1) Whether Petitioner was denied his Fourteenth Amendment right to
the Due Process of Law when the Sixth Circuit Appellate Court denied
relief without having the Record on Appeal before it to review the
District Court 's clearly erroneous determinations for "clear error. "

2) Whether the Sixth Circuit Court of Appeals reached a decision that
was contrary to existing U.S. Supreme Court precedent, and directly
conflicted with findings of its sister circuits in similar cases on the
issue of "novel " state procedural default determinations, and the
relevant standard of review?

3) Whether Petitioner was denied his Fourteenth Amendment right to
the Due Process of Law, and the AEDPA sanctioned "one bite of the
apple " when the Sixth Circuit applied deference to a constitutional
claim supplanted by the state appeals court, who then adjudicated
their own supplanted claim rather than the actual claim properly
presented to them concerning the rejection of a plea-offer?

Whether Petitioner was denied his Fourteenth Amendment right to the Due Process of Law