Lawyers often use the names of the forms and the rules upon which they are based interchangeably. For example, a notification of a late filing is often referred to as a 12b-25 filing. If I ask one of my associates to prepare a 12b-25 for one of my clients, he doesn't babble incessantly that I asked him to prepare a rule, rather than a filing.
You are evading the question. Please explain by what authority Keaveney was appointed "custodian" of EEGI.
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