WHETHER THE DISTRICT COURT APPLIED AN INCORRECT STANDARD OF REVIEW TO PETITIONER'S APPLICATION FOR A CERTIFICATE OF APPEALABILITY ("COA") ON PETITIONER'S GROUND FOUR CLAIM UNDER FED. R. CIV. PRO. 6O(B)(6) IS CONTRARY TO TENNARD V. DRETKE, 542 US 274 (2004); SLACK V. MCDANIEL; AND MILLER-EL V. C 9A SE A T ( Z S L TZD 597 (8TH CIR. 2014); EVANS V. LUEBBERS, 371 F.3D 438 (2004); FOWLKES, 326 F.3D 542 (4TH CIR. 2003); LAMBRIGHT V. STEWART, 220 F.3D 1022 2 (9TH CIR. 2000) IN LIGHT OF THE NEWLY DISCOVERED EVIDENCE OF PETITIONER'S ACTUAL INNOCENCE CLEARLY DEMONSTRATED IN EXHIBITS 1, 2 AND 3?

WHETHER CERTIFICATE OF APPEALABILITY SHOULD ISSUE ON PETITIONER'S CLAIM OF INEFFECTIVE ASSISTANCE OF BOTH NA A T Y BN AM BIN RAISED IN PETITIONER'S REPLY BRIEF, RULE 59(A)-(E) AND UNDER FED. R. CIV. PRO. 6O(B)(6) MOTION BEFORE THE DISTRICT COURT IN LIGHT OF UNITED STATES V. HARFST, 168 F.3D 398 (10TH CIR. 1999) IN LIGHT OF THE NEWLY DISCOVERED EVIDENCE OF PETITIONER'S ACTUAL INNOCENCE CLEARLY DEMONSTRATED IN EXHIBITS 1, 2 AND 3?

WHETHER PETITIONER HAS DEMONSTRATED CAUSE UNDER FED. R. CIV. PRO. 60(B)(6) IN LIGHT OF AND PREJUDICE MARTINEZ V. RYAN, 566 US 1 (2012); 1 TREVINO V. THALER, 569 US V. UNITED STATES, 500 (2003); STATE V. (2013); MASSARO 538 US ZERNECHEL, 304 N.W.2D 365 (MINN. 1981); AND REAGAN V. NORRIS, 279 F.3D 651 (8TH CIR. 2002) BASED ON THE NEWLY DISCOVERED EVIDENCE OF PETITIONER'S ACTUAL INNOCENCE CLEARLY DEMONSTRATED IN EXHIBITS 1, 2 AND 3?

WHETHER UNDER FED. R. CIV. PRO. 60(B)(6), A CERTIFICATE OF APPEALABILITY SHOULD ISSUE ON THIS CASE UNDER THE ACTUAL INNOCENCE EXCEPTION, MISCARRIAGE OF JUSTICE EXCEPTION, ENDS SOF JUSTICE EXCEPTION, MANIFEST INJUSTICE EXCEPTION, OR COLLATERAL CONSEQUENCE DOCTRINE EVIDENCE IN UDOH V. BARR, USCA8 NO. 20-2389 IN LIGHT OF THE NEWLY DISCOVERED EVIDENCE OF PETITIONER'S ACTUAL INNOCENCE DEMONSTRATED IN EXHIBITS CLEARLY 1, 2 AND 3, AND PETITIONER'S LACK OF ACCESS TO THE PRISON LAW LIBRARY

Whether the district court applied an incorrect standard of review