1.) To be issued a COA : Does the claim of Factual Innocence qualify as a
debatable claim for the denial of a Constitutional Right as enunciated in
Slack v. McDaniel, 529 U.S. 473, 484-485 (2000)?

2.) To be issued a COA : Does the claim of Factual Innocence qualify as a
debatable claim regarding whether the lower courts properly applied a
Procedural Bar, as enunciated in Slack v. McDaniel, 529 U.S. 473, 484-485
(2000); McQuiggin v. Perkins, 569 U.S. 383, 386 (2013)?

A.) Notwithstanding Factual Innocence : Was Petitioner required to object
when state statute preserved his claims?

B.) Notwithstanding Factual Innocence : For the purposes of the District
Court relying on the NCCOA opinion to apply a procedural default, Did
the NCCOA definitively rule on Petitioner 's Sandstrom claim?

C.) Notwithstanding Factual Innocence : For the purposes of the District
Court relying on the NCCOA opinion to apply a procedural default, Was
the last court Petitioner appealed to the NC Court of Appeals (NCCOA) or
the NC Supreme Court?

D.) Notwithstanding Factual Innocence : Does the District Court 's analysis
that Plaintiff was legally innocent rather than Factually Innocent qualify
as a debatable claim for issuance of a COA, when this basis was used as
the justification for a procedural bar?

E.) Notwithstanding Factual Innocence : For the purposes of the District
Court relying on a procedural bar - Was Petitioner required to prove to the
District Court that he was not a felon, when Respondents had failed to
produce evidence of that element during trial?

Does the claim of Factual Innocence qualify as a debatable claim for the denial of a Constitutional Right