< 78. | Alexandria | 80. >
the Court was reversal on the issue of guilt. And that has never really been the standard.
I would suggest to you, Your Honor, that in the course of our argument last week, Your Honor acknowledged that if the Court of Appeals felt that the voir dire in this case were not sufficient that that would indeed result in a reversal and a retrial. And I only remind Your Honor of that statement because of the nature of the issue. But that was something that was discussed last week, and it would be.one of the issues that we clearly intend to raise. I don't wish to belabor the point, but I wish to have the motion before the Court so if it is necessary for me to appeal this, I will.
I would also suggest to you that if there were ever a candidate who was available for voluntary surrender in any case I would suggest to you that there shouldn't be any question of whether or not Dennis Small would show up for voluntary surrender to this Court. He has been out all this time.
There really isn't any reason that he not be allowed to voluntarily surrender, and I suggest that you impose it.
I would also suggest that a B-2 is appropriate under 4205 in this case, and most assuredly I would suggest to you that level one in a level one institution is appropriate.
MR. ROBINSON: Your Honor, I don't think we attempted to question during the course of this case, and I don't think we attempt to question now the sincerity of