that's a that's a dodge of the argument i wanted to start off with but i think that the issues that are really at the heart of this case you were brought up in the apparent argument here and so i just want to take care of a couple of them the st one  yes and ok i agree that good ok and that's and that's what he you know he was told by the supervisor listen you have to tell the nurse what you saw and that's that's what our case is about that if they would have just told  factual scenario but what we do need to look at is someone who is experiencing these obvious concerns of intoxication mcraven is the one that is that is the easiest comparison and the citation to that one your honor i'll get you t one of many factual i and that's that and that's what really yeah and that's really the key here when we're talking about whether it's a serious medical need that is a question of that that is up to the jury so the jury goes and says ok what would a normal person with an average layperson look at a person who just deaf a kid all over himself and vomited all over himself and slipped off had a seizure or was under spots where they consider that to be a serious medical need the question of whether it's clearly established is is separate from the serious medical need that's why we're lying on mcraven that's why mcraven whenever these these are what i would consider much there is that his causation under the thought i did the analysis what would have happened that's irrelevant here all we're asked all that the court has to do is decide whether there was a constitutional violation whether it was clearly established law there's no that the court can even consider could be causation element that was brought up there but there is there is evidence in the record that we went through this summary judgment motion the nurse says yeah i want to know about this the doctor says well we would this back and forth i don't mean arms or you're not playing as an expert in this case that said all these all these symptoms are readily treatable in the hospital setting that we have we have expert testimony so i'm happy to take some questions on where where the you know the big issues are here but i think it really just comes down to whether it was clearly established that when you see someone that has these kinds of severe medical problems and you don't medical personnel in there but the issue for qualified immunity is is for the officers like you because the medical professionals don't have qualified immunity but the outside of course they do the  citation for you there i don't think that it's necessary been this case because they didn't even tell the night nurse whenever they came on duty so it wasn't just they didn't call it at the time that's the question i mean night nurse asserter you know that and that's the keep so the real question we got to ask is what would a reasonable person would a reasonable officer know that what they were doing was violating their rights well it would have been so we had that their supervisor told them officer white put in his report well i was told i need to tell the nurse whenever she gets in a reasonable person would know that that's that what their duty it under these circumstances they didn't do that yet if you are serious readily admit that they never talk to the nurse that's going to occur then deliberately ignore it there where and i think that that's what exactly what we put before the court that's what the court assumed those were the facts the core soon and so whenever you are in that position where the court goes well the legal question the fact the factual question we get to go up there put our case on we got to go up and say well yeah they saw x y and z they saw deprecate on stuff they saw going to see here and then the other side gets to come up and say well before you know before bed before