PETITIONER'S COUNSEL WAS INEFFECTIVE IN FAILING TO CONDUCT A REASONABLE PRE-TRIAL INVESTIGATION. THIS VIOLATED PETITIONER'S RIGHT TO COUNSEL, AS GUARANTEED BY AMENDMENTS 6 AND 14 TO THE U.S. CONSTITUTION

PETITIONER WAS CONVICTED ON THE BASIS OF A GUILTY PLEA THAT WAS THE PRODUCT OF INEFFECTIVE ASSISTANCE OF COUNSEL. THIS VIOLATED PETITIONER'S RIGHT TO COUNSEL AND TO DUE PROCESS OF LAW AS GUARANTEED BY AMENDMENTS 6, 5 AND 14 TO THE U.S. CONSTITUTION.

PETITIONER'S APPELLATE COUNSEL WAS INEFFECTIVE IN FAILING TO AUGMENT THE APPELLATE RECORD WITH THE REPORTER'S TRANSCRIPTS OF THE PRELIMINARY HEARING TO COURT CASE (#VA070097) TO SHOW THAT PETITIONER'S PRIOR WAS INVALID. THIS VIOLATED PETITIONER'S RIGHT TO COUNSEL, AS GUARANTEED BY AMENDMENTS 6 AND 14 TO THE U.S. CONSTITUTION.

Ineffective assistance of counsel