Whether Florida Statute § 90.804(2)(f) violates the Sixth Amendment and Due Process rights of defendants, whether a state court can force a defendant to appeal and abandon their counsel, whether the state court made an unreasonable determination of the facts in the case

QUESTIONS PRESENTED ——— CAPITAL CASE —— 1. REQUEST TO CERTIFY CONSTITUTIONAL QUESTION IN ACCORDANCE WITH 28 U.S.C. § 2403(b): How is Florida Statute § 90.804(2)() (2012) “Hearsay Exception: Statement offered against a party that wrongfully caused the declarant’s unavailability” Constitutional when it completely removes a Defendant's Sixth Amendment right, as well as removes a Defendant's Fifth and Fourteenth Amendment tights to Due Process because no evidence need be presented by the State to support a claim to use this Statute; further, the Florida Supreme Court refused to adopt this Statute due to violating the Sixth Amendment specifically citing Crawford v. Washington, 541 U.S. 36, 124 S. Ct. 1354, 158 L. Ed. 2d 177 (2004), but then, paradoxically, reversed itself and adopted the Statute upon rehearing motion by the State? . 2. Can the State court force a defendant to appeal; force assigned counsel to abandon his client and become a thrall of the court; order counsel to purposefully | violate the state Bar rules; then refuse to allow/strike pro se filings by , unrepresented Appellant and make a “sham” of proceedings in Appellant’s name? 3. Can the State court “invent” a version of the facts of the case; violate a signed plea agreement by pretending it is not an agreement via an “unreasonable determination of the facts’; and to refuse to hear unrepresented Appellant’s brief, all in an effort to avoid a precedent setting issue while condemning Appellant to death without due process? 7 i TABLES OF CONTENTS PAGE(S)