(1)
WHETHER THE GOVERNMENT'S UNAVAILING DEFENSE OF THE INDEFENSIBLE, WITH RESPECT TO THE
INDICTMENT, INADEQUATE JURY INSTRUCTIONS, AND THE CONSTRUCTIVE DENIAL OF COUNSEL WERE CLEARLY
PREJUDICIAL TO FRANCISCO FELIX, WHICH BY ANY STANDARD OF REVIEW, THE COURT SHOULD ALSO FIND
DEFENDANT'S COUNSEL HOPELESSLY DEFICIENT.

(2)
WHETHER PETITIONER FRANCISCO FELIX 'S INVOCATION OF THE "ACTUAL INNOCENCE" AND THE "CAUSE AND
PREJUDICE" DOCTRINES, ALLOWS THE SUPREME COURT TO ENTERTAIN ANY PROCEDURALLY DEFAULTED CLAIMS
PRESENTED BY FRANCISCO FELIX.

(3)
WHETHER BY REASON OF THE NUMEROUS CONSTITUTIONAL VIOLATIONS COMMITTED BY THE DISTRICT COURT
IT EFFECTIVELY LOST SUBJECT MATTER JURISDICTION UNDER THE POWERS GRANTED IT BY CONGRESS
PURSUANT TO 28 U.S.C.. 3231 TO TRY FRANCISCO FELIX.

Whether the government's defense, jury instructions, and denial of counsel were prejudicial