1. Does a failure by trial counsel to investigate known-to-be material facts and/or witnesses constitute federally defined ineffective assistance of counsel? If yes, in defense of such habeas claims, does the submission of a false affidavit constitute a fraud upon the state court? If yes, is such a submission an admission by conduct? And if so, has any federally protected due process right been violated?

2. Did the federal courts abuse their discretion in failing to exercise their vast equitable powers in not granting relief where its plain on its face that Relator's habeas judgment was obtained by fraud which in turn amounts to an admission by conduct to the claimed IAC?

3. Based on the facts and circumstances described, would the average reasonable-minded citizen on the outside looking in see a corruption in the truth-seeking process?

Does a failure by trial counsel to investigate known-to-be material facts and/or witnesses constitute federally defined ineffective assistance of counsel?