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It is not unlikely that the defendant was in a state of extreme stress, mental disorganization, and anxiety resulting from the shooting of [his] father so that the subsequent events resulting from amnesia would be in keeping with his disorganized mental state at the time.

During trial, Kling interviewed Bloom for a second time.

In September 1982, counsel moved the state trial court for the appointment of a psychiatrist to examine Bloom and a neurologist to conduct an electroencephalogram.Kling or to any other physician who examined Bloom. On one occasion, Melanie threw Bloom across the room when he was a baby. [Bloom, Sr.] would then pound [Bloom] with closed fists all over his back while screaming obscenities.The information discloses that Bloom suffered a long history of severe childhood abuse. Melanie also held a gun to Bloom's head for forty-five minutes because Bloom would not reveal the identity of “Tony,” Bloom's imaginary friend. At various other times [Bloom, Sr.] used a variety of different objects to beat [Bloom].One witness testified that approximately a week before the murders Bloom asked him if he could buy a gun because he was going to kill someone. Bloom then stood over him and shot him twice in the head. These wounds apparently were made by scissors which were located near her body. Bloom was arrested within an hour after the murders. Bloom initially pleaded not guilty to the three murders. The district court denied the petition, see Bloom v. Kling with necessary and available data which Kling requested and which would have assisted him in his evaluation of Bloom and in his trial testimony. At this time, California had abolished the diminished capacity defense. During the evidentiary hearing in the district court, she testified that counsel was “very rarely available” because “[h]e often would disappear for hours at a time, and he would go across the street and be at the bowling alley playing Pac-Man and we'd have to go get him.The witness agreed to obtain a gun for Bloom but never did so. Bloom appeared to reload the rifle before he reentered the house. Before trial, he changed his plea to the murder of Sandra to not guilty by reason of insanity. To prevail on this claim, Bloom first must establish that his “ ‘counsel's representation fell below an objective standard of reasonableness ․ considering all the circumstances ․ under prevailing professional norms.’ ” Harris v. And he really wasn't available to discuss matters with.” She testified everyone at the firm was “concerned about [counsel's] lack of preparation.”After drafting the appointment order, Drury left counsel's office to study for the Bar examination. On August 4, 1983, counsel asked her to contact Kling to ask him when he would have his report completed.

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