1. In determining whether a hearing related to equitable tolling is warranted, do the unsworn representations of an attorney —while that attorney is operating under a conflict of interest —conclusively rebut a petitioner's allegation that those same representations were dishonest ?

2. Is an evidentiary hearing related to equitable tolling appropriate when a habeas petitioner has made a showing that the petition's untimeliness is attributable to his attorney's false representations, lack of communication, and failure to follow the petitioner's explicit directives ?

Whether habeas counsel's unsworn representations can rebut a petitioner's allegation of dishonesty