TRIAL COUNSEL FAILED TO DO PRETRIAL DISCOVERY

Trial Counsel Robert Donatoni was completely ineffective for failing to do pretrial discovery. Commonwealth witnesses changed their testimony at the trial, and the prosecution made several crucial misstatements of evidence and introduced defective priors. Defense attorney Robert Donatoni would have been aware of this and should have acted, however he failed to do pretrial discovery. There is no way any reliable adjudication of guilt or innocence could have taken place. Trial Counsel Robert Donatoni's ineffective assistance of counsel rendered the whole truth determining process unreliable, and defendant Brandon Simmers was denied his due process rights.