Whether certiorari should be granted to clarify that probable cause must be based on actual facts, rather than mere assumptions interposed by the court during its review of those facts, and to clarify the proper appellate standards for 'waived' arguments

QUESTIONS PRESENTED I. Whether certiorari should be granted to clarify that probable cause must be based on actual facts, rather than mere assumptions interposed by the court during its review of those facts, and to clarify the proper appellate standards for “waived” arguments? I. Whether certiorari should be granted to clarify that when ineffective assistance of counsel causes a party to lose the right to even raise an issue on appeal, that scenario should be treated in the same manner as when an appeal is untimely filed because of ineffective assistance of counsel —i.e., since in both situations no appeal was possible, with prejudice arising from the loss of the right of appeal itself, the party should simply be afforded a new appeal, without the need to prove before that appeal is even briefed that he would also surely win that appeal on the merits? ii STATEMENT OF RELATED CASES There are no