1. Whether defense counsel renders constitutionally ineffective assistance under the Sixth Amendment when, for financial gain, he affirmatively lies to his client that a grand jury indictment has been returned thereby inducing waiver of the Fifth Amendment right to indictment and whether such a fundamental misrepresentation can ever be "cured by a routine plea colloquy.

2. Whether a guilty plea is knowing and voluntary under the Due Process Clause where it rests upon a prosecutor's specific, off-the-record promise of a fully concurrent sentence a promise later disavowed at sentencing through reliance on a boilerplate "non-binding" clause in the written plea agreement.

3. Whether due process is violated when a prosecutor coerces a defendant to dismiss a pending appeal by threatening to bring additional, more severe charges if the appeal succeeds, thereby insulating constitutional errors at trial and sentencing from appellate review.

4. Whether the Ninth Circuit erred in denying a certificate of appealability ("COA") under 28 U.S.C. § 2253(e), thereby barring appellate review of substantial constitutional claims in conflict with Slack vs. McDaniel, 529 U.S. 473,483 (2000), and Murray vs. United States, 579 U.S._, 596 (2016).

5. Whether defense counsel's undisclosed collusion with the prosecutor including text message communications assuring petitioner "everything was handled" and proposing a three-way call to pressure petitioner into pleading guilty constitutes ineffective assistance of counsel under the Sixth Amendment and a conflict of interest under Cuyler vs. Sullivan, 446 U.S. 335 (1980).

Whether defense counsel renders constitutionally ineffective assistance under the Sixth Amendment when, for financial gain, he affirmatively lies to his client that a grand jury indictment has been returned thereby inducing waiver of the Fifth Amendment right to indictment and whether such a fundamental misrepresentation can ever be 'cured by a routine plea colloquy'