first the district court simply neglected to address these beaches claims that the shangri la defendant directly violated the trafficking victims were checked protection act by harboring or maintaining her at the shangri la hotel any affirmative action to call the authorities the allegations are that she it seems i'm not at all surprised by what was happening she smiled she turned away is it established she understands english not alleged but she does not there is no suggestion that as the operators of this motel there was any inability to understand english and again i don't think it's not easy to tell understand to be a defense i think it wouldn't necessarily doesn't lot of the motel they encountered mr patel and mr going to mr patel shared conversation where there was a discussion about making money and getting this thing going again reasonable inference from that allegation is that the making money and getting things to make a determination on the i'm i will result would be would be fine your honor i think certainly it's very clear the district court didn't address the direct claims at all in the reconsideration or in the original those are viable claims we think that reactions in the conduct to witnessing his riches abuse at the hands of mr mclean and the allegations of paragraph thirty nine that ms patel when she entered the room with mr mclean and ms riccio and observed ms reaches state demanded additional money from captivity and that then supports the inference why didn't and that supports the inference that the patel was and mr mclean were engaged in a venture together that they were they were believe well i just would like to speak about the motion for reconsideration for a moment because i think it needs to be viewed in the context of the conspiracy and the tempo factual allegations in this complaint that give well the allegation is that this was a little bit of his purpose to indoctrinate her into the world of sexual exploitation and it certainly began when he asked her to come home from maine to visit him at the hospital there's no allegation that they knew anything about that there's no allegation that they had any knowledge of actually what it it's what they see when they are there at the moment and being held  shoe known or recklessly disregarded that there was a domestic dispute that there was an act of domestic violence that there was a small and was mis patel's actions if true the definition of morality is it something that we would wish a stranger would act or respond to a daughter or son or a family member no but that's not why we're here we're here to they have enough information other allegations that there was another front of them that they knew who should have known or recklessly disregarded act of showing trafficking or forced a waiver for purposes of sex there's not enough of it in her mind there would have to turn on fact that he stayed there i mean it this is the sort of cone ring that they added to the hits to make it more likely that  comment about this is a haven for a whistle activity i would ask the court to disregard that i don't believe that there are sufficient factual allegations asserted to to support that the four hundred seventy five phone calls that are mentioned no description of the character of the phone calls with the day were a medical emergency disorderly conduct notable allegations to who initiated the phone calls hotel management you have three minutes l purposes of labor service is not for purposes of a commercial sex course commercial fact fact and it's an important distinction because regular service has been interpreted in the context of the t p a as including commercial sex which is of course interesting and to be the ultimate intent of mr mclean but the trafficking had occurred when his riccio was in the hotel it was a crude and she was enticed to the hotel and she was forced into the labor services that were this unwanted knowledge standard for these purposes i want to briefly address the discussion about allegations  suggesting is that the modus operandi is mr mclean faction of drugging mr riccio having her period disoriented state beating her and raping her in the in the room in order to coerce her into a commercial sex operation