Whether Petitioner demonstrated the requisite 'diligence' and 'extraordinary circumstances' to warrant equitable tolling

QUESTION PRESENTED Whether Petitioner, a mentally ill prisoner serving a 110-year prison sentence, whose appellate counsel led him to believe that no further legal challenges to that sentence were possible following conclusion of direct review, and who filed a pro se motion to vacate, pursuant to 28 U.S.C. § 2255, with reasonable diligence after learning of the availability of that vehicle, demonstrated the requisite “diligence” and “extraordinary circumstances” to warrant equitable tolling, such that this Court should remand to the United States Court of Appeals for the Second Circuit with instructions to issue a certificate of appealability?