for independent arguments as to why the district court's decision should be overturned and reversed i think that there's one factor that parents on these extraordinary factual records  and that is that if i had missed this and zito been represented by a lawyer when she brought this lawsuit there would have been no way that the lawsuit would have been dismissed on time when it's grounds and that's because the very outlined in her carefully worded decision well we took that decision to heart and i think that in the proposed nd amended complaint which is part of the record in this case and we did discuss it i believe in the factual section of the offer without consulting with the plaintiff or i am i thinking of a different part of the record now that it's actually in our complaint and it's also touched upon in our grief i would be and i believe it's in a footnote but that certainly is one of the several seems to require objective manifestation of a breakdown in the actual relationship of trust it does have to turn on whether in the client's heart of hearts they have secretly lost all faith in their lawyer because of that were true i went think that in the course of most representation at some point that relationship has broken and then maybe be repaired but nobody gets fired people go along with their lawyer so in the true that under new york law you do need some objective manifestation not just sort of an armchair psychoanalysis of a call i don't say i have lost faith in my mind lawyers state of mind not relevant because that is the subject matter isn't there a need for an objective manifestation of the state of mind well there's them instead you're fired or they say you can you give me a specific with the plaintiffs the appellant in this case did that we can say at this point the was no longer mike jones because anything else leads the start of a statute of limitations completely vague impossible you need it so it's what was it you want the ultimate firing is support that the trust and confidence was lost in the fifteen because of a client didn't just get up and say i'm going to fire my lawyer on this particular date is predicated on a belief before that or something that occurred before that which is her obligation to plead so d let me ask you this question hypothetically a client hires you you represent them for four years later on  after they submit an affidavit saying that in your two they lost absolutely every shred of confidence in you and then secretly then terminate the relationship of trust and confidence just because the client has lost confidence the fees can continue to be true well judge i would respectfully argue it so that i believe a client shouldn't have to pay a lawyer after the client has made a manifest representation that i no longer have trust in you and i would bring us so october th of two thousand and eighteen and a complaint was filed on december rd of two thousand and eighteen not the only thing that happened after october th as alleged in the complaint the only legal work ms had lost trust and confidence earlier than december thirty two thousand and fifteen and therefore the continuous representation doctrine stopped tolling the limitation every single one of those cases involve some objective manifestation legal malpractise for example as judge and already mentioned the fact that the defendants rejected seven hundred and fifty thousand dollars offer that was made at a mediation two thousand and fourteen after the