(1) There is no rebuttable presumption of prejudice for unpreserved unanimity instruction issues in a PCRA petition. The defendant bears the burden of satisfying the Strickland prejudice standard. 
(2) Geographical links in multi-count cases can alleviate prejudice from the lack of unanimity instruction because if the jury was unanimously persuaded that the conduct occurred at all of the locations they likely would have also agreed on the type of conduct that occurred at each location.