likely they're from michigan as somewhere else if we don't know where they're from at this point you'd be asking us to speculate that's true most of the as you just summarize yours wrongest argument as to why we should is most centrally located inconvenient all the parties then you know then that the plaintiff's choice of form should prevail obviously we're entitled to substantial deference because we believe this contract cause a national rise in illinois maybe the rd argument that i think is also worth considering is that defendant has failed to meet their burden in this case the declaration of mr beaudry which is attached to the fairness of titian promotion is grossly deficient the case law does require that defendant alleged facts indicating that illinois were the alternative for him is more can be done for all the parties and witnesses in this case they did not do  have to say that in so many words you have to use the word convenient well i don't know that he has to use the word convenient specifically there's no discussion of travel expenses there's no discussion of time expense you know travel time there's no discussion of you know any burden on you one way versus michigan and i think that's a live hurdle that must be m and there are extensive facts indicating that this cause of action rises in both illinois and other jurisdictions you know that's not really in dispute but we believe that illinois has a substantial interest in this case because the financial aspects of this transaction occurred in illinois and as much as this case is a case about production and manufacturing it's also a case about the financial aspects of the of the criminal and we're going to need witnesses and there's going to be evidence that's related to that that comes out of illinois illinois has a substantial interest in in reviewing you know the acts of its citizens and there were many acts that occurred apples to apples with the court congestion numbers i recognize that defended his produced numbers indicating that there's a very substantial difference between the total number of cases that have been filed and you ursus the number of cases that have been that are filed in kent county which i don't dispute that gross number but i don't believe there's a sufficient breakdown in the numbers that have been provided to indicate we're talking about a lot of asian cases obviously but a judge's docket if it's full of lot of vision cases is going to translate much differently than you know four hundred traffic cases and i'm not sure that we know with those cases are we haven't been told that we just weren't given a gross number so you know i believe the judge was clear you know like you said your honor and the judge would indicate it would be great if i had less cases but in this case he couldn't find any reason  from the docket aspect that he should dismiss the case so i don't see any reason why you know there was an abuse of discretion in that decision is just he's equally significant as the place where someone's legislature performed their portion of the agreement i think that is a significant factor and they're entitled to their significance we're entitled to our ears and we  complaint and also the counter affidavit attached to that police motion before the trial the one of the points that was made you do here to look at the facts at the facts that are in this record and this discussion about credit terms is not in the record if you look at the complaint which brief you characterize a complaint said you concluded two pages of rumbling were put language well cell phone data and retrieval and you suggest that this one was cut paste i things he wanted to search for videos and images and he explains how these images can be city correct and preserved for viewing at a later point in time yes it isn't that closer question and even that would not be probable cause if you look at the case that addressed let's just look at patient dress in your possession of the phone and whether that in itself is a link to justify the search of that phone let me ask you with just the four corners of the warrant it is to know the supreme court did not say that the supreme court in mansell's reference is with respect to reviewing the trial court's decision not to issue a judge and in so again most cases in many cases maybe not most are decided on the steamer to review is it critical that we apply the correct spirit of review i don't want to get hung up on what the center of view is because what it comes down was she taken who sexually assaulted him and why did this occur sakhalin and now are all of those have put that in the warrant that's that's the problem you can't deal with what we think the warrant meant to say we have to d in reviewing a judge's decision and issue a judge's decision we use a commonsense approach and we defer to the trial and into the issue judge correct commonsense is an extremely vague term in and so courts are saying well in practice what is common sense to me ok and man so look that someone walked out of a house and sold a bunch of drugs that's not maybe it's reasonable think there might be drugs and i mean and that's just not what people do people don't leave their phones away from that they care you hearing them with the right no so and that's like earlier stated mere possession cannot be the sole basis for searching a phone seems to be that because the defendant was successful in boarding detection for a couple of days whatever probably cause may have existed has evaporated now i'm saying you need to link the crime  the idea that when someone is accused of sexual saw that it's reasonable to infer that they are also holding child pornography on their phone course of address that and said that in ence is not reasonable the only instance i could find of the case where they said that was reasonable was where the officer said based on my experience people who sexually assault children often have  reason why we don't know if that's even true and that's why we want officers to tell him that in the in the affidavit because they're sitting under oath and it's based on their experience and so for us we make that up it's under oath but it would still be a difficult question and manful gets to this point they say that links based solely on officer experience there's there are splits in the courts about whether that their case that when you were trying to apply logical reasoning to a suspect it is vivi's of the suspect the three of course that we cannot say that a reasonable person would readily ascribe common sense and logical reasoning to one who engaged in a bizarre crime the facts and the police requests to view the video images is not reasonable that's not what a no reasonable person would agree with this judge is essentially what we would have to find correct i think we need to nail down what george when they offenses are located on the above described items in paragraphs eight through our above so while the earlier you said we don't know for sure that this is a cut and paste job certainly there is some evidence direct evidence which come paste but if this was done intentionally then i'd have to wonder are they reading this why are they thinking that this is even a link it looks like a cut and paste and  hands so there's not the concern about it being destroyed and things being raced is it isn't the destruction of the possible destruction of evidence and exigent circumstance absolutely good enough why it's important that he had the officer had the phone in the front was arrested so the possibility of this being destroyed is not but they still didn't know the location of the the precise location where defense occurred where and she was taken where he assaulted her they did know online the mere fact that you sell drugs is not enough to search your home it's not enough to search your phone it's not enough to search the car you have to have some skin there linking more can be based on surely bare bones bare bones affidavit and while i agree there's not mine and here it's just definitely rushed it's possibly cut and pasted and looks to be  to the actual writing to be served it will be putting all these pages of your own information is that the police officer clearly lays out the people who produce child pornography say and of course he's not he did they did whether there may or may not be but maybe he didn't put that link down there because he in his experience that was true of good it and that's the only inference we can draw from him not saying he didn't put in there my experience is that people commit photograph what they're doing with these children right and so on that's why there's no rush we have to for what it's commonsense isn't it what's comes that people who there would be no explosion of child pornography on the internet if people didn't these images there's an explosion every day one million said and millions of images of this type of sick behavior are downloaded on the internet by predators who grab children in communities warble crimes that is given to home we don't have that here this is a car and a cell phone found in a car so it's not exactly the orders some people would say that having of your phone has more private information than your but man so they saw him leaving the house selling drugs right away we don't have him arrested with the phone immediately after the offense because he did this case a bit further removed from even manson because he  i'm not saying you're saying it you said it in your brief if the the phone had been recovered ah right after immediately after the facts then the inference would be would be a fair inference but because he and why they were asking to look at the phone to explain or to find out where the assault occurred who committed the assault what was the object it was used why did he do this  all those questions that might be revealed by the cell phone if if they had put those questions in the warrant that the war would have passed muster can't the trial judge him for that these are reasonable a reasonable basis the should and i think that i guess to this day we characterize it as a non deliberate or i don't think that that it's not intended to be misleading earlier and the license plate information that the sister heads of this you know the cell phone wasn't the only evidence here and then there was evidence from a bystander that dropped or just a sudden drive away from the parking lot where she was isn't in the standard is not whether or not it's more probable than not or a strong likelihood it's a fair probability that the evidence might be found because of that the standard pressure off their probability you don't have a  i don't think so i mean i think we all specially judges have to inform some of their decisions based on life experience and i don't think it's always going to be that well extract once stated in the warrants that we have to assume that's not true judge had a substantial basis to issue the warrant right got a search warrant for the home puter and the poor really looked at stale in which could be an issue here because it was so quick we're talking two days later and manzanillo i think the big distinction  making an attempt to link these two up and given that we have such a young victim who is very unlikely to be able to link up the cell phone to the defendant in the commission of a crime i think also certainly act in good faith and a supreme court said and again in store we don't record but what the common sense of people who commit crimes like this bizarre behavior and in fact the facts show that your client did exactly a defendant who commits a bizarre set of crimes what a rational person would be doing in the same set of circumstances and the that goes a judge issuing a search warrant the standard is reasonable and franc making reasonable inferences of what made the recorder or whether or not the police have a reasonable grounds to request a warrant whether or not there's a fair probability not not a substantial probability not likely it's so two thousand and eighteen just came out and said you have to look like the reason if you're not looking they need time you're just of a crime it's fair game to search your phone it seems that your argument is and that was taken from us but when there's factual determinations when there's evidence you're hearing like a motion to suppress and they talk about what the officer did so you search the item and everything then those facts and the term