Whether newly discovered evidence, which directly undermines the reliability of the petitioner's conviction and establishes a plausible claim of factual innocence, meets the materiality threshold necessary to satisfy the demands of the Due Process Clause of the United States Constitution, where the evidence creates a substantial likelihood that no reasonable juror, acting fairly, would have convicted the petitioner in light of the totality of the evidence?

ISSUES PRESENTED FOR REVIEW Whether newly discovered evidence, which directly undermines the reliability of the petitioner's conviction and establishes a plausible claim of factual innocence, meets the materiality threshold necessary to satisfy the demands of the Due Process Clause of the United States Constitution, where the evidence creates a substantial likelihood that no reasonable juror, acting fairly, would have convicted the petitioner in light of the totality of the evidence? Page 3 of 40