oh thank you so much for your patience your honor my pleasure may please the court i am unaware of any case in this judicial circuit or in any other judicial circuit that holds that a federal court's mandamus jurisdiction is withdrawn unless there is a specific statute expressly stripping the court of its jurisdiction over in this case the attorney general's enforcement authorities under the ethics in government and are limited to situations in which there is a willful or knowing non disclosure and in this case there is no willful or knowing non disclosure and as such the attorney general's authority in this case is essentially an respect your honor to be issue of the disclosure of debts in this case it seems evident that in this case there was no full and open disclosure of full and complete disclosure do you dispute that they were all disclosed you just said your concern is that they were other things were disclosed to which makes it harder to identify well makes it impossible to identify in dispute that although i don't read you anywhere is disputing that in fact all of the personal liabilities were disclosed i am not disputing the fact that there were personal liabilities of the president here that was that were not listed on the financial disclosure not if you dispute is that to me a disclosure means to make clear and in this case it is entirely unclear from the president's financial disclosure statement whether or not he is liable for these debts and as such there is no disclosure let alone a full and complete disclosure all right i had thought you had argued in your brief that they're all there he just needs to go through with asterix and identify which is which yes ok so they're all there you just want to asterix we're going i don't know that they're all there i'm not challenging i'm not ok right as for as you know you're not claiming that's right but he sure did you on disclosing for the form shorted you and disclosing all of because i don't know which of the debts listed in the financial disclosure statements or personal one of the statute titles you to police the accuracy of his disclosure as opposed to get a copy of such report filed you know i don't believe your honor congress went through that the entire purpose of these financial disclosure statements is essentially to give information to the public not to agency ethics officials i mean that's  don't know i can't decide that maybe it's both all right fair enough maybe it's a poll because we're going to write to his such report under the section one l five i think it is still logical to believe that congress was asking texturally when you're serving in the informational injury here right right and what's the stand that and so that's a creature of statute you're informational injury right wouldn't exist if congress didn't say you get this information correct congress said if you get a copy of such report with the information that's supposed to be in the report it just says you got a copy of such a report well you know i don't know i don't know it's a difference i don't see i i don't think it's contra and complies with the law that's a different argument them i didn't get such a report fair enough it is what you need to show that you didn't get such a report have an informational introduction you know  why because i think your honor that the statute provides that there's certain information not just giving a copy of whatever is thrown together in a report that doesn't serve the public disclosure provisions of the statute at all such report report refers to the file report well i think congress was fairly specific as to exactly what is supposed to be in these reports supposed to be in the report and also said to who polices that issue i'm sorry it it also says who polices whether there wasn't enough stuff in the report and it's not you well in this case i would suggest you that the agency at whoever's policing it doesn't have authority to waive the requirements of the statute number one number two the police even don't know that you have standing to bring a lawsuit that says they haven't been forcing the ethics in government act well i have standing well your honor my stand in to get such report what you did well i think you only get what congress authorized you to get correct and congress authorized any research you might be crystal clear on what you agree that you get and we're fighting now about what congress authorized but you would agree that an informational injury is something created by this one at least as created by statute and so your informational injury is to get what congress authorized you get whether they are right exactly and what congress authorized me to write to gaming more than what congress often does what congress authorized me to get was a report which contains certain information that's what congress authorizes that congress requires together and the president's liabilities are five hundred dollars but the corporate liabilities are five billion dollars doesn't tell you anything that's correct nancy you're out which is which  shows that you know i'm not asserting that the president is going to come from disclosing as much as he wants i mean maybe it should even be encouraged i don't know that is not the case is not the issue here is not what is prohibited interest except going to congress didn't see report everything congress or said report personal liabilities in excess of ten thousand dollars yet we're going to set and report at least personal liabilities at a require so that's what i'm not saying i'm just saying assume that hypothetical to ok ok then you would not have this argument i think that's fear think that's right i think there's another reason i am not saying that the statute prohibits him from reporting more than is required i think that's true and i think that he but under the way the statute is currently structured the president has a certain obligation to advise the public of what are his personal liability is in excess of ten thousand i don't know what your loses is we don't have the loan guy commands underlying which these mortgages secure and as i got copies of the mortgage documents but not the loan documents which are secured by the mortgages so unless you have the loan our separate documents from the mortgage documents but if it if the if it's listed as trump park avenue l c mortgage we know that's not a personal loan no i just can't that's correct your honor because the loan documents may have provisions requiring unconditional guarantees from the president under which would you know your theory bothers me the validity of it which is that we have to separate out the personal loans because that will reveal potential conflicts of interest which is what you told george rogers right but the same is true with if you've got a closely held court producer not public companies a closely held c donald trump is the only shareholder and he's got ten million dollars at stake would do a ship back to or a particular with trump to raul the same argument namely that would we have to know that in order to prevent conflicts good point and there's two responses you are st number one not all of the loan documents are the loans are to entities some of those loans are entities which are disclosed his assets on the financial disclosure statement i mean for example is a loan to t i h t chicago you will not find on the financial disclosure statement and if he call each teacher congo you'll find something kind of sounds like that but i have no way of knowing whether it's the same administrative office of u s courts correct but did you file a complaint with the particular agency no your honor i filed actually to begin with in this case started i sent a letter to the white house counsel a of government ethics no such procedure exists there's no regulations no guidance and it just doesn't exist and if i may say so from doing that or i'm sorry you are not barred from doing it or not bar no but the but the nd the nd point i would sponsor your question your honor is that with respect to the issue of the we know in so many of these cases you're right the presidents are closely held financial corporations and in some cases the president does have a financial interest in them but still we don't know the extent to which the president's financial interest exists except exist whereas if his personal liability we know the president's potential liable for the whole amount of the loan and that we liable for the entire amount on the loan even a closely held corporation if you pierce good corporate veil fair enough he could be but the point is you have to remember in this case we're still in a motion to dismiss stage for the litigation and we haven't had a chance yet to get into the fans and the meat of what the president is liable for what he's not like questions i'm asking don't go so much as good as to question whether there is some clear duty on the part of the president that  feel to satisfy to understand your honor and the president's clear duty is to let the public know which liability any personal liabilities advise the public of any personal liabilities of him spouse or independent child in excess of ten good morning and may it please the court i'm matthew glover and i represent the president the united states i think is the discussion with my friend mitchell of the key of vinces there are a raft of issues with his claim not least of which is the statute doesn't provide him a clear and indisputable right for the relief he seeks which is to have the president put an asterisk next to personal non personal liabilities in his ethics form and nor does the statute impose a duty on the president not to do so to add those aspects nor does it limit you to only disclosing certain things i think we put in our brief to a few places where the statute says you need not list something where you are not required to list something and it doesn't say but if you do here's what you need to do for those procedures court saying if on your reading of the statute i think there is a line to that effect we cited some country precedent below we didn't prevail and we think we have a lot of strong arguments obviously we can't concede standing by no i asked for the report they got thirty four dollars and they go wow you know i didn't fill out the report properly so i still have an informational injury no one would allow that under right that they get whatever the government has yes so and this actually is this is i read it honor and we had argued below relying on some cases dealing with the f e c that in that statutory scheme the court hell i believe was this court may but some district court had held there was no informational injury when what you were asking for the statute didn't produce but the district court here read the line friends of animals versus the government gives an individual right to receive particular information in the individual doesn't get that information that that's mission under for standing under article regulation i'm sorry if i can marry body yeah i mean i just i took him to say the attorney general's one of four authority is that you can bring a civil enforce a no no sir said he's not making a claim that procedure that that's true your honor and that's because the statute isn't contemplating individuals being involved in reviewing and asking for changes to see if i get a report that's all i'm getting is no you're for reconsideration correct john there is no formal procedure i would know what i think this is noted in the briefing in masers i believe it's in the opinion that there has been an entity that it has you know written a letter to the office of government ethics saying if you know you know we think this father's report was not completed know he just wrote the wrong he wrote to the wrong person wrote white house counsel to do it and he had an office of government given that there is no procedure the office of government ethics isn't under an obligation to respond to that he came into this court and he needs to show that there's a clear right to relief and of the president had a clear duty to do what he's asking for the asterix the liabilities and i  they put their personal liability in there and then voluntarily included the liabilities of every liability this person has every liability a family member has every liability friends have and so going on hundreds and hundreds and hundreds of pages resulting in completely obscuring but the statute requires to be disclosed would that until they have stated the liabilities they've just stated a lot of other liabilities your honor to secure that might be a closer case and i'm trying to ask whether that would violate a duty under the statute because i thought your theory was there's nothing in the statute that  may be a case for the ethics officer to inquire and say are you willfully violating this and or are you trying to do you can i mean that willfully did they can't willfully violated the statute doesn't permit it can't but i think the statute envisions a process in which if you produce i think you that would be a clear violation of the statute i don't think it will be a clear violation of statute on its face because it does not prohibit you from listing additional liabilities but i think that's far afield from where we are here and that would be you know they ethics officer it raised a red flag with them would discuss it with you and i see that i'm over time people all right i was thinking about previous presidents and their put their assets in a blind tr something like that and so when the disclosure form it was very limited as to what needed to be disclosed that was still  personal liability this president has taken a party to what i read in the press and that's all i know he's taken a different attitude toward continuing involvement in various corporate activity and i guess the way i was reading this was there's nothing that prevents him from doing what judge millette just described although the statute when it was passed and as it's been apply for a number of years has focused on the president's individual personal liability and so this disclosure may be a little different but there is nothing in the plain text of the statute that prevents the type  i just have two points prefigured like to make one an informational standing with specter standing and informational injury cases it's quite clear that standing is should be based on the appellant's interpretation of the statute that's that's number one and the court just accepts that interpretation and presumes the merits in standing with respect to standing second i think we have an adverb in there somewhere i agree ok i think you ha information that he could or that he was not prohibited from disclosing correct but when the disclosure itself when the information he voluntarily discloses obscures the information that he is required to when i was reading the statute that i thought i saw a provision that permitted congressional committees to review the the disclosures and then report back to the office of government ethics that they have problems with it's not right it doesn't exist with respect to the executive branch or a that is the i think the disclosures forms you're referring to those situations do come up for example when members of congress do not make the disclosures they're required to make big in that case the house ethics committee or the senate ethics committee is required in that case to take the issue and look at it and resolve it but with respect to the executive branch disclosures it's all handled  executive branch and as i said in my briefs there is no internal procedure in the executive branch to police the president's disclosures of some or little details are these reports these financial reports put online or do you