The first part of your essay, above the dotted-line, is wrong. We are not conceding anything. The elements of adequate representation, are indeed being applied to the Rule 60 motion, not the trial. Thus the first half of your essay is off-base.
The second part of your essay, below the dotted line, is excellent, articulate, and useful. I will be adding that part to my oral argument preparatory notes file. Thank you for your positive contribution to this effort.