shanklin first thing i want to mention is all of the witness who testified in this case and if there's testimony and the job descriptions are system she's an interesting lady testified on her behalf stated that it was strenuous and intensive work that she did although there's a number of different tools jackhammers shovels picks  impose a higher standard williams would would be yes but that i mentioned the well you know what i think because you'll you'll see different ways of handling the big issue at the our problem in this case is we don't have an individual who's doing the same job with the same piece of testimonies all three of those because for all eighty years the first five years shoveling asphalt out of the truck but in all nine years she's using your hands and strenuous physical labor and this is not just for females i mean she's competing with the men on the job and treating physicians in that case say it's unrelated and he contradicts his own testimony i just don't see what relevance to case has this case the cases we found that have similar facts and not as extreme as this case we have a female other than this you know in summary i think it were just the three with mr de grace decision that this was strenuous hand intensive job being done eighty five ninety percent of the time she's a female and it was a contributing city which is good contract labor but also to substantiate her testimony that even when she became a foreman she was still doing that same percentage of labor which was critical but because again dr who seem to think that when that happened  your opinion she quantified what it would be they never approved the quantities that she said would be required so you can't say what is or is of at least saying the word those things well i think we're seventy four hours a day doing things such as lawyer the jackhammering you never testified that because she doesn't do those things for four hours a day in all likelihood counsel so why didn't counsel her to say seventy percent of this and and five percent of that cetera you need to quantify in some regards if you say why do you jackhammering is that one percent or twenty percent it makes a difference and yet there was no attempt to quantify it also you said i use my hands at work eighty five ninety percent of the time i use my hands at every one of those activities in and of themselves if you did them for four hours or six hours seventy five percent of the time but she didn't testify that she did any of them for that amount of time  statement the written by the operator states dr chua kind of petitioner had sub significant diabetes that no matter what occupation she performed no matter what activity she would go on to have carpal tunnel and require surgical no matter what the activity while no she went on to say that this is no matter what the act yes but but i'm further questioning on cross examination we find this all the time where you'll say one thing and then you'll you'll explain it more later later on she did some dermatologist giving her this magic cream that would keep her from having palaces and these nice officers and she forgot to bring the green wonders of the arbitration and no medical records from any dermatologist were introduced in other words it was a soft serving comment doing and we know the job did change and she did testify that she did more supervisory work and talked about job assignments and things work and paperwork and things like that so there is job changes and the second one mr williams he had worked with her on jobs many years before and he started working with her after she was symptomatic and treated he wasn't there and seeing what work she was doing before either one of them the past five what were she was doing before she became something  mr williams did because well yes because he he did work for the city when and when she became sent medical was treated he came on later he wasn't there i use the correct he came on later but he had worked with her for other employers more than nine years or whatever earlier and he knew that she was a hard working woman back then for those other employers but he didn't know anything about the work she was doing at the time she became symptomatic was still employed by or after she became something of yes she she was and she was a supervisor working foreman a very working foreman when he worked with her after she was treated for carpal tunnel so did have diabetes and it was so bad she was on oral and injected insulin and so bad that she had diabetic neuropathy in her feet but she also had a tonic colon where an area of her colon because of diabetes is no longer squeezes and moves the material long maybe go in and take out that area of call and she denied that that was diabetic dr doctor who had those medical records and testified yeah that's diabetic so she in some respects even we have have you know have more callous than this woman and she really be doing this work and there's physical evidence her hands saying no her hands tell a story and  hands tell a story said her diabetes tells a lot of story also and she had already two diabetic problems and she was taking medication she was asked you take medication for your hands she's taking you have it's for neuro life i don't think she can syria because then she says you know if you show me that you do this for hours a day or you show me a job description that says she does the seventy five percent of the time not any particularly with this physical labor then i would change my opinion so she actually didn't have it there but the only conclusion you can reach when you look at the job just for the testimony that those are all things that have happened and therefore hurt her opinion would be different but no one ever questioned that she's doing the work so say that she wasn't no one's really going to have to decide whether you win or lose i mean when we saw when we heard her testimony and we we talk to the people she worked with and then looked at the job descriptions there on her own system and nobody in the city ever said any of those were watson obviously that the last half of his deposition after been told about the diabetes was fully aware of it in this case or in any other face i've ever seen where the degree of the i v s makes a difference but our  our position is once you prove beyond a doubt that a woman is working heavy physical labor with her hands eighty five ninety percent for ninety plus years that you know the per and that's what the doctor said th