ISSUES RAISED BY DEFENDANT IN pro per ON DIRECT APPEAL ::

WHEN THE PROSECUTION IS HIGHLY FAMILIAR WITH AN EXPERT, WAS IT A
DRASTIC SANCTION FROM THE TRIAL COURT TO EXCLUDE THIS DEFENSE EXPERT
FOR A FAILURE TO TIMELY FILE THE EXPERT'S CURICULUM VITAE, AND DOES
THIS EXCLUSION DENY A DEFENDANT OF THE RIGHT TO PRESENT A MEANINGFUL
DEFENSE AS DEEPLY ROOTED IN THE COMPULSORY PROCESS OF THE SIXTH
AMSOMENT AND THE DUE PROCESS CLAUSE OF THE FOURTEENTH AMENDMENT?

I. WHEN THE EVIDENCE OFFERED AT TRIAL WAS LEGALLY INSUFFICIENT TO
ESTABLISH THE REQUIRED ELEMENTS OF PREMEDITATION, WAS THE DEFENDANT
DENIED HIS RIGHTS TO DUE PROCESS WHEN A JURY CONVICTED HIM OF SUCH?

II. WAS DEFENDANT DENIED OF HIS SIXTH AMENDMENT RIGHT TO THE EFFECTIVE
ASSISTANCE OF COUNSEL WHEN:

a. Counsel failed to comply with statutes regarding supplying a
Curriculum Vitae of his Expert Witness in a timely fashion??

b. Counsel failed to mount any formal investigation of
witnesses/exculpatory evidence that was presented to him' from
Family members of the Defendant which would have exposed the jury
to exculpatory evidence that would have compelled them to find a
NOT GUILTY verdict??

c. Counsel failed to invstigate or locate an additional expert
witness to explain Cyclic Vomiting Syndrome which required
Defendant to get in the shower immediately to prevent himself
from becoming deathly ill?;

d. Counsel failed investigate and present evidence of the victim's
violent character which would show deceased's probable aggression
towards the Defendant and would this have further supported
Defendant's Self-Defense theory/ resulting in a NOT GUILY
Verdict?

ISSUES RAISED 3Y APPELLATE ATTORNEY ON DIRECT APPEAL:

I. DID THE FAULTY JURY INSTRUCTION ON SELF-DEFENSE VIOLATE THE
DEFENDANT'S FIFTH AND FOURTEENTH AMENDMENT RIGHTS AND DID THIS AILING
INSTRUCTION INFECT THE ENTIRE TRIAL ENOUGH THAT THE RESULTING
CONVICTION. VIOLATE) DUE PROCESS?; and

a. Did this faulty instruction cause a plain error to occur?? and

b. Did trial counsel 's unawareness and ignorance of the self-
defense statute and jury instruction (and his failure to object)
create a quintessential example and unreasonable performance
under Strickland?; and

c. Was the Defendant's right to a properly instructed jury violated
by the giving of a legally incorrect instruction on a critical
issue (self-defense)?; and

d. Did this faulty instruction causa a miscarriage of justice?

II. WAS TRIAL COUNSEL CONSTITUTIONALLY INEFFECTIVE WHEN HE:

a. Failed to object to improper prosecutorial statements/ arguments
and grossly misstated evidence?; and

b. Failed to object to an improper jury instruction on self-
defense?; and

c. Failed to comply with discovery requests by not timely supplying
the curriculum vitae of a necessary defense expert even if the
prosecutor was highly familiar with this expert/ even using

When can a defense expert be excluded for failure to timely file curriculum vitae?