so you are you were asking us to invoke rule that it is a matter of law it's improper to book a license where there's no prior of violations and no showing of knowledge on the part of the owner you're trying to say so yes the owner doesn't know it regardless of whether they have undertaken any steps to manage these issues to places can never be revoked who are you i mean storage of rage and i'm a good he knew this industry it's well known to me you could go on the internet you watch on t v you watch press conferences from the united states government targeting this industry and other industries you are correct the good histories in new jersey being just white with prostitution and slave trade but only when he gets into the business he has to be aware of the risk and take steps to ensure which would be mitigating if you had presented evidence at this sanctions portion of the hearing to show that your client had taken reasonable steps to ensure background checks both of these cases on the record presented revocation was a permissible sation by the commissioner given the deferential standard and i'd like a moment to maybe give you a mindset because when we've got things clearly erroneous arbitrary and reasonable they all end up being kind of conclusions but i want to i want to as i mentioned in my reply for the ace of the court perhaps a conflict there something in the liquor control business called have training of the bartenders here's how you check for right vs here's how you recognize somebody who's been over served in the like and that's another that's in the context of an open letter establishment if we had a record here proactive management who said there this person was a was a renegade i think that would be a far different record in chains there was no evidence whatsoever to permit inference that this was a management that was proactively client i believe the evidence in the eighty's the so called mitigation evidence is worse the the manager of the premises and  corporation corporate responsibility where the individual admitted that he had developed of the corporate responsibility would come to the place once a month to collect money was was was next to a complete no show i didn't do a training that is really didn't do any supervision and indeed didn't take any disciplinary action against this employee until after the prostitution case were to have a business where it is very easy to have illegal acts committed and you have a potential end law enforcement and social problem they had in the view of the village imposes a level of corporate responsibility on the company in other and the hearing loss is not limited to the traditional rules of evidence that would be applied in a criminal case credits correct it's almost a modification for those to whom much is given much is expected this business has prostitution case of each one what a coincidence but the fact that these cases are so hard to to make because they're going behind closed doors they had elevators deter because good operators won't care about it it's the only effective deterrence the only way we can do it is your honor you know they have it takes a lot of time and effort to do these things you can't use local officers in you really you really have to stage it and we did and if it turns out that with all the resources we spent it it turns out to be a thirty day suspension of limited government resources will have to go somewhere else and that's a that would be a crime her because as all of the as all of the information that the attorney general has given these projects in the middle who are performing these services are forced to perform these services they are victims of this of this operation and we need as a as a in this a pallet as a government to do what we can to make sure that the good operator has flourished and  and the evidence was clear that there were violations and there was no contest here that there were violations but the commissioner only gave a thirty day suspension would you be here appealing that decision well fine abuse of discretion i  know i don't think i would have standing to but i don't i think they had discretion is discretion and you know if i'm fired if i'm a village attorney the fire this commission says he shouldn't be fired it's only it's only thirty day suspension cool twenty three that makes reference to if it's a sanction case only it's got to be shown that this action was arbitrary and reasonable you know that that kind of standard here's what i would suggest to the court as a potential as a potential way to to a court to airlines something like this given this type of business is the section of revocation i'm the one who record rationally related to illegitimate governmental goal so rationally  why because any business can have bad wiring it needs to be fixed so i think i think that your honour's is a suggested suggested way to look at it and i agree it it would seem whether it's clearly it is i am sure important case for all municipalities for i just do municipal law and i think in terms of abuse of discretion from the famous wow in his case at this plains that was a good cop good record who left his post when there was a flood and the supreme court upheld the terminations and i think in a way there's an analogy here that that decision is rationally related to a legitimate governmental goal the goal is to make sure the police just like i'm allowing this case if they say action of revocation for something more prostitution violations in a business where that's the biggest risk that is committed these violations because of the threat that these businesses polls for human trafficking and corporate prostitution there's no you don't know who is going to violate the law if you know there's no crystal ball for the village but they had a tough ordinances to prevent this type of activity danger aspect of it sure every day that these drug dealers are sharing weapons and obviously it's dangerous for the investigating officer which requires a lot of bag of officers for his safety i've never he did operate the business both onsite and then later on with the manager there was no evidence presented that he enacted a written policies or practices or employment