1. Whether the State's failure to disclose that its centerpiece witness was admitted to a psychiatric hospital prior to testifying, which was discovered years later in a discharge summary that the State now concedes was Brady material, and thereby precluded the defense from exploring impeachment material on the only witness that could testify about the defendant's criminal actions alleged as no forensic evidence existed, is a violation under Brady v. Maryland, 373 U.S. 83 (1963) as such psychiatric admission disclosure should be deemed absolute and material pursuant to Kyles v. Whitley, 514 U.S. 419 (1995) and thereby overcoming any procedural defect so as to assure a defendant receives due process.

2. Whether this Court should clarify the discrepancy that exists between the Second Circuit Court and Third Circuit Court regarding the Brady disclosure requirement by a state's prosecuting unit of their centerpiece witness's psychiatric records which could be used for impeachment purposes where said witness's testimony is the only evidence of the specific crimes charged.

Whether the State's failure to disclose a centerpiece witness's psychiatric hospital admission constitutes a Brady violation warranting relief under due process principles