or questions the court may have about the abuse of discretion the discovery and the contempt issues the so that i page eighteen in your blue gray if you say at the bottom of the i'm looking at it and it appears to me that what actually happened was that you arrived at the hearing with a set of exhibits and title plaintiff's duplicate exhibits to be offered during really years examination march first two thousand and sixteen that's two six six four the district court judge remarks you were very optimistic  six zero to six three in light of what i just read to you how do you justify the statement and footnote in the blue brief the exhibits that were prepared and presented to the court were the ones that the court requested authentication of in other words a lot happened before we got there all the court was willing to permit him to do pursuit of prior court order was permit him to come and authenticate documents so that set of exhibits where the cannot defeat standing on the basis of irrelevant collateral information in the relevant collateral attack doesn't stand in have we positively shown that is correct but the standing that was positively circumstances of the assignment or the corporation or the corporate actions leading up to the assignment he he formed the corporation he was the driving force behind it he paid apply it should not be applied here because it was odd because the credibility of terminations was was a pain as a means to shield the cord from appellate review on the important issues of the of the actual to permit a collateral challenge to assignment documents to documents of title then it would it would be of welcome to give you an example to give your honor your example in the state  title cases involving real property one can imagine the havoc that would occur if if the title insurance company were to issue the policy of title insurance policy on real estate and somebody said well the matters and what happened to lead to the resolution assigning the property assigning the interest of mr right that's what the court focused on but they were relevant so it would be an abus discretion and it would be a matter of an air of law really to focus upon the credibility determination that was made on matters that should never have been before the court in the upon collateral matters and when mr neary was offered up to testify at trial he was there only because the court told him the only thing he could do was to authenticate documents he couldn't submit declaration he couldn't submit the declarations of any other person that's all he was permitted to do and so when we get there and the court permits the pending of the mist of ability of the documents well we we could tell the court wanted him to testify and we put him out and that is accurate and if the brief is is inaccurate on the part you have my apologies your honor but why is it not inaccurate it is it is not  it and that being the case your honor i would urge the court to look at the the realities of the of the statutory of the standing issues and that is one cannot attack standing type titular documents by un raveling or challenging the shareholder relationships and that was all he was examined on he wasn't examined on any other point and thank you your honor may have pleased the court there is nothing collateral at all about what happened in the district court if the view of the law to you just heard the right nothing would stop me from throwing together a set of assign all of apple's patents to me that's what we're neary did here now he did it for g g i am not apple so it was less transparently ridiculous what was no more legitimate than that if i had done it for myself or apple now this was a lost on judge when she said and this is a twenty seven sixty eight of the appendix so obvious sudden mr ranieri services says he's still stockholder signs everything to himself are you telling me the court is just stock that nobody can evaluate whether that's true because he has a document that looks like an assignment well council of course said no he had to say no and he went on to wholeheartedly agree that the question of whether ranieri actually own g p i stock was a proper area of inquiry for the court in fact he told the judge linda her question is quote so on point and gets to the heart of the issue well of course it did in fact a couple of weeks before in a brief filed in january of this is that a kind of sixteen zero nine he said this is quote if he that is remarry didn't own g p i he couldn't transfer himself the patents and so well of course he couldn't so that was the core issue it's not collateral it goes to the to the heart of whether there is a facially valid assignment whatever that means it can't mean a piece of paper that somebody just writes up and says he the and the other thing is here there's a suggestion in the brief certainly and i think mr crockett suggested if you're to that you know judge lane was getting tangled up in corporate formalities and that sort of thing she didn't require that there be some transfers in writing even though there are by last required it but she did comment that well it seems sort of odd that there are all these things that are supposed to be done in writing there are no documents that support any of it the only documents that do say that do show up here say that he was not a shareholder and contradict his story so and she actually asked counsel doesn't this go to credibility and he wholeheartedly agreed well yes it does go to credibility and that's a very important province for the court especially today that's what he said and so again you know i don't want to beat a dead horse but as i said there's nothing collateral here this went to the core of whether there was any assignment here the judge found on a compelling record that he had not established ownership of a single share of g t our stock so the documents he executed in december were false they actually were knowingly false so her finding of confirmation signature required his approval this he was the primary inventor he had the technical capacity and ability to create this patent he was not a complete stranger who suddenly shows up and sa to make that argument and that's the kind of argue and that is being made here by the by the defense now it's not technically a standing argument it's in there it's their relevance argument because they're defendants are not pla in none of their cases do they cite any in any decision which permits this kind of collateral attack on the face of the assignment so notwithstanding  early supposedly lying on the stand about the one hundred percent ownership versus seventy percent ownership of the corporation that's all that he was really found in difficulty of he the district court had problems with him versus one hundred it was that he was a liar on the stand and she refused to accept the veracity of his testimony yes that is correct that was a finding that is correct in the lie pertaining to the the corporate resolution that was executed in two thousand and fourteen that said i own one hundred percent of g p i when in fact he only seventy percent benefit or seventy five percent beneficial to his girlfriend but he explains in the transcript the reason why i signed that is because the person who owned the other the persons who owned the other twenty five percent they prepared this document for me to sign so i didn't consider it a lie and said hey if they want me to sign this document saying they say that i own