that was within a month of the answer the prior counsel did not say this was premature the judge made findings of fact without the proper purchase she was purchasing the property with her own money there was no reason to get a loan cyrus you know stephanie was the only better who was asking to get public money to buy th property where does the government get the right to love own public money to a private individual for a private good process this is not a public purpose this is not a government building out he was not a competing applicant she was not a competing applicants for the loan of course she wasn't at the s h r a commission meeting she didn't know it was on the agenda whole process began with lives the county people told lies the ethics are a employees told lies and when those lies were brought before the court do we have a factual issue if we do we go to trial we do not make sense we don't weigh the facts we don't weigh the competing declarations version we like that is not our judicial system that's what happened here there was a decision made in the early ninety's to take the property away from the dodge family that decision was made in private without her knowledge and everything that followed afterwards was to effectuate the decision to take it away and be to give it to another private individual to profit from your  honor she had an early years situation where to make a point she didn't pay the mortgage her point was made they went back they renegotiated she paid two and a half years after that under the agreed upon modification yes it wasn't finalized but it was agreed upon the predecessor bank they accepted her payments when home savings came in the first merger bank to come in they claim to lose the file then when they found the file they returned her payments they returned the payments she was not a defaulting borrower let's not be mistaken about that and that has been carried through everywhere we go now we hear foreclosure she's been foreclosed upon why should we expect the bank to deal with her this was an all cash purchase her history or anybody's history makes no difference she has money in  hand she wanted to pay one point two million dollars they sold it for nine hundred twenty five thousand dollars there's no explanation for that other than the corruption that actually took place in the intervening years we had an opportunity to learn about a number of things that went on there is no further explanation when government officials lie to each other and lie to their commissioners and lie at board a geographic area scheduled for redevelopment this building was not a mass that you may have heard you have color pictures in there of what this property looked like it was a beautiful property profit rather than a dodge family to be the owner to make the profit that's what's going on here private taking by the governments with all the forces of the government a raid against tens i don't know where the world is coming to your honor if this case does not get back to a trial level these abuses have got to being made public and they've got to be stopped property the fact of the matter is the end is recognized by the court washington mutual made a decision that we're not going to deal with this person and the reason we're not going to deal with them because you previously  application for a loan i would like to develop this property which i don't own but i want to i want to develop this property for senior housing her proposed by her asking even a hypothetical as  talking about facts today the things that she's talking about are not facts that were established to be genuine issues of material fact to enable her to move forward or mister to move forward on any of the claims that were made in the amended complaint as far as the photographs that were submitted in evidence that there are photographs from one nine hundred ninety to one nine hundred ninety five that has nothing to do with the time period in question the county did not ever receive made on the property going back over four months before mr items actually cited the county had found over one hundred seventy rooms initially to be in violation in september and then there were two which indicated that she herself acknowledged that there were continuing violations no on the property and that she needed more time to deal with those you can only been four months since i have been original notice a violation and at that time in  appeal that's actually before the court today so i work with partic well know she was foreclosed upon they've already told you she didn't molong there and now they're citing her and complaining that she didn't clean up her property that she didn't they can't have it both ways she didn't own the property she wasn't responsible she actually despite that was trying to fix it up and was succeeding and when she was exceeding is when they had to take greater action because they needed to get her out because they wanted to have it belong to someone that would be more economically beneficial to them she did not have any bad track record she had an excellent track record and the facts are in there she ran other motels she had a history of picking up bad motels and fixing them up that's her track record there were there should have been no findings of fact that's what this problem is there's findings of fact everything in there was disputed she most certainly is very offended that her reputation has been be smirched there were a number of occasions where she didn't even appear and she didn't even make a presentation and that there were findings against her this is replete with her not having had an opportunity to be heard in court over and over that theme by the way those health and safety code violation allegations abandoning made and were the subject matter of his testimony at the trial of the criminal trial on those charges and the judge found her to be credible and him to be not credible and i am now bringing up the issue that the photographs that they were using to to indicate that that that there were some violations were doctored and were not even of the property at the time when th hundred ninety eight from someone else and she was trying to fix it up and by september she hadn't finished mixing it up and why should she be expecting it up because everyone knew it was going be totally remodeled they didn't make washington mutual r your argument to concluding well a property that previously what she's complaining about here is she was not allowed in the bid process she didn't make an offer there's copies of the offers in the record washington mutual declined her offers not for the reasons that you've heard here because the county and as they try to put pressure on them when the board of supervisors tells you either you sell to our people or we're going to condemn it and make you have an extremely expensive toxic cleanup and we're going to demolish and condemn it and you'll have nothing you get them to act and that's what happened here and we need an opportunity to prove that or think very much counsel your time has expired the case just argued will be