for my two colleagues but we've read all your briefs we're very familiar with the fashion background you're here on in the feel from the denial of a preliminary injunction why aren't damages sufficient to adequately redress the injuries that pocket at much greater expense out of network healthcare providers or after surgery here versus going to the internet provider for that same charge far more in a non contract situation but the whole point of signing up for health care under her provider plan is just that to take advantage of the preferred provider plans i welcome any questions the court may have regarding issues presented by the parties in the briefs but absent any questions i'd like to focus my time on how the factual record that was developed below on the motion for  every case related to these patients requested additional documentation but not specify what additional documentation has been requested and then has refused to respond to  additional requests for what information is needed contrary evidence was submitted by united below in the form of declarations and documentary evidence that shows that that's simply not true the only evidence or set of claim records that were submitted for patient one a patient to want to particular claim just saying that in every case related to tens of thousands of claims that i have handled on behalf of the get then providers with respect to patient two up for the facility for the actual lap band surgery that claim was initially denied for failure to provide information on close to one hundred thousand dollars was paid on these claims that by itself completely allies the argument by plaintiffs that united has this implemented this scheme of frustrating any claim by these get them providers requesting for one patient we're not i'm not asking about all of the patients that have potentially members of the class but just with these two patients that you knew were the name plaintiffs it would seem that you would be able to tell us what the actual there is there is testimony below from united that united did request documents and that those documents were not provided in some circumstances one are saying that they were provided in every circumstance and adjustments and united has made x and we've requested it we've submitted all the appropriate documents in summary fashion and we haven't been paid and based on that record alone they say you should force united to all mediately pay all of those claims despite the fact that they're in dispute and united if you can't in a matter of two weeks in response of this motion for primary injunction come up with the entire administration record and explain all the reasons why you should win this case and essentially try this case in two weeks well then you're stonewalling and being obstructive and i still think that that was very honor and when it comes to what i think is a very important point whether these patients are really being tonight care we need surgery now and it's not really we need a surgery but we need adjustments i think it's important to take a look at what the record established with respect to that there is no evidence whatsoever that these patients are unable to get lacob just once either from their chosen providers or from a number of other reasonable options the united has given them about the actual price of these adjustments and there are some there's some evidence in the record with respect to the average reasonable charge for of such a loss of three hundred versus the thirty three hundred yes but that really doesn't address issue with regard to patient one because the only thing i saw on the record was the declaration from i think it's the get thin employee who was trying to respond to united's requests for records and it looked to me like it was sort of the  classic almost voice mail jail of try being referred from one part of united health care to another part of united health care and the right hand didn't know what the left hand asked for what had been submitted and we get thin person is saying we send them what we have nobody united seems to know what they have so they can't really tell us what more we need and what we have there your honor our mean process there isn't anything in the records that addresses that your honor but i can talk to your client ask them how they track their claims process in history i can tell you your are from experience to speak of such a record for just a moment for just a moment for question that as it is not a simple as as that sounds for a carrier who administers and processes two million quantities i day to track down here is not is not really whether the records whether or whether a particular records request was appropriate or whether it was complied with what is it if you is whether they have pointed out they have that's not what they've asked for what they've asked for is the immediate payment but they haven't said they haven't said what they're in how to other than this is what we build and we should be paid everything they haven't said why the planet titles them to that your honor suggests that it's pointed out they haven't identified the terms of the plan that they allege have been breached they haven't identified a single actual claim record they haven't they haven't established that they back surely exhausted administrative remedies with respect all these and i think i see you're out of time ok thank you thank you