Whether trial counsel was ineffective for failing to object on Double Jeopardy grounds to nine identical carbon copy indictments

QUESTION PRESENTED Dodd was indicted on nine counts for the sexual abuse of a child more than fifteen years ago. Each count of the indictment was an identical carbon copy, including that each alleged that the crime happened over an identical time span. The evidence did not prove nine specific instances of abuse but gave general allegations. Dodd had a strong defense that the crime could not have happened during the first four years of the allegations. The question presented is whether trial counsel is ineffective where he failed to object on Double Jeopardy grounds to these nine identical carbon copy indictments? 1 LIST OF ALL PROCEEDINGS Commonwealth v. Dodd, No. CR13801133-01 through 09, Chesterfield Circuit Court. Judgment entered April 7, 2015 (trial). Commonwealth v. Dodd, No. 10438-15-2, Virginia Court of Appeals. Judgment entered July 5, 2016 (direct appeal). Commonwealth v. Dodd, No. 161146, Supreme Court of Virginia. Judgment entered January 30, 2017 (direct appeal). Dodd v. Director, No. CL18HC-930, Chesterfield Circuit Court. Judgment entered October 21, 2019 (state habeas). Dodd v. Director, No. 200091, Supreme Court of Virginia. Judgment entered February 4, 2021 (habeas appeal). 2