here what you have is a brief forty five month period prior to a political campaign where the village apparatus was very good at helping if if if j and its owners get things done kind of didn't old school political way and then you have a form of political campaign where they made the mistake of supporting the mayor's opponent and then you have an eight month period where you have an old school way of the village finding ways to be very unhelpful include it including things like suggesting that they use a different architect suggesting that they use a different photographer for their presentation to the court  encouraging them to pay their bills quicker and then ticketing them for all sorts of violations even though they weren't their cars they were the ones who owned the lot in that were they were trying to repair a lot that the mayor herself suggested that they do just a year earlier when they were in good terms so with each one of these kind of particular violations that the court addressed there may seem to be on the surface justification but when you take back and take a step back and look at the larger picture there's a clear dispute affects here as to whether or not you had an entire village and paradis giving a hard time for lack of character pusing it's power in retaliation for for a political decision that the owners made to support a political party i mean that's the basic story here in that there's another fax in the back in the record to allow a response to your opening there and you can tell me where i go awry here what what i have a harder time around i have the hardest time with here is on the causation element with respect to the village president  village mayor mary warner and then they tell you specifically why i the record the record you're right suggests or shows perhaps that she had awareness of the tickets in other words it's not a situation where you face a hurdle of you know trying to establish knowledge on her part i think she knew about it i think you've you've done ok there but i don't know that she was the impetus for the parking tickets and when it comes to the permitting issue the special permitting for that that lot she actually seems to have helped your clients in the end to get the special permit and what late seventeen or eighteen early eighteen and along the way she seems to help them fill out an early draft of it or fill out some portions of those those couple of facts seem very much it odds with your with your narrative that you know she was intent on making life miserable as a political payback so where do i go wrong there i have three responses that the st response is specifically as it relates to the parking tickets i think there's enough evidence in the record enough inferences that there were communications between her and give you a business license because somebody else already has a business license there that license went to months earlier she had secretly given that somebody else a tobacco license even though my client's already had its back license there it said completely ironically and without any understanding of the of the obvious contradiction here and how she had done a favor to another business person for the sole purpose that she could hurt our folks in two months later without even publicizing that they had their license this is what i well i mean by kind of old school abuse of power that the parking ticket here is maybe she wasn't personally aware of the parking tickets i find it hard to believe this is a small village ten thousand folks a small question is there is a reasonable could could a jury reasonably infer that because she's doing these other things particularly nice combination of things at the very end of this where she deprives them of their license  wrong during that year was apart because of her it least we're talking about causation i think it's at least affection for the jury renewal which his clients were seeking at the end of the year of two thousand and seventeen in in november of that year the owner of the building in which the pla the restaurant came to miss ms warner the mayor complaining to her that he was going to have to find a new talent for the restaurant premises because the restaurant owners were not paying is paying him is a rat and the record shows that he claims they owed him two hundred and fifty thousand dollars he was unable to pay his real estate tax after that conversation ms warner met mr ibarra who was looking for of location for his but he planned to have cafe warner referred d mystery bara to the owner of the premises where the plane just rented d and that the owner complained that they well it wasn't getting paid and outside of ms warner's premises as of d the end of the year or the beginning of two thousand and eighteen based on that the those parties apply for  business license which the village granted them as effective was the beginning of the new year and the beginning of the new lease so that was that was the factual background of why the business license for the plaintiff appellants was not renewed mr ryan can you write mr show or makes makes a fair point that i think warrants a response from you and that is you can't just focus on one little matter one little micro piece of this here and there as as he invites you know there is a broader mosaic here and that mosaic all surrounds  jury should be able to consider that look this is a scenario where there was a political payback and no matter what these gentlemen were going to be run out of town so to speak and you know it came in and it took a little bit of time and it came in a lot of forms by lo and behold it worked so which what's your response to you know that narrative that broader narrative well everything that happened involved in their obtaining permits required by the law and the ordinance violation of of you know or dunces for parking  business d license renewal which you just talked about and during one of those transactions or during the course of time when the comments were being obtained and tickets were big issue was there any indication any of the issues i mean there were requirements for the permits they simply weren't meeting the requirements when he did meet the requirements the village board granted the permit st of the mollusca building and then  eventually to to build a parking lot which then wasn't paid for a long time during which time i got tickets during which time the people ticket originally complained to the village about them getting tickets because a valet their car at the restaurant and the bellies but the cars in the parking lot illegally which led to the chief bissett to issuing his memo that the parking requirements or d the d licensing at the end of the day at the end of that year they're all they happened but they happen for a valid reason the village had ordinances that they were enforcing and there was really no connection between the election and election i don't know that there is any evidence in the record that she knew that i do not recall that being in the  district court's brand of opinion so i i don't know that all right well that but that doesn't what's in the summary judgment record not in the opinion because didn't they hold some kind of  a happy hour or something at the at the restaurant or the lounge yes state of a fundraiser they held for the opponent of mary warner during the election right and what's the dept what's the written record in the deposition testimony suggest with respect to mayor warner's knowledge of that event i don't recall there being any evidence that she knew or didn't know about it i really don't know the answer to that question aware in so they had they held the fundraiser they actively supported with donations as i'm sure you know in illinois all the way she's a public plea reported on a website especially in small elections like this people track serves multiple purposes he is the you know he's the person every zoning board dealing with law enforcement but you know it's like say chicago that's a completely different person i think those facts they're just a matter of public record are  equal protection but see that is evidence of retaliation if you stop our your useful code to find an ordinance it's never been used and decided to use it to ticket somebody three months after they actively