1. Under the Jackson standard and per Garrett v. U.S. 471 U.S. 779,1791, is this conviction of
Texas Penalty code §19.03 (a) (2) capital murder a "Void Conviction " because it is
impossible to intentionally commit a (completed) murder "in the course of' committing or
attempting to commit the predicate felony if the death did not "ensue " until nearly 30 years
later and there is no evidence to prove so?

2. Did the trial counsel 's failure at trial to subject any of the prosecution 's witnesses to cross
examination or present any defensive evidence amounted to denial of counsel and
"structural error " under U.S. v. Chronic and Bell v. Cone?

3. Did the state courts adjudicated and reviewed the case with a lack of impartiality based
a presumption of guilt standard which conflicted with the due process requirements of
Jackson standard and constituted a "structural error" ?on

4. Did the prosecution of the case as a 30-year delayed death capital murder despite time bar
violate the protections of statute of limitations, due process, and ex post facto rights
enunciated in Stogner v. California and Rogers v. Tennessee?

5. Did the retrospective application of the novel construction of the capital murder charge
with the novel definition of delayed death homicide in the case violate the fair warning and
ex post facto principles of due process enunciated in Rogers v. Tennessee, and is the
continued use of the novel definition of delayed death homicide with post-acute-
hospitalization sequential causation plausible and reasonable?

6. In the context of Texas Penal Code §6.04 (a) and after the abrogation of the "year-and-a-
day" rule in Rogers v. Tennessee, what criteria would justify prosecution of a death after a
remote injury as a delayed death homocide and prevent abusive use of such charge, as in
this case and potentially against athletes in CTE (chronic traumatic encephalopathy) and
other chronic encephalopathy cases?

7. As under Texas law, expired limitation is a complete defense equivalent to constructive
amnesty, and extension of expired limitations is invalid under Stogner v. California, should
Blockburg 's "sameness " test be applicable in determining if a time-barred case can be
validly prosecuted under a different charge such as in this case?

8. Should common law doctrines of attenuation and laches have precluded the prosecution of
this assaultive case decades later as a homocide, and was the retrospective judicial
abridgment of those right a violation of the fair warning, and ex-post facto principles
enunciated in Rogers v. Tennessee?

9. Did the state courts violate due process 's fair warning and ex post facto principles of
Rogers v. Tennessee by retrospectively changing the rule of evidence for admission of Rule
404 (b) (2) evidence to allow the state to introduce the extransic testimonies of F.M. and
K.A.B. against statutory and case law requirements?

10. Did the retrospective judicial abrogation of the common law doctrine of reasonable-
hypotheses-of-innocence analytical construct violate fair warning and ex post facto
principles of Rogers v. Tenseness, and should the reviewing court in the case have found
acquittal base

Question not identified