Use the Tracking Comment feature to note that you looked at the KeyCite flags AND indicate, which, if any source, has a red flag; If you find a red flag do NOT do further research, just note it. If a source does not have a red flag, note that you checked and there was not a red flag. ARGUMENT John Doe should be granted leave to file a second habeas petition because newly discovered evidence raises serious questions about Mr. Doe's innocence as well as the integrity of the jury verdict rendered against him. It would constitute a fundamental miscarriage of justice to execute Mr. Doe without a single court meaningfully reviewing the merits of the scientific evidence supporting his actual innocence claim. See Calderon v. Thompson, 523 U.S. 538(1988)(credible claims of actual innocence overcome procedural bar); U.S. v. Crevini, 379 F.3d 987(10th Cir. 2004) (new reliable evidence of actual innocence overcomes procedural bar). New and reliable evidence has come to light that demonstrates that Mr. Doe's jury was presented with "false facts" by the prosecution at trial. These "facts" appeared to strongly support an inference of guilt, but now have been objectively disproved. First, the jury heard testimony and