fourteen when she stepped into an open battle in a mobile home we believe that the center for friendly holdings is the property the fund and in this case however but by the midwest home rentals is is the owner of the trailer in the property upon which the plaintiff was injured that's the case because st part of the search of the property reveals that santa for a family holdings l l c the knowledgeable about from the insurance company of that that was in fact the the correct home defendant and then we proceeded to negotiate with the insurance company and they offered money on this case before we file purchased the trailer home which was called tries daughter in two thousand and thirteen and that the purchase included all the trailers that were then on the up on the property there is there's no evidence in i that the incident happened that way as well so and also construct his notice on based on the fact that the two companies share the same law firm that the two companies share the same the same people thomas and for him brian geller basically control on both both properties both companies and that the presence of of a huge number of related in our brief or read said sanford deny that it own operated maintain control of the premises in response to paragraph three of how i want to play to some point i think that should have been a reference to our rd affirmative defense where we denied that we had violated any duty and that if any duty had been violated it was of other parties that being said i think this is actually a pretty straightforward and easy case the plate of names the wrong party and throughout discovery sanford family holdings repeatedly said we did not own this trail when it became clear through discovery that she felt inside the home itself there was no fall outside three they objected that sanford family homes admittedly misstating their name as a typo did not own the property but they never at any time in this case of the center for family homes own this property at the time between those two periods it may have been in the inventory of sanford family holdings but it would have been transferred to midwest home rentals before april two thousand and fourteen when the plaintiff in response to the plaintiff's response to or reply for their response we actually went and polled the title which shows that it was transferred from janet where over its attash is exhibit b to our reply and shows the title transferred directly from her or the prior owner to  midwest home rentals it didn't even actually go through sanford family holdings but even if it had testimony was clear that it had already moved to midwest home runnels that we in response to the point is request transferred to midwest home runnels or that it was in the inventory of midwest home rentals the point of specifically requested those depositions to confirm that it was actually on my midwest home reynolds still the plaintiff did nothing the plaintiff and that time could have filed a motion to amend her complaint she never filed that motion your honor was correct when asked if they ever did they never filed that motion to actually file an amended complaint and their references at this after the point to file their response say without any basis saying that they thought the title would have gone to center for family holdings we actually hold it and produced it to the plaintiff and it's attached to a client that's one of the things p said we should a producer earlier but it was never actually center for my holdings dr no we also hold the tax documents to show that the public tax documents that showed that general or over paid the taxes and then midwest b and pay the taxes sanford family holdings never paid the taxes for these are all things that the plaintiff could have pulled herself their public records which she didn't do that before she called her complaint and then during discovery when it repeatedly pointed out to her that midwest  now is the proper owner of this trailer home as opposed to the land on which is this that's where she found when she did this our title search she found out that christ aristide's is owned by santa for a family holies that owned the land but the actual trailer that sits on the land and who is responsible for the word is midwest runnels and at no point did she ever attempt to actually bring that party in the case for this reference to their response to our motion for summary judgment being a motion for leave to file an amended complaint one year on was crime he doesn't attach the proposed minute pleadings which if that's not part of the record there was nothing for the circuit court even to rule to review and the plaintiffs only reference and i wrote down exactly what she said was if this court finds that messina will sue the wrong entity it must allow her to refile complaint naming midwest home reynolds as a defendant that would only happen if the court has already entered summary judgment it's a request for post judgment relief to add a new party which again the case was clear you do know party has a right to host judgment adn party in the case the circuit court looked at all the evidence in the skis and found that as a fact midwest home rental only this properly only this trailer at the time the fourteen days to reply and then another seven to fourteen days we actually hear so that you hear courtesy copies of the court things of that nature but we had produced it to them before the actual summary judgment here they still in response to our reply could have filed a motion for need to add a new party which they never did at any point throughout this entire case  under either statue and they never actually attached the proposed amendments leading in this court something to actually read you in regards to piercing the corporate veil i still don't really understand why they're making that argument as you are pointed out that's really a way to go after the shareholders the point of own briefing in the underlying case pointed out there's a lemon factors that you look at to determine what pierce the corporate we only made arguments on two and plaintiff's argument is that well the only reason these corporations can exist is a fraud brian gallagher testified in his deposition as to what the reason was there is a in requirements in the mobile home field that required the landowner and the actual owner of the manufactured home to be separate entities for lending purposes that's why these corporations were set up and it's not as talk my client is santa for family holdings i'm assuming that if the court had done that then they would be out of the case or we still would have filed the same summary judgment motion there'd still be the same evidence that san family holdings would not have owned the property as to whether they would have been prejudiced in the west i can't speak to that because i'm not representing midwest in this case and i don't know that i would be brought in to represent them considering the factual background of this case but the simple fact is that they didn't do that and we don't know if the court would have even given them leave to do it because as i said in their motion for leave they do have to address certain things they have to say why this proposed meyer standing at this testimony was that he wasn't entirely he testified that they would have bought all that together and that it definitely would have been transferred if it had ever been in the possession of santa for family holdings it would have been transferred before property did two representatives from midwest themselves said that this was in the inventory of midwest at the time that she allegedly fell that and that title transfer