in trying to get recess we redress excuse me we found ourselves in a thicket of procedural technicalities which frankly are the let's leave in the way of two things i would like to reconsider be on the twenty eight dollars days that rule fifty nine dollars he alone knows and again she was pro se at the time and she had no way of knowing that this was going to deprive the scored of jurisdiction came from the old equity rules it's not derived from a statute and so this is a court a court of bills to rule this is not an act of congress that says if you don't file that there were a number of documents under seal that she needed and so for that reason we would argue that this court should entertain the appeal with respect to the summary judgment being granted as well as the denial of  the court in dealing with the the question of for a st amendment retaliation the court starts to look at the credibility of the defendant  to extend that deadline a timely rule fifty nine motion does so but your clients will fifty nine dollars motion was not time so the only thing that's before us is the post judgment motion this was a summary that's just normal review that's a normal review standard when an issue that's been far fitted for this this is a civil case you're asking for relief from the judgments the only basis for granting relief from the judge would be under sixty be so you have to fit your arguments within the requirements of rule six  admitted that that the defendant took action against mr endacott because of the content of her speech and he had proceeded to say there was no in other words a wholesale disregard misapplication or failure to recognize conform to a defendant stand by their position taken in the brief and further stand by their compliance with cannot expand alter or dictate the reviewing court's jurisdiction taking a step back here the trial court docket is replete with instances of extensions failure to appear failures to meet deadlines time and time again the trial court nonetheless accommodated plaintiffs now playing it was only on represented for twelve months of the six year lifetime of this case so for plaintiff to contend that her or her indigent status should be considered plaintiff nonetheless spends the majority of her brief asking this court to review the order granting defendant's motion for summary judgment though the notice of appeal was not filed until seven months after the deadline she predicates her argument on the unique circumstances court reiterated that the unique circumstances doctrine is illegitimate congress specifically limited the amount of time by which a district court can extend the notice of appeal period in section twenty one dollars of seven of the united states code a limitation that goes to the very heart of our separation of powers if this court were to allow plaintiff to have the order granting the motion for summary judgment reviewed today such a ruling would contravene the bounds of appellate jurisdiction established by congress and undermine a century's worth of precedent and practice regarding time limitations on appeals the essence of rule for a is finality of judgment the time limitation is specific and unequivocal it's not a technicality while rule for main work misfortune in its application it is an overriding principle which demand enforcement no exceptions no accommodations so what's left since there is no jurisdiction for review of the order granting mode the motion for summary judgment the question turns to to the only issue on appeal today which is the order denying plaintiff's motion to reconsider and the standard of judgment is abuse of discretion in other words no reasonable person for free with the decision of the trial court this court must have a definite firm conviction that the trial court committed a blatant error of judgment and is convinced firmly that the decision lies beyond the pale of reasonable justification now the record on appeal overwhelmingly supports the trial court's proper finding that play to fail to establish a manifest error of law in denying the motion to reconsider that's the rule fifty nine dollars standard this can only be construed as a rule sixteen no motion so we shouldn't even be considering a rule fifty nine standard i agree with you it's a very steep standard in both instances but right steve b has specific baskets of relief into which the case must court's attention to one single mistake or fraud or anything and sixty one refers to the parties excusable neglect or mistake in in his finding that the plaintiff contends that the trial court failed to consider the fourteen day notice requirement which was addressed ad nauseum at the summary judgment stage and during the motion to reconsider not a single indication the manifest error is is is present in the in the letter that's a state law requirement that's not a constitutional violation absolutely plaintiff's claims arose under the th amendment which does not create remedies for violations of state or local law so i agree with the honor in adhering to the th circuit the precedent the trial court held that whether a search is reasonable within the meaning of the th amendment has never depended upon the laws of a particular state the trial court properly found that no clearly established statutory or constitutional right which a reasonable person would have been aware was violated as any such right was not established in a particular i sense judge probably judge we properly found that the th th amendment were not sufficiently clear such that a reasonable social worker would have recognized she was engaging in an unreasonable search by entering the foster home to remove the child the th circuit has noted that there is an absence of compelling authority for holding a grandparents for holding the grandparents without permanency custody for without permanent custody rights and liberty interest under the pew process clause in associating with the grandchildren  it should be noted that casey was and remain a ward of the state plaintiff never had custody of casey much less a reasonable expectation to continue caring for casey plain of consented in writing to care for a ward of the state plaintiff knowingly assumed a contractual relationship with the state of illinois to be a temporary caregiver that the trial court recognized that plaintiff violated both her foster parent and relative caregiver agreement repeatedly by prohibiting visits failing to bring casey to court and prohibiting for him and not reporting to the c f s regarding doctor appointment now with respect to the nd contention in pla motion to reconsider she next complains that judge that johnson's testimony constituted an admission but the trial court properly relied on this court's precedent in holding that temporal proximity alone is insufficient this court was satisfied in finding that dissatisfaction with counsel is not enough to show any of the requirements under rule fifty nine or sixty any other finding by julie would have contravene