thank you i good morning and may please the court mary christine's one guy left of the bunk culture law firm and the loyola law school appellate clinic pro bono point of counsel for the petitioner i would like to reserve five minutes we could possibly have jurisdiction she may win this point that she could ever be theirs easily win as lose and so what right is there to vindicating this moment she she's not subject to remove all reinstate and which could be reinstated at any time once again and that has not been reopened or terminated what we are trying to do is to get back to and justice clifton indicated in that in the case just before ours that that there are some shenanigans going on here with regard to the government in that we had our earlier possibly be better for your client to brasi on the theory that he's facing deportation order when he is not and that the agency is bound to brazil a claim against her which is theoretically possible barbara facsimiles and at this point i mean this sounds to me like the gays when the judge says you when you get out of the court room before they can change their mind because i don't understand how your client's position  improved by successfully pursuing the argument you're trying to make the os at the end of that day the best that happens is the whole thing gets remanded to the agency which is exactly where it is by your telling right now so what is their cause you want is to breastfeed to make it any better for your client well i'm sure that that previous appeal we had we had urged and because the the i i reached every this if you dig into your arguments is seems to me at the end of the day the most likely relieve you can get is going back and telling the agency no the browns upon which you were elected rejected this application fail but that doesn't mean that we're in a position to say you must grant relief you must grant asylum at the end of the day asylum is discretionary anyway and so what's the withholding which is mandatory and cat protection but that's that's a much harder kind of relief to get so i and i tend many of these cases this is a strong this is i have the strongest case i've ever seen on the merits well it's not the strongest case i've everything that i come back to that well it's your election but it seems to me and i'm really hard pressed to see how your client is better off by pursuing the argument you're making that causes us to dig into this case and who knows maybe we say gee there's enough here the idea record might not compel the result that you're arguing or as opposed to simply remanding and seeing what happens in the next stage in this is a year call but as i say i really have trouble seeing how your clients benefited by that position that that there were no grounds for reopening in this case and there have been constant shifts just as we get to a point of decision by this court both in the prior pill and this one and so we do think there is value to this because we re concerned that there are what if this court isn't able to supervise or review things that the government could continue to do things that are not reveal by this court and that could further harm our that there be an inability to indicate the goals of the writers by waiting for example if you're not subject to suit at all then having to go through a trial can be really came in after the trial but it seems to me in this context that if there is a regardless of whether there's a new proceeding if it's ever there if there's an ever is finding in order to remove all everything can be vindicated thank you your honor yes as to the the status there is no change in status as to our client the there is deferred status as i mentioned which which the where they should have been a year ago so why is that a brother who well because it could be reinstated again i mean it is on of the goodness of their heart they do not have this doubt as tomorrow after this after this argument they can decide that it's not and that that's not cancellation isn't required because until she has a judge's no doubt it is some irony if if that happens and if there is a hearing and if your client loses again you'll have a full opportunity to come to this court on the appropriate and relevant record i don't understand how we can possibly metal at this point especially when i think we don't have any idea what's going on because neither party has all those and well i do think that there is a point to it to addressing the reopening and the reopening standards which were done with absolutely you i i i well we can see on an remount already the i j a has doubled down on its earlier decision denying her relief i don't imagine to be i e will do anything different they will be smarter this time and the only decide one grounds so that remain and will be necessary over and over to the b i a if they do reinstate things and that is what is unfair about it and improper about these proceedings and that is a ground for collateral order review with regard to reopening as well if there is a possibility of analyst agency proceedings without oversight from this court on the grounds that ms greer is quite experienced and their  experience they know when there is grounds when there is not grounds to be doing these things and thus far does not give a lot of confidence that they will do whatever they can do like i said tomorrow we're reinstate that they're currently