Thanks guys. Ok I am working on a case where hunter allegedly has been lost from his buddies during hunting. He found himself in the woods. Prior to that there was some news coverage in the area about dangerous bears so hunter decided to spend the night on a tree with his bow that he used to make a better balance. When confronted with the skepticism about that story this was an argument for choosing a tree for sleep - quoting:

"It's a common tactic for a hunter, who is separated from other members of his party who is in a dark wooded area like this alone to pick a place for shelter, if not on the tree, then perhaps some another shelter, rock outcropping or something in order to be safe from predators. So this is not out of ordinary at all."

Is there any credibility in that explanation choosing a tree for a sleep (taking possible danger from bears in account)? What do you think based on your experience?