1. In a challeng e under Ramos v. Louisiana 590 U.S. 83, 140 S. Ct. 1390, 206 L. Ed. 2d 583
(2020), where the record is silent as to the votes on the verdicts, how must the unanimity of the
verdict be proved to sustain the conviction? Is the lack of any evidence in the record as to unanimity
of the verdict an anomaly or departure that prohibits the presumption of regularity ? Does the State
have the burden of proving the verdicts were unanimous to sustain the convictions?

2. Where the uncontroverted defense evidence shows that the verdicts were not unanimous
and the per curiam acknowledg es that there was nothing in the record to show the verdicts were
unanimous, did the L ouisiana Court of Appeal and a majority of the L ouisiana Supreme Court err
in allowing Issa Lamizana's convictio ns to stand on less than a unanimous verdict, contrary to
Ramos v. Louisiana and in violation of due process of the F ifth and F ourteenth Amendments?

3. In a trial based solely on the words of the complainants, were the defendant's Six th and
Fourteenth Amendments rights to confrontation and to a defense violated when the trial court
prevented the child protection investig ator from testify ing, and prevented the defense from using
newly discovered agency records, to impeach and rebut the State's witnesses' testimony , contrary
to Davis v. Alaska, 415 U.S. 308, 94 S. Ct. 1105, 39 L. Ed. 2d 347 (1974)? Was the defendant denied
his right to a defense as held in Chambers v. Mississippi , 410 U.S. 284, 93 S.Ct. 1038, 35 L.Ed.2d
297 (1973); Crane v. Kentucky , 476 U.S. 683, 90 L. Ed. 2d 636, 106 S. Ct. 2142 (1986); and
Pennsylvania v. Ritchie , 480 U.S. 39 (1987)? Where the State's case was based solely on the veracity
of the claimants, was the ex clusion of impeachment, bias and motive evidence harmless?

Whether a non-unanimous verdict can be sustained under Ramos v. Louisiana when the record is silent on jury vote unanimity and what burden of proof applies