Did the district court deny Mr. Robertson the meaningful representation informed by investigation to prepare a habeas corpus application to which he is entitled under 18 U.S.C. § 3599?

QUESTIONS PRESENTED This Court has unanimously ruled, in multiple cases, that Congress’s intent in enacting 18 U.S.C. § 3599 was to provide high quality representation to qualifying prisoners sentenced to death in federal habeas corpus proceedings, above even that afforded to the accused in non-capital trials. Ayestas v. Davis, 138 S. Ct. 1080 (2018); Martel v. Clair, 565 U.S. 648 (2012). By denying Mr. Robertson any requested representation services under § 3599(f), the court below ignored these rulings (albeit while paying lip service to them), along with many of the Court’s other rulings, including: the duty of a habeas applicant to investigate all grounds for relief that may be raised in a first habeas corpus application on penalty of forfeiture, McCleskey v. Zant, 499 U.S. 467 (1991); the duty of federal courts to provide meaningful representation for the preparation of a habeas corpus application, McFarland v. Scott, 512 U.S. 849 (1994); the duty of federal courts to provide meaningful representation in federal habeas corpus proceedings before permitting a prisoner to be executed, id.; the duty of federal courts to ensure one meaningful round of federal habeas corpus review for a non-dilatory prisoner before permitting his execution to occur, Lonchar v. Thomas, ° 517 US. 314 (1996); and the importance of meaningful review of Sixth Amendment claims by at least one tribunal, Martinez v. Ryan, 566 U.S. 1 (2012). Absent the Court’s intervention, Mr. Robertson will be executed without having received any meaningful representation informed by investigation to prepare a first federal habeas corpus application and without having received any judicial review ofa plausible Sixth Amendment claim he identified but was unable to meaningfully plead. Far from high quality representation, Mr. Robertson has only had counsel deprived of any means to effectuate her representation. The ; Court’s intervention is necessary to preserve Mr. Robertson’s access to the writ of habeas corpus in this case. (1) Did the district court deny Mr. Robertson the meaningful representation informed by investigation to prepare a habeas corpus application to which he is entitled under 18 U.S.C. § 3599? (2) Would a reasonable lawyer representing a death-sentenced prisoner pursue an investigation . ofa “bedrock” Sixth Amendment claim under the totality of the circumstances of this case? (3) Was the Sixth Amendment claim identified by counsel representing the petitioner a “plausible” one within the meaning of Ayestas v. Davis, 138 S. Ct. 1080 (2018)? (4) Does an attempt to amend a habeas corpus application following an appellate court’s reversal and remand for further proceedings related to the provision of representation by the district court on the initial application constitute a second or successive habeas corpus ; application under 28 U.S.C. § 2244(b)? ii