Was Petitioner denied his right to compel witnesses when counsel failed to subpoena
an expert that had found exculpatory evidence and this evidence was found in the
police and prosecutor files?

Was counsel's performance deficient when counsel failed to examine the police and
prosecutor files and conduct an independent investigation after a retained expert
found exculpatory evidence in these files and did this deficient performance prejudice
Petitioner?

Was Petitioner prejudiced where counsel's deficient performance rendered the state
court record insufficient and precluded from federal review and can Petitioner
overcome the bar of Harrington v. Richter and Cullen v. Pinholster, when it is this
ineffectiveness of counsel that obstructed the preservation and conservation of the
state court record?

If the State utilizes evidence outside the state court record, is the bar of Harrington
v. Richter and Cullen v. Pinholster, overcome under 28 §2254(d)(2) when the use of
such evidence resulted in a decision that was based on an unreasonable
determination of the facts in light of the evidence presented in the State court
proceeding.

Do voir dire statements by the defense open the door to allow the State to bypass fair
notice and the balancing test of relevancy concerning the introduction of inadmissible
evidence under state and federal law?

Was Petitioner denied his right to compel witnesses