thirty one forty one b which under the appropriate circumstances is a mandatory order and we urge that this is one of those circumstances it is mandatory there it is clear  convincing of evidence of no flight risk which will come to later and if there is the appeal will raise substantial questions of law which if taylor prevails will likely result in a new trial we raised three issues which we think fit that standard only mentioned two and leave the third one for the brief the first one deals with judge forests a ruling that prohibited taylor's defense counsel from cross examining the seven victim witnesses upin out the fact that they signed a written contract and a relatively short two page contract and  very bold language which says that this contract does not cover the roots so what did you tell what did you tell trial you wanted to accomplish by  did tell the judge that we understood what she was saying about the thomas case and that we were not trying to introduce or argue with these contracts that the victims were gullible or that they are at fault we said fairly clearly that the issue is credibility that if they're saying on the stand that we were told something verbal e and we say it didn't happen and the contract very clearly right above their signature in bold language says this can this contract does not cover the roots we think that goes to their credibility and i believe judge forrest was informed of that and i think that if it becomes a very significant issue  the case because we would argue that they were told something about the contracts other than here in the here's the contract i thought that was i thought that was what you find to be the contract is signed by the witness and at a certain date before the effect date of the conduct if that is that we want to ask them did they see that did they under what do they understand by that and that clearly if they did understand it and they did see it that would clearly contradict their testimony that we were told otherwise because the other is a clause in there that says no verbal representations can supersede this so that i think the issue is really one only of credibility so it gets out of the issue that was raised in the thomas case which i think confused judge forrest on the point of what we were trying to do with the issue was are these but this is lying did we not inform them that they were not going to get the roots that was the that was the clear import of that cross examination secondly i see my time is getting near the other point i want to bring bring up it is the reasonable doubt charge this court other courts the supreme court has said please do not mess around with the reasonable doubt charge judge forrest ignoring that because she said the bits of evidence she said that they didn't have to find proof beyond a reasonable doubt on every bit of evidence would you rely on this with this is testimony in important matters of your life standard reasonable doubt language what what was wrong with it is that it goes beyond and requires a special finding that goes beyond what this court the supreme court and this court after the supreme court has said must be said you can't a bits of evidence actually was discussed in i believe the supreme court case and said that it is confusing and when it is confusing it reversible error we think that those two issues mandate they all pending appeal whether we win or we don't your honour's know that the standard is if we win those two long time he knew that the sentence was going to be enormous if he lost the judge said now you know you've got the sentence and you asked for probation so now you have a motive to run how that simply is not the right standard he's not a flight risk based the probation department report they had said he was not a flight risk so for all those reasons or because we think that these issues raised substantial issues we think he's entitled to bail pending appeal and we will comply with any schedule no i think that's enough for failed to show that he is entitled to an exception to not default rule because first he has not offered clear and convincing evidence that he is not a flight risk and second none of the issues that he resists present a substantial question of law or fa his demeanor and credibility at the sentencing she assessed him at that and at that proceeding and throughout the course of the trial and determined that in her words he didn't get it and in other words he didn't have a concept for the fact that he was going to receive such a longer has the job at which he was employed he lived alone has no children his stepmother has ties to the florida area perhaps maybe there in the future so we would submit that his his circumstances have changed enough that he does have incentive to  forest allowed the contracts to be admitted into evidence she allowed the violations that were submitted to each victim that were in a packet with their name assigned as she did with those victims to be admitted into evidence she also allowed the victim would guarantee a certain amount of profit and in the contracts clean contains some disclaimer language that undercut those representations so judge forrest assessing the evidence felt that to avoid the improper purpose of blaming the victim cited in thomas if she admitted the contract and allowed the victim testimony the jurors could make that comparison what she also admitted was the testimony of ken levin's lawyer about the contracts how they were drafted what the evidence the comparison that was proper could have been made beyond not the only purpose was improper or so the line of argument did the victim see it who do they understand the language in the contract that's very close to blame the victim did you what's your capacity to understand these contractual terms to compare them and to the misrepresentations that you supposedly heard that is the plain the victim argument that thomas counsels against and that's why judge forrest correctly structured why didn't the guy in the government's view in preparing the witnesses be they had not observed they had not read the language of the contract it wouldn't whether it would have been had a interest is different than whether it would have changed the outcome of the trial given the amount of evidence otherwise you know there were cooperating witnesses recordings of scripts written by taylor levin about the lies that he to the extent there in his name your honor we can certainly do not his father did pass away recently we don't know whether there were proceeds out of life insurance or anything else to the extent they were put in the name of someone other than taylor alive and his father had not been sentenced when he was deceased so there's no way to attach his assets or any assets that were given to his stepmother so there are ways that he could have assets that the government cannot attac