reserve for my rebuttal thank your honor this case presents a very discreet and narrow issue for the court and that's whether the district court here made an error in holding the california state law that requires provision of meal and rest breaks should be adopted as surrogate federal law on the outer continental shelf or the o c s which is governed by the exclusive federal jurisdiction as set forth in the outer continental shelf land federal law does specifically address meal and rest breaks so under the parker drilling standard that the us supreme court handed down in two thousand and nineteen there is no need to reach the nd issue as to whether state law is inconsistent because it is addressed under federal law instead of ending the inquiry with a starting point as to whether there's a federal gap at all and i think the best illustration in this instance is that the o c a isn't just adjacent to california obviously there are many other states whether or not there is a significant void or gaps in federal law but broadly speaking unlike other potential disputes or controversies federal law provides a comprehensive statutory scheme in the form of the f l s say to govern issues does in my view mean that state law does need to be adopted but this case presents a much easier and much cleaner question for resolution under parker drilling which is that the f l s a does address human rest breaks so there's no claim here that there is a significant gap in federal law it seems that the california law governs when and where a meal and rest breaks must be given a federal law here which the earlier versions of the complaint alleged was that mr ma it was not permitted to leave the premises during his will break the federal law would govern because federal law does address the issue of meal breaks that are provided if employers choose to provide them don't have to allow the employed to leave the premises that's directly inconsistent with california law which holds that employees have to be free entirely including leaving the premises during meal breaks so i believe that federal law addresses the exact issues and  plaintiffs in the district courts analysis was was applied then every time there was any kind of claim on the o c s district courts would be looking with a magnifying glass at which elements of state law which particular theories of liability were applied and then law addressing the subject matter and in that circumstance as the adoption of state law had to apply here it's the complete opposite there is a very well developed very comprehensive body of federal law addressing wage an hour and conditions of working including right and we know that when and when they when they started down this road there was this notion that they were going to be platforms are going to be cities out there they're going to be all kinds of neat needs where we might need to borrow state law because federal law didn't cover things like i mean you get the tough to say that the state more generous minimum wage was inconsistent but at this point you know we have a decision from the united states supreme court resolving that circuit split right so what's your best shot that to less it's not inconsistent with federal law but the supreme court in parker seems to be pretty clear that traditional preemption doesn't apply account in the context of the outer continental shelf plan so i guess what's your best argument to the contrary my argument is there is no we're not making a prevention argument i think substantial gap but it does apply that it has to because the whole thrust of part of drilling was to make clear that state law should be extremely sparing and limited in the role that it plays and so council scheme a state might provide then the o c s would just be a hodgepodge of state and federal law and that was never the intent and the supreme court made that very clear that if there was a sufficiently detailed legal framework to govern life on the  then there was no need to look to state law and what it thinks counsel has not addressed at all in the briefing or in argument is that it's i'm contested that in all of the other o c s locations that are adjacent to states other than california the f l s say is clearly sufficient to govern life on the o c s the f l s say also happens to be sufficient to govern life in those states because those states do not have any of their own un rest break laws but under plaintiffs analysis any time a state decides to enact more detail of legislation on any topic the then the courts would be engaging in this painstaking view of looking for a direct counterpart seeing if the state and the federal schemes mirror one another on a one dollar to one dollar comparison and any time that the states have decided to enact more detailed legislation rules then the analysis would violate parker drilling if the courts say that the federal law hasn't addressed it also regulates if they are provided there are certain circumstances where they have to be provided properly so that people are paid properly in connection with that time just