I. WHETHER THE NATURAL LIFE SENTENCES IMPOSED ON ROBBERY FIREARM COUNTS 2-3 WERE ILLEGAL WHERE THE TRIAL COURT NEITHER ORDERED A MANDATORY PRESENTENCE INVESTIGATION REPORT, CONDUCTED A SENTENCING HEARING, OR PERMITTED PETITIONER TO ALLOCUTE?
II. WHETHER THE SENTENCES IMPOSED ON ROBBERY FIREARM COUNTS 2-3 WERE BASED UPON UNLAWFUL APPLICATION OF FLORIDA STATUTES SECTION 775.087?
III. WHETHER THE NATURAL LIFE SENTENCES IMPOSED ON ROBBERY FIREARM COUNTS 2-3, AS SECONDARY OFFENSES, WERE ILLEGAL SENTENCES IMPOSED, BECAUSE THEY EXCEEDED THE SENTENCE IMPOSED FOR THE PRIMARY OFFENSE, CAPITAL MURDER, FOR WHICH A SENTENCE OF LIFE WITH A 25 YEAR MINIMUM MANDATORY WAS IMPOSED, SUCH THAT THE ROBBERY COUNTS WERE LIMITED TO THE STATUTORY MAXIMUM OF 30 YEARS?
IV. WHETHER WILLIAM NEWKIRK'S RIGHTS UNDER ARTICLE 1, SECTION 9 OF THE FLORIDA CONSTITUTION AND THE 5TH AND 14TH AMENDMENTS TO THE UNITED STATES CONSTITUTION, SECTION 921.231(1) (1980), RULE 3.720(B), FLA.R.CRIM.P. (1980) WERE VIOLATED RESULTING IN THE IMPOSITION OF UNLAWFUL NATURAL LIFE SENTENCES IN VIOLATION OF HIS RIGHTS TO DUE PROCESS OF LAW AND A FAIR TRIAL?
Whether the natural life sentences imposed on robbery firearm counts were illegal due to lack of presentence investigation, sentencing hearing, and allocution rights