morning good morning your honor please the court my name is hassan abbas i'm representing me demene as parent limited and myself pro se the issue before the court here is whether the district court abused its discretion in imposing seventy five thousand dollars sanctions i believe i was heavily sanctioned and unfairly sanctioned and i believe the district court abused its discretion and i'll tell you why it is a court recognized the counting the award itself or just the amount because i didn't think that the challenge to the your ward was properly before the court on this appeal but perhaps you want to speak to that yes i am challenging both your honor how do you challenge the award itself is that repeating earlier challenges you know the case of hensley versus ecker heart your honor i'm the supreme court and the case of agent orange product liability from the second circuit states as follows with respect to ours he says with respect to ours a district court must exclude from a few request hours that are excessive redundant otherwise unnecessary due to over staffing you ma'am yes to the amount and i would discuss the broader issue of sanctions after and discuss the issue of the hours i think all that's in front of us is the computation fair your honor but so there's no point discussing something that's not front of us i mean a lot of interesting things in the world but this appeal just deals with the computation and whether it's recent ok so the facts here show that oracle overstaffed the motion with five lawyers three senior partners and two associates i believe five lawyers was redundant was not necessary and it was unreasonable the district court had three methods by which it could have excluded the hours one was going through the time entries the other was a percentage across the board percentage cut as was done in american honda where the fee would quest or fee was slashed from two hundred thousand to sixteen thousand it was ninety two percent reduction he would be from seventy five thousand five thousand and the third method by which you could reduce the fees is by looking into the financial situation designed from the quote i don't have the was a substantial reduction and it was hundred ninety seven point nine no that's the hundred ninety seven point nine hours but there was not a single hour excluded by the district court that exercise need to do needed to be performed under th significantly higher than the number of the district were approved that's the question it's a simple question he answered no the district court awarded seventy five thousand based on this this is what i received i received this all these blacked out privilege is used as a sword and a shield so i had no viewing of this i challenged the hours basically blindly just the total number of hours saying that look this was over staffed and it was over built in the supreme court says if a few request is overstaffed it's got to be reduced it was it was staffed with partners and associates three senior partners each has considerable experience about thirty years we could have been done by one of the partners who responded and the need for other two other senior partners and two other associates so but our position is it was unnecessary why is because the blended rate is three is four and under four hundred dollars an hour which i understand nowadays is a real partner had worked five hours and built net eight hundred and five lawyers billing me a four hundred don't usually get in a run but our adversaries staffing i know but the supreme court says if it's excessive it's going to be reduced if they had put ten lawyers the district  hour out of the hundred ninety seven it took it as is one hundred ninety seven our seventy five thousand and just said hey if this is what happened and just let me go on to the filing injunction district court and cut it in half again would you pay it your honor i think we had this discussion previously as i mentioned to the district and i mentioned earlier i don't i don't have i don't have that money and they sort of the purpose of sanctions is deterrence not financially to ruin a person overstaffed that's what the law says and if the district court doesn't apply the law then who will apply the law on that must be applied it says that if it's over stuff with five one of their submitted with ten lawyers and hundred fifty thousand and not a single i would reduce that's not fair and you wouldn't pay that either your honor if it was reduced if it was reasonable they had an obligation to to to exercise billing judgment when they submitted their bill and they submitted this overstaffed and overbuild i can't pay it as to the falling injunction it's see who took my money and and i was trying to do good and i was trying to get my money back and i was sanctioned i don't know why it was sanctioned to this day i don't know what was an underhand powers of those under twenty eight us see the supreme court said if there was no bad faith i had no bad faith that also i should not have been sanctioned because i operate in good faith at all times your honor they took a hundred fifty thousand dollars from me they took everything that i have and now i'm being sanctioned i think it's topsy turvy honor ok well you and against my employer the law firm all of mr abbas's various claims and motions of the past several years have been soundly rejected by every single court in which has brought them including by this court and mr abbas has been both warned and indeed sanctions multiple times as a result of his vexatious tactics again including by this very court as well as others an issue now in this appeal as to whether judge to pursue all of those same things again but simply in the name of other corporate entities but in the context of this appeal it was mr abbas himself who submitted the petition to judge delavan seeking leave to file the declaratory judgment action in the name of those entities according the judge sullivan looking at the circumstances properly concluded that mr abbas was simply using those corporate entities for the improper purpose of evading the filing injunction that had been imposed against him and to really get claims again that he had previously brought in his own name which had already been dismissed additionally separate and apart the improper and vexatious nature of mr abbas's new proposed action it was also appropriate for the district court to deny mr boss leave to file the action for two fundamental merits based reasons that are abundantly clear from the record and neither of which mr abbas seriously contests in his briefing at the first of those the subject matter jurisdiction one of the plaintiffs in this new proposed action is means congo a foreign honor alluded to there is a form selection provision that has already been adjudicated by both the district court and this court it's law of the case in this action that that form selection provision binds both meta means illinois and me to means congo which of the two plaintiffs in this new proposed action and that the therefore cannot bring these claims against in the united states very quickly or on ours just with respect to the fiord determination as we laid out in our papers the district court's view determination was a textbook lodestar analysis judge sullivan diligently reviewed all of oryx fully on redacted billing statements and determined that both the rate charged and the number of hours spent by work were both reasonable and well within the scope of this court's monetary sanction that it imposed on mr abbas as your honour's pointed out through the last sort of raises the question of how many work lawyers are required to take him yes to that point your honor he talks a lot about the fact that there were five lawyers on the file in reality it was one associate and one partner performed more than eighty percent i believe of the hours there was one senior partner that was the client relationship partner on the matter that build less than a single hour and then the other two attorneys played supporting roles and that yes your honor as your honour's pointed out earlier the amount that was ultimately approved by judge sullivan was both well below what actually charged and was also well below what he v c actually paid how did he get the loan i believe it or