hold unable to satisfy any judgment close quote requires a player to show under two six twenty one b four we respectfully submit that the statement means what it says that manufacturer here is to be quote only able to satisfy any judgment close quote because it is capable of completely discharging its financial obligations under the judge the plain meaning of the phrase if we are correct the judgment below cannot stay the manufacturer in this case is not insolvent bankrupt or no credit for to record a judgment and in for state judgement in a sister state and even in a different country and while i would never call myself an expert when it comes to these efforts made outside a law so this is not a case where you are going to be asked to address trying on those hostile policy of not excess are outside the state of own that's just the nature of modern stuff guess manufacturing one place it goes into the swing of commerce and it wants up in another so they go to the north by march through georgia all county as a sales office there he sees whatever the stuff is in the warehouse in savannah georgia and you know what they don't get  think the standard comes down to what the statute says inability to meet the financial obligations under the judgment so when they go to georgia depending upon what they've done the trial court is going to have to make a determination they didn't start that process here and that's why i think that  effects from the finance and placing liability were ultimately belongs upstream with the ultimate wrongdoer the manufacturer and this policy would not be defeated by requiring a plaintiff to present some evidence to actually show where the manufacturing defect and head operations threats that would seem to be a fairly straightforward test now might become a more difficult question depending phrase an able to satisfy any judgment means judgment proof because the blacks laud their dictionary definition of judgment proof means quote on able to satisfy a judgement for money damages because the other follow from the other the fact that judgment proof means an able to satisfy a judgment for three a numerated reasons doesn't and doesn't mean that the unadorned phrase unable to satisfy a in that paragraph three to her this doesn't the met i mean the manufacturing no longer really exists so purpose isn't that of manufacturing doesn't mean that the manufacturer no longer exists the same as non website until after the citations discover assets have been issued and come up empty that sales office is listed as and being in alpharetta georgia and it i wait group's website provides an address for that sales office and if argument just moments ago that mr paskey didn't satisfy that burden and didn't look outside cook county or simply misstatements of the record mr cassie's efforts to find assets with which by way group satisfy the scotchman are documented in the record in volumes additional severe yes there's no need to use the phrase unable to satisfy any judgment if what you mean is bankrupt or nonexistent you could just simply say bankrupt or not exist and we believe that that shows the general simply thought of  maybe they want to maybe they want to i think things just a little bit and make sure the manufacturers truly unable to satisfy any judgement and not veer off into what the true rock of ascii and i'll call some difficulty in enforcing the judgement but i think  with which this company can satisfy a judgment then the burden should be on the defendant to show some proof that their assets actually in georgia are actually in another state or in indiana is tried and said we would have no problem assets were located know where he served and these were just blind aimless searches these were actual searches based on financial records and incoming information about highway group's financial viability where they were paying their bills from