WHETHER RESPONDENT WAIVED/FORFEITED ANY OF IT'S PROCEDURAL
DEFENSES IN McGIRT 'S DECISION AND RESPONDENT IS PROCEDURALLY
BARRED FROM ASSERTING ANY IF IT'S PREVIOUS PROCEDURAL DEFENSES
THAT WERE AVAILABLE AGAINST PETITIONER 'S SUBJECT MATTER
JURISDICTION CLAIM IN COLLATERAL POST CONVICTION PROCEEDINGS
WHEN CONVICTON WAS FINAL?

WHETHER McGIRT V. OKLAHOMA ANNOUNCED A NEW VINDICATIVE
REPLACEMENT OF SUBSTANTIVE RULE DICTATED BY PRIOR PRECEDENT
MADE RETROACTIVE BY TEAGUE 'S EXCEPTION TO NON-RETROACTIVITY?
WHICH RESPONDENT REFUSED TO APPLY RETROACTIVELY AS STATE
POSTCONVICTION RELIEF TO CASES FINAL WHEN McGIRT WAS DECIDED ON
JULY 09, 2020?

WHETHER LACK OF TRIBES VOLUNTARY CONSENT TO STATE 'S ASSUMPTION
OF CRIMINAL JURISDICTION AND THE ATEMPTED EXERCISE OF JUDICIAL
POWER BY RESPONDENT WITHOUT TRIBE 'S CONSENT IS VOID?

Whether respondent waived/forfeited procedural defenses