- STATEMENT OF THE CASE
- STATEMENT OF THE FACTS
- ARGUMENT
- I.THE PROSECUTION HAS UNCONSTITUTIONALLY WITHHELD INFORMATION FROM THE DEFENDANT WHICH WOULD HAVE BEEN OF MATERIAL BENEFIT TO HIS DEFENSE.
- II.THE TRIAL COURT ERRED IN QUASHING DEFENDANT'S SUBPOENAS AND DENYING HIM ACCESS TO THE RECORDS OF THE NC VICTIMS' COMPENSATION PROGRAM
- III.THE TRIAL COURT ERRED IN NOT SEALING MATERIAL FOR APPELLATE REVIEW
- IV.THE TRIAL COURT ERRED IN RULING THAT THE DEFENDANT WAS NOT ENTITLED TO THE ACTUAL RECORDINGS OF INTERVIEWS WITH THE INVESTIGATION CHILDREN
- V.THE SUPPRESSION OF EXCULPATORY MATERIAL BY THE PROSECUTION DENIED DEFENDANT'S DUE PROCESS RIGHTS
- VI.THE TRIAL COURT ERRED IN DENYING DEFENDANT'S MOTION FOR PHYSICAL AND PSYCHOLOGICAL EXAMINATIONS OF THE PROSECUTING WITNESSES
- VII.THE TRIAL COURT ERRED IN ALLOWING SEVERAL STATE'S WITNESSES TO TESTIFY THAT THEY DIAGNOSED THE CHILDREN AS HAVING BEEN SEXUALLY ABUSED
- VIII.THE TRIAL COURT ERRED IN ADMITTING OPINION TESTIMONY FROM SEVERAL LAY WITNESSES
- IX.THE TRIAL COURT ERRED IN ALLOWING DEFENDANT'S FORMER ATTORNEY TESTIFY AGAINST HIM AND IN ADMITTING EVIDENCE OF THIS ATTORNEY-CLIENT RELATIONSHIP
- X.THE TRIAL COURT ERRED IN OVERRULING DEFENDANT'S OBJECTIONS TO THE TESTIMONY OF KELLI DE SANTE
- XI.THE TRIAL COURT ERRED IN DISQUALIFYING JURORS FOR CAUSE WHO WOULD TEND TO GIVE MORE WEIGHT TO AN ADULT'S TESTIMONY THAN TO A CHILD'S
- XII.THE TRIAL COURT ERRED IN EXCUSING JURORS FOR CAUSE ON THE GROUND OF ALLEGEDLY POOR READING ABILITY
- XIII.THE TRIAL COURT ERRED IN NOT INTERVENING EX MERO MOTU TO PREVENT THE STATE FROM MAKING SEVERAL GROSSLY IMPROPER ARGUMENTS
- XIV.THE TRIAL COURT ERRED IN SUBMITTING THREE CASES TO THE JURY THAT WERE DISMISSED AT THE CLOSE OF THE STATE'S EVIDENCE
- XV.THE TRIAL COURT ERRED IN NOT INSTRUCTING THE JURORS ON THEIR DUTY
- XVI.THE TRIAL COURT ERRED IN DENYING DEFENDANT'S MOTION FOR APPROPRIATE RELIEF AND MOTION TO RECUSE
- XVII.THE STATE'S RELIANCE ON INADMISSIBLE AND UNRELIABLE HEARSAY DENIED THE DEFENDANT'S CONSTITUTIONAL RIGHTS TO PRESENT A DEFENSE AND TO DUE PROCESS OF LAW
- XVIII.THE TRIAL COURT ERRED IN DENYING DEFENDANT'S MOTION TO DISMISS BECAUSE THE EVIDENCE GAVE RISE TO NO MORE THAN A SUSPICION OF DEFENDANT'S GUILT
- XIX.THE SENTENCES IN THIS CASE DENY THE DEFENDANT'S STATE AND FEDERAL CONSTITUTIONAL RIGHTS TO BE FREE FROM CRUEL OR UNUSUAL PUNISHMENTS
- XX.THE TRIAL COURT ERRED IN ENTERING JUDGMENTS FOR MULTIPLE CRIMES FOR EACH ALLEGED ACT BY THE DEFENDANT
- CONCLUSION
- CERTIFICATE OF SERVICE
- QUESTIONS PRESENTED