-1-

BEFORE THE JUDICIARY BOARD OF THE CHURCH OF GOD IN CHRIST

THE GENERAL BOARD OF THE CHURCH OF GOD IN CHRIST, INC., PETITIONER.

VS. NO. ______________________

BISHOP THOMAS L. HOLSEY PRELATE OF THE DELAWARE JURISDICTION, RESPONDENT.

JOINT MOTION FOR RECONSIDERATION AND WITHDRAWAL OF THE MAY 29, 2013 ORDER

Petitioners, The General Board of Church Of God In Christ, Inc. (the “General Board”),

together with The Board of Bishops of Church Of God In Christ, Inc. (the “Board of Bishops”),

hereby jointly1 seek reconsideration and withdrawal of the May 29, 2013 Order of the Judiciary

Board, Order 106-11 (the “May 2013 Order”),2 lifting the probation of the Respondent, Bishop

Thomas L. Holsey.

While there are many bases supporting this Motion, the primary grounds for

reconsideration include the following:

(1) The May 2013 Order resulted from an improper inquiry initiated or filed by the

Respondent Bishop Holsey with the Judiciary Board;

1 The Board of Bishops is joining this Motion only to the extent that it seeks a procedural correction by the Judiciary Board. The Board of Bishops has not predetermined the outcome of any decision with regards to the General Board’s motion against responding seeking enforcement of the November 2010 Order. 2 The May 2013 Order is actually dated April 2013 in the caption.

-2-

(2) Appellate review of this matter by the Judiciary Board is premature since a

motion to enforce the Board of Bishops’ November 15, 2010 Order (the

“November 2010 Order”) is (and has been for several months) pending before the

Board of Bishops and, thus, any application for appellate review with the

Judiciary Board must be made in the form of an appeal, within a timely fashion

and subsequent to the issuance of an actual decision by the Board of Bishops on

the pending motion; and

(3) The Judiciary Board’s exercise of impromptu appellate review of the November

2010 Order while a motion to enforce the November 2010 Order is pending

before the Board of Bishops is both unconstitutional and problematic for several

reasons: it serves as a direct usurpation and abuse of the power and authority of

the Board of Bishops; is manifestly unjust and potentially results in inconsistent

judicial determinations, all of which unnecessarily and improperly frustrate and

impedes the existing legal process and ecclesiastical structure governing the

Church.

This Joint Motion is supported by the following:

STATEMENT OF RELEVANT FACTS

1. On or about August 13, 2010, the General Board, pursuant to Article VIII, Section

D of the COGIC Constitution, brought charges against the Respondent for various alleged

improprieties surrounding the disposition of funds belonging to the Delaware Jurisdiction. (See

Exhibit “A” attached hereto– a copy of August 13, 2010 Complaint.)

2. An ecclesiastical trial was held against the Respondent before the Board of

Bishops during November of 2010 and resulted in a finding that the Respondent was guilty of

-3-

misfeasance and nonfeasance with respect to the performance of his episcopal and managerial

duties on behalf of the Delaware Jurisdiction. (See Exhibit “B” attached hereto – a copy of the

November 2010 Order.)

3. The Board of Bishops placed the Respondent on a two-year probationary period,

where Respondent would remain in the position of Jurisdictional Bishop under the supervision of

Bishop Frank O. White, as Jurisdictional Overseer, and subject to the following restrictions:

“[N]o decision regarding, concerning, or impacting the financial matters of the Jurisdiction of Delaware will be conducted, carried out, or performed by Bishop Thomas L. Holsey during [the] probationary period.” (November 2010 Order at ¶ 3);

“That during the Probation Period, Bishop Thomas L. Holsey must gain the following and support of the majority of the Pastors, Elders, and Leaders of the Delaware Jurisdiction, the progress of which shall be demonstrable and assessed by the Board of Bishops.” (November 2010 Order at ¶ 5);

“Bishop Thomas L. Holsey shall immediately provide to the General Board all bank statements, cancelled checks, and all other financial records for any account for which Delaware Jurisdiction has or has had any interest.” (November 2010 Order at ¶ 6); (emphasis added) and,

“[H]e will comply and conform with all of the obligations therein and that any breach thereof will be considered contempt of this order and allow summary disposition by the Chairman and Executive Boar [sic] of the Board of Bishops.” (November 2010 Order at ¶ 9) (emphasis added)

(See Exhibit B.)

4. Within the November 2010 Order, the Chairman and Executive Board of the

Board of Bishops reserved the right to summarily dispose the Respondent of his duties as

Jurisdictional Bishop of the Delaware Jurisdiction in the event that Respondent breached any

obligation imposed by the Order. (See Exhibit B at ¶ 9.)

-4-

5. The Respondent, elected not to pursue his right to appeal the November 2010

Order of the Board of Bishops,3 but instead signed the Order, attesting to the fact that he had not

only reviewed and read it, but would adhere to all of the duties and responsibilities imposed upon

him under the penalty of contempt and subject to summary disposition. (See Exhibit B.)

RELEVANT PROCEDURAL HISTORY

6. On November 14, 2012, the General Board notified the Board of Bishops of

Bishop Holsey’s non-compliance with the November 2010 Order and the General Board’s intent

to file with the Board of Bishops a motion for contempt and sanctions against Bishop Holsey.

(See Exhibit “C” attached hereto – a copy of the General Board’s November 14, 2012 letter to

the Board of Bishops.)

7. In December of 2012, the General Board filed its motion before the Board of

Bishops seeking enforcement of the November 2010 Order against the Respondent, including

dismissal as the Jurisdictional Prelate of the Delaware Jurisdiction based on his non-compliance

with the November 2010 Order (the “Motion to Enforce”). (See Exhibit “D” attached hereto – a

copy of the Motion or Enforce filed on December 22, 2012 by the General Board with the Board

of Bishops.)

8. The Respondent was served with a copy of the Motion to Enforce.

9. The Motion to Enforce filed with the Board of Bishops is still pending as no

written decision has yet been made or issued to date.

3 Bishop Holsey did, however, appeal a subsequent January 2011 Order of the Board of Bishops to the Judiciary Board. In April 2011, the Board of Bishops withdrew its January 2011 Order and the matter was remanded back to the Board of Bishops for further enforcement under the re-instated November 2010 Order.

-5-

10. The Respondent never opposed the motion filed and currently pending before the

Board of Bishops, which seeks sanctions against him, including his dismissal as the

Jurisdictional Prelate of the Delaware Jurisdiction.

11. The Respondent has made no application or motion with the Board of Bishops in

any way seeking even remotely to challenge or oppose the allegations raised against him in the

Motion to Enforce currently pending before the Board of Bishops.

12. Without providing proper notice to either the Board of Bishops or the General

Board, on or about April 18, 2013, we understand and believe based upon the representations in

the May 2013 Order itself that the Respondent made what shall be referred to herein as an

‘inquiry’ with the Judiciary Board regarding the status of his probation pursuant to the November

2010 order. (See Exhibit “E” attached hereto – a copy of the May 2013 Order of the Judiciary

Board.)

13. While the Board of Bishops was reviewing and (and still is) considering the

motion to enforce filed against the Respondent Bishop Holsey regarding the appropriate action,

if any, to be taken in connection with the November 2010 Order, this Honorable Court issued the

May 2013 Order in response to the “inquiry.” (See Exhibit E.)

ARGUMENT

Point I:

The “Inquiry” of the Respondent Was Not Properly Before The Judiciary Board.

14. First, the April 18, 2013 application of Bishop Holsey to the Judiciary Board as to

the status of his probation was inherently and entirely facially flawed and improper, as there is

no process within the Judiciary Board’s Rules and/or the ecclesiastical framework of the Church

-6-

of God in Christ, Inc. which allows an ‘inquiry’ to serve as the basis for triggering or initiating

any form of appellate review.

15. The Judiciary Code contains the policies and procedures relating to the processing

of complaints governed by the Judiciary Board. (See Exhibit “F” attached hereto, Para. 1 of

FOREWORD – a copy of the Judiciary Code.)

16. The Judiciary Code does not include or contain any provision(s), whether directly

or indirectly, which would allow the submission of an ex-parte or even non ex-parte “inquiry.”

(See Exhibit F.)

17. Nowhere in the Judiciary Code is there any reference to consideration of any

inquiries, such as the one that Bishop Holsey apparently filed with the Judiciary Board during

April, 2013.

18. Indeed, even if such an inquiry is allowed, in furtherance of justice and the

administration of fairness, the other parties of interest, such as the Board of Bishops, who is

currently entertaining a motion on the issues pertaining to Bishop Holsey, and the General

Board, which is the party that brought the motion currently pending before the Board of Bishops,

should have been placed on timely and appropriate notice of such inquiry (the Judiciary Code

requires such notice within twenty-one (21) days after receipt) and given an opportunity to

respond to the same. (Refer to Exhibit F, including the lack or non-existence of any provision(s)

pertaining to the filing of any inquiries with the Judiciary Board and/or notice to parties of

interest of any filed inquiries with the Judiciary Board.)

19. Second, at the core of the Judiciary Code is a mandated request for Candor,

including the full disclosure in ex-parte proceedings of “all material facts known to him/her

-7-

which will substantiate the Judiciary Board’s decision, whether or not the facts are adverse”.

(See Exhibit F - Judiciary Code, Rule 3, “Candor Before the Judiciary Board.”)

20. While Rule 3 of the Judiciary Code pertaining to the absolute requirement of

candor applies by its very language to Counselors and Advisors appearing before the Judiciary

Board, now that Bishop Holsey represents himself in these proceedings and, on his own

initiative, took the liberty of making a direct inquiry with the Judiciary Board regarding the

status of his probation, he had an affirmative ethical obligation to notify or disclose to the

Judiciary Board the well-known fact that the Board of Bishops was entertaining a motion to

enforce the November 2010 order.4

21. Such lack of candor or failing to disclose critically relevant information, appears

to have played an integral part or role in this Honorable Court concluding that the Board of

Bishops did not timely entertain any allegations of non-compliance against Bishop Holsey in

connection with the November 2010 Order and that the time for any further consideration has

expired. (See Exhibit E.)

22. Third, the appropriate adjudicatory body for Bishop Holsey to raise any issue with

regarding the status of his probation would clearly, without contradiction, be the entity that

issued the Order in the first instance.

23. The Board of Bishops, and not the Judiciary Board, is the appropriate body for

Bishop Holsey to raise any issue regarding the status of his probation since this is the entity that

found him guilty of guilty of misfeasance and nonfeasance with respect to the performance of his

4 Indeed, Bishop Holsey has been notified in writing by Bishop White, on several occasions, including in letters dated December 13, 2010 and February 28, 2011, regarding Bishop Holsey’s non-compliance with the November 2010 Order.

-8-

Episcopal and managerial duties on behalf of the Delaware Jurisdiction in the first place and

imposed the November 2010 Order. (See Exhibit B.)

24. Bishop Holsey executed the Order outlining the terms of his probation as

mandated by the Board of Bishops and, thus, any issue or concern relative to whether or not the

terms and/or conditions of the November 2010 Order were fulfilled (or not) should be initially

addressed with the Board of Bishops. (See Exhibit B.)

25. Unlike Bishop Holsey, the General Board raised issues regarding Bishop Holsey’s

failure to fulfill the terms and/or conditions of the November 2010 Order and, thus, proceeded

with the filing of a motion with the appropriate adjudicatory body, i.e. the Board of Bishops, and

not the Judiciary Board. (See Exhibits C and D.)

26. Bishop Holsey has not opposed the current motion pending against him before the

Board of Bishops which relates specifically to whether or not the terms of the November 2010

Order have been fulfilled or, alternatively, whether grounds exist for the imposition of sanctions

due to his non-compliance with the November 2010 Order. (See Exhibit C.)

27. As opposed to defending himself before the Board of Bishops, Bishop Holsey

entirely circumvented the appropriate legal process by soliciting an ex-parte and improper

audience with the Judiciary Board which, as will be addressed below, does not comply with the

Judiciary Board’s existing Rules of Procedure as contained within the Judiciary Code.

28. The appropriate legal avenue for Bishop Holsey to have taken in order to raise an

issue regarding the status of his probation at this time would have been to either (1) raise them in

connection with the filing an opposition to the pending motion to enforce filed against Bishop

Holsey before the Board of Bishops, or (2) by making an independent application with the Board

of Bishops raising an issue regarding the status of his probation.

-9-

29. By entirely ignoring the Board of Bishops and essentially circumventing the

appropriate legal process or channels for raising issues regarding the status of his probation

under the November 2010 Order, Bishop Holsey has indeed committed the same procedural

infraction (i.e., lack of notice) that he previously complained before the Judiciary Board that the

General Board violated in connection with the Board of Bishops’ January 2011 Order. (See

Exhibit “G” attached hereto – Petitioner’s Writ of Certiorari and Application for an Emergency

Stay of Order Removal and Suspension filed January 29, 2011.)

30. The only things that have been accomplished by filing of the April 2013 inquiry

with the Judiciary Board is the circumvention of the appropriate legal process, in utter disrespect,

defiance and disregard for the ecclesiastical body to which this matter it to be adjudicated before,

i.e. the Board of Bishops, and ultimately the issuance of the May 2013 Order at a time when

jurisdiction over this matter appropriately belonged with the Board of Bishops.

31. Therefore, since the ‘inquiry’ was improperly before the Judiciary Board, the May

2013 Order issued by the Judiciary Board in response to the inquiry should be reconsidered and,

upon reconsideration, withdrawn and/or rescinded.

Point II:

Appellate Review By The Judiciary Board Of This Matter Is Premature.

32. The Judiciary Board’s Rules of procedures pertaining to an appeal provide, in

relevant part, as follows:

APPEALS GENERALLY

The Judiciary Board shall receive appeals from all forums within the Church having mandates to present the same. …

-10-

Upon such appeal, the Board may review any questions of ecclesiastical procedures, orders, determinations and ruling, made or used by the lower tribunal or referring body.

APPEALS PROCESS

Any person(s) making an appeal to the Judiciary Board, must follow the Procedure set forth in the Constitution, including the filing of notice with the Chairman of the Judiciary Board or the Secretary of the Judiciary Board, within 30 days after the final decision of the lower tribunal.

The “NOTICE OF APPEAL” shall be sent by Certified, Return Receipt, via the United States Postal Service, or by other method which will ensure timely delivery and provide proof of said delivery.

Within twenty-one (21) days after receipt of the Notice of Appeal, the Secretary of the Judiciary Board shall notify both Appellant(s) and Appellee(s) of the receipt of same and request any additional written documentation needed, to perfect and process the appeal. …

A sample of the written documentation which the parties are required to furnish, is as follows:

1. Transcripts and/or records of the lower tribunal; 2. Orders and rulings appealed from; 3. Documents and other evidence submitted at the lower tribunal; and 4. Judgment of the lower court or tribunal.

In its sole discretion, any hearing scheduled by the Judiciary Board may be held:

…

3. By telephone conference, in what the Board determines is an “emergency” situation, but only with the consent of the Appellant(s) and Appellee(s). On matters requiring a determination as to the constitutionality of an act, a Board meeting must be held and conducted by the entire Board.

(See Exhibit F.)

33. Only upon an unfavorable determination issued by the Board of Bishops would

Bishop Holsey or any other party of interest to these proceedings have legal standing to file an

appeal to the Judiciary Board.

-11-

34. However, to date, the Board of Bishops has not issued any decision in connection

with the pending motion to enforce filed before it in December 2012 against Bishop Holsey, in

connection with the November 2010 Order.

35. In accordance with the Judiciary Code of the Judiciary Board, only upon a

decision by the Board of Bishops, to which Bishop Holsey did not agree with or objected to,

would Bishop Holsey then be put in a position, within a relatively limited timeframe, to file an

appeal of that decision with the Judiciary Board. (See Exhibit F.)

36. The Judiciary Code does not allow or permit Bishop Holsey or any other party of

interest to this matter carte blanche access to appellate review at any time that feel compelled to

request the same and in defiance of the rules and procedures as contained within the Judiciary

Code. (See Exhibit F.)

37. As a Motion to Enforce the November 2010 Order previously entered by the

Board of Bishops is currently pending before the Board of Bishops, any appeal of the November

2010 Order is blatantly premature.

38. Therefore, respectfully, this Court should reconsider the May 2013 Order lifting

Bishop Holsey’s probation and, upon reconsideration, either rescind or withdraw the Order in its

entirety.

Point III:

The May 29, 2013 Order of The Judiciary Board Confirms That Appropriate Jurisdiction Of This Matter Should Be Before The Board of Bishops.

39. Within the May 2013 Order, this Honorable Court stated as follows:

We offer no opinion as to the satisfactory completion of each condition of the probation, as this would or should be rightfully determined by the trial court. Sufficed to say, had Respondent at any point had failed to complete any condition of the probation, it is the responsibility of the trial court to convene a hearing on such

-12-

failure, and if Respondent’s failure to comply is sustained, the trial court could have exercised its authority to suspend probation, extend the length of probation or apply such other measures to bring Respondent into compliance. …

However, at this point, the clock has run and Respondent cannot be compelled to participate in a hearing (if requested) regarding his possible failure to satisfactorily complete any or all of the probationary conditions.

The Respondent having been placed on probation for a period of two years by Order of the Board of Bishops’ court dated November 15, 2010 and the Judiciary Board not being aware of any material violations of probation during the period of supervision, and after notifying the Board of Bishops of this Court’s intent to terminate and discharge the Respondent absolutely.

(See Exhibit E.)

40. Within the May 2013 Order, this Honorable Court confirms that any issues

regarding the November 2010 Order, including the related issues of the probation status of

Bishop Holsey and compliance with November 2010 should be entertained by the Board of

Bishops.

41. However, this Honorable Court, at the time of the issuance of this decision, either

was unaware or did not take into consideration the fact that since December of 2012, and

continuing until the present, a motion to enforce the November 2010 Order against Bishop

Holsey has been pending and not yet decided by the Board of Bishops. (See Exhibit C.) Further,

upon issuing the May 2013 Order this Honorable Court admittedly lifted the Respondent’s

probation without any knowledge as to whether (or not) the Respondent satisfied each condition

of the November 2010 Order. (See id.)

42. The statement by this Honorable Court in the May 2013 Order that “the Judiciary

Board not being aware of any material violations of probation during supervision” can only lead

to the conclusion that knowledge or information pertaining to the proceedings still pending

-13-

before the Board of Bishops, with respect to the whether or not there has been material violations

of Bishop Holsey’s probation, was not properly or accurately disclosed to this Honorable Court

or considered.

43. Indeed, this Honorable Court, in its April 2011 Order, previously issued in

connection with this matter, outlined a host of concerns to be addressed before the Board of

Bishops. (See Exhibit “H” attached hereto – a copy of the Judiciary Board April 12, 2011

Order.)

44. For the Judiciary Board to now even consider lifting the probation without raising

an inquiry regarding any of the concerns it outlined in its April 2011 decision is strange at a

minimum. The failure of the Judiciary Board to require clarification or resolution of these

issues, coupled with the clear errors relative to the lack of timely notification to the other parties

of interest and the allowance of an inquiry by Bishop Holsey in circumvention of proceedings

already pending before the Board of Bishops, merits reconsideration of this Court’s May 2013

Order and, upon reconsideration, withdrawing or rescinding the same.

45. Therefore, even upon review of this Honorable Court’s decision, which does not

take into account that the Board of Bishops is currently entertaining this matter, a withdrawal,

rescindment, or reversal of this Court’s May 2013 Order is warranted.

Point IV:

The Board of Bishops’ Opportunity To Review and Adjudicate the November 2010 Order Has Not Expired.

46. Within the May 2013 Order, this Honorable Court stated as follows:

However, at this point, the clock has run and Respondent cannot be compelled to participate in a hearing (if requested) regarding his possible failure to satisfactorily complete any or all of the probationary conditions. (See Exhibit E.)

-14-

47. This Honorable Court concluded in the May 2013 Order that the clock has run out

relative to whether or not Bishop Holsey has complied with the November 2010 Order. (See

Exhibit E.)

48. However, the Board of Bishops is not governed by any timing limitation which

would thereby prevent it from entertaining the General Board’s December 2012 Motion to

Enforce filed with the Board of Bishops.

49. The fact that the Order was in effect until November 2012 solely pertains to the

time period for which Bishop Holsey was given to comply with the demands of the November

2010 Order and was in no way an attempt to limit the ability of the Board of Bishops to issue any

directives or decisions as a result of non-compliance with the November 2010 Order anytime

subsequent to November 2012; if that was the Board of Bishop’s intent, the November 2010

Order would have expressly stated it. Indeed, the November 2012 Order does not state that

Bishop Holsey would, automatically, be fully re-instated at the close of the Probationary Period,

which clearly infers that some final disposition of the November 2012 Order by the Board of

Bishops was necessary to complete Bishop Holsey’s probation.

50. Given that the Board of Bishops’ final determination on the November 2010

Order was not time barred, the May 2013 Order—which indicates that “the clock has run”—

should be reconsidered and, upon reconsideration, withdrawn or rescinded.

Point V:

The Judiciary Board’s Exercise of Appellate Review Impedes And Undermines The Integrity of the Judicial and Ecclesiastical Processes.

51. First, with great deference and the utmost respect for the Judiciary Board,

appellate Courts inherently by nature are not designed to monitor cases previously entertained

-15-

before them and/or for which a decision was previously issued without an appropriately proper

and timely application being made before the Judiciary Board.

52. The Judiciary Board of COGIC is the established highest appellate court serving

as the final authority on questions of ecclesiastical constitutional doctrine, less any exceptions

already outlined within the rules and regulations of the Church. (See Exhibit F, Judiciary Code,

PREAMBLE, Par. 1).

53. The civil courts, by nature, take a hands-off approach generally when it comes to

any ecclesiastical proceedings or decisions pertaining to the internal laws and procedures of a

hierarchical denomination.

54. However civil courts, underscoring the well-established ecclesiastical deference

in the application of the church autonomy doctrine to church disputes of this nature, rely heavily

upon the key foundational premise of unrelenting integrity of the internal legal process.

55. Indeed, the integrity of the legal process is sorely and severely diminished or

compromised anytime the process is not adhered to or complied with by the very individuals

designed to uphold and enforce the process.

56. When an adjudicatory body over-reaches in its exercise of judicial authority, the

sanctity of the concept known as due process or more relevant to this matter, i.e. church process,

is not only unnecessarily tarnished, but the litigants to a party are now not allowed a fair

opportunity to litigate their claims before the appropriate decision-making body.

57. What is clear is that there has been no decision issued as of yet by the Board of

Bishops in connection with the Motion to Enforce the November 2010 Order filed in December,

2012.

-16-

58. What is equally clear is that without a decision, there is nothing at this juncture

for Bishop Holsey or any other party to appeal from.

59. Further, there should be no question that any inquiry regarding the November

2010 Order should be appropriately made before the entity or adjudicatory board which issued

the order in the first instance, prior to seeking relief from elsewhere.

60. Essentially, given the posture of this matter, any action taken by the Judiciary

Board that does not follow or comport with the existing legal process and/or ecclesiastical

structure within the Church unfavorably taints the proceedings as a whole, including the

impeding into matters rightfully before another adjudicatory board and undermining the integrity

of the entire system.

61. Second, the Judiciary Board’s May 2013 Order now questions the validity of any

future decision by the Board of Bishops, in its capacity as the appropriate and constitutional body

with authority to adjudicate this matter.

62. Realistically, since jurisdiction over this matter is rightfully held presently with

the Board of Bishops, the May 2013 Order of the Judiciary Board leaves all parties in a state of

confusion resulting from two potentially inconsistent decisions issued by two different

adjudicatory bodies on essentially what amounts to a determination on the same issue, i.e.

whether or not Bishop Holsey has complied with the November 2010 Order.

63. There is a definitive abrupt disruption of the smooth functioning of ecclesiastical

process and procedure since the Judiciary Board has essentially usurped the constitutional

authority of the Board of Bishops and instead of awaiting an actual decision, has taken the

initiative to simply make a final determination on issues pertaining to the November 2010 Order

-17-

of the Board of Bishops when the Board of Bishops has not yet formally determined whether the

issues pertaining to the same November 2010 Order are final.

64. If the May 2013 Order is not reconsidered and then either withdrawn or rescinded,

this created state of confusion resulting from a level of inconsistency in the application of our

existing rules and procedures over ecclesiastical matters within the Church essentially allows any

party in interest to rely upon such precedence for the purpose of circumventing the appropriate

process, to the potential detriment of the remaining parties.

65. With the utmost great deference and sincere respect to the Judiciary Board, to

allow clear errors in the allowing of the filing of an inquiry, without proper notice to other parties

of interest, resulting in the ultimate decision to lift the probation of the Respondent when the

Board of Bishops is already considering whether or not the November 2010 Order has been

satisfied or whether sanctions should be considered, runs afoul of the Judiciary Code’s rules, is

entirely repugnant to the entire judicial system and creates unnecessary chaos, friction and

confusion amongst adjudicatory bodies.

///

///

///