1. Whether trial-counsel erred by not filing a motion to
quash the indictments, despite the overwhelming-evidence
that proves the investigating officers never obtained
search-warrants, and gave false-testimony to The Grand-
Jury?

2. Whether trial-counsel erred by not calling as a witness,
Sgt. Randy Young of The Strafford Police Department?

3. Whether collusion occurred during trial; based on the fact
that The State begged The Court in front of Defense-Counsel,
to exclude The State's Chief-Witness (Randolph H. Young) whom
built the entire case for The State: and prevent the wire-tap
recording from being admitted into evidence, that proves
attempted-extortion, criminal-threats, & warrantless-search by
The Strafford PiD.*. in-whieh may be a Plain-Error Standard?

4. Whether trial-counsel erred by not filing a motion for a sup
pression hearing or to dismiss all charges, prior to trial?

5. Whether trial-counsel erred by not filing a motion for a
probable-cause hearing, prior to trial?

6. Whether trial-counsel erred by not consulting with his client
prior to filing a motion for a 'Richard 's-Hearing' ; and after
The Court granted his motion, Robert J. Watkins failed to ask
The Court on the day of the hearing, to commence with Officer
Randy Young on the stand for questions about his illegal-acts?

7. Whether trial-counsel erred by excluding the Defendant
(Brim Bell) from the last two-days of trial?

8. Whether trial-counsel erred by failing to object, when
Judge Howard made bias remarks about the evidence? in the
presence of the jury, while Mr. Bell was left at the jail?

9. Whether trial-counsel erred, by not objecting, when Judge
Howard entered live-deliberations (alone) on several occas
ions, and allowed inadmissible-evidence to be admitted at
trial?

10. Whether trial-counsel erred by not challenging the admissi
bility of The State's Evidence, or failing to object when
The State knowingly elicited false-testimony during trial?

11. Whether appellate-counsel erred by not raising any of the
issues that his client demanded, repeatedly? LIST INCLUDES?
a) Ineffective Assistance of Trial-Counsel
b) Warrantless-Search by Strafford P.D. & Somersworth P.D..'
c) Prosecutorial-Misconduct & Malicious-Prosecution
d) Attempted-Extortion & Criminal-Threats by Sgt. Randy Young

12. Whether appellate-counsel erred by failing to withdraw from
this case? despite the numerous calls to his boss, demanding
the removal of Thomas A. Barnard, and Petitioner filed sev
eral motions to The Supreme Court of New Hampshire requesting
new-counsel, unaffiliated with the New Hampshire Public
Defender Program?

13. Whether appellate-counsel erred by using The State's
fictitous perjury charge against Brim Bell* as black
mail & used criminal-threats, to coerce Mr, Bell to DROP
his Direct-Appeal?

14. Whether appellate-counsel'-erred by"his failure td-raise
Ineffective

Whether trial-counsel erred by excluding the Defendant from the last two-days of trial?