1. Whether Petitioner was denied effective assistance of appellate counsel when court-appointed counsel failed to file or consult Petitioner about filing, a petition for panel rehearing under Federal rule of Appellate Procedure 40 or a petition for rehearing en banc under Rule 35, resulting in the complete forfeiture of appellate review on Counts 1-29.

2. Whether procedural forfeiture (default) caused solely by counsel's neglect or abandoned as opposed to any informed or strategic decision by the defendant must be excused under this Court's decision in Maple v Thomas, 565 U.S. 266 (2012), Holland v Florida, 560 U.S. 631 (2010), and Garza v Idaho, 139 S. Ct. 738 (2019).

3. Whether an indigent defendant may be denied the right to proceed pro se on direct appeal, and whether the denial of that right followed by counsel's subsequent forfeiture of all appellate remedies constitutes structural error the Sixth Amendment.

Whether petitioner was denied effective assistance of appellate counsel when court-appointed counsel failed to file petitions for panel rehearing or rehearing en banc, resulting in forfeiture of appellate review, and whether procedural default caused solely by counsel's neglect must be excused under Maple v. Thomas, Holland v. Florida, and Garza v. Idaho