Whether the Supreme Court holding in Session v. Dimaya vacates administrative charges under the 'residual clause' of 18 U.S.C. §16(b)

question presented for review on grounds consistent with Petitioner’s actual innocence is: 1. Whether The Supreme Court holding in Session v. Dimaya vacates each and every administrative allegations and charges bearing upon the “residual clause” of 18 U.S.C. §16(b) as a “crime of violence” by Respondent because the April 17 holding provided that the residual clause of 18 U.S.C. §16(b) defining “crime of violence” was unconstitutionally vague — that is, too arbitrary and indistinct to comport with the constitution’s guaranteed of due process. ld 1212 — 18? And In light of the January 20 22, 2021 Executive.Order Of President Joseph R. Biden That Bans Deportation Or Removability? _ Undisputed facts show the presence of COVID-19 virus at the Rush City Facility where Petitioner is currently detained by Respondent. See the Memorandum(s) filed in the district court record regarding the positive COVID-19 cases found in Rush City Facility in Udoh v. Knutson, Civil No. Docket No. 106 at. 11; Udoh v. Dooley, Civil No. 0:16-CV-4174 (PAM/HB), as well as, in the Administrative Record. The third, fourth and fifth questions presented for review on grounds consistent with Petitioner’s actual innocence is: 2. Whether The Board Of Immigration Appeal Should Have Granted Petitioner’s Request For Extension Of Time Due To Petitioner’s Lack Of Access To The Prison Law Library Resulting From The Spread Of Covid-19 Coronavirus Pandemic In Minnesota Department Of Corrections in light of Bound v. Smith, 480 U.S. 817 (1977); and Flittie v. Solem, 827 F.2d 276, 280 (8th Cir. 1987)? And In light of the January 20 22, 2021 Executive Order Of President Joseph R. Biden That Bans Deportation Or Removability? 5 Petition By Udoh Page ii 3. Whether The Board Of Immigration Appeal Should Have Granted Petitioner's Request For Extension Of Time To Obtain The Record And Transcripts Of The Immigration Hearings To Fully And Fairly Present His Case For Reopening In Light of Bound v. Smith, 480 U.S. 817 (1977)? And In light of the January 20 22, 2021 Executive Order Of President Joseph R. Biden That Bans Deportation Or Removability? 4. Whether The Board Of Immigration Appeal June 24, 2020 Order That | | Affirmed The In-Absentia Order Is Invalid In Light Of (A) Petitioner's Actual Innocence Clearly Demonstrated In The Administrative Record (B) Petitioner's Ongoing Proceedings In State And Federal Courts; (C) Petitioner’s Notification To The Court Of This Change Of Address On February 2019 Pursuant To 8 U.S.C.S. §1305; (D) The Fact That Notice To Appear And Hearing Was Not Sent To Petitioner's Address After The Change As Required Under 8 U.S.C.S. §1229(A); And (E) This Absentia Order Violates Petitioner’s Due Process For Failure To Notify Petitioner Of His Hearing And To Appear Even: Where Petitioner Never Spoke Or Saw A Judge, Was Never Call Or Subpoenaed To Any Hearing, Never Participated Or Consented In Any Telephonic Conference In light of Ghounem v. Ashcroft, 378 F.3d 740 (8th Cir. 2004); Williams — Igwonobe v. Gonzales, 437 F.3d 453 (5th Cir. 2006)? And In light of the January 20 22, 2021 Executive Order Of President Joseph R. Biden That Bans Deportation Or Removability? Petition By Udoh Page iii