Whether a defendant's Sixth Amendment right to effective assistance of counsel is violated when multiple attorneys fail to adequately challenge plea agreements, sentencing enhancements, and potential prosecutorial misconduct

No question identified. : COMES NOW the Petitioner in the above-styled cause, Stephen Christopher Plunkett, pro se, and moves’ this Honorable Court to extend the time for filing a Petition for Writ of Certiorari to the United States Court of Appeals for the Fifth Circuit for good cause shown. In support of the motion, Petitioner Plunkett would show the Court as follows: I. BACKGROUND Mr. Plunkett, the biological son of Joseph Robinette Biden, Jr., is being currently held in a facility which purports to be FCI Forrest City, ARkansas Medium and which is, in fact, an undisclosed Communications Management Unit in an effort to impede Mr. Plunkett's legitimate access to the courts, the press, counsel, and Congress. Such obstruction has already been applied and has worked. Mr. Plunkett pled guilty, pursuant to advice of counsel, to two counts of 18 U.S.C. §2113(a) in the Northern District of Texas in Case No. 3:14-CR-00239-L. Mr. Plunkett's first counsel refused to file a Motion to Withdraw Mr. Plunkett's guilty plea after the stipulation in Mr. Plunkett's guilty plea, made pursuant to advice of counsel, to additional counts under U.S.S.G. §1b1.2(c) was objected to by the government upon the return of Mr. Investigation Report. Although the United States Probation Office upheld the initial report as written in the First Addendum to that report, ultimately, after back channel communications by the government, United States Probation, in the Second Addendum to the report, agreed with the government in accord with an Unpub=~ lished Fifth Circuit case, United States v. Harrier, 229 Fed.Appx. 299 (5th Cir. 2007). Probation then wrote the report to recommend that the instant sentence be treated, instead, under U.S.S.G. §521.3(d). Plunkett asked Mr. Morris to file a Motion to Withdraw his guilty pleas Mr. Morris, despite his emails to the prosecutor, AUSA Lisa Dunn, stating that he was going to so file a motion at Mr. Plunkett's request, and admitting his own ineffectiveness and representations and advice to Mr. Plunkett, refused to file the Motion to Withdraw. Mr. Plunkett sought, and was granted, substitute counsel. Mr. Lewis then investigated Mr. Plunkett's claims of Mr. Morris's ineffectiveness and found them to be valid. Mr. Lewis then prepared a Motion to Withdraw the plea. Mr. Lewis submitted a copy of excerpts from this Motion to the District Court and to AUSA Dunn. In response, AUSA Dunn made an offer concerning sentencing agreement in order to avoid the Withdrawal issue. Mr. Lewis, just prior to sentencing, visited Mr. Plunkett at the Federal Detention Center at FCI Seagoville, TX and reported the offer to Mr. Plunkett. Mr. Lewis recommended Mr. Plunkett reject the offer. In addition, Mr. Lewis also recommended Mr. Plunkett NOT file a Motion to Withdraw his guilty plea and, instead, proceed to sentencing with Mr. Lewis's arguments concerning sentencing and other issues. Mr. Plunkett followed Mr. Lewis's advice. On December 11, 2017, Mr. Plunkett was sentenced to 116 months imprisonment ordered to run fully consecutively to Mr. Plunkett's undischarged Georgia Bank Robbery Sentence of 20 years to serve 10*years as the district court found Mr. Lewis's ineffective, and off-point, arguments unavailing. Mr. Plunkett, through ineffective counsel, filed a direct appeal to the United States Court of Appeals for the Fifth Circuit. See United States v. Plunkett, 749 Fed. Appx. 306 (5th Cir. 2019). Appetlate Counsel Hooks, despite letters and phone calls urging him to do so, would not appeal the reasonableness of the fully consecutives sentence orany of the other issues urged by Mr. Plunkett. Instead, Mr. Hooks chose to argue the issue on appeal with the least likelihood of success; the district court's application of a firearm enhancement. Mr. Hooks did not argue there was no evidence to support the district court's finding which there was not. The government submitted only argument in support of this enhancement. Mr. Hooks knew the standa