To satisfy the 'knowingly' and with 'intent' in 18 U.S.C. § 1029(A)(3), do Courts have to prove precise 'mens rea' as set forth in Rehaif v. United States 588 U.S.-- (2019) and Flores-Figueroa v. United States 556 U.S. 646, 650, 129 S.Ct. 1886, 173 L.Ed.2d 853?

QUESTIONS PRESENTED. 1) To satisfy the "knowingly" and with “intent in 18 U.S.C. § ~ 1029(A)(3), Do Courts have to prove precise "mens rea" as set. forth in Rehaif v. United States 588 U.S*-(2019) ana Florestte tates : =-Ofes~ Figueroa v. United States 556 U.S. 646 650, 129 S.ct. 1826 173 ; LED.2d 853. ; ° 2) Do jury. instructions have to be sufficient and list charged and uncharged conduct or does. either party have a right to choose without interuptions. , . v MEMORANDUM , Comes now, Petitioner Trayone Lefferio Bell, who files this motion pro-se prays this Court construes this liberally. ; Haines v. Kerner 404 U.S. 519 (1972). Petitioner prays the . ; Court grant certiorari, vacate the judgment of the District Court and remand for new trial. ; . Question (1) To satisfy the "knowingly" and with "intent" in 18 U.S.C. § 1029(A)(B),. do Courts have to prove precise "mens rea" as set forth in Rehaif v. United States’ 588)-U.S.--(2019): and : Flores Figueroa v. United States 556 U.S. 646, 650 129 S.Ct. 1886 173 L.Ed. 2d. 853? ; : Petitioner was charged with 18 U.S.C. § 1029(A)(3), ithe statute reas as follows 18 U.S.C. § 1029(A)(3): Whoever (3) "knowingly" and with "intent" to defraud possesses fifteen or mores devices which are counterfeit or unauthorized access devices. "The words "knowingly" and "intent" appears more than 2,577 , times in statutes written by Congress to prove "mens rea" is difficult because Courts have to take into consideration the defendant's actual mindstate. The United States Constitution requires proof beyond a reasonable doubt of every element necessary to constitute the crime." See Federal Habeas Corpus Practice and Procedure 9.1 N. 27 quoting Hall v. Haws 861 F.3d ; vi , 977 (9th Cir. 2019) ("standard state jury instruction that ' ‘allowed'the jury to. infer guilt of murder from evidence that defendants were in possession of recently stolen property plus slight collaborating evidence ‘violated due process' because . ' presumed fact does not follow from the facts established.'") . The word "knowingly" means having or reflecting knowledge. See Webster's Collegiate Dictionary 2001. The knowingly nor the ; ! "intent" of the 18 U.S.C. § 1029(A)(3) statute was not met when Petitioner was given erroneous jury instructions. Petitioner requests a remand based on the fact the question{s] presented , ‘ and the constitutional violations that occurred are similar to . the issue in Rehaif v. United States 588 U.S.=-(2019). In Rehaif, Justice Breyer wrote: "In determining Congress, ‘intent' we start from a longstanding presumption, traceable to the common law, that congress “intends' to require a defendant to possess a culpable mental , : state regarding ‘each of the statutory otherwise innocent conduct.'" Rehaif quoting United States v. X-Citement Video Inc. 513 U.S. 64, 72, 115 S.Ct. 464, 170 L.Ed 2d 372 (1994). See also Morissette v. United States . 342 U.S. 246, 256-258, 72 S.Ct. 240, 96 L.Ed. 288 (1952). Wherefore Petitioner prays that this Court grant certiorari vacate the judgment of the lower courts and remand in light of Rehaif v. United States 588 U.S.--(2019). . vii Question (2) Do jury instructions have to be sufficient and list charged and uncharged conduct or does either party have a right to choose without interuptions? ; Petitioner exercised his right to go to trial. Whereas the evidence that was brought to trial was very scant and insufficent. The jury instructions were inadequate and did not state the specific facts about Petitioner's "intent" nor if Petitioner "knowingly" committed the crime alleged. Petitioner did not fulfill the "actus reus" however the jury was given an erroneous instruction. , At trial, the Government stated "that even though we have no finger prints nor proof of Mr. Bell's involvement in the crime, he is in fact guilty." Those statements tainted the jury and, violated Petitioner's due process rights. See Musacchio v. United States 136 S.Ct. 709 (2015). See also Jenkins v. H