Emem Ufot Udoh v. Minnesota

QUESTION ONE: WHETHER THE LOWER COURT ERRED IN THE DENIAL OF APPELLANTS MOTION TO VACATE THE JUNE 15, 2018, NOVEMBER 29, 2018, AND FEBRUARY 05, 2019 POST-CONVICTION ORDERS IN DISTRICT COURT FILE NO. 27-CR-13-8979 AND TO OBTAIN THE AUDIO RECORDINGS WITH TRANSCRIPTS OF THE 867 PRISON CALLS FOR APPELLANT TO ADEQUATELY, EFFECTIVELY AND MEANINGFULLY PREPARE HIS PRINCIPAL BRIEF DUE BY MARCH 16, 2020 IN A19-1129 APPEAL? QUESTION TWO: WHETHER PETITIONER RECEIVED INEFFECTIVE ASSISTANCE OF APPELLATE COUNSEL FOR FAILURE TO EFFECTIVELY AND ADEQUATELY RAISE THE ISSUE ON WHETHER PETITIONER RECEIVED INEFFECTIVE ASSISTANCE OF TRIAL COUNSEL FOR FAILURE TO PROPERLY PRESERVE THE ISSUES IN: A. WHETHER DISTRICT COURT ERRED IN ADMITTING EVIDENCES THAT WERE IN VIOLATION OF APPELLANT’S DUE PROCESS CLAUSE UNDER THE FOURTEENTH AMENDMENT AND DENIED APPELLANT’S CONSTITUTIONAL RIGHT TO A FAIR TRIAL? B. WHETHER CUMULATIVE EFFECTS OF PROSECUTORIAL MISCONDUCT DENIED APPELLANT’S CONSTITUTIONAL AND SUBSTANTIAL RIGHT TO A FAIR TRIAL IN VIOLATION OF THE DUE PROCESS CLAUSE OF THE FIFTH AND FOURTEENTH AMENDMENT, AND EQUAL PROTECTION CLAUSE OF THE FOURTEENTH AMENDMENT? AT TRIAL UNDER STRICKLAND V. WASHINGTON DURING APPELLANT’S DIRECT APPEAL IN LIGHT OF STRICKLAND V. WASHING TON, 466 U.S. 668, 690 (1984); BRADY V. MARYLAND, 373 U.S. 83 (1963); MOONEY V. HOLOHAN, 294 U.S. 103 (1935); PYLE V. KANSAS, 317 U.S. 213 (1942); NAPUE V. ILLINOIS, 360 U.S. 264 (1959); GIGLIO V. UNITED STATES, 405 U.S. 150 (1972)? QUESTION THREE: WHETHER PETITIONER IS ENTITLED TO AN ACQUITTAL OR NEW TRIAL ON THE NEWLY DISCOVERED EXONERATING EVIDENCE SHOWING ACTUAL INNOCENCE BASED ON RECANTATIONS OF KEY MATERIAL WITNESSES’ TESTIMONY IN LIGHT OF LARRISON V. UNITED STATES, 24 F. 2D 82 (7th CIR. 1928) AND HERRERA V. COLLINS, 506 U.S. 390 (1993)? PETITION by Udoh - Page ii V- -N