a1572-25 | MIRANDA - State v GA

MERP (00:00)
Morning Meg, welcome back to the Mighty MERP Podcast and mornings with MERP and Meg. I hope do you have your

Meg McCormick Hoerner, Esquire (00:06)
Good morning, Melissa. Great to be back.

MERP (00:09)
do you have your coffee cup?

Meg McCormick Hoerner, Esquire (00:12)
I have my coffee cup, I'm on my second cup.

MERP (00:16)
I just I just brewed my second cup, so you're you might be a little ahead of me. How are you today on this happy Friday morning?

Meg McCormick Hoerner, Esquire (00:24)
I am very good, very good, other than uh the male issues we're all having.

MERP (00:32)
And male you mean the Microsoft male and not male as in the men issue, you know, because

Meg McCormick Hoerner, Esquire (00:35)
Correct. um Correct. Mail as in A I

L. The Microsoft issue. So other than that, I'm good. I'm glad it's Friday. Happy Friday. And uh

MERP (00:45)
I don't know if

people are that devastated that Microsoft Outlook is down. I think that

Meg McCormick Hoerner, Esquire (00:50)
no.

MERP (00:51)
uh people are enjoying uh maybe an extra hol day of a holiday, you know, uh making uh

Meg McCormick Hoerner, Esquire (00:56)
You never know. I mean w

MERP (00:58)
go ahead, you said you never know.

Meg McCormick Hoerner, Esquire (01:00)
One one

day might be okay. We'll see how long this goes on for.

MERP (01:05)
Um, it's sort of an interesting um turn of events from someone who's practiced law where email was not as um as prevalent, people demanding, you know, responses, courts re you know, relying solely on email. I mean, the fact that we're s we're so reliant reliant on it today, I've talked over and over again about how

since COVID, my emails have exploded daily. If I don't touch my

Meg McCormick Hoerner, Esquire (01:39)
I know.

MERP (01:39)
emails, you know, within an hour there's anywhere from fifty to a hundred emails, maybe even more. S

Meg McCormick Hoerner, Esquire (01:46)
I I understand. Same. And I was thinking

about that too this morning, how uh COVID changed so much for the practice of law in twenty twenty and you know, it it could be very you you could you could see how something like this could shift the pendulum back the other way very quickly.

MERP (02:06)
Yeah, so that's what I was thinking is my goodness, how is this gonna potentially change, especially if um everything is down the rest of the day today as well. I mean, even little things like court continuances, because even if you're able to file it on the court system, notice to all the parties goes through email. Um, I had a

Meg McCormick Hoerner, Esquire (02:31)
No one's gonna

get the link. No one's going to get the link to court.

MERP (02:35)
Well, that was the

issue I'm thinking too, because I had a forfeiture trial scheduled this afternoon, and I sent over a witness list yesterday morning that went through, which was I'm really happy about. And the prosecutor called me in the afternoon and said, I talked to our witness and um we're not proceeding on the forfeiture. And

Which is great for my client and it's great that I don't have to do a trial at two thirty in the afternoon in Cumberland. Um but

Meg McCormick Hoerner, Esquire (03:13)
Mm-hmm. Right.

MERP (03:16)
She said I called and left a message with the court. I don't know if they're gonna get it. I can't contact them. And and my response was we can do this virtually now because it's not a trial. We just have to put it on the record. And she said, Yes, but I don't know I don't know how the court's gonna move forward with sending out the links without proceeding all of that. Excuse me, I dropped something.

Meg McCormick Hoerner, Esquire (03:38)
Well, right. And it it's

a bigger issue than just today or just this incident, right? It it makes you think.

MERP (03:47)
I think that's like

uh, you know, uh just an e a very small microcosm of an example of how big it is. You know, multiply I'm one person, one practice, one case. Multiply it by the whole state of New Jersey legal practice. So, you know. But I I would be acceptable

Meg McCormick Hoerner, Esquire (04:06)
Right. Yeah. oh

MERP (04:08)
of Microsoft being down for just one more day.

Meg McCormick Hoerner, Esquire (04:12)
One more day. Right. I understand we can get caught up on other

MERP (04:14)
One day more,

you know? So um all right. Well there was a new uh we're gonna jump into some case law this morning. And I know we're gonna focus on a published decision that came out on November tenth, state of New Jersey uh verse GA. Um spoiler alert, it's a Miranda decision. Um before we jump into the case and and and really

nerd out as I like to call it. Um my my general thoughts, I'm gonna say two or three is it always amazes me that there's new Miranda decisions. There have been so many in the last few years. And yet one could say understanding Miranda or understanding the elements of Miranda and what needs to be honored is not complicated and yet it is

Potentially challenged or gotten wrong quite often. Um, so this is a published decision. I believe on the same day there was an unpublished decision that addressed the Miranda issue as well, um, and whether somebody was actually in custody. Um, the defendant was not victorious on that, and that was state versus webb. I sent you that one as well.

It was an overturned decision, but not on the Miranda decision. So one day two different Miranda decisions came out. And um I think we talked

Meg McCormick Hoerner, Esquire (05:46)
Right. And and it's interesting

to think about this one and why it was published. So let's let's talk about it because I think

This case is a very good review of some well settled principles that I think we ought to talk about first before we get into the facts. And and these well settled principles are really, you know, what do police have to do um if they want to take a statement from an individual for whom a criminal complaint or arrest warrant has been filed?

MERP (06:25)
And as you said it, it like the decision is clear and lays out what the police and law enforcement have to do. And um so we can start with that. My last insight is and I always start with this. Does this decision change the law of New Jersey?

Meg McCormick Hoerner, Esquire (06:48)
And I and we've talked about this, and I don't think that this does. I don't think this opinion changes anything. I think it provides clarification uh and reiterates some principles and responds to um uh a specific argument that the defense made, uh, which would have expanded the requirements.

MERP (07:09)
Okay, so let's talk basic requirements. I always like to start with um before we get to even the complaint warrant being issued, let's start with yeah.

Meg McCormick Hoerner, Esquire (07:17)
Can I just can I just interject

one thing I wanted to comment on? Um, this is state of New Jersey versus GA. And for those listeners who might be wondering why the defendant's full name was not provided in the opinion, there's a footnote at the very beginning which references court rule one colon 38 3 subsection C12. That court rule relates to

Certain court records being excluded from public access. And item number 12 refers to records of criminal proceedings, including names and addresses of victims or alleged victims of domestic violence or sexual offenses. You typically see a victim's name being referred to by their initials to protect their privacy. You don't always see it, or at least I haven't always seen it.

um that you are using or that the courts use the defendant's initials, I have to imagine that there is a concern that by knowing the defendant's name, you know, individuals out in the public could thereafter access the victim's name. Would you agree with that? Is that why they're using the defendant's initials?

MERP (08:33)
Absolutely. And and I think you're you're a hundred percent right, but I think that's also why even in the earlier Miranda decision that we're going to focus on as well, it's the it would be for the same reasoning, state versus AGD, which is a 2003

Meg McCormick Hoerner, Esquire (08:49)
Good point.

MERP (08:51)
decision. s so basic Miranda 101, before

Meg McCormick Hoerner, Esquire (08:52)
Good point. Okay. I just wanted to mention that. So let's talk basics. Right.

MERP (08:58)
you even get to is there

A criminal charge, is there a complaint or summons or a complaint warrant issued? Um um

What do you need in order to trigger Miranda? 'Cause I know as a criminal defense attorney, you do too. Every client says I was not read my Miranda warnings when I was taken into the police custody, which is what we see on TV. What's the reality?

Meg McCormick Hoerner, Esquire (09:24)
Right. Well,

yeah, and and what we're focusing on here is what the state has to do if they want to admit a statement by a defendant made post arrest, right? And it's it's a two-pronged step. The the state has to first demonstrate that the individual was advised of their Miranda rights, right? Miranda versus Arizona, night what is it, 1968 US Supreme Court decision. Anybody who's watched a criminal

Police show is heard the the rights being read, and they have to first prove that those rights have been read. But secondly, 66,

MERP (09:58)
Sixty six, Mag, I'm sorry.

Meg McCormick Hoerner, Esquire (10:01)
there we go. Um, but secondly, the state has to also show that a waiver of those rights was made knowing, intelligent, and voluntarily. Knowingly, intelligently, and voluntarily. And the state has the burden in New Jersey of proving both of those prongs beyond a reasonable doubt.

MERP (10:22)
Mm-hmm.

Meg McCormick Hoerner, Esquire (10:23)
Federal standard is proponents of an evidence of the evidence, but in New Jersey, um, as is often the case, our state courts have made the burden higher on the police, and it's a beyond the reasonable doubt burden. So the state has to file the motion to admit a postmiranda statement if they want to use it at trial, and that's what occurred here.

MERP (10:46)
Correct. And and I always tell people that Miranda's not even triggered until you're in custody. And we can debate custody, but that wasn't an issue in this case. And there has to be an interrogation. And um I don't think there's a dispute about that in this case either. not at

Meg McCormick Hoerner, Esquire (11:06)
Yeah, the facts are not in dispute in this case.

MERP (11:08)
all, not at all. The question is, um, you know, really.

Once they're once you're in custody and you're being questioned and it and specifically there was a complaint warrant filed against the defendant. There were actually several complaint warrants filed in three different jurisdictions. And when the defendant uh was in custody, um my understanding was he was read the complaint warrants, correct?

Meg McCormick Hoerner, Esquire (11:42)
He was advis I don't know that he was read them specifically, but he was read the information related to them. And and again, before we get into the facts of the of the case, I just wanted to touch upon and you started to say it already. Um the 2003 decision of AGD um requires police to advise if a criminal complaint or arrest warrant has been filed. And again.

That was done here, and there's no dispute about that from either the state or the defense or the court. Um, there was a a case in 2009, Nyhammer, N Y H A M E R, um, which uh did not extend that requirement to mere suspects. Um, and then there was a 2017 case, which the court cites here of Vincenti.

V-I-N-C-E-N-T-Y 2017 case, which adds to reiterated the the court's ruling in AGD, but also says that detectives have to give a a simple declaratory statement as to what the charges are. So I don't I don't believe that that necessarily means that they need to read the charges in their entirety, but a a simple statement as to the nature of the charges.

and that's where

MERP (13:06)
Sure.

Meg McCormick Hoerner, Esquire (13:07)
we get the issue here in this particular case. Um, and there were some other cases that came out um over the years, you know, discussing these governing principles. Um you know, here the issue was the motion court found that again, the state complied with AGD, but the motion court agreed with the defense argument.

that the defendant upon his request should have been advised of the names of the victims, uh, the and the dates of the offenses and some more specificity. And and and we

MERP (13:47)
Right.

Meg McCormick Hoerner, Esquire (13:47)
can now go back and and get into the facts of of what occurred in in this particular case. It sounds like the defendant was trying to

MERP (13:56)
expand just slightly. But

Meg McCormick Hoerner, Esquire (13:57)
Well, the defendant was trying

to expand. The defendant was trying to um take charge of the questioning and and get specifics.

MERP (14:03)
Right, right.

Well, as you being former law enforcement, you you're like, that's not gonna happen. But just to highlight state vs AG s AGD, um the issue there really goes to whether um it can be a knowing and intelligent waiver of your rights, which is required if there's already a criminal complaint or warrant out there and

The AGD court held that the government's failure to inform a suspect slash defendant that a criminal complaint or arrest warrant had been filed or issued deprives that person of information it says indispensable to a knowing and intelligent waiver of rights. It's that simple.

Meg McCormick Hoerner, Esquire (14:52)
Right, a person has to know their true status.

MERP (14:54)
Correct. So you so you know law enforcement can't lie.

in that instance. They can't say, no, no, no, you know, there there's no criminal charges or there's no, you know, there's no complaint yet. We're just still investigating, especially if there is a complaint issued. But then

Meg McCormick Hoerner, Esquire (15:16)
Right. Right. Because it

it would it would it would lead police to potentially um make a defendant believe that they're fine, they're not being charged, they're not arrested. Just tell us what you know, and then meanwhile there's been a complaint warrant filed. But you can't do that. You cannot do that under AGD. Police must tell a an individual if a complaint warrant has been filed. And again, Vincenti indicates that.

A simple declaratory statement of the charges must also be made.

MERP (15:50)
And so in this case, in state of New Jersey versus GA, state versus

Meg McCormick Hoerner, Esquire (15:56)
Okay. Yeah.

MERP (15:57)
GA, did the police do that?

Meg McCormick Hoerner, Esquire (16:00)
They did. They did. And

MERP (16:02)
Okay.

Meg McCormick Hoerner, Esquire (16:02)
the and the court and the the appellate court here rules that they that they did. Um and despite the police, there were three detectives interviewing GA. He wanted to know more specifics. He wanted to know who and when and where and all of that. And they

they didn't provide that information and this appellate court says that they did not have to.

MERP (16:36)
So and I think of it from both sides. Why just why is law enforcement not giving him the details? A witness defendant

Meg McCormick Hoerner, Esquire (16:44)
Right. I I don't know that it would

have made a difference. Um I I don't I thought about that this morning. Would it have made a difference to just read the read the complaint and give those details? The other thing I was thinking about was and we don't have his whole statement. Um the state obviously has taken this past year to to file this appeal and they want to admit the statement. Um there must be something in there that they want to use when the case goes to trial.

Um, but sometimes sometimes you're better off without a self serving statement. So it we don't know all the facts and all the reasons. but I think they yeah.

MERP (17:22)
Sometimes, sometimes,

Meg, sometimes this I feel like I'm gonna like pull out my pedestal now or my, you know, standing on my soapbox and shout. Don't ever give a statement. Don't ever give a statement. This is a perfect example. The complaint was already filed. There was nothing defendant was going to say that was gonna stop the criminal charges from proceeding. Nothing.

There was no side of his story that was going to be helpful in any way. And I don't because we don't have the statement. I don't know if he said things that were helpful. It looked like he was trying to make statements that it was consensual, correct? If you look at some of the footnotes.

Meg McCormick Hoerner, Esquire (18:05)
Correct.

MERP (18:07)
But but there was nothing he was going to say that was going to stop the criminal charges from moving forward. There was only, in my mind, two things that he should have done. Maybe three, in the way in the way you phrase it.

I think you know what I'm gonna say.

Meg McCormick Hoerner, Esquire (18:22)
Well,

I know I know exactly what you're gonna say. Spoken like a true defence attorney.

MERP (18:26)
He should have said, I want a lawyer. And then he should have shut up. And he shouldn't have said anything. Or when they said to him, You have a right to remain silent. Do you understand those rights? You have a right, you understand anything you say will be used against you. He could have said, I'm invoking my Fifth Amendment rights. And then what did he need to do? Shut up.

Meg McCormick Hoerner, Esquire (18:53)
Well,

r r I mean we've had yes, I mean the the you are correct. The the charges had been filed. It wasn't going to change that. Um but uh as you well know, uh most of the time when an individual is faced with this situation, they believe that they can explain it away.

MERP (19:19)
I know, but I'm gonna take it one step further. The problem is there's a statement now, and the statement was led by the detectives that had a very specific goal in mind, different than the defendants. And so if a defendant is going to testify in the future

They might be able to explain any discrepancies. I wasn't given a chance or opportunity to explain, it was misinterpreted. But any statement that they give next that isn't consistent with it is going to be used to impeach them. And so if you have a client with no prior record, you don't want a statement. You want them to be able to testify clean without any inconsistencies or contradictions. So um, you know, it just uh is problematic. But

As you said, the officers informed him of the charges, they read him the Miranda warnings.

Meg McCormick Hoerner, Esquire (20:17)
They read him their Miranda warnings. He waived his Miranda warnings. They they advised him that there was a complaint. Uh and um they gave that what what was what we've referred to as a declaratory simple declaratory statement as to the nature of the charges. The appellate division parted company with the motion court's uh expansion of governing law.

which would have required police to disclose the identities of the victims in the time periods of the assault, uh alleged assaults. Um the the appellate division found that the um police complied uh with the court's mandates by, you know, advising the defendant of his true status as an arrestee, charged with multiple sexual assault and related charges, which were which were the, you know, quote unquote essential facts.

um that are required to make an informed decision on his waiver of rights. And so the appellate division held the detectives were not required to disclose the underlying factual details of the charged conduct.

i.e. you

MERP (21:27)
Right. 'Cause

Meg McCormick Hoerner, Esquire (21:28)
know the names or initials of the alleged victims and the time periods related to the alleged assaults.

MERP (21:30)
Right. Cause that's what

the trial court decided, and they the trial court relying on Vicenti I mean so so I don't think the trial court I don't I think the trial court was following the intent of Vincent Vis Vincenti by saying the you know, in the decision, quoting the dis the Vincenti decision, they were persuaded with the facts that

uh were objectively verifiable as they constituted critical important information concerning the essence of the charges filed against defendant, the names of the alleged victims or the initials and the time period, ah in order for it to be completely a knowing, intelligent, and voluntary waiver. And the trial court said not only was it withheld information factually, readily confirmable and easy to convey,

It was critical to defendants' understanding of his true status. So I think the trial court was thoughtful and in its reliance of Vincent D. I think the defense attorney's arguments were obviously persuasive and interesting.

Meg McCormick Hoerner, Esquire (22:46)
Likely the

defense attorney's arguments were likely very aggressive.

MERP (22:50)
Yes, I would agree with that. And that's knowing some inside baseball.

Meg McCormick Hoerner, Esquire (22:53)
And the tr and the motion court was persuaded by that.

MERP (22:56)
Yes, yes. But um I think the appellate division firmly and clearly said no, not required by Vincenti. That's not the requirement. It is uh um taking it a step too far, requiring more than that's necessary by the case law.

Meg McCormick Hoerner, Esquire (23:20)
Now, I don't think

MERP (23:20)
Okay.

Meg McCormick Hoerner, Esquire (23:20)
police should and law enforcement should interpret this decision as somehow um allowing them to be purposefully vague. Um I I still uh I still would tend to think that it might the simplest thing is to just read the complaints, which would provide the details that the defendant here was arguing he he or she he should have had. but in

nevertheless.

MERP (23:41)
Why do you think in this

case law enforcement didn't do that? Because I think you said it. I don't think it would have changed anything in this case.

Meg McCormick Hoerner, Esquire (23:49)
Right, right. It wouldn't have changed anything. I mean, the

MERP (23:52)
Do you think

Meg McCormick Hoerner, Esquire (23:53)
you know, there is an there is a case, uh and I can't remember if it was Diaz or Sims that was uh referred to in in this opinion. Um d does a defendant are they entitled to enough specificity that they can thereafter craft their statement. And and they they they aren't. So

MERP (24:20)
Again, I don't think it would have mattered. It goes back to don't talk to the police. Don't give

Meg McCormick Hoerner, Esquire (24:24)
Right.

MERP (24:25)
a statement. It's not helpful. Do you think this case is gonna be appealed? Do you think the Supreme Court's gonna take it?

Meg McCormick Hoerner, Esquire (24:32)
I I don't y well, d do I think that the defendant will appeal? He may. Right. um

MERP (24:39)
No, I think that's gonna occur. I think they're gonna

seek cert at the Supreme Court. I could be wrong. Um, but but it's a published decision,

Meg McCormick Hoerner, Esquire (24:47)
I don't I don't know. I I don't

MERP (24:49)
so why wouldn't they seek cert to have clarification on it? I'm just curious

Meg McCormick Hoerner, Esquire (24:54)
Right. Right. It'll be interesting.

I I don't see that it's something that needs that this New Jersey Supreme Court needs to address, but unless of course they disagree.

MERP (25:07)
Right. I think it is Sims that you're relying on, which is a twenty twenty two decision, just so you know.

Meg McCormick Hoerner, Esquire (25:14)
Okay.

MERP (25:15)
Um and SIMS Court determined if the complaint warrant or arrest warrant has been issued. The rule of AGD mandates disclosure of the factual information about the pending charges that the offic officer can readily confirm and clearly convey. That's the extent of it.

Meg McCormick Hoerner, Esquire (25:33)
Yeah, and and I'll I'll just I guess the question I guess just to be very specific, what did the detectives in this case tell the defendant? Um and I'm just gonna quote from from the detective. It says a a criminal complaint and arrest warrant has been issued for you uh from the Mercer County Superior Court for the for the charges of the following two counts of sexual assault coming from the I don't know what TPD means.

One count of endangering the welfare of a child coming from the

MERP (26:05)
T P D

isn't the alleged victim?

Meg McCormick Hoerner, Esquire (26:09)
No. One count of endangering the welfare of a child coming from the TPD. One count of aggravated sexual assault coming from the TPD. Um Trenton Police Department. Okay. One count

MERP (26:19)
Triton Police Department. Sorry.

Meg McCormick Hoerner, Esquire (26:22)
of sexual assault coming from the Trenton Police Department. One count of kidnapping come out coming from the Trent from okay. I think it's Lawrence. Yes. So it's and so

MERP (26:30)
Lawrence Police, yeah.

Meg McCormick Hoerner, Esquire (26:32)
it's so the defendant was advised of the number and nature of the charges.

just not the alleged victims names or dates of the alleged offenses. So you know that would be the only, I think, reason that the Supreme Court would take this is if they felt that the full complaint should be read uh to it to a defendant.

MERP (26:58)
agree with you I think that if if they're reviewing it I don't think they're gonna I don't know would they take it just to

Meg McCormick Hoerner, Esquire (27:07)
Well say.

MERP (27:07)
clarify the appellate division is correct I don't know you know um but it is interesting it's interesting I I find when there's published appellate decisions that are just clearly saying

This is the law when they're not changing or interpreting it in any different way. So um the decision doesn't change what the law and requirements are. I do think that law enforcement providing the information secures a more guaranteed way of knowing that the statements are going to come in.

Meg McCormick Hoerner, Esquire (27:53)
Right, I agree. I agree. Well, well it remains to be seen. Um and I think it's a good one to file under Miranda. Uh and a good primer for anyone out there listening who needs a refresher.

MERP (28:11)
So and it's it's a great decision for those reasons and it it it it provides a lot of the case precedents and the cases that you should know if you have Miranda issues. Um

Meg McCormick Hoerner, Esquire (28:24)
I agree.

MERP (28:24)
as as I said, I think we I mean we've taught a lot of Miranda C L E courses and I I can't remember because years just blend together, but I think in twenty twenty five there might have been

between the Supreme Court and the Appellate Division about ten cases that came out within that year alone.

Meg McCormick Hoerner, Esquire (28:46)
Right,

and that's when we did our uh shut up, stop talking C L A.

I'll file this right on top in that binder. Um

MERP (28:54)
Uh yes,

yes. So um again,

Meg McCormick Hoerner, Esquire (28:59)
Right. Well I have

MERP (29:01)
interesting arguments. Um and I'm looking forward to see if the Supreme Court takes it. Um I will say that so many of the Supreme Court cases usually do benefit the defendant and ensuring that um their constitutional rights are protected. So I found it very interesting this one.

was clear to say, you know, you can't expand AGD, not AGD persp specifically, but Vincente, you know.

Meg McCormick Hoerner, Esquire (29:31)
Vincenti. Mm-hmm. Right.

MERP (29:34)
Um, and uh I'm gonna go back to stop talking. Nothing you're gonna say helps. So um

Meg McCormick Hoerner, Esquire (29:43)
Good good

point to end on and um I hope you have a good day and um

MERP (29:48)
I know.

Any announcements, any upcoming events, anything interesting?

Meg McCormick Hoerner, Esquire (29:51)
I

I uh I don't have any. I looked. Uh I did not make it w was there a professional day C L E yesterday. I didn't make it over to it. If there was.

MERP (30:01)
There was an Atlantic County Bar Association had their professionalism um event. That was yesterday afternoon. I wasn't able to make it as well. I was in family court handling numerous uh domestic violence complaints and receiving a decision that took over an hour to receive. Um, I know that's a long, long decision. And um, so I don't know how that went. Um, my few announcements, um

And a lot of times my information is from the Atlanta County Bar Association now has a new mentor mentee program, or I'll say uh new and improved mentor mentee program. So um if you're an attorney and have experience, I urge you to sign up to help mentor the young attorneys. Um we do a lot via Zoom and I think that for experienced attorneys it doesn't take away anything, but for the younger attorneys.

Um I I think that it's harder to learn and to experience trial work and to be able to ask attorneys questions because you're all in a Zoom room. Um so that's one thing that's coming up. Uh December 3rd, they just announces the holiday party. Um holiday party uh proceeds go to a fundraiser for a children's party that they do uh for local kids in our community.

So I highly recommend that. And on Saturday is the New Jersey State Bar Association criminal law update, which is a full day or I'll say half day of CLE credits. I saw the Attorney General Jennifer Davenport is now attending or going to speak at some point. Um so if you're available and you're either a criminal practitioner or um interested in criminal law,

That is the C L E with the state bar that I would highly recommend. They have an amazing panel of people. So those are my law updates of the week. Um I don't think

Meg McCormick Hoerner, Esquire (32:05)
Great.

MERP (32:05)
I have anything else.

Meg McCormick Hoerner, Esquire (32:07)
All right. Well, I hope you have a great day.

MERP (32:11)
Me too, happy Friday and

Meg McCormick Hoerner, Esquire (32:13)
Happy Friday.

MERP (32:13)
and I think I'm gonna be pouring myself now a third cup of cor coffee.