Could-reasonable-jurists-debate-whether-the-district-court-abused-its-discretion

QUESTIONS PRESENTED FOR REVIEW 1. Could reasonable jurists debate whether the district court abused its discretion by denying as untimely Petitioner’s motion to amend to add a Brady v. Maryland claim when government suppression was the reason for the earlier unavailability of the exculpatory evidence at issue? 2. Where a key factual dispute at trial was if Petitioner understood Arabic words spoken during a recorded conversation with an undercover agent, could reasonable jurists debate whether trial counsel provided ineffective assistance by failing to consult or retain an Arabic language expert to opine on the recording and government’s translation? i