1. WHETHER § 2255 (E) "SAVINGS CLAUSE " IS IN CONFLICT WITH THE DECISIONS
OF THIS COURT AND OF OTHER COURTS OF APPEAL AS THE CORRECT
INSTRUMENT BY WHICH PETITIONER-APPELLANT COULD BRING FORTH A
BURRAGE- TYPE ARGUMENT.

a. WHETHER THE PETITIONER-APPELLANT COULD HAVE BROUGHT AN
EARLIER ARGUMENT FOR BURRAGE IN A DIRECT APPEAL OR § 2255 PRE-
BURRAGE V. UNITED STATES, 571 U.S. AT 204, 134 S. CT. 881 (2014).

2. WHETHER BURRAGE IS IN CONFLICT WITH THE. DECISIONS OF THIS COURT
AND OF OTHER COURTS OF APPEAL, WHEN IT RULED,

a. BURRAGE APPLIES ONLY TO THE CONTROLLED SUBSTANCE ACT OF 21
U.S.C. § 841 STATUTE CONTAINING A "DEATH OR SERIOUS BODILY INJURY
RESULT " ENHANCEMENT;

b. THAT BURRAGE HAS NOT SET A NEW STANDARD, BY WHICH ONE MUST
INTERPRET THE USE OF "BUT-FOR " IN A WIDE RANGE OF CASES;

c. WHETHER BURRAGE APPLIES TO GUIDELINES SENTENCE OR ANY CASE IN
WHICH AFFECTS THE STATUTORY SENTENCING RANGE BY A "DEATH OR
SERIOUS BODILY INJURY RESULT " FINDING.

3. LASTLY, IS BURRAGE IN DIRECT CONFLICT WITH THE DECISIONS OF THIS
COURT AND OF OTHER COURTS OF APPEAL WHERE A DEFENDANT WAS
SENTENCED PRE -BOOKER, AND WHERE THE GUIDELINES WERE STILL
MANDATORY.

a. THUS, SHOULD PRE -BOOKER GUIDELINES EFFECTIVELY SET MANDATORY
SENTENCING RANGES, THUS IT MAY BE THAT THE CAUSATION STANDARD
SET FORTH IN BURRAGE SHOULD BE EXTENDED TO "DEATH OR SERIOUS
BODILY INJURY RESULT " PROVISION CONTAINED IN THE MANDATORY
GUIDELINES.

Whether § 2255 (E) 'savings clause' conflicts with SCOTUS and other courts' decisions on bringing a Burrage-type argument