15 Grounds on 9.141 – Too Many???

Help. Are these too many grounds and which ones are not worth pursuing? Charles thinks that we will lose our credibility with so many grounds, even if all if them are true.

Some say to leave them all in

I just do not know.

GROUND 1

Appellate Attorney was ineffective for not raising the flawed verdict forms on direct appeal

GROUND 2

Appellate counsel was ineffective for failing to raise that element (2a) of the attempted robbery with a firearm instruction was omitted from the jury instructions constituting fundamental error.

GROUND 3        

Appellate counsel was ineffective for failing to argue on direct appeal the trial court’s order denying trial counsel’s timely motion for a new trial. Additionally, appellate counsel was ineffective for not referencing the motion for a new trial in the direct appeal, especially since trial attorney argued about the same prosecutor’s improper closing arguments, used by appellate counsel 

GROUND 4

Appellate attorney was ineffective for failing to argue that the trial court erred by giving instructions relating to robbery and theft, effectively adding new charges after all the evidence had been presented to the jury, thereby denying the defendant the opportunity to defend against  crimes in which he had not been charged.

GROUND 5       

Appellate Counsel was ineffective for failing to raise that the State constructively amended the information at trial to allow petitioner to be convicted of attempted robbery with a firearm as opposed to attempted robbery with a firearm and mask (the primary charge) in order to allow the tainted identification of the petitioner to be allowed at trial.

GROUND 7

Appellate attorney was ineffective for not requesting a Richardson or evidentiary hearing when the victim went from someone unable to identify the suspect at all 0%to 100% able to identify the petitioner two and a half years later at trial. In the interim, appellate attorney was ineffective for failing to argue that trial counsel was ineffective for not motioning to suppress the 2nd photo lineup and in-court identification, as well as not requesting an evidentiary hearing, in light of the fact that was all trial counsel discussed in his closing argument.

GROUND 8

Appellate counsel fail to argue on direct appeal, that a Brady violation had been committed when the state did not disclose that the favorable phone records of the petitioner had been subpoenaed and that trial counsel was ineffective on the face of the record for not cross examining the detective about the phone results.

GROUND 9

Appellate counsel was ineffective for failing to argue on direct appeal that his judgment and sentences for one count of attempted robbery with a firearm and one count of aggravated assault with a firearm (on a single victim) constitute double jeopardy

GROUND 10

Petitioner claims that appellate counsel was ineffective for failing to argue that the trial court erred in conducting his trial before making a determination of competency after having entered a written order invoking the competency proceedings described in Florida Rule of Criminal Procedure 3.210.

GROUND 11

Appellate counsel was ineffective for failing to raise or discuss the trial court’s error on not responding to the trial attorney’s motion to continue. (TR 112).

GROUND 11

Petitioner contends that appellate counsel was ineffective for failing to argue that the trial court erred in denying trial attorney’s motion for judgment of acquittal as to Count 1 attempted robbery with a firearm and later to Count 2 aggravated assault with a firearm.

GROUND 12

Appellate attorney was ineffective for failing to argue that the petitioner’s statement became involuntary once the police made him a promise. 

GROUND 13

Appellate Counsel was ineffective on direct appeal for raising the questions asked by jurors during deliberation without putting in a claim or argument; for failing to raise that the trial court or trial attorney erred in not requesting a mistrial due to the abundance of questions and failed to raise that the trial court erred by suggesting that the jurors should take the video to the jury room. 

GROUND 14

Appellate failed to raise a meritorious issue when trial judge erred in overruling trial counsel’s objection to the detective questioning the detective about the bandana. 

GROUND 15

Appellate Counsel was ineffective for not raising that the numerous improper state closing arguments constituted ineffective assistance of trial counsel on the face of the record, in addition to not raising the many more improper closing argument made by state.

 

Justice for My Son 2

PO Box 70111

Tuscaloosa, Alabama 35407

Facebook pamelok@aol.com

Facebook – Under the Realm of the Wrongly Convicted Group –  Charles Ajoloko Is Innocent. Please like page.

Email – justiceformyson2@aol.com

Twitter – https://twitter.com/justiceforhim2

https://vine.co/Pamela.Ajoloko

Instagram – Pamela Ajoloko

 


Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out / Change )

Twitter picture

You are commenting using your Twitter account. Log Out / Change )

Facebook photo

You are commenting using your Facebook account. Log Out / Change )

Google+ photo

You are commenting using your Google+ account. Log Out / Change )

Connecting to %s