1. Whether a defendant in a state criminal case who is prohibited by state law from raising on direct appeal any claim of ineffective assistance of trial counsel, but who has a state-law right to raise such claim in a first post-conviction proceeding, has a federal constitutional right to effective assistance of first post-conviction counsel specifically with respect to his claim?

2. Whether "new" evidence in relation to the actual innocence gateway for the purpose of due process in habeas cases is defined as [all reliable evidence that was not presented at trial, even if it would have been available through the excercise of due dilligence], OR is it [evidence that was discovered post-conviction and it could not have been discovered prior to trial through the excercise of due dilligence?

Whether a defendant has a federal constitutional right to effective assistance of first post-conviction counsel