whether-under-brady-and-its-progeny-the-prosecution's-intentional-nondisclosure-of-petitioner's-requested-911-audio-recordings-requires-his-convictions-to-be-set-aside-or-a-remand-for-coa

question presented is: whether under Brady and its progeny, could reasonable jurist debate whether the prosecution team's intentdonal nondisclosure of Petitioner's requested 911 audio recordings requires that his convictions be set aside or that remand is necessary for the issuance of a COA. : QUESTION IT: : oo In Strickland v. Washington, this Court recognized the Sixth Amendment right to counsel exists and is needed in order to protect the fundamental right to a fair trial. 466 U.S. 668, 684 (1984). The question presented is: whether . . under Strickland and its progeny, could reasonable jurist debate if initially retained, pretrial counsel was ineffective for failing to use any legal means other than basic discovery to obtain Petitioner's 911 audio recordings that Petitioner made counsel aware of when he was retained, implored counsel to obtain said recordings and that were critical to his defense; and, if such ineffectiveness requires Petitioner's convictions to be set aside or a remand for a COA to issue QUESTION III: : , In Crawford v. Washington, this Court announced that where testimonial evidence is at issue, the Sixth Amendment demands unavailability, a prior opportunity for cross-examination, or plainly, confrontation of one's accusers. . 541 U.S. 36, 37-38 (2004). The question presented is: whether under Crawford and its progeny, could reasonable jurist debate whether the expert medical . examiner's hearsay testimony, from a Detroit Police Fatal Squad report that was-compiled from unnamed witnesses’ statements on the ultimate issue of intent, violated Petitioner's Sixth Amendment right to confrontation and if such violation requires Petitioner's convictions to .be set aside or a remand is necessary for a COA. : QUESTION IV: : : In Strickland 'v. Washington, this Court recognized the Sixth Amendment right to counsel exists and is needed in order to protect the fundamental right to a fair trial. 466 U.S. 668, 684 (1984). The question presented is: whether ; under Strickland and its progeny, could reasonable jurist debate whether trial counsel was constitutionally ineffective for failing to object and request a “curative instruction to the, obvious, highly prejudicial hearsay testimony of the expert medical examiner that came from a document prepared by the Detroit ' Police Fatal Squad, and: wasi compiled from unnamed witnesses statements; and, .. does such ineffectiveness: require Petitioner's convictions to be set aside or a remand is necessary for a COA. a ry o . QUESTION V: In Evitts v. Lucey, this Court announced that nominal representation on an appeal of right,. like nominal representation at trial, do not suffice to . render the proceedings constitutionally adequate. 469 U.S. 387, 396 (1985). The question presented is: whether under Evitts and its progeny, could reasonable jurist debate whether appellate counsel was constitutionally ineffective for failing to investigate and raise the above substantive constitutional violations in Petitioner's right to appeal and if such ineffectiveness consti: tutes cause and prejudice to excuse the procedural default of the above claims or a remand is necessary for the issuance of a COA. : : : iv : :