1. Whether the "clear and convincing evidence standard" should be used instead of the "preponderance of evidence standard" when determining the relevant conduct in a First Step Act Reduction Motion under Sec. 404?

2. Whether the Sixth Amendment protections for Effective Assistance of Counsel are to be applied on the First Step Act Reduction Filings?

3. Whether the Court should have Remanded for further consideration of the First Step Act Sec. 401, 851 changes, seeing that the Virginia prior used no longer qualifies today as a 851 predicate?

Whether the 'clear and convincing evidence standard' should be used instead of the 'preponderance of evidence standard' when determining the relevant conduct in a First Step Act Reduction Motion under Sec. 404