Whether the trial court erred in accepting defendant's guilty plea when the plea was equivocal

QUESTIONS PRESENTED 1. Whether Trial Court erred in accepting defendant Tsai-Fen Lee to plead guilty when the plea was on its face equivocal. 2. Can Lee’s guilty plea be considered voluntary when she was deprived of liberty by her own counsel for almost 4 months? 3. Whether it is an effective assistance of counsel when trial counsel fails to perform basic research regarding the law. 4. Whether the petitioner’s constitutional rights to effective assistance of counsel and due process were violated when her appellate counsel failed to utilize investigation results and failed to raise substantial claims of coercion and ineffective assistance of trial counsel in the opening brief. 5. Whether the denial of the petitioner’s pro se motion for reconsideration by the lower court, after ruling on the merits, warrants Supreme Court review to address the deficiencies in the appellate process. ii LIST OF PROCEEDINGS The Supreme Court of Washington Case No. 102333-2 In the Matter of the Personal Restraint of Tsai Fen Lee Ruling Denying Review: November 22, 2023 Order to Deny Motion to Modify: March 6, 2024 Court of Appeals of the State of Washington, Division One Case No. 84274-9-I In the Matter of the Personal Restraint Petition of Tsai Fen Lee Opinion: July 31, 2023 Order Denying Reconsideration: August 15, 2023 The Supreme Court of Washington Case No. 99453-6 State of Washington v. Tsai Fen Lee Order entered on June 7, 2021 iii Court of Appeals of the State of Washington, Division One Case No. 78512-5-I State of Washington v. Tsai-Fen Lee Opinion: November 16, 2020 Order Denying Reconsideration: December 28, 2020 Washington State Superior Court, King County Case No. 16-1-02293-2 SEA State of Washington v. Tsai Fen Lee Judgement entered on May 11, 2018 Washington State King County Superior Court Case No. 15-2-18274-9 Cassandra Mitchell v. Tsai-Fen Lee Protection Order issued on September 1, 2015