good morning may have placed the courage my name is helen green and i'm here today on behalf of the citation responding appellant sandra they are at the order we are appealing but entered in a section two dash fourteen  two supplemental proceeding to force a judgment that was entered against a single defendant the estate of canberra the trial court here help c after bearing as citation responded personally liable for in overpaying himself and sandra whether or not she worked for katie asked and it didn't it wasn't an itemized in anyway it didn't impose a constructive trust on sandra personally overpayment of compensation to sandra accrued over several years they were not specific and identifiable  an action against sandra baron and also brendan king county that was dismissed with prejudice the court also said that there was no specific identifiable funds in that case to support a conversion action so  that you know at the time of his gap he dead shortly before trial right so the constructive trust was not imposed on the wage overpayments it was for the amount of money had an issue at the time with the constructive trust only being imposed against the state and that it be under baron or not against you know this money that she had paid which at the time when we had been part  payments as an employee and he was her employer so it was a principal agency relationship so they couldn't conspire with each other because if she had done anything that would have been at the direction of her employer that was also he would have done that in the g twenty twelve orgon they need somebody to come back and say oh this obama sticker it doesn't belong to her she was an attendant at the time the judgment with entered so you have th for over three hundred thousand dollars in prejudgment interest in that it ever grew from the time that these wages were paid until the time of the twenty twelve judgment and there was no debt or credit t is again something bad conduct on the part of the actor and she again was not liable for anything and so he the judge still in the supplemental proceeding gave her three hundred thousand dollars of math and told her she had to pay that and on top of the at the trial judge in the supplemental proceeding held her liable for over five hundred thousand dollars impose judgment interest i'm a judgment that's been a this eight hundred s in dallas so you have to pay over five hundred thousand dollars in post judgment interest i'm talking back so at the very least if this order in the context of a motion for judgement that come back wishes he would have recovered or should have recovered again sandra baron if he had claims against terror it's purely statutory they haven't come up with any authority case authority or statutory authority to require ago so i want to collect my money now this this is very unsettled and you know every time we get it and have a new venue or a new judge this this issue comes up again with the wages for payments but any questions other than essentially her name and ask for the reason we're here not just to not just for the motion to compel the trial but for her meaningful participation in the citation proceedings because their position is is really quite simple they've these are issues that aren't then litigate it and those clients who are already appealed in are a decided by this court and what plaintiffs trying to do is just again do what you couldn't do before it's the same thing he's been at this for ten years and if he wants to collect on his judgment it's his burden to identify and trace the race which in this case it's the assets of the stage on which the construct of trust was is that shoes in answering the questions that we can't meekly do that this is just a distraction all the difficulties that he's having in collecting his judgement this is not the subject of the appeal that these are issues that can be addressed in the supplemental proceedings and when you say she was you know having he was having difficulty having her answering questions there is a simple court orders and we point these alex in our brief that limit and that's why there was a lot of motion practice going back and forth and also i just want to point out he refers to this earlier order where there is a first a this court's decision they had used that number as the amount of the constructive trespass should be imposed against her that order wasn't a cave it and we believe that order was also incorrect because it was seeking to impose job generally there is also this was the subject of they have onset of claims this is also being litigated in the supplemental proceedings they filed a complaint under the uniform fraudulent transfer  act trying to you know flesh out these issues as to whether funds that were part of the joint tendons tennessee that transferred to her upon hand parent's death whether these you know what happened to these things liable for the portion of the judgment entered and danced the estate as well as personally liable for a portion of the pre judgment interest and post judgment interest against the judgment better