When the defense attorney previously represented the state's key witness who now has conflicting interests with the defendant, does this amount to a conflict of interest?

QUESTIONS PRESENTED A) When the defense attorney previously represented the states key witness who now has conflicting interests with the defendant, does this amount to a conflict of interest? See State v. Alexis, 180 So. 3d 929; Hope v. State, 654 So. 2d 639, 640 (Fla. 4" DCA 1995) B) When an attorney represents the states prime witness in a previous case, is a ; colloquy required to determine if an actual conflict of interest exist? See Lee v. State, 690 So. 2d 664 (Fla. 1 DCA 1997), Rutledge v. State, 150 So. 3d 830, 838 : (Fla. 4" DCA) rev. denied, 171 So. 3d 120 (Fla. 2015) C) When a conflict of interest that adversely affects counsel’s performance, (Counsel could not properly cross examine witness and left that duty to his father and Co-Counsel). Is this a violation of the Sixth Amendment? D) Is it the trial court’s or the defense attorney’s duty to ferret out the facts underlying a potential conflict of interest? See Rutledge v. State, 150 So. 3d 830, 838 (Fla. 4% DCA 2014) rev. denied, 171 So. 3d 120 (Fla. 2015) E) Does the trial court have the judicial authority to avoid the necessity of conducting a waiver colloquy by ignoring a potential conflict of interest brought to , its attention? See Rutledge v. State, 150 So. 3d 830, 838 (Fla. 4 DCA) rev. denied, | 171 So. 3d 120 (Fla. 2015) Larzelere v. State, 676 So. 2d 394, 403(Fla. 1996) cert. denied, 117 S.Ct. 615 (1996) ii yO! E 2) When the defense counsel labor under an actual conflict of interest that is not waived, does the de novo standard of review apply? See Alexis v. State, 180 So. 3d at 934 F) Fla. R. Crim. P. 3.575 when a party who has reason to believe that the verdict may be subject to legal challenge may move the Court for an order permitting an ~ interview of a juror or jurors to so determine. Does the abuse of discretion standard apply to trial Court’s ruling denying a motion to interview a juror? a ae G) When the good character of a witness is supported when said witness has not been impeached by evidence, Is this a per se reversible error? See Whitted v. State, 362 So. 2d 668, 673 (Fla. 1978), Mohorn v. State, 462 So. 2d 81, 82 (Fla. 4* DCA . 1985) H) Is the impropriety of a key witness’s testimony that he had not been previously arrested a violation of the Due Process Clause of the Fourteenth Amendment to the United States Constitution which guarantees the accused the right to a fair trial? I) When one witness is allowed to opine on the veracity of another witness and this has been prohibited, has an error occurred? See Acosta v. State, 798 So. 2d 809, 810 (Fla. 4thDCA 2001), Tumblin v. State, 29 So. 3d 1093, 1101-1102 (Fla. 2010) Solomon v. State, 267 So. 3d 25, 32 (Fla. 4" DCA 2019) J) Due to the great weight afforded to a Police Officer’s testimony. Isitaperse . reversible error for a Police Officer to testify to the truthfulness of the State’s key | iii Pog witness? See Tumblin v. State, 29 So. 3d 1093, 1101-1102 (Fla. 2010) Solomon v. State, 267 So. 3d 25, 32 (Fla. 4° DCA 2019) iv