its reliance on unsupported defense legal theories an argument that are only inconsistent with this court case law should be reversed st on the issue of whether the documents that allison aides stole  trial record st when the district court cited none of the government witnesses could simply ascribe a value to living wills when asked that's incorrect not only to the director of the office a complex financial institutions cost twenty seven million dollars or more the cost of them to produce and provide to the state additional weight we argued a number of factors that the jury could reasonably considered as market value and that's really what i'm interesting with respect to living will and by chance or as we are not by chance the job she was applying for at deutsche bank was in resolution planning and in preparation of living wills and so she went right to the source of what anyone would presume you would she had to take the documents with her because she knew she would be needing the g s t within twenty four hours and so she was planning to have these materials as a private citizen not as annette yes your government wait she was accepted at least taking them rt can recognize that there are certain types of highly confidential information and this is somewhat different than in plays that frankly where there was a decision went from a nation of the centers for medicare medicaid kept secret and it's the government and on it meaning within this minutes after it's highly important government information i think that would address exactly the really egregious situation that at it's here let me that where the government can establish the one thousand dollars threshold which again in any of these particular cases is not meant to say we just saw a one thousand dollars there's and that's the most important point that the precise value a particular document of stone is the important point it's really a test of seriousness the one thousand dollars threshold which is a threshold that applies across a number of statutes is about the seriousness of what is stored there is a case out of the eight circuit w important government function which in that case would be the prosecution case so the government as it did here can come forward with an explanation about why material or information or document or tax return as a significant  carrying out its function i think that the jury underwrote is is fairly entitled to consider that in making the value judgment man just ask you i know you are out of time but i want to just ask a couple of questions that are really to respond to judge livingston question to say that yes under the government's theory it would allow any mishandling that is taking home as regulatory documents filed by any strict limited monetary definition of value which includes relevant here market value or cost price now the government seems to just argue value basically value as as just a right that as the court found that is the there was only the cost to the lawyers to be to the banks their lawyers fees that wasn't the cost to the government and cost trace as all the cases i've cited in my brief show means the cost to the owner the cost to acquire the property and that makes sense because six hundred and forty nine is really intended to deal with property that the government has bought or could sell in all of the cases all of the case here is a mansion that somebody would actually pay for this having the government put on no evidence that anybody would be interested in paying for this so i we have to break it down it's got to be either cost price the market value it can't be kind of it believed that these had any value let me just remind the quite that easy were these memos were old outdated superseded bills from years before it was there was no evidence that anybody would want to buy them in fact one of the bank witnesses job would would help them get the job but it wasn't clear it was general knowledge of how these things work not the specifics of any living well so no there was no evidence was that this would not be interested if the government thought that somebody else might be case ever holding that cost price is the cost that some private property spent to file documents that the government concentrates in the case on the cases i've cited in my brief is the cost that the owner spent  and that was what congress understood these are cases that were cases established in a bush at the time the statute was passed that cost price is the price the owner pays to acquire the goods and the owner disclosure maybe there were three factors that the courts found established serious interference only one was the confident strong interest in confidentiality the other two were based on the disclosure of the intended or probably intended to use this to get a job doing to bank was just a theory and it was based solely on one phone call and she probably got thousands of phone calls she put in twenty applications to but to each bank she was applying to every well your honor if missing from the timing is that on the very day not the next day but on the very day she downloaded and it was only a portion of the deutsche bank it was only a summary of the executive summary portion of the bank document  just before that and that's in the ten and that and the record that were made at that one fish in the one fifties but she she had just downloaded the wells fargo resolution plan that she was assigned to testimony in the record is that she was assigned to the wells fargo global corporation or web international cooperation section that required me to understand foreign banks issues issues facing banks and other jurisdictions she had to do a report on that and announce s and right to she downloaded that that when she was assigned to she then downloaded question just a summary of the doing to ban document which she wasn't allowed to access and you know that's another issue that the government suggest that that that is closer to the term from going to bank as i said she applied to many banks submitted hundreds of applications she was probably on the phone with recruiters every day but this one was plucked out as this must be it it's not this idea that the government needs to have paid for something in order for it to have value is directly contrary to case law for this circuit and every other circuit gerard where the stored information in the one thousand nine hundred and seventy s the seminal case judge friendly said more than fifty years ago this is not something that is meat meat this is something we can clearly entrust to a jury to decide if something is of such significance delany conviction is warranted here this was a case where these documents were out there were millions and millions of dollars or absolutely nothing and what the jury decided wasn't these documents consistent with the evidence both of them bait witnesses from director dealt then from the security supervisory information communications that depend on secrecy and the trust that banks are required to have the regulators will keep their information secret give it is what provides the banks incentive to be truthful and provide the regulators the information and also know that it could be used if you know hopefully we'll never need it but for a terrible reason that the bank had to be resolved or had to go into bankruptcy and so was the list to showing us that when intent is absolutely clear when the nature of the information is so i would confidential that waiting could pose an extreme risk to a financial industry or some us economy as a whole well as your study s i don't i don't think that rely on simply runs that are serious interference at the end of the day should should you know if trump card over all of the additional actors i will say however that in that situation w