(1) Does the Due Process Clause of the Federal Constitution's Fourteenth Amendment entitle a convicted prisoner serving a 25-to-life sentence with additional consecutive sentences to (A) appointment of counsel on a Notice of Post Conviction Relief asserting a claim of newly discovered material evidence directly bearing on the credibility of a crucial state's witness who has been found to have lied under oath in multiple homicide cases, and/or (B) an opportunity to amend, if necessary, the Notice of Post Conviction Relief ("Notice of PCR"), when the prisoner has no reasonable means of further investigating on his own?

(2) Does the Due Process Clause of the Federal Constitution's Fourteenth Amendment prohibit a state from ignoring this Court's materiality standard and applying a preponderance of the evidence standard rather than the federal constitutional standard of a "reasonable probability which is less than a preponderance of the evidence? This Court held that a reasonable probability is "a probability sufficient to undermine confidence in the outcome" and is less than a preponderance of the evidence. Strickland v. Washington, 466 U.S. 668, 693-94 (1984); Kyles v. Whitley, 514 U.S. 419, 434 (1995).

Does the Due Process Clause entitle a convicted prisoner to appointment of counsel and opportunity to amend a notice of post-conviction relief asserting newly discovered evidence of witness credibility?