Did Appellant receive ineffective assistance of counsel, in violation of her Sixth Amendment Right, beginning at the Bucks County PA Court of Common Pleas level?
• No direct appeal was filed by Attorney Michael Kotik after her August 31,2016 guilty plea hearing Appellant had asked him to do so from the recorded phone lines at Bucks County Correctional Facility.
• Attorney Kotik coerced Appellant into taking an unknowing and involuntary guilty plea.
• Kotik never discussed or showed evidence/discovery the Prosecution allegedly had to use against Apellant. He stated he sent discovery to the Appellant at SCI-Muncy, but never did.
• Kotik told the court he was Russian speaking, but failed to translate information to the Appellant regarding pertinent issues in or out of court and could not read or write the Russian language.
• After initally telling her she would receive house arrest, he informed her she would receive a 40 year sentence if she did not take the plea, creating fear in her and her husband/codefendant.
• Kotik failed to inform her of deportation consequences in connection with the plea.
• Kotik would not allow Appellant to testify on her own behalf, though she insisted she wanted to do so. Kotik forced her to read a statement he said he "cowrote" with her, but that he had actually composed himself.
• Attorney Kotik failed to impeach witnesses against the Appellant as to their motives for testifying against her, some of whom were attempting to receive reduced charges for their own separate criminal offenses.
• Kotik failed to introduce any evidence to counter the Prosecution to include phone records and bank statements that would prove Appellant's innocence. Kotik never objected to anything stated by the Prosecution, even when alleged prior bad acts of Appellant were introduced.
• Attorney Kotik, a schoolmate of Bucks County DA Jennifer Schorn, complimented her on the good job she and her witnesses were doing in court.
• Kotik was paid $27,000 to represent the Appellant and failed to mount any sort of defense.
• Appellant was never informed by the Court or Attorney Kotik that she had 10 days after sentencing to withdraw her guilty plea.
• Appellant was assigned severai attorneys in her appellate phase, but they were changed or permitted to withdraw without an explanation to her. This was later held against her in the appellate process as Judge Wallace M. Bateman told her that she "can't just go jumping from lawyer to lawyer". Appellant did not want to change attorneys and has letters to prove this. This caused any counsel's communication with Appellant poor throughout the appellate process.

2. The District Attorney, Jennifer Schom, introduced alleged information into the trial court that contradicted statements in the police affidavits. She stated false earnings from Appellant's businesses and spoke'of prior charges in another state. She stated that Appellant held her employees passports, which was untrue. No proof of this was ever offerred in spite of searches of all business and personal property of the Appellant and her family.

3. Were Appellant's rights violated as she was subject to arrest, interrogation, trial, and sent to prison without benefit of a Russian translator at every step?

4. Was Appellant unable to exhaust state remedies in her case due to prison COVID lockdowns and a lack of access to courts?

5. Was Appellant's Habeas filing effectively derailed as and ex-inmate, Mark Marvin, filed a Response to the District Court for the 3rd Circuit that was

Ineffective-assistance-of-counsel