1. The factual determination for denying the certificate of appealability was wrong and reversal is warranted.

2. Pro-se petitioners are to be given a liberal reading of motions and filings.

3. Certificate of appealability must be granted prior to a ruling on the merits or facts.

4. Antecedent constitutional claims can be argued to show the totality of failure of defense counsel, resulting in constructive denial of counsel at the plea stage of the proceedings, resulting in petitioner entering the plea unknowingly and unintelligently.

Whether the factual determination for denying the certificate of appealability was wrong and reversal is warranted