earth and it doesn't appear that you are what well it's a long confusing when you start to read the record and you start to read your information and it says you're representing mother i think that's something that needs to be looked at  because i mean there could be also an argument that he was in custody for not possibly beating up their mother and then their mother the day that they were taken their mother was was there possibly hi i'm something with a knife to her wrist in front of the children that took the children disrupted generally that could as well  concerning that issue was that it really wasn't in the best interests of the children to be in foster care because look what's happening they're still disruptive i thought that's what you're arguing about the disruptive children believe it to that's the best part of  were that various levels of parental rights not be terminated and you mention the the location of the children and some two criteria and you mention some problems that the children have but nowhere do you discuss how the reality of the placements when compared to being placed with the father would result in the best interests of the children in other words when you attempt to establish that it's in the best interests of the children to be with the father it would seem to me is that you should make some mention of what the father's abilities and proclivities are and you haven't said a single thing about what the father could have dima let alone could have done better in so far as custody relationships whatever with the children do you understand that when you make an argument regarding  the concept that the evidence doesn't support the proposition that you set forth what the facts are and then you set forth hypothetically or otherwise why your proposition is  correct meaning you which you should be probably in my opinion at least this is the way i would do it i would state what the father supposedly could do or would do and if hopefully i in the past he did those things you could use that to corroborate your suppositions but there's nothing in here that suggests that we're supposed to work we're supposed to make a comparison between eight and nothing and i don't know how you can say that a is bad when you have a comparative against anything you know websites that sell things have computers you have a little checkbox and the point is if you don't check anything you're not comparing anything and if you don't compare anything there's no way that you're going to convince me that whatever it was that you're suggesting is better isn't better because you haven't sucked forth want  your client would or could do and until you even in the top that there is no way for us to compare whatever you wrote and make a determination that it's against the manifest weight evidence even see that how did you think he could be the children could be placed closer than thirty to thirty five miles away from each other and they could be placed in with you didn't mention today in the terminal i think grand piano there but do we have anything in the record that indicates integrated assessment to complete and releases which would be what would allow them to talk to the department of corrections on his about him and that was mailed nov th two thousand and eighteen the after your children have for the war and any one of the three interest concern or responsibility is sufficient to find under that ground we have not only his own caught up in him to be incarcerated but then we also have  after and progress of the same situation which is his efforts were insufficient because if you didn't understand the documents that were provided to him he certainly could have reached hours without releases they can't talk to movement towards reunification and we certainly don't have that there is no way that these children would be returned to him at any time at the time of the hearing in the near future and as of today that's we have no further information that he would you otherwise or done it does mean i think when we think of depravity we think of a definition that might be in a dictionary that someone who's not keep cool with someone who is just after the children were born that removed him from the care it doesn't the record isn't entirely clear whether it was the mother but it was certainly a domestic which means it was a family member or some household member this situation and can function and be a moral person and that certainly hasn't happened here did they respond to him any issues that were identified mental health issues or things of that nature that were  we're back but if if the court isn't time to find a conflict it would not be anything prior to the appeal the notice of appeal was violence thirty days after is not wise to put his surname completely spelled out on a piece of grief that should have been to various and just like the children of war in the interest of the children with their initials so in the future please don't put anything that will identify the wrist the respondent minors or any abuse a that i mean it is in the trial record i think there were a couple of times maybe when he wasn't able to be there or it wasn't transported maybe from from he'll did his attorney  and sometimes distance from winnebago to his old winnebago to galesburg isn't around the corner but is there anything that you're saying that department did to prevent him others and this mr know there's one final thing i would like to address that doesn't actually relate to the substance of yesterday filed a motion to continue and we have to deny it because this matter had been set i think since the middle of december and now we're about thirty days out from that if you want to moral argument ask for it and we'll do our best to give it to you if time permits and they don't violate supreme court rules but it's well to think relative to these are excel or any cases and only place this case on our argument calendar that meant that it was delayed this case could probably have been disposed of at least a month ago had you not placed the time he'd world calendar your requests and secondly we prepare for these oral arguments and so i had prepared in fact i think the entire panel had prepare requests but keep in mind that if you do there will be a delay handing you don't ask for it to be withdrawn a day or two before or are you going to schedule