Whether the defendant was denied a fair trial due to improper other-acts evidence

QUESTIONS PRESENTED FOR REVIEW I. RIVERA WAS DENIED A FAIR TRIAL BY OTHER-ACTS EVIDENCE THAT HAD NO PROPER PURPOSE AND THUS ENCOURAGED THE JURY TO CONVICT HIM ON AN IMPROPER RATIONALE. ; I. THE TRIAL JUDGE COMMITTED PLAIN ERROR BY REQUIRING THE DEFENSE EXPERT TO PREPARE A REPORT AS A PRECONDITION TO TESTIFYING. IN THE ALTERNATIVE, TRIAL COUNSEL WAS INEFFECTIVE FOR NOT MAKING A TIMELY OBJECTION. I. APPELLANT WAS DENIED HIS FOURTEENTH AMENDMENT RIGHT TO DUE PROCESS OF LAW WHEN THERE WAS INSUFFICIENT EVIDENCE TO SUPPORT THE ESSENTIAL ELEMENTS OF SECOND-DEGREE MURDER BEYOND A REASONABLE DOUBT, AND THE TRIAL COURT ABUSED ITS DISCRETION BY NOT GRANTING APPELLANT’S MOTION FOR A DIRECTED VERDICT BASED ON THIS ISSUE. IV. DEFENSE COUNSEL WAS INEFFECTIVE FOR NOT WAITING UNTIL AFTER DR. HOROWITZ TESTIFIED BEFORE ASKING FOR THE DIRECTED VERDICT. i