Whether the Supreme Court should recognize an exception to procedural default rules for successive petitions in state post-conviction proceedings based on the Martinez v. Ryan standard for ineffective assistance of counsel claims

No question identified. : Pursuant to Supreme Court Rule 13 (5) Teats, the petitioner , reg vests an 2x%rtension of Ae days +o submit a petition for a writ of certioratl . The reasons for the request ate explained below. A. The petitioner submitted a Petition for Panc| Rehearing . The petition Was Filed denied on Joly 3], 2023. This Order triggecedl the GWOclay dead line according TO Sup. Ct Rule 13 (3). (hibit 1) 6. The petitioner submitted a peti tion foc more time to Submit a Ffetition for Rehearing En Bancs (exhibit 2). 4 Fileel Order was made on Avgust 18,2023 authorizing the return of Teats' peti tion. The Sixth Circuit Order Stated request Was subject to the “svccessive peti tion’ law expoused by the U.S: Sup. Ct, (Exhibit 3). Aceording to Sup: Cr. Rule 13 (3) this Order Triggers the AO “day dead line to submit a Writ of Certiorari. / prgt az The August ig" Order created contusion as to the appropriate 20 clay triggel Clate. Supreme ct Role 13(3) langvage Support s O trigger date for the August 18” and Tely 31% Order, In light of this leaks submitted a handwritten petition lacking Full compliance with all Sup: Ct, rules in orcer for this Court to maintain jocisdiction. C. The petitioner has 3 gveStions: that will be raised id the writ of certiorari: (, Did the petitioner Satisfy the “Exhaustion Role” by submitting his claims to the Tenn. Ct. of Crim. App: Sy way of a Motion to Reheac! Exhibit 4 UL Should a Petition for Rehearing En Bane be Vide 7 He bs petition when a Fane} enearin pe joy) has been Sub itte an ad utli cated ¢ mi tte al and itt Did the clecision 19 Martinez v. Ryan (32 S.Ct, 1304 (2012) require claims to be page 3 raised beyond the initial collateral roceeding in States like Tennessee's proced veal” Frame work 2 Di A Sixty -dlay extension is needed so the petitioner can Folly comply with Sup. Ct, roles , ty pe up the writ of certiorari, and Fhis Court can clarity What the trve dve clate is. In addition this Facility iS prone to lockdowns and sta of prevent the access to the law library. Shortages the Conclusion Wherefore the petitioner prays this Couct wi Il grant avi eXtension +o submit on Writ of Certiorart for the reasons in this petition or any reason it Sees fit. Respect Fully submitted , Jee Date: October 3017 2023 page 't