Whether the 2009 amended version of 18 U.S.C. §1014 was retroactively applied in violation of the Ex Post Facto Clause

question presented is — ; whether the United States Court of Appeals for . the Second Circuit contravened this Court’s precedents by denying Michael Bouchard’s Motion for a Certificate of Appealability (COA Motion) and Motion for Panel Reconsideration & Reconsideration en banc for Mr. Bouchard to : obtain review of his claim that the indictment and _ the manner in which it was prosecuted violated the Constitution’s Ex Post Facto Clause by retroactively applying the 2009 amended version : of §1014 to pre-amendment alleged conduct? Il. Under Strickland v. Washington, 466 U.S. 668 (1984), this Court held that the Sixth Amendment -guarantees criminal defendants the right to the effective assistance of counsel for their defense. The question presented is whether the United States Court of Appeals for the Second Circuit contravened this Court’s precedents and Circuit ; Courts’ precedents by denying Michael Bouchard’s , Motion for a Certificate of Appealability and Motion for Panel Reconsideration & Reconsideration en banc for Mr. Bouchard to | GSViSOSH | 1 ggas e$ BAM : {owas gecagaanae | ii QUESTIONS PRESENTED (continued) obtain review of his claim that he was denied effective assistance of counsel, and, Mr. : Bouchard’s claim that the cumulative effect of the . 27 prejudicial errors by defense counsel also denied him effective assistance of counsel? ZI. Michael Bouchard filed a motion with the district court for an evidentiary hearing regarding a Brady, Giglio, Jencks claim raised in his §2255 ; proceeding. The government did not oppose the motion. But, the district court ignored the motion. Mr. Bouchard then moved the Second Circuit for a Writ of Mandamus ordering the district court to schedule the hearing. The district court then abruptly denied Mr. Bouchard’s §2255 petition, discovery motion, and motion for an evidentiary hearing. The question presented is whether the United States Court of Appeals for the Second Circuit contravened this Court’s precedents and ; Circuit Courts’ precedents by denying Michael Bouchard’s Motion for a _ Certificate of Appealability and Motion for Panel Reconsideration & Reconsideration en banc for Mr. Bouchard to obtain review of his claims that ~ he was entitled to an evidentiary hearing regarding the Brady, Giglio, Jencks claim, and, that the district court usurped the authority of the . Second Circuit to decide the necessity of an evidentiary hearing on a constitutional issue? j ’ PROCEEDINGS IN FEDERAL APPELLATE COURTS THAT ARE DIRECTLY RELATED TO THE CASE IN THIS COURT : Court In Question: U.S. Court of Appeals for the Second Circuit, Docket# 19-1913 | | . Caption: ‘Michael G Bouchard, PetitionerAppellant v. United States of America, Respondent-Appellee : ' Date of Entry of the Judgment: 11-14-19 and 12-27-19 ’ Court In Question: U.S. Court of Appeals for the ; Second Circuit, Docket# 19-1037 Caption: In Re Michael G. Bouchard, Petitioner Date of Entry of the Judgment: 7-8-19 Court In Question: U.S. Court of Appeals for the Second Circuit, Docket# 14-9008-am . Caption: Jn re Gaspar Castillo, Attorney. ; : Date of Entry of the Judgment: 1-18-18 Court In Question: U.S. Court of ‘Appeals for the , Second Circuit, Docket# 14-4156-cr Caption: United States of America, Appellee v. Michael Bouchard, Appellant : . Date of Entry of the Judgment: 7-7-16