Memorandum from Bob to Doug regarding Kaczynski's Petition for Re-Hearing

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Memorandum from Bob to Doug regarding Kaczynski's Petition for Re-Hearing
I. The Claim: Self-Representation Request Cannot Be Denied on the Grounds of Purpose to Delay Without Showing There Would be an Actual Delay (pp. 6-9)
II. The Claim: the District Court Must Conduct an Adequate Inquiry in Order to Find Purpose to Delay (pp. 9-10)
III. The Claim: Kaczynski Could Have Assumed His Defense Immediately; the Fact That it Would Have Been an Inadequate Defense Is Irrelevant Because Kaczynski Was Not Required to Present Any Defense at All (pp. 10-13)
IV. The Claim: Postponing Self-representation Request until All Other Reasonable Avenues Have Been Exhausted Is Not a Tactic for Delay (pp. 14-17)
V. The Claim: the Panel Should Not Be Limited to “The Record and Files” to Show That the Purpose of Delay Finding Was Clearly Erroneous; the Panel Should Be Allowed to Rely Upon the 2255 Petition (pp. 17-19)
Source, notes...