Whether Contra.Costa County California's blanket policy of depriving a criminal defendant the facts and the evidence (exculpatory or otherwise), surrounding their arrest and incarceration is an unreasonable application of clearly established federal law — and if so whether the policy violates a defendant's right to counsel

QUESTIONS PRESENTED ‘2 Whether Contra.Costa County California’s blanket policy of depriving a criminal defendant, the facts 3 || and the evidence (exculpatory or otherwise), surrounding their arrest and incarceration is an unreasonable ‘ application of clearly established federal law — and if so whether the policy violates a defendant’s right to ° counsel. This is a policy that has been practiced and enforced by and/or, with the knowledge of the officers of the court, representing the Office of the District Attorney, Office of the Public Defenders & th 8 Superior Court. The policy is said to stem from an unspecified California Supreme Court ruling claiming 9 that it is unsafe for a criminal defendant to obtain facts or knowledge of his case exculpatory or otherwise. 10 . 11 Whether petitioner received the Ineffective Assistance of Counsel, when counsel refused to thoroughh 12 || investigate the existence of video evidence showing petitioner being beat without cause of justification by! 13 || Concord California police officers; refused to investigate incorrect preliminary transcripts that are missin: 14 vital testimony needed for impeachment purposes; ignored, refused to obtain, or was not aware of police 5 reports, showing that Petitioners either did not commit a crime, or it was impossible for the crime to have ‘6 been committed, and counsels flat out refusal to produce discovery, all the while giving Petitioner a . presumption of guilt, and recommending Petitioner sign the plea being offered. 19 20 Whether Petitioners plea-agreement was fulfilled. After Petitioner received an Order to Show Cause in| 21 |{ both State and Federal Courts, the district attorney and public defender involved in his case, went into 22 || court and had Petitioner resentenced for a fourth time, never matching the original plea agreement. 23 24 Whether Petitioner is a victim of Brady violations. District attorney Scott Cunnane, in this case was 25 present when alleged victim Betty Zierke admitted to being drunk while making her preliminary 26 testimony, and black out drunk on a regular basis. Zierkes admissions are not in the preliminary ” transcripts. Cunnane had stated that he would investigate Zierkes admissions through court recordings, 3 never doing so. Cunnane charged Petitioner with crimes regardless. i 1 LIST OF ALL PROCEEDINGS 5 . 3 United States District Court Northern District of California 4 Torres v. Hatton (Habeas), case # 17-cv-06607-PJH, denied on 3-8-19 5 6 3 Supreme Court of the State of California g Torres v. Kernan on Habeas Corpus, case # $259093, filed on 11-8-19, undecided 9 In re Mario Torres on Habeas Corpus, case # $246875, denied on 5-9-2018 10 || Torres v. Contra Costa County Superior Court, case #, transferred to appellate ct. on 6-9-17 11 ||In re Mario Torres on Habeas Corpus, case # $236859, ruled En Banc on 4-19-17 12 13 || California Court of Appeals i4 People v. Torres, case # A151181, dismissed on 6-8-17 8 In re Mario Torre, case # A150980, denied, 4-13-17 "6 In re Mario Torres, case # A148979, denied, 8-11-19 . Torres v. Contra Costa County, case # A148495, denied 6-9-16 . 19 In re Mario Torres, case # a146598, denied 10-29-15 20 21 || Superior Court of the State of California, County of Contra Costa 22 ||Inre Mario Torres on Habeas Corpus, case #05-190325-1, denied on 4-10-19 23 ||In re Mario Torres on Habeas Corpus, case # 5-181767-5, ruled moot on 10-31-18 24 11 In re Mario Torres on Habeas Corpus, case # 05-170756-1, denied on 6-1-17 25 In re Mario Torres on Habeas Corpus, case # 05-170047-7, denied on 2-7-17 26 In re Mario Torres on Habeas Corpus, case # 05-160428-9, denied on 5-20-16 *7 In re Mario Torres on Habeas Corpus, case # 05-152098-0, denied on 1-27-16 28 . Lt