Whether the Court should adopt a definition of reasonable doubt and whether the District Court erred in applying sentencing guidelines related to perjury and self-defense

1. Whether this C ourt should adopt and encourage, when requested by a party, a definition of reasonable doubt to include “ a doubt that would cause a reasonable person to hesitate to act in a matter of importance” and not defining reasonable doubt would violate the Fifth Amendment requirement of a finding of guilt be made beyond a reasonable doubt and the Sixth Amendment’s requirement of a unanimous verdict? 2. Whether the District Court erred in applying U.S.S.G. §3C1.1 when failing to make specific findings on the elements of perjury and where the circumstances show Mr. Biel’s testimony was due to faulty memory which he realized when confronted on cross -examination at trial and apologized, the defense did not reference Mr. Biel’s testimony thereafter, and defense counsel stated the decision to call Mr. Biel as a witness was purely counsel’s strategic decision? 3. Whether the District Court erred in not applying U.S.S.G. §5K2.10 when its explicit reason for doing so was the jury rejected Defendant’s claim of self defense at trial, failed to address any of the 6 factors/criteria under U.S.S.G. §5K2.10, and failed to identify any relevant case -specific reasons for not applying U.S.S.G. §5K2.10? ii LIST OF DIRECTLY