Did the Ohio Sixth District Court of Appeals impose an improper standard for Brady claims by requiring proof of state possession of evidence and materiality?

This case poses a constitutional question of national importance. Did the Ohio Sixth District Court of Appeals impose an improper and unduly burdensome standard over Petitioner ’s “Brady ” claims and his ability to present evidence of such claims; more specifically: A. Whether the Ohio ’s Sixth District Appellate Court put an intolerable / undue burden of limitations that distorted and violated the original Brady analysis and the purposes behind the prosecutorial obligations enunciated in Brady (see Kyles v. Whitely, 514 U.S., 419, 437-; , Strickler v. Greene , 527 U.S. 263, syllabus, 280-282; Wearry v. Cain, 577 U.S. @ fn. 8; etc.), when it erroneously required this Petitioner to show that the state had possession of TLI/CSLI in order for it to be suppressed within the meaning of a Brady violation; plus, provide the actual physical evidence of TLI/CSLI without a proper review analysis of materiality —a “Trombetta ” effect where a letter from Verizon wireless warranted such? (This case stems from from the Sixth Appellate District Court ’s denial of Petitioner ’s Assignment of Error: “The trial court erred, abused its discretion, when it improperly applied res judicata / law of case (doctrine) without making the prerequisite findings of (Petitioner) being “unavoidably prevented ” to (Petitioner ’s) motion for leave to file a delayed motion for a new trial pursuant to Crim. R. 33(B).” )