widely divergent in terms of you know their ability to to pursue those claims example i think with respect to reduction in that the group of wonderful plaintiffs are people who just happen to use the county hospital system some of these clinics taillight we don't quite know the facts that lead to the sequence that but he ends up the subject of the tell called by the time it's all over he's unconscious on the ground having been injured he then brings a suit seeking not called well on there on those facts i can understand that because i mean what is he his one person out of the entire population once angeles one of the chances of him actually being subject to that again that's not what's going on here we have people who  just too speculative here these people are going to use these services the question is and what's going to be the effect of this on the services they receive and we're going to factual fine of the services are going to be worse but if you look at the name the way these people use if you say these are people who may just have to they don't dispute that i think we're the bone of contention here is you're talking about a general impact on the system but you can't there's no link can be drawn between that general impact and the individual plaintiffs and in my contentions the supreme court case look the county has in place these policies and you know that's the question that's what they're required to do is to have them in place this is not like cook where you have that very specific very narrow type of claim for a particular service and i think that when you measure the county's liability your obligation rather under the under the state statutes is that the requirement to provide subsystems care we have a strategic plan in place  to provide discharge planning it is just have to keep branch open so that's something where the injunction self is really tailored to the nature of that legal claim and again as well as things that we talk about specific in title meant to relieve measure against  will deal with state law issues in this case i expect to be very brief your honor i want to talk very quickly about the the stand in question that counsel spoke about a credible threat have we shown a significant risk of the injury that's required you don't have to wait for the injury to actually occur in cases like the delta water agency case those are environmental cases in the court says look you don't need to have to wait for  the law to be affected in such a way that there is damage to the environment certainly in a case involving the sorts of health care needs in states that are involved in this case no different standard should apply i was planning your honor to read the very sections that the court did refer to with respect to paragraph seventeen and eighteen of the just records findings hence noted in this matter that while counsel makes pretty much the same argument that  county professionals who talked about the sort of harms that were that were being exhibited in fact there were five studies most of them county commissioner county committed that supported the court's findings but i want to enlarge just a moment because i and under federal law the argument under federal law is as i understand it the medicaid requires an adequate plan for discharge i mean that's the argument right that is that's correct rangel yes correct that there has to be a  question with respect to standing question with respect to federal law is somewhat tighter or more hokus and with respect to state law was probably enough listen under state law i mean i'm delayed and therefore my services are being adversely affected do we have an individual clearly means with them under the care of that particular facility itself with i have to be in that bed the the regulations the statute itself say that more from a common sense nature once an institution takes over primary care of an individual that institution if it's go members of the association in this particular instance require continuing health care from the facilities including rancho los a because one one final point that with no showing the people didn't even live in the community they could show that because of that zoning ordinance that that would somehow affect the private individual to build particular housing in this case whether you're talking redress ability we're talking traceability whether you're trying to injury in fact the story is the county the candie's are county facilities and in paragraph twelve through eighteen of the district court's findings the court specifically finds that that's what makes this case so unique that if this if these facilities are closed quoting from sit with paragraph sixteen the county will not be able to meet the needs of the county indigent population fifteen the county hospital system is not equipped to absorb the additional patients from rancho and l system that we're talking about this isn't just of the straw that broke the camel's back this is removing all the orthopedist they are completely removing those portions of the system that are necessary for appropriate emergency trauma and  discretion that counties have when they administer their seventeen thousand and ten thousand programs yes the counties have discretion but they must exercise discretion only within six pound raise and the county court must stri seventeen thousand and one to adopt formal written waiting time standards when it already had waiting time standards was complying with those waiting time standards and the patience necking had no argument or problem with the waiting time approximately seventy medical professionals many of them working for the county all unanimous on the harm that would befall if these closures went through including overwhelming the private and public emergency rooms a shortage of beds throughout incredible board that could justify its decision to cut no single person testified that the county would somehow be able to provide subsistence medical care much less any appropriate level of medical care should these closures was said previously the budget deficit is not going to be reached until two thousand and five two thousand and six but in july of two thousand and three after the injunction was issued a county discovered that it had underestimated the amount of its budget surplus by another hundred million dollars so it's always been of dubious reliability their projections third your honor their claims of fiscal describes ignore some of the evidence which was within the record with regard to the higher costs that would result cuts go through higher costs resulting from longer nations from patients whose conditions worsen because they couldn't get rehab care malpractise claims and other other reasons for that reason the district court found that the public interest heavily favor the granting of this injunction because if these costs went through patients especially los angeles county needing trauma care would be endangered and particular plant plaintiffs who is showing a lack of discharge planning services with respect to their individual case and as i noted the only person that appears to qualify was a plaintiff class with a current inpatient that would be eligible under those