1) Did the district court create a split in circuits by denying relief
on charges —in the indictment that violated Congressional Intent/ where
the D-C. and Fifth Cirucits both gave other defendants relief for' the
identical crimes charged that had identical indictment defects?

2) Does it violate the Constitution under the Double Jeopardy Clause
to charge Movant with the same crime/ then dividing a single conS-
spiracy between two indictments/ convicting Movant on the second,
indictment then'dropping the first indictment after Movant was convicted
the second indictment? on

3) Does it violate the Constitution and the Supreme Courts holdings
in Apprendi v. New Jersey to increase Movants sentence for an alien
smuggling conspiracy charge above the statutory maximum without any
explanation for the district court?

4) Does it violate the Constitution for the district court not tot::eint \after the government filed appoint counsel upon request of Movant
a second idiscovery with new details of this case?

5) Did the District Court allow the Government to violate the Supreme
Courts ruling in Brady v. Maryland at trial and at sentencing?

Whether the district court violated constitutional rights by denying relief on indictment charges, charging the same crime across multiple indictments, increasing sentence beyond statutory maximum without explanation, failing to appoint counsel, and potentially violating Brady v. Maryland