1. Whether Petitioner is innocent of the charges resulting from a complete miscarriage of justice based upon the facts herein and is therefore qualified for relief on Writ of Coram Nobis.

Noise Flash Diversionary Devices (NFDD) are neither Destructive Devices nor Firearms — Affirmative defense to prosecution.

No legal avenue exists to transfer NFDD to individual police officers.

Government did not prove the mens rea requirement under the statue.

Ineffective assistance of Counsel.

2. Whether Petitioner documented sound reasons for not seeking a subsequent 28 U.S.C. § 2255(h) motion in accordance with United States v. Esogbue, 357 F.3d 532, 535 (5th Cir. 2004).

Whether Petitioner is innocent of the charges resulting from a complete miscarriage of justice