Discovery indicates that your client was polite, calm and cooperative.  This demeanor is incompatible with a diagnosis of alcohol intoxication.

DSM indicates, under Criteria B, that “The essential feature of alcohol intoxication is the presence of clinically significant behavioral or psychological changes (e.g., inappropriate sexual or aggressive behavior, mood lability, impaired judgment, impaired social occupational functioning) that develop during, or shortly after, alcohol ingestion.”  This requirement for the diagnosis of alcohol intoxication is not satisfied.