for argument i always like to ask myself what is the one thing that i don't know that i have written in my grief or in my reply brief but i know what is written on the page but it is so important that must be verbalized there are certain things that just don't chop off the written page that are important and pivotal in cases in this case i think that it can be fairly soon as relationships it's important for this court to look at the relationship that existed between all of the parties certainly it wasn't unusual recall originally it was thought that this was a nine one one call it is through effective cross examination at trial that it's brought out that it wasn't a nine one one call that terry make our hand picked the investigator it and shows his  what is this about and the most response to it is we can do it the easy way or we can do it the hard way it is clear at that point i'm can they are looking to arrest my clients and they should have mirandized him prior to putting him in the doing when they were using that question first tactic where they get all the good information that they want and they then know what it is that they want the target to say i'll take and then they decide after they get all of that the other issue that you spoke of the should address is of course the question regarding the jury instructions and i know i guess i'd like to ask the question sure that you do acknowledge the general rule that the state doesn't have to prove the precise date applicable and of course before the indictment is returned and there is an exception to the general rule but you make a statement specifically i'm going to quote it courts have also ruled that the giving of the i p i criminal second number three point i want to make result in reversible error where is the defendant is misled into scenting his defense or where the defendant presents an alibi defense to counter the alleged date i think that's on page sixty defense has the ability and the right to say the that's fine if your points are expanded but then you need to be more specific as to what specific allegations are speaking out after all the pretrial work is done and as it relates to the bill of particulars and so that's why you cited these two cases because they dealt with bills of particular reading everything in concert ye one of the officers weren't able to articulate the precise words they used however in context it should also be remembered that the conflict friend was tending to a young boy in the yard and the office it's allowed him to go into the house by a friend's house in their care and walked to the front door with them maybe well flanked me in other words i'd be walking between them but that's not necessarily something that's pesto neal that's how people walk from a car to a building of this rule doesn't seem defendant that he was free to leave at any time and that if he wanted to go home they'd be glad to drive him so even if the room is locked dolling had to say it's look i'm outta here let's go back and according to their promise they'd be obligated to do it if they did not keep that i can't remember but it doesn't matter at this point because the officers were found to be credible and that was very specific testimony that they did they did recall that point so the defendant was never subjected to any sort of interrogation techniques the officer simply said we want to talk to you about possible inappropriate or allegations of inappropriate touching and the defendant immediately responded with the name of the different victim things then asked him about the victim in the ca the defendant was questioned as someone that the defendant didn't know and who was friends with the family have caused the defendant to feel pressured to confess in a way that he wouldn't have if it was some other maybe i should i can confide in him i certainly wouldn't have felt that way but he could have had that feeling which may have made him more ready to confess the defendant didn't exactly explain how mr karr goal  to somebody he actually knew it's highly embarrassing to admit these sorts of things the fact that he knew the man so so many different ways it just and without a good explicit testimony from the defendant that would be believed by the trial  way i don't believe anyone asked the trial judge for further information and had been requested the trial judge may well have explained himself further but even going beyond that the statute that seven twenty was the similarity in the way the defendant great she didn't do so with his child victims and she might have done different acts with them but he got himself into their trust and became friends with them and he almost precisely the asking the trial judge to further elucidate his reasoning it should also be noted that counsel claimed today that this disabled the the defendant too would do his defense and if i were working on the defense and didn't have a basis for the ruling and felt it was abused over a long period of time that child is simply not going to be able to distinguish as to each one went to each of these events occurred so to say that the ability to keep killers has give you know a timely manner and every single that did have a specific date i think july fourth one of the dates you know yes and if the state was able to do that then they met the defendant's request with respect to those but as i said with the child sex abuse case where the child so there's no so it's i'm saying it is i believe it is inappropriate i also think it was inappropriate that your trainer said order my client's pay restitution i think it's very clear you can't just get up on the stand and say i think that the ballpark figure for what we