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2dca 15 Form

2dca 15 Form

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may it please the court I'm mark stuff a counsel for the appellant I would request five minutes for rebuttal sure Thank You mr. Stoker this issue this is what the fifth or sixth or seventh or both have I think it's number seven for me I was actually going to start with that it's funny you say that because in a lot of the prior oral arguments including a couple with you I think that's my third with you we've the issue has come up of is this the right case correct case to write an opinion on you know we have there were preservation issues and some of the cases turned on factual disputes potentially to me this is the perfect fact pattern to write an opinion on its de novo review everything was preserved there's and they're not even arguing preservation at all there aren't there is this isn't a case that turns on the facts at all because the other side had no notice of assignment the data as contemplated by the statute and they acknowledge that in their own testimony you purely have the le

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