Is the undefined/ non-specific/ ambiguous language used in
Ohio's App.R.26(B) (2) .(c) that results in arbitrary/ incon sistent/ and discriminatory enforcement unconstitutionally
vague in violation of a defendant's right to Due Process
under the Fourteenth Amendment and effective assistance of
counsel as a first appeal of right as guaranteed by the1.
Sixth Amendment?

Does the persistent misrepresentation Of the facts/ actual
arguments presented/ and proper standard of review to be
used in a petitioner's actual innocence claim as a gateway
to defaulted claims violate their Due Prodess rights under
the Fourteenth Amendment?2.

Is the undefined, non-specific, ambiguous language used in Ohio's App-R.26(B)(2)(c) that results in arbitrary, inconsistent, and discriminatory enforcement unconstitutionally vague in violation of a defendant's right to Due Process under the Fourteenth Amendment and effective assistance of counsel as a first appeal of right as guaranteed by the Sixth Amendment?