scene, the subjects and the current surroundings. they have to take into consideration whether they suspect -- the suspect was under the influence of a controlled substance. they can take into consideration -- again, this is a dynamic and ever changing -- just like life. things change. it's a dynamic situation. it's fluid. they take into account their experience with the subject at the beginning, the middle, the end. they try to -- a reasonable police officer tries to predict or is at least cognizant and concerned about future behavior based upon past behavior. the unpredictability of humans factors into the reasonable police officer's analysis, too. sometimes people take -- reasonable police officers take someone into custody with no

problem and suddenly they become a problem. it can change in an instant. a reasonable police officer will take into consideration his immediate surroundings. are there bystanders, civilians? a reasonable police officer will take into consideration who he is at the scene with. are these veteran officers? are they rookie officers? what do i know about my partners and my partners' abilities? throughout the course of this trial, the state has focused your attention on 9 minutes and 29 seconds. the proper analysis is to take those 9 minutes and 29 seconds and put it into the context of the totality of the

circumstances that a reasonable police officer would know. the proper analysis starts with, what did the officer -- what would a reasonable officer know at the time of dispatch? these are records that have been kept. they have been introduced. you can look at them. this is exhibit 151. this is the computer aided dispatch report. you heard the testimony of the 911 dispatcher. this is information that they are passing out to the officers. you will see that the initial information that a police officer has in his squad car looking at his computer or hearing over the radio was that on may 25, 2020, at 20:02:13 -- that's 8:02:13, a business, cup

foods, who police officers have the obligation to respond to these calls, whether it be from a person or a business, but a citizen of the state of minnesota runs a business and they called for assistance. they told the officers, the reporting party, there's a male who provided a counterfeit bill to the business. he is six feet tall or higher. he is sitting on top of a blue mercedes ml320 suv. it appears this subject is under the influence. the analysis of what a reasonable police officer would know in this circumstance is that, a, a business is requesting its help, the suspect is still there, he is large and

he is possibly under the influence of alcohol. or something else. the analysis begins at 8:02:13. you may recall the testimony of the 911 operator. it's not reflected in this exhibit pretty well. in the evidence, exhibit 10, you can hear the audio recording of the dispatch to the officers. she informed you that initially officer chauvin was assigned to this call on a code 3 priority 1 basis. code 3, get there lights and sirens. get there fast. per the minneapolis police department policy, get there fast.

the person is on scene. right? that's what she testified to. very quickly after that, that occurred at 8:04:28. then what you see is -- what she told you was that the sector car, sector car 320, the car that patrols this part of the city, said, we can take this call. officer chauvin and officer tao were canceled from the call. they were canceled from the call. sector car 320, king and lane took it. that occurred at 8:05:11. when officer king and lane took it over, you can hear -- you can go back and you can listen to the audio of the dispatch. you can hear them talking to each other. officers king and lane arrive at the cup foods at 8:08:20.

now we see police officers are responding. they are on scene at 8:08. both jenna and peter describe that during the course of the interaction between the initial interaction between officers king and lane and mr. floyd, through dispatch, they heard what sounded like the sounds of a struggle. jenna described she's trained to listen. she heard the sounds of a struggle. she aired out on her own other officers need to respond, code 3

to assist officers king and lane. a reasonable police officer is going emergent to a scene. he gets cancelled from the scene. he is now being told that other officers need assistance and step it up. get there fast. so you can see, again, based on the records, that at 8:10:08, backed up 320 with 330. now 330 is officers chauvin and tao. they are backing up officers king and lane. you can see peter chang respond at 8:10:21. you hear 320 taking one out. that means they are removing

someone from the vehicle at 8:11:02. the scene is ultimately c4, code 4, all clear, at 20:12:21. literally, this demonstrates to you a couple of things. how quickly a situation can change from second to second, minute to minute. they went from, get there fast, back off, get there faster because someone needs help, it's clear. the situation is dynamic and it's fluid. they are provided with information that an officer needs assistance. they testified about the sound of a struggle. right? if you recall, the sergeant said, all of this information would be known to a reasonable police officer. and it goes into and factors

into the reasonableness of the use of force. ultimately, officer chauvin and officer tao arrive at cup foods. pause this for one second here. sorry. when we look at officer -- i have to give you a little piece of information. when we look at officer chang's video, he arrives first. the time is 1:16:33 z. that's greenwich meantime. subtract 5 from 1:00 a.m., get you back to 8:00. officer chauvin and officer lane

pull up. 8:16. go over there. >> stay put. i don't want anybody near his car. >> information gathering in terms of this assessment and reassessment of, again, the decision making process of a police officer. right? don't come over here where i am, officer chang says. go over there. they need your help. because at that point, at that precise moment, they don't know what's happening over at the squad car. they don't know that officers

king and lane struggled with mr. floyd getting him out of the car, that they sat him down, that they stood him up, they walked over. they haven't seen any of this information. there's no evidence to suggest that they have. that doesn't factor into the information. a reasonable police officer, what do they know? they don't know that. they are starting to get some indication, go over there. go over there. you can see right at about 8:17 -- i apologize for quality of the picture. officer chauvin is arriving and walking up to the squad car. so what a reasonable police officer -- what would a reasonable police officer see in this instance? what a reasonable police officer would see could be defined --

because a reasonable police officer has to be aware of his department policies. active aggression or active resistance. let's call it active resistance. a response to police officer efforts to bring a person into custody or control for detainment or arrest, a subject engages in active resistance when engaging in physical actions or verbal behavior reflecting an intention to make it more difficult for officers to achieve actual physical control. as derek chauvin walks up to the scene, he has all of the information from dispatch, he has all of the information from officer chang sending him over. he knows his department policy on the difference between active aggression, active resistance, passive resistance based on

policy, training, et cetera. this is an officer's consideration of, again, the use of force. all of these things factor into it. what does he see? he sees officers king and lane struggling with mr. floyd, attempting to put him into the car. he hears the words that mr. floyd is saying at that point. i'm claustrophobic. i'm a good guy. i'm a good man. i'm claustrophobic. i just had covid. he is hearing this information. he is observing with his eyes. a reasonable police officer is observing this with his eyes and his ears and assessing what he sees pursuant to policy. and what he sees at a minimum is active resistance. mr. floyd is not simply getting in the back seat of the car.

let's watch, what does officer chauvin see when he walks up? this is from his body camera from 8:17:21 to 8:18:15. just shy of a minute. >> you can't win. >> i'm not trying to win. >> get in the car. >> he know it. hear me. don't be like that. >> get in this car we can talk. >> i'm claustrophobic. >> you are not working with me. >> i'm claustrophobic. can you put me in the front? >> no. get in the car. >> i'm not a bad guy. >> get in the car. >> you ain't going to win. >> please, please.

please. i can't breathe. please. my wrist. man, my wrist. please. >> by 8:18:15, officer chauvin has not laid a finger on mr. floyd. but he is observing. a reasonable police officer is doing this. he walks on a scene. he sees active resistance occurring, potentially active aggression occurring. he has two other officers. he has not intervened. again, based on the policies and the training that you have seen, what were his options available to him at that time? if a person is actively resisting, in the center,

distraction techniques. controlled takedowns. conscious neck restraints. these are options available to mr. chauvin at this point. he has, per his training, these techniques at his disposal. a reasonable police officer would be making these observations. he would observe the white foam around mr. floyd's mouth. he would consider the possibility that this person was under the influence of something. basically, using the information from dispatch. making these observations. how is he analyzing this? how would a reasonable officer analyze this and what would be known to a reasonable officer? a reasonable officer would look

at the size of the person and assess that person's size in relation to his own size. because it's a part of the risk/threat analysis that we have heard about so much. a reasonable officer would know that these are two rookies putting this man in the car. in fact, as the evidence established, mr. chauvin trained one of the officers. a reasonable officer may step back at this point to see if these two guys can get this under control. a reasonable officer will hear the words that the suspect is saying. i'm a good guy. i'm a good guy. i'm claustrophobic. he is going to compare those words to the actions of the individual.

this is part of the analysis. i can say, i'm going to cooperate with you, i'm going to do whatever i want, but if my behavior is inconsistent with what i am saying, a reasonable officer takes that into consideration. in fact, a reasonable officer, who is aware of his department policies, knows the deescalation policy. part of what a reasonable officer has to do is to consider whether a subject's lack of compliance is a deliberate attempt to resist or an inability to comply based on these factors. medical conditions, mental impairment, developmental disability, physical language, language barrier, influence of drugs or alcohol or behavioral crisis. an officer -- a reasonable officer has to take the information and assess, is this

suspect purposefully or intentionally, deliberately trying to thwart our efforts to take him into custody or are they experiencing one of these other types of factors? but such consideration, when time and circumstances reasonably commit, shall be balanced against the incident facts when deciding which tactical options are the most appropriate to resolve the situation safely. again, reasonable officer. based on the totality of the circumstances, is going to take all of this information in, all of these policies, all of this training, and a reasonable officer at that point would conclude that the amount of force that was being used by officers king and lane was insufficient, was not enough use of force to overpower mr. floyd's resistance to getting

into the car. he has seen it. he has heard it. he is familiar with the policies. at precisely 8:18:15, officer chauvin goes hands on. officer king, lane and chauvin struggled, fought, whatever adjective you want to use. they struggled with mr. floyd from 8:18 until 8:19:12. about a minute. a little over a minute. it doesn't really seem that it's that long of a time. again, the amount of physical exertion -- remember how the sergeant described this. when the apparent attempts to get him into custody were futile -- i wrote his quote down. the futility of their efforts

became apparent. they weren't able to get him into the car. three minneapolis police officers were not able to get mr. floyd into the car. they themselves are experiencing that surge of adrenaline. a reasonable police officer will be experiening that surge of adrenaline. again, balancing all of the evidence against each other, let's look at three different angles of the struggle. this is officer king's body camera. >> i'm going down. i'm going down. i'm going down. i'm going down. i can't breathe. >> get in the car.

>> i can't breathe. >> take a seat. >> is he going to jail? >> he is under arrest for forgery. >> take him out. >> for what? police, man. i can't breathe. >> come on out. >> thank you. thank you. >> on the ground. on the ground. >> he is under arrest for forgery. for what? this is the video of the same time period from officer lane. >> i'm going on the ground. >> get in the squad. >> i'm going down. i'm going down. i'm going down.

i can't breathe. i can't breathe. i can't breathe. i can't breathe. please, man. listen to me. >> he is under arrest right now for forgery. i don't know what's going on. >> take him out. >> i can't breathe. >> on the ground. >> i appreciate that. >> officer tao. >> i will lay on the ground. i will lay on the ground. i'm going down. i'm going down.

i can't breathe. i can't breathe. >> you are talking. you have oxygen. >> let go of me. i can't breathe. >> he is under arrest right now for forgery. >> take him out. >> please, man. >> on the ground. >> a reasonable police officer understands the intensity of the struggle. you can see at points when mr. floyd's legs kick back, it almost knocks officer lane over. it knocks off the body-worn camera and the badge of officer

chauvin in this struggle. a reasonable police officer would understand this situation. mr. floyd was able to overcome the efforts of three police officers while handcuffed, with his legs and his body strength. a reasonable police officer standard can be seen in another way, from the milestone camera. this is what caught the attention of the 911 dispatcher. she observed the struggle and the vehicle rocking back and forth, back and forth. watch the vehicle.

reasonable police officers will consider their training. before we talk about the

training again, there's something that i think is really important to understand. two things, actually, at this moment. not a single use of force expert that testified, not a single police officer who testified said that anything up until this point was unlawful or unreasonable. it was reasonable for these officers to put them into -- mr. floyd into the squad car. it was reasonable, the efforts that they took to overcome his resistance were reasonable. every single expert agrees that to this point, nothing is contrary to policy, training, defensive tactics, crisis intervention, all reasonable. it's at the point that mr. floyd is brought to the ground that there becomes a dispute about the reasonableness of the use of

force. and what a reasonable officer would know. it was the law professor who said at the point mr. floyd came out of the car, putting him on the ground was unreasonable. was it reasonable for officer chauvin or a reasonable police officer to put mr. floyd on the ground in that instance? a reasonable police officer is going to rely on his training and information, his evidence, what he knows, all of the information he built up to this point. you heard the lieutenant testify about how 15 years ago the minneapolis police department went to ground defense tactics. getting people on the ground to control them, control the head, control the body. different moves that the police use to create and eliminate

space. escape versus control. those are two different things. these are the tactics that have been employed by the minneapolis police officer for 15 years. why? it's safer for the officers and the suspects. it keeps people contained, controlled and confined until they no longer are resistant. a reasonable police officer would also consider his department's policies. including the use of non-deadly force policy. force that does not have the reasonable likelihood of causing or creating a substantial risk of death or great bodily harm. this includes but is not limited to physically subduing,

controlling, capturing, restrain ing or physically controlling the person. non-deadly force can be used to physically manage a person. every single person has agreed that the use of force up to this point is reasonable, lawful and meets the reasonable officer standard. so we get into the 9 minutes and 29 seconds at this point. the state has really focused on the 9 minutes and 29 seconds. 9 minutes, 29 seconds. 9 minutes, 29 seconds. it's not the proper analysis. because the 9 minutes and 29 seconds ignores the previous 16 minutes and 59 seconds. it completely disregards it.

it says, in that moment, at that point, nothing else that happened before should be taken into consideration by a reasonable police officer. it tries to reframe the issue of what a reasonable police officer would do. a reasonable police officer would, in fact, take into consideration the previous 16 minutes and 59 seconds. their experience with the subject, the struggle that they had, the comparison of the words to actions. it all comes into play. why? because human behavior is unpredictable. human behavior is unpredictable. nobody knows it better than a police officer. someone can be compliant one second and fighting the next. someone can be fighting and then compliant. nobody knows it better.

reasonable police officers continue to assess and re-evaluate. this is the critical decision making policy or model. gather information. you assess the threat versus the risk. do we have an authority to act? what are our goals and actions? review and assess. start over. because this is not a singular cycle. this is a cycle that humans -- as humans, we literally make millions of decisions in a day. right? do i go this way, do i go that way? we are constantly doing this. this is just human behavior. in the policing context, you have to gather the information, assess the risk, assess the threat, do i have authority to act, what are my goals and actions, review and assess.

it's constantly rotating. at the precise moment that mr. floyd was laid on the ground, a reasonable police officer would know about those previous 17 minutes. a reasonable police officer would know about the struggle. a reasonable police officer would consider the suspect's reactions to the previous use of force. a reasonable police officer would continue this process of reassessment. a reasonable police officer would consider whether to use an additional force to overcome the su suspect's level of resistance. 9 minutes and 29 seconds.

>> i can't breathe. i can't breathe. >> thank you. >> stop moving. >> mama. mama. >> continuing to assess the risk and affect. the first 29 seconds, 20 seconds, continued resistance is what a reasonable police officer interpret that to be. jesus christ, the kicking. a reasonable police officer would consider, should we elevate the use of force as we meet this threat? that's precisely what these officers did. they discussed using the mrt. >> there you go.

>> mama, i love you. >> ems is on the way. >> i can't breathe. please. please. let me stand. please, i can't breathe. >> they are discussing, should we use the hobble? should we elevate our use of force? a reasonable officer would continue to evaluate whether the suspect is under the influence. precisely what these officers did in this 9 minutes and 29 seconds. [ inaudible ]

>> please, man. mama. >> is that the eyes? >> i'm through. >> reasonable police officers discussed the scene. first clip, they are talking about the two other people that are over at the car. what's going on here? what are we dealing with? is this person under the influence of controlled substances? these are the actions of a reasonable police officer. a reasonable police officer would rely on his training and experience. call ems. possibility that a suspect who was struggling with us will begin to struggle again. you have heard this testimony from multiple police officers.

the risk that the suspect would present to himself if he is not continued to be controlled. the risk that the suspect presents to other officers or citizens if not continued to be controlled. if he is not continued to be controlled. these are things that all of the police officers have testified about. these are what a reasonable police officer should do. a reasonable police officer in this situation would call ems. 20:20:11. 8:20:11, within a minute of the struggle, ems code 2 for a mouth injury. because they are not observing life-threatening. a reasonable officer is not observing life-threatening injuries at this point. they just fought with the man for a minute. he continued to kick at them when they got him on the ground. they see he has a mouth injury.

we need ems. a reasonable police officer would evaluate the injuries of the suspect, compare words and actions and respond by calling ems. non-emergency. again, reasonable police officers evaluate, re-evaluate. 20:21 -- 8:21, 1 minute and 24 seconds later, we need ems here faster. code 3. we need him here faster. a reasonable police officer would take into consideration the anticipated time of an emergent response. you heard there's a firehouse a

few blocks away. she would have expected ems to be there within minutes, three minutes is what she said. a reasonable police officer, based on his training and experience is going to have and take that into consideration. i put this person in a prone position on the ground. i'm holding them for my safety and their safety. i'm expecting someone to be here within three minutes to help this person. i have called for that help. a reasonable police officer will take into consideration, again, his training, his experience. the lieutenant talk -- many people talked about -- many of the officers talked about how it is not uncommon for suspects to feign or pretend to have a medical emergency to avoid being arrested.

unfortunately, that is the reality. nobody likes to get arrested. reasonable police officers know that. my heart hurts, i'm having a medical emergency, insert whatever emergency. simply because think don't want to go to jail. a reasonable police officer will take his training into experience. you heard the lieutenant specifically say, when someone says that they can't breathe but they are talking, if they are talking, it means they are breathing. campaign that to the testimony of dr. tobin who told you that same thing. if you are talking, you are breathing. doesn't mean effectively. dr. tobin described how even

medical doctors have problems sometimes assessing the legitimacy of a patient's needs relevant to their respiratory processes because they are saying, i can't breathe and some doctors confuse it for anxiety or this or that. if medical doctors make these mistakes, dr. tobin told you it provides a false sense of security. the lieutenant told you that is what is said among police officers. he is the trainer. how many ty times do we hear an officer say, based on his training and experience, if you can breathe, you can talk? if you can talk, you can breathe. i counted seven. >> i can't breathe. please. >> you are talking. sit down.

>> i can't breathe. i can't breathe. >> you are talking. you have enough oxygen. you can breathe. >> relax. >> i can't breathe. >> you are talking fine. >> deep breath. >> i can't breathe. please. i can't breathe, officer. >> you are talking. it takes a lot of oxygen. >> i can't breathe. >> reasonable police officers,

again, are trained and take into consideration a person's actions relevant to their words. their train, their experience, takes a lot of oxygen to talk, takes a lot of -- you are breathing fine if you can talk. >> i can't breathe. >> he is talking. so he is fine. we tried that. he is talking. he is fine. we're done. >> reasonable police officers will take into consideration their training and experience on excitd delirium and they will analyze it within the context of this case.

>> i worry about that. >> i worry about the excited or delirium or whatever, that's why we have ems coming. it's not just, leave him here. it's we have ems coming. this is why we have ems coming. reasonable police officers throughout the course of a controlled technique will continue to assess the level of resistance. remember what the lieutenant said. simply because a person isn't kicking at you or punching at you or biting at you, it does not mean you can't control them physically with your body weight. this is at 8:24.

this is the point where dr. tobin testified that mr. floyd had an anoxic seizure. it's a reasonable police officer's standard, how would a reasonable police officer interpret this. does a reasonable police officer even know what an anoxic seizure

is? a reasonable police officer will interpret this as at least some form of minimal resistance. reasonable police officers, again, are continuing to monitor. they are expecting ems to arrive. >> non-deadly force. it includes but is not limited

to physically subduing, controlling, capturing, restraining or physically managing a person. these are the policies of the minneapolis police department. reasonable police officers, again, continue to monitor. see if he is breathing. >> i think he is passing out. i mean -- my knee might be a little scratched. i'll survive. >> i think he's passing out. but he is breathing, right? >> an anoxic seizure. >> reasonable police officers

are building and basing their decisions based on all of these factors coming in at multiple times. including the bystanders. call them a crowd, call them onlookers, call them bystanders. it doesn't matter what term you use for the people that gather to watch what police do. reasonable police officers are cognizant of and aware of their surroundings. before i really kind of start talking about the crowd in some limited detail, i have thought a lot during the course of this trial about the difference between perspective and perception. perspective and perception are two distinct concepts. perspective is the angle at which you see something.

it's your perspective. perception is how you interpret what it is that you see. i thought about this a lot during the course of this trial, because this situation here in the courtroom is incredibly unique. right? it's not the normal setup for a jury trial. so my perspective through the course of this trial, sitting in this chair, is that i cannot see four of the jurors. very limited opportunity to observe the jurors. they probably can't see me, either. several of the jurors i have a very good view of. four of the jurors i don't, and obstructed views of others. my perspective sitting in this chair of witnesses, there is a camera blocking the head. so in order for me to see the witness, i have to roll all the way over to the other side. then i have to look through the plexiglass that has these large

reflecting lights. things block your perspective. things can affect your perspective. but your perception is how you interpret what it is you see and what it is you experience. and that is our life, right? this is our experiences. these are the things that make us who we are. three people in this trial went to the same high school. me, darnella frazier and chief arradondo. all at different times. my experience, chief arradondo's experience, darnella frazier's experience -- we all saw the same chalkboards and whiteboards.

but our perspective of being there is going to be much different. ultimately at the end of the case, when we're done with these arguments, the court will instruct you on how to deal with these biases and the perception issues. the court's final instructions will guide you to try to recognize your biases, recognize what we bring to the table and analyze the evidence from the perspective of the evidence itself. so let's look at this incident on may 25th from the perspectives and perceptions of simply just four of the bystanders. charles mcmillian, 61 years old. third grade education. grew up in the south. he described himself as a curious guy. he likes to know what's going on in his neighborhood, so he stops and he checks things out, right? his perspective -- he's the first one who is dealing with

these guys. he has more information because he sees the entirety of the situation. but his perception is altered by his experiences. at the end of the night, he said to officer chauvin, i hope you get home safely, because that's what he says to police officers every night. >> that's one person's opinion. this guy is a sizeable guy. >> i'm just saying, you respect me, i'm going to respect you. you get home safely. >> darnella frazier.

she's a 17-year-old high school student who, upon seeing the restraint of george floyd, her response was to pull out the cell phone and start recording and then sought to upload it to facebook. her perception of the event, her perspective of the event. she didn't even know officer king was there because her vision was blocked by the squad car. she began recording at 8:20 and 51 seconds. he spent the day fishing with his son, stopping for a drink when he became aware of the

incident. he described his view of this based upon his perception as a mixed martial artist, all right? he has a set of experiences that caused him to react in a different way. what he perceived was happening was that mr. floyd was being choked with a blood choke. i think we're past this at this point. the paramedic reached in, touched the carotid artery. to have a person rendered unconscious through a choke requires the blockage of both carotid arteries. this was not a neck restraint. this was not a chokehold. he was upset. and that, again, is okay because his perception affected what he was seeing.

genevieve hanson, right? 27-year-old female firefighter for the city of minneapolis. she testified that when she walked into the scene, she described the crowd as upset. she said, i walked into an upset crowd. she said the other voices distracted me from getting the officers' attention. and she testified again based on her perspective that officer chauvin appeared to have his hand in his pocket. she observed what she believed to be blood from mr. floyd's face being pressed into the pavement. she observed fluid coming from mr. floyd's body that she presumed to be urine. she told me no one told her ems was on the way. when i asked her about response

time, she said she would expect three minutes. when i told her paramedics had been called about five minutes prior to her arriving on scene, no way because her perception is three minutes. but when you look at the things ms. hanson saw, whether it be from her perception or perspective, there can always be another story. the blood coming from mr. floyd's nose is why they called ems in the first place. you've seen the pictures. he injured his nose during the struggle or his face during the struggle in the squad car. the fluid that she described as potentially being urine, we know that that's fluid coming from the undercarriage of the squad car. officer chauvin specifically told her an ambulance was coming

when she first came on scene. >> don't come over here. we need you to keep some distance. >> we got an ambulance coming. the computer-aided dispatch reports clearly show what time ems was called. so genevieve hanson has a perspective and a perception. and what she observed was not consistent with the actual evidence. but remember, we don't look at this incident from the perspective of a bystander. we do not look at this incident from the perspective of the people who are upset by it. we look at it from the perspective of a reasonable police officer. a reasonable police officer when confronted with these bystanders would know everything that had

occurred up to that point, 20 minutes, 25 minutes, 30 minutes. they know all of that information. the bystanders do not. a reasonable police officer would understand that his actions were actually being recorded. take the bystanders out of it. the officers wear cameras for a very specific reason, to record their actions, so they know they're being recorded. officers are aware of the placement of city cameras. you're in a high retail -- you've got gas stations, restaurants, convenience store. high surveillance. reasonable police officers know this. they would know if citizens take out their cell phones and start filming. this is the point at 8:20 and 49

seconds when ms. frazier starts recording. reasonable police officers are aware when they're using force, but sometimes what they are doing does not look good to the general public. a reasonable police officer will hear the frustration growing. a reasonable police officer will hear the increase in the volume of the voices. a reasonable police officer will hear the name calling, right? chump, whatever names are being called. they'll hear the cursing. they'll hear this and they'll take that into their consideration. a reasonable police officer will rely on his recent training. a reasonable police officer will hear -- i'll come