good afternoon may it please the court my name is victoria andersen i'm appearing pro se i'd like to note that although i am an attorney by profession i'm not a litigator and this is actually the st case i district court was applied compelled to apply california law to the facts and my contention is that the district court feel to do so and three material was respect those cases being for cause e p brant says are is the science and most importantly spiers feet american bus lines and by not applying those cases holdings in those cases the court awarded fees almost thirty the contract i actually i raised it in the i guess mine in the district court level and my reply i went back to double check and i did see that i raised it and  which stands for the proposition that if the retainer agreement only requires notice of terminations then the relationship actually ends as of the date of that notice role by deciding that my main six e mail constitute the terminations my contention is that the district court impose new and different and more either to respond immediately to preserve any rights that plus the notice the advice i was given by my new attorneys we believe that if we didn't send something then i might be in a position of losing my rights and so i was advised to send something so i sent the notice on on may six but my contention is that sending a notice after the attorneys have already terminated the relationship but before the district court could adjudicate whether you fired that more for which you have a right to do for any reason right sure how can one say that this was a withdraw without cause when you on a breach of a duty the laws in california specifically say that even if there were certain acrimonious relationship and the attorneys just does and doesn't want to work with the client anymore that's insufficient meet the burden of justifiable cause i would also say that even in the event that you would hold that they did not withdraw but they were discharged i was still posit that girard enforce the contention percentage after discharge however the client may still enforce the contention contract in order to limit the current and discharge attorney's fees to the agreed contention  then there has to be a pro rata apportionment and although the district court reviews and cites to and quotes from the l are free los angeles county case it's stop sort of just before that actually only paid the the four percent attorney's fee was required so that roughly fifty five thousand dollars under california law has to be apportioned among all attorneys pro rata according to t spent on the case in achieving the client's settlement and with respect to chart gives they negotiated a settlement offer for me and the amount of one hundred and forty seven dollars roughly eight hundred and forty seven thousand dollars that was actually based on the wrong personal injury and then i filed an appeal it was through them but i'm the one that said hey this is the wrong personal injury that you are asking me to someone and your kids injury determination was overturned and on appeal and through that appeal the settlement and the settlement administrator twenty percent raising my settlement offer to one hundred dollars roughly one hundred and seventy six thousand dollars roughly on behalf of our co counsel dank america i'm here for a very simple reason and that is to protect honest pay received for honest work each of our firms working on this matter always works hard for our clients embrace our obligations as counsel and we take pride in doing that that's exactly what we did for miss anderson for four years we were happy with the outcome that we ultimately were able to make available to her and our work set the floor value for miss anderson's case when she ultimately went on to engage in further negotiations after declining the offer we have obtained for her and later terminating our  the law allows us to recover the reasonable value of our work once she did recover through the later settlement and the district court properly awarded us our fees and i appreciate that miss anderson acknowledges that the court did have jurisdiction to make those rulings and that certainly takes some her cup of me in for my argument today i do want to address of course a number of things that she mentioned this morning regarding the withdrawal versus terminations the district court looked very closely at this issue and was very clear in its holdings and determining that as your honor noted that he was denied the opportunity to adjudicate whether there would were required to do under the local rules we could not just withdraw of her own volition required the courts approval we gave her that notice on may st and as your honor noted the response  received was determination notice on may th and so the facts of the case do show that counsel was terminated and under california case law we are entitled to the reasonable value of our services that we have rendered up until that point ms anderson's comments regarding you know her opinion that the firm would have lacked cause to withdraw i think are just not relevant here because it would have been the district court's position to adjudicate that and make that determining which it was not able to do because of the terminations of our relationship of six by miss anderson the court did not enforce the contingency fee with the court did was properly apply the for cossey case to determine that the firms were entitled to some reasonable value for the work they had done and then looked at the various factors that are discussed in that case to determine what an appropriate fee might be  as based on its analysis it determined that the equivalent of forty percent of the offer that we have obtained from mrs anderson was inappropriate i think it's important to note that under the the actual starting point would be the lodestar value of the work done and looking at that our lodestar value was just under two hundred thousand dollars dollars if i remember correctly meaning that actual value of the fees as initially agreed to far exceeded what would have been available under the forty dollars or even thirty three percent conceived agreements and so it was appropriate for the court to look at  alternative methods other than the lodestar to determine what would be reasonable i do want to touch on the comments regarding the settlement offer amount and i think what's happening is just sort of a fundamental misunderstanding of how the settlement process worked this case was one of amongst twelve thousand individual cases and a large in d l within that in d l cases were generally settled through aggregate settlements for small groups of individuals and then a special master would be involved once an aggregate amount was determined to allocate that amount to the individual with the special master there's always an opportunity that some error might be made to a document might be missed and so the settlement from the beginning had a built in process to allow us to go back to the special master or claim it might have disagreed with the way he allocated aggregate settlement amount out to the individuals sanderson did disagree some of with one of the medical factors that was taken into consideration we were able to advocate for her through the process set forward in the settlement and were able to increase that amount to be slightly higher amount that was turn the district courts general practice was to not dismiss cases until there was a disbursement from the qualified settlement fund meaning this case was sort of stuck in the just court in front of that  resolved so that distribution could occur and that's been done and that has now record correct i think unless the court has any further questions i have nothing further to add thank you very much