and we don't need to look at the one thousand nine hundred and nine removal anymore right that would be correct your honor i know you don't want us to go there i understand that i'm not but i just i want to kind of hint of a pressure point so go ahead ok so know not at the risk of sounding a little light hearted about this your client is quite a high achiever in terms of criminal law violations so how would you or i think one of the things adverse factor here which is his criminal history which in one thousand nine hundred and ninety nine was the two robberies committed when he was twenty years old and in this inner fires arms offense he was late teens a few things to say about this st these are four opposed to say some of the k star and his prison record as opposed to some of the cases government sites so he's not fighting in prison it's not you know he's not picking up infractions to the contrary is building this i think very strong record of equities to receive discretionary with relief yes your honor and as i go over in the briefs this court has defined and this court and the i have discussed what what qualifies as an outstanding equity and things like it's family ties of numerous family ties all families that is on you know but he hasn't he hasn't shown that the family relied on them or that he's supported or even was involved with his child or that he had any real employment history or that he served in the military or the serve the community this just it seems to me that there's an insufficient showing here what do you want i think of the people he doesn't need to show each one of those things he needs to show a collection of  have a process in place where i j can convert an ordinary removal proceedings into a reinstatement and if so what is that process look like i don't believe there is a process at least formal reinstatement the parties in those cases including the government at argued for being a statement and so the very summary preceding but another case or situation had i seen a situation where despite unnoticed hearing under two hundred and forty one despite a full and fair hearing in which by and in this case i wasn't i wasn't present that wasn't the case either although the defendant talk about it in for the defendant talk about an argument the only case that may support that view at least in a cursory glance is what chuck and this case i ninety nine if we allow the collateral attack on net you seem to concede there was error but there's no prejudice is that your position greg your honor that's correct your honor there was i'm not sure why that's happening that your but again we only get there if there is either a reinstatement or there is an effect an infection from the prior removal onto the subsequent two thousand and five removal and that didn't take place here while the defendant did have family here on the defendant did get certificates and vocational certificates in prison those relative to the crimes they committed are insufficient to meet the unusual and what is or outstanding i call the standard set forth by what's our standard of review on that point is that just substantial evidence or is it some other standard i believe the standard is whether or not the defendant had a plan will basis for relief and this court can look at any crimes any positive equities any negative equities in the record i suppose to know to some extent and make that determination as to whether an i j would cause a given well that sounds like the and the time of the nine hundred and ninety nine removal again has his convictions is a rest and all the other positive that but even again if this court were to do that i don't believe i believe the court would be hard pressed to find that despite his armed reiterate the only way we could ever get there is if there were reinstatement which is not the kids if somehow that there were an infection from the one thousand nine hundred which is also not an after after getting argument this matter will stand submitted