Key legal question
Whether the appellant's supplementary filing of 17 September 2009 could be considered despite expiry of the appeal period.
Extracted holding
No. The supplementary filing was submitted after the 30-day appeal period had expired and could not be taken into account.
Extracted reasoning
The appeal period under Art. 100 Abs. 1 BGG had expired on 14 September 2009; improvements filed after that date are ineffective.