fun good afternoon your honour's may please the court just like reserve two minutes for about of that's ok ok i'm the plaintiff appellant in this case some an attorney i'm representing myself and i believe i'm entitled to an injunction pending appeal  the denial of the injunction by the district court for the following reasons under the four factor test i meet all of the factors and they will weigh in my favor first of all on the irreparable harm issue the harm that we're discussing is happening as we speak  s is not wheelchair accessible not by any means and attorneys such as myself are denied meaningful access you go and try to conference a case because jury you can't get up to the conference room there's no ramp provided you try to use some of the bathrooms are not accessible or if they are they're very tight you'll be a science of motion parts the trials will try to get into a court room and you just can't fit through the bench and some of the bedrooms don't work and the important point is this is not just for the broken courthouse for example terrible situation as you're an attorney you work for a firm it's kind of difficult to complain about the situation you make do with terrible situations terrible narrow courtroom when it's all in the papers have been circumstances when there's been no working  bathroom yes there have been the last two trials i did were on the fourth floor and there's no bathroom on there that's accessible and until a couple in the courthouse is a whole i mean i thought there were three on three or three that are accessible and on two occasions i was trying a case they were completely out of order say that's been remedied now based on their efforts but it definitely is reparable harm and i'd like to move on to the other factors if that's ok if that's time is limited substantial injuries to a party the government's not going to be injured the quicker they get to remedies the jury are still wrong and obviously i think that's because they wanted jurors to thank but i'll leave that for another matter as far as the the public insurance this is not just about me anything they do for disability access will help every single person will bill interest the new signs they put in for the first time have braille on them so blind people can know where to go to the bathroom and finally in the likelihood of success of this appeal the district judge denied my motion within about an eight hours no hearing didn't hold any fact finding it's defective as a matter of law ultimate relief in this litigation but he has not shown irreparable harm and he has not shown a clearance or stanch a likelihood of success on the merits a heightened bar that applies here because the injunction sought is both mandatory and because it's sixty  want to start with the reparable harm the only concrete harm the point of identifies in his papers consists of two upcoming trials one this month one next month well we've been tracking those trials based on the index numbers provided so that we can reasonably accommodate plaintiffs in those two trials and what we've learned is that one has been transferred to another courthouse and the other has settled so the only concrete harm identified it no longer exists that should be enough to deny the motion on the basis that there is no irreparable harm and that's not just speculative the other harm the point of identifies that he might be in the courthouse on certain days is to conjectural to meet the standard for a stay pending appeal that this court has articulated in prior cases it isn't reasonable of plaintiff to demand access under the rehab back to the eighty eight to a working bathroom and my understanding is there have been occasions in which there's been no accessible bathroom in the in the whole court house i mean putting aside the question of the law library and other public facilities that he isn't titled have access to why isn't that both kind of immediate and irreparable need if if that their situations and now can monitor them so that those bathrooms remain in working order so the city could be be sure and promise basically to maintain a working accessible bathroom at all times well obviously there are situations where an individual toilet might become in operable and that would require attention i don't think would be possible to ever know between monitor it rather than to let it yes and i think that the defendants can promise to monitor the situation going forward and as it stands today those bathrooms are in working order in addition to ca the office of quarter ministration reached out this week to point of to let him know that going forward he should just let them know of any proceedings he has in the king's county supreme court house and they will make efforts to reasonably accommodate him including by transferring his proceedings to one of the four fully a b a compliant court rooms in the courthouse in which he is able to maneuver without human intervention indeed he admits in his peepers that those courtrooms are stark contrast to the unidentified ones about which he complains are there any plans to provide access to the law library and some of the other details of those structure negotiations are confidential as i understand it so i unfortunately am not able to provide more detail i actually don't have more detail myself am i right in understanding that the only portion of the courthouse t least for now are reasonable accommodation can be ensuring that point of proceedings take place in one of those four fully compliant court rooms as for something like the law library just carney  that he didn't have a quiet place to review his notes if that is the combination he needs o c a is more than willing to find a way for him to have a quiet place in the courtroom to review his notes or otherwise prepare for trial and other proceedings in the building that the touchstone here is reasonable i and in terms of likelihood of success on the merits i think plaintiff has not shown it because he has not shown that he's even made these requests for reasonable accommodations would his paper show or ad hoc requests to be accommodated on a one off basis often at the last minute  interest in this and he said that any requests can also go to him they can also go to the chief clerk charles small or to his first deputy so as to any of those people can handle our request and they will be logging these in a systematic  i just want to know that there's nothing in any of the papers or any evidence somewhere that there's ever been a situation where all three of the accessible bathrooms have been out of order there is no  just to speak briefly to the issue of temporary ramps and law library i think that the plaintiff makes it sound like this would be some sort of you know five minute fix i think that the reason that there's a very methodical process for renovations and and the judges here where this building was renovated not long ago is is it takes a long time there's lots of compliance or lots of regulations both at the state local and federal level that need to be met you know just even focusing on j itself has very strict requirements as to the grade and slope that's permissible and there's no showing at all that even you know those you know simple requirements could be met here if there are no further questions thank you thanks so as the thing comes down basically for reasonable accommodation to be reasonable has to be effective and in order to be effective as this court is held and right versus corrections last year it has to get rid of non trivial temporal delays delays a time and has to get rid of structural impediments for example as a complaint shows before that case was filed and on aug sixteenth i wanted to watch a case of one of my colleagues watching the lawsuit was filed the court basically said we're not going to we're not going to relocate it for you that was invalid then after the suit was filed i prepared my client for trial over the weekend it was a big trial it took four days to do and they relocated me from the room that was not accessible but we waited an hour an hour and a half to get it my client is freaking out everyone is like what's going on here we finally got to the courtroom and it's not an easy complaint courtroom it's not it's barely accessible you can't get around that's not an effective accommodation it doesn't get rid of the temporal delays because you still have to find another floor for a bathroom it doesn't get rid of structural impediments because there's other issues there and it's  impossible to ask a trial attorney who wants to build a reputation from there only being out of law school for three years to every time you go to the court once or twice a week to ask a sitting judge i'm sorry you're going to have to move your court to another place that just doesn't bode well and it's kind of similar to the situation the right kids where the inmate was kind of scared to tell officers or has cellmate that what was being given is insufficient because it harms him with the wanted the judge to hold a hearing to find some facts at the early juncture as required on a on a plane or injunction a normal overtime but that's really the purpose of this idea that the judge can serve any evidentiary hearing no evidentiary hearing at all the right the appeal is only on the question of whether we should grant the stay of the district court proceeding what is it do you want well on this motion i'm just asking for a temporary injunction to require the government's you basically provide temporary access you're