Securities
Whether the Court erred in failing to sever the counts by date
QUESTIONS PRESENTED 1. Whether the Court erred in failing to sever the counts by date. 2. Whether the Court erred in requiring the Appellant to appear in shackles in front of the Jury. 3. Whether the trial should be remanded for a new trial due to ineffective assistance of counsel. 4, Whether the 18 USC 924 convictions should be overturned because: a. The firearms were not “used” in the commission of a drug offense. b. There was no proof of “intent to distribute” 5. Whether the convictions in counts 2-6 should be overturned due to the fact that there was no proof of “constructive possession” of the narcotics by Appellant. 6. Whether or not the Appellant’s Confrontation Clause rights were violated by the testimony of Officer Brea about what the informant told him. 7. Whether the Court erred in denying the Motion to Suppress of the Appellant regarding the traffic : stop of February 14, 2018. 8. Whether or not the Court Erred in failing to determine on the record if there would have been any delay in allowing the Standby Counsel to resume his role as counsel of record for the Appellant and if this should cause this cause to remanded for a new trial.