I. Whether the Sixth Circuit Court of Appeals erred by expanding the type of
bank account that constitutes a client escrow/trust account contrary to state
statute and or the rules of the Kentucky Supreme Court in violation of
Petitioner 's Fifth Amendment Rights.

II. Whether there is a statutory violation and/or Sixth Amendment violation
when, after withdraw by a Criminal Justice Act appointed counsel, during a
defendant 's first appeal, a Circuit Court refuses to appoint new counsel in
disregard to a request for the same.

Whether the Sixth Circuit Court of Appeals improperly expanded the definition of a client escrow/trust account and violated the Petitioner's Fifth Amendment rights