Did the Trial Court error in denying petitioner's motions for Discovery violations under BRADY v. MARYLAND and for refusal to enforce petitioner's court ordered subpoena for petitioner's jail recorded phone calls?

QUESTIONS PRESENTED , . . . I , Did the Trial Court error in denying petitioner's : motions for Discovery violations under BRADY v. MARYLAND and ‘ for refusal to enforce petitioner's court ordered subpoena for petitioner's jail recorded phone calls? : Where evidence that was requested and subpoenaed . "petitioner's jail recorded phone calls" were withheld from. petitioner's court ordered psychologist Tiffany K. Smith. Where the psychologist requested access to : petitioner's jail recorded phone calls and stated that they . would be necessary and helpful in determining petitioner's competence and mental health diagnosis. a . This evidence was BRADY material because the doctor . said she needed it to determine petitioner's competence and a . ° mental health diagnosis. Petitioner's competence and mental health condition directly relates to guilt, innocence and punishment. How could the psychologist's diagnosis be deemed reliable when they were denied access to evidence that they said they needed for petitioner's mental health evaluation? : Were petitioner's jail phone calls exculpatory when , they would have been used to establish petitioner's self , defense and necessity defense claims, and would have been used to impeach petitioner's mother and father's trial testimony, . sey itl in which they testified that they were not cooperating for the government and that they were not involved in several attempts to murder petitioner for a major Mexican drug cartel. And where the government argued that petitioner was : making his necessity claims up and that petitioner was a liar : oo and could not be trusted. : ; Where petitioner made a sworn declaration as to the jail recorded phone conversations and their content and exculpatory value and stated to the court that these jail . phone calls show over a year's period worth of conversations where petitioner's mother and father admit that they are cooperating for the government and show over a year's period : ‘ of conversations that discuss the murder contract that is out . on petitioner's life by the Cartel which also involved the ‘ . Hell's Angels, the Surrances 13, the Native Mob, the Crips and * ; Vice Lords. : ; : The recording discussed the people involved and show that petitioner's mother and father made prior statements that would have established petitioner's necessity defense. : Where petitioner attempted to prove to the jury that he possessed these guns and bulletproof vests to protect ; himself from being murdered. And that this was reasonably , necessary because of the major organized crime groups involved. ; ‘ . IV And because petitioner could not go to the police, because these people threatened to murder petitioner's family and because they have police who work for them, making : : petitioner unable to trust the police. , . Answer of the court below was that petitioner failed . . to establish a violation of BRADY v. MARYLAND, 373 U.S. 83 (1963). . : ; Il 7 : Did the Trial Court abuse it's discretion in : determining that petitioner was competent to stand trial. Where petitioner was diagnosed as having Delusional . Disorder and displayed distrust in his own attorney, rendering , petitioner unable to assist in his own defense. . 7 Where petitioner believed his own attorneys were : ‘ involved in a conspiracy against him to assist the government in covering up that petitioner's family is cooperating for the government and that petitioner's family was involved with the Cartel, Hell's Angels, Surranoes 13, The Native Mob,. the Crips : and Vice Lords in trying to murder petitioner. ; , Where the attorney stated to the court that he did not | oo have the trust of petitioner, that petitioner left him several voice messages everyday, telling the attorney different directions in which way to go with the case and defense. , Where petitioner actually withdrew his mental health . q . defense against his attorney's advice, which was a legitimate defense the petitioner had in which petit