ineffective assistance of counsel.” Hernandez, supra, 242 F.3d at 114 (citing Jones v. United States, 167 F.3d 1142, 1145 (7th Cir.1999)). However, as a number of courts have found, to allow an ineffective assistance of counsel claim to come forward under Section 2255 and bypass a valid waiver of appellate rights, the scope of inquiry is limited to “those discrete claims which relate directly to the negotiation of the waiver [or the plea agreement] ... ”, Jones, supra, 167 F.3d at 1145, and to the “validity of the plea or the waiver.” United States v. Cockerham, 237 F.3d 1179, 1187 (10th Cir.2001); see also United States v. White, 307 F.3d 336, 343-44 (5th Cir.2002); Davila v. United States, 258 F.3d 448, 450-52 (6th Cir.2001); United States v. Johnson, 347 F.3d 412, 415 (2d Cir.2003) (<HOLDING>). As with all ineffective assistance of counsel
recognizing such limitations in dicta holding that the statute of limitations is nonjurisdictional and defendant expressly waived it observing in dicta that a statute of limitations defense should be raised no later than the trial recognizing limitations existence in other circuits recognizing that alternative holdings are not dicta recognizing such an exception