Whether the District Court erred in denying petitioner's actual-innocence claim

question presented isywhether the District Court : | erred in denying petitioner's actual innocence claim. : QUESTIONS PRESENTED FOR REVIEW o , . (1) Does a defendant in a criminal proceeding have a ; . constitutional right pursuant to Section 10,Article I,of th Ohio/United States Constitutions Sixth and Fourteenth Amendments to have adequate notice of the true nature and | cause 0€ the accusation against him as to afford him an H Opportunity to defend the allegations made against him in a| criminal complaint pursuant to Crim.R.3,and Crim.R.5 (A)(1 at the initial stage of the proceeding. ; \ . Petitioner was not adequately notified of the true nature and cause of the accusation against him at the initial stage of the proceeding on August 30,2012, i 7 preventing him from having an opportunity to confront his | accuser (s) face-to-face under the Sixth and Fourteenth _ |Amendments to the United States Constitution. citing | CRAWFORD V.WASHINGTON,541 U.S.36,124 S.Ct.1354,158 L.Ed.2d | 177 (2004).See Transcript filed August 30,2013. | (2) After a defendant has been taken into custody,or | : deprived of his freedom of action in any significant way, does he have a constitutional right to be informed of his . Fifth,Sixth and Fourteenth Amendment rights,privilege against self-incrimination and right to retained or ; appointed counsel in the face of interrogation. (Tr .585-588) See,e.g.[1964] Crim.L.Rev.,at 166-170. (Tr.594). : The United States Supreme Court reversed the judgment of three cases,and affirmed the fourth. When an individual was. . taken into custody and subjected to questioning,the U.S. : Const.amend.V privilege against self-incrimination was { ; jeopardized. As in this Case, (Tr.561,575-578). ' The failure of defense counsel to object to the improper | introduction at trial of an alleged statement obtained jduring a brief interview by Detective John K.Hudelson,does jnot preclude consideration of the issue by the Supreme Court"Of the United States,and does not constitute a waiver of the claim,where the trial was held prior to a decision | of the Supreme Court establishing the pertinent rules for the first time. See (Doc#:15-1,at | The lower court applied precedent to petitioner's claims denying him of a fair adjudication on the merits. All . aspects of this case presents this court with both a [subetencdan constitutional question and a matter of general . and great public interset. | . QUESTIONS PRESENTED FOR REVIEW a ; (3) Does a defendant in a criminal proceeding have a " constitutional right to present a complete defense by presenting surrebuttal evidence. The trial court allowed the State to put on rebuttal evidence. However,petitioner was not permitted to defend those additional assertions by Detective John K.Hudelson, the State's witness. Detective John K.Hudelson presented a false statement in a document filed on August 29,2012, in which he claimed he advised me of my constitutional rights. See (Doc#:15-1,at 414). At trial Detective John K.Hudelson committed perjury