRESTEIN: Don't tell

1 0 them what you said, what they said to

1 1 you. So if that's it, that's it.

1 2 A I've been given enough

1 3 information about the settlement and the

1 4 strengths of the arguments on both sides

1 5 to be able to determine its

1 6 reasonableness in my view.

1 7 Q But you're not able to tell

1 8 me without revealing communications with

1 9 counsel whether you're aware of any basis

2 0 for the fuel line lenders' position that

2 1 they have priority over general unsecured

2 2 creditors?

2 3 A I've already said I don't

2 4 know all of the parameters of the current

2 5 expense, seniority that they've argued

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Exhibit B Page 14 of 29
1 DAVID SKEEL

2 answered.

3 Q Has the board done any

4 analysis of -- has the board or PREPA

5 done any analysis of whether the fuel

6 line lender claims, in fact, qualify as

7 current expense claims?

8 MR. FIRESTEIN: So, A, it's

9 compound. B, to the extent it's

1 0 directed at the board, it's the

1 1 deliberative process piece which is

1 2 not proper. So start with the

1 3 compound piece. You said the board

1 4 or PREPA.

1 5 Q Has the board done any

1 6 analysis of whether the fuel line

1 7 lenders' claim qualify as current expense

1 8 claims?

1 9 MR. FIRESTEIN: You can

2 0 answer that question yes or no, if

2 1 you know.

2 2 A Yes. If the board is

2 3 defined as the board and its advisors,

2 4 yes.

2 5 Q And I assume you're not

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1 DAVID SKEEL

2 going to be able to tell me the

3 conclusion of that analysis?

4 A Correct.

5 Q Has PREPA, to your

6 understanding, done any analysis of

7 whether the fuel line lenders' claim

8 qualify as current expense claims?

9 A I don't know.

1 0 Q Has the board, to your

1 1 understanding, done an analysis of

1 2 whether any general unsecured claims,

1 3 other than the fuel line lender claims,

1 4 qualify as current expenses?

1 5 MR. FIRESTEIN: It's the

1 6 same yes-or-no question, if you know.

1 7 A I don't know.

1 8 Q Do you personally have any

1 9 understanding of whether claims within

2 0 the general unsecured claims pool also

2 1 qualify as current expenses?

2 2 MR. FIRESTEIN: If you know.

2 3 A I do not know of a

2 4 particular claim that qualifies. It is

2 5 possible that there is an unsecured claim

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1 DAVID SKEEL

2 that qualifies in my view.

3 Q If there was another

4 unsecured claim that qualifies as a

5 current expense claim, is there any

6 reason, to your knowledge, why a fuel

7 line lender's claim would be entitled to

8 better treatment than such other

9 unsecured claim that is also a current

1 0 expense claim?

1 1 MR. FIRESTEIN: Lacks

1 2 foundation, calls for a legal

1 3 conclusion. If your source of

1 4 information is anything other than

1 5 conversations you had with your

1 6 lawyers, you can speak to that if you

1 7 understand the question, otherwise I

1 8 would instruct you not to answer.

1 9 A I'll just say that there are

2 0 other considerations that go in.

2 1 Settling a big claim is more attractive

2 2 than settling a small claim. So I really

2 3 can't answer the question in the

2 4 abstract.

2 5 Q Setting aside those other

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1 DAVID SKEEL

2 considerations, are you aware of any

3 reason why a fuel line lender's claim

4 would have a greater legal entitlement to

5 payment from PREPA as compared to another

6 general unsecured claim that is also a

7 current expense claim?

8 MR. FIRESTEIN: I'm going to

9 instruct him not to answer that

1 0 question. You're expressly asking

1 1 for a legal conclusion. It's clearly

1 2 invading attorney-client privilege

1 3 because you excluded his answer that

1 4 he gave you before. So I don't know

1 5 how it could be anything but.

1 6 MR. BASSETT: I don't know

1 7 how he's able to sit here and testify

1 8 to the reasonableness of a settlement

1 9 if he's not able to explain the basis

2 0 for how he gets that.

2 1 MR. FIRESTEIN: You could

2 2 argue that sometime if you'd like.

2 3 But he's already articulated for you

2 4 what his reasonable basis is.

2 5 Q You're not going to answer

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1 DAVID SKEEL

2 completely secured. And they were

3 entitled to 100 cents on the dollar, plus

4 post-petition interest for the duration

5 of the case. And in return for the

6 settlement, they compromised that

7 argument and agreed to take the

8 71.65 percent.

9 And the other components of

1 0 the deal, they agreed to support the plan

1 1 to vote in favor of the plan. And by

1 2 reaching the deal with them, we took

1 3 roughly a billion dollars off the table.

1 4 So it was a very attractive settlement.

1 5 Q The settlement with National

1 6 was reached the end of January,

1 7 approximately, of this year; is that

1 8 right?

1 9 A I don't remember exactly

2 0 when it was. But it was sometime around

2 1 then.

2 2 Q And then sometime after

2 3 that, the court issued its summary

2 4 judgment decision in the lien challenge

2 5 litigation?

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1 DAVID SKEEL

2 A That is correct.

3 Q Have you -- strike that.

4 Do you believe that sitting

5 here today, in light of the decision

6 issued by the court, concerning the

7 narrow scope of National's lien that the

8 National settlement is still reasonable?

9 A I think it was a very

1 0 reasonable -- it is a reasonable

1 1 settlement. We settled it at a time when

1 2 we didn't know what the outcome of

1 3 that -- of that litigation is. And I

1 4 think it was a very sensible settlement.

1 5 Q And at the time you settled

1 6 it, that litigation was ongoing; right?

1 7 A It was ongoing, yes.

1 8 Q And when you entered into

1 9 the settlement, you knew that the

2 0 litigation would continue; right?

2 1 A We knew that -- we knew it

2 2 would continue. It had been argued. And

2 3 it would continue.

2 4 Q Does the National settlement

2 5 contain any kind of fiduciary out or

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1 DAVID SKEEL

2 other provision that would allow the

3 board to either get out of the deal or

4 restructure it in light of the court's

5 ruling?

6 A I don't remember whether

7 there were -- whether there were

8 provisions of that sort or not.

9 Q Also, do you have any

1 0 understanding of whether the board could

1 1 get out of the deal today, if it wanted

1 2 to based on the new facts before it,

1 3 including the decision the court has

1 4 issued?

1 5 A I would have to look at the

1 6 agreement to read through the various

1 7 provisions and conditions in the

1 8 agreement. So sitting here today, I

1 9 don't know what the precise details are.

2 0 Q Well, do you believe the

2 1 board has a duty to reevaluate the

2 2 reasonableness of this settlement in

2 3 light of the court's decision?

2 4 A I believe that the

2 5 settlement was reasonable when we made

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1 DAVID SKEEL

2 it. And I don't believe that the court's

3 decision has changed that fact. It still

4 was reasonable when we made it.

5 Q Well, the court's decision

6 drastically changes the scope of the

7 bondholders' security interest, including

8 National, as compared to what they were

9 arguing in the litigation; right?

1 0 A It does, although there are

1 1 still some open variables. There's still

1 2 the possibility that it will be appealed.

1 3 And the extent of the bondholders' claim

1 4 is -- is not yet clear. There still are

1 5 open issues in the litigation.

1 6 Q And because of the open

1 7 issues that remain in litigation today,

1 8 it's your view that the National

1 9 settlement, as it is set forth in the

2 0 National PSA and in the plan, remains

2 1 reasonable?

2 2 A I believe it is a reasonable

2 3 settlement, yes.

2 4 Q In addition to the

2 5 71.65 percent exchange rate of the Series

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1 DAVID SKEEL

2 Q What are those contributions

3 and benefits?

4 A So this is shifting fees to

5 the structuring fee. The kinds of

6 contributions that are included in that

7 include their involvement in structuring

8 the bond indenture, the new bonds that --

9 new bond indenture that will be put in

1 0 place, the new bonds that will be part of

1 1 that. It also includes them committing

1 2 to support the plan, to vote in favor of

1 3 the plan and in my view, the public good

1 4 that they provide as a result of all

1 5 that.

1 6 Q So you switched to the

1 7 structuring fee?

1 8 A Yeah.

1 9 Q What value or benefits did

2 0 National provide in order to justify the

2 1 3 percent consummation fee that we were

2 2 talking about before?

2 3 A I think part of that is some

2 4 of the same benefits. But the focus of

2 5 the fee is primarily on reimbursing

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1 DAVID SKEEL

2 attorneys' fees and professionals' fees.

3 Q National is also receiving

4 what's called an interim charge which is

5 I think a tenth of a cent per kilowatt

6 hour during the pendency of PREPA's case;

7 is that correct?

8 MR. FIRESTEIN: You could

9 restate your question.

1 0 Q Are you familiar with

1 1 something that has been referred to as an

1 2 interim charge that National is also

1 3 receiving out of the settlement?

1 4 A Yes. I'm familiar with the

1 5 interim charge.

1 6 Q And do you believe that's

1 7 reasonable?

1 8 A I believe that is

1 9 reasonable, yes.

2 0 Q What is the basis for that

2 1 interim charge?

2 2 A The interim charge, which I

2 3 believe is National's pro rata share of

2 4 1 percent, which would work out to I

2 5 believe roughly one-ninth of 1 percent,

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1 DAVID SKEEL

2 is kind of a carrying cost fee for the

3 fact that the plan will not be confirmed

4 and go effective immediately. And so

5 it's a payment to them for the delay, in

6 effect.

7 Q And National is not entitled

8 to post-petition interest; correct?

9 A National is -- as things

1 0 stand now, if the district court's lien

1 1 decision is upheld, if it's appealed,

1 2 National would not be entitled to

1 3 post-petition interest.

1 4 Q And you're saying if that

1 5 was appealed successfully, they could be

1 6 entitled to post-petition interest?

1 7 A Potentially, yes.

1 8 Q I want to talk about the

1 9 reimbursement claim which you provided

2 0 some testimony on earlier. I want to try

2 1 to find what I wrote down about your

2 2 testimony.

2 3 I believe you said you

2 4 characterized the National reimbursement

2 5 claim as a contractual obligation owed by

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Case:17-03283-LTS Doc#:24583-2 Filed:06/15/23 Entered:06/15/23 11:50:32 Desc:

Exhibit B Page 25 of 29
1 DAVID SKEEL

2 PREPA to pay National for moneys that it

3 paid to bondholders, post-petition, has

4 interest on the bonds; is that correct?

5 A I would just say the amounts

6 paid post-petition to bondholders that

7 National insured.

8 MR. FIRESTEIN: Before you

9 ask your next question, I have a

1 0 technical issue.

1 1 Q The amounts paid

1 2 post-petition, those are interest

1 3 payments; correct?

1 4 A It is primarily interest

1 5 payments. I don't know whether there are

1 6 other components of that or not.

1 7 Q And I think the way you

1 8 characterized this earlier, your words

1 9 that you think that National had a

2 0 plausible argument, that they were

2 1 entitled to payment on their

2 2 reimbursement claim, but not a strong

2 3 argument?

2 4 A In my view, they had a

2 5 plausible argument, but not -- it was

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Case:17-03283-LTS Doc#:24583-2 Filed:06/15/23 Entered:06/15/23 11:50:32 Desc:

Exhibit B Page 26 of 29
1 DAVID SKEEL

2 entitlement to recovery on account of its

3 claims, which are unsecured, other than

4 the approximately $17 million in the

5 sinking fund?

6 MR. FIRESTEIN: It's an

7 incomplete hypothetical.

8 MR. BASSETT: I'll strike

9 the question. I'll rephrase it.

1 0 Q So assuming that the

1 1 National -- assuming that the summary

1 2 judgment decision is not overturned on

1 3 appeal, then National only has a secured

1 4 claim to the extent of the moneys in the

1 5 sinking fund; correct?

1 6 A That is correct.

1 7 Q Aside from that secured

1 8 claim, on account of whatever unsecured

1 9 claim National ends up having against

2 0 PREPA, would National have any greater

2 1 legal entitlement to recovery than other

2 2 general unsecured creditors?

2 3 MR. FIRESTEIN: Calls for a

2 4 legal conclusion, lacks foundation.

2 5 You can answer if you understand.

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Case:17-03283-LTS Doc#:24583-2 Filed:06/15/23 Entered:06/15/23 11:50:32 Desc:

Exhibit B Page 27 of 29
1 DAVID SKEEL

2 A National's deficiency claim

3 would be an unsecured claim with the same

4 status as general unsecured claims.

5 Q So other than the likelihood

6 of that decision being overturned on

7 appeal, can you think of any reason why

8 National's claim is different than

9 general unsecured claims for purposes of

1 0 the 1129(b)1 analysis we talked about

1 1 earlier?

1 2 A Subject to the same

1 3 qualifications. If we're talking about

1 4 just not the secured portion, we're

1 5 talking about the deficiency claim, it

1 6 does seem to me that it has the same

1 7 stature as a general unsecured claim or

1 8 would.

1 9 Q And it's also possible that

2 0 an appeal or -- you understand that it's

2 1 possible that the district court will

2 2 decide that bondholders have an unsecured

2 3 deficiency claim much lower than

2 4 $8.5 billion?

2 5 A I understand that that is

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Case:17-03283-LTS Doc#:24583-2 Filed:06/15/23 Entered:06/15/23 11:50:32 Desc:

Exhibit B Page 28 of 29
1 DAVID SKEEL

2 possible, yes.

3 Q And you understand that it's

4 possible that following an appeal to the

5 1st Circuit, the 1st Circuit could

6 determine that National does not have and

7 the bondholders do not have any recourse;

8 correct?

9 A That is possible, yes.

1 0 Q In fact, depending upon the

1 1 outcome of the claim estimation process

1 2 pending before the district court, it's

1 3 possible that National's settlement could

1 4 generate a recovery for National that is

1 5 in excess of its allowed claim?

1 6 A You're going to have to say

1 7 that question again. I didn't follow it.

1 8 Q To the extent that the -- to

1 9 the extent the district court were to

2 0 determine that the bondholders'

2 1 deficiency claim is, let's say, only half

2 2 of the asserted amount, which is 8 and a

2 3 half billion, then National's claim would

2 4 only be half of its asserted amount as

2 5 well; correct?

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Case:17-03283-LTS Doc#:24583-2 Filed:06/15/23 Entered:06/15/23 11:50:32 Desc:

Exhibit B Page 29 of 29