DEATH-QUALIFICATION.
51. THE TRIAL COURT ERRED BY ITS ORDER THAT ANY RECORD OF A JUROR'S DEMEANOR BY COUNSEL MUST BE SUBMITTED TO THE COURT IN WRITING.
52. THE TRIAL COURT ERRED BY REFUSING TO EXCUSE FOR CAUSE PROSPECTIVE JURORS WHO KNEW THAT CHRIS RODRIGUEZ HAD BEEN CONVICTED FOR, AND/OR SENTENCED TO LIFE IN PRISON FOR, THE SAME CASE. THIS INCLUDED SEVERAL JURORS WHO ACTUALLY SAT AS JURORS ON THE CASE. THE COURT ALSO REFUSED TO INSTRUCT THOSE JURORS AND PROSPECTIVE JURORS NOT TO DIVULGE THAT INFORMATION TO OTHERS AND NOT TO CONSIDER THAT INFORMATION IN DECIDING THE CASE. MR. RODRIGUEZ WAS THEREBY DENIED A FAIR TRIAL BY IMPARTIAL JURY AND DUE PROCESS OF LAW.
53. THE TRIAL COURT'S FAILURE TO HAVE THE PROSPECTIVE JURORS TAKE THEIR OATH TO TELL THE TRUTH BEFORE THEY WERE GIVEN AND TOLD TO FILL OUT THE JURORS QUESTIONNAIRES, AND ITS COMPLETE FAILURE TO HAVE MANY PROSPECTIVE JURORS EVER TAKE THEIR OATH, VIOLATED THE CONTROLLING STATUTE AND RULE AND DENIED MR. RODRIGUEZ DUE PROCESS AND A FAIR TRIAL BY IMPARTIAL JURY.
54. THE TRIAL COURT'S FAILURE TO ORDER MANY OF THE PROSPECTIVE JURORS NOT TO BE EXPOSED TO, OR BE AFFECTED BY, ANY PUBLICITY IN THE CASE, NOT TO DISCUSS THE CASE THEY WERE INVOLVED IN WITH ANYONE ELSE, ON THE FIRST DAY OF TRIAL BEFORE THOSE PROSPECTIVE JURORS WENT HOME, VIOLATED THE CONTROLLING RULES AND DENIED MR. RODRIGUEZ DUE PROCESS OF LAW AND A FAIR TRIAL BY IMPARTIAL JURY.
55. THE TRIAL COURT'S FAILURE TO EXCUSE FOR CAUSE PROSPECTIVE JUROR [R.K.] BECAUSE, INTER ALIA, HE WAS AWARE OF THE ALLEGED CONFESSION OF MR. RODRIGUEZ, WAS ERROR AND DENIED MR. RODRIGUEZ A FAIR TRIAL BY AN IMPARTIAL JURY.
56. THE COURT'S REFUSAL TO ALLOW INDIVIDUAL SEQUESTERED VOIR DIRE ON DEATH PENALTY ISSUES DENIED MR. RODRIGUEZ DUE PROCESS AND A FAIR TRIAL BY IMPARTIAL JURY. THIS WAS PARTICULARLY SO IN LIGHT OF THE INADEQUATE AND UNREASONABLE TIME ALLOWED FOR DEFENSE COUNSEL'S VOIR DIRE ON THOSE ISSUES.
57. THE COURT'S REFUSAL TO VIDEOTAPE THE JURY SELECTION PROCESS DENIED MR. RODRIGUEZ HIS RIGHTS UNDER THE DUE PROCESS, RIGHT TO APPEAL, CRUEL AND UNUSUAL PUNISHMENT AND TRIAL BY JURY CLAUSES. MR. RODRIGUEZ WAS DEPRIVED OF AN OPPORTUNITY TO MAKE AN ADEQUATE RECORD ON THE DEMEANOR OF THE PROSPECTIVE JURORS, ESPECIALLY SINCE THE COURT PREVENTED HIM FROM MAKING A CONTEMPORANEOUS ORAL RECORD ON THAT MATTER.
58. THE GROUNDS AND ALLEGATIONS CONTAINED IN THE OBJECTIONS *310 AND OBSERVATIONS, MOTION TO QUASH JURY PANEL AND MOTION FOR ADDITIONAL SPECIFIED AND OTHER APPROPRIATE RELIEF, ENTITLE MR. RODRIGUEZ TO HAVE THE DEATH SENTENCE AND CONVICTIONS VACATED, AS DOES THE TRIAL COURT'S FAILURE TO ALLOW A HEARING AND THE COURT'S FAILURE TO GRANT RELIEF.
59. THE COURT'S REFUSAL TO ALLOW DEFENSE COUNSEL TO RE-OPEN VOIR DIRE OF THE PANEL OF PROSPECTIVE JURORS FIRST QUESTIONED BY MS. DESMOND WAS PREJUDICIAL ERROR SINCE THE ORIGINAL VOIR DIRE WAS INADEQUATE DUE TO THAT COUNSEL'S INEXPERIENCE AND MENTAL AND PHYSICAL STATE.
60. THE TRIAL COURT'S UNDISCLOSED COMMUNICATIONS WITH JURORS DURING