(i) Whether a freestanding claim of actual innocence can overcome AEDPA's gatekeeping provisions and/or whether a prisoner may be entitled to federal habeas relief based on a freestanding claim of actual innocence?

(2) Whether the State of Colorado had the power to enter the conviction or impose the sentence in this case, including:

(a) Whether Brooks was involved in selling securities?

(b) Whether the State of Colorado had jurisdiction to indict Brooks?

(c) Whether criminal enforcement of the Colorado Securities Act ("CSA") is unconstitutionally vague, overbroad, and is criminalizing otherwise innocent conduct?

Whether a freestanding claim of actual innocence can overcome AEDPA's gatekeeping provisions and/or whether a prisoner may be entitled to federal habeas relief based on a freestanding claim of actual innocence