Subject: File No. SR-FINRA-2007-021
From: Jan Graham

April 11, 2008

I strongly support the rule change as it goes a far way in eliminating the extreme abuse and harrassment from Respondents in filing these motions in virtually every case. I responded to 26 such motions last year. These technical motions have no place in arbitration that is purported to be streamlined, efficient, and fair to claimants. The only concern I have with the rule change is it legitimizes motions at the end of the evidence and that is completely illogical. It will confuse panels and Respondents will argue that FINRA is telling panels that even if the case is meritorious it can be dismissed at this late stage for technical deficiencies and that the polar opposite of reform - it simply adds another layer of technical battling that will prolong and complicate the process.

Jan Graham
Graham Law Offices
801-596-9299 Fax
150 S. 600 East Suite 5B
Ambassador Plaza
Salt Lake City, Utah 84102