WHETHER CAPITAL DEFENSE TEAM FAILED TO PRESENT MITIGATING EVIDENCE REGARDING THE PETITIONER'S HISTORY OF MENTAL ILLNESS?

WHETHER THE NEW YORK STATE CONSTITUTION ARTICLE § 2 VIOLATED PETITIONER'S GUILTY PLEA THAT WAS IN WAIVES OF A JURY TRIAL IN WHICH THE CRIME CHARGED MAY BE PUNISHABLE BY DEATH?

WHETHER PETITIONER WAS DENIED THE EFFECTIVE ASSISTANCE OF COUNSEL WHEN ASSIGNED COUNSEL'S FAILURE TO PRESERVE THE WITHDRAWAL OF GUILTY PLEA WHEN PETITIONER WAS DENIED DUE PROCESS BECAUSE THE RE-SENTENCE VIOLATED PETITIONER'S STATUTORY RIGHT TO HAVE PETITIONER'S RE-SENTENCE TO BE PRONOUNCED WITHOUT UNREASONABLE DELAY?

WHETHER THE PEOPLE FAILED TO DISCLOSE EXCULPATORY MATERIAL?

Whether capital defense counsel's failure to present mitigating evidence of mental illness constitutes ineffective assistance of counsel and violates due process rights