Kovacs v. U.S., 744 F.3d 44, 54 (2d Cir. Mar. 3, 2014) (No statute of limitations governs the filing of a coram nobis petition. See Foont, 93 F.3d at 79. At the same time, the petitioner must demonstrate sound reasons for any delay in seeking relief. Id. The critical inquiry ... is whether the petitioner is able to show justifiable reasons for the delay. Id. at 80.).

The court stated:

Kovacs has supplied sufficient reasons to justify the delay. He avers that he has diligently pursued ways to reenter the country, but was unaware that a writ of coram nobis existed until October 2011"and contacted the Government soon thereafter. The Government is skeptical about the recent discovery of a writ so ancient. Morgan, 346 U.S. at 506, 74 S.Ct. 247. When such a disputed issue of fact arises, we typically remand for a hearing. Under present circumstances, however, no hearing is needed because it is improbable that Kovacs (or whatever attorney he consulted) would have promptly thought about coram nobis, which is as arcane as it is ancient. The writ is an extraordinary remedy available only in rare cases. Id. at 511, 74 S.Ct. 247. Further, the Government does not suggest any tactical reason Kovacs would have delayed pursuit of the writ until 2011 if he had learned of it earlier. Lastly, the focus on the filing date of the petition insufficiently accounts for Kovacs' efforts to negotiate for an agreed-upon motion in 2011. We conclude that Kovacs' petition was timely.

(Id. at 54.) See also United States v. Kwan, 407 F.3d 1005 (9th Cir. 2005).