and we can avoid addressing questions about sec shichb 5 about redistricting. on page 144 of the jurisdictional statement appendix, the district court expressly found that we did not impose a quota. the court says that we imposed no -- we followed preexisting district lines, we followed roads, we followed county lines, municipal lines, we met the needs of incumbents and we preserved communities of interest. the plan that we passed is a status quo plan. the whole point of the plan was to preserve the status quo, because the majority had won the legislature for the first time in 1 30 years. >> but the other side says it was impermissible for you to preserve the status quo because the majority in the minority districts to participate in the electoral process had improved to the extent that maintaining the status quo would be characterized as packing? >> actually if you look at, two responses to that, your honor, the first is that if you look at the micus brief supported by political scientists, they show that black voter turnout and white voter turn out actually e