1. Whether Congress intended for an order under the Stored Communications Act to be
sufficient to authorize real time tracking of cell phone generated Cell Site Location
Information?

2. Whether Petitioner's trial attorneys' failure to understand the Stored Communications Act,
together with their failure to conduct basic legal research into the Warrant requirements
pertaining to the collection of historical Cell Site Location Information, as well as the
active tracking of real time Cell Site Location Information constituted deficient
performance resulting in prejudice to Petitioner sufficient to deprive petitioner of a fair
trial?

3. Whether this Court's decision in Carpenter v United States, 138 S.Ct. 2206, applies
retroactively to the Petitioner, where the decision was foreshadowed by and predictable
from the Court's decisions in Jones v United States, 565 US 400 [2012] and Riley v
California, 573 US 373 [2014] and Petitioner's conviction went final in 2016?

4. Whether, in the alternative, Petitioner should be able to be heard as to his Carpenter
claim under the Fundamental Miscarriage of Justice Exception to the procedural default
rule where he was clearly aggrieved by ineffectiveness of his trial counsel and that
ineffectiveness is the sole reason for the procedural default?

5. Whether the Trial Court's correctly interpreted the Carpenter holding when it held that
the State complied with the Carpenter holding because they had established probable
cause in their SC A affidavit?

Whether Congress intended for an order under the Stored Communications Act to be sufficient to authorize real time tracking of cell phone generated Cell Site Location Information?