Whether the Court should grant certiorari to resolve a conflict among the federal courts of appeals as to whether petitioners may ever prevail on a Federal Rule of Civil Procedure 60(b)(6) motion premised, in part, on Martinez v. Ryan, 566 U.S. 1 (2012)

QUESTIONS PRESENTED (Capital Case) This case presents the following questions worthy of the Court’s review: 1. Whether the Court should grant certiorari to resolve a conflict among the federal courts of appeals as to whether petitioners may ever prevail on a Federal Rule of Civil Procedure 60(b)(6) motion premised, in part, on Martinez v. Ryan, 566 U.S. 1 (2012). 2. Whether the Court should grant certiorari to bring the Fifth Circuit’s rigid approach to assessing timeliness under Rule 60(c)(1) into line with other courts of appeals. 3. Whether the Court should grant certiorari and provide guidance to the courts of appeals regarding the scope of the 18 U.S.C. § 3599 right to adequate representation post-Martinez and Trevino, and in particular whether federal habeas petitioners are entitled to conflict-free counsel to investigate all available claims and respond to the State’s procedural arguments. i