1. Did Coggins ' Public Defender 's (Weber) entering into a joint defense
agreement with Coggins ' co-defendant 's (Tabor) lawyer without Coggins '
knowledge or consent constitute ineffective assistance of counsel in that this had the
effect of leaving Coggins without any defense when the District Attorney dismissed
Tabor in the middle of the trial, in that Coggins ' Public Defender had made no
preparation for trial and had subpoenaed no witnesses? In 2018, Coggins discovered
for the first time following his trial in 2006 that his court-appointed Public Defender
(Weber) had, without his knowledge or consent, entered into a joint defense
agreement with his co-defendant 's (Tabor) lawyer. (Dkt. 14-3, pp.1-34). The
evidence implicating Tabor was available to Weber prior to trial and showed that
there was physical evidence in 2001 tying Tabor to the stabbing (blood), that Tabor
had a motive (self-defense) in that the victim (Smith) had attacked him, and that
Tabor had made admissions in 2001 to a deputy (Deputy Dennis Mack) at the scene
and to Tabor 's then-girlfriend (Whitney Varna) that he had stabbed Smith in self
defense?

2. Did the District Attorney, without disclosing to the trial court the
admissions made by Tabor to Deputy Mack in 2001 and without disclosing to the
trial court the content of Osborne 's and Roberson 's letters, mislead the trial court
and in turn, the jury, in violation of this Court 's holdings in Napue v. Illinois, 358
U.S. 919 (1958) and Glossip v. Oklahoma , 604 U.S. , 145 S.Ct. 612 (2024), by
moving to dismiss the charges against Tabor, which in essence had the effect of the
District Attorney 's telling the jury that Coggins stabbed Smith?

3. In light of the fact that the late filing of Coggins ' Federal habeas case
was caused by his pro bono lawyer 's assuming that the days during which his
previous Petition for Certiorari before this Court was pending did not count, is
Coggins ' late filing of his Federal habeas claim entitled to equitable tolling under
Holland v. Florida, 560 U.S. 631 (2010); Christian v. Roper , 574 U.S. 373 (2015),
in that Coggins is actually innocent or does this Court 's decision in Lawrence v.
Florida , 549 U.S. 327 (2007) foreclose the right of this Court to grant the relief
sought?

4. Is Coggins actually innocent of the murder charge for which he was
convicted when the jailhouse snitch (Osborne), who was previously represented by
Coggins ' Appellate Counsel (Johnson), admitted to Johnson and to others that he
had never even met Coggins ' co-defendant, Barry Tabor, that co-defendants were
never housed together, and that his court testimony and letters were pure
fabrication?

5. Should the State have disclosed the implied deal it had with Osborne
under

Did Coggins' Public Defender's joint defense agreement without his knowledge constitute ineffective assistance of counsel, potentially leaving him without a defense?