Did trial counsel's failure to adequately consider mental-retardation-and-history-of-abuse deprive defendant of effective-assistance-of-counsel,right-to-jury-trial

QUESTION(S) PRESENTED I. DID TRIAL COUNSEL’S FAILURE TO ADEQUATELY CONSIDER MR. CARLYLE’S MENTAL RETARDATION AND HISTORY OF : ABUSE, AND OTHER VARIOUS ACTS, DEPRIVE DEFENDANT OF HIS SIXTH AND FOURTEENTH AMENDMENT RIGHTS TO THE EFFECTIVE ASSISTANCE OF COUNSEL IN MITIGATION OF MR. CARLYLE’S SENTENCE, PLEA AND DEFENDANT’S RIGHT TO A JURY TRIAL; DEPRIVE DEFENDANT OF HIS SIXTH AND FOURTEENTH AMENDMENT RIGHTS TO THE EFFECTIVE ASSISTANCE OF COUNSEL? Tl DID PRIOR APPELLATE COUNSEL’S CONSTITUTIONALLY INEFFECTIVE ASSISTANCE, TOGETHER WITH APPELLANT’S MENTAL RETARDATION, ESTABLISH “GOOD CAUSE” FOR APPELLANT’S FAILURE TO PROPERLY SUPPORT THE PLEA WITHDRAWAL ISSUE RAISED IN HIS PRIOR APPEAL, AS WELL AS ARGUE TRIAL COUNSEL’S CONSTITUTIONALLY INEFFECTIVE ASSISTANCE RAISED IN THIS MOTION FOR RELIEF FROM JUDGMENT?