sure well is it fair though to just shut it down and say i'm not going to allow you to present you've told me you are going to present specific additional damages other things i'm not going to let you do that rules of the restriction is also that issue it's a two part definition the first part defines clients who mean and then for you who has given myers group a job order or for which the marriage group has a solicitor job if there's actual contact with the car the second limitation is a limitation specific to defend america that you fully show i solicit any client who the employee actually has contact with or knowledge of or access to so there's two reasonable limitations you know based on the presence of the appellate court its customers that the meiers group is actually dealt with and customers that the defend cases cited assured partners and once an hour for the proposition that restriction yet bar you from potential customers no one's ever contacted just in a political here so the restriction itself is reasonable  solicit should also be voided but the focus of that legal rule is on the essential he invited term has to be essential to the contract in order to avoid an entire contract it's different here in this context because it was another mole that part right another thing another point the cap on company decision makes is that cases not sipar complex multi part agreements should not be by voided just because one particular problem is an employee agreement with twenty at least twenty three parts and most of those of ours this is the modified or contract the cap on company decision is talking about and finding at the close of the myers group's case and the breach of contract claim cited our points and authorities in our brief and today i want to address those two arguments in the context of the questions that counsel was asked and the points that he raised questions that were asked i think counsel ben could have phrased his questions more clearly and did not so i don't recall the specific ones offhand i know what you're i know what you're referring to generally but you mustn't think he gave up on following up i'd also suggest too that if you look at the last ten fifteen questions that counsel asked of ms meredith when she was on adverse examination they were totally irrelevant to the case there was there was discussion about whether she point money out of her retirement a nothing to do with any issue in the case if there was some frustration creeping in at the end of a long day that's understandable that's the human nature and you know in terms of the real thing proves that us i think that you know the judge is an offer proof at all and in this case you know that i think that the trial judge is being asked to exercise her discretion she's entitled to know specifically what it is and in going back to donnegan to distinguish that case because they heavily statute was worded they got the particular day wrong on how to calculate the damages under wage garnishment proceeding and they may have a set having made a mistake but then they x or says good faith in trying to get the specific evidence that damages in here what we have some damages here ten minutes is not sufficient ten minutes would not have the management to present historical say as evidence the very types of information you think the plaintiff would be prepared to present nature of these agreements that were at stake the undoing hardship ms meredith if if the covenants words of the enforce the time and place restrictions under the contract the fact that they were in in certain struggle sales how deep these relationships were invested in by the employer in terms of marketing expenses advertising expenses what percentage of sales the business derives from its top tier customers and how it's got a very deep interest in having those long period of time that that reflects the good will of the business we don't have any idea we don't have any idea about best and extrusions deal with the matters group over the period of the past five years we don't have any idea what kind of placements ms meredith made with i just a couple of points on what reliable fire actually says at paragraph thirty four the restraint is usually and that's a child sized justified on the ground that the employee has a legitimate employer  as a legitimate business interest and restraining an employee from appropriating the employer's customer relationships from stealing the customers relationships no more than that now you do look at this as how the circumstances would want to speak to rule twenty three or counsel mentioned i think i know the decision he's talking about i think if you read that decision it does side chapel but i think the issue the court is addressing there is one of