start with that he means pacific indication of somebody saying something specifically  where the chief said and she say i just put that in perspective because that's what this is going to address she saw i would suggest you think about  efficient made by a witness is not a fact it's an opinion it's an opinion of that witness i believe that this person did this this person did that it doesn't mean that that's a fact it is strictly that witnesses opinion somebody bought it we didn't sue him for making the arrest we didn't sue him for a statement that he thought there was probable cause we sued him for saying that she did it and that's crossing the line now  by your analysis if something was put into a book or an article every time every time somebody picked it up and read it the statute would start a new no your honor for this reason continuing to publish on the internet it least on a website which where changes are made so it's not ait's it doesn't continue to be identical that is patients which created a new cause of action i will agree and i said in the brief the issue was whether this type of internet situation which is not addressed by the statute is more akin to the example out again the rationale behind that being out here or people will hear it or see it welfare more people will will read this on the internet when they go to the website and they go to this taken down south that's a substantial difference between the newspaper the book it's put out there and you can't get it back and you can't control it or it does make it more like the second edition of the newspaper or you can edit it out  statement dealing with the falsity of what was reported you have your observations several laypeople and a police officer they report what they saw and what they observed and what they saw it seems to me is pretty consistent with your client's self described training techniques that she uses positive and negative reinforcement she straps feel like her collar electronic collar on these dogs she shocks them when they don't do what she wants them to do isn't that part of her training technique oh so then what is so unusual about people seeing that and reporting simply what they observed which is consistent with what she admits she does but they weren't really admissions they're drawing certain statements from the newspaper  collars we're talking about one a round the neck and want to round the hind quarter some say it's the genitals near the genitals around the genitals but isn't this part of her training regimen she know that electronic dance he's got it maxed out so they've dug even comes near it and he's he's taken a five ten steps through the air coming their way people use walk on it but it's a there's a fundamental difference between a out and putting something attached to the complaint and those control your orders you must look at the language as contained in the exhibits and examine the specific statements of both of these individuals to determine if they rise to defamation per se if the dog collar around the neck of a dog and another electronic dog hole not a belt around the rear most waist of the hand now that my client but it seems that there seems to be some contention to the point if i'm playing a sport that there is nothing in the record suggesting another belt was on the dog around the rear most area of the that is flat out wrong if you look at the record as the exhibits attached to this complaint your honour's you have to assume that that's true and if heather davis a statement is true now in the present state there's also another statement in that record on the second page it seemed ninety five second page of the chicago reader article identifies the state's attorney who told the recorder in the article that a nother witness not i know president intended to testify that that witness saw another dog with three collars on the animal including one around the groin of the m the exhibits the tact this complaint that are established as true because those allegations and those claims in the exhibit have not been identified as falls by this point if in her business they are true so for them to get up here and say or in their brief i mean and say well there's nothing in the record that suggested another caller was around the dogs rear area he says this time i'm sorry again damn second has done a story that involves animal cruelty this is his exact level of state this time her story is about anymore a so called dog trainer whom i arrested and charged with  trainers in illinois are not certified there is no agency that certifies dog trainers in that capacity therefore i could get up to call myself a dog you're almost put anybody in this room could because there is no trainer there's a that's true there's no certification for the other aspect of that calling someone a so called dog trainer but that doesn't suggest anything defamatory about a person's ability to to train dogs  opinion it's protected by the first amendment so that that alleged statement that its rise to the defamation has is not actually on those three bases the second statement which is when wrote in his web log that i can tell you that miss more open to training facility in the west loop neighborhood and shortly after was seen by several area residents using what the residents felt were cru believe that her techniques were cruel that is absolutely true if you read the chicago article or the shuttle reader article identified in the piece or residence in the area not including diner president who defended in a defamation case in this case there is no factual underpinning for what officer sheen was calling a cruel technique it's not identified in his web he doesn't say anything that would allow the court or me to deny the allegations and move on i can't deny whether something's going on in it if that's the allegation when i go to respond to that pleading and the and that's why specificity is required i don't know whether i deny it or not what was an eyewitness to a criminal proceeding and she simply poll actually pam sackman and the reader what she saw and if you read her specific statements let's take the chicago she saw more with the same dog that week the b zhang was literally lifted into the air that's how strong the shot was the president says i've never seen someone strap a color around the dog's genital genitals before and when i confronted her she said something like i'm just making sure that the sean will never run into the street and get hit by a caught a live b john is better than a dead beat on it was so disturbing i still can't get that sound out of my head identification of the area where the rear most collar which wraps around that rear hind area of the of the dog would be located she never said the dog was being shot on its genitals that's not in record that's not even in the first many complain is an allegation and even if you assume that's what she said it's still not because he already that color could have been in a position where at some point during the course of activity in activating the impulses to the dog the animal was experiencing some activity or a compulsive in the area of its genitals i don't care if it's a female or male and in date range that issue in the in the actually please the defamation per se activity because it paints the plaintiff's profession in a bad light let's pick that this statement about the all about the location of the collar on the animal is capable fantastic training technique that would not mean that the plaintiff is a bad trade because residents may have felt that that's it but her statement that the collar around the general to the dog is capable of an innocent construction is simply an that you have to report the opportunity to review the specific statements so the court can understand whether in the context that there may there is an action for defamation false light and the players haven't done they also have a pledge how peter would have come to the information through the end of present the article that's attached to the complaint suggests other people thought peeta no there's no factual statement in those exhibits that diana present herself talked to peta of there is a reference in the article the reader article that diana president and no individual that was interviewed for that article or members of peta so for all those reasons the information and belief allegations trying to drag diane into what peter said should be  the first reason is the idea that somehow the rules of putting it on the internet are different than any other type of publication inviting it's in their pleadings the only thing still ledge is that it was put on the peta website one time one time or so we challenge the whole purpose our premise that because it's on the internet that it's only put there one time somehow  because people can read it after it's pop the other premise that the challenge is that this is not married to palos website this is peter's website and so they keep talking about things can be accept the plaintiff's argument that once you put it up on a website then every day that it's up there it's a republic ation in a fact there will be no special limitations for defamation on the internet any time good still up there could be up there forever there would never be a statute of limitations so then we would be carving out sums specific rule for the internet that would apply to a newspaper prince and then the last article on the internet and just because you can pick up some newspaper and read it every day for the next one hundred days that doesn't mean that there's a new cause of ash in the same thing applies to th so in effect if you accept this argument i think the effect would be that you're eliminating any statute of limitations for me and then the other allegation that they rely upon or argument is that they have this day allegation that married apollo repeated this to people in the neighborhood within one year of the filing of the complaint and i submit that under the case law that's certainly not specific enough and what's missing is as we've indicated the room why where who did she repeated to what did she say and when did she say none of that is there about this one year within the statute so i think right now collision case that we cited the same type of argument was made in equities in regard to the statue of limitations and price you have to wop or one hundred years is that when you say something to them when i say something the family tore it to somebody else anticipating they can repeat it i'm liable for their work eating for their republication all that's going on makes a huge difference