It is a predicament that any lawyer with courtroom experience will recognise.
In England, for example, many lawyers will have their own story about when they are instructed to go to court to apply for the ‘usual order’ only to be asked by the judge as to what order that might be and the hapless lawyer did not know.
It is an experience that should only happen once to a lawyer, if it happens at at all.
This is because the basic requirements of any court room advocacy are to know (a) exactly what order or other remedy you are asking for and (b) the applicable test to be applied by the court in granting that order or other remedy.
If you know nothing else, that is what you should always know before you open your mouth as an advocate.David Allen Green, ‘A bad day in court for Rudolph Giuliani’ davidallengreen.com