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should have shot when they cited a net worth stipulation which I decided to you this and solely for the purposes of the punitive damages phase to the childhood or no other purpose here's how they describe and we've bolded this at the top paragraph paragraph the page 16 open parent network stipulation entered into for purposes of the case now you don't think that's them trying to pull one over on this court and on us that's literally not what it says I mean I don't know how you do that unless you're trying to work a fraud on this court unless you're trying to work something that isn't supported by the fact network stipulation entered into for purposes of this case it wasn't entered into for purchase of the case it was entered into for a specific phase for specific reason for no other purpose I don't think mr. Brandon understood what they did in their forbidden they used it to challenge the compensatory damages expert we put wasn't about what they argued to the jury that we entered into it so they can tell the jury living network book now that would come back and said oh look they're expert the forensic economist doesn't comport with the stipulation that was entered into perfect pew damage the others but look at that language we would submit to you that that's exactly what mr. grant just argued they were trying to do is exactly let me try to do with this [ __ ] okay thank you very drastic courts going to denied a motion to destructive strike but I do also recognize some of that was in the defense to the other motion civil so you don't have to repeat some of those are mr. boats going to handle that part we understand each other so what the defense at this time like to do the motion for judgment notwithstanding the verdict or would you rather just jump to the one that we first learnt already and no I think problem your honor logically a mixed emotions that's all right there are times just taking it CR as you know we have moved or javi and a number of grounds I'm happy to address anything your honor language address arrange any questions but i'm not going to go through you'll be having on this part this i'm not going to go through each of the grants I just want to focus on four pieces of this first piece is the public amenities the part of that set in peace is the right implicitly piece in particular the commercial purpose prom that's work the third piece is entitled in compute advantages and a four cheese is personal liability for addictions I think if opposing counsel don't know jack you don't judge your honor and it makes sense to do with one by one by one by one is that has me talk a long time it done it's another yes that's hot so you're on the pub and sturdy shoes you're very familiar this space in the case with our basic story about public concerns I won't belabor that I want to focus on one issue which i think what they focus on in their opposition and that is the issue of what to do about prior injunction as you notice argue that the DJ's prior rule in the challenge publication leads to medical concern compels reaching the same result here's the merits stage we think that's true whether that understood in a lot of case decision for simply binding appellate precedent that you need to apply to the facts of this case which by the way our homes exactly the facts of that case because it's the same case now that we're going to post route motion days plankton has sort of fully articulated plaintiffs theory for why the second disease opinion can be disregarded and that's why I folks a serious energy and it basically two steps the first step is to say that agent Larry testimony which seat was not before dc-8 the temperature keep it if that test was the game in a way that make our decision in a football gets it on the game on it's gone the second step is basically say that now that the only for decades I have that addresses the public concern tissue in the celebrity sex tape context now that case is gone we can go back to a line on the cases we talked about before the Senate easy a to the minus 1 capability hate the go case all these days we know so welcome time especially those gates it's my visit our position your honor than both steps in that argument or wall I want to talk about malaria decimal that one makes you points there first thing plaintiff has mischaracterized alerts definitely it's just not true there's no connection between the grounds on which that you see a basic public concern determination and mr. clerics testimony about what he was trying to do when he drafted the publication question how I hope from the BCA's temporary judge incision right the heart of that ruling was as well as this is from cage 1201 it is clear that as a result of the public controversy surrounding the invader antiseptic exacerbated our time Mr bland missa the report and a related video dancers address that's the heart of the devastation page 12 of oil under that woman the doctor complication including the video description or addition fry relate to that public concern because they relate to this ongoing public discussion of sex tape to which mr. globally including to imparting there were other thing from DC talking about ready to talk about mr. Boyles autobiography and confident some other than to the experience that they got formed the relevant context for evaluating publication your honor but the heart of it was there was ongoing public discussion mr. Blair participated in that understanding of the grounds for holding that the publication lady medical concern is consistent perfectly consistent a billiards resting point contesta meant to testify at ruggles and not disputed that keeps aware of those prior reports about sex tape yet read reports in march two thousand set 2012 in dmz he's seen the pictures of the journey in april 2012 and testify dozens well explicitly referenced those prior two seconds in the task of this contrary there were hyperlinks to TMZ the jury and the Samoan list now that's a seaman mr. Larry also testified that upon watching the tape he was dropped by the fact that on the phone clearly consent mean deck circle he testified highlighted that original decision and highlighting the video excerpts and has a new bag of dr. Cartwright dr. advanced the conversation that assess it and that's what he is focusing on the conversation of excessive got advanced that by adding these facts that people that what happens at macarthur publishes you get these new reports they're jumping off that in fact mr. Blaine how it's turning in ferns various things though one of those ratios refer to things the ball is advanced about the sex and discussion that pre-existed the gauger cognition so if you look at the farm in the dc-8 maybe look at the heart miss alert testimony they line up completely now I'll concede to mr. jeweler they talk about his personal interest the propagation talk about other names too he said as a fan of using the sex tape that maybe think about study senses general admission and I thought about a lot of things of consciousness but he was certainly in thinking about how he was recruited into the public discussion he was exactly in sync with what the DC a mission that's the first point there's not a disconnect between a canoe the second point is it doesn't matter the public concern analysis is it for fundamentally injected what makes a publication laser medical concern is not rushing off with the specific things the author in the publication happen to focus on the analysis we've been through this three years rate announced insurance on the content of a speech in question evaluated and the context in which a public receive message in that context includes fast other people know about the subject matter publication facts that they then use you know whatever occasion such advances