hospitalized for seizures on twenty different occasions and the state's witnesses in this list agreed with seizures present differently in different people but you say the paramedics who deal with people having seizures all the time should not have been permitted to testify that he wasn't hearing a seizure but they testified to your honor is that mr jackson was undergoing a medical emergency of some sort to the paramedics so i mean he was not undergoing a seizure  testified the curious last make reasonable inferences there's no reason but in frames they can be taken found the paramedics testimony in this case because testimony corroborated mr jackson's defense that he was suffering from concluded there mr jackson's kind of was intentional you hear of a person who is kicking and punching according to the paramedics in the police he is speaking in sentences while they may not make sense or still speaking don't touch me get away from me you're not the ambulance he's conscious and you have paramedics who by virtue of your experience say we don't believe this man was he having a seizure you have his girlfriend on the other hand saying he suffers from seizures i think he was either going again or coming out of a seizure when they were bringing him to the ambulance how under those fags no it creates a reasonable doubt of guilt here the panic says you as you said testified he was not undergoing a seizure in their opinion in their opinion based on their limited experience with a certain type of seizure that they testified to but they also testified to not point to different points in the record but something there was medically going on with mr jackson that he needed some kind of medical attention that his mental status was altered at the time that he was doing and that he seemed clued the rational so whether or say i've dealt with in one case hundreds of seizures and the other one thousand you see there's and they both say in my opinion this man was not undergoing a seizure  leaned over and bit me that he kicked the officer is soon as he came into the vestibule i'm i guess i'm confused because you're relying on mr jackson was not undergoing some sort of medical emergency because bill said that they could not assess mr jackson medically so does the sizzix existence of a medical emergency and then the substitute a finding and i recall seeing a rather extensive cross examination by defense counsel on the types of seizures and the experience that these officers and i don't recall seeing an objection by defense counsel to  primary thirty and people taking it i'm disappointed the point that the specialist knowledge that was taken for granted here by me quite in this case and the jury in fact in this case was never meant to pass the test  liability so we have to see paramedics expression expensing the bedouins based on their knowledge and their experience about what type of seizures or what type of bad behavior there's a kind of a seizure activity and they presented none so in this case the state has now met spain to prove about terri asked this is not a clearance where the defendant was committing a crime and there to try to resist ruth bader arrest mr jackson argument and remind him that evidence to say that in the professional experience of these paramedics that he was not suffering from a seizure of course that had an impact on the jury as a terminations in this case you also challenge the mission of testimony spiral down to whether he was suffering from a seizure and whether the jury believed she was suffering from a seizure and sent to the scene on the putting the onus of the actual charges the state introduce the pensa the evidence suggesting that mr jackson was the sort of person who commit basis that testimony about him being paralyzed cannot tensing and in fact the tragedy except at that evidence and that was one of the sincere sense a conditional discharge to his medical condition of crutches didn't have a rock or didn't have a wheelchair officer pike testified that he felt some heart kissing on defendants legs and that's it that's all we have for the factual evidence that was before the jury in this case to determine whether defendant's conduct w he was coming out of a seizure going into a seizure if he was going into a seizure that he wouldn't have been having one when the paramedics and the police officers were there there's absolutely rational for the jury in this case t just turn around and turn their backs on defendant they were trying to get him to the hospital to get him to help that he required just because different he was acting irrationally doesn't mean the defendant was acting in voluntarily the fact the defendant was clearly could give their opinion that that person was having a seizure in this case the converse would be true when i witness who is not an expert but was has some fighting that based on their contributions and with the history of their experience this person was not having a seizure if going on that neighbor could say didn't seem like it was having a seizure to me exactly where his girlfriend could have testified opposite that yes he has this history of seizures and this was not a seizure and her testimony would have been just as intitled two points the state agrees that mr jackson is acting irrationally there's clearly something wrong and he's clearly suffering from a medical issue but they also argue that mr jackson did not present evidence to contradict the paramedics test