ultimate merits with standing and the government has to prove any point of fault about me has to prove but we don't apply that test at the courthouse door to find out whether they're standing actually your honor i believe struggling with a low threshold with regard to the article three standing i understand you are trying to argue that the statute imposes something more but i have to say it's getting dangerously close to saying the government has to win before it can out of the courtroom  doctor's office and what didn't belong to them from the moment they signed this it means that their ability to get the car out of a parking garage didn't belong to them because of the five dollars he had in his pocket to pay the parking bill didn't belong to him anymore i mean that's something that is some completely all encompassing outside of the second trust is it your view that in california there is no longer a statute of frauds in other words if you have trust number one and the trust doors and the trustees are the cells and then you have trust number two in the trust doors or do you sell them the trustee is a third party that that this casual language you have in trust number two or it written in veins it doesn't require it just doesn't it doesn't require anything more than when it's that's already conveyance there's no description of the property i rejected the statute of frauds argument because the the provisions that i'm transferring all my property are at all the partition my interest in all the partnership property the partnership property could be an eye for by looking to even if you would you believe them the one point that they had an ownership they had no ownership interest in their lands property for possibly nine years before the government found forfeiture action on the ranch property and they had no ownership interest transfer or purported transfer and exhibit a or through the irrevocable trust document was an effective and stripping or taking ownership away from whatever on the before and putting it into the trust yes is fairly recent utah supreme court case which says you've got to have a description of the property ogust or the the relevant documents they are actually containing a description of the partnership property and you can see if you what property of the partners the people we're talking about the beverage first this cancer place or mine in case relied upon by the claim it's the california case in that case the california supreme court said the descriptions got to be reasonably certain and it has to the description was that it was near it was i believe seventy acres more a last below highway eighty near canton plain your mind in that was much more of the description it was very descriptive and it was it gave and parliament was this is these witnesses the decorations lack foundation clearly it had to have been based on hearsay because someone say it is just my understanding is really nothing about how they came to that knowledge in the government objected on those attempted to find out what information what witnesses and documents the claimants had and as a result the government noticed the depositions of each trust entity to try to flush out what their story was and the end result is the trust that we don't have any knowledge of the witness that we can provide so the government entered into a stipulation with them stipulation of facts which was filed with the court and became a court order and pursuant to that stipulation they said we have no witness who can testify about the transfer of any asset into their radical trust we have no witness who can testify about the management of any assets we have no knowledge about how it whether any tax returns were filed we have no knowledge about the drafting of either trust instrument and then two weeks later after that stipulation in order were found at the court the parties filed summary judgment motions in the corporations from the kleenex came forth at that point so as an additional grounds for the government's objection it was that because the claimants would have to be able to prove the elements of the construction in the first element is you have to demonstrate your rights to the rest in order to demonstrate that they actually have a right to this property you have to look at the written documents none of which describes property and so you really have to look at california law to determine whether or not they have a right to distress and under california law you have to look at whether or not the document satisfies the statute  from the trustee saying well it was my it was ours we knew it was wrong it was ours and somebody made a promise to us they promised that they were going to take the party temporarily and they were going to transfer it back there's just no evidence that this property  itself and the i r s had recorded a lien on the ski lodge in utah for about approximately one million dollars and it was attempting it was just like a creditor attempting to collect on his debt and what you see in the record is the s didn't get any notice of the foreclosure action and it was an ira as well a new agent went in to try to stop the foreclosure action so they would have some time to explore the issue because they had no choice but foreclosure and they were trying to preserve the government's rights as a bowden about privileged issues that's when the government learned that if you cells were really the owners of c i b m which was the then title holder on the property in san diego and the government would point out that the is not the position of the government has been advocating with regard to what what evidence can be beautiful stock authenticated or potentially authenticated in some fashion and what's the basis for forgetting mean it's a common practice attorneys are frequently doing that but that never authenticate the document as the documentary never has personal knowledge of of a document like that he's saying basically this is evidence we're going to submit but that doesn't authenticate i understand