WHETHER A (15) FIFTEEN YEAR PREARREST DELAY WHERE THE PROSECUTOR COULD NOT GIVE A SUFFICEINT REASON FOR THE DELAY TO JUSTIFY THE PREJUDICE TO THE PETITIONER WAS A DENIAL OF DUE PROCESS AND WAS THE PETITIONER EGREGIOUSLY DENIED EFFECTIVE ASSISTANCE OF TRIAL COUNSEL AND APPELLATE COUNSEL WHEN THEY FAILED TO ARGUE SUBSTANTIAL AND ACTUAL PREJUDICE AND CONCEDED THAT THE STATE DID NOT INTEND TO GAIN A TACTICAL ADVANTAGE BY THE DELAY. US CONST. AM V, VI, XIV: CONST. 1963 ART. 1 §§17, 20.

Whether the state court's denial of the defendant's motion to dismiss for pre-arrest delay violated the defendant's due process rights