there was a parade of victims who testified as to what the trees and he told them that persuaded them that she was going to help them not whip them off in her defense advocate took the stand and told the jury that she believed that her client's counsel never made an offer of proof at trial and rule one on three b i submit requires such an offer of proof and that to me is the weakest point in your album was said that she had conversations were from other rebel about mr williams she had conversations from mother about whether a mother was helping her friend isabel morales get residency documents she had conversations with her try to reach the bar getting to the jury thank you thank you is a a long case for me it was eleven days of testimony possibly forty nine witnesses were listed initially well not all forty nine witnesses actually got called it was it was a large case and part of part of the press of it came from the fact it seems like the government is trying to set a conspiracy case despite the fact that it was distinct charges outlined in the particular counts and the fact is so much evidence was presented to the jury and the fact ha it was so difficult for counsel to keep everything sure it was difficult to ask the jury to render a verdict in this case and the fact that they came back with the questions that they did suggest showed that they were s and that's why the specific unanimity instruction that was requested after question number three the question of five from the jury was so important i think it's interesting that it's judge cell use case and le and judge her way as case in new will this sort of creates this division force and i think that probably the best way to divide these cases is that in the lead on lightly we're not talking about a stack of credit cards and the jury was simply asked to decide well did they did they do something or which one of these did make this in this case more like new because we had this threat of federal criminal the jury has to be unanimous as to the defendant's guilt i don't know what more did you want in terms of the human image i think what we wanted was a chance for the jury don't understand that it's not just it's not just being criminal there's a lot of evidence that came in there but that doesn't answer my question what what did you want the judge to say to the jury that had already been said substance when the judge us in making that determination what more should the judge of told that but to put it plainly i think that the judge should have told the jury that they have to unanimously agree on what was say it was that there was a lot of bad stuff happening here even though these particular counts didn't deal with my client's bank account you should still convict her because she was in on the scheme as a whole and when you're talking about the scheme as a whole i think we have to get the separate unanimity instruction involved because you didn't know me as to what as to where and when just like in chad we can't convict for assault i specifically requested a separate unanimity instruction night and i suggested we go through the transcript there's a conversation between myself and judge moment where judge shown in specific we talked about the idea that he had considered the ideas specific scheme that you wanted to be separate instructed on is it possible i think it's going to be difficult i think it's going to be difficult because the case just doesn't get it so what do you want to have happen i mean what i really want them to decide it is for everybody to agree that she did  always see separate unanimity instructions would be in say a state level criminal prosecution for sexual assault on a series of days where you narrow down so that was sort of where it came at it from and then i didn't know think the testimony was that information provided they used to that information in part from zuniga there's some testimony did the alleged victims got a phone call and he wasn't really sure who it came from but the i think the most important point is they didn't convict her on all the counts this was a split birth five counts conviction one deadlock two not guilty and the idea i think that conveys that they did not believe in principle liability here and so it's important to know that they all came together in a decision on so i think the the biggest problem is that because we have the principal liability church in aiding and abetting instruction as well as a vocal blindness instruction we don't really know how they got there well  that make a difference i think it does because we'll take the john doe accounts for example it's more than just brute facts to say we think she did it there's enough here i think in this case we need to separate instruction to prevent her from being convicted on of where there's smoke there's fire kind of theory especially in the context of the john doe and titans thank you thank you issue more broadly is that the way that wire fraud works if you have to show no participation in the scheme and there's not a requirement of showing a connection to each specific just so i try to say just as you can be yes but i just want to understand if the that as to one victim the money went into their personal account and they use it for personal purposes with debbie sufficient to make every town viable even if there was no the opening argument the only argument made with respect to what the jury would hear about her pain would believe it was that she believed that she was the pain you believe that a mother was helping her sister and brother now that she believes anything about her work with others that her mother was a was simply the court thought that was simply a matter of sort of general awareness of what was going on their household and not directly relevant and you have just did not perceive the reason why that would particularly be meet the stated and precise words again this is defendant is total ninety time get into conversations because once he is thirty even if we offered not for the truth of the matter is true that we don't know on this record what conversations to defend the point of prof probably have here is the group out of the property we can't say anything more than that where the evidence would have been exactly what was offered the impressions but simply the mother's words that's the most we can say because nothing more was ever given to the district court my mother you most would have done no more than restating the mother's words i wish was doing it on the up and up because she said she was and that that coupled with all the evidence the money she spent the ways that pay in particular was involved reading in talking to people telling people that she was going to continue her mother's mom and they had no way of assessing that defense because they didn't have the basis for the substance of what that offense was based on we don't know the jury would have believed her but we can certainly say as a least a