dollars which is the term signaling that she the district court sole finding on this issue was was that the officers were driving behind mr wrenn to rehear when he require showing that there was at least actual or potential impact on another car including the officer's car of middling for the violation of the law now here there was no such evidence presented the government presented no evidence that the turn had any impact whatsoever of any kind on the officer's car and there were no other cars on the road as the officers themselves concede it's on the speed of the officers car whether it's because of the distance between the two vehicles whether it's because the police officer was stopped and could have potentially kept going could not because of the turn every single one of those cases has there must have been at least the possibility of an impact and why doesn't that why doesn't that argument go to whether he actually could have been convicted  of a violation i mean reasonable suspicion or reasonable probability to give them the opportunity to stop him it seems to be a lower standard i mean i mean you're saying that because they didn't say that the district court that therefore the whole thing was polluted but but that doesn't go to the fact of they may have had that in their head at the time they stopped it i think the court's point i think the issue of your honor is that the government bears the burden of showing that reasonable suspicion was proper that there was some reasonable suspicion in this case i don't think there's any authority that says that  a conclusory statements such as we were driving behind him which is what we have in this case that is literally all have that the record shows we were driving behind doesn't play anything else i  don't think any authority stands for the proposition that that's enough to support a minimum of reasonable suspicion which is all that the government had to do in this case they say that yes if the court look and seen him and no one a nd i'm not sure that's a fair statement i mean at the end of the day the officers did say he didn't turn on his turns i i don't know how far away from a car you need to be to determine whether the turn signals been turned on or not but certainly you would be able to note that from a mile or so so i i mean that's where i just i think it's an interesting argument i just don't know how they get you  reasonable suspicion if he was charged and we were reviewing of whether he actually should have been convicted on a left turn you know i'm not putting on signal it's an interesting argument but i think the reasonable suspicion  case and i think that's the issue that that we're facing here i think i think the court looks at the court's briefing room the court basically said well i read these cases and these cases say that if you're behind that is what if anything does the u s supreme court said in its cases about when a traffic stop amounts to reasonable honor i think the standard is is is the classic standard where if it's a very minimum if it's a very minimum showing to show that certain facts can provide reasonable why we don't have that here we just don't know anything and i think that's our because everybody's focused on kind of what happened after that point which are more interesting questions of whether or not it happened or not but books but at the end of the day of the so i believe the supreme court is that you need at a minimum some some particularized facts that you don't know why reasonable standard the terry case for what's reasonable suspicion i don't believe that it is your honor i think at the end of day the court to the officers still need  those six minutes i think the court is going to see it is going to find contrary to what the district court found here which is there was no the consent was completely knowing and voluntary i think the court  mr renner rhea's demeanor was far different than what was perjury by the district court meaning even from the get go as soon as he was placed in hand coats one of the officers is already searching the car and  at that point no consent had really been given basically the officer says i got over here look for some papers and he goes over there and he's searching inside inside the front cabin and finds nothing at least and is shouting some strange things  allegedly given mr renner you know was trying to even talk to the officer and say hey we wait a minute and the officer was already gone off to the races and that coupled with the fact that he was in handcuffs the whole time even after the that she didn't have a warrant out for his arrest they still left him in handcuffs and the fact that he wasn't given his miranda warnings or told that he could refuse consent we think that weighs in favor of a of a finding  involuntary and finally i'll say a little bit about the whole destruction of the car i think if the court looks far reply brief if if the court sees the timeline of events i think we've we feel that that supports finding of bad faith in this case it's not as easy to say well look the government let the car go and the the car company just destroyed it they tried to warn him what the court has to focus on is what the government knew at the time that they released this car and if the courts see that's a very compact timeline in terms of that not that much time went by between when this all happen and when mr wren ultimately it was only a few weeks and still at the end of the day the government said well look we can't hold the car forever and we can't be held to that really the government knew right off the bat that the car was going to be this paddle it was very easy to do and there was really no way to revoke that because the the car had been strong so and i think the government could and should have known that it could have been just a plane that anticipated that from the very beginning when united states i'd like to start with the reasonable suspicion is share with the court's permission with respect to reasonable suspicion the clearest paths were firms to give due deference to the district court's finding that the defendant and signaled turn may have affected the patrol car or driving behind him well there was no finding of the exact distance between the patrol car and the defendant's car that is not necessary under the law  did testify at trial but there was only fifty feet between the hole in the patrol car right before the toher turn into the alley but i submit that the record before the district court was sufficient that the court could have inferred that the patrol car and the talk were close enough that the patrol car was affected by may have been affected by the defendant's right hand turn into the alley the evidence in the record is that st officer may have testified in his declaration stated in the declaration and testified that he was driving up behind the founding nd at and that there were no other cars between them there were no other cars on fix all that time nd even though it was dusk and even though the defendant had tinted windows the defendant that the patrol car was driving up behind him and that's why the defendant attempted to flee leaving tried marks scorched in two separate locations and finally i would submit to the court that the only reason  that the officers were actually able to catch sight of the defendant and they were able to follow him despite the fact that he was speeding and doing his best bade them is because of the officers were already close enough to the toher to begin with  this record there is no clear air around the district court's finding the there was reasonable suspicion for the traffic stop and the defendant's on signal on may have affected the patrol car driving behind with respect to unless the court has any questions for mean with respect to reasonable suspicion i will move ahead to the consent to search issue there is no clear error in the district court's ruling that the defendant voluntarily consented to the search of the talk the district court found that the defendant voluntarily consented to the search and although he was in handcuffs and miranda warnings had not been provided content was voluntary considering th circumstances in particular the nature of the interaction between the defendant and officer now so and i would urge the court not to just watch the st six minutes of the video the defendant was not actually handcuffed in the st six minutes of the video watch the st release the st twenty minutes of the video including mitt from minute ten to about minute eight seen or so where the defendant was talking to officer a no so he was engaging in a casual relax conversation about serino so they were just gusting opteron notes on multiple occasions expressed admiration for the defendant's car they were disgusting at the neighborhood and how the neighborhood had been in the past the defendant felt comfortable enough that he told officer a no so that he'd been shot multiple times that he'd left two gang life behind and he even at one point solicited off serranos advice from a car accident that he'd been on this basis and taking into account again th value of the car was not evidence of the government the government did not act in bad faith at worst it was negligence and the district court's ruling should be what we wanted to just ask one question on that it just seems like there is an inherent need for the card to show where it where the gun was found in one of the one of the arguments here used how accessible was it and so why wouldn't that have been enough for the government to know that they needed to your car the court found that there were the st big government was not on notice that this was going to be the defendant theory at trial but nd the government the court noted that the government had thoroughly search and examine the car had taken photos had processed the car for evidence and made sure that it could be released there was testimony from officer jenkins that it was easy for him to lift the the concealed come the window control panel and there's no there's the burden on the defendant to at some point to prove that had they had an opportunity to actually examine the compartment that there would have been some sort of they would been able to make some sort of heavy out of this out of this examination and the defendant simply has not met this burden the defendant was august over six months after the defendant had already been  destroyed so the government had already done what it would do go to the grand jury use all this information to bring criminal charges including the possession of the gun and then at that point the car had not been  really work i it wasn't as easy or he could trust me look the gun was placed in there in a way that we couldn't have been able to move at least somebody from his side could have could have tried to present some conflicting evidence to what the government did which is the court looks at the transcript of the trial the fence counsel basically try to get try to get the government officers there now it was a very successful moment that didn't really pan out so  anyway i'm over my time so i'm not here you know who is the owner of the car the owner of the car was it was the least his position that it's his least car but he doesn't know that there's a secret compartment with the well that's i mean  remote argument i'm sure hope it will be good practice for you for the next pandemic