(1) After a. criminal defendant's plea of guilty, if it is later
found that the government did not live up to the requirements
- of discovery, is the withholding of multiple recorded statements.,
which were ordered by a federal court to be produced for
inspection by the defense under Rule 16 of the Federal Rules
of Criminal Procedure, and the recordings are known to law
•• /
enforcement agents, a violation of Due''Process and a violation
i
under Brady v Maryland , 373 U.S. 83, 83 S.Ct. 1194 (1963)?

(2) Does a state (Texas) law enforcement agency have to comply*
with an order granted under Rule 16 of the Federal Rules of
when such agency is Criminal! Procedure by a federal court
in possession of recorded statements are covered by Rule 16
and the recorded statements have direct impact upon the case
and decision the defendant made to plead guilty?

(3) Is a civil litigant entitled to appointment of counsel, when
the litigant is not a trained attorney
access to any state laws, rules or procedures and can not
look up relevant case laws, nor afford to pay an attorney, to
properly present his case, and only has access to the federal
rules and procedures since he is an inmate in a federal
prison that is not required to supply any state resources
for this •purpose?and does not have any
laws
i

(4) Is John Alan Conroy entitled to at least an IN CAMERA review
of the reorded videos by the District Judge, as in the joined
case Conroy v Sloan, et al. , 2016-523428 (99th District Court,
Lubbock County, 2016), where the appellate court ordered a
writ of mandamus for the interrogation video of Petitioner,
John Alan Conroy, directed to the Texas Department of Public
Safety?

(5) Can an appellate court consider evidence contained on a
■}
floash drive that the Petitioner did not get to examine, nor
review, and of which was not entered into evidence nor the'
record, and was part of a private transaction between Pecos
County's attorney and'the Judge?

(6) Can a Judgment of Dismissed With Prejudice be proper when the
case is in pursuit of possible exculpatory or helpful
information, documentation, or materials that could be used
in a federal habeas at a later date, where the Dismissal
with Prejudice would forever bar the inmate from the evidence?

(7) Does the Michael Morton Act (2014), Section 2(k) apply in
this case with the continuing duty abligation of the state,
and does the Michael Morton Act override Texas Governmetn Code
§ 552.028 as Section (m) of the Michael Morton Act states?

(8) Is there a continuing duty of the Federal Government to hand
over newly discovered Brady materials to a person who pled
guilty, if that material would be beneficial to the defendant?

Whether the withholding of recorded statements by the government violates due process and Brady v. Maryland