Whether reasonable jurists could argue that the State failed to meet its burden of proof beyond a reasonable doubt, every essential element of the offense charged;

Whether reasonable jurists would find that Mr. Lemoine was denied effective assistance of counsel, in violation of the Sixth and Fourteenth Amendments to the United States Constitution;

Whether reasonable jurists would debate that Mr. Lemoine was denied a fair and impartial trial with the submission of testimony from an "Expert" witness which failed to meet the Daubert standard, in violation of the Sixth and Fourteenth Amendments to the United States Constitution;

Whether reasonable jurists would find that the State improperly introduced the testimony of unsubstantiated, unfounded "expert" witnesses in order to overcome the factual insufficient evidence.

Whether reasonable jurists would find that Mr. Lemoine was denied a fair and impartial trial with the State's improper use of his statements which were made while intoxicated and could not be considered to be voluntary or knowing; Fifth, Sixth and Fourteenth Amendments to the United States Constitution; Beecher v. Alabama.

Whether reasonable jurists could argue that the State failed to meet its burden of proof beyond reasonable doubt