Case 2:08-cv-00437-LRH-RJJ Document 173 Filed 01/27/11 Page 1 of 13

1 JOHN M. McCOY III, Cal. Bar No. 166244

E-mail: mccoyj@sec.gov
2 KAREN MATTESON, Cal. Bar No. 102103
E-mail: mattesonk@sec.gov
3 MOLLY M. WHITE, Cal. Bar No. 171448
E-mail: whitem@sec.gov
4
Attorneys for Plaintiff
5 Securities and Exchange Commission
Rosalind R. Tyson, Regional Director
6 5670 Wilshire Boulevard, 11th Floor
Los Angeles, California 90036-3648
7 Telephone: (323) 965-3998
Facsimile: (323) 965-3908
8
9 UNITED STATES DISTRICT COURT
10 DISTRICT OF NEVADA
11
12 SECURITIES AND EXCHANGE Case No. 2:08-cv-00437-LRH-RJJ
COMMISSION,
13 Plaintiff,
14 vs.
15 CMKM DIAMONDS, INC., URBAN
CASAVANT, JOHN EDWARDS,
16 GINGER GUTIERREZ, JAMES
KINNEY, ANTHONY TOMASSO,
17 KATHLEEN TOMASSO, 1ST
GLOBAL STOCK TRANSFER LLC,
18 HELEN BAGLEY, NEVWEST
SECURITIES CORPORATION,
19 DARYL ANDERSON, SERGEY
RUMYANTSEV, ANTHONY
20 SANTOS, and BRIAN DVORAK,
21 Defendants.
22
23
OPPOSITION BY PLAINTIFF SECURITIES AND EXCHANGE
24 COMMISSION TO MOTION BY DEFENDANT BRIAN DVORAK TO
STAY ACTION; REPLY IN FURTHER SUPPORT OF PLAINTIFF’S
25 MOTION FOR SUMMARY JUDGMENT
26
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1 I. INTRODUCTION
2 Rather than file the required opposition to the motion by Plaintiff Securities
3 and Exchange Commission (“Commission”) for summary judgment, on the final
4 day on which Defendant Brian Dvorak (“Dvorak”) was permitted to file an
5 opposition to the Commission’s motion, he instead moved for a stay of this action
6 pending resolution of a related criminal case against him. Dvorak’s stated grounds
7 for his stay motion are vague, but purport to relate to his exercise of his Fifth
8 Amendment privilege against self-incrimination. In fact, however, Dvorak can
9 show no prejudice to this right because he previously testified in the Commission’s
10 deposition of him, and the Commission’s motion as to his liability for violating the
11 securities registration requirements of Section 5 of the Securities Act of 1933
12 (“Securities Act”), 15 U.S.C. § 77e, is based entirely on his own admissions and,
13 with regard to its claim for disgorgement, also on bank records. Moreover, to the
14 extent that Dvorak is asserting, pursuant to Fed. R. Civ. P. 56(d), that he cannot
15 present facts essential to justify his opposition to summary judgment, he has failed
16 to meet his burden.
17 II. ARGUMENT
18 A. The Defendant’s Motion For A Stay Should Be Denied
19 The Constitution does not ordinarily require a stay of civil proceedings
20 pending the outcome of criminal proceedings. Keating v. Office of Thrift
21 Supervision, 45 F.3d 322, 324 (9th Cir. 1995), citing FSLIC v. Molinaro, 889 F.2d
22 899, 902 (9th Cir. 1989); SEC v. Dresser Industries, 628 F.2d 1368, 1375 (D.C. Cir.
23 1980):
24 In the absence of substantial prejudice to the rights of the parties
involved, [simultaneous] parallel [civil and criminal] proceedings are
25 unobjectionable under our jurisprudence. . . . Nevertheless, a court
may decide in its discretion to stay civil proceedings. . . ‘when the
26 interests of justice seem[] to require such action.’”

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1 Id., quoting Dresser, 628 F.2d at 1374 & 1375 (quoting United States v. Kordel,
2 397 U.S.1, 12 n.27 (1970).
3 The decision whether to stay civil proceedings in the face of a parallel
4 criminal proceeding should be made “in light of the particular circumstances and
5 competing interests involved in the case.” Keating v. OTS, 45 F.3d at 324, quoting
6 FSLIC v. Molinaro, 889 F.2d at 902. This means the Court should consider “the
7 extent to which the defendant’s fifth amendment rights are implicated.” Id. In
8 addition, the Court should generally consider the following factors: (1) the interest
9 of the plaintiffs in proceeding expeditiously with this litigation or any particular
10 aspect of it, and the potential prejudice to plaintiffs of a delay; (2) the burden
11 which any particular aspect of the proceedings may impose on defendants; (3) the
12 convenience of the court in the management of its cases, and the efficient use of
13 judicial resources; (4) the interests of persons not parties to the civil litigation; and
14 (5) the interest of the public in the pending civil and criminal litigation. Keating v.
15 OTS, 45 F.3d at 324-25, citing FSLIC v. Molinaro, 889 F.2d at 903.
16 Consideration of these factors does not warrant staying this case. As
17 explained in Keating, the first factor the Court assesses is the extent to which the
18 Defendant’s Fifth Amendment rights are implicated. Indeed, Dvorak is somewhat
19 coy about whether he in fact intends to assert his own Fifth Amendment privilege,
20 generally arguing that his Fifth Amendment right is “implicated” because of the
21 similarity of the allegations in this case and the criminal case (Stay Motion at 11),
22 but also generally arguing that his criminal co-defendants are potential witnesses
23 whose testimony would be favorable to him, and that their rights are implicated.1
24
1
25 For example, Dvorak broadly asserts that “Based upon the striking similarity
of the allegations contained in the indictment and those raised in the Complaint in
26 this case, Dvorak believes that critical testimony of the other defendants would not
be available to him in the defense of the civil matter in that said testimony suggests
a waiver of each defendant’s Fifth Amendment rights would be needed,” (Stay
2
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1 Contrary to the Defendant’s general assertions, his Fifth Amendment rights

2 are not at all implicated. A review of the Commission’s Statement of Undisputed
3 Material Facts (“Facts”) filed in support of its motion for summary judgment
4 (Docket No. 161-2) and the supporting evidence attached to the accompanying
5 Declaration of Karen Matteson (Docket No. 161-3) reveals that the Commission’s
6 evidence against Dvorak which establishes his liability for violating the securities
7 registration provisions of Section 5 consists solely of Dvorak’s own admissions
8 from three sources: (1) his Answer; (2) his testimony in the Commission’s
9 investigation; and (3) his deposition testimony in this action. (Facts ¶¶ 1-5 &14-
10 36.) This is very similar to the situation in Molinaro, where the Ninth Circuit, in
11 affirming the District Court’s denial of a stay, explained:
12 As for his fifth amendment privilege assertions, Molinaro had already
given a partial deposition to FSLIC attorneys which provided the basis
13 of support for FSLIC’s summary judgment motion. Moreover,
nothing prevented Molinaro from responding to FSLIC’s motion with
14 information that did not tend to incriminate him. Under these
circumstances, any burden on Molinaro’s fifth amendment privilege is
15 negligible.
16 FSLIC v. Molinaro, 889 F.2d at 903.
17 Here, Dvorak did not assert his Fifth Amendment privilege in response to
18 any of the Commission’s questions. Even if he had asserted that privilege:
19 A defendant has no absolute right not to be forced to choose between
testifying in a civil matter and asserting his Fifth Amendment
20 privilege. Not only is it permissible to conduct a civil proceeding at
21
22 Motion at 5 ¶ 13), and that “it is a reasonable assumption” that “most or all” of the
criminal defendants will “potentially” invoke their Fifth Amendment privilege.
23 (Id. at 5 ¶ 14.). However, Dvorak has not sought to take these Defendants’
depositions; nor is the relevance of their testimony to his opposition to the
24 Commission’s summary judgment motion apparent, as the Commission’s motion is
based on Dvorak’s own admissions. Nor does Dvorak explain why his assumption
25 that the Fifth Amendment will be asserted is “reasonable” as to his co-defendant
Helen Bagley, who filed a declaration in opposition to the Commission’s summary
26 judgment motion as to her, rather than asserting her Fifth Amendment privilege.
(Docket No. 167.)
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the same time as a related criminal proceeding, even if that

1 necessitates invocation of the Fifth Amendment privilege, but it is
even permissible for the trier of fact to draw adverse inferences from
2 the invocation of the Fifth Amendment in a civil proceeding.
3 Keating v. OTS, 45 F.3d at 326, citing Baxter v. Palmigiano, 425 U.S. 308, 318
4 (1976). See also SEC v. Colello, 139 F.3d 674, 677-78 (9th Cir. 1998) (affirming
5 summary judgment against nominal defendant against whom the District Court
6 drew an adverse inference based on his assertion of the Fifth Amendment).
7 Similarly, the Commission’s evidence in support of summary judgment against
8 Dvorak as to the remaining issue – the amount of his ill-gotten gains – consists
9 solely of his own admissions in testimony and his deposition, including that he
10 received at least $157, 500 for writing at least 450 CMKM opinion letters at $350
11 per letter, and the Declaration of Nina Yamamoto, a Commission accountant who
12 analyzed bank records. (See Facts ¶¶ 87-89.) Dvorak nowhere states that the
13 Commission’s analysis is incorrect, or explains why it is incorrect. Making such
14 an argument would not appear to require testimony. In any event, as in Molinaro,
15 nothing prevented Dvorak from responding to the Commission’s motion with
16 information that did not tend to incriminate him.
17 Assuming that Dvorak’s Fifth Amendment privilege was implicated, the
18 Court would look to the remaining five factors set forth in Keating and Molinaro.
19 Factors (1) (the interest of the plaintiffs in proceeding expeditiously with this
20 litigation and the potential prejudice to plaintiff of a delay); (4) (the interests of
21 persons not parties to the civil litigation); and (5) (the interest of the public in the
22 pending civil and criminal litigation) do not favor imposition of a stay. The
23 Commission filed its summary judgment motion because it is in the public interest
24 and the Commission’s interest to expeditiously resolve this action, obtain
25 judgments against all defendants, and seek to collect on those judgments for the
26 potential benefit of the victims of the Defendants’ scheme.

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1 The Commission does not believe that the third factor, the convenience of
2 the Court in the management of its cases, and the efficient use of judicial
3 resources, favors a stay either. Although Dvorak seems to argue that it would be
4 best to stay this case because, if the defendants are convicted in the criminal case,
5 this Court would then be able to grant a motion for summary judgment by the
6 Commission on collateral estoppel grounds, this just means that the Court would
7 be evaluating a different summary judgment motion, not that it would be
8 expending substantially less judicial resources. (See Stay Motion at 14-15).
9 Dvorak’s arguments regarding discovery disputes that would result if a stay is not
10 granted are simply puzzling as he has no discovery pending in this case, which was
11 filed almost three years ago, and does not set forth, as required by Fed. R. Civ. P.
12 56(d), what discovery he requires to oppose the Commission’s motion, which is
13 based on his own admissions. As one district court has explained:
14 [T]he courts have an interest in seeing civil actions proceed
even where a criminal investigation is ongoing:
15
[C]onvenience of the courts is best served when motions to stay
16 proceedings are discouraged. The courts must be mindful that
“a policy of issuing stays solely because a litigant is defending
17 simultaneous lawsuits would threaten to become a constant
source of delay and an interference with judicial
18 administration.”
19 CFTC v. A.S. Templeton, 297 F. Supp.2d 531, 535 (E.D.N.Y. 2003) (citations
20 omitted).
21 The only factor that arguably favors a stay is factor (2): the burden which
22 any particular aspect of the proceedings may impose on the defendant. Even this
23 factor is weak, however. Dvorak’s burden would have been no greater if he had
24 filed a proper opposition to the Commission’s motion for summary judgment rather
25 than his somewhat lengthy meritless stay motion. The fact that this Defendant is
26 unable to present any evidence controverting his own admissions, and can think of

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1 no legal basis on which to argue that the Commission’s motion should be denied
2 does not, of course, constitute a “burden” on the Defendant as contemplated by the
3 Ninth Circuit in Keating and Molinaro. In particular, this factor was not significant
4 in Keating because even though the criminal trial and administrative proceeding
5 before OTS were pending during the same period, Defendant Keating had adequate
6 time to prepare for the OTS hearing. 45 F.3d at 325. Here, the criminal trial is now
7 scheduled for October 17, 2011.2 Dvorak has had years to conduct the discovery in
8 this action, and has plenty of time to prepare for his criminal trial, even if he had
9 taken the time to oppose the Commission’s motion.
10 B. The Commission’s Motion For Summary Judgment Should Be
11 Granted, As The Defendant Has Not Met His Burden Under Fed.
12 R. Civ. P. 56(d)
13 Dvorak boldly “seeks additional time” in which to respond to the
14 Commission’s motion, should the Court deny his motion for a stay. (Stay motion
15 at 6, ¶ 18). He does not state how much time he wants; nor does he cite a legal
16 basis for seeking such additional time.
17 The proper mechanism for Dvorak to seek an order seeking additional time to
18 respond to the Commission’s motion was for him to comply with Fed. R. Civ. P. 56(d):3
19
20
2
21 Dvorak conspiratorially suggests that the Commission was aware of the now
vacated February 7, 2011, trial date in the criminal case, and that it timed its
22 summary judgment motion to make it difficult for the Defendant to defend one or
both actions. It is not clear what the legal relevance would be of such intent on the
23 part of the Commission. Nevertheless, assuming the relevance of this issue, the
undersigned counsel, who was assigned to this case in order to facilitate
24 completion of the Commission’s litigation of it, had no knowledge of either the
February 7 trial date or the new October 2011 date until served with Dvorak’s stay
25 motion.
3
Effective December 1, 2010, Rule 56 was amended; Subdivision (d) carries
26 forward without substantial change the provisions of former subdivision (f). See
2010 Amendments, Note to Subdivision (d) of Rule 56.
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1 When Facts Are Unavailable to the Nonmovant. If a nonmovant

shows by affidavit or declaration that, for specified reasons, it cannot
2 present facts essential to justify its opposition, the court may:
(1) Defer considering the motion or deny it;
3 (2) Allow time to obtain affidavits or declarations or to take
discovery; or
4 (3) Issue any other appropriate order.
5 Dvorak has not even attempted to meet these requirements. Failure to comply with
6 the requirements of Rule 56(d) is a proper ground for denying discovery and
7 proceeding to summary judgment. In re Silicon Graphics Inc. Securities
8 Litigation, 183 F.3d 970, 989 (9th Cir. 1999) (proper for district court to proceed to
9 merits of summary judgment where nonmovant failed to file a motion seeking
10 discovery or even explain why discovery was necessary, as well as failing to file
11 the required affidavit detailing with particularity the information she hoped to
12 obtain by discovery). See also Metro Lights, LLC v. City of Los Angeles, 488 F.
13 Supp. 2d 927, 938 (C.D. Cal. 2006) (“In short, the opposing party must explain
14 with particularity why it is unable to oppose the motion, state with specificity what
15 facts it intends to seek through discovery, and show how its discovery efforts are
16 reasonably expected to create a triable issue.”)
17 Assuming that the Court were generously to ignore Dvorak’s procedural
18 failures, and treat the stay motion as a motion for additional discovery under Rule
19 56(d), the Court should still proceed to grant the Commission summary judgment.
20 Dvorak has not pointed to any evidence that he could have discovered that would
21 preclude summary judgment in the Commission’s favor. See NRDC v. Houston,
22 146 F.3d 1118, 1133 (9th Cir. 1998), citing Garrett v. City and County of San
23 Francisco, 818 F.2d 1515, 1518 (9th Cir. 1987) (nonmovant’s pending discovery
24 motion satisfied then-Rule 56(f) because it made clear the information sought, and
25 did not seek broad additional discovery, but rather sought only personnel records
26 of 16 named firefighters and indicated the purpose for which the information was

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1 sought). Nor has Dvorak identified any disputed factual issues in his stay motion.
2 See Trevino v. Gates, 99 F.3d 911, 921 (9th Cir. 1996).
3 The party opposing summary judgment bears the burden of showing what
4 facts he hopes to discover to raise a material issue of fact, as well as the burden of
5 showing that the evidence sought exists. Terrell v. Brewer, 935 F.2d 1015, 1018
6 (9th Cir. 1991); see also Maljack Productions v. Goodtimes Home Video Corp., 81
7 F.3d 881, 888 (9th Cir. 1996) (district court properly denied then-Rule 56(f) motion
8 where counsel listed a number of facts that, even if established, would not have
9 precluded summary judgment, and properly refused to allow discovery to search
10 for evidence nonmovant thought “may exist”). Denial of a Rule 56(d) application
11 is proper where it is clear that the evidence sought is almost certainly nonexistent
12 or is the object of pure speculation. Terrell v. Brewer, 935 F.2d at 1018. Here,
13 Dvorak has not even articulated the evidence he would seek, much less speculated
14 as to what it might be.
15 Moreover, this action has been pending almost three years. The Court does
16 not abuse its discretion by denying further discovery if the nonmovant has failed
17 diligently to pursue discovery in the past or if the nonmovant has failed to show
18 how the information sought would preclude summary judgment.4 California
19 Union Ins. v. American Diversified Sav., 914 F.2d 1271, 1278 (9th Cir. 1990).
20
4
Among other things, Dvorak states that he learned on January 6, 2011, that
21 “there are about 200 file boxes of material not previously disclosed in the
possession of the SEC in Los Angeles.” (Stay Motion at 7.) This is false. As set
22 forth in its Notice Of Compliance With Rule 26 Of The Federal Rules Of Civil
Procedure And Local Rule 26-1(D), filed July 14, 2008, the Commission sent all
23 defendants CDs containing electronic copies of the testimony transcripts from its
investigations related to this litigation, as well as all documents marked as exhibits
24 at those testimonies, totaling 52 testimony transcripts and 675 exhibits. (Docket
No. 64 at 3.) The Commission made all other discoverable materials available to
25 the defendants for examination and copying. (Id. at 3.) Dvorak obviously cannot
legitimately claim that documents made available to him that he chose not to
26 inspect and copy are “not previously disclosed,” and that he therefore needs to
conduct formal discovery.
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1 As explained, the Commission’s motion as to Dvorak’s liability is based

2 solely on his own admissions. As to disgorgement, the motion is based on
3 Dvorak’s admissions coupled with an analysis of relevant bank records, which
4 Dvorak does not challenge. Dvorak nowhere explains why, given the evidence
5 presented by the Commission, the Commission is not entitled to judgment as a
6 matter of law against him. Nor has Dvorak, an attorney who is represented by
7 counsel, explained why he needs additional time to respond to the Commission’s
8 motion when the other two parties against whom the Commission moved, one of
9 whom is pro se, timely filed oppositions prior to Dvorak filing his stay motion.
10 Accordingly, to the extent that Dvorak’s request for additional time is
11 construed as a request for additional discovery under Rule 56(d), it should be
12 denied as it does not articulate a basis for such relief. Additionally, to the extent
13 Dvorak’s request for additional time is considered as just that, it should be denied
14 because it is unsupported. Dvorak took a calculated risk in waiting until the last
15 day his opposition to the summary judgment motion was due to file instead a
16 motion for a stay. There is no reason such gamesmanship should be rewarded.
17 III. CONCLUSION
18 For the reasons stated, Dvorak’s motion to stay this action should be denied,
19 and the Commission’s motion for summary judgment should be granted as to
20 Dvorak.
21
22 Dated: January 27, 2011 Respectfully submitted,
23
24 /s/Karen Matteson
Karen Matteson
25 Attorney for Plaintiff
Securities and Exchange Commission
26

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PROOF OF SERVICE
1
I am over the age of 18 years and not a party to this action. My business address is:
2
[X] U.S. SECURITIES AND EXCHANGE COMMISSION, 5670 Wilshire
3 Boulevard, 11th Floor, Los Angeles, California 90036-3648
Telephone No. (323) 965-3998; Facsimile No. (323) 965-3908.
4
On January 27, 2011, I caused to be served the document entitled OPPOSITION BY
5 PLAINTIFF SECURITIES AND EXCHANGE COMMISSION TO MOTION BY
DEFENDANT BRIAN DVORAK TO STAY ACTION; REPLY IN FURTHER
6 SUPPORT OF PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT on all
the parties to this action addressed as stated on the attached service list:
7
[X] OFFICE MAIL: By placing in sealed envelope(s), which I placed for
8 collection and mailing following ordinary business practices. I am readily
familiar with this agency’s practice for collection and processing of
9 correspondence for mailing; such correspondence would be deposited with
the U.S. Postal Service on the same day in the ordinary course of business.
10
[ ] PERSONAL DEPOSIT IN MAIL: By placing in sealed
11 envelope(s), which I personally deposited with the U.S. Postal Service.
Each such envelope was deposited with the U.S. Postal Service at Los
12 Angeles, California, with first class postage thereon fully prepaid.
13 [ ] EXPRESS U.S. MAIL: Each such envelope was deposited in a facility
regularly maintained at the U.S. Postal Service for receipt of Express
14 Mail at Los Angeles, California, with Express Mail postage paid.
15 [ ] HAND DELIVERY: I caused to be hand delivered each such envelope to
the office of the addressee as stated on the attached service list.
16
[ ] UNITED PARCEL SERVICE: By placing in sealed envelope(s)
17 designated by United Parcel Service (“UPS”) with delivery fees paid or
provided for, which I deposited in a facility regularly maintained by UPS or
18 delivered to a UPS courier, at Los Angeles, California.
19 [X] ELECTRONIC MAIL: By transmitting the document by electronic mail
to the electronic mail address as stated on the attached service list.
20
[X] E-FILING: By causing the document to be electronically filed via the
21 Court’s CM/ECF system, which effects electronic service on counsel who
are registered with the CM/ECF system.
22
[ ] FAX: By transmitting the document by facsimile transmission. The
23 transmission was reported as complete and without error.
24 I declare under penalty of perjury that the foregoing is true and correct.
25 Date: January 27, 2011 /s/ Karen Matteson
26 Karen Matteson

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1 SEC v. CMKM DIAMONDS, INC., et al.

United States District Court - District of Nevada
2 Case No. 2:08-CV-00437-LRH-RJJ
(LA-3028)
3
SERVICE LIST
4
Irving M. Einhorn, Esq. (served via electronic and U.S. mail)
5 Law Offices of Irving M. Einhorn
1710 10th Street
6 Manhattan Beach, CA 90266
Email: ime@einhornlaw.com
7 Attorney for Defendant John Edwards
8 Mark S. Dzarnoski, Esq. (served via CM/ECF only)
Gordon & Silver, Ltd.
9 3960 Howard Hughes Parkway, Ninth Floor
Las Vegas, NV 89169
10 Email: mdzarnoski@gordonsilver.com
Attorney for Helen Bagley and 1st Global Stock Transfer LLC
11
Urban A. Casavant (served via electronic and U.S. mail)
12 RR 5 Site 16 Box 29
Prince Albert, Saskatchewan S6V 5R3
13 Canada
Email: ucasavant@shaw.ca
14
John Wesley Hall, Jr., Esq. (served via CM/ECF only)
15 1311 Broadway
Little Rock, AR 72202-4843
16 Email: forhall@aol.com
Attorney for Brian Dvorak
17
Kathleen Tomasso (served via U.S. mail only)
18 9580 Lake Serena Drive
Boca Raton, FL 33496
19 Email: ttomasso@ncfgcomm.com
20 Anthony Tomasso (served via U.S. mail only)
9580 Lake Serena Drive
21 Boca Raton, FL 33496
Email: ttomasso@ncfgcomm.com
22
Sergey Rumyantsev (served via electronic and U.S. mail)
23 1951 North Jones Boulevard, #G-202
Las Vegas, NV 89108
24 Email: chaptak@embarqmail.com
25 Anthony Santos (served via electronic and U.S. mail)
6965 North Durango Drive, Suite 1115-208
26 Las Vegas, NV 89149
Email: Ams.nwst@gmail.com

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1
NevWest Securities Corporation (served via U.S. mail only)
2 c/o Anthony Santos
6965 North Durango Drive, Suite 1115-208
3 Las Vegas, NV 89149
Email: Ams.nwst@gmail.com
4
Douglas E. Griffith, Esq. (served via electronic and U.S. mail)
5 Kesler & Rust
McIntyre Building, 2nd Floor
6 68 S. Main Street
Salt Lake City, UT 84101
7 Email: dgriffith@kesler-rust.com
Attorney for Daryl Anderson
8
Eric N. Klein, Esq. (served via electronic and U.S. mail)
9 Eric N. Klein & Associates, P.A.
1200 N. Federal Highway, Suite 200
10 Boca Raton, FL 33432
Email: enk@kleinattorneys.com
11
Michael R. Bakst (served via electronic and U.S. mail)
12 PMB 702
222 Lakeview Avenue, #160
13 West Palm Beach, FL 33401
Email: michael.bakst@ruden.com
14
15
16
17
18
19
20
21
22
23
24
25
26

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