purposes that were not properly considered or ordinarily i and i suspect all who practice before this for a regular basis tend to read with my you argue and not focus on argument of the other urging even when raised in response but i'm going to probably violent the rules taught in mock trial classes and start with an argument raised by the state and worker because i think it  which the post pravin motion was filed three and a half years all sides in the instant case the motion was filed less than thirty days following the sentencing the trial court obviously retains jurisdiction for more than thirty days following the jury's verdict and before the sentencing hearing very typically the sentencing hearing is set for more than thirty days following yuri's verdict so  and said that at the sentencing hearing it was assumed all along that there was the order in which counsels we see that there would be a sentencing hearing in the post trial while in so if for no other reason than fairness to the defendant given that the error was that trial or we would suggest that in fact this court has jurisdiction that the trial court had jurisdiction in that that air would not be held against the defendant assuming that this court and groupies that the order in the trial court had jurisdiction then i think that that provides an obvious answer to the question of whether the twenty ten cook county conviction montgomery occurred this time when judgment if you have to be rendered in the book and there had been a plea of guilty but it was within the thirty day period for filing a motion to withdraw guilty there had not been a sentencing hearing and therefore there is no conviction certainly there is no final judgment that could be allowed or for the state has already conceded in its free that another conviction which occurred in the federal case that was not true to be within the time year ten year time period a lot by the state has conceded that that conviction was improperly so at this point then the defendant would argue that there are two invalid convictions out of three and particularly in a case where where the defendant's credibility is going to be absolutely necessary open title can be used to perpetuate from a life in that in very early on the trial court noted in the state conceded that there wasn't an overlap between stolen cars that were common property in the open and the open titles that that were found in this case didn't relate to the cars that were found on the property so there were different questions between an open title and stolen motor vehicle but else then he would be able to perpetuate criminal activity but there was no showing of any sort of criminal activity of that nature and another manner in which it was specified that these open titles dealership and transfer the titles in that way are matched description if not then the vehicle identification but again this was an older car described by council at one time as having seen better days and being an art that could not be mistaken as a new car the various ways that were shown to be allowed for the use of criminal purposes any of the questions that have to be considered by the jury and as it's been argued that this was done for merit but the cases in which a narrative purpose is is found  consider proper is always words of art of the story and part of the explanation and it times the defendant specifically to the criminal acts that are alleged that didn't occurrence and instead there was just this possibility if there is in different ways that could happen and when the expert witness from the state then said it's open titles and crime go hand in hand it's very easy for the jury then to reach that conclusion even though there's been nothing to show that there was criminal activity aside from that which is alleged in his essay the open title which the state contended had to be related to criminal activity and used in that fashion and because the times to ten it was evidence of other crimes was not properly admitted in this case and for those reasons we would ask that the or it must be filed within thirty days of the order disposing of a timely filed motion against the judgment that didn't happen here either the judgment was the verdict on december first two thousand and eleven therefore the post promotion need to be filed in thirty days or that have i was i was a little i was discussing with the mr michael we were kind of anticipating what the panels were going to look like and if they would be completely separate because the issues by and large are kind of separate and they're a little different but obviously i was i was wrong therefore trooper jennings stated that you believe that the identity was being concealed in that vehicle second built was a black mercedes which was stolen their vehicle was the red b m w which clearly indicated fraud was public vin and the true vin was reported to have come from his stolen car and the four of course the issue in this case were for open titles as counsel i mentioned the before with titles pertaining to vehicles that were not found on the property and but the people would submit that it is relatively clear that this gentleman is in the business of of possessing and selling fraudulent fake stolen vehicles and titles and that this is this is a continuing narrative of criminal conduct and i believe i can make absolutely this narrative of conduct in one sentence as i tried to do my brief these four open titles which omitted he information that needs to be on a title when you are in possession of such title these four open titles were following a pile of forty titles which were charge him with absolutely everything that was found at his house that i don't know why they didn't do it but the fact is these these four vehicles information about these four vehicles was in the intent knowledge in the absence of mistake and i believe clearly for these these four vehicles for information on these four vehicles to be and they did they need to be exactly pertaining to that the charge crimes i believe again the continuing narrative theory of law is that if know if you are clearly in the in the business or the charge of crimes and if this other evidence is all interconnected that's the word the trial judge used that they are admissible for finding that this is not a mistake and that he had knowledge of these titles based on knowledge of the cars he admitted that he didn't name here and that i know your honor but i think that's actually more support than the people's case because the  discussed with the fan and he met with him at the at the jail and talked with him and he gave completely incredible explanations about where he got these titles he said that two of them were vehicles that were reposed but yet on these mug it's all connected this guy is really in the business of handling him if he even said that he's up he has all these cards because he auctions them for dealers but he doesn't have a license to do that choose to prosecute but you can't bring in the whole bain you know alleged any other bags you have to prove the cases you charge him with and if you don't charge him with those other crimes then the rules are the other i'm absolutely ones which are the mission of the prior convictions for pitchman i don't her people do acknowledge that the the they did not present the type of criteria that you need to for the one thousand nine hundred nine federal convictions regarding whether or not occurred within the ten year window but the people some of the no reversible error occurred here because there were still two valid convictions to be used for peace and one is clearly the two thousand for don't consider actions has the judgment includes the sentence that's not in the bay i'm not fighting that but a conviction in the sense or different a judgment is not a conviction a conviction for purposes of impeachment seems to be pretty specific for normally you will see matter set more than thirty days out so that there is time for the bio and that's why it concerns me a little bit that the state now argues well if it if the notice of appeal isn't state would argue that anybody would argue that the trial court loses jurisdiction thirty days following the finding by a juror because obviously sentencing is part and parcel to convict and those looking proving that charge which is before the people or rather than proving that it happened in other areas the defendant did it before so he must be guilty is a policy that's absolutely been rejected by this in the courts and we would until our june