Whether reasonable jurists could argue that the State failed to meet its burden of proof beyond reasonable doubt

QUESTIONS PRESENTED 1. Whether reasonable jurists could argue that the State failed to meet its burden of proof beyond 2 reasonable doubt, every essential elem ent of the offense charged; 2. Whether reasonable jurists would find that Mr. Lemoine was denied effective assistance ef counsel, in violation of the Sixth and Fourteenth Amendments to the United States Constitution; 3. Whether reasonable jurists would debate that Mr. Lemoine was denied a fair and impartial trial with the submission of testimony from an “Expert” witness which failed to meet the Daubert standard, in violation of the Sixth and Fourteenth Amendments to the United States Constitution; 4. Whether reasonable jurists would find that the State improperly introduced the testimony of unsubstantiated, unfounded “expert” witnesses in order te overcome the factual insufficient evidence. 5. Whether reasonable jurists would find that Mr. Lemoine was denied a fair and impartial trial with the State's improper use of his statements which were made while intoxicated and could not be considered to be voluntary or knewing; Fifth, Sixth and Fourteenth Amendments to the United States Constitution; Beech er v, Alabama. | | | | | J. #596689\Lemaine Joseph ushabwrt.odt INTERESTED PARTIES District Attorney's Office 22™ Judicial District Court 701 N. Columbia St. Covington, LA 70433 Darrel Vannoy, Warden Louisiana State Penitentiary General Delivery Angola, LA 70712 J. #596689\Lemoine Joseph ushabwrtodt