HomeMy Public PortalAbout2014-CA-003721 Deposition of Robert Ganger (01/31/2018)1
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR
PALM BEACH COUNTY, FLORIDA
CASE NO. 2014-CA-003721
Division AH: Judge Small
STOPDIRTYGOVERNMENT, LLC,
Plaintiff,
v.
TOWN OF GULF STREAM,
Defendant.
- - - - - - - - - - - - - - - x
DEPOSITION OF ROBERT GANGER
TAKEN ON BEHALF OF THE PLAINTIFF
Wednesday, January 31,2018
Gulf Stream Town Hall
100 Sea Lane
Gulf Stream, Florida
9:30 a.m. - 10:05 a.m.
Examination of the witness taken before:
Felecia Curreri, Court Reporter
Daughters Reporting, Inc.
101 Northeast 3rd Avenue
Suite 1500
Fort Lauderdale, Florida 33301
2
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 APPEARANCES:
2 Appeared for the Plaintiff
3 Sach Sax Caplan, P.L.
6111 Broken Sound Parkway NW
4 Suite 200
Boca Raton, Florida 33487
5 BY: ROBERT RIVAS, ESQUIRE
Tel: 561-994-4499
6 Email: robertrivas@comcast.net
7 The O'Boyle Law Firm, PL
1286 W. Newport Center Drive
8 Deerfield Beach, Florida 33442
BY: JONATHAN R. O'BOYLE, ESQUIRE
9 Tel: 754-212-4201
Email: joboyle@oboylelawfirm.com
10
Appeared for the Defendant
11
Jones Foster Johnson & Stubbs, P.A.
12 505 S. Flagler Drive
Suite 100
13 West Palm Beach, Florida 33401
BY: JOANNE M. O'CONNOR, ESQUIRE
14 Tel: 561-659-3000
Email: joconnor@jonesfoster.com
15
Town of Gulf Stream
16 100 Sea Road
Gulf Stream, Florida 33483
17 BY: EDWARD C. NAZZARO, ESQUIRE
Tel: 561-221-9008
18 Email: tnazzaro@gulf-stream.org
19 Appeared for the Deponent
20 Weiss Serota Helfman Cole & Bierman
1200 North Federal Highway
21 Suite 312
Boca Raton, Florida 33432
22 BY: MATTHEW T. RAMENDA, ESQUIRE
Tel: 561-835-2111
23 Email: Mramenda@wsh-law.com
24 ALSO PRESENT:
25 Mayor Scott Morgan
3
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Daughters Reporting, Inc.
1 INDEX
PAGE
2
Direct Examination
3 By Mr. Rivas 5
4
Cross-Examination
5 By Ms. O'Connor 22
6 Certificate of Oath 24
7 Certificate of Reporter 25
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
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Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 EXHIBITS
2 PLAINTIFF'S
EXHIBIT DESCRIPTION PAGE
3
A (Deposition Notice) 6
4
B (Documents Produced) 7
5
C (Public Records Request) 8
6
D (12-17-2013 Letter) 16
7
E (4-23-2013 Letter) 16
8
F (Appointment of Treasurer) 18
9
G (Emails) 19
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
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Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Deposition of ROBERT GANGER, taken before
2 Felecia Curreri, Registered Professional Reporter
3 and Notary Public in and for the State of Florida
4 at Large, in the above cause.
5
6 THE COURT REPORTER: Do you swear or
7 affirm that the testimony you are about to
8 give will be the truth, the whole truth, and
9 nothing but the truth?
10 THE WITNESS: I do.
11 DIRECT EXAMINATION
12 BY MR. RIVAS:
13 Q. Good morning, Mr. Ganger. Thank you for
14 being here today. I'm Robert Rivas. We just met.
15 I'm going to try to be as simple and expeditious as
16 possible this morning and if you feel that because
17 of tiredness or any other condition you need to
18 leave, I'll be happy to accommodate that.
19 So, if it's okay with you, I'll jump right
20 into the issues without any preliminaries or delay.
21 You are aware that this is a public
22 records lawsuit against the Town, correct?
23 A. Generally.
24 Q. Are you familiar with the particular
25 public records request that's the one at issue
6
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1 here?
2 A. The one that was issued to me?
3 Q. The one that's at issue in this particular
4 case.
5 A. Explain. What's the question, am I aware?
6 Q. Yes.
7 A. Yes.
8 Q. Okay. And you were subpoenaed to be here
9 today. I just want to have marked as Exhibit A and
10 give you a copy of the -- I think this is the
11 former subpoena from the 16th.
12 MR. O'BOYLE: I've got a copy of it.
13 MR. RIVAS: Well, for purposes of the
14 questioning today, the only thing that's
15 changed is the date, so I'm going to go ahead
16 and use this one.
17 You want another copy, Joanne?
18 MS. O'CONNOR: No, I have it.
19 (Plaintiff's Exhibit A, was marked for
20 identification.)
21 BY MR. RIVAS:
22 Q. I'm going to show you a document that's
23 been marked as Exhibit A and ask you if you've had
24 an opportunity to review that?
25 A. The first one I received was to appear on
7
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1 January 5th.
2 Q. Right. It was supplanted twice and you
3 are now here on the third one, but I only wanted to
4 ask you a question or two about something that
5 didn't change from one of those through -- that was
6 identical in all of them, anyway. It's the list of
7 -- the request there to produce documents.
8 Did you review the items on that list that
9 are requested to be brought?
10 A. Yes.
11 Q. Did you bring documents in accordance with
12 that request?
13 A. I submitted documents to the attorney.
14 Q. To counsel?
15 A. Uh-huh.
16 MR. RIVAS: I would like these to be
17 marked as Exhibit B.
18 (Plaintiff's Exhibit B, was marked for
19 identification.)
20 BY MR. RIVAS:
21 Q. Now, I'm going to show you -- I may look
22 at these documents that you produced later, but for
23 the moment we'll just skip over them. I'm going to
24 show you a document that is the particular public
25 records request. You've undoubtedly seen quite a
8
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1 few public records requests, right?
2 A. When?
3 Q. Over the years as a city council member.
4 A. Some.
5 Q. The particular public records request that
6 is at issue in this lawsuit, I'm going to give you
7 a copy of it. It says Exhibit 1 on the front
8 because that's the way it's marked at trial, but if
9 we could have that marked as Exhibit C. I have
10 extra copies of all these things, if counsel need
11 them.
12 MS. O'CONNOR: Sure. If I could take a
13 look at them. Thanks.
14 (Plaintiff's Exhibit C, was marked for
15 identification.)
16 BY MR. RIVAS:
17 Q. Have you ever seen that particular public
18 records request?
19 A. I simply can't remember.
20 Q. Okay. Do you remember in February of 2014
21 being asked at some point to help with producing
22 documents in response to a public records request
23 that sought all communications in the public
24 records sent by or received by Commissioner Ganger
25 for a certain period of time prior to
9
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1 February 2014?
2 A. I have no recollection, but when I went
3 back as a result of this recent thing, yes,
4 something was asked of me back then, but you have
5 to understand I just don't remember.
6 Q. A lot of people wouldn't.
7 Do you remember what you were asked to do
8 about it?
9 A. No.
10 Q. Do you remember searching for documents to
11 help respond to it?
12 A. Well, apparently I did, but I don't
13 remember.
14 Q. Do you remember who contacted you about
15 it?
16 A. I'm assuming it was the town manager, but,
17 no, I don't remember.
18 Q. When you get public records requests and
19 someone from the town administration asks you to
20 help gather documents to respond to it, what do you
21 normally do?
22 MR. RAMENDA: Object to form, but go ahead
23 and answer.
24 MS. O'CONNOR: Join.
25 THE WITNESS: What do I normally do?
10
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1 When?
2 BY MR. RIVAS:
3 Q. When you get a request that's been
4 forwarded to you from the Town.
5 A. I fill it out. I do whatever I was asked
6 to do.
7 Q. Okay. And you have no recollection of
8 what you were asked to do in this particular
9 instance?
10 A. You have to understand, I've had a serious
11 brain problem. I just don't remember. Sorry, but
12 I don't remember.
13 Q. Okay. I understand.
14 I would like to take a break for a few
15 minutes. We may be finished.
16 MS. O'CONNOR: Sure.
17 MR. RIVAS: If I could just take a break
18 and talk to Jon.
19 MS. O'CONNOR: Sure.
20 (A brief recess was taken, after which the
21 following proceedings were had:)
22 MR. RIVAS: Back on the record.
23 BY MR. RIVAS:
24 Q. Mr. Ganger, do you have any knowledge or
25 training about the public records law?
11
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1 A. Yes.
2 Q. What would your training be?
3 A. We were all actually in this room,
4 somebody from the county, I believe it was a former
5 police officer came and took us through a
6 presentation and we had some reading material and I
7 don't remember how we passed, but we all passed it.
8 I believe at our meeting, there were people from
9 outside of Gulf Stream. I happen to remember the
10 major of Ocean Ridge was here, so it was obviously
11 a big meeting.
12 Q. Do you remember when that was?
13 A. No. It was shortly after. I mean, I
14 don't remember, but it was shortly after I became a
15 commissioner or possibly I wasn't even a
16 commissioner yet.
17 Q. When did you first become a commissioner?
18 A. I was afraid you were going to ask me
19 that. The mayor, our mayor for many, many years
20 passed away and I believe it was the second meeting
21 after he had died that I was named a commissioner.
22 Q. Do you consider yourself proficient in the
23 use of computers?
24 A. Oh, no.
25 Q. Email systems?
12
Fort Lauderdale, Florida 954-755-6401
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1 A. Yes, that's what I use them for.
2 Q. But do you feel you are proficient in
3 email technology?
4 A. No.
5 Q. Do you know how to do searches?
6 A. I know how to -- we didn't have computers
7 when I was working, which is what happens when you
8 are over 80, and so I learned, as many older people
9 learn, just enough to be able to use the computer
10 essentially as a typewriter.
11 Q. If somebody asked you to search your
12 previous emails for emails on a certain topic, do
13 you know how to do a search like that?
14 A. I do the best I can.
15 Q. But you don't consider your abilities in
16 that area proficient?
17 MR. RAMENDA: Object to form.
18 MS. O'CONNOR: Objection.
19 BY MR. RIVAS:
20 Q. You said no?
21 A. No, I didn't say anything. I was still
22 listening to the question. You asked the question.
23 Finish the question. I'm sorry, I'm trying to be
24 as --
25 Q. I understand.
13
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 A. -- listen to you carefully.
2 Q. I thought your mouth moved and I couldn't
3 hear anything, I thought you said no or --
4 A. Repeat the question, I'm sorry.
5 Q. Do you feel that you are proficient in
6 being able to search emails to find emails on a
7 search topic?
8 MR. RAMENDA: Objection to form.
9 MS. O'CONNOR: Objection; form.
10 BY MR. RIVAS:
11 Q. You can answer.
12 A. I'm sorry, you'll have to ask the question
13 again.
14 Q. If somebody asked you to search for all of
15 your emails, past emails, search through those for
16 every one that's on a certain topic, do you know
17 how to do that?
18 MS. O'CONNOR: Object to form.
19 MR. RAMENDA: Objection. If you are able
20 to answer the question and you understand it,
21 you can answer it.
22 THE WITNESS: That's an absolute question
23 and I do the best I can, let's put it that
24 way.
25 BY MR. RIVAS:
14
Fort Lauderdale, Florida 954-755-6401
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1 Q. Okay.
2 A. And please understand, you are talking
3 about somebody who's had a stroke and I don't
4 really remember whether or not I was -- how
5 proficient I was before, but if you ask me today
6 versus if you ask me five years ago, I would
7 probably give you a different answer.
8 Q. Over the years that you were on the town
9 commission, you routinely received agendas and
10 backup materials for meetings in advance of the
11 meetings; is that correct?
12 A. In paper form.
13 Q. Right. You didn't receive them by email
14 transmission?
15 A. No.
16 Q. You got them in hard copies?
17 A. Yes.
18 Q. Did they get mailed to you or did you pick
19 them up?
20 A. They were usually delivered by the police.
21 Q. So you routinely get a hand delivery
22 before each meeting of materials that you needed
23 for the upcoming meeting?
24 A. Correct.
25 Q. That would include an agenda?
15
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1 MR. RAMENDA: Object to form.
2 BY MR. RIVAS:
3 Q. Would that include an agenda for the
4 meeting?
5 A. Always.
6 Q. And would there usually be, at least,
7 minutes of previous meetings?
8 A. Always.
9 Q. And if there's a proposed amendment to an
10 ordinance, would the proposed amendment be -- the
11 whole text of it be one of the backup materials?
12 A. Most of the backup materials would, as
13 complete as the town clerk could make them before
14 the meeting.
15 Q. And there would be routine budget and
16 performance, financial reports?
17 MS. O'CONNOR: Object to form.
18 BY MR. RIVAS:
19 Q. Was that a yes?
20 A. Sometimes.
21 Q. Sometimes. And there were occasional
22 reports of ongoing matters, update reports of
23 ongoing matters that involved the Town that you
24 would receive in the agenda package?
25 MS. O'CONNOR: Objection to form.
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1 MR. RAMENDA: Objection; form.
2 THE WITNESS: Sometimes. I mean, you are
3 asking a general question, I'll give you a
4 general answer. We received as much
5 information as the clerk could get in time for
6 us to review it and be prepared for the
7 meeting.
8 MR. RIVAS: Okay. Copies for you and I
9 have another document I would like to have
10 marked as the next exhibit.
11 (Plaintiff's Exhibit D, was marked for
12 identification.)
13 BY MR. RIVAS:
14 Q. I'm going to show you a document that's
15 been marked as Exhibit D. Do you recall that
16 document?
17 A. No, but I -- doesn't mean -- that's my
18 signature, so obviously I wrote it.
19 (Plaintiff's Exhibit E, was marked for
20 identification.)
21 BY MR. RIVAS:
22 Q. I'm going to show you a document that's
23 been marked as Exhibit E and ask you if you
24 remember ever seeing that document?
25 MS. O'CONNOR: I'm just going to object.
17
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1 It appears to be a composite of a number of
2 documents.
3 THE WITNESS: No recollection whatsoever.
4 BY MR. RIVAS:
5 Q. If you'd look at the last page of it.
6 These documents are all attached to an email, you
7 see, that was transmitted to
8 rwganger@bellsouth.net.
9 MR. RAMENDA: Objection to form.
10 MS. O'CONNOR: Objection.
11 BY MR. RIVAS:
12 Q. Is rwganger@bellsouth.net, that's your
13 email address, right?
14 A. Yes.
15 Q. And 2013 and '14, it would have been your
16 email address?
17 A. Yes.
18 Q. You see where it's forwarded from Bill
19 Thrasher?
20 A. Uh-huh.
21 Q. Do you believe -- that means you must have
22 been sent this email by Mr. Thrasher.
23 MR. MAN: Object to form.
24 MS. O'CONNOR: Join.
25 THE WITNESS: No recollection. As far as
18
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1 I can tell you, I've never seen it, but then
2 again.
3 BY MR. RIVAS:
4 Q. Okay. You ran for reelection in 2014; is
5 that correct?
6 A. I'm sorry, what? My brain is going back
7 to 2014. I don't know when I ran -- I ran for
8 reelection, yes, but I was not elected the first
9 time because the mayor had died and I was
10 appointed.
11 Q. Okay. Let me show you a document that
12 we'll have marked as Exhibit F.
13 (Plaintiff's Exhibit F, was marked for
14 identification.)
15 BY MR. RIVAS:
16 Q. This on its face says that it's an
17 appointment of campaign treasurer and designation
18 of campaign depository for candidates and I wonder
19 if you'd look at that and confirm if this is yours.
20 A. Yes, it's definitely mine.
21 Q. That's your signature on the bottom of the
22 front page?
23 A. It's my signature on the bottom of the
24 front page.
25 Q. Do you mind glancing through it and see if
19
Fort Lauderdale, Florida 954-755-6401
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1 it at all looks like one unit, they all belong
2 together, they are all yours? There's the oath,
3 certification, candidate petition.
4 A. Yep.
5 Q. That's your filing papers, correct?
6 A. Yes.
7 Q. Okay. The next document I'll ask to be
8 marked is Exhibit G.
9 (Plaintiff's Exhibit G, was marked for
10 identification.)
11 BY MR. RIVAS:
12 Q. I would like to ask you if you'd look at
13 Exhibit G. Turn that horizontal document on its
14 side and tell me from your examination of those
15 names and the information on that page if you know
16 what that is, if you recognize it.
17 A. I have no idea what it is, nor do I
18 recognize it.
19 Q. Did you, at some point years ago, transfer
20 a large number of emails to the Town for them to
21 put them on the Town's website; do you remember
22 that?
23 A. No.
24 Q. I wonder if the organization and
25 subheadings of the categories of files on this list
20
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1 look to you like subheadings from your email
2 directory?
3 MR. RAMENDA: Object to form.
4 THE WITNESS: Yeah, I recognize a couple
5 of these, but it's like asking me what did I
6 have for breakfast in 2013.
7 BY MR. RIVAS:
8 Q. Well, when you log onto your emails, does
9 this look like the directories that come up?
10 A. No. I have no idea what this is.
11 Q. Okay. The documents that you brought with
12 you today, they were marked as Exhibit B that you
13 brought in?
14 A. I didn't bring in anything.
15 Q. That your lawyer carried in and handed to
16 me but you provided to him, correct?
17 A. I provided it to him, yes.
18 Q. How did you find them?
19 A. How did I find them? By going online and
20 doing every possible type of search I could think
21 of doing. It took me countless hours and because
22 the computer -- I may have slipped or done
23 something wrong, but I had to go to 2014 and when I
24 got one, it went right back to 2017. So, I was
25 laboriously trying to search every possible way I
21
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1 could think of searching for any record that I had,
2 which was responsive to the request that you all
3 sent me for me to appear on my birthday,
4 January 5th.
5 Q. When you found one that appeared to be
6 responsive, what did you do with that one?
7 A. Printed it out.
8 Q. You just sent it to the printer?
9 A. Just sent it to the printer.
10 Q. And then you stacked them all up, gave
11 them to your lawyer?
12 A. Correct.
13 Q. So these are all true and accurate, let's
14 say, un-authored photocopies of emails from your
15 email system?
16 A. Directly off my computer, printed and
17 handed it to him. I tried to organize them by
18 date, but you have to understand that the computer
19 would go back. So then I tried to figure out where
20 was I and it just kept going back and forth. I
21 must have spent hours doing it and my brain is just
22 not working.
23 Q. So it should be no surprise if we find
24 they are not in chronology order?
25 A. I don't know how you are going to find
22
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1 them, but I handed them up 20, 30 emails and said
2 this is the best I could do.
3 Q. Okay. Anything else? I have no further
4 questions at this time.
5 CROSS-EXAMINATION
6 MS. O'CONNOR:
7 Q. Joanne O'Connor for the Town. Very
8 briefly.
9 You indicated that you have a health
10 condition, a serious brain problem, correct?
11 A. Uh-huh.
12 Q. When did that occur?
13 A. Around April 20th, 2015 or is it '16?
14 Q. 2016?
15 A. Yes, I'm sorry.
16 Q. That's okay.
17 And was that a significant change in your
18 mental capacity from before this occurred to after?
19 A. It was significant as it could possibly be
20 because if it had lasted another couple of minutes
21 long, I probably would have died.
22 Q. During that time, you were an active
23 commissioner --
24 A. -- yes.
25 Q. Prior to experiencing this health event,
23
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1 correct?
2 A. Uh-huh.
3 Q. And you even advocated for the Town and
4 before the Florida Legislature, correct?
5 A. Yes.
6 Q. Do you consider yourself well-versed in
7 Sunshine Law and public records law?
8 A. Yes, was. Right now I can't remember what
9 my name is, but that's --
10 Q. Do you recall when you ran for reelection
11 that Martin O'Boyle also ran for election to the
12 town commissioner?
13 A. I certainly do recall.
14 Q. Did he reach out to you for assistance
15 relative to his campaign; do you recall?
16 A. Yes.
17 Q. And did you help him with his campaign?
18 A. Yes.
19 Q. Did you have any animosity towards
20 Mr. O'Boyle running for town commission?
21 A. No.
22 MS. O'CONNOR: No further questions.
23 Thank you very much.
24 MR. RAMENDA: Thank you. You're done.
25 (Deposition concluded at 10:05 a.m.)
24
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1 CERTIFICATE OF OATH
2
3 THE STATE OF FLORIDA
4 COUNTY OF PALM BEACH
5
6 I, the undersigned authority, certify
7 that the witness, ROBERT GANGER, personally
8 appeared before me on the 31st day of January,
9 2018, and was duly sworn.
10
11 Signed this 10th day of February, 2018.
12
13
14
15
16
FELECIA CURRERI, RPR
17 Notary Public - State of Florida
My Commission Expires: 12-19-2019
18 Commission No. FF 939059
19
20
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Fort Lauderdale, Florida 954-755-6401
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1 CERTIFICATE OF REPORTER
2 THE STATE OF FLORIDA
3 COUNTY OF PALM BEACH
4
5 I, FELECIA CURRERI, RPR, Shorthand
6 Reporter and Notary Public, State of Florida,
7 HEREBY CERTIFY that I was authorized to and did
8 stenographically report the deposition of ROBERT
9 GANGER; that a review of the transcript was
10 requested, and the foregoing transcript, 5 pages to
11 23, is a true and accurate record of my
12 stenographic notes.
13 I FURTHER CERTIFY that I am not a
14 relative, employee, attorney, or counsel of any of
15 the parties, nor am I a relative or employee of any
16 of the parties' attorney or counsel connected with
17 the action, nor am I financially interested in the
18 action.
19 Dated this 10th day of February, 2018.
20
21
22 ___________________________________
Felecia Curreri, RPR, Notary Public,
23 State of Florida at Large
24
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Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 ERRATA SHEET
2 IN RE: STOPDIRTYGOVERNMENT v. TOWN OF GULF STREAM
CASE NO: 2014-CA-003721
3 DEPONENT: ROBERT GANGER
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Reason for change:________________________________
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Reason for change:________________________________
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Under the penalties of perjury, I declare that I
22 have read the foregoing document and that the facts
stated are true.
23
24 ___________________________________________________
DATE ROBERT GANGER
25
27
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 February 10, 2018
2 Weiss Serota Helfman Cole & Bierman
1200 North Federal Highway
3 Suite 312
Boca Raton, Florida 33432
4 ATTN: MATTHEW T. RAMENDA, ESQUIRE
5 IN RE: DEPOSITION OF: ROBERT GANGER
TAKEN ON: January 31, 2018
6 STOPDIRTYGOVERNMENT v. TOWN OF GULF STREAM
7 Dear Mr. Ramenda, Esquire
8 This letter is to advise you that the transcript
taken in the above-referenced deposition has been
9 transcribed. Please contact our office at
954.755.6401 to make arrangements to read and sign.
10
The original of this transcript has been forwarded
11 to the ordering party and your errata, once
received, will be forwarded to all ordering parties
12 for inclusion in the transcript.
13 Sincerely,
14
15
_________________________________
16 Felecia Curreri, RPR
Daughters Reporting, Inc.
17 101 Northeast 3rd Avenue
Suite 1500
18 Fort Lauderdale, Florida 33301
daughtersreporting@gmail.com
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Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
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Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
A
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ATTN 27:4
attorney 7:13
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doing 20:20,21
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Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
21:21
Drive 2:7,12
duly 24:9
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E 4:7 16:19,23
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elected 18:8
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Expires 24:17
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3
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
M
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major 11:10
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Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
received 6:25
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Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
typewriter 12:10
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2015 22:13
2016 22:14
2017 20:24
2018 24:9,11
25:19 27:1,5
20th 22:13
22 3:5
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