1. tether New York State residents are always actually innocent of felony and attsipted felony criminal possession of a weapon offenses if they possess a loaded firearm within their hare and had no pra/ious convictions.

2. tether petitioner is actually innocent of a felony or attarpted felony criminal possession of a weapon offense under legal exceptions/defenses within New York law.

3. tetter a defendant may make a freestandirg claim of actual innocence under the rare occasion that te discovers that te is actually innocent of an offense on the laws of the state.

4. tetter New York State's hare or place of business exception for criminal possession of a weapon offenses applies anytime possession of a firearm, loaded or not, actual ly occurs in the hare or place of business regard! ess of whether the excqntion is contained within a sqnarate subdivision of the sane Statute.i

5. ten New York legislature has proscribed a nisdenaanar offense for a defendant te has possessed a loaded firearm in his hone te also had no previous convictions, may the State's prosecutors apply the prescription of unlawful intent under New York Fdnal law 265.15(4) in order to raise that rrasdeiBanor up to a felony or sustain a felony ten only a irasdsneanar occurred?

6. Does New York's Banal law 265.15(4) override and circumvent tew York's heme or place of business and no previous conviction exarptions for criminal possession of a weapon offenses?

7. tetter it is legally impossible to caimit attempted criminal possession of a weapon in the second degree in tew York State ten the offense is based solely on the fdnal law 265.15(4) presuipticn.

8. tetter a trial/sentencirg court lacks authority and jurisdiction over a criminal natter in tew York State ten an indictment alleging criminal possession of a weapon fails to specifically articulate that the possession occurred outside of the hare or place of business.

9. tetter an attorney's recognition of, and failure to challenge, the application of tew York Ifenal law 265.15(4) constitutes ineffective assistance of counsel ten that statute is being relied upon by a prosecutor as,the soie'dindoned'-to seewm'a conviction.

10. Wnetter petitioner's counsel rendered ccnpletely deficient assistance of counsel.

11. tether a defendant is entitled to the appeal .that was lost altogether no natter hew much time has elapsed since sentencing when both the sentencing court and counsel failed to inform defendant of a right to appeal in addition to counsel's failure to file a notice of appeal.

12. Itether writ of error coran nobis is available no matter the length of tine elapsed since imposition of judgment when counsel fails to file a notice of appeal and both counsel and the sentencing court failed to inform defendant of a right to appeal.

13. Does Roe v. FLores-Cttega,528 U.S. 470(2000) extend or apply to del deficiency instances ten both counsel fails to file a notice of appeal and both the sentencing court and counsel fail to inform a4'-t defendant of the right to appeal?

14. Wnether a defendant may file a writ of error coram nobis as soon as discovering the facts that entitle him to coram nobis relief no natter how much tine has elapsed since the discovery of those facts.

15. Wether the harm and prejudice

Whether New York State residents are always actually innocent of felony and attempted felony criminal possession of a weapon offenses if they possess a loaded firearm within their home