Is it sufficient reason for failing to raise new issues in a postconviction motion after first appeal that were not already litigated

QUESTIONS PRESENTED 1. a) Is it sufficient reason for failing to raise new issues in a postconviction motion after first appeal that were not already litigated — that the new issues could have been litigated in the first appeal if not for the complete absence of legal assistance by court-appointed postconviction counsel? b) Is it sufficient | reason also that a legal authority supporting the new issue (of the Rule of Completeness applying to something intended to be made viewable from code in electronically stored information) was not accessible by a prisoner. (The legal authority was the Sedona Conference Committee findings intended for ‘ attorneys and Judges.) 2. In postconviction, does it matter that a defendant is not informed by appellate counsel about the no merit report option and dangers of self representation verbally? 8. Is data that is contained within electronically stored information that can be readily compiled into viewable information, whether presented on the screen or printed on paper, also a “document” under Rule 34? 4. Helectronically stored information is considered on an equal footing with a “document”, does the Rule of Completeness apply to electronically stored information? 5. In the case of legal representation of an indigent defendant on first appeal in a state procedure, is it ineffective assistance of counsel when the attorney never speaks with nor communicates in any other way with the defendant, | where the only assistance to the defendant is from inexperienced law | students?