IN COUNTS 2 TO 9, AND COMBINING COUNTS 2, 4, 8 IN THE JURY CHARGE RESULTED IN THE DEFENDANT NOT RECEIVING A FAIR TRIAL AND WERE ERRORS REQUIRING A REVERSAL OF THE DEFENDANT'S CONVICTIONS AND SENTENCES.
POINT 3 THE TRIAL COURT COMMITTED REVERSIBLE ERROR BY DENYING THE DEFENDANT HIS SIXTH AMENDMENT U.S.C.A. RIGHT TO CONFRONT, CROSS-EXAMINE AND EVALUATE COMPETENCY OF THE STATE'S PRIMARY WITNESS MS. MADELINE ROSADO, ON HER MENTAL HISTORY AND COMPETENCY TO TESTIFY, WHICH HAS UNQUESTIONABLE RELEVANCE TO HER CREDIBILITY AND HER ABILITY TO PERCEIVE, RECALL AND RESPOND TO EVENTS, FURTHERMORE, THE DEFENDANT WAS DENIED HIS SIXTH AMENDMENT U.S.C.A. RIGHT TO DISCOVERY OF MS. ROSADO'S MEDICAL-MENTAL RECORDS, AND DENIED HIS FOURTEENTH AMENDMENT U.S.C.A. RIGHT TO DUE PROCESS OF LIFE AND LIBERTY REQUIRING REVERSAL OF THE JUDGMENT OF CONVICTION AND SENTENCE.