as i understand the way it's framed it would mean that unwritten what you're calling an unwritten policy just doesn't come in come within the fold of this provision at all and the consequence of that would mean i think that for example underneath three there's limitations on relief yet the court can oppose declaratory or injunctive relief of things of that nature but then if it were unwritten those limitations wouldn't even apply and that seems kind of odd to those limitations wouldn't kick in and even though maybe the court squarely addresses and rejects the government's argument that that section far judicial review because that keep it but look the government has an adopted a policy a procedure for long detention therefore can't by definition encompass unwritten policy and what you're saying is there's uninhibited judicial review on of on written policy but there's cabin judicial review of written policies and i think that  that that's just seems it seems hard to imagine that's what congress intended but they wanted to make sure that written policies were only reviewed through a carefully calibrated tab and regime but to the extent there's an unwritten policy they're careful cabin ing the congress implemented with written policies just doesn't apply and it's open season well i think that was a paper there concerning that congress that intended to that's a very important point to make here our client  form that it came unlawful and incorrect after the plan to ban was implemented because that form didn't provide updated guidance on what standard immigrant  agency officials say you know we want to make sure that everybody officers in the field undertake review in the following circumscribed way but if i put it in writing it's go subject to judicial review so this is just an edict that i would like and we do it by video conference we just disseminate it say i would like to make sure that everybody operates in the following way everybody gets a generally applicable policy but i'm not going to reduce it to writing and presented in this case we have i think that and so i know that's not what i know that your position is it's not what's presented in this case i guess that i'm just understand trying to understand the implications of your argument and let's do my hypothetical but i know you would never assume and i totally understand that i've learned in the government i understand what you're saying but let's just for purposes of understanding the parameters of the government's admission about the scope of judicial review i just want to make sure that i'm properly understanding it that in that hypothetical where somebody says you're only for the purposes of the  someone would be an extreme example someone says at the credible perry interview to an individual you know what i've been told we have a policy that we don't accept anyone from asia anymore so you cannot do that that would be strong constitutional claim that's equal fertility i think a protection based based on the policy itself it's in your view and i totally understand this is the reading of the statute i just want to make sure that it is if they put on one side and equal protection claim based on the parameters of the particular policy at issue if the government decides to adopt a policy but not reduce it to writing precisely to avoid judicial review at work that's actually a way to avoid judicial review is to make sure the and i'm wondering if we have the requisite clear statement here even though the time limit at issue is embedded within what's otherwise a jurisdictional limiting that provisions we still have decisions and the supreme court complex of issues and says that it's a firm expansion for the reasons stated by the district court so there could be a question as to whether that's a holding us to every particular that the district court reached but in any event if i could just ask you for these purposes just to put it to one that return of jurisdiction expressed the condition on it being done within sixty days and then there's a good reason for why congress would want to make that jurisdictional and not allow for the whole purpose the words but only if you said but only careful and thorough and also most recent decision it's up from last year when judge matter that goes through all these points and makes many of the same arguments i'm making here and so that at the end of the day it is still addressed actual provision you have precedent on that  you can't apply rule fifteen there can be no relation back i question as to whether or not that the law the two cases cited in the district court decision in a land versus the united states postal service and resolution trust co sense are not on point in fact land on the court actually performs an analysis as to why the rule fifteen applied and and and found that in good apply and i believe in that case ended up not a step in the men for other reasons but ninety one so any way you cut it is this your court erred in not conducting the rule fifteen analysis as to whether or not the points made by the plaintiffs in the nd amended complaint related back and also the same analysis or any and reverse if there are no more questions thank you counsel thank you to both counsels we predict missions the cases submitted and you