note that "we ordinarily do not address ineffective-assistance arguments on direct appeal, especially where, as here, the factual basis for the claims is not well developed.” United States v. Duka, 671 F.3d 329, 353 n. 18 (3d Cir. 2011). 4 . Our certificate of appealability directed the parties to focus on three issues: (1) the impact of the Waiver on Murray's claim concerning his right to effective assistance of counsel on direct appeal; (2) whether a § 2255 petition is the proper vehicle for such a claim; and (3) whether Murray’s rights were, in fact, violated by a denial of his right to effective assistance of counsel on direct appeal. In light of our conclusion concerning the first issue, we do not reach the second and third issues raised in our certificate. Mabry, 536 F.3d at 242
holding obliquely raising issue in footnote insufficient to surmount waiver threshold holding that a failure to file an appeal is within the scope of the waiver because the failure does not undermine the validity of the plea or waiver holding that a plea agreement with a waiver of direct appeal rights does not include a waiver of collateral remedies because the government could have included a waiver of collateral rights in the plea agreement and chose not to do so holding that the validity of a collateral waiver is a threshold issue holding that collateral review of the validity of a jury waiver in the absence of a rule 23a writing is not available absent any indication the defendant was prejudiced by the technical error