Whether Douglas Krusley qualifies for equitable tolling due to prison lockdowns and inability to access legal resources when filing a federal habeas corpus petition

PETITION FOR EQUITABLE TOLLING, DUE TO INABILITY TO ACCESS LIBRARY AND RESOURCES AND ON THE MERITS OF PETITIONER KRUSLEY'S CASE AT BAR? THE QUESTION HERE IS-THIS ? WHETHER PETITIONER QUALIFIES FOR EQUITABLE TOLLING DUE TO INABILITY TO ACCESS THE LIBRARY AND OTHER RESOURCES AND ON THE MERITS OF BEING ACTUALLY INNOCENT? WHETHER THE PETITIONER DOUGLAS KRUSLEY IS LEGALLY LIABLE FOR THE EQUITABLE TOLLING, BECAUSE UNDER THE BRADY VIOLATION, PETITIONER IS NOT LIABLE ? WHETHER PETITIONER'S CLAIM OF ACTUAL INNOCENCE IS ENOUGH EVIDENCE TO TOLL THE STATUTE OF LIMITATIONS ? WHETHER THE PETITIONER, DOUGLAS KRUSLEY IS ELIGIBLE FOR EQUITABLE TOLLING, DUE TO THE GROUNDS OF INABILITY TO ACCESS THE LIBRARY AND OTHER RESOURCES AND ON THE MERITS OF BEING ACTUALLY INNOCENT ? PETITIONER DOUGLAS KRUSLEY ARGUES THAT HE IS ENTITLED TO EQUITABLE TOLLING, DUE TO LOCK-DOWNS AND LACK OF ACCESS TO THE LAW LIBRARY. • PETITIONER ALLEGES THAT INSTITUTIONAL LOCKDOWNS GENERALLY DON’T ' . HAPPEN, BUT WHEN THEY DO, THIS WOULD REQUIRE EXTRAORDINARY ■ CIRCUMSTANCES THAT WARRANT THE GRANTING OF EQUITABLE TOLLING. PETITIONER CONTENDS THAT PRISON AUTHORITIES MADE IT IMPOSSIBLE FOR HIM TO FILE DOUGLAS KRUSLEY ’S WRIT OF FEDERAL HABEAS CORPUS PETITION BY THE DEADLINE, BECAUSE DOUGLAS KRUSLEY*S ALLEGATIONS WARRANT FURTHER DEVELOPMENT OF THE RECORD, THEREFORE, PETITIONER WOULD HUMBLY ASK THIS GREAT AND HONORABLE UNITED STATES SUPREME . COURT, TO REMAND BACK TO THE COURT, FOR FURTHER PROCEEDINGS. SEE LOTT V. MUELLER , 304 F. 3d 918, (9th Cir. 2002). PETITIONER ’S REMANDING FOR FURTHER PROCEEDINGS WHERE DOUGLAS KRUSLEY ’S ALLEGATIONS, REQUIRE AN APPLICATION OF THE RECORD FOR EQUITABLE TOLLING. THE PETITIONER PLAINLY CLAIMS THAT "HE" DOUGLAS KRUSLEY ’’HIMSELF" WROTE THE COURTS ASKING FOR HIS CASE FILE, BUT TO FIND OUT THAT IT WAS MISSING PAGES AFTER IT FINALLY ARRIVED, AT THE NORTHPOINT TRAINING CENTER, P.O. BOX 479 BURGIN^ KENTUCKY. SO, I DOUGLAS KRUSLEY HAD TO THRSWITHE WRIT FOR FEDERAL HABEAS CORPUS, TOGETHER VERY QUICKLY. IF THE EVIDENCE SUPPORTS PETITIONER DOUGLAS KRUSLEY ’S ALLEGATIONS THAT PRISON CONDITIONS MADE FILING THE PETITION TIMELY, THEN DOUGLAS KRUSLEY ’S ALLEGATIONS UNDERMINES PETITIONER DOUGLAS KRUSLEY ’S CLAIM THAT PRISON CONDITIONS MADE A TIMELY FILING BY A PRO-SE PRISONER LITERALLY IMPOSSIBLE (CITING RANDOV. ROWLAND , 154 F. 3d 952, 958 (9th Cir. 1998) WE HAVE PREVIOUSLY SAID, THE "IMPOSSIBILITY" REQUIREMENTS SHOULD NOT BE STRICTLY IMPOSED, BECAUSE IMPOSING EXTRAORDINARILY HIGH EVIDENTIARY STANDARDS ON PRO-SE PRISONER LITIGANTS WHO HAVE ALREADY FACED AN UNUSUAL OBSTACLE BEYOND THEIR CONTROL DURING THE AEDPA LIMITATION PERIOD-RUNS AGAINST THE GRAIN OF OUR PRECEDENT. PETITIONER DOUGLAS KRUSLEY ALREADY FACED A-LOT OF PROBLEMS CONCERNING HIS HEALTH, FAMILY AND PRISON LIFE IN GENERAL, THIS EXTRAORDINARY CIRCUMSTANCES ARE SOME-WHAT TO MUCH FOR ANY-ONE WITH MEANINGFUL PROBLEMS. THEREFORE, THE PETITIONER, DOUGLAS KRUSLEY CLAIMS THAT TO ENSURE THAT A PRISONER'S ACCESS TO THE COURTS IS ADEQUATE, EFFECTIVE AND MEANINGFUL, (QUOTING BOUNDS V. SMITH , 430 U.S. 817, 822, 97 S. Ct. 1491, 52 L. Ed. 2d 72 (1977). ALSO IN HOLLAND , 130 S. Ct. AT 2563. OFTEN THE EXERCISE OF A COURT'S EdUITY POWERS. MUST BE MADE ON A CASE-BY-CASE BASIS. PETITIONER DOUGLAS KRUSLEY GOES ONE STEP FURTHER BY ATTEMPTING TO PURSUE HIS CLAIMS ABSENT LIBRARY ACCESS. SEE UNITED STATES V. OAKES,445 FED. APPX. 88, 94 (10th Cir. 2011). (UNPUBLISHED). (FIRST QUOTING) LEWIS V. CASEY , 518 U.S. 343, 351 (1996). AN INABILITY TO ACCESS LEGAL MATERIALS CAN ALSO MERIT EQUITABLE TOLLING. THE CIRCUMSTANCES IN PETITIONER'S DOUGLAS KRUSLEY CASE AT BAR, IS A NEED FOR "BOTH" EXTRAORDINARY AND BEYOND THE LITIGANT'S CONTROL. AS IN, MENOMINEE INDIAN TRIBE V. UNITED STATES , 577 U.S. 250, 257 (2016). EQUITABLE TOLLING IS APPROPRIATE IN RARE AND EXCEPTIONAL CIRCUMSTANCES SUCH AS PETITIONER DOUGLAS KRUSLEY'S CASE AT HAND BECAUSE THE KENTUCKY PRISONER DOUGLAS KRUSLEY IS ACTUALLY INNOCENT OF THE CHARGED OFFENSE. T— N.' TH