serious reasons and but they're both well and that they will be participating in the discussion of this case they will be listening to audiotape of this world argument and  participating in the resolution of this matter so they're here in spirit but for the time being you're stuck with me so mr leonard may please the court  e police officer got to the house with and and the victim of the nobody would open the front door yes and they said open a door i'm going to kick it in and in response to that somebody opened the door would there be a consensual and the police walk in would that be a consensual going to the bathroom no there isn't she was in there and it was pretty clear she didn't want to come out yes she was in there she was bad maybe but we have to look to the words there were spok can she is a resident of that house has the right to exclude the police from areas there she didn't want to end and three yes she does and so when they said open the follow somebody back in the day i was involved in a few of those and but that you've got to start the arrest or try to attempt the arrest out in the public and then somebody runs away from you and then you can follow many yes but there was no because the officers trying to fight here but they don't catch up with the vehicle until she pulls into her house and closes the gries door at that point this bid for the sake i mean i'll agree with me that this is the defendant hand the right in her own home to repeat not withstanding her husband's allowing the police to the front door that she had the right to go into a room close the door and it and exclude the police yes just to finish my argument be here the officer stuck the so the problem here in this case is because there was no restraint of movement and i don't believe that that statement  s and what the words were were very important in this case to what degree the defendant's freedom of movement was restrained by the office series word i'd say that they were not she was free to open the door she did open if you were i would argue that it was consensual but even if you don't believe it was she proceeded home the complaining witness call the police like your honor indicate your honor indicated the police arrived in front of missing toby's house they never chased or there is no chasers knock on the door and the transcript is clear it's for forty five seconds to me and then she says if you don't open up the door i'm going to knock it down and your honour's can only imagine that there are knocking on honour's that when someone you're in the privacy you know bathroom and there's no place more private in your house than your bathroom you know when someone is saying if you don't up want to open up the crime is clearly chasing that person that's i that's i pursued with you views you know you're pursuing somebody when you can see him you know where they are and that i mean i guess you don't want to yell a guy you're under a rash but if you're facing somebody out of your pull out for armed robbery and somebody opened the door you've been following in your chase him that's i pursue whether you ever got the time to tell him you're under a rash or not than really well the person behind a bus had no place to go but this was not so much freedom of movement is whatever reason believe innocent person feel free to refuse to answer a police questions or decline the request to search their with me that if a reasonable if we were to find a reasonable person reasonable innocent person would not feel free to decline the police officers