QP: Whether reasonable jurists could debate the application of 18 U.S.C. § 2251(a) to video voyeurism and the procedural and substantive challenges to the petitioner's conviction

This Petition seeks an order granting a certificate of appealability or. in the alternative, plenary review of the following questions: 1) Whether reasonable jurists could debate whether 18 U.S.C. § 2251(a) — statute that carries a mandatory minimum penalty of 15 years ’ imprisonment and that applies to people who rape minors in order to produce child pornography — also applies to people who engage in video voyeurism, as the Ninth Circuit held in my case, or whether it does not, as the Third Circuit has held, where that statute's text makes clear that it does not, and where a forthcoming law review article explains that it does not. 2) Whether reasonable jurists could debate whether a defendant is estopped from raising a legal-innocence claim in habeas where he raised an claim on different grounds in direct review. 3) Whether reasonable jurists could debate whether my appellate counsel violated my right to the effective assistance of counsel and to autonomy over my own defense by incorrectly conceding over my explicit objection that I surreptitiously filmed a minor masturbating? 4) Whether reasonable jurists could debate whether my Trial Counselor provided Ineffective assistance of counsel by failing to file a Motion to Dismiss the Indictment or a Motion for Acquittal.