and our next case for this morning actually is roughly arising out of the same thing it's case number four michael needle p c against cousin o'connor this one is nineteen to china for one believe that is i believe that is the record before judge palmer i cannot cite specific citations to that your honor but it was it was argued you look through them looking for the brief right now to see where the point is but it was argued down below your honor this is mr is needle p c or whoever the client is making this argument because if you get rid of coalitions lean and somehow prevail on something else they'll be money in it for you i'm trying to figure out what's your interest since it seems that there brown's perfected lean which was superior to the coast and lean has already eaten up all the funds all the funds are that is part of it your honor when you look at the total breakdown of the of the monies of both cases it turns out that mr neil ends up with virtually nothing in this with the fact that cozen has a judgment against mr needle or his company is that that is part of the concern in that we believe the judgment was an error because you're just trying to eliminate the liability of the judgment yes i mean you're not getting because mayor brown has the money as far as i can tell  yes but the the argument here is that this should have never been with your withdrew after two months did not do much work the only work that he did do scuse me or the other work that was done was something that was not submitted to us to my client which was a verification of the eight thousand hours that mr newdow had put into the underlying case it did you argue below that the response to the motion to dismiss was not submitted to your client it's a st time hearing that's what i'm arguing your honor is that we never received any work because of alleges that they had done and basically it referred to an audit of of mr needles ours that that particular documentation never put over to us cosen payment at this case and i think there were about seven hundred documentaries are ready when cozen came into the case and they filed a response to the motion to dismiss that the court had been trying to get for some time the district court judge palmer specifically found that that work allowed your client to continue pressing its claim in the case how can you claim in light of enable him to recover any fault but that goes to the merits of his position at the district court specifically found on the altar alternative was dismissed at that point and the district essentially found that cozy and saved the case and its response to that motion is what led her to deny the motion to dismiss and the case to go forward that seems like a a big benefit to me and again there's a specific district court finding on that particular fact and we disagree with that specific finding your honor in that he did not know we could deference to just record findings unless there's some evidence to show otherwise unless there's evidence to show that they're clearly erroneous if it's a finding of fact would have provided some benefit we don't know i mean you have to take an ex ante perspective on these things can't just say well in the end it didn't work but i would also point noted oh it is not specifically noted no your honor but but cousins petition provided the district court with its reasons for a withdrawal and establish that it did have good cause in this case the petition stated that cause in cousins ability to be paid in the case but it also created a serious lack of trust between needle and co's in and ultimately a breakdown in the attorney client relationship which led to cozen giving needle its thirty a motion for default as as runners are aware and had been sanctioned several times and causing had to familiarize itself with the convoluted history of the case  learned that that wasn't going to happen gave our notice and then we were obligated to remain on for another thirty days but in that time period we continued to work there asli as as judge will on my are recognized   yes if you're on a team i don't think the judge judge palmer was required to specify a finding that there was good cause but i do think she was well aware of the in substantially primarily to produce his share of the find doesn't render the attorney when you invalid or in forcible that's not a requirement under under illinois and there's some confusion here between what pennsylvania requires correct or analogous circumstances correct it's in under illinois law the attorneys work just needs to assist in that recovery and present means that requirement here necessary in this case the judge acknowledge judge palmyra knowledge and was very familiar with cozens work in the case and the circumstances in which pose and was appearing  makes an argument in this reply and that's why we're defending this appeal and you know aside from having a valvoline cozen is defending its integrity in this case and while closing clearly had a disagreement with the needle relating to his truthfulness when he hired posen cause and gave one hundred percent effort and abided by its duty to faithfully represent him until the court granted cozens motion to withdraw and now needles contending the cause and should be compensated for that effort and it's causing position that that's just wrong and so we doubt that district court's decision and i thank you very much anything