I. Whether Lower Court's denial of Motion for Reconsideration pursuant to Rule 60(b)(6) based on intervening law was an abuse of discretion that conflicts with decisions of U.S. Supreme Court and deprives Petitioner of constitutional right under 14th Amendment to due process of law.

II. Where State allows Petitioner Pro se. to raise IATC claim on direct appeal, where Constitutional right to counsel, fails to resolve issue, and provides no counsel at initial-review collateral creates a State created impediment that deprives of counsel assistance before the Courts in violation of due process of law under, U.S. Const, Amendment 6, 14. Crllch/ep v. Thu/er. 586 F.3d 318, (5th Cir. Oct. 21, 2009); So/thu v U,& 709 F.2d 160 (2" Cir. (N.Y) 1983)

III. Whether indigent forced to proceed Pro se on direct appeal with IATC claim (Patent on Face of Record), and court flails to appoint counsel at initial-review collateral on claim of IATC deprives of due process and equal protection of the law. U.S. Const., Amends 6, 14.

IV. This Court's Supervisory Authority needed to determine whether Lower Court's rccharactcuization of Pro se Rule 60(b)(6) motion to a habeas corpus without prior notice and opportunity to amend is an abuse of discretion denying Constitutional light to due process of law.

V. This case involves the important issue of whether when State fails to complete the court with the Six Amendment clause of appointment of counsel for indigent defendants. State creates an impediment constituting extraordinary circumstances sufficient to proceed under Rule 60(b)(6)?

VI. The Court's Supervisory Authority needed to answer important federal question whether a defendant preserves tight to counsel at initial-review collateral when he raised IATC claim on direct appeal that was unresolved? U.S. Const., Amend. l4

VII. This Courts Supervisory Authority needed to establish uniformity in Lower Court's application of § 2254 successive petition standard to a, Rule 60(b)(6) that challenges a prior habeas proceedings integrity because of a structural defect, subjecting Petitioner to denial of due process under, U.S. Const., Amend.'s 6, 14'

VIII. Movant's Substantial Showing Thal Counsel's Cumulative Errors Rendered Actual Objective Deficient Performance That Prejudiced Movant By Denial Of A Fair Thal, And There Is A Reasonable Probability But For Counsel's Deficient Performance The Results Of The Proceeding Would Have Been Different Martinez. suvra: St.rlcfrJand Y. Va&hlneton, 466 U.S. 688, 687, 104 S.Ct 2052, 2064.80 L.Ed.2d 674 (1984)

IX. Substantial showing of IATC under Martinez does not raise new claim as Lower Court's suggest, deprives of merits ruling in violation of due process of law under 101 Amendment.

X. Lower Courts denial of COA. WE with memorandum in support on IATC is an abuse of discretion that deprives Petitioner of due process of law under, U.S. Const, Amend.

Whether Lower Court's denial of Motion for Reconsideration pursuant to Rule 60(b)(6) based on intervening law was an abuse of discretion