1. Whether a claim of actual innocence is cognizable on a writ of error coram nobis where new evidence of defendant's innocence is discovered after sentence is served, and whether a credible actual innocence claim on a writ of error coram nobis may allow a defendant to pursue his underlying constitutional claims on the merits notwithstanding the existence of a procedural bar to relief?

2. Whether a petition for a writ of error coram nobis is ineligible if the claim could have been raised on a § 2255 motion, as five circuits hold, or a petition for a writ of error coram nobis is eligible as long as a more usual remedy is not available, as seven circuits hold, and whether ineffective assistance of counsel claims are a fundamental error that is cognizable on writ of error coram nobis?

Whether a claim of actual innocence is cognizable on a writ of error coram nobis