1. Whether the combined effect of (a) appointed appellate counsel's abandonment and refusal to provide
the case file and (b) the court of appeals' failure to act on a pending motion to terminate counsel and
compel a supervised, certified file return —leaving a litigant unable to prepare a Rule 14-compliant
petition —constitutes presumed prejudice and a constructive denial of the right to effective assistance
on appeal. See Penson v. Ohio, 488 U.S. 75 (1988); Evitts v. Lucey, 469 U.S. 387 (1985).

2. Whether due process requires access to a record "of sufficient completeness" to permit meaningful
review, and whether denial or obstruction of that access warrants administrative relief or abeyance to
permit record completion. See Griffin v. Illinois, 351 U.S. 12 (1956); Draper v. Washington, 372 U.S. 487
(1963); Mayer v. Chicago, 404 U.S. 189 (1971).

Whether the Supreme Court should grant relief due to constructive denial of appellate record access through counsel abandonment and court of appeals' non-ruling on a pending motion