(Topic ID: 203700)

deeproot Pinball thread

By pin2d

6 years ago


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14
#33351 5 months ago

The thing you have to remember with Robert's business plan is that he's crazy.

If it doesn't make sense to you, congrats. You're not crazy.

#33352 5 months ago
Quoted from benheck:

The thing you have to remember with Robert's business plan is that he's crazy.
If it doesn't make sense to you, congrats. You're not crazy.

Replace "crazy" with "an idiot" and your statement about Robert is more accurate.

#33353 5 months ago

A former Mueller colleague wants the judge to quash a subpoena to have to appear in court to provide live testimony as an expert witness as proposed by Mueller. And if he has to, he wants the judge to make sure Robert compensates him appropriately for travel, expenses, and missing work. He'd be open to appearing via zoom, if necessary. But he'd prefer to forego that, too.

SEC-134-2023.11.28.pdfSEC-134-2023.11.28.pdf
#33354 5 months ago
Quoted from mbeardsley:

I still don't understand what Robert was actually trying to accomplish with his pinball endeavor.

I think pinball was his "cover plan" for when the investment Ponzi scheme eventually collapsed. I think he aiways knew the "investment fund" scheme would inevitably implode, and he planned to point to the unsuccessful, but "legitimate" pinball business as where all the money went.

"See, I'm just a bad businessman, not a scammer and a thief."

#33355 5 months ago

Q. So, the stolen money wasn't your fault, the failed pinball company wasn't your fault, stealing old peoples retirement money wasn't your fault....WHO'S fault WAS it???

A. Pinside.

#33356 5 months ago
Quoted from blueberryjohnson:

Courtlistener shows that an order on the motion in limine has been filed. But there is no associated document. Occasionally, triggering the right thing in PACER populates the CL page with info that lives outside a filed document. But I forget where/how to trigger that. Can a PACER expert try to look whatever up to see if there are any details regarding the contents of the order?
https://www.courtlistener.com/docket/60223430/securities-and-exchange-commission-v-mueller/?order_by=desc

it is updated if you request the relevant docket part, you need to request by date instead of number.

#33357 5 months ago
Quoted from masterX244:

it is updated if you request the relevant docket part, you need to request by date instead of number.

Thanks!

Screenshot 2023-11-28 at 11.28.38?PM (resized).pngScreenshot 2023-11-28 at 11.28.38?PM (resized).png

So Robert's motion (to exclude the entering into evidence of details on what he spent money - the weddings, rings, divorces, cruises, condos, and such) was denied.

And the SEC's motion to exclude certain things was partially granted and partially denied (which doesn't tell us much of anything since that motion was 33 pages long).

#33358 5 months ago
Quoted from sgtski1978:

He could not possibly have done enough due diligence to understand that the costs of developing and manufacturing a pinball machine far exceed any hope of profit unless you're doing it at scale. And he didn't have scale. He didn't have a manufacturing base, he didn't have staff, he didn't have a supply chain. I mean, let him get on the stand and talk 'expertly' about pinball. What could possibly go wrong?

I wonder if Turner will be in attendance that day to listen to what his "expertise" is. Whatever level of expertise Turner thinks he has, Mueller had more of it, technically. Let that fact sink in when you think about Ninja Eclipse.

#33359 5 months ago
Quoted from TreyBo69:

Also it's depressing this still has not advance in the slightest. The fuck is wrong with the system where a guy who blatantly steals millions is waddling around looking for wife number four.

System isn't the fault at all. US Attorney in the district should have indicted him weeks after SEC started this investigation. 2 different US Attorney's in this district have dropped the ball so far in this case. If defendant had been indicted, a different federal criminal judge would have ruled much differently regarding the allowance of monies that were allowed to be distributed to his attorneys.

Quoted from CrazyLevi:

The US takes care of these guys. They are the straw that stirs the drink and we worship rich con men in this country.
Robert should probably run for President.

The SEC is civil and and is a walk in the park compared to DOJ. Our criminal laws are downright scary when you read and have someone (federal criminal attorney) interpret them for you. Rich people can afford much better representation. They can afford appeals when convicted. And still they usually end up doing time like the rest of us. Just takes longer. I met and became friends with a dozen or so famous people, politicians, and extremely wealthy in prison.

#33360 5 months ago

The reasoning behind this failed Ponzi scheme comes down to two things. Robert's ego and greed.

He believed he could make profit from pinball. He was going to do it better and faster than anyone in history, no one could convince him otherwise. And he wanted that money. He had more wives, Hawaiian condos, and cruises to fund.

**I am not a profiler, but I do play one on Facebook.**

#33361 5 months ago
Quoted from Beechwood:The reasoning behind this failed Ponzi scheme comes down to two things. Robert's ego and greed.
He believed he could make profit from pinball. He was going to do it better and faster than anyone in history, no one could convince him otherwise. And he wanted that money. He had more wives, Hawaiian condos, and cruises to fund.
**I am not a profiler, but I do play one on Facebook.**

those weird guys exist in other businesses, too. https://www.therpf.com/forums/threads/anovos-issues-anovos-only-discussion.212164/page-140 on a similar weird case, not sure where exactly in this long thread that thing started. Took way too long for a emergency brake pull

#33362 5 months ago

I'm not a laywer, but I did mock trial in HS in the late 1900s. The way I've read the main line "defense" so far is that some lawyer said it was OK, so RM isn't to blame. He was simply doing what his laywer said. Does that hold any water at all?

#33363 5 months ago

That someone was “ill-advised” by a lawyer or not, if they do something illegal they are responsible for their own actions. They might have a subsequent claim of malpractice against their attorney, but an attorney’s bad advice is not an excuse to committing a crime or performing some otherwise illegal act. It might be an argument to be made for mitigation of the charges or negotiating a plea deal, but it’s not going to excuse the behavior.

#33364 5 months ago

He is hanging his hat on lawyers saying he could pay old investors from the same accounts new investor money went into. That may be true, if there were also actual investment returns booked into those accounts. Money is fungible, accounting is not. You can’t treat new investor money as gains for previous investors, even if you commingle the money.

#33365 5 months ago

There's a lot in the recent filings that speaks to these elements.

One part of the SEC's in limine motion is asking the judge to not allow the introduction (by deposition or live testimony) of the advice of counsel defense. Mueller contends it should be allowed to demonstrate that he was acting in good faith. If he can establish that, SEC won't be able to persuade the jury Robert acted with scienter, which is needed to find that he committed fraud.

Yesterday, the judge issued an order that in part granted and in part denied the SEC's in limine motion. But since we don't currently know what was granted/denied, we don't know if Robert will be able to play that card or not (a reason it could be disallowed is if the judge has been persuaded that Robert didn't actually seek counsel regarding the legality of the illegal acts he has allegedly committed).

Note: The above is just my lay reading of the court documents. I've picked up a bit of legalese and understanding of court proceedings by following this case, but I'm by no means a lawyer or legal expert. So take my takes with the grain of salt you would if I thought buying a bunch of machines meant I was an expert on how to run a pinball company.

#33366 5 months ago
Quoted from trilogybeer:

Replace "crazy" with "an idiot" and your statement about Robert is more accurate.

Why not both?

#33367 5 months ago

I wonder if Nate is the whistle blower?

Doc113 references "P357" (Spradlin Memo to Mueller June 11, 2022 - why 2022?) and "P358" (Spradlin Resignation Letter July 9, 2020)

Doc134 states that on June 9, 2021 he gave "investigative testimony" to the SEC

SEC charges deeproot on August 20, 2021 (https://www.sec.gov/litigation/litreleases/lr-25179)

(nvm, dates don't line up)

#33368 5 months ago
Quoted from blueberryjohnson:

A former Mueller colleague wants the judge to quash a subpoena to have to appear in court to provide live testimony as an expert witness as proposed by Mueller. And if he has to, he wants the judge to make sure Robert compensates him appropriately for travel, expenses, and missing work. He'd be open to appearing via zoom, if necessary. But he'd prefer to forego that, too.
[quoted image]

Update: Quash has been mooted (legal terms are funny).

Spradlin can appear remotely via zoom.

#33369 5 months ago

Screenshot 2023-11-29 at 1.23.57?PM (resized).pngScreenshot 2023-11-29 at 1.23.57?PM (resized).png

Screenshot 2023-11-29 at 1.24.05?PM (resized).pngScreenshot 2023-11-29 at 1.24.05?PM (resized).png

Screenshot 2023-11-29 at 1.24.05?PM (resized).pngScreenshot 2023-11-29 at 1.24.05?PM (resized).png

#33370 5 months ago

Not sure if those are even documents. Pull a docket report for 29th november to see whats really there. CL gets updated with the data grabbed that way when you got the recap plugin

#33371 5 months ago
Quoted from Miguel351:

I wonder if Turner will be in attendance that day to listen to what his "expertise" is. Whatever level of expertise Turner thinks he has, Mueller had more of it, technically. Let that fact sink in when you think about Ninja Eclipse.

I dont think anyone is thinking about Ninja Eclipse at this point.

#33372 5 months ago
Quoted from Roostking:

I dont think anyone is thinking about Ninja Eclipse at this point.

I really wonder how many preorders they ended up with. It has to be less than 10. Less than 5 maybe even?

#33373 5 months ago
Quoted from masterX244:

Not sure if those are even documents. Pull a docket report for 29th november to see whats really there. CL gets updated with the data grabbed that way when you got the recap plugin

Screenshot 2023-11-30 at 12.51.11?PM (resized).pngScreenshot 2023-11-30 at 12.51.11?PM (resized).png
#33374 5 months ago

Doesn't look like anything is happening next week after all.

Previously:
pasted_image (resized).pngpasted_image (resized).png

Now:
pasted_image (resized).pngpasted_image (resized).png

There's also nothing on the calendar for the next 3 months: https://www.txwd.uscourts.gov/judges-information/judges-calendars/#/san-antonio/xavier-rodriguez/2023-12-01-to-2024-02-29/

My guess is that due to the trial expecting to take 10 days (according to the filings), it'll need to be scheduled for some time in the distant future.

#33375 5 months ago
Quoted from Haymaker:

I really wonder how many preorders they ended up with. It has to be less than 10. Less than 5 maybe even?

DFAFD36A-A1D0-4275-A501-82F74175C06A (resized).jpegDFAFD36A-A1D0-4275-A501-82F74175C06A (resized).jpeg
#33376 5 months ago

Transcript filed of Proceedings held on 11-28-23, Proceedings Transcribed: Pretrial. Court Reporter/Transcriber: Gigi Simcox, Telephone number: [email protected], 210-244-5037. Parties are notified of their duty to review the transcript to ensure compliance with the FRCP 5.2(a)/FRCrP 49.1(a). A copy may be purchased from the court reporter or viewed at the clerk's office public terminal. If redaction is necessary, a Notice of Redaction Request must be filed within 21 days. If no such Notice is filed, the transcript will be made available via PACER without redaction after 90 calendar days. The clerk will mail a copy of this notice to parties not electronically noticed Redaction Request due 12/26/2023, Redacted Transcript Deadline set for 1/4/2024, Release of Transcript Restriction set for 3/3/2024, (gs)

12
#33377 5 months ago

Interesting development in the bankruptcy case:

Largely on the basis of Mueller's attempts at an 'advice of counsel' defense in the SEC matter, the trustee files a complaint against those lawyers for legal malpractice.

The trustee claims the lawyers advising deeproot / policy services knew or should have known that Mueller was setting up a ponzi scheme from the start.

deeprootcapital-313-2023.12.08.pdfdeeprootcapital-313-2023.12.08.pdf
#33378 5 months ago
Quoted from blueberryjohnson:

Interesting development in the bankruptcy case:
Largely on the basis of Mueller's attempts at an 'advice of counsel' defense in the SEC matter, the trustee files a complaint against those lawyers for legal malpractice.
The trustee claims the lawyers advising deeproot / policy services knew or should have known that Mueller was setting up a ponzi scheme from the start.
[quoted image]

Furnishing legal advice to financial outfits is a risky undertaking. Legal malpractice insurance carriers charge high premiums to law firms which provide these services.

#33379 5 months ago
Quoted from ZNET:

Furnishing legal advice to financial outfits is a risky undertaking. Legal malpractice insurance carriers charge high premiums to law firms which provide these services.

Someone warn @benheck! /s

11
#33380 5 months ago
Quoted from LeonSpinkx:

Someone warn benheck! /s

Maybe I can bundle it with home and auto.

#33381 5 months ago

Well, the BK attorney's argument is pretty solid. But Robert has to prove to a jury that he had no clue what he was doing was wrong, and I think based on reading the docs, he knew exactly what he was doing but is relying on the 'my lawyer did it' defense. Also it's going to come out in court that he's a lawyer, so it doesn't help his cause.

3 weeks later
#33382 4 months ago

Nothing new to report.. nothing on the docket or on the court calendar.

I did reach out the court reporter via email in the docket and she said that the transcript would run around $77.

I might go down to the court house to view it in person since I think that's free. Otherwise we'll have to wait until march to get the transcript via PACER to find out wtf is going on.

#33383 4 months ago

Just wanted to say that I check this thread regularly, looking forward to the day this fat shyster is thrown in jail.

Thank for the updates!

#33384 4 months ago

It's really weird that the SEC case just disappeared. It doesn't even show as assigned to that judge anymore.

#33385 4 months ago

that is weird

#33386 4 months ago

Plea deal?

#33387 4 months ago

I thought that ship sailed with the failed mediation and advancement to trial.

Perhaps if inside goes to the court house can get us some helpful updates

34
#33388 4 months ago

Okies, your local court reporter checking in. Below is a summary of my understanding what's happening with some commentary. It may not be exact (or may even be grossly incorrect) since I'm going off my recollection and I'm not a lawyer and don't really understand all the technical terms.

When is the trial?
Trial has not been scheduled. This is due to the proposed 10-day length of trial. The judge and the lawyers all have other trials that they're working around so everything needs to be shifted around to squeeze in SEC vs. deeproot. Someone also noted that nobody wants to do jury duty so it's hard to even sit a panel of jurors (6+2).

Unclear when the trial date will be.

Does Robert have any money?
Does not appear to be so.

Who is paying for the lawyers?
Family and friends of Robert who "don't like the SEC" (approximate quote).

What was considered in november?
10 motions. Each motion was briefly debated by the prosecution/defense/judge.

128.1. Defense's motion to exclude details expenses/compensation (like Disney trips) because it may introduce unfair prejudice (filing 128)
Denied

The following motions are all introduced in filing 130:

130.1. SEC's motion to exclude viability of deeproot businesses.
Partial allow/deny.
SEC argued that it's not relevant if deeproot pinball was ever going to be viable. Can mention that other businesses existed, cannot go into deep detail (probably because those businesses should've never had the money to begin with).

130.2 SEC's motion to exclude consequences of investigation
Granted
Can't blame the SEC for going under, just that the businesses failed/went bankrupt at some point.

130.3 & 4 SEC's motion to exclude reliance of counsel/accountants
Partially granted

Doesn't look like accountants can be brought in (since they don't know the legal basis), but they can discuss what was discussed with Robert's
lawyer and how much the lawyer really understood what Robert was doing and what he blessed.

130.5 SEC's motion to exclude undisclosed opinion testimony
Granted.

Robert was going to call Deeproot Pinball's COO to testify about how deeproot pinball was an actual business. Due to the ruling on the motion of viability of businesses - it doesn't make any sense to call the DR pinball COO since the viability of the business cannot be brought up anyway.

Robert was also trying to sign on as an expert witness on investment/financial advice, but this is also denied because apparently you're supposed to provide all of your "expert opinions" ahead of time so that the other side will know what you're going to say and can counter it. Robert's team did not provide a list of this.

130.6 SEC's motion on excluding character witnesses
Will be decided later.

Basically this trial is about "scienter" - that is, "the defendant's knowledge that an act or conduct is wrongful and intent to act despite this knowledge." Since the SEC is attacking Robert's character, in some situations character witnesses can be brought in to say "nah, this guy was a good guy." Robert wants to bring in family members and former employees to vouch for him. There are some recent circuit court rulings around what is permissible/not so everyone will review and get back to this.

130.7 SEC's "Motion To Exclude Characteristics of the SEC or the SEC Staff" and 130.8 "Motion To Exclude Evidence Concerning SEC Investigative
Techniques"

Granted without much discussion.

Basically the trial is to focus on the facts and now how the facts came to be discovered. From the SEC's filing: "The Court should preclude Mueller from referring to the actions and conduct of the SEC and its staff during the course of its investigation, its internal deliberations, and the views of individual Commissioners"

130.9 SEC's Motion To Admit Scott Allen Resignation Memorandum
Side stepped.

Scott Allen is going to be deposed anyway so they can just ask him directly instead of admitting the letter into evidence. There are issues around hearsay because the letter mentions that the whole operation is Ponzi-like.

130.10 SEC's "Motion Impeach Mueller with His Prior Invocation of the Fifth Amendment Privilege if Necessary"
Denied in part.

This one is hard to understand. Basically you have a right to invoke the 5th, but the pattern of when you invoke the 5th can be used against you to establish guilt. That is - if you're cooperating during questioning and then suddenly start invoking the 5th, your silence can be used against you (Thanks SCOTUS!). So during initial deposition Robert invoked the 5th, then later recanted saying that he's taking back having invoked the 5th (as I understand it). The SEC's argument is this:

"If Mueller believed that there was nothing wrong with using company money to pay for his expenses, such as a condo in Hawaii, jewelry, cruise vacations, etc., there was no reason for him to have previously asserted his Fifth Amendment right against self-incrimination and refuse to answer those questions when he was, at the same time, willing to answer other questions about his businesses and actions"

The court is now ruling that the SEC can't bring up that Robert previously invoked the 5th amendment, but only that he previously "refused to answer."

I don't really understand the above ruling - it's probably because deposition is not the same thing as a trial?

Other amusing bits

Both parties have to share their powerpoints ahead of time. Oh and everyone has to bring paper backups as well.

#33389 4 months ago

Tip of the hat to TreyBo69.

http://sndup.net/jmrq

#33390 4 months ago

Sounds like most of Robert's defense is moot.

#33391 4 months ago

"witnesses can be brought in to say "nah, this guy was a good guy." Robert wants to bring in family members and former employees to vouch for him"

Jpop will vouch for me!

#33392 4 months ago
Quoted from toyotaboy:

"witnesses can be brought in to say "nah, this guy was a good guy." Robert wants to bring in family members and former employees to vouch for him"
Jpop will vouch for me!

Heh you laugh, but Robert has his mom, dad, Steve Bowden and Quinn Johnson (amongst others) on the potential witness list.

#33393 4 months ago
Quoted from toyotaboy:

"witnesses can be brought in to say "nah, this guy was a good guy." Robert wants to bring in family members and former employees to vouch for him"
Jpop will vouch for me!

What about the SEC's motion to strictly limit the number of mail-order former bride character witnesses to three maximum?

#33394 4 months ago
Quoted from Inside:

Heh you laugh, but Robert has his mom, dad, Steve Bowden and Quinn Johnson (amongst others) on the potential witness list.

Well I mean he still lives in Austin so I wouldn't be surprised if he ends up on the list.
https://pinside.com/pinball/forum/topic/jpop-update-thread%e2%80%a6%e2%80%a6%e2%80%a6%e2%80%a6%e2%80%a6mg-raza-and-aiw%e2%80%a6/page/490#post-7934197

#33395 4 months ago
Quoted from Inside:

Okies, your local court reporter checking in. Below is a summary of my understanding what's happening with some commentary. It may not be exact (or may even be grossly incorrect) since I'm going off my recollection and I'm not a lawyer and don't really understand all the technical terms.
When is the trial?
Trial has not been scheduled. This is due to the proposed 10-day length of trial. The judge and the lawyers all have other trials that they're working around so everything needs to be shifted around to squeeze in SEC vs. deeproot. Someone also noted that nobody wants to do jury duty so it's hard to even sit a panel of jurors (6+2).
Unclear when the trial date will be.
Does Robert have any money?
Does not appear to be so.
Who is paying for the lawyers?
Family and friends of Robert who "don't like the SEC" (approximate quote).
What was considered in november?
10 motions. Each motion was briefly debated by the prosecution/defense/judge.
128.1. Defense's motion to exclude details expenses/compensation (like Disney trips) because it may introduce unfair prejudice (filing 128)
Denied
The following motions are all introduced in filing 130:
130.1. SEC's motion to exclude viability of deeproot businesses.
Partial allow/deny.
SEC argued that it's not relevant if deeproot pinball was ever going to be viable. Can mention that other businesses existed, cannot go into deep detail (probably because those businesses should've never had the money to begin with).
130.2 SEC's motion to exclude consequences of investigation
Granted
Can't blame the SEC for going under, just that the businesses failed/went bankrupt at some point.
130.3 & 4 SEC's motion to exclude reliance of counsel/accountants
Partially granted
Doesn't look like accountants can be brought in (since they don't know the legal basis), but they can discuss what was discussed with Robert's
lawyer and how much the lawyer really understood what Robert was doing and what he blessed.
130.5 SEC's motion to exclude undisclosed opinion testimony
Granted.
Robert was going to call Deeproot Pinball's COO to testify about how deeproot pinball was an actual business. Due to the ruling on the motion of viability of businesses - it doesn't make any sense to call the DR pinball COO since the viability of the business cannot be brought up anyway.
Robert was also trying to sign on as an expert witness on investment/financial advice, but this is also denied because apparently you're supposed to provide all of your "expert opinions" ahead of time so that the other side will know what you're going to say and can counter it. Robert's team did not provide a list of this.
130.6 SEC's motion on excluding character witnesses
Will be decided later.
Basically this trial is about "scienter" - that is, "the defendant's knowledge that an act or conduct is wrongful and intent to act despite this knowledge." Since the SEC is attacking Robert's character, in some situations character witnesses can be brought in to say "nah, this guy was a good guy." Robert wants to bring in family members and former employees to vouch for him. There are some recent circuit court rulings around what is permissible/not so everyone will review and get back to this.
130.7 SEC's "Motion To Exclude Characteristics of the SEC or the SEC Staff" and 130.8 "Motion To Exclude Evidence Concerning SEC Investigative
Techniques"
Granted without much discussion.
Basically the trial is to focus on the facts and now how the facts came to be discovered. From the SEC's filing: "The Court should preclude Mueller from referring to the actions and conduct of the SEC and its staff during the course of its investigation, its internal deliberations, and the views of individual Commissioners"
130.9 SEC's Motion To Admit Scott Allen Resignation Memorandum
Side stepped.
Scott Allen is going to be deposed anyway so they can just ask him directly instead of admitting the letter into evidence. There are issues around hearsay because the letter mentions that the whole operation is Ponzi-like.
130.10 SEC's "Motion Impeach Mueller with His Prior Invocation of the Fifth Amendment Privilege if Necessary"
Denied in part.
This one is hard to understand. Basically you have a right to invoke the 5th, but the pattern of when you invoke the 5th can be used against you to establish guilt. That is - if you're cooperating during questioning and then suddenly start invoking the 5th, your silence can be used against you (Thanks SCOTUS!). So during initial deposition Robert invoked the 5th, then later recanted saying that he's taking back having invoked the 5th (as I understand it). The SEC's argument is this:
"If Mueller believed that there was nothing wrong with using company money to pay for his expenses, such as a condo in Hawaii, jewelry, cruise vacations, etc., there was no reason for him to have previously asserted his Fifth Amendment right against self-incrimination and refuse to answer those questions when he was, at the same time, willing to answer other questions about his businesses and actions"
The court is now ruling that the SEC can't bring up that Robert previously invoked the 5th amendment, but only that he previously "refused to answer."
I don't really understand the above ruling - it's probably because deposition is not the same thing as a trial?
Other amusing bits
Both parties have to share their powerpoints ahead of time. Oh and everyone has to bring paper backups as well.

Thanks for the intrepid reporting!

Were you able to get the transcript you wanted (and was your summary a summary of that?)? Any timelines we should keep in mind for when next steps will be stepped or at least stuff will start showing up on pacer again?

#33396 4 months ago
Quoted from blueberryjohnson:

Thanks for the intrepid reporting!
Were you able to get the transcript you wanted (and was your summary a summary of that?)? Any timelines we should keep in mind for when next steps will be stepped or at least stuff will start showing up on pacer again?

I went to the public terminal at the courthouse and took notes. Wasn’t about to pay for the transcript

I’m guessing there’ll be another scheduling order that’ll pop up on pacer and then the actual scheduling will happen after that.

At this point the only real thing left is jury selection and then the trial.

#33397 4 months ago
Quoted from Inside:

Okies, your local court reporter checking in. Below is a summary of my understanding what's happening with some commentary.

That’s a heck of an update. Thank you for your effort.

#33399 4 months ago
Quoted from Seraph:

Correction: San Antonio.

They must be putting something in the water there.

#33400 4 months ago

Bankruptcy proceedings proceed on

deeprootcapital-317-2024.01.10.pdfdeeprootcapital-317-2024.01.10.pdf
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