all counsel now that if you're not familiar with the practices in the ninth circuit the clock in front of you tells you how much time you have left if you wish to reserve time for rebuttal it is your responsibility to monitor your own time when the red light comes on you're out of as it is i think wishful thinking because the one hundred fifty days starts the time to appeal in the absence of a separate of the separate document of course in this case we've got the added complexity of the would you just just give me just a very very specifically what the minimum contacts are with arizona that the that you put into play here the minimum context to be looked at in two ways the actual action don't think it does actually i'm i wouldn't i don't see how conceptually it does and they went into the form state final delete and that i think is an action in the states where they were taking two look at the actual facts if you will in terms of the effect of the filing of what i understand to be an abstract of judgment i think th that she recorded her judgment in maricopa county and that there were letters and phone calls between counsel for the parties in negotiation of the payment of the judgment the lower court correctly analyzed the situation and the first case which is the dandiest versus ziff davis publishing is right on point that's an arizona court of appeals cases that specifically held that the domestication of the foreign judgment along with the client that is different that's not what happened here do you agree that the effects test applies or do you disagree with the application of the color test or i think i think the last clear that the the effects test does apply  case the facts in that case your honor i can't distinguish the facts but in the calder case which is what mr macon relies upon that is where we have the national enquirer publishing six hundred thousand copies of defamatory material in california in the form in the form of the state so you have a much greater future jackson in the form state in that case can you hear and that is easily distinguishable but you still have to go back to what the what the facts and with the actions were taken and if we if we look and again this is the only argument that was made below the effects test no it wasn't mentioned by name does it have to be probably not but it sure needs be enough to be developed enough so the trial court can pass on the issue and you've read her decision if you've read the briefs there was no mention of probably eighty percent of what mr macon is now trying to bring before this do with the additional fact alleged by mr macon that that's your client's attempt to collect money in addition to the record of judgment in the that now whether that's justified or not i don't i don't want to get into said i believe the judgment is x my client's attorney said we believe the judgment is why you need to pay it they came to a standstill nothing happened after that had mr mayne can actually take in some formal action to have the whether it be declaratory relief a a hearing it would have been a ten minute hearing your honor to bring the parties together under the cause a number that was domesticated in arizona and ha court commissioner or a judge decide here's what is going on this judgment paid or don't you did you have any mechanism for enforcing that yourself for bringing for bringing this to a head so you could have that ten minute hearing initiated a cornishman action it would have been under the cost number that the domesticated judgment falls under you can file a motion you can file a motion to compel you can file and they could have held it in a garnishment objection proceeding what's the amount here's a likely would've happened let's say it was a bank account with eighty thousand dollars in we attached the bank account and the garnishment statue at that point he has a right understand to object and objection hearing is held then we can decide what the amount is or alternatively the bank can say no we're not seizing all of these amounts because the face your judgment isn't for seventy nine thousand dollars it's for thirty six thousand dollars this is all we're going pursuant to the writ of garnishment until a judge tells us we need to do otherwise so there are it's hard to answer the question but no you can't simply throw in additional songs to your to your judgment if it's not on the judgment now whether or the judgment they have in nevada well there's no question that the additional negotiations that went on between the parties is an additional action to the domestication yes and the wreck and the letters are in the record and i think that's an accurate hostage it's a little bit of an extortion at least it could be characterized that way that says well now we not only want the satisfaction of the better judgment but you put us to a lot of trouble and we want our attorneys fees and we want to dish well amounts you know adding up to whatever it was thirty thousand dollars and you're going to pay that out of the proceeds is well over not going to let the lien go why isn't that an additional action it is an additional action it's not a sufficient additional action why isn't it sufficient already is again all it is is a letter between attorneys telephone calls between attorneys those are still the only contact but that's what the effects test your point now well then under the effects test i think what you can do then is look at the way that judgment get in a license situation and said and she did cite a couple of cases involving garson an attachment that said even your participation in those types of actions are still not sufficient for personal jurisdiction and even though we don't have that natural formal attachment and situation here all we have property practice there would have been a way for mr mencken to have a title company right over the effects of the abstract could be worth what they would have had to make some kind of financial arrangement with the title company but they couldn't deliver good title would you comment from your perspective on what effect if any the ability of mr macon to do that has on the effect of the filing of the abstract of judgment in arizona well i think you're a right title companies do that it's a nonconsensual lien it is something that can be written down in his written around had that had that happened obviously the rug is pulled out underneath mr ma entire case and yes you certainly then minimize the effect of the situation which was a refusal to satisfy the lien that's just that's just the mr mak not he was angry with the situation i don't know whether whether we characterized the self help or actually something that yes he could have done with the assistance of the title company and certainly he was using a title company for this transaction why they didn't occur i don't know it's not clear in the record but you do feel that it is in at least some way it has some impact on the war so i call it the quantum of effect that occurred in this case we got some fairly minimal context here that's what we all struggle with and i just interested in your perception of how you believe you have this written around  effect the whole thing go away for purposes of the underlying action what in fact impact that has on these minimum context yes and i think it does certainly minimize it minimises well i'm not sure about the contacts themselves but it argument that he's only doing as this whole action was about whether or not they're entitled to try to domesticate and force a judgment that every right to do that but that's not what the most of the perhaps the most suit is about the fact that they were trying to