Question #1:
The Northern District Court reasoned that because K.S. told '
other people (speculating what K.S. told other witnesses ), "there
was abuse," an appellate court must respect the jury's credibility
decisions. Thus, the Northern District Court held that as long as
the jury determined the evidence is sufficient to convince them
that the offenses occurred, regardless of Petitioner's age, the
evidence isrlegally sufficient under Jackson because this standard
is not held to the same standard as applied to in other crimes or
cases. By law, the prosecution must prove beyond a reasonable
doubt that sexual offenses occurred after Petitioner turned 17
years old. 98% of all testimony described at trial occurred when
Petitoiner was a juvenile, and at best, there is only conclusory
evidence (that is, a modicum of evidence)
convictions . Thereforeto support Petitioner's
Does the Northern District Court's deci
sion conflict with the holding in Jackson v. Virginia -f443- U.S.
307, 99 S.Ct. 2781 (1979) as the Northern District Court misappl
ied the standard in deciding that conclusory evidence, at best a
modicum of evidence, is sufficient to prove the sexual offenses
beyond a reasonable doubt?

Question #2:
Petitioner argues he is actually innocent in light of the ab
sence of any physical evidence of "anal or genital trauma," K.S.'s
inconsistent statements to the various individuals involved,
f K.S.'s mother's animus toward Petitoiner and his father. See
Appendix H. This Honorable Court has not yet resolved whether a
habeas petitioner may be entitled to habeas relief based
freestanding actual-innocence claim. See Mcquiggin v. Perkins ,
383, 392 (2013). Therefore, in the interest of justice,
should this Honorable Court create a freestanding actual innocence
exception that applies only to sexual related offenses?

Question #3:
Petitioner was on trial for prohibited-fsexual conduct after he
turned 17 years old. Being that 98% of all evidence of Petition
er s trial was based on his juvenile extraneous offenses,
ing the same complainant; accordingly, does the Northern District
Court's decision conflict with the holdings of Old Chief v. United
States , Michelson v. United States
dening relief based on the complainant's account of and use of
Petitioner's Juvenile Extraneous offenses? See Old Chief , 519 U.S.
172, 181, (1996); Michelson , 335 U.S. 469, 484 (1948); and Lisenbaon a
569 U.S.
concernand Lisenba v. California, for
314 U.S. 219 (1941).

Question #4:
As related to Question #3, Wood v. Quarterman , in the Fifth
Circuit, allows admission of sexual extraneous offenses if: (1)
the state makes a strong showing that Petitioner committed the
offenses, and (2) the offenses bears a rational relationship to
the offenses charged. The long-standing precedent of this Honor
able Court prohibits extreme use of extraneous offenses because

Does the Northern District Court's decision conflict with the holding in Jackson v. Virginia as the Northern District Court misapplied the standard in deciding that conclusory evidence, at best a modicum of evidence, is sufficient to prove the sexual offenses beyond a reasonable doubt?