THE HALL COUNTY DISTRICT ATTORNEY'S OFFICE CONTACTED THE GEORGIA BUREAU OF INVESTIGATION (HEREIN AFTER G.B.I.) AND TOLD THEM NOT TO RELEASE MITIGATION EVIDENCE TO THE DEFENSE.

WAS PETITIONER DENIED DUE PROCESS AND HAVE A VALID BRADY CLAIM WHEN THE STATE WITH HELD EXCULPATORY EVIDENCE THAT COULD HAVE AND PROBABLY WOULD HAVE CHANGED THE OUTCOME OF THE TRIAL, DIRECT APPEAL AND THE PETITIONER'S HABEAS CORPUS UNDER 28 USC § 2254 IF THE STATE HAD RELEASED THE INFORMATION TO PETITIONER'S COUNSEL?

THE HALL COUNTY DISTRICT ATTORNEY'S OFFICE CONTACTED A DEFENSE WITNESS AND THREATENED THE WITNESS WITH IMPRISONMENT FOR PERJURY IF THE WITNESS TESTIFIED FOR THE DEFENSE. THIS WITNESS WOULD HAVE TESTIFIED THAT SHE WAS ON THE PHONE WITH PETITIONER WHEN THE CRIME OCCURRED AND THAT PETITIONER DID NOT FIRE THE WEAPON THAT KILLED THE VICTIM.

WAS PETITIONER'S RIGHT TO DUE PROCESS VIOLATED WHEN THE STATE THREATENED HIS ONLY WITNESS WITH IMPRISONMENT IF THE WITNESS TESTIFIED TO ANYTHING OTHER THAN WHAT THE STATES IDEA OF WHAT THEIR IDEA OF THE EVIDENCE WAS?

4) PETITIONER WAS REPRESENTED AT TRIAL AND ON DIRECT APPEAL BY THE SAME ATTORNEY. COUNSEL COULD NOT RAISE INEFFECTIVE ASSISTANCE OF COUNSEL AGAINST HIMSELF. THERE WERE ISSUES OF INEFFECTIVE ASSISTANCE OF COUNSEL THAT SHOULD HAVE BEEN BROUGHT FORTH IF PETITIONER HAD BEEN APPOINTED NEW COUNSEL FOR HIS DIRECT APPEAL. THERE WERE MATTERS WITH MUCH MORE CHANCE OF REVERSAL ON DIRECT APPEAL IF COUNSEL COULD HAVE RAISED THEM. COUNSEL BROUGHT FORTH ISSUES JUST TO MAKE A SHOWING OF REPRESENTATION INSTEAD OF RAISING MATTERS THAT COULD HAVE AND PROBABLY WOULD HAVE CHANGED THE OUTCOME OF THE PROCEEDINGS.

DID PETITIONER RECEIVE CONSTITUTIONALLY INEFFECTIVE ASSISTANCE OF COUNSEL?

Did the petitioner receive constitutionally ineffective assistance of counsel?