1. If the evidentiary hearing was based upon the challenges ' being time barred, yet the
Appellate Court concurred that the fourth and fifth convictions were not time barred, is
that not a failure of the courts to grant the defendant a partial evidentiary hearing for
challenges to the fourth and fifth convictions and more particularly, on the claim of
ineffective assistance of counsel being in plain error? (Appendix A)

A. If Counsel 's function is to assist the defendant and hence counsel owes the client a duty
of loyalty to assist the defendant, whom deserves the overarching duty to advocate the
defendant 's cause and more particularly has a duty to consult with the defendant on
important decisions as well as keep the defendant informed or important developments in
the course of the prosecution, how does Counsel 's failure to file proper motions on behalf
of the defendant not violate the defendant 's Sixth Amendment? (Appendix F) {Ind. #
04-04-1503-1}

B. If counsel 's duty is to bring and bear such skills and knowledge as will render the trial a
fair and impartial and reliable adversarial testing process, does not the failure to object to
the improper testimony of a drug expert violate the due process of law found in both the
Sixth and Fourteenth amendments of the Constitution? (Appendix F) {Ind. #04-04-1503}

C. If it is a constitutional violation when counsel fails to advise his client of the possible
consequences of immigration prior to entering a guilty plea, is it not also a constructional
violation if counsel fails to advise a defendant of the greater consequences of entering a
guilty plea beyond this case, especially when counsel was aware, as evidence was
presented, of an on-going Federal investigation? (Appendix- D) {Dec 5th 2015 plea
hearing}

D. If counsel 's error in advising the defendant to plead guilty to a crime was so serious that
it cost the defendant his life, {see Appendix B-l} where the court granted a motion to
receive the surveillance location, counsel wholly failed to investigate this location or any
additional information stemming from the alleged location prior to advising the defendant
to take the plea, is this not a clear deficiency in counsel 's performance which is binding
on the constitutional guarantees to be afforded to a defendant? Additionally, is this error
not so serious, having caused the defendant a sentence of life, that this ineffective
assistance of counsel warrants a full reversal and or if necessary, an evidentiary hearing?
(Appendix-D) {Dec. 5th 2015}

Whether the courts erred in failing to grant the defendant a partial evidentiary hearing on challenges to the fourth and fifth convictions, particularly the claim of ineffective assistance of counsel