1. The Trial Court's error in refusing to give the Virginia
Model Jury Instruction on Circumstantial Evidence
violated the Appellant's 6th and 14th Amendment
rights to a jury trial by failing to allow the Appellant
an opportunity to present a meaningful defense since
the jury instruction was a Model Jury Instruction
and was directly related to evidence and issues in the
case and was a proper statement of the law, and the
Virginia Court of Appeals and the Virginia Supreme
Court also erred by their holding regarding each point
that they cited in support of their decision to affirm
the Trial Court's decision and deny the giving of the
instruction.

Whether the trial court's refusal to give a Virginia Model Jury Instruction on Circumstantial Evidence violated the appellant's Sixth and Fourteenth Amendment rights to a fair jury trial