I. Where the plea colloquy clearly indicated the
defendant-petitioner 's disagreement with the factual
admissions stated in a written plea agreement,
included multiple recesses upon the defendant 's
repeatedly expressed desire to plead "not guilty, " and
resulted in the district court judge expressing that the
colloquy was problematic, should the defendant be
permitted to withdraw his guilty plea several days
after finally stating "yes" to the district court 's inquiry
whether he admitted to the facts stated in the written
plea agreement?

II. Whether the Sixth Circuit misinterpreted Federal
Rule of Criminal Procedure 11, thus flouting the
constitutional rights recognized in Boykin v.
Alabama, 395 U.S. 238 (1969), and McCarthy v.
United States, 394 U.S. 459 (1969), by dismissing
Petitioner 's appeal from the district court 's order
refusing to permit him to withdraw a guilty plea
where the district court itself characterized the plea
colloquy as "suboptimal for all involved," stated it was
"the longest change of plea this Court has ever
conducted," tried to stop proceedings "on numerous
occasions," expressed being "not comfortable with
this," and the defendant declared "I want to plead not
guilty" twice before ultimately succumbing to mere
agreement with the written plea agreement he had
recently signed because defense counsel told him to
"stop fucking around" and warned that his "elderly
mother may not live to see him free again" if he did
not tell the court that the written statement was
factually accurate.

III. Whether the district court 's immediate grant of
a defense attorney 's motion to withdraw, where the
defendant had not been consulted and had exhausted
his resources to pay his attorneys in advance,
constituted a deprivation of the Sixth Amendment
right to counsel of choice warranting an automatic
reversal of his subsequent conviction.

IV. Whether the Sixth Circuit departed from the
constitutional requirements as correctly stated in
United States v. Bashara, 27 F.3d 1174 (6th Cir.
1994), and United States v. Ellis, 470 F.3d 275 (6th
Cir. 2006), by affirming denial of pre-sentence guilty
plea withdrawal despite the district court's findings
that: (a) the plea colloquy was "suboptimal for all
involved"; (b) "minimal time elapsed" between plea
and withdrawal motion (11 days); (c) there would be
"minimal prejudice (if any) to the government"; and
(d) the court "tried to stop the proceedings on
numerous occasions."

V. Whether the Sixth Circuit's reliance on the
guilty plea to dismiss the appeal in this case
constitutes an unacceptable degree of conflict with
other Circuits in a matter of constitutional
importance affecting the 95% of federal criminal
cases resolved through guilty pleas.

VI. Whether petitioner's prosecution violated the
First and Fifth Amendments when federal felony
charges carrying up to 20 years ' imprisonment arose
directly after he filed EEOC complaints against his
recently appointed supervisor, who provided
significant information to the prosecution.

VII. Whether permitting the guilty plea to stand
despite defendant 's effort

Whether a defendant should be permitted to withdraw a guilty plea where the plea colloquy was characterized as problematic by the district court, the defendant repeatedly expressed disagreement and desire to plead not guilty, and the defendant only agreed after coercive statements from counsel, and whether the Sixth Circuit misinterpreted Federal Rule of Criminal Procedure 11 in violation of Boykin v. Alabama and McCarthy v. United States