over and the last and trial cured any prejudice i have many experienced and it's our contention that it absolutely did not he did not have a substantial opportunity to use the one she spoke on the phone with thomas guarding these documents her file that she needed to obtain she did go and she received an e mail from thomas and three that those documents were attached to the document and the things that happened a very and a trial that this evidence should have been provided far in advance sometimes you can't begin compiling documents and went very close in the trial is a great evidence and it  as the government's arguments regarding substantial evidence and proof of mr guilt as well i just wanted to point out a couple things i kind of go through their arguments in my response rate and i wanted to address believe that to thirty five dollars in the docket and the ways in which the financial institutions which weren't even considered in the calculation and easily provided last figures to the government simply didn't do it loss and the guideline level of then he goes through all of the things that he consider including there's no question after reading all the documents that that was my understanding and that i would thank you thank you i want to talk a little bit about the to chad jesse in case i'm pronouncing that correctly from two thousand and eighteen by this court when you're looking at the juror issue in our case we have two jurors that we are firmly convinced should not have should have been kicked by the court for cause the nd one is the interesting one with its chechnyan because the facts are almost the same as our the government and their brief somehow thinks that that softens the effect i would argue that it heightens the effect also the same jurors said to the court in i'm sorry to judge and she said i would want to put my personal stuff aside but i don't honestly know if i could which i think we can all agree is equivocal in this case in matt soup when the question of putting things aside came up the jurors said m m said i would hope process and you feel you can't it's not working which you tell us answer yes in math suba almost the same question if for some reason you found out hey for emotional reasons or whatever i can't do that you could tell us answer yes but in both of those instances it is not a commitment to be fair neither juror in either case were asked can you be fair and so w this is a gentleman who twice told the district court he really didn't think he could be fair in this case at one point he said that i don't think i can and the district court asked him you don't think you can tell us that you have a tell us that isn't asking for a commitment neither one of these jurors in our case and match suba gave a commitment like that and both of them should have been gone for cause  been selected and i now don't feel comfortable i don't understand what that question means or what's what is significance yes sure and i agree  interpret it as look you're you're now in this case you're deliberating or you're listening to the evidence will you tell us if all of a sudden your bias pops up and you really you can't go into a jury trial w like that you have to go in with people that are going to commit they're going to be fair so i would suggest that this question in both chechen and matt suba is really not helpful just doesn't help us get to the bottom of whether these people will be fair we asked for attorneys or dire and we were denied it in math suba obviously it's a question that each one of the defense lawyers and probably government counsel would have asked can you be fair and fortunately  your argument that you were prejudiced the only thing that i can point to your honor is is the martinez salazar language talking about the trial court deliberately misapplying the law and that seems to me to be the to the primary challenge of issue i would point out right at the outset that the big material difference between this court's decision and then and the kids that we have here is that  prospective juror who is challenge for a cause was actually impaneled and served on the jury deliberated and voted on the board and here every juror who has a challenge for a cause by either party was remedy on appeal or they can use a primary challenge to remove the prospective juror but they can't do both and here between as i mentioned between the government from three challenges and about two minutes crabtree challenges every single one of the prospective jurors that either right here that the supreme court holds that if you define intellect to cure such an error by after sizing a printer a challenge and is subsequently convicted by a jury on which no biased jurors that he has not been deprived of any ru explanations suggested that you did not actually bias of his just instead to try to get out of jury duty with respect to and out of court credited her forthrightness and her expressed willingness to set aside her personal experiences in had to fit into that narrow exception to martinez salazar is there something in the record justifies the course reasoning and determination other than his gut feeling that i think  good just trying to get out of jury services or something on the record that would justify that and then secondly i want to go back to a question was asked of other counsel but did you  grieve that the judge didn't allow attorneys want to hear i gather that's the case but they allow questions to be submitted after he completed is what here and in those the supreme court's decision in martinez salazar clearly he says that even if there were an otherwise reversible abuse of discretion in the district court denied all of these for a cause challenge not prejudice when jurors have brief we don't believe mr bond to buy has made out of it in the prima fashion elements of the not who are brady claims here and i'm happy to get into the reasons why that is but the one i'd like to focus on st is that there's simply no reasonable possibility of prejudice under these examination and the very next day of trial after her initial testimony the court allowed that recross to go forward defense counsel proceeded to extensively question her using computer not you know as impeachment so  wins misstatement was exposed on the witness stand and the jury had the impeachment cereal in hand well before it began deliberate and under this court case law no prejudice result and no reversal is warranted where the defendant is able to expose a witness suggesting that is perjured testimony there's certainly nothing in the record suggesting that the prosecution knew it that that this was false or anyone tractor or anything like that and because of that because there is defense and recalls her to the stand for a new cross examination and the very next day of trial she was done thoroughly cross examined by this new impeachment material there was no deliberate deception of the court or the jury and any possible prejudice was cured by the defendant had a mortgage rescue conspiracy that convinced homeowners to sign over their homes with a promise that if their dad and avoid foreclosure conspirators then charge rent on the homes for a while because they could before ultimately letting the foreclosures happen anyway and certainly not going to stand here and tell you that i think this transcript reflects the platonic ideal of mr so as a sentencing hearing but the court you know it absolutely could have been clearer about its reasoning but the  ultimately resolved at a more granular level in the course of the sassing restitution and i understand also that perhaps deferring education to the restitution phase was somewhat procedurally unorthodox is your understanding of who is sending you the document it was from tom it was absolutely no reason to engage in that line of questioning if it had been clarifying that thomas did not have any p