I. THE EVIDENCE PRESENTED AT TRIAL WAS INSUFFICIENT TO SUPPORT THE CONVICTION OF CSC 1st DEGREE WHERE THERE WAS NO PROOF OF PENETRATION AS REQUIRED BY THE MICHIGAN SUPREME COURT IN VIOLATION OF DEFENDANT 'S US CONST. XIV AMENDED RIGHT.

II. THE EVICENCE PRESENTED AT TRIAL OR WHETHER THE LACK THEREOF, WAS INSUFFICIENT TO SUPPORT THE ABORTION CONVICTION IN VIOLATION OF THE DEFENDANT 'S RIGHT TO DUE PROCESS UNDER THE U.S. CONST. XV AMENDMENT

III. THE TESTIMONY OF THE PROSECUTOR 'S "EXPERT " WITNESS, ANDREAS SULLVAN, INADMISSIBLY VOUCHED AND BOLSTED THE CREDIBILITY OF THE COMPLAINTANT IN VIOLATION OF BECKLEY COURT PRESEDENCE AND VIOLATED THE DEFENDANT 'S SIXTH AND FOURTEENTH AMENDED RIGHT TO A FAIR TRIAL, DEFENSE COUNSEL 'S FAILURE TO OBJECTRENDERED INEFFECTVE ASSISTANCE.

IV. THE DEFENDANT DENIED HIS RIGHT TO CROSS EXAMINE DR. ANGILLI WHEN HER REPORT THAT CONCLUDED THE COMPLAINANT WAS ABUSED AND HAD TERMINATED THE PREGNANCY WAS ENTERED INTO EVIDENCE THROUGH ANDREA SULLIVAN VIOLATING THE DEFENDANT 'S CONFRONTATION CLAUSE. TRIAL COUNSEL 'S FAILURE TO OBJECT RENDERED INEFFECTVE ASSITANCE IN VIOLATION OF DEFENDANT 'S SIXTH AMENDMENT RIGHT.

V. THE DEFENDANT SENTENCED UNDER FALSE INFORMATION DUE TO THE PROBATION DEPARTMENT 'S FAILURE TO CALULATE HIS PRV AND OV SCORE IN DEFENDANTS PSI REPORT IN VIOLATION OF HIS RIGHT TO DUE PROCESS? DID DEFENSE COUNSEL FAIL TO CHALLANGE THE INACCURATE GUIDELINES RENDING INEFFECTVE ASSISTANCE.

VI. WAS THE DEFENDANT DENIED HIS RIGHT TO EFFECTIVE ASSISTANCE OF TRIAL COUNSEL DUE TO: (A) COUNSEL FAILURE TO INVSETIGATE AND PREPARE A SUBSTANTIAL DEFENSE, (B) COUNSEL WITHHELD IMPEACHABLE DISCOVERY MATERIAL, (C) COUNSEL FAILED TO EFFECTIVELYU CROSS-EXAMINE THE PROSECUTOR 'S WITNESSES, (D) COUNSEL CONCEDED TO THE DEFENDANT 'S GUILT INFRONT OF THE JURY AT CLOSING ARGUMENT?

VII. THE SUBSTANTIAL ISSUES RAISED IN DEFENDANT 'S 6.500 MOTION ALL HAVE A CUMULATIVE EFFECT ON THE OUTCOME OF DEFENDANT 'S TRIAL AND DIRECT APPEAL IN VIOLATION OF HIS RIGHT TO DUE PROCESS EVEN IF THE TRIAL COURT CONSIDERS THEM TO BE HARMLESS.

Insufficient-evidence-to-support-conviction