Whether a petitioner must show 'civil disability' to obtain a writ of error coram nobis,

QUESTION PRESENTED ~ . 1. Whether a petifioner must show he ‘suffers from a “civil disabitity’"—that is, a collateral consequence that causes a substantial and present harm, is specific to the criminal context, and arises solely from the erroneous conviction— before a court can grant a . wit of error coram nobis, as the First, Second, Sixth, and Seventh Circuits have held, or whether a court may instead. presume that every conviction has collateral consequences that provide adequate standing to seek relief, as the Fourth, Ninth, and Eleventh Circuits have held? I: Whether a writ of error coram nobis should issue for a petitioner who presents “compelling” new evidence and intervening change of law that establishes his actual innocence of the.crime of conviction and as a continued collateral consequence loss of civil disabilities loss of right to vote or sit for jury trial? (il. Whether the Fifth Circuit requires more than actual innocence before a writ of coram nobis vacating the conviction could be issued. This holding conflicts with the hoidings of three other circuits (the Fourth, Sixth, Eighth, Nineth, Tenth and Eleventh) that actual innocence itseif is a basis for coram nobis refief. The Court should grant review to address the circuit spfit on this important question, and should hold that at least where advances in science establish innocence, coram nobis relief is appropriate? iv. Whether new evidence and controlling faw presented in CMS exhibits 82-142 can demonstrate insufficient evidence to support Givil or criminat charges for heafthcare fraud. Specifically, the question involves whether the District Court Judge erred in hofding that Petitioner's counsel! was constitutionally effective (new-evidence exhibit 80-81) and whether the Petitioner was guilty of treating without a specific referral based on a misinterpretation of CMS laws (exhibits 82-142; 90, 133, 140, 141, 142). Additionally, whether medical doctors should be held fiable as gatekeepers for non-compliant referrals, referencing CMS requirements and new evidence in exhibit 90, 133, 140, 141, 142 showing comptiance with CMS guidelines for routine foot care, which could invalidate the Petifioner’s conviction for wrongful treatment without referral. V. Whether the court erred in finding the referring medical doctor not guilty and the consulted podiatrist guilty for not instructing the medical doctor on how to write referral orders, which the court construed as healthcare fraud. Additionally, whether the consulted podiatrist, who follows directions in referral orders and patient charts according to CMS Certifying Orders/Referrals exhibits 82-142, 133; is wrongfully convicted of healthcare fraud because they cannot produce a "more specific order’ than. required by CMS. This question considers whether new evidence shows conflict between CMS guidelines and court : interpretations, highlighting plain errors that need correction to prevent manifest injustice and protect healthcare providers and public interest. vi. Whether the petitioner has satisfied the actual innocence prerequisites for coram nobis relief by demonstrating errors of fact against the Northem District Court of Texas in a felony conviction. This includes jurisdiction under 28 U.S.C. § 1332, involving a controversy amount exceeding $75,000, Nature of Suit 151 Medicare Act. The petitioner claims actual and factual innocence, presented in exhibits 80-142, and requests review by the Court of Appeals for the Fifth Circuit under 28 U.S. Code § 1291, highlighting the need to correct plain, factual, fundamental, constitutional, and procedural errors to prevent manifest injustice. * vii. Whether a petitioner can demonstrate new evidence, an intervening change in controlling law in CMS/HCFA Judicial Review Guidelines, Laws, and Rules presented in exhibits 82-142, to show that certifying orders/referrafs are not standing orders, and thus prove the court made errors in law. This includes whether federal courts can