Ineffective-assistance-of-counsel

No question identified. : , 1. Did Appellant receive ineffective assistance of counsel, in violation of her Sixth So, ; Amendment Right, beginning at the Bucks County PA Court of Common Pleas level? , . : | e No direct appeal was filed by Attorney Michael Kotik after her August 31, 2016 ; ; guilty plea hearing. Appellant had asked him to do so from the recorded phone . : . lines at Bucks County Correctional Facility. . , : -. OO . * Attorney Kotik coerced Appellant into taking an unknowing and involuntary oe . | a guilty plea. — oe ; | an So ° Kotik never discussed or showed evidence/discovery the Prosecution allegedly ' | 7 ~ had to use against Apellant. He stated he sent discovery to the Appellant at sce a ; | : ; Muncy, but never did. i ; © Kaotik told the court he was Russian speaking, but failed to translate information . | | ; . to the Appellant regarding pertinent issues in or out of court and could not read | : | . or write the Russian language. : oe : ; * After initally telling her she would receive house arrest, he informed her she : | , : would receive a 40 year sentence if she did not take the ple, creating fear in ) : | her and her : ; a | : © — Kotik failed to inform her of deportation consequences in connection with the | _ plea. ; . | ; i . * Kotik would not allow Appellant to testify on her own behalf, though she . : | insisted she wanted todo 20, Kotik forced her to read.a statement he saidhe . | “cowrote" with her, but that he had actually composed himself. . | © Attorney Kotik failed to impeach witnesses against the Appellant as to their oO Motives for testifying against her, some of whom were attempting to receive , 7 _-Feduced charges for their own separate criminal offenses. a Se | ; o Kotik failed to introduce any evidence to counter. the Prosecution to include oo . . ; phone records and bank statements that would prove Appellant's innocence. "© Kotik never objected to anything stated by the Prosecution, even when alleged ae __. prior bad acts of Appellant were introduced. _ . oe . oo 7 : ; . © Attorney Kotik, a schoolmate of Bucks County DA Jennifer Schorn, 7 : | complimented her on the good job.she and her witnesses were doing in court. . . ' © Kotik was paid $27,000 to represent the Appellant and failed to mount any-sort | : ‘ , of defense. 7 : | . : : ° Appellant was never informed by the Court or sdtcmey Kotik that she had 10 7 | : : ) days after sentencing to withdraw her guilty plea. . 7 . “Appellant was assigned several attorneys in her appellate phase, but they were OS | a changed or permitted to withdraw without an explanation to her. This was later _ : . | a ' ‘held against her in the appellate Process as Judge Wallace M. Bateman told her : that she "can't just go jumping from lawyer to lawyer", Appellant did not want to change attorneys and has letters to prove this. This caused any counsel's ; . 7 | communication with Appellant poor throughout the appellate process. : . | . 2 The District Attorney, Jennifer Schorn, introduced alleged information into the-trial = a court that contradicted statements in the police affidavits. she stated false eamings "from Appellant's businesses and spoke’of prior charges in another state. She stated that ne : : | Appellant held-her employees passports, which was untrue. No proof of this was ever ; offerred in spite of searches of all business and personal property of the Appellant and . — her family, oe oe 7 , . : 3. Were Appellant's rights violated as she was subject to arrest, interrogation, trial, and ; ; . : . sent to prison without benefit of a Russian translator ateverystep? . 4. Was Appellant unable to exhaust state remedies in her case due to prison COVID : : : . : ~ lockdowns and a lack of access to courts? a 3 . : ; 5. Was Appellant's Habeas filing effectively derailed as and ex-inmate, Mark Marvin, bis | i filed a Response to the District Court for the 3rd Circuit that was unsigned and did not : : ; : . : contain all the issues about which Appe