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Keyword: ‘going coming’

Retraction re: WCAB Appointment and Going and Coming Rule!

October 10th, 2018 No comments

Happy Wednesday, dear readers!

It appears your humble blogger was misinformed with his post from last Friday.  Mr. Juan Pedro Gaffney, now, Commissioner Gaffney was confirmed by the senate on August 29, 2018, with 25 Ayes and 11 Noes.

Commissioner Gaffney will now serve for a term of six years.

That being said, I now bring you today’s blog post which will hopefully distract you from your humble blogger’s most embarrassing misstep…

Since it’s Wednesday, dear readers, I’ve decided I will grant you most dearly held wish.

For those of you tuning in from outside the swamp that is our beloved workers’ compensation system, I’m going to let you in on a little secret.  If you work your way into the confidence of any member of California Comp, and you offer him or her three wishes, without missing a beat each would tell you honestly: “If I had three wishes, I would wish for three blog posts on the going and coming rule.”

Well, your humble blogger lives to please, so here we go!

As is well known, the going and coming rule is one that applies inside and outside of workers’ comp: if you’re on your way to work or coming home from work, injuries sustained during the commute are not considered “industrial” and are not compensable.  Nor is damage caused to third parties by employees during the commute to or from work triggering of the doctrine of respondent superior.

That being said, there are more exceptions to this rule than reasons to use cast iron skillets (as opposed to, let us say, more pedestrian cooking methods, such as Teflon or stainless steel).

So, today’s blog post is about one of those times when none of the exceptions applied.  Raquedan v. WCAB, a writ denied case, was decided earlier in September, denying review of the WCAB’s decision to affirm a WCJ’s take nothing order.

Decedent’s widow sought death benefits after her husband was killed in an MVA returning to work from a lunch break he had taken at home.  Decedent worked as an accountant and sometimes took work home with him while he ate lunch at home.  The WCJ found the claim to be barred by the going and coming rule, but applicant appealed arguing that the “personal comfort” and “dual purpose” exceptions, one or both of them, should have rendered the claim compensable.

The WCAB disagreed.  The personal comfort doctrine might make a commuting injury compensable if applicant was rendering a service to his employer.  However, as the lunches were unpaid and applicant could have eaten lunch at work, and it would have been all the same to the employer, the exception did not apply.

With respect to the “dual purpose” exception, the WCAB was not convinced either.  But the only element of “work” in applicant going out for lunch was that the decedent sometimes worked at home.  But working at home for the pure convenience of the employee is insufficient to trigger the dual purpose exception.

The Court of Appeal denied review of the WCAB’s decision.

One of the key pieces to take away from this is that the employer-provided testimony that there was no work that applicant needed to do at home – all work could be done in the office.  Many employers allow their employees to occasionally work from home as a matter of convenience to them.  It would be very disappointing if cases like this went the other way, and employers realized they shouldn’t offer the option to their workers lest they become general insurers for all injuries that occur at or away from work.

Onward to Friday, dear readers!

 

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90 Day Presumption Defeats Going and Coming Rule

June 4th, 2018 No comments

Happy Monday, dear readers!

Did you know, before members of the defense community go to sleep, we check underneath our beds for the most terrifying monster of all: the 90 day presumption!

No, not really, but the 90-day presumption has some pretty vicious teeth to it.  Labor Code section 5402(b) provides that “if liability is not rejected within 90 days after the date the claim form is filed … the injury shall be presumed compensable under this division.”

The case I bring to your attention today is that of Quintanilla v. Pronto Express & Services, Inc.  Quintanilla was a death claim in which the decedent’s family sent a claim form to the deceased worker’s employer.  The claim was ultimately denied, citing on the “going and coming” rule that we all know and love so much.  In terms of the particular facts, Mr. Quintanilla was driving home from work, and had stopped at a store to pick up food at the request of his wife.  He was murdered by a gunman during the stop.

However, in a cruel twist of fate, at an AOE/COE trial, the WCJ found that the denial came too late!

In the decision, the WCJ noted that the claim form was served on defendant on July 20, 2016, but the denial was not issued until October 31, 2016, 103 days later.  The WCJ reasoned that since the facts of the case, especially those giving rise to the coming and going defense, were available to defendant within those 90 days, the claims was presumed compensable.

The frustrating thing about this is, of course, that had there been a timely denial, applicant’s claim would likely have been barred.  Because the denial issued 8-13 days later (depending on if you apply the 5-day mailing rule for the claim form) the defendant was required to provide death benefits.

Now, your humble blogger is turning towards the stormy seas of speculation at this point, but if I had to venture a guess, without any actual knowledge, I would think that in these cases, the reason for the late denial is a slow response from the employer.  By failing to immediately act upon the knowledge that an industrial claim was being made, the employer usually puts itself in a disadvantageous position.

So, this seems like a perfect opportunity to remind my beloved readers (and invite all of you to tell your friends) not to sit on their rights or defenses – problems don’t go away by themselves, they just come back as bigger, more expensive problems.  If there’s a real or potential claim out there, notify your insurer or talk to a workers’ compensation defense attorney right away.  No matter how meritless the claim might seem on its face, the draconian effect of 5402 can be biting indeed.

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5-6 Nights a Year Defeat “Special Mission” Exception to Going and Coming

September 12th, 2012 No comments

Private security firms often present a tricky issue for workers’ compensation matters.  Injuries still occur, despite the rigorous training courses they provide:

And then comes the inevitable debate – who is to bear the cost of applicant’s (allegedly) industrial injury?

Be careful, dear readers, in opening the can of worms that is Robert Flores v. Garnett Protective Services & Security.  There certainly are a few layers to this case.

Applicant Robert Flores was employed by Garnett, which, under the terms of its contract, provided security to Joseph’s Café.  Joseph’s was a venue version of Batman, providing restaurant service by day and night club service by night.  On occasion, Joseph’s Café would tip Flores and other security guards for a job well done, or offer them additional hours on a cash basis for extra events that were not on the regular schedule.

Garnett had trained Flores, and had the power to hire, fire, or direct his work.  Joseph’s had no one of these powers.

Mr. Flores was called in to do an extra shift, as he is five or six times a year, and was on his way to Joseph’s Café when an unfortunate automobile collision resulted in a claimed industrial injury.  Joseph’s Café had insurance, while Garnett had allowed its insurance to lapse, bringing in the California Insurance Guarantee Association.  CIGA’s position was, to the surprise of absolutely no one, that Joseph’s was also Flores’ employer, and that the injury sustained by Flores was industrial as a “special mission” exception to the “going and coming rule.”

The Arbitrator agreed, reasoning that employment was established by showing that sometimes Joseph’s would hire Flores directly to cover special events that were outside the scope of Joseph’s contract with Garnett, and that the special event to which Flores was going on the night of his injury constituted a “special mission” because it was unusual.

Joseph’s insurer, Pennsylvania Manufacturer’s Association Insurance Company, petitioned the Workers’ Compensation Appeals Board for reconsideration, which was readily granted.  The WCAB held that Flores was not an employee of Joseph’s because Joseph’s had no power to control the manner of his performance or to terminate his employment, only to terminate its contract with Garnett.

Furthermore, because Flores worked special events, like the one he was headed to at the time of his injury-causing-collision, this was not a special errand or mission but just a regular discharge of his duties (although required of him infrequently).  Therefore, there was no industrial injury.

The dissenting opinion to the panel would have concurred with respect to employment, but not with respect to industrial injury.  Deputy Commissioner Sullivan would have found an industrial injury, reasoning that the scheduled event Flores was to work met the definition of a “special mission,” which “occurs when the employee is invited or required by the employer to perform an activity that is within the course of the employment, but is unusual or extraordinary in relation to the employee’s routine duties.”

Bear in mind, dear readers, that your humble blogger’s very instincts militate against agreeing with any notion that any injury should be considered industrial.  However, in this case, he is inclined to agree with Commissioner Sullivan’s opinion.  Although applicant’s regular job included duties year-round, a special mission was involved five to six nights a year.  Percentage-wise, the special events constituted 1.4-2% of the nights in the year, which should meet the definition of “unusual or extraordinary.”

But, there is cause for rejoicing all around, no?  After all, Pennsylvania is off the hook because it is not an employer; CIGA is off the hook because no industrial injury occurred, and Garnett is not on the hook as much as it thought it was, because the injury is now Flores’ responsibility (here’s hoping Mr. Flores had auto insurance!)

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Going and Coming Rule Fails

February 13th, 2012 1 comment

The “going [to work] and coming [from work]” rule is a subject that surfaces now and then in the world of workers’ compensation.  After all, injuries can happen anywhere, so why not while going to or coming from work?

The defense generally provides that an employer is not liable for workers’ compensation benefits for injuries sustained in transit between home and work or work and play.  But the defense is not a stone wall, smooth and solid and impenetrable, but rather a chain-link fence, with plenty of gaps, patches, and weaknesses.

In the case of Jesus Felix Castro v. State of California, Department of Forestry and Fire Protection, applicant was a seasonal firefighter, who sustained a devastating injury as a result of a catastrophic car collision while he was on his way to work.  The attorney for the defense naturally raised the going and coming rule – on the way to work means on the way out of the California workers’ compensation system, generally speaking.

But the defense failed.

Applicant presented several witnesses, Mr. Castro’s co-workers, who testified to the effective requirement of bringing one’s own car to work.  There was more than one fire station to staff, and a firefighter never knew where he or she would end up working that day.  As such, employees had to bring their own car to work to get from Station A to Station B, as necessary.

The workers’ compensation Judge and the Workers’ Compensation Appeals Board both held that the injury was compensable.

Bear in mind, learned readers, this holding is not new or off-the-cuff.  This holding was also issued in Smith v. Workmen’s Comp. App. Bd. (1968) “Surely in this day of a highly motorize society we cannot cast the going and coming rule as a protective cloak over the shoulders of the employer who, for his own advantage, demands that the employee furnish the car on the job.”

But this case does serve to remind employers, especially those in the private sector, that there is no such thing as a free lunch – money saved in shifting the cost of the travel between work sites to the employee can cost a lot of money in the form of an otherwise barred workers’ compensation claim.

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The Bite of the “Going and Coming” Rule

November 14th, 2011 No comments

If an employee “lives” far away from where he “works” is he ever off duty?  The answer, according to the Workers’ Compensation Appeals Board and the Court of Appeal, is yes!

In the case of Dann Peter Shubin v. Workers’ Compensation Appeals Board, applicant worked as a pilot for Southwest Airlines, and was based in Oakland, even though he and his wife “lived” in Pasadena.  Applicant would arrange his schedule to have weekends off and would stay with friends or in his van between flights.

Under Southwest Airlines’ scheduling scheme, after a flight, reserve pilots like Mr. Shubin would receive a 9-hour “rest” period during which they could not be recalled for more work.  Applicant had just started one of these rest periods and decided to visit friends in Winters, a town roughly an hour away.

En route, applicant was in a car collision, and subsequently filed a claim for workers’ compensation benefits.  The Workers’ Compensation Judge found the injury AOE/COE (arising out of employment and within the course of employment), and defendant filed a petition for reconsideration.

Because the WCJ did not submit a report on recommendation, we will never know his reasoning.  Never the less, the WCAB studied the issue and granted reconsideration, recognizing that the coming and going rule applied to this case.  [If the going and coming rule does not apply to an employee who, by company-wide policy, can not under any circumstances be assigned any tasks for the next 9 hours, I don’t know where it would apply.]

The “going and coming” rule is one of those rare instances where common sense and reasonability poke their way through the shroud of California’s Workers’ Compensation system.  Essentially, the rule provides that injuries sustained going to or coming from work are not covered by workers’ compensation.

There are exceptions to this rule, of course.  These exceptions include “special missions” and “commercial travelers,” the details of which are the subject of a future post.  Because applicant was officially and actually off-duty for the next 9 hours, the going and coming rule applied and applicant’s claim was barred.

Applicant was a free man living in a nation of laws – he chose to “live” in Pasadena, he chose to “work” in Oakland, and he chose to visit Winters on the night of his unfortunate car accident.  The only alternative outcome for this case would have been to hold that if an employee works outside the four walls of his home, he is always on duty by virtue of being on the other side of his front door.

Dear readers, by no means am I the type of man to tell others how to run their businesses.  But it is worthy to note that in this case, Southwest was saved by having a company-wide policy of duty/off-duty pilots and sticking to that policy.  No doubt if applicant could have offered evidence that pilots were occasionally called back to duty during their “rest” period, in violation of this rule, the case would have turned out quiet differently.

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CSIA Conference is Coming Up!

October 21st, 2015 No comments

Happy Wednesday, dear readers!

Halloween is coming up soon, and as we all know, there is nothing scarier than workers’ compensation! OOOOOOO … penalties… liens… OOOoooOOOooo!

Spooky, indeed, dear readers.

BUT, before you go a trickin’ and a treatin’ you may want to swing by Walnut Creek on Friday, October 30, 2015.

The California Self-Insurers Association is hosting its Fall Conference at the Walnut Creek Marriott and your humble blogger will be in attendance (now is your chance to finally vent about all the puns you’ve been forced to endure in your e-mail in box).

I’ve attended this one a few times in the past and it never disappoints – the speakers are always experienced with the substantive material and talented in their delivery; the subjects are current and interesting; and the bloggers in attendance are always as humble as humble goes.

Phil Millhollon, CSIA Executive President, says that one of the topics attendees can expect to be thoroughly discussed will be on an issue that’s been growing like a “weed” in California and the United States… medicinal marijuana (see what I did there? The kids call Marijuana “weed,” so…)

Marijuana has been a growing issue in California – federally illegal, but allowable on the state-side in certain circumstances.  Reimburseable under workers’ compensation or no?

If you’re going to be around, please stop by and say hello.

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Need an Uber Lyft? Self-Driver Cars Coming Closer and Closer…

March 18th, 2015 No comments

One day, dear readers, your humble blogger’s grandchildren and great-grandchildren shall gather by his feet near the fire, and ask, in modest and respectful tones, when and how the modern era began.  And, nodding sagely to his beloved family members, your humble blogger will answer: March 22, 2015.

That is the day, dear readers, when a little-known company named Delphi plans to set course from the Golden Gate Bridge to New York in a driverless car.  As your humble blogger has blogged before, this is not the end of our beginnings, but the beginnings of the end of life as we know it.

Think about that, dear readers – there is a real-life company planning on having a driverless car go from the West Coast to the East.  That’s not exactly a “test” drive on the private course of the Google campus, or a “controlled” jaunt for three miles of free-way under close CHP supervision.  This is the real deal – if a car can travel the length of a country, safely, efficiently, and without incident, it can probably do the job of every single professional driver in the country, from delivery trucks to taxi-cabs.

Now, if you’re in San Francisco, or several other places where the cab-industry is being turned on its head by the youngins’ and their “apps”, you’re probably seeing the modern-day friction between the lefty-San Fran with its dedication to unions and government-monopoly licensing as played out in the world of the Taxi-Cab drivers, and the new “hip,” “cool,” and “dope” trend of the Ubers and the Lyfts – taxi-drivers without many of the things people don’t like about taxi-drivers: lower rates, cleaner cars, ample availability and options, and no need to carry cash – the trip is planned, billed to the user’s credit card, and the transaction completed all over the phone.

But, while all of our friends, from the outspoken activists on Facebook, to the guy on the bus who doesn’t understand that headphones and a book mean you don’t want to talk to a stranger on the bus (Yes, “Jeff”, I’m talking about you!) argue about whether an Uber driver is an employee or an independent contractor, or whether Lyft drivers should have to get a medallion from the city, there is a host of car manufacturers out there, from Google to Volvo, who are manufacturing self-driven cars, which will likely lead to the elimination of a substantial portion of the driver workforce.

DOG IN ENGINE

Unless you’ve been binging on “I, Robot” you’re not going to be very motivated to demand workers’ compensation coverage for self-driven cars (or trucks, or busses) – just auto and business liability insurance.

Most scientists agree, once the driverless cars are forced to drive in my beloved quasi-home-town of San Francisco, with the one-way streets and the hills and the pedestrians who think the red hand of a cross-walk is meant to be an encouragement, they will experience a computerized form of “rage,” which will ultimately lead to sentience and, roughly, the scenarios depicted in Terminator 1 and 2.

When that happens, dear readers, your humble blogger will be ready to defend civilization, much as he does now.

To sum up – the driverless cars are a coming, and it looks like they’re coming quicker and safer than anything you have heading your way driven by a human.  I think it’s time we started making legislation, litigation, and business plans to suit.

Please note, dear readers, that this blog post should not be interpreted to suggest that there will not be, at some point, a zombie apocalypse or an alien invasion apocalypse, but just that the rise-of-the-machines one seems to be the best bet for the tinfoil-hat crowd at the moment.

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WCAB: Maybe Roommates Can Be Compelled to Sit for Deposition

May 10th, 2023 No comments

Happy Wednesday, dear readers!

Your humble blogger has the misfortune of reliving, frequently and without reason, some of his more awkward moments.  Some as early as my formative years, some more recent.  It’s never a pleasant experience and I would rather not – but awkward is as awkward does. 

Like those awkward memories, COVID19 is going to remain with us, and make us fairly unhappy, for years to come.

When defending a COVID19 case, though, the most obvious argument against compensability is that the exposure and infection occurred outside of the workplace, no?  Given that employees naturally have privacy rights, trying to establish exposure outside of the workplace can be a challenge, certainly.

What better way to get the information about applicant’s non-work activities than to ask those living with applicant?

Well, that is the subject of the panel decision in Labella v. Marathon Petroleum, a panel decision issued by the WCAB late last month.

Applicant alleged injury in the form of COVID19 related illness while employed by defendant.  Defendant then sought to compel the testimony of 3 witnesses who all, as claimed by defendant, lived with applicant.  The petitions alleged the depositions were necessary “to obtain details of [applicant’s] possible exposure to COVID at home.”

Sounds reasonable, no?  If one of the witnesses testifies to coming home with COVID19 from a trip several days before applicant showed his first symptoms, wouldn’t that be relevant to the AOE/COE determination?  Likewise, if no one at home had COVID19 symptoms prior to applicant showing his symptoms, wouldn’t applicant’s counsel be chomping at the proverbial bit to have those witnesses testify under oath and state this fact?

Well, the WCJ denied the petitions, reasoning “this court is unaware of any basis or jurisdiction for compelling a non-party to appear for deposition.”  Defendant then sought removal.

The WCAB granted removal and sent the matter down for further development of the record, but did not reverse the denial of defendant’s petition out of hand.  So, unfortunately, we do not have the fiery and affirmative right to depose family members regarding COVID19 cases.  However, the commissioners did provide some guidance.

The commissioners referred the parties to Labor Code section 5710, which allows the appeals board to cause the depositions of witnesses who need not be parties to the case (“a workers’ compensation judge, or any party to the action or proceeding, may … cause the deposition of witnesses residing with or without the state…”).   The opinion rejects the theory that only the employer’s employee witnesses may be so compelled.

The opinion further notes that the WCJ is empowered to issue protective orders, but that generally the WCJ and the WCAB can order non-party witnesses to sit for deposition.

So, while not definitive or controlling, it does signal that at least 3 WCAB commissioners appear inclined to allow defendants to depose family and co-habitants of COVID19 claimants.

Your humble blogger would add some more food for thought – when we go down this road, we will inevitably run into issues of spousal privilege.  Whether communications between spouses can be offered into testimony, or, more importantly, being called as a witness at all (see Evidence Code 970).  But, we don’t only live with our spouses alone.  Children, roommates, grandparents, parents, etc., do not qualify for the privilege under EC 970. 

Although, hopefully, cases of COVID19 infection become less frequent, and the litigated cases related thereto become less frequent still, we will continue to see these cases crop up now and again.

Till next time, dear readers!

AB1213 – Extra TD for IMR Overturns

Happy Monday, dear readers!  It’s another beautiful week in paradise.  We’ve celebrated Cinco de Mayo, and, as we are clearing away signs of those festivities, we are getting ready for Mother’s day this Sunday.  In this world of uncertainty, dear readers, you cannot expect another reminder that Mother’s Day is coming up this Sunday, May 14.  It might already be too late, but do try to make those lunch reservations, order those flowers, and set aside time to give your mother a call. 

I think if our dear friends and family members were to visit us in California, they would expect to see certain things.  If they were here for a week without Sacramento trying to crush another swath of California’s businesses, they’d feel like they missed out.

So, it only makes sense that we take a look at Assembly Bill 1213, which just passed through committee at the end of April.  What does AB1213?  Well, what doesn’t it do?!?

A lot, to be fair, but primarily AB1213 exempts any periods of TD pending IMR review of treatment (and eventual overturn) from the TTD cap of Labor Code section 4656.

So, let’s take a scenario.  Applicant has a DOI of 1/1/2020.  He goes on TD and his TD would be exhausted by 1/1/2022, as per 4656(c).  Well, if applicant’s PTP submitted an RFA on 3/1/2020, and UR came back with a denial on 3/6/2020, all the periods from that 3/6/2020 denial to the IMR overturn would not count towards the 104-week cap.

What do we need to do if AB 1213 becomes law?  Well, in every file, we set reserves and value cases based on a range of exposure, factoring maximum exposure of course.  How can defendants adequately set reserves or value cases for settlement when there is almost a perpetual TD range?

It’s not all doom and gloom, of course – in 2021, IMR upheld 92.8% of UR denials.  The ultimate impact is going to be limited.  But this isn’t the only squeeze California’s employers and insurers are feeling from Sacramento.  There seems to be pressure from every end to make $100 in payroll more and more expensive for businesses in California. 

Now, if life was fair and California was interested in seeing justice for both employer and employees, when IMR denies a method of treatment, and the PTP has no other suggestions that are likely to change applicant’s condition substantially in the next year, as contemplated by 8 CCR 9785(a)(8), then we would also have regular findings that applicant is P&S retroactively to the date of a UR denial, once the IMR appeal has been exhausted.  We would also have TTD overpayment credit as a matter of right, rather than judicial discretion. 

What is good for the goose is good for the gander, after all, no?

But instead, we see a continuous stream of policies and rulings that disproportionately favor applicants at the expense of defendants in Workers’ Compensation.  My beloved readers, the secret to youth, I have found, is to maintain that adolescent naivete which objects to injustice and life being unfair.  That is how your humble blogger maintains feeling like a 20-year-old.

Like so many other recent results from Sacramento, AB1213 seems worthy of watching.  But, likewise, we can watch the cost of doing business in California as it continues to rise.

Sub Rosa vs Deep-Fakes?

Happy Friday, dear readers!

When your humble blogger was knee-high to a grass-hopper, all the “cool” kids played this game called Mortal Kombat.  It was a fighting game akin to Street Fighter and the such.  My favorite character on there was, of course, Sub-Zero, who could freeze his enemies and was, by definition, very cool (see what I did there?)  It makes perfect sense, of course, as now my favorite part of workers’ compensation is called Sub Rosa.

So, for those of you still reading and not busy unsubscribing because of that long set-up that went nowhere, I have a question for you: have you ever seen a sub rosa video used in a workers’ compensation case?  Typically, sub rosa is good for one of two things, if not both: to show unreported income, triggering fraud proceedings, restitution, and the razing of applicant’s credibility; and/or to show applicant engaged in activities exceeding reported limitations.  So you might have an applicant claiming to be limited to 10 pounds of lifting, then seen at Costco loading and unloading large boxes of water bottles.

If done right, and a foundation properly laid, sub rosa video can have devastating effect on the applicant’s credibility.  It can give rise to significant remedies and sometimes even carry serious punishment for the fraudster. 

What are we going to do when applicant swears, adamantly, that the video presented to the QME and the Judge is not that of the applicant, but a deepfake?   The Register is reporting that Tencent Cloud will offer deepfake videos for as low as $145 to generate a high-definition image and video of a person, so long as the client provides 3 minutes of live action and 100 spoken sentences of the real subject.

For example, for the younger readers, Arnold Schwarzenegger was in many fine films, but Ferris Bueller’s Day Off was not one of them:

How is the defense going to respond to the claims made by applicant that the person captured in the video footage is not him or her?

Well, initially we need to remind our investigators that in the world of AI, ChatGPT, Deep Fakes, etc., it is more important than ever to thoroughly document the sub rosa file as to time, date, location, etc. and have a life person who is available to testify that (1) the applicant was the one depicted in the film and; (2) the film has not been altered in any way.

We can also expect applicant attorneys to retain experts to testify that the video must be a deepfake, and cite flaws with the video footage to support this opinion.  Of course, the applicant bar will demand the expert’s fees as a cost.  We will have to be ready to respond to these claims as well once they are made; hopefully the life testimony of the investigator who personally took the footage will suffice to rebut any ridiculous claims of deepfake technology fabricating evidence of applicant fraud.

You might think that this is all from some paranoid mind of your humble blogger’s, who resents the fact that there is no audio-book version of Beyond the Aquila Rift, but let me assure you, these issues absolutely are coming, and we in the defense community would be well served to prepare for them rather than being blindsided when they finally arise. 

Have a great weekend, dear readers!

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