reply to the motion to reconsider and he would raise their hand at least in my view the response to the motion to reconsider facts alleged in that complaint but that's not a certified fair fight or otherwise notarized document it's just signed my new jersey now we have a judgment over here and can't we  upon appeal in before the kentucky appellate court and one of the big issues there is the statute of frauds of the in summary tell us why these transactions are not related to all these issues are not related to the same operative sort of facts where they are not really because they were separated by two years because they don't with different subgroups because he would require different issues to be get the money that he was otherwise owed from two thousand six isn't that the issue here it's all about the money owed back there never was  transactional test for the application of race today and what i believe some of your questions elicited in terms of response were that section twenty four of the restatement motion to dismiss are the certified copies of the original complaint mission tuckey action and the first and then you can point as well as mr went on his answer and in those meetings it's clear that  the facts underlying the kentucky litigation were the series of connected transactions related to mr black's employment disputes that arose out of the terminations thereof and the effect of the two thousand and six agreement by an attorney in syria different standard in kentucky about the signature of an attorney well i don't know move there's a different standard about the signature of  agree with those facts they're not true but that's exactly why this went to trial in kentucky and was resolved in his actions bar and now we don't need to have that fight again it's a question of judicial economy we don't keep waiting for just position by the kentucky court of appeals on this case the documents that were attached to this affidavit that's going to this six nineteen motion that's correct ok now i'm sorry i didn't see in his brief which talks about a complaint filed by a against a homeowner homeowner third party existed a contractor and says you breached your con your construction contract with us and a contractor comes in and says i filed a small claims complaint against you previously and that bores your action against me here and the eggs case talks about two thousand and eleven and the illinois complaining was filed on may thirty one two thousand and twelve the jury verdict in kentucky was on july twelfth of two thousand and twelve so that's four years before the verdict well into the litigation in kentucky so there's nothing that would have prevented this compulsory counterclaim in terms of time the resolution of the case is anything what about counsel's argument that the issue really isn't why the contract is not that he was the one point six but that the contract here in illinois failed because of the business climate how would that there are different contradictions behead you go through all the pieces cited by the parties put the horns indicating that you're not interested in this term well not that we're not interested in the good we have already looked at them and we can continue to