Could reasonable jurists debate that trial counsel's constitutional duty to consult with a defendant on whether to file an appeal pursuant Rose v. Flores-Ortega is not satisfied by counsel simply sending a letter by mail to an incarcerated defendant explaining the appeal process and advising against an appeal, without a direct consultation?

1 Could reasonable jurists debate that trial counsel’s duty to consult with a defendant on whether to file an appeal pursuant Rose v. Flores-Ortega, 528 U.S. 470 (2000), is not satisfied by simply sending a letter by mail to an incarcerated defendant explaining the appeal process and advising against an appeal, without a direct consultation on the subject, and if such question is debatable, did the Ninth Circuit error in denying petitioner’s motion for a certificate of appealability on the district court’s denial of his motion to vacate, set aside or correct sentence under 28 U.S.C. § 2255? i