I. WAS MR. HAMMONDS DENIED EFFECTIVE ASSISTANCE OF
COUNSEL GUARANTEED BY THE FEDERAL AND STATE
CONSTITUTIONS (U.S CONST. 1963, ART l § 20) WHERE TRIAL
COUNSEL FAILED TO CALL A WITNESS WHO WOULD HAVE
TESTIFIED THAT WHENEVER DEFENDANT SLEPT AT HER HOUSE
THAT THEY WENT TO BED TOGETHER AT THE SAME TIME AND
SLEPT TOGETHER ALL NIGHT. FURTHER SHE WOULD HAVE
TESTIFIED THAT THE COMPLAINING WITNESS WOULD FLIP FLOP
TO HER ON THE ISSUE AS TO WHETHER SHE HAD SEX WITH
DEFENDANT OR NOT?

II. DID THE TRIAL COURT ABUSE ITS DISCRETION WHEN IT
DENIED DEFENDANT MOTION FOR A NEW TRIAL BASED ON THE
PROSECUTION 'S MISCONDUCT OF SHIFTING THE BURDEN OF
PROOF TO DEFENDANT DURING CLOSING ARGUMENT?

DID THE TRIAL COURT ABUSE ITS DISCRETION WHEN IT DENIED
TRIAL COUNSEL 'S MOTION FOR A MISTRIAL WHERE THE
PROSECUTION REPEATEDLY VIOLATED THE TRIAL COURT 'S
ORDER THAT THE COMPLAINING WOULD NOT BE REFERRED TO
AS A "VICTIM " AND DEFENDANT 'S ABILITY TO GET A FAIR TRIAL
COULD NOT BE CURED BY A LIMITING INSTRUCTION?

III. DID THE TRIAL COURT 'S INTERJECTION THAT THE COMPLAINING
WITNESS STATEMENTS WERE NOT INCONSISTENT STATEMENTS
BUT RATHER "MISUNDERSTANDINGS " DEMONSTRATED THE
TRIAL COURT 'S PARTIALITY TOWARD THE PROSECUTION AND
IMPROPERLY INFLUENCED THE JURY BY CREATING THAT
APPEARANCE OF ADVOCACY AND PARTIALITY AGAINST MR.
HAMMONDS?

Ineffective-assistance-of-counsel