forward for three reasons the st is that this court arms are the supreme court could benefit from this court to use on this particular issue this court account for a significant percentage of the nation's immigration docket so be useful  the non citizen because it buys him or her a little more time in the country the exact opposite is the case here mr ortiz is trying to reopen if proceedings to return to the country and return to his family in new york  the longer that this case gets drawn out at least for mr t s he continues to experience irreparable harm every single day that he separated from his family for those those are the reasons that we think that moving more expeditiously on this is so the before you commit in front of the court and that might have an impact although my own view is that they don't really listen to us anyway but here there was an argument and it was fully fleshed you have a pretty good sense of maybe reading tea leaves where this might go just isn't really going to have an impact if we say something one way or the other so far be it from me to try to predict the inner workings of the supreme court but at the very least the opinion of this course court will be out there it will be there for the few printed court to consider as it works on its opinion of course we humbly don't and don't know what goes on behind those closed doors  but having that opinion out there is definitely something that the supreme court can read it is available to will be available to them so even though the case has been argued and we perhaps we don't know for sure we don't know our every justice will view it and also sometimes you never know based on oral argument and what actually was and i still think an opinion would be  helpful if there are no further questions on these chavez i'm happy to continue mr t s seeks to reopen his proceedings and i think it's useful to remember that the immigration court here motion to reconsider by the government and that motion to reconsider it was just based on the application of pereira and based on that one issue whether pereira would apply whether to stop time rule is triggered here the immigration court stood on them and the only real ground here for reversal is the knees chavez point and i'd also like to just point out the reasons why the b i d am piecemeal notice theory is incorrect as a matter of law the statutory text statutory history the statutory purpose not to mention the clear separation of powers between the h s and the immigration courts all counsel for it's one straightforward conclusion a notice to appear as a single legally operative charging document that can't be that  together including the the notice of appeal which itself did not have the requisite information but all of the other documents that were together contain the the necessary information that would be enough correct absolutely so we're talking about a an analysis based on regulations and statutes why is that different from a notice of your appearance that doesn't have efficient but then subsequent documents come in and as a matter of just understanding the the scheme and congress's requirement and the regulatory requirement other documents come in the fill in those blanks than if the mailings are separated by a week and that's exactly the problem that congress is trying to avoid is all these paper asked why is it different why is it different because when everything is together it makes it clear to the non citizen what exactly is being required of him or her it explains why they are receiving this package in the mail what the charge that the st the st document is missing a date and the nd document a a week later in the mail and you don't think that would be sufficient fills in the date and time no your honor we do not believe that is sufficient because i don't think one can argue that two separate documents coming from two separate entities or two separate times are one document that would seem to stretch the phrase one document beyond any comprehensible meaning and the reason for that as i guess i was saying is that once everything is together it's much easier for the non citizen to know what's going on it prevents papers from getting lost that prevents paper from it prevents confusion and that actually is what happened in pereira where the is never received the notice hearing everything is much more straightforward when it's produced by one when everything is on one document and i guess we can quibble as the supreme court did whether a bunch of paper stapled together constitute one document i think it's clear have please the court corey farrel on behalf of the attorney general as this court to recognize this issue has is currently pending before the supreme court the supreme court heard arguments and we will have that decision followed by a hearing notice which completes that document is to get there sufficient to stop a cruel of continuous physical presence and importantly the supreme court's decision  job as will also tell us whether this court's decision and remains good law because this court did decide and that this two step procedure satisfies the requirements to trigger the stop time rule we also have the board's intervening decision of matter of mendoza hernandez and as the government argued in its brief and as the th circuit and the circuit have concluded this mendoza hernandez has the best interpretation of the i and a's notice requirements and those courts base it on the plain language of the statute but also determined that it would if the statute were ambiguous it would defer to the board's decision and mendoza hernandez and if the court has any specific questions on ms chavez or the board's decision to mendoza hernandez i'd be happy to answer those questions reiterate is that the supreme court might not decide you need chavez until june potentially in fact waited until june th seen to decide pereira so we're talking about a substantial amount of time and for the reasons i  a problem i guess on both sides but if we were to rule in your favor and grant the petition and the man as i think you're requesting and then the supreme court  to remove my client and if that were to happen then we'd have to litigate whatever the supreme court based on whatever the supreme court ultimately decided that that just where one actually worse does of the waiting for this long time before he was rightfully allowed to return so it sort of cuts both ways i would say but if the supreme court order or rule adversely for my client then we'd have to the