1. Did the State and the Federal Habeas courts' decision that ineffective assistance of trial and direct appeal counsel issues were defaulted because of an unartful couching of the claim as a Brady violation, conflict with this Court's precedents and other Circuit Court decisions that hold that pro-se litigants' petitions are to be liberally construed especially when as here, the last state court made a factual interpretation that the claim "was really" a claim against both counsels; and "sounds in ineffective assistance of counsel"?

2. Was trial counsel ineffective for failing to use available interrogation/polygraph transcripts during a suppression hearing that deprived the court of conclusive evidence that self-incriminating statements were involuntary due to law enforcement's overbearing, coercive tactics and lies over the course of nearly eight hours to compel the inculpatory statements?

3. Was direct appeal counsel ineffective for violating a rule of appellate procedure that waived an issue that the trial court comitted reversible error by disallowing trial counsel requested time to review critical suppression information handed over by the Commonwealth on the day of the pretrial hearing?

Did the State and the Federal Habeas courts' decision that ineffective-assistance-of-counsel issues were defaulted conflict with precedents