catch twenty two for the government and let's say they say you cars the shredding fifteen passports on november sixteenth and such and such a place and everything's very particular and they prove it and you say well you have to demonstrate whose passports they were shredded and you don't anymore no and i mean when was that particular document drawn we're not saying that they have to  a particular person passport by name but they have to prove that he was aware that a passport was to be shredded and that he intended that passports be shredded when the passport couldn't otherwise be shredded and the we don't know what their exact thought process was but all of the evidence could be considered by the jury with respect to these two counts so any evidence in the record varying on these two counts is fair game for the government says that this happens all the time rolls prince who was the assistant senator rector for the record to explain what the ira's policy was with respect to reading made very clear that certain receipt notices documents that was on the awful situation she knows that she's read i seventy seven of his but she doesn't know what kind and unless the government can prove that mr salazar intended that seven out of seven notices that could not otherwise be inferences in favor of a verdict there is evidence from which reasonable finder of fact could have found that your client knew that the documents that were given to be destroyed on those states should not have been destroyed and i think that's their from his own words that they were and he says he was under orders to do this that they started shouting that in your filing which he knew the inner filing was not to be shredded and  documents were going to be shredded now we assert that again he does not need to know that these particular documents were shredded but i did see in the record that he did in mid m two occasions that he did review  undisputed he admits that he ordered his corpse to destroy it there are two aspects under willfully also and one is that he had no and it to be unlawful and secondly that it was done for the purpose of violating a known legal duty now with respect to a known legal duty this gentleman had a background check he had a contract that said he was exposed to sensitive information and had to protect that he had been a naturalized citizen he knew how important these documents were to folks who were trying to get citizenship or residency status and he had gone up a series of letters and promotions first was the clerk then he was an inspector in fact inspected the file rooms to make sure that everything was in compliance with standard operating procedure one big standard operating procedure was that you should never shred or destroy inter filing he worked in the secure area and he was promoted then to senior supervisor and we have testimony saying that once you make it to that and you need to know the standard operating procedure and in order to get that position you have to demonstrate your knowledge in terms of unlawfulness of course he knew that it was unlawful based upon a couple  charged with this case but i do understand that they probably have set up a phone number subsequently for people to call and i hope that they have taken additional  these documents to give the defendant notice in no way shape or form were they reflective of the essential elements of this crime and and certainly in terms of the statute does not specify in any way filing backlog that was completely separate from the special searches had nothing to do with the return mail situation which as i discussed before it was perfectly lawful know notice that he has to defend against the destruction of some typos government documents if he has caused destruction of documents that it was perfectly lawful to record then he's not guilty of crime government documents can't be destroyed and it's not necessarily a crime and one looks at the statute it speaks in terms of if a record whether any record will proceed in your book or paper or document