of the events giving rise to the killing. Further, Appellee contends that his trial counsel was derelict in his failure to interview Hammer, which Appellee asserts would have revealed additional inconsistencies and yielded avenues for the impeachment of other witnesses. Appellee stresses that, at the post-conviction hearing, trial counsel could identify no strategic reason for failing to cross-examine Hammer with the inconsistent statements given to state troopers. See N.T., November 22, 2004, at 216. According to Appellee, if the jurors had heard these lies about the events which formed the foundation of the Commonwealth’s case, they would have had an insight into the self-interested motivation for his trial testimony. See Berryman v. Morton, 100 F.3d 1089, 1098-99 (3d Cir.1996) (<HOLDING>). While Appellee recognizes that trial counsel
holding that where trial counsel was not ineffective appellate counsel was not ineffective for failing to raise claim of ineffectiveness of trial counsel holding that counsel was ineffective for inter alia failing to impeach a witness with prior inconsistent statements holding in rule 3850 proceeding that trial counsel s failure to impeach witness with statements he made on night of murder was not reasonable under the circumstances holding that counsels failure to impeach a witness by showing bias was ineffective assistance holding that a witnesss prior inconsistent statement to an officer could be used to impeach her