1. ) THE COURT ERRED, A kelly hearing was required to test the reliability of
the process used to create the videotape of still photographs originally re
corded on a signle VHS tape.

2. ) THE COURT ERRED, The Court erred in allowing Detective Doster testimony
because doster had no experience,training, or education in videographs or
experience in calcolating the time between still
photographs and no knowledge of the camera system that had taken and recorded
the VHS tape .

3. ) TRIAL COUNSEL WAS INEFFECTIVE ASSISTANCE OF COUNSEL: Here Counsel failedforensic videographs, no
to object to Doster's estimate time, Counsel's failed to call expert witness,
Cole was present evidence deprived Cole of effective assistance of counsel
denied the rights guaranteed to him by the Sixth Amendment and by Article 15
of the California Constitution.

Whether a Kelly hearing was required to test the reliability of the process used to create the videotape of still photographs originally recorded on a single VHS tape