1. A writ of certiorari is requested to determine whether the district court's loss
calculation which included intended losses under §2B1.1 Application Note 3 of the Sentencing
Guidelines and the losses attributed to alleg ed co-conspirators was erroneous in light of this Court's
decision in Kisor v. W ilkie, 588 U.S. 558 (2019).

2. A writ of certiorari is requested to determine whether the district court's final bank
fraud instruction to the jury constructively amended Count Three of the indictment, charg ing bank
fraud [18 U.S.C. §1344] , by including the elements of both subsections 1 and 2 of the statute when
the indictment, which did not articulate the subsection being charg ed, only included lang uage that
tracked subsection 2.

Whether the district court erred in its loss calculation under the Sentencing Guidelines by including intended losses and losses attributed to alleged co-conspirators, and whether the bank fraud jury instruction constructively amended the indictment