Whether a Kelly hearing was required to test the reliability of the process used to create the videotape of still photographs originally recorded on a single VHS tape

QUESTION(S) PRESENTED 1.) THE COURT ERRED, A kelly hearing was required to test the reliability of the process used to create the videotape. of still photographs originally recorded on a signle VHS tape. 7 : ; 2.) THE COURT ERRED, The Court erred in allowing’ Detective Doster testimony because doster had no or education in videographs or forensic videographs, no experience in calcolating the time between still _ photographs and no knowledge of. the camera system that had taken and recorded : the VHS tape. i . 3.) TRIAL COUNSEL WAS INEFFECTIVE ASSISTANCE OF COUNSEL: Here Counsel failed to object to Doster's estimate time, Counsel's failed ‘to call expert witness, present evidence deprived Cole of effective assistance of counsel, Cole was denied the rights guaranteed to him by the Sixth Amendment and by Article 15 ‘of the California Constitution.” , | ° II ; |