Whether a plea agreement to return illegally seized property in exchange for a guilty plea, induced by the prosecutor, is breached when the prosecution and police later renege after a defendant is sentenced, refuse to return all of his illegally seized property, and turn over items that never belonged to him to begin with.

2. When a plea agreement induced by the prosecutor is comprised of a defendant pleading guilty in exchange for the return of property belonging to him that has already been ruled illegally seized in violation of the Fourth Amendment and suppressed, is the plea agreement meaningless and illusory?

3. Is a defendant's right to due process and access to the courts violated when they are advised by the trial court that they are waiving "a jury['s]" right to appeal, rather than their own, then not allowed to appeal on grounds of federal retroactive change in law due to that waiver?

4. When a new rule and newly recognized right on fourth amendment standing is pronounced, must the case announcing that new rule and recognized right be applied retroactively to all cases pending at the time of the announcement, specifically Carpenter v. U.S.,585 U.S.___(2018)?

5. Is counsel's assistance deficient when he fails to investigate or acquire exclupatory evidence as well as the facts and integrity of a prior conviction and also fails to lodge a challenge to it during prdicate felon adjudication proceedings?

6. Whether the right to due process is violated when a judge threatens to enhance a defendant's sentence for exercising his right(s).

7. Whether federal precedent mandates that a state court proceed to the "credible and compelling" prong of analysis when a defendant presents newly discovered evidence on a claim of actual innocence.

8. Whether People v. tiger, 32 NY3d 91(2018) unconstitutionally forecloses and undermines federal standards of actual innocence claims on a state level, thus automatically foreclosing and preventing first-instance review by the state in circumvention of O'Sullivan v. Boerckel,526 U.S. 838(1999).

9(a). Whether a state prosecution is barred and a state lacks jurisdiction when accusatory instruments are twice defective.

9(b). Whether the complete lack of a court's jurisdiction over a defendant in a criminal case is of a constitutional, rather than merely a jurisdictional, demension.

Whether a plea agreement to return illegally seized property in exchange for a guilty plea, induced by the prosecutor, is breached when the prosecution and police later renege after a defendant is sentenced, refuse to return all of his illegally seized property, and turn over items that never belonged to him to begin with