having business before this honorable court may now drawn near and they will be heard that state the united states and this honorable court first case for argument this morning case number  books letters or magazines newspapers can be sent through the mail the prisoners cannot receive them through any other means in fact if your v c did call to determine whether or not they could send them they were told that there was no means for each other p c to send good books b and i apologize your honor is in our briefing but there is no no fiction reading and the law library is limited to four books and the only books allowed in the would just go back to the exact same nd factor for her considering what the ban does and the impact on those asserted rights you also have to look at the plaintiff your publisher means of expression for  sees particular speech to a new feasible alternative it's like their work of the mother and simpson and the absence of feasible alternatives is evidence that regulation isn't reasonable he probably alternatives that we have in the lower court are not only and reasonable but total ban on all of age thirty c but we would also say that it's a total ban on every other publisher in the united states as well publishers do not print books on postcards and in particular other publishers could be subject to a reasonable turn like they have been county jail it's a block and a half from my courthouse there are major jurors in new york city so when you say every other jail that to me is as not it helpful he still didn't consider those whatsoever and like the st factor where we get to look at whether or not their decision pretty during and post implementation is arbitrary that's the most important here we see at every single phase of this implementation of this policy it's arbitrary and it's a rational as related to the legitimate people logical interests they initially the general got only two reasons for its regulation st as a security precaution discreet to decrease the amount of incoming contraband and nd as a cost saving measure for the county which has to supply postage for indigent and  not indistinguishable but it's fairly baxley similar in those it operates as a total ban on letters newspapers books and magazines if the simpson point to it had challenge it as facial they could have made that argument they didn't  client well not only does my client not have access to that prison library and there's no means to donate or otherwise is going to be requested to see if we could send some men but that prison library also is not it serves the purpose of assisting publications does special publications so not all of them with well within the strictly legal law library category nor does it need to because they felt he still has a right to communicate even if it wasn't political or advocacy speech it still has a right to communicate that speech and given the complexity of the issues it would be impossible to reduce the contents of that legal speech into postcards we would flood the jury over thousands of postcards of exactly everything that the j that to sell your when your d c colin followed up regarding the policy was told that there was no means of sending it works and again at trial to share my grammer he confirmed that there were no means other than individuals bringing  actual finding predicated on such things as one person doesn't sort of phone calls nor alternative means of communication among the artists client burger but those are not me those are the three that were brought up and since so don't book certainly seen or been focused on because those are already been approved as available alternative agents in this case was about notice and the afternoon be heard if they were attempting to avail themselves by making a phone call there's no evidence chairman henry testified  i find that that a child to see up may tend to distinguish various types of mailings with respect to the policy or was it across the board or not subscriptions versus the good name getting books helpful books and pamphlets into the into the inmates hands this is what was it it wasn't cross the board trial we did present evidence across the was the district court asked to during a separate turner analysis for the different kinds of things you want different kinds of mailings you wish to have a constitutionally protected not necessarily