1. Whether court-appointed, counsel rendered ineffective assistance under the
Sixth Amendment where counsel (a) sought to secure a guilty plea against
Petitioner 's interests; (b) refused to pursue discovery and to permit Petitioner
to review the Commonwealth 's evidence; (c) failed to participate in critical
pretrial proceedings, including the pretrial conference; (d) impeded
Petitioner 's attendance and participation at critical stages; (e) failed to seek
or obtain a pre-judgment judicial probable-cause determination before
Petitioner 's incarceration; (f) failed to cross-examine key witnesses; and (g)
failed to obtain and provide arrest or search warrants and supporting
affidavits.
2. Whether a criminal judgment entered before the trial court acquired subject
matter jurisdiction —because no pre-judgment judicial probable-cause
determination was made, is void ab initio and requires vacatur as a matter of
law, and If so, does this violate the Fourteenth Amendment to the U.S.
Constitution.
3. Whether confining Petitioner for nearly four years and compelling labor
without a valid conviction violates the Thirteenth Amendment 's prohibition
on involuntary servitude, which permits such servitude only as a punishment
for crime whereof the party shall have been duly convicted.
4. Whether a person can be guilty of a crime never established.
Whether court-appointed counsel rendered ineffective assistance under the Sixth Amendment and whether a criminal judgment entered without pre-judgment judicial probable-cause determination is void ab initio