ISSUE I
(A) WHETHER CONSTITUTIONAL, STATUTORY INFIRMITIES, AND VIOLATIONS OF RULE 11 MAY HAVE RENDERED
COREY DEVON EATON'S PLEA AGREEMENT, AND HIS PLEA WAIVER INVOLUNTARY, UNKNOWING AND
UNINTELLIGENTLY MADE, BY REASON OF THE COURT, THE GOVERNMENT AND RETAINED COUNSEL'S FAILURE TO
ENSURE HE WAS ENTITLED TO HIS RIGHTS TO APPEAL AND GET RELIEF UNDER THE SAFETY VALVE PROVISION
AND 782 AMENDMENT.
(B) COREY DEVON EATON'S ENTITLEMENT TO SAFETY VALVE
(C) WHETHER IN LIGHT OF PETITIONER'S CONSTRUCTIVE DENIAL OF COUNSEL AND CUMULATIVE ERRORS, THIS
HONORABLE COURT HAS THE POWER TO GRANT RETROACTIVE RELIEF ON THE 782 AMENDMENT, BY REASON OF
THE SUPREME COURT'S 2018 HOLDING IN HUGHES V. UNITED STATES, (CITATIONS OMITTED).
ISSUE 2
WHETHER PETITIONER'S INVOCATION OF THE CAUSE AND PREJUDICE DOCTRINE, ALLIED WITH AN ACTUAL
INNOCENCE CLAIM, ENTITLES HIM TO A MERITS DETERMINATION OF HIS OTHERWISE PROCEDURALLY DEFAULTED
CLAIMS.

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