the way i would like to priest request please two minutes for a bottle yes may please the court maybe a city jail and i'm privileged to represent plaintiffs apparent christopher grant a decorated veteran of united states navy with a distinguished record of public service who was not rehired as a correction officer at the main department of corrections in march of two thousand and fourteen he alleges because it grace the district court su judgment order should be reversed and mr brady granted his day in court because question evidence of race based just discrimination has been presented to race gender issues of material fact with respect to claims because the only reason given for not rehiring mr grant assaults a jury love you have to show more than just read well in this case there's clearly more evidence mr grant was hired for the position there's no other black probation officer if he complained about race discrimination his reputation for honesty and ethics were superior he was recommended by soup supervisors in the position and they went outside the usual hiring process and made a false accusation that he lied and because  their explanation for not hiring him is false and there's no other possible explanation for not hiring him a reasonable jury could find that race was a motivating factor because black dishonesty is a stereotype department of corrections it's because of a hiring freeze that was true on that day and mr gray had no reason to not believe him but nevertheless he didn't and then he went inside he will hiring practices and spoke with a woman he described about a plant in contrast to a man who had this exemplary record of public service to choose him of the ethics issue that would prevent or put his law enforcement career in jeopardy it is a jury could find a motivating stereotype now in the barents case this court relied on a rock review article for the proposition that women can be leaders is a stereotype and this is or should read the jury decide the  not and mr brett my client has raised sufficient evidence to today's decision for a jury and that's why we believe the district court's decision with respect to the motivating factor claim should be reversed and she  regard to the race discrimination claim mr grant still has to show some evidence of discriminatory and ice on the part of that apartment and based on his record he has not done so the crux of mr grant's argument it seems to be a couple of interviews pam on mr grant argues that the term using the term grokking might think or to describe him as a racial stereotype i would submit that no reasonable person would conclude based on this record that black and white thinker would be attributed as a racial stereotype that mr brand described himself as a black and white think or when he came to drugs during one of those interviews  for just a few minutes we need to take a quick break sure known at the time he did not make any notes of the conversation so he did not know the tiniest approach to that person was he just said it was that person in the human resources department and he didn't even he didn't play the right after he spoke with that we know anything that made the records is that mr brandt was the only african american in this particular department do we this is new hampshire i'm sorry this is i yesterday to this is made do we know anything about african american applicants for these positions who are the correctional officer positions him on that there's not a lot of reason to doubt the reason given by find out for his coming down so there was no reason to check on his story because there was no reason to doubt what he was saying do we know the race of john doe we don't know that's not on the record craig can show that he was treated any differently than somebody who was not rick an american in that regard because we don't know the case of that person in the in the deposition that was there in the testimony about doubts because he had the impression which is undisputed he had the impression that berlin was not under a hiring freeze and so that's the only doubt that i can recall from the record that he had crafts so so you only ha to ask one question i'm trying to understand why he's asking these other question i'd again i don't know it's not there's nothing in the record that i am aware of so to put it as it is that very fact that he was asking these questions which may have been personal in nature and subject to non disclosure of my charge does that raise an inference that he was engaging in discriminatory and it should go to seem relevant given that that landry you're not in the land you could rely on that information if if the plant was acting in bad faith or are you i don't believe  it's unusual maybe in different states but is it usual in this particular department or do great just grit your little where guns well that's an excellent question your honor it's a question that a jury should explore and that he was escorted out of one of the interviews about playing by somebody who had a weapon and that his remarks were cut short through this is just additional evidence in addition to the falsely being accused of  that that should release enough evidence of a motivating factor because there's no other possible explanation for not rehiring my client for a job that he performed well that he was recommended to be rehired