the product liability claims of ninety eight plaintiffs who have absolutely no connection whatsoever to st clair county with the claims to residents of s the principles and factors informed on convenience are well known to this court the cases are all cited in the breach of the parties and i'm not going to meet those principles of those cases principles  detail here today the key is to talk about how those principles apply to the factual situation i think it's important to note one thing right now so there's no dispute that the claims of ninety eight of these plaintiffs if they had been brought they had attempted to sue and sink their county against the defendants then under the doctrine of form nine beans there's no dispute that those cases individually would have been transferred dismissed and cannot argue that he did in private interest or public interest would be served by having any one of these ninety eight plaintiffs from thirty one different states outside of st clair county somehow magically becomes a convenient form for these out of state planes because the plaintiff lawyers combine the claims to think they are county residents with ninety eight claims  counsel law firm from louisiana and texas been used by a couple other law firms as well another deal on this issue is pending and this is for the court is excepted of addition for leave to appeal on the wilson case against or case against another pharmaceutical company i represent with eighty five players from all around the country and one residence for the judges in madison county have not committed this type of ignoring  we believe this is an important case this case gives the court once and for all the opportunity to stop what we consider being abused it's just i'm going to talk about private interest in public interest that we believe judge police and misapplied the law we asked him to certify that questions of the law is clear he declined to do so and we have not appeal that issue wherever we feel the form one c we believe this court has the power and must remain and these cases to thank their county with instructions to have the cases transferred to the appropriate county in illinois not find one of these cases without testimony from the driving doctor and the treatment and when the doctors are in virginia or california or florida or who knows where in these thirty one states it's implausible to have them forty's access to evidence practical problems of trial all of these factors of private interest weigh in these cases favor these cases or see where the plaintiff and their doctors reside none of those factors no for these ninety plaintiffs point to saying but you know the private interest issue here this private interest issue particularly about the availability of these prescribing doctor pretty doctor it overwhelms every other there's no feeling that these cases represent some type of issue of national importance in fact except for the two cases brought by these law firms in st bernard is only a couple of other pending cases anywhere else in the united states with the same kind of allegations about those brown skin disorder related level so there is no issue of national or we're dealing with here also why still annoying  best in most convenient for the plaintiff and certainly with the best and most convenient for the court will be giving a green light to law firms around the country to bring all the cases the same fair count that would be the wrong result for the citizens of this state it would be the wrong result for the court system of this state and it would be the wrong result for the all the individuals and companies to rely on this court system we urge this court here now to put in it is fr always we always instruct services and that i do your honor and as you just read they could have separate trials so forth and so on why wouldn't we separately determine the form the inconvenience issue as to each plaintiff's case well that's the way i just heard mr reed or you know that he was missed talking about things like common issues between the plaintiffs and the fact that their same kind of conduct those are those are not factors under a fortni i just for brought up that is in our brief and in that case it involves some not a claim against all state or in which the the underlying fracture in five different states and under a form nine convenience analysis record there is the district back in two thousand and four said no you've got to bring these cases in where those five different events occurred and where the witnesses are your argument here is that that all that each of the plaintiffs claims in these two cases arose out of totally separate frame sakshi jessica and other words if we'd had a boss coming through southern illinois with people from thirty two states on it and it my believe judge told her she would your case the proper level in which thirty two plaintiffs were joined in one case and that in the court went through just this four went through the analysis and said twenty seven of them don't have any connection with thank their count