implausible and not supported by the actual evidence is that mr younger the the witness for rushmore never said that the five methods of or the sources i should say bankruptcy informations of the policies and procedures were exclusive mr younger never said that russia would not consider any other sources nor did he say that it would in the best a gay other sources of information and i mean any evidence they did what mr moon said that the central holding supporting the unit advantages system was that they damped was knowing that it was deliberate and that it was inconsistent with the written policy procedures look at the written policy procedure  defense was based on the fact that the information they received didn't fall within the criteria with their policies and they purposely ignored it and didn't act on it even though they might of they told not to and that's what spurred the bankruptcy set the there's no question that there was an automatic stay violation and we don't contest that on this appeal that the the problem that we wish appellate review for is the bankruptcy court conclusion that bad that was deliberate that it was the result of reckless indifference to the rights of the of the bar owners and that's the part where there is no support in the evidence for that concluded and so it would steer younger explained is that when information comes in any of those calls actually requested pa i think because there was no the act to obtain possession a property of the estate or property from the estate what acted they other than the call that they take to possess or obtain possession right but he was home and he opened and then he had to inform her and that created marital strife also he would be within his own of the interest of this day to be an odd situation that a debtor can't use to stay in a bankruptcy case i also mentioned age robinson the unusual circumstances to a ship there's no relationship closer than a husband and wife to become one and in this situation nothing's more glaring than that but i also put out that moving on the damages are reasonable and i want to make a note about the punitive damages it wasn't two to one it's really two dollars to one dollar point than if you add in the attorney's fees as actual damages they came out later on that they had this list five ways to know in their witness testify he mr moon was unauthorized to give them that information now they get they will our procedures are beyond those five ways but obviously mr moon was not authorized and he wasn't one of those leagues and they stuck to it they held their position from the beginning and want to remember as they called the moon's house at their home number this wasn't a random person going in and say it is a bankruptcy here watch out no they kept calling the moon house hundreds of times and then the moon tells the boy at least on occasions he told them about the bankruptcy now they'll say that's not in our records so we pointed out that not every call is listed in their records that came out of trial any other questions regarding the you know just to clarify it what i understand your argument is that they they had a policy that seemingly was quite bold but their actual action demonstrated that they stuck to a policy even in the face of actual knowledge they refused to stop their conduct because they could discount that particular information under their policies so they said one thing but they acted in a different way and that's why they understood that a fair statement of what you're argu yes exactly said much better than i could not avoid the two point two if the judge said they had an unwritten policy of who they would accept information from and it will was a rogue employee defends it was hey this is our policy is an authorized we're not going to take action on it in terms of the cross appeal there's very reason why the decision of the bankruptcy court should be reverse notice they should have checked into it so in terms of the continuing stay violation le grand is the case i would point to judge klein's case and i won't beat it to death because i'm sure you're aware of it basically the same acts continue the violated the stay after the destroyer has been heard and we're arguing now to continue list a violation and the court should have awarded damages from the point of the discharge injunction on as part of the stay while ation the course specifically said i'm going to cut down the one thousand two hundred and forty day six hundred and forty eight days until the discharge blindness in the court brought that up numerous times they didn't use the word willful blindness but the court basically said that several times in fact it was so clear rushmore as opening brief list willful blindness that in times we were willfully blind so the implication was rushmore willfully blinded itself not only to the state but to the destroyed and if that's the case then the discharge date should have been considered the date it was entered and corporate award damages from their nd they were also on constructive notice after knowing of the steady and the bankruptcy they should have looked into it they had more than two and a half years of two years to do something instead of they  to their practice he's authorized let's just keep calling and sending preston getting back to your st great in a situation then where the lender has turned a blind eye to the  specifically said willful blindness can still be considered actual knowledge and so i'm saying using doubt standard the courts held there was a woeful blindness without using that word then they would have known of the destroyed on that day and the scream but also in that opinion said constructive knowledge can be actual knowledge you haven't a duty to look into stuff so there are two bases the court could have awarded damages by finding the dish shortage knowledge was on the dish or the was entered based on those two prongs but instead the court just said i don't know the date because mr moon didn't know the date so i'm not going to war damages i'm saying that's the wrong standard you hold in essence is willful blindness so that can be considered actual knowledge of the dish charge and the same thing with constructive knowledge in terms of the discharge being entered as opposed to a case being dismissed where you just look at sun quest there are only just the one hundred and thirty three months and the damages went on for four years after and so this will be no different and if it was discharged in the moon shouldn't be penalize forgetting it is charging completing their pain plan and that's what we're doing because if we set the stage continue after the dish charge in this case because of the same acts were being done case there is that there's a rd share here and it is the world's attorney who didn't get the right address didn't call the lender didn't do much of anything in the case how does that factor into the  the five or six mailings that were made at the bankruptcy court level i want to say that the bankruptcy attorney there you know that the five different addresses it's hard to believe they didn't get any of them but that's subject for a different case down the road in this but the idea is they don't always they they knew virtually there was a bankruptcy and so i don't think the letters in the notice played into it that i'm having trouble putting your argument in the context of our limited range of motion on some of these issues on the peel you know the the record seems to me is not lacking in support for the conclusions that the bankruptcy judge reached you  know he could have reached a different conclusion he simply didn't know number one and number two eat you know you want him to sanction less based on sort of an testified in so we understand that that there is a limitation there but even within that even within that there standard i think the court should reverse and that's that's my minute thank you it's great and you have anything you wish to yes