Carter's claims that he did not have a fair criminal trial that comports with constitutional due process do not fit within the actual innocence equitable tolling doctrine. To the extent that Carter claims there were errors of law in his Michigan criminal proceeding, the actual innocence equitable tolling doctrine does not apply. Craig v. White, 227 Fed. Appx. 480, 481 (6th Cir. 2007); Harvey, 179 Fed. Appx. 298-99; Ross, 417 Fed. Appx. at 555; Nash v. Woods, 2012 WL 70571, * 6 (W.D. Mich. Jan. 9, 2012); Cable v.Woods, 2010 WL 502722, * 4 (W.D. Mich. Feb. 5, 2010). B. Traditional Equitable Tolling

To the extent that Brown claims there were errors of law in his Michigan criminal proceeding, the actual innocence equitable tolling doctrine does not apply. Craig v. White, 227 Fed. Appx. 480, 481 (6th Cir. 2007); Harvey, 179 Fed. Appx. 298-99; Ross, 417 Fed. Appx. at 555; Nash v. Woods, 2012 WL 70571, * 6 (W.D. Mich. Jan. 9, 2012); Cable v. Woods, 2010 WL 502722, * 4 (W.D. Mich. Feb. 5, 2010). B. Miscarriage of Justice Exception and Actual Innocence

Although Carballea is proceeding pro se and is untrained in the law, this circumstance does not warrant equitable tolling. Ignorance of the law, even for incarcerated pro se habeas petitioners, generally does not excuse the late filing of habeas petitions and does not justify equitable tolling of the statute of limitations. Allen, 366 F3d at 403-04; Craig v. White, 227 Fed. Appx. 480, 482 (6th Cir. 2007); Harvey v. Jones, 179 Fed. Appx. 294, 299-300 (6th Cir. 2006); Jagodka, 148 Fed. Appx. at 347; Winkfield v. Bagley, 66 Fed. Appx. 578, 583 (6th Cir. 2003). 2.

The material facts and evidence in Nash's underlying criminal case and trial have not changed. At this juncture Nash does not offer any new reliable evidence showing that he did not in fact commit the criminal acts for which he now stands convicted. Where a habeas petitioner asserts claims based on alleged errors of law, the actual innocence equitable tolling doctrine does not apply. Craig v. White, 227 Fed. Appx. 480, 481 (6th Cir. 2007); Harvey, 179 Fed. Appx. 298-99; Ross, 417 Fed. Appx. at 555; Cable v. Woods, 2010 WL 502722, * 4 (W.D. Mich. Feb. 5, 2010). In sum, Nash's claims that he did not have a fair trial that comports with constitutional due process do not fit within the actual innocence equitable tolling doctrine.

Petitioner's assertion that his habeas claim has merit also does not establish his actual innocence. Craig v. White, 227 Fed.Appx. 480, 481 (6th Cir. 2007). In sum, the affidavits submitted by Petitioner, in light of the evidence as a whole, do not provide a credible claim of actual innocence.

His assertion that his habeas claims have merit, e.g., that he acted in self-defense or lacked the required intent for first-degree murder, does not establish his actual innocence. See, e.g., Craig v. White, 227 Fed.Appx. 480, 481 (6th Cir. 2007). His own self-serving, conclusory assertions of innocence are also insufficient to support an actual innocence claim.

Petitioner's assertion that his habeas claims have merit also does not establish his actual innocence. Craig v. White, 227 Fed.Appx. 480, 481 (6th Cir. 2007). Habeas relief is not warranted on this claim.

The fact that Petitioner is untrained in the law, was proceeding without a lawyer, or may have been unaware of the statute of limitations for a certain period does not warrant tolling. See Allen, 366 F.3d at 403-04; see also Craig v. White, 227 Fed.Appx. 480, 482 (6th Cir. 2007); Harvey v. Jones, 179 Fed.Appx. 294, 299-300 (6th Cir. 2006); Martin v. Hurley, 150 Fed.Appx. 513, 516 (6th Cir. 2005); Fisher v. Johnson, 174 F.3d 710, 714 (5th Cir. 1999) (“[I]gnorance of the law, even for an incarcerated pro se petitioner, generally does not excuse [late] filing.”).

His assertion that his habeas claims have merit does not establish his actual innocence. See, e.g., Craig v. White, 227 Fed.Appx. 480, 481 (6th Cir. 2007). Moreover, any self-serving, conclusory assertion of innocence is insufficient to show actual innocence.

As previously noted, actual innocence means factual innocence, and without new and reliable evidence sufficient to demonstrate that it is more likely than not that no reasonable juror would have convicted him, Bell's innocence claim fails to rescue his untimely § 2255 motion.See also Craig v. White, 227 Fed.Appx. 480, 481 (6th Cir. 2007) (Where a habeas petitioner asserts claims based on alleged errors of law, the actual innocence equitable tolling doctrine does not apply); Harvey v. Jones, 179 Fed.Appx. 294, 298-99 (6th Cir. 2007) (similar). In his amendment, Bell elaborates on the law relating to the actual innocence tolling doctrine, but he makes no effort to demonstrate therein that he is entitled to tolling under this doctrine.