QUESTION#!:
Does the 11th Circuit decision conflicts with this Court's decision in Martinez v. Ryan . (2012),
since it ignores that in Martinez v. Ryan . 566 U.S. 1 (2012), the Court held: [t]hat where, under
state law, ineffective assistance of trial counsel claims 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 proceeding, counsel in that proceeding was ineffective
pursuant to Strickland v. Washington . 466 U.S. 668 (1984)?

QUESTION #2
Does the 11th Circuit procedural bar conflicts with this Court's decision in Cuvier v. Sullivan .
(1980), since it ignores that in Cuvier v. Sullivan . 446 U.S. 335 (1980), the Court established
that [t]o show ineffectiveness, a petitioner must demonstrate that his defense attorney had an
actual conflict of interest, and that this conflict adversely affected the attorney's performance?

QUESTION #3:
The 6th Amendment right guarantees conflict-free effective assistance of counsel and does not
afford the defendant the hybrid right to simultaneously represent himself and be represented by
counsel, while the Georgia Rule of Professional Conduct 1.7 prohibits a representation
involving a potential conflict of interest unless and until the attorney has disclosed the potential
conflict, in writing, to his client and thereafter received the client's written consent to undertake
or continue that representation. The question is:
When a defendant is represented by multiple circuit defender's and subsequently files a pro se
post-conviction collateral attack raising substantial ineffectiveness federal constitutional claims
for failure of a succession of attorney's from the same circuit defender's office to raise it; Should
the principles underlying this Rule be discounted in a criminal proceeding, where 6th
Amendment right to conflict-free effective assistance of counsel is involved?

QUESTION #4:
Does the constitutional protections of effective assistance of counsel on only appeal as of right in
Evitts v. Lucev . (1985) and Douglas v. California , (1963), extend to filing a timely Motion for
Reconsideration on only appeal of right?
If so, and appellate circuit defender does not withdraw in writing to allow petitioner to file a pro
se Motion for Reconsideration on direct appeal to resolve his constitutional questions, can such
noncompliance, if substantiated, procedurally bar a pro se habeas petitioner from having
substantial claim(s) heard by a federal court?

QUESTION #5:
The State elected to indict and try Petitioner on 3 Felony Murder counts and Vehicular Homicide
for the same victim. Georgia is a proximate cause state, and in virtually all of Georgia's many
homicide statutes, including vehicular homicide statutes, the General Assembly has employed the
same or very similar causation phrasing; The question is:
Does the 11th Circuit procedural bar conflicts with Jackson v. Virginia. 443 U.S. 307 (1979) .
since it ignores that in Jackson v. Virginia , this Court held: in a challenge to a state court
conviction under 28 U.S.C. § 2254, the applicant is entitled to habeas corpus relief..if it is foun

Does the 11th Circuit decision conflict with Martinez v. Ryan?