Whether Lower Court's denial of Motion for Reconsideration pursuant to Rule 60(b)(6) based on intervening law was an abuse of discretion

QUESTION PRESENTED L Whether Lower Court’s denial of Motion for Reconsideration pursuant to Rule 60(b)(6) based on intervening law was an abuse of discretion that conflicts with decisions of U.S. Supreme Court and deprives Petitioner of constitutional Tight under 14th Amendinent to due process of law. He Where State allows Petitioner Pro se, to raise IATC claim on direct appeal, where Constitutional right to counsel, fails to resolve issue, and provides no counsel at initial-review collateral creates a State created impediment that deprives of couns¢l assistance before the Courts in violation of duc process of law under, U.S. Const., Amendment 6, 14. Critchley v. Thaler, $86 F.3d 318, (5" Cir. Oct. 21, 2009), Solna y US, 709 F.2d 160 2" Cir. (N.Y) 1983) I. Whether indigent forced to proceed Pro se on direct appeal with IATC claim (Patent on Face of Record), and court fails to appoint counsel at initial-review : collatcral on claim of ATC deprives of due process and equal protection of the law. U.S. Const., Amends 6, 14. ; Iv. The U.S. Middle District Court, and the U.S. 5" Circuit of Louisiana has entered decisions applying 28 U.S.C., § 2244 to a Fro se, Rule 60(b)(6), needing this Court’s exercise of Supervisory Authority to decide matter. Vv. This Court’s Supervisory Authority needed to determine whether Lower Court's recharacterization of Pro se Rule 60(b)(6) motion to a habeas corpus without prior notice and opportunity to amend is an abuse of discretion denying Constitutional right to duc process of law. VI. This case involves the important issue of whether when State fails to complete the court with the Six Amendment clause of appointment of counsct for indigent defendants, State creates an impediment constituting extraordinary circumstances sufficient to proceed under Rule 60(b)(6)? VEE. The Court’s Supervisory Authority needed to answer important federal question whether a defendant preserves right to counsel at initial-review collateral when he raised IATC claim on direct appeal that was unresolved? U.S. Const., Amend. 6", 14% VI. This Courts Supervisory Authority needed to establish uniformity in Lower Courts application of § 2254 successive petition standard to a, Rule 60(b)(6) that challenges a prior habeas proceedings integrity because of a structural defect, subjecting Petitioner to denial of duc process under, U.S. Const., Amend.’s 6, 14% IX. Movant's Substantial Showing Trial Counsel's Cumulative Exrors Rendered Actual Objective Deficient Performance That Prejudiced Movant By Denial Of A Fair Trial, And There Is A Reasonable Probability But For Counsel’s Deficient f a ‘ Performance The Results Of The Proceeding Would Have Been Different. Martinez, supre: Stricklond v. Washington, 466 U.S. 688, 687, 104 S.Ct. 2052, 2064. 80 L.Ed.2d 674 (1984) xX. Substantial showing of IATC under Martinez does not raise new claim as Lower Court’s suggest, deprives of merits ruling in violation of duc process of law under 14" Amendment. XI. Lower Courts denial of COA, IFP, with memorandum in support on IATC is an abuse of discretion that deprives Petitioner of duc process of law under, U.S. Const., Amend. 14; 28 USC, § 2253 (©). ii t a . .