Does the Due Process Clause entitle a convicted prisoner to appointment of counsel and opportunity to amend a Notice of Post Conviction Relief asserting newly discovered evidence of a congenital neurological condition?

QUESTIONS PRESENTED Does the Due Process Clause of the Constitution’s Fourteenth Amendment entitle a convicted prisoner | serving a natural life sentence to (1) appointment of counsel on a Notice of Post Conviction Relief asserting a claim of newly discovered material evidence directly : bearing on a sentencing judge’s determination of : whether to impose a sentence of natural life vs. life with a possibility of parole for the offense of First Degree Murder, and/or (2) an opportunity to amend, if necessary, the Notice of Post Conviction Relief (“Notice of PCR”), when the newly discovered evidence involves a congenital neurological condition, Chiari Malformation,! with wide-ranging and highly complex effects and the prisoner has no reasonable means of investigating on her own and articulating to the court the full extent of physical, emotional, psychological, and behavioral effects of the newly discovered medical condition? ; ! Petitioner’s congenital neurological condition is called Chiari Malformation, and was discovered when Petitioner was sent by the Arizona prison medical services provider for an MRI, as a diagnostic tool to investigate possible causes of Petitioner’s various symptoms and conditions. Upon learning of the existence of the condition and with the assistance of her family, Petitioner initiated research into Chiari Malformation, its causes, effects, and treatment; and presented the information to the Court as newly discovered material evidence that placed consideration of her personal and criminal history in a completely different light. The result of her admittedly preliminary research was stunning in the scope of the implications arising from the condition.