well here rodriguez versus and and then there was an appeal with respect to another of the defendants and that appeal then went back down but the clear but just to clarify your honor and i understand what the court want understand this when i filed not at this time but because i am a attorney who practices in various jurisdictions i have something right now in and out of stooge restriction for a large company where my firm and myself may have to follow application is solely within the four corners of nineteen million thirty two thousand two hundred and eighty one clear precedent but i just want to come back for one second if i might your honor there are numerous in the plan the reasons mandating a reversal but the simplest way for this do we have sitting here in the federal court in new york over what a state court judge does with respect to the mission of attorneys in his court because there are no multiple violations of federal law counsel for the plaintiff and underlying action that petition for certiorari on his behalf there was no opportunity for me to bring as a separate independent party the federal constitutional issues with respect to the v t revocation including fraud in the court perjury by florida attorneys and other conduct that under the sun cho precedent and many other precedents around the country would mandate that the court review that bring your hoc granted there's a two property interest in that pro hoc violations of privileges immunity use the florida lawyers got a free pass and were rewarded for their misconduct i was a whistleblower representing a whistleblower with a for with regard to widespread fraud down in florida and it was clear that the court wanted to shut me out shut me down and get me out of there and there's there's again after only six days the district court dismissed the case to a sponsoring preventing additional supplementation of the record that would further show their fraud their greed just a fraud on the court that is you have three minutes for a bottle we'll hear from the other side thank morning your honor sir i'm bill stafford with the florida attorney general's office here on behalf of miami dade county circuit court judge roberto d s the only issue the only question before this court is whether the federal district court properly dismissed cases sponte i'd submit that the answer to that is a resounding yes for three principal reasons number one the case the complaint is nothing more than a request for three judge d s is immune from injunctive relief and because judicial immunity provides immunity from declaratory relief he is protected from suits under section  it's clear that those were only in the southern district of florida and the only question for before the district court on the venue issue was whether the case should be dismissed or venue transferred  the southern district in the court properly under these circumstances the court properly determined that the case should be dismissed and as the court has already pointed out there is this case the state court case has been resolved so granting the relief that requested by the defendant in this case i would suggest means that this case is is moot the only thing that  prospective injunctive relief so there is nothing respectfully there's nothing for this court to award or do our federal court to ward plaintiff in this case and the only other point that i would like to make before resting on my brief is that this case was dismissed by the circuit court arm sorry twenty thirteen which provides that for a attorney admitted in the in midan state in new york designates the appellate division clerk as agent for service of process and this is key here arising our base on the legal services rendered or offered by the attorney within the state this case was dismissed prior to the judge vs having an opportunity to object to  personal jurisdiction and i just wanted to make it point out for the record that there were certainly is no concession that person with your personal jurisdiction was obtained in the district court over judge and for the reasons discussed here today and for those set forth in my brief i would rest on my brief unless the court has any questions you make yours here there about attention a to the record the clerk of the rd department unequivocally accepted service on the appellate at that point defendant and moreover i highlight the service if the clerk accepts the filing that binds judge in florida i believe it doesn't the showing felt precedent by this court and the court of appeals decision rendered by judge littman and in the certification of that why did you file in the southern district of new york  d new york st of all under the disparity of economic positions here there would now be a possibility of a fair trial for me in florida that's number one number two the southern district has