Whether the Sixth Amendment right to effective assistance of counsel was violated by trial counsel's failure to investigate and present third-party culpability evidence in a capital murder case

No question identified. : Reasons for Extension The reasons for the requested 60 day extension to file Mr. Moore’s Petition for Writ of Certiorari are as follows. First, Mr. Moore is legally blind whereby he has substantial visual impairment requiring that the pleadings and legal research in his case must be read to him, generally in person, or that he must have unfettered access to the Computerized Document Reader available at the Arizona State Prison Complex Tucson Inmate Library, which access is first come, first serve, and is only available for limited times each week. Secondly, Petitioner Moore’s case presents significant and important federal constitutional issues arising from the following unique circumstances of his case which arguably resulted in his wrongful capital convictions and death penalty sentences. Since he was 18 years old, Defendant Julius Jarreau Moore has maintained that he is innocent of the Yale Crackhouse homicides that occurred on November 16, 1999 in Phoenix, Arizona, at which time the original suspect, Tony Lamont Brown, was seen by multiple witnesses to be either brandishing a firearm or running from the scene of the homicides immediately after the shooting. At trial, several witnesses stated that Defendant Julius Jarreau Moore closely resembled original suspect Brown, including the State’s only eyewitness, surviving victim Deborah Ford, who could not identify Defendant Moore as the perpetrator of the homicides on three (3) separate occasions including when shown a six pack lineup a few days after the shooting, viewing a video line-up within a few weeks of the shooting, and on the first day of trial when she questioned who Mr. Moore was prior to the commencement of the Moore guilt phase trial on “911”, the very day our country was under attack by terrorists who struck the Twin Towers in New York City. It is especially noteworthy that following Mr. Moore’s convictions he was offered a life sentence if would just admit to committing the offenses, yet, in good conscience he could not do so. Sadly, Mr. Moore became the victim of a number of alleged miscarriages of justice which ultimately led to his believed wrongful convictions in this case. At the time of his guilt phase trial, Petitioner Moore was battling the serious 2 medical condition Diabetic Ketoacidosis, which was alleged to the Post Conviction court to have been caused by the State failing to properly feed him throughout trial nor give him his prescribed insulin, and which combination caused him to be incompetent at the time of trial, being unable to understand the nature of his case, nor assist counsel in his defense. During the pretrial and guilt phase of trial, former trial counsel was admittedly gravely ineffective because he not only failed to properly investigate Mr. Moore’s case as required by longstanding United States Supreme Court authority in Strickland v. Washington (1984) as confirmed by this Court’s 2014 decision in Hinton v. Alabama related to the 3" Party culpability of Tony Brown and present this 3" Party Culpability Defense at trial, yet failed to call a single witness to testify at trial in Petitioner’s defense and essentially cross examining the State’s witnesses in order to frontload mitigation concerning Petitioner’s drug use contemporaneous to the homicides effectively admitting his guilt, with such blatant error by counsel rivaling that found by the United States Supreme Court’s more recent decision in McCoy vy. Louisiana in which former trial counsel admitted Defendant McCoy’s guilt waiving his right to the presumption of innocence without his client’s consent, leaving Mr. Moore in this case without any effective representation at a critical phase of trial in apparent violation of United States v. Cronic which found that the lack of legal representation at a critical phase of trial is per se ineffective assistance requiring a new trial. Petitioner Moore’s case was also plagued by alleged egregious State misconduct in