boies i think we've i think we're pretty familiar with all of the facts so it's now you've had you were here before now we're back after a trial so we have matters of law and we have batters facts and the facts we have to review for claire air so let's just say i you know having been a trial judge i could have looked at all of that and everything that you said right there i think i could have satisfied every legal standard probably doing that but the district court went a different way with you and found what the baron found didn't find good faith but found no actual knowledge and then we go over to i guess is it ok if i just want to b c and we get over to t b c and then we have you know we have all of that going i am struggling with we all know now that this is a nazi looted pinky but the district court at the junctures makes findings that cite certain pieces of evidence and so i struggled with even though i probably would have decided this case differently that i'm stuck with some clear error looking at it and that how do i get past that if you're i think that if you sit with one of the we have to say ok on the facts before the court we have to say as a matter of law spanish wine that you can come to no other conclusion than that it was actual knowledge is that what that pvc itself a court recently demonstrates that where the basic issue is a question of law that is something that the court decides to go if the fundamental question is the law the district court applies to stamp asserted knowledge or highly improbable and if you look at the opinions that are here it is clear that under spanish law they are  similarly if you look to say that they have it i'm not i even if it was error i'm having a hard time this deciding why it wouldn't be termed bias because they're not really that different and if you kind of go to anyone that has been a trier of fact that you know they in less and less the standards are so different you're really dealing with what you believe at that point and the district court i v s lay didn't you know found that t b c was not in and could get a door and it didn't and then under you know just pointed to other six minutes but however much time i use i'll give you five minutes for a bottle sound now all right and cast your wine we sad that what the last one we said you have to my spa spanish it's clearly it's clear now that this is looted nazi it's just it's clear now what but the state at the time was that the facts were different as it was going to do what i want to spanish government apart moral obligation which i think that's the district judge what's your authority for the fact that the fact that they've signed a treaty informs the law here because think the spanish course should and we think the spanish course would take into account in determining whether or not this was an appropriate situation to require finding the museum was a something obvious and sure ok i think i understand i think i understand your arguments and there is to play stance that you were down wind at the at at the actual knowledge with the baron and then with the a number of actual issues but prior to that judge walther gave the plaintiff every opportunity to present evidence made good on the allegations that they had presented judge webster asked us to and we did that as this t v say and when you you know when provenance on the back shows torn labels and all of those things it certainly district court didn't say there were red flags and didn't give good sa but it seems to me a little bit of your argument is if we keep doing things like for example we don't look at any of the picture we don't we have them signed a pledge and we don't look at anything that was ninety five you know that all of that but just to all of those things really kind of removed the blood of the nazi looting it seems like that that seems problematic to me  exercised and entered into the negotiations we can find for you your honor the spanish government entered into this washington principle and the terrorism declaration which are not treaty guidelines which help me for i have myself been involved in numerous discussions with this particular council council and three councils before this work collectively together to bring forward to this court the complete story this  our work we have never shy from that story and we have shared that story and it is in that context that we have made efforts to work with counsel and also resolve this without the need of his  facts that andy and i could have decided this completely differently i'm not saying hypothetically but i don't i can't do that here i have to look at whether if there were different ways to get let's just say i had decided and i found everything against her client i think there are facts that support that and i think an appellate court would have to uphold that on the other hand judge walter looked at other knowledge he heard from thirteen witnesses analyzed three hundred and eighty five exhibits remarkably remarkably he heard from the only live witness it nine hundred and eighty eight thousand nine hundred and ninety three days action in the day they are buying into purchasing this collection which is known to the world which has never had a claim made against it before for the very purpose of bringing it into the public domain under those sufficient suspicions that he should have undertaken investigation in one thousand seven hundred so people want to maintain that good faith you need to show us what he did well the fact of the matter is we don't know bought it from a public gallery in i'm madison avenue all tend to show that he didn't have actual dollars specifically as we know many years later despite the public display there were no claims against it so while that may not  examination pointed out the baronet no time and the ability to make any decisions on and on himself and no time was he in a position to instruct the spanish government or the foundation which was really just brought in at the last minute because the owner of this art works so the structure of spanish was the way the transaction was put together while we certainly agree that the baron was in a pivotal role judge while they're examining b and i are in the complete record on the transaction why you can't look at one action that a party does an eight billion three hundred and fifty million dollars transaction involving over seven hundred dollars artworks and look at one single  a party that he doesn't know he then immediately takes it to another town and sells in that particular context certainly one can imagine perfectly imagine easily imagine that they are willfully blind and therefore we do have receipt of stolen property but in this particular situation we have to look at the nearly twenty pages of factual findings that judge walther made along with the  run i'm trying to say that i have been personally and professionally involved with this case that we have always shared all of the research it's remarkable quite candidly having worked in these cases that there was this panel was hoping we would win quite honestly honestly and i think judge walters is to be commended for i guess meticulously working through the evidence and at the end of the day showing his human side and his involved in the drafting of those treaties but those treaties all call for disrespecting the lots of different nations and historical events and how they interacted with a call for us to examine questions like what did the germans do with respect to this plane what  c courts and the court of appeals there which has a different focus of walkmans we've represented probably the national gallery of the u k in the case filed in in the state of new york my point of that is to say that the law questions all right thank you both for your very helpful argument it's always a pleasure to have wires that know about the facts and the law on their cases and we it's it's a pleasure for us this matter will now