Whether the Trial Court and the Georgia Supreme Court abuse their discretion in failing to reach the merits of petitioner's out-of-time appeal and whether the Georgia Supreme Court abused its discretion in dismissing petitioner's out-of-time appeal as untimely when clearly the petitioner filed a timely notice of appeal.

Whether the Trial Court and the Georgia Supreme Court abuse their discretion in failing to conduct an evidentiary hearing as to who bore the responsibility for failure to file a timely appeal.

Whether petitioner's withdrawal of guilty plea hearing was unconstitutional where the Trial Court failed to inquire of the petitioner of the nature of the guilty plea, and failed to apprise him of the consequences of the guilty plea, and whether the Trial Court's error in failing to inform the petitioner of his right to directly appeal his withdrawn guilty plea violated petitioner's First Initial Review Collateral Proceeding.

Whether a withdrawn guilty plea guaranty as a criterion sine qua non of criminal procedure and the right to counsel attach to a de facto proceeding in First review Collateral proceeding.

Whether Georgia's Habeas Corpus Statute is unconstitutional barring petitioner of his constitutional rights to file an out-of-time appeal at a later date or a claim of ineffective assistance of counsel, because in petitioner's First Initial Review Collateral proceeding on his withdrawn guilty plea the petitioner did not have counsel and the Trial Court failed to inquire whether the petitioner waived his right to counsel, and the Trial Court failed to inform the petitioner of his right to appeal, and whether Georgia law passage of time does not prevent a defendant from filing an out-of-time appeal at a later date if the defendant's rights to appeal has been frustrated to no fault of his own, and whether Martinez v. Ryan, a party to Georgia's Habeas Corpus Statute as being unconstitutional, because the United States Supreme Court held where under state law ineffective assistance of trial counsel claim must be raised in an initial review collateral proceeding, a procedural default will not bar a federal habeas court from hearing those claims if in the initial review collateral procedure there was no counsel or in trial proceeding counsel was ineffective.

Whether the trial court and the Georgia Supreme Court abused their discretion by failing to reach the merits of petitioner's out-of-time appeal