What constitutes a legally sufficient standard of diligence for pursuing coram-nobis-relief

QUESTION PRESENTED As petitions for writs of error corum nobis are not subject to any formal deadlines nor any statutes of limitations, the nation’s courts generally deny relief in the absence of any “sound reason” for delay as suggested by this Court in United States v. Morgan, 346 U.S. 502, 512 (1954), including offering no reasons at all, prejudice or harm to the respondent, or those cases in which the petitioner appears to be abusing the writ. What constitutes a “sound reason” for delay has been left to the lower courts to answer and define in their discretion on an ad hoc basis. Mr. Yadigarov, by this petition, presents the question as to what should constitute legally sufficient diligence, as a matter of law, in the pursuit of coram nobis relief; asked differently, what specific and express standard of care should uniformly govern the requirement of presenting “sound reasons” for any perceived delay in filing petitions for a writ of error corum nobis? li PROCEEDINGS IN FEDERAL TRIAL AND APPELLATE COURTS DIRECTLY RELATED TO THIS CASE Petitioner, Zafar Bakhramovich Yadigarov, was the defendant and the petitioner in the district court and the appellant in the court of appeals. Respondent, the United States of America, was the original plaintiff and respondent in the district court and the appellee in the court of appeals. The related cases include the following: United States District Court (M.D. Fla.): United States v. Zafar Bakhramovich Yadigarov, No. United States Court of Appeals (11th Cir.): United States v. Zafar Yadigarov, No. 18-14405-JJ (Feb. 13, 2019) United States v. Zafar Yadigarov, No. 20-10857DD (Jan. 8, 2021), also available at 840 F. App’x 487 (11th Cir. 2021) (unpublished).