know that if they want someone else to come in and argue on the next date that they have to be here and they have filed a written response to the motion but otherwise they will not be permitted and now is there move to withdraw because these irreconcilable differences so you need to have someone tell us now what would've happened had this gone the way you wanted it to have the judge said ok you want to withdraw i'm back to being again the motion it confirms to dish will sell say you know well i'm not going to do that i'm going to do what coun and that there was a reason questions of material fact that were raised based on your your briefs not that i think you have a valid argument that would help improve am all right so let's talk about foreclosures have we had in illinois in the last ten years most of those corporations were registered in other states they were never required to register to do business because of the com it in reference to the cases i was talking about right versus golden rule insurance finding that an affidavit was signed by turney is deficient for purposes of rule one ninety one there's another case under one ninety one and then use them easier for purposes of summary judgment or easter arguing as a counter affidavit that can be used in this particular i mean but i understand your position you're saying it was a each page and they lined up with a whole bunch around the so so they're basically saying that it was attacked by way of  talking about now about whether or not there was appropriate standing is something that absolutely could have been raised in response to the summary judgment was released here was a run to run for david not a response so we continue to hear about m mr ferret's testimony in his affidavit that was in conjunction with a motion to extend the time to respond to the motion for summary judgment not efficient response to the motion at the time which judge i know made these determinations right through all of the reasons why the one ninety one p d f for david and motion should have been rejected by the clerk and one of those was specifically these are legal arguments that absolutely could have been raised in a response nothing precluded one sixteen west hubbard from responding to the motion for summary judgment and protests updating him and actually hearing i mean these legal affirmative defenses as to standing and failing to register and so again the isn't anything that was going to come from this additional scot free being sought by way of the depositions that were going to change anything we agreed we agreed that there was not a state with the last alliance we agreed that  methods in which and i documented attached to a no is considered to be a real proof in the record now that we don't believe what you're saying course but in the trial court is there a record of a paper it's the actual affidavit  the pendency of the case which i didn't want to do so to circumvent bad i brought in the originals so that we would actually kind of take this issue out of the equation because i believe there are significant number of cases that proof of possession of the we're talking about stamping these arguments we're missing the point that all we're focusing here is i'm standing this is a very large amount of money at issue no one's ever saying that some of the prodi is seeking to crack down they know i mean no one  true because this is a liberal issue that he could have raised in response to the motion for summary judgment and chose not to so additional depositions on the issue wouldn't have mattered and we also raised that exact issue that an attorney affidavit can't be nothing was done in that time actually ever asked for a deposition or to discover it wasn't until this came out and as you see it was the day before the present of motion that i got the discovery and answered it twenty four hours verified produced documents then again they waited for the full forty days set aside for their briefing schedule to then ask for another extension of time so it does go back to the bigger issue of delay and this was a it's a rouse case as i said and unfortunately there are the foreclosure  take a long time and the situation you were prejudice to judge understood that with the taxes being redeemed for nine hundred thousand dollars so the damage that was accruing consistently goes to my client and to the defendant mr pertains to deficiency judgment was another thing the judge took into account as to all these things because the truth this was not a situation it was a pretty straightforward case in which you know there was we never would claim the principal amount was any different than it was from the first day things like that they never said they had made payments dating credit get credit for all the typical normal factual issues that you may see raised in a situation like this only so i was just stapled to the a line shoe and the  that is not a direct oh in my case it's a court case in point on this issue the business corporations act is specifically i'm right saying that if you conduct interstate commerce you don't have to register your business sel just not have that exact same provision i do knowledge that however the entire situation if the same reasoning applies to l l siac that conducts interstate commerce that they should not have to made everything for a have an issue but there's a series of cases and we didn't really get into this in a brief that says that's a fixable thing you just register so you know we would go back i guess we would register and then that would be taken out of outside that you did for that purdy are relevant as it pertains to whether or not be agents actions can be imputed to the principle here from the attorney standpoint i represent fifty other clients it doesn't mean my actions in relation to my working for those other fifty clients are imputed to that one other agent so they need to focus their energies solely on this particular issue and they'd never get around the fact that this entity holds loans and night different states as identified in the actual