1) Did the Ninth Circuit Court of Appeals error, and/or so far depart from the Supreme
Court of the United States processes and precedents, by failing to issue a Certificated Of
Appealability for the significant and/or admitted Constitutional violations, as to call for a
Grant of Certiorari, Reversal of the denial, and Remand to the Ninth Circuit Court of
Appeals to hear an appeal?

2) Did the Idaho Federal District Court error by finding Habeas Claim l(a)(b) and (c),
were procedurally defaulted in State Court, for a lack of presentation, despite talismanic
Federal legal language including cases, quotes, Amendments, and Federal Precedents
being cited?

3) Did the Ninth Circuit Court of Appeals so far depart from the Supreme Court process
and precedents, by failing to issue a COA, for the 5th, and 14th, Amendment claims when
it is clear from the face of the record that the Federal District Court was unreasonably
incorrect, as to call for a GVR?

4) Did the Federal District Court error by attempting to delineate protected silence into
anything other than pre-Miranda, and post-Miranda silence?

5) Did the Federal District Court error by finding that when Neyhart stated: "silence
during and after both interviews," and then cited Doyle error, in his opening State
Appellate brief, that he really only intended to raise the State's use of his silence during
the two interviews?

6) Did the District Court error by failing to find Neyhart was silent as to certain topics
during and after the second interview, since nothing was asked, and nothing was stated
about those topics Neyhart had previously invoked upon?

7) If Neyhart's counsel failed, somehow, to present so plain a Constitutional violation as
using protected silence, despite his best efforts to do so, did the Idaho Federal District
Court error by failing to find excuse by cause and prejudice under Martinez v. Ryan 566
U.S. 9, 10, 14, (2012), since such a failure would have clearly equated ineffective
assistance of counsel?

8) Did the Idaho Federal District Court error by failing to grant relief on any part of
habeas claim one?

9) Did the Idaho Federal District Court error by failing to find that by asking the Idaho
Supreme Court to review all issues raised on appeal, all issues had been brought to the
attention of the Idaho Supreme Court by Idaho Supreme Court rule 18?

10) Did the Idaho Federal District Court error by failing to find that the Prosecutor's
declarations, vouching, and misstatement of fact, during cross-examination of the
testifying defendant were testimony, since the document was worthless absent the
Prosecutor's false declarations?

11) Did the Federal District Court error by applying an unreasonable standard of review
to prosecutor misconduct, by misrepresenting facts, or lying, and failing to correct the
false impression of the facts when she clearly came to know of the falsity, in order to
falsely impeach the testifying defendant?

12) Did the Federal District Court err by unreasonably applying the harmless standard of
review, because the Court ignored the effect of falsely impeaching a testifying defendant
on all the testimony and evidence presented by defense, finding instead that there was
"plenty of other evidence," presented by the State?

13) Can falsely impeaching a testifying defendant ever be harmless, since it is likely that
any jury would apply common

Whether the Ninth Circuit and Idaho Federal District Court erred in procedurally defaulting habeas claims and denying a Certificate of Appealability for alleged constitutional violations