Ja'Krai Banks filed an 11.07 on August 23, 2019. Banks received an affidavit from Private Investigator James McKay in March of 2020. Banks used McKay's affidavit to rebut Attorney Hubert Todd McCray's affidavit filed June 30, 2020. The rebuttal nor McKay's affidavit was acknowledge in the findings of fact and conclusions of law of the trial court.

Is Banks entitled to pursue a subsequent writ withthe newly discovered .evidence found in the affidavit of McKay?

Ja'Kroi Ranks, Attorney Cornelius Cox, and Private Investigator James McKay's affidavits are in contradiction of Attorney Hubert Tbdd McCray's affidavit, which the court exclusively used for its findings.

Does the trial court failure to grant an evidentiary hearing to ascertain the truth of the contradictions deny Banks of the enforcement of his 6th and 14th Amendments?

Many circuits have found the plea withdrawal hearing to be a critical stage in a criminal proceeding, however the Supreme Court, 5th Circuit, nor Texas Court of Criminal Appeals have not expressly ruled that the plea withdrawal hearing is a critical stage of the crim inal proceeding.

Ts a plea withdrawal hearing a critical stage of the criminal proceeding?

After the ruling on Shinn, how does an indigent pro se defendant enforce his right of effective assistance of trial counsel, afforded by Gideon, when as the Supreme Court has acknowledged in Trevino, Texas has an inadequate system to protect a defendant 's right to ineffective assistance of counsel?

The Supreme Court has acknowledged Texas inadequate system to protect an indigent pro se defendant's right to effective assistance of counsel in Trevino, is indigent pro se applicant entitled to counsel in the state collateral proceeding, being the first opportunity to raise, an ineffective assistance of counsel claim, to properly litigate said claim?

If conviction has been obtained in violation of due process, by not providing effective assistance of counsel to assist in the critical stage of plea bargaining, and void for lack of jurisdiction, by the involuntary waiver of jury trial, in violation of due process, in regards to procedural defaults, what jurisdiction does the court' have besides to rule the original judgment void?

How can the right to the effective assistance of counsel at trial be ensured if a state has no adequate vehicle for an indigent pro se defendant to assert that the right was violated?

Is a live evidentiary hearing necessary in post-conviction proceedings on claims of ineffective assistance of counsel during plea negotiations?

If the Sixth Amendment and procedural due process entitle criminal defendants to a remedy for a constitutional violation, do they also entitle indigent pro.se defendants to provide evidence to prove there was a violation, and if not does it deprive the right?

Is a plea withdrawal hearing a critical stage of the criminal proceeding, and how can an indigent pro se defendant enforce their right to effective assistance of counsel when Texas lacks an adequate system to protect such rights?