1. WHETHER THE STATE COURT'S OCT. 13, 2021 ORDER (App. P-2) DEPRIVED PETITIONER OF THE FUNDAMENTAL CONSTITUTIONAL RIGHT TO FAIR TRIAL, E.G., A MEANINGFUL OPPORTUNITY TO PRESENT A COMPLETE DEFENSE [476 U.S. 690 (1986)] BY DENYING ASSIGNED APPELLATE COUNSEL ARGUMENT [App. V-5]? "BECAUSE OF TECHNOLOGICAL ADVANCES, MR. GARCIA REQUIRES A COPY OF THE ENTIRE VIDEOTAPE PLAYED AT HIS TRIAL IN SUPPORT OF HIS DEFENSE. VIDEOTAPE DEPICTED HIS STRUGGLE [App. X-3(a):97;103; 124-133; 2-3(a):147-146; 162-167; Z-3(b):234-237] COULD ENHANCE THE QUALITY OF THE TAPE PROVING THAT THE GUN WENT OFF PURSUANT TO THE ATTACK [App. V-5]"?

2. WHETHER THE STATE COURT'S OCTOBER 13, 2021 ORDER (App. P-2) DEPRIVED PETITIONER OF HIS RIGHT TO PRESENT A COMPLETE DEFENSE BY FAILING TO ASSESS MERIT OF FIRST PCR, AND THE PRO-SE SUPPLEMENTARY POINT II DISCOVERY REQUEST (App. T-1; May 4, 2007 Trans. 56:15 to 57-9)?

3. WHETHER THE STATE COURT'S OCTOBER 13, 2021 ORDER (App. P-2) DEPRIVED PETITIONER OF HIS RIGHT TO DUE PROCESS AND EFFECTIVE ASSISTANCE OF COUNSEL GUARANTEED BY THE 6TH AMEND. U.S. CONSTITUTION?

4. WHETHER THE APPELLATE DIVISION'S OCT. 13, 2021 ORDER (App. P-2) DEPRIVED PETITIONER OF THE ASSISTANCE OF COUNSEL, GUARANTEED BY THE SIXTH AND FOURTEENTH AMENDMENT OF THE U.S. CONSTITUTION, BY AFFIRMING THE LOWER COURT'S AUGUST 25, 2016, MARCH 3, 2017, AND MARCH 28, 2017, WHICH WERE ALL ISSUED WITHOUT ANY PARTICIPATION OF ASSIGNED COUNSEL [App. T-2; Jan. 25, 2019 Trans. 62-1 to 63-3; App. S,T,U]?

5. WHETHER THE APPELLATE DIVISION'S OCT. 13, 2021 ORDER (App. P-2) DEPRIVED PETITIONER OF DUE PROCESS OF LAW GUARANTEED BY THE FIFTH AND FOURTEENTH AMENDMENT OF U.S. CONSTITUTION, BY AFFIRMING THE LOWER COURT'S AUGUST 25, 2016, MARCH 3, 2017 AND MARCH 28, 2017, AND JANUARY 25, 2019 ORDERS (App. 0:1-3; P-1,) BY ISSUING RULINGS WERE AN UNREASONABLE DETERMINATION OF THE FACTS IN LIGHT OF THE EVIDENCE PRESENTED?

6. WHETHER APPELLATE DIVISION'S OCT. 13, 2021 ORDER (App. P-2) DEPRIVED PETITIONER OF DUE PROCESS OF LAW GUARANTEED BY THE FIFTH AND FOURTEENTH AMENDMENT OF U.S. CONSTITUTION, BY FAILING TO REVERSE IT

Whether the petitioner was deprived of the right to a fair trial and present a complete defense