One can not ever, ever guarantee, be assured of, or know what will come from the mouth of a witness. We had a suppression hearing this afternoon in front of Judge Mott. With a reasonable degree of certainity, we had an even chance. After all, it is the State's burden--correct? But this does presuppose that one has a general ideal of the testimony that will be given. One has spoken with his client and the witnesses about the events in question--their version of the facts. Occasionally one is pleased at the testimony one had no idea would come out, but more often one scrolling through the words and phrases that come to mind while driving in traffic in rush hour. Don't know how this particular hearing will resolve itself, but will submit a short memorandum in support of our position.
The issue that presented itself, the issue that I was unaware, is whether an peace officer can purloin the code to a punch lock of an apartment building and enter at will, without consent, and without the knowledge of the owner or the tenants. Don't know the answer.