No. 1
Randall Scott Jordan/petitioner/ contends that external impediments,(State's w
witness,(Galvan) extensive violent criminal history and gang affiliation) ,hindered
trial consel from being prope*rly prepared to impeach state's witness' credibility
resulting in ineffective assistance of counsel, thereby denying petitioner a complete
defense guaranteed by the 6th and 14th Amendment to the United States Constitution.
Evidence of state's witness Galvan's extensive violent criminal record would have
revealed to the jurors the following:
1. Confirmation of state witness' criminal history, information that
was favorable to defense for impeachment purposes to credibility,
see; exhibits attached.
2. Furtherjdenied information would have supported petitioner's defensive
theory,or mental culpability,(mens rea),(motive) to state's
-.llalleged offense against accused.
Thei.State created external impediments to discovery evidence, impeded
counsel's defense to present objective factors to petitioner's defense, failure to
review and consider claims of violation to accused 6th and 14th Amendment rights,
would result in a fundamental miscarriage of justice.
Did the prosecution's suppresion or withholding of state's key witness' prior
violent criminal history that was favorable to accused for impeachment purposes ,
violate defendant's due process to the 14th Amendment under Brady??...
Withheld evidence of state's witness' criminal history, for impeachment purposes
was favorable to defense because it could have been used to impeach witness to
jurors and proven the facts of witness' gang affiliation, and prior offenses
of moral turpitude.

No. 2
Petitioner contends that trial court erred by relying on an incomplete evidentiary
record, at pre-trial hearing to reflect defendants claim that State's failure to
disclose and preserve cell phone recordings from his cell records and complaintant's
cell records which were confiscated by police.
This constituted a denial of due process because the evidentiary record was too meager
to render a proper ruling on due process.
MS Further, the trial court erred in freely admitting evidence alleged by the State
prosecution concerning witness testimony to the charges against accused, because
the Court's ruling rested on unsubstantiated premises, and the Court's error
was not harmless.
There is a significant likelihood that the jury was inflamed to convict defendant
upon only the state's version of the case, therefore denying defendant his right
to present his defense in the case before the jury.
Did the trial court err, when it relied solely on the prosecution's word.to evidence
that was recorded on defendants cell phone and complaintant's cell phone, without
actual investigation to the exact contents of information actually recorded, which
petitioner identifies as exculpatory and material to his defense.
Prosecution only claims that content of recordings aresmerelysexual related
between accused and complaimtant, and stated to court that she did not want to
listen, prosecution avoided telling the court of many other conversations within
cell records with various witnesses including accused alibi witness which if
revealed to jurors, subjects state's case to vulnerability and jeapordizes conviction.
see; ground two, attached

No. 3
Petitioner contends that his trial counsel's prior representation of this casejs
state's key witness against accused, violates his 6th Amemdment

Did the prosecution's suppression or withholding of state's key witness' prior violent criminal history that was favorable to accused for impeachment purposes, violate defendant's due process to the 14th Amendment under Brady?