I.
Whether certiorari should be granted to clarify that probable cause must be
based on actual facts, rather than mere assumptions interposed by the court
during its review of those facts, and to clarify the proper appellate standards
for "waived" arguments?

II.
Whether certiorari should be granted to clarify that when ineffective
assistance of counsel causes a party to lose the right to even raise an issue on
appeal, that scenario should be treated in the same manner as when an appeal
is untimely filed because of ineffective assistance of counsel - i.e., since in both
situations no appeal was possible, with prejudice arising from the loss of the
right of appeal itself, the party should simply be afforded a new appeal, without
the need to prove before that appeal is even briefed that he would also surely
win that appeal on the merits?

Whether certiorari should be granted to clarify that probable cause must be based on actual facts, rather than mere assumptions interposed by the court during its review of those facts, and to clarify the proper appellate standards for 'waived' arguments