1. Is the low threshold for a certificate of appealability ("COA") met on a claim that trial counsel provided prejudicially deficient performance when counsel failed to impeach the key prosecution witness with his inconsistent testimony?

2. Does a petitioner meet the low threshold for a COA on a claim that trial counsel provided prejudicially deficient performance when counsel failed to adequately emphasize petitioner's history of mental illness to support his requests that the trial court dismiss a prior "strike," so that the instant conviction would not be his "third strike"?

Is the low threshold for a certificate of appealability (COA) met on a claim that trial counsel provided prejudicially deficient performance when counsel failed to impeach the key prosecution witness with his inconsistent testimony?"