One thing that's clear in this argument, the reason you have a district court proceeding to develop the facts before a case goes on appeal is to avoid exactly what's happening here: Lawyers unable to answer factual questions, guessing about how stuff works. Not only does the court of appeals lack jurisdiction, this hearing is also a master class in why the district court should do its job & develop the factual record before there is an appeal (even when the appellate court does have jurisdiction)