success as they would result in no substantial injury to see in the us and the public interest factors favor a stay to began lap does face irreparable harm absent stay as this court has held irreparable harm to hers where there is substantial possibility that the parties may not be placed back in the positions they previously occupied absent equitable belief that is the case here if the banks produce these documents before lapse appeal has result even if his  that is true your honor it prevents c m s from taking the documents and using them as a basis for any further lawsuits that he may choose to bring perhaps in other jurisdictions but i don't believe the protective order does or can do is have today first this discovery did not need to be obtained from banks in the united states what c m s seeks is information information concerning lapse profits that were made during the relevant period that information could have been obtain period is available to them through the u k proceeding and has partially been given to them if i may there was a second point that i once wanted to make with respect to going the second point that we wanted to make with respect to the district court's order was that the scope of this discovery is extraordinarily proud it is unduly intrusive and it is disproportionate to the door your honor we would not have given them this scope of information because we don't believe this scope of information actually most of it actually doesn't help them funded by their last profits in the u k litigation their stated purpose for the discovery much of what they're seeking is face equations from a ship transfer information and you know i will just remind the court that this is very very broad discovery this is discovery concerning every wire transfer made or received by law or any of twenty one alleged affiliates none of whom are produced if you kill a geisha over a seven year period from sixteen days and as judge to pony recognized in later proceedings in the district court huge i understood your answer which was law to be yes but i want to confirm as to the reason i hesitate is because we see a distinction between the documents and the information so if i make that the basic wire transfer information that is being sought here through the seven hundred eighty two proceedings is only going to show very basic information concerning each transaction so for example the sender the recipient the amount and the bank's  intermediary banks where the transfer went but it will not show and what this information is not going to show is whether any of the transfers that show up in these documents were actually reflective of profits made by lot and more importantly whether they are reflective of profits made by law that are attributable to the services that c m s allegedly provided so for that reason we believe that this information it's overbroad it's not targeted to the stated purposes of the discovery and if c m s requires information concerning lots of profits that is information that we have that we can turn over to them through the u k proceeding for example through a financial statements which will show on a consolidated basis exactly which of those transfers resulted in profit appeal there's no irreparable injury to law the only injured party will be c m s here and the public policy weighs in favor ways against so granting the stay with respect to the merits of the the first discovery deadline is set for september thirtieth that's for a standard disclosure and basically what that is is each side submit a list of the documents that they will intend to rely on that or that is relevant to their this if we delay the standard disclosure that will have a trigger effects where all of the other discovery deadlines flow be delayed and then likely be i've been advised by english council that  trial date set in the end of april of next week will likely men and it will probably be delayed by another eight months to me year because it's hard to find a four week locked date for this trial  that's good that's the substantial injury here so right now you may be wondering all the banks have produced it fully except for one bank and so  at this point the labs point about having information released is not really in irreparable injury it's not an that we've already gotten ninety five percent of the documents and so should the court grant the stay basically c m s is not going to be able to move forward with preparing for its case not goes to  point which is we need time to actually process the documents look through them have them reviewed by forensic accountants figure out that you know who these transfers are made  whether that information whether a particular transfer related to c m s is contribution to labs that you know to want to plops businesses and so this takes time to review these wire transfers can share it with a list of individuals one of which is our clients and the attorneys but everybody has to sign and an agreement whatever services and management services to law the client is in the best position to know you know who x y z business might be in relation to the last technologies which was a you know that you know is a technology investment for example it's going to be very difficult for the lawyers to ascertain whether x y z company had any relation to so you're saying basically for the time being until the appeal has decided whether it would affects preparation of the case and wilson who saw his room i think it would your honor because you know we have to we have to go through leaves and investigations on who's who and and based on not i mean what i understand is there's going to be after the standard disclosure there's go