The appellate record needs to be examined because what is in the record already sets the stage for what can be done next. The answer to your question may take several hours of legal research.
And to decide what the next step will be needs to be really fast because the appeal deadline clock is running.
You might find helpful my Legal Guide Questions to Consider Before Bringing an Appeal
http://www.avvo.com/legal-guides/ugc/questions-to-consider-before-bringing-an-appeal
Because this matter is so important you should really get a lawyer.
You might find my Legal Guide helpful "How to Choose A Lawyer For You"
http://www.avvo.com/legal-guides/ugc/how-to-choose-a-lawyer-for-you
You might find my Legal Guide helpful " What Do I Tell My Lawyer"
http://www.avvo.com/legal-guides/ugc/what-do-i-tell-my-lawyer
No one can know what the record is in the case because online we cannot see your documents. You need a lawyer. Check with a lawyer in your locale to discuss more of the details.
Good luck to you.
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