1. a) Is it sufficient reason for failing to raise new issues in a postconviction
motion after first appeal that were not already litigated - that the new issues
could have been litigated in the first appeal if not for the complete absence of
legal assistance by court-appointed postconviction counsel? b) Is it sufficient
reason also that a legal authority supporting the new issue (of the Rule of
Completeness applying to something intended to be made viewable from code
in electronically stored information) was not accessible by a prisoner. (The
legal authority was the Sedona Conference Committee findings intended for
attorneys and Judges.)

2. In postconviction, does it matter that a defendant is not informed by
appellate counsel about the no merit report option and dangers of self
representation verbally ?

3. Is data that is contained within electronically stored information that can be
readily compiled into viewable information, whether presented on the screen
or printed on paper, also a "document " under Rule 34?

4. If electronically stored information is considered on an equal footing with a
"document ", does the Rule of Completeness apply to electronically stored
information?

5. In the case of legal representation of an indigent defendant on first appeal in
a state procedure, is it ineffective assistance of counsel when the attorney
never speaks with nor communicates in any other way with the defendant,
where the only assistance to the defendant is from inexperienced law
students?

Is it sufficient reason for failing to raise new issues in a postconviction motion after first appeal that were not already litigated