1. Was counsel.ineffetiye. within the meaning of Strickland, and did the ineffectiveness present
a Martinez claim irfthe'petitioner's appellate proceedings?

2. Did a Brady violation occur within the context of the new statements made after the discovery
process, and used in trial? Did counsel have an obligation to object or otherwise move to
exclude the statements as being outside the scope of discovery?

3. Was trial counsel ineffective within the meaning of Strickland for "misplacing the trial record" and
and notes, which disallowed appellate counsel to properly perfect the petitioner's direct appeal?

4. Without an accurate record on direct appeal, could it be presumed that the petitoner's Rule 61
motion for post-conviction relief in the Superior Court was futile and fatally flawed, due to trial and
appellate counsel 's ineffectiveness?

Was counsel ineffective under Strickland, and did the ineffectiveness present a Martinez claim in the petitioner's appellate proceedings?