county washington case know what this is a madison county so those are the cases they cited but there's no witnesses in this case there's no arrest in forty nine witnesses and then a fight end in the state of illinois and in fact if you get to the heart of this case which was included new standard which is tragic or said that he decided it's more readily accessible the better walk that's inappropriate without citation contrary to the decisions of this court as well as the only supreme court and  i don't i don't know how we got to that he said that most of the witnesses most of the witnesses are not are not in more ah that's a better deal we know she stole it she pled guilty she's in jail that's a done deal they wouldn't certainly she's not going to be a witness and there's not one most importantly there is no evidence not no piece of paper in this record to suggest it's easy it's it's inconvenient to come here i suggest it's because they send the factors identified as relevant in that case and the other precedents strongly favor trial this case in wisconsin and cement leave the arguments that process making here arguments about the weight if particular factors and not arguments about the legal standard in fact if you know what is the legal standard here i'm sorry what is your legal standard the legal standard is after considering the de recognized that the i think it's very important to to focus on the standard because the trial judge is in the best position to understand that the most significant issues in the  case and the after extensive briefing and argument and consideration of the affidavits the trial court determines that seventeen out of the eighteen witnesses which actually did the audit work that is at issue in all those cases the words talked about of witnesses who who were identified but who were determined to be not clearly relevant or significant that could be cited i suppose as witnesses in any case about any one of the grand point anywhere in the country ran for his offices twenty six states and the district of columbia they do hundreds of what it's every year and there's nothing specific that links any of the witnesses about training or the national office to these audits and i think what they really done is that what they've done is they've taken they've realized that same the proper headquarters are here one affidavit that said that this is and it can be in part your i think they are confusing the convenience factor with the ease of access to sources of evidence which is a separately identified private factor and  not aware of any case that would say that for example with respect to the eighteen auditor's we would have to submit affidavits from eighteen people talking about the personal level of it can be so in fact the interest especially for a lengthy trial which this would be and i don't think any of the cases they've cited a stablish that the personal level of inconvenience perceived by the individual witness is mandatory in some cases people may put that in a judge may consider it a judge may say if you if you watch to see that i'd like to see that but i don't think it is the absence of that evidence requires rehearsal for frankly is is reminiscent of what happened in the harry versus chicago request days where the plaintiff there were occurrence witnesses to an accident in a county down say in the plain of set but but here's a list of two hundred fifty people who work at the chicago northwestern railroads corporate headquarters and some of those people might somehow relevant to my case i can't tell you how yet but it's two hundred fifty to four so i mean and that's not how th came out in that case the court rejected that argument here some of the training people that they were cited as we noted in our brief i mean these are people who talk training course in two thousand and ten or two thousand and eleven years there is they haven't done any way kids of the training in national office reported training in national office witnesses to the actual facts of this case if i talked briefly about the public back so i think those why the problem with the core congestion factors has they cited that cook county had over three hundred thousand cases including small claims and i'm jury trials everything it could take of which isn't true it was less than a fifth of that our case is over fifty thousand a large area jury trials here and there is no way to compare terms and to ration because walkie doesn't keep statistics in terms of how long it takes for a case to go through the system unlike cook county so what we were left to do is say how many cases are disposed of as of last date we have the statistics in cook county was more efficient in disposing of cases that were over fifty thousand dollars jury ena action resistant plaintiff making a claim under your own i consumer fraud act that particular case was decided by every before brigley or every said that someone from another state does not have a right to know why consumer fraud that count and so that was dismissed or was left was an unjust enrichment claim which state farm handles on a state to state basis so the court setting quickly there's nothing here for us to decide you don't have a consumer  the standard is first of all they have the burden of proof to show inconvenience they did not meet their evidence or burden of proof secondarily the judge just ignored the facts that there's over i respectfully suggest that the trial court ignore the law or ignore langton hearst ignore the brand case ignore the irwin case ignored the cradle society case and