Petition for Writ of Certiorari — Byron Lee, Petitioner v. AT&T Services, Inc., et al.
Supreme Court briefNov 17, 2020
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A'
GRiGIsMAL
'•4
ZZD
to.
FILED
NOV 1 7 2020
IN THE
OFFICE OF THE CLERK
SUPREME COURT HR
SUPREME COURT OF THE UNITED STATES
r 1
'.i
BYRda/ Lee
— PETITIONER
(Your Name)
vs.
/p"
i Services,xtJc. /Padf;c &ell
— RESPONDENT(S)
ON PETITION FOR A WRIT OF CERTIORARI TO
"T'ME bhMTR C1R. CT. oF A7PS-AL S
(NAME OF COURT THAT LAST RULED ON MERITS OF YOUR CASE)
PETITION FOR WRIT OF CERTIORARI
BYRoN Lee
(Your Name)
H&SV-&U3 EAST Me. S
(Address)
PaLHDaLE, CA. 93E50.
(City, State, Zip Code)
A//A
(Phone Number)
Questions
1.)
Did
of
Appeals,
Los
Angeles'
commit
FEHA
violation(s)
neither
court
Ct.
2007
the
courts'
2.)
Did
of
Appeals,
California
Court
or The
Ninth
Protection
Under
The
Law
violation
or
Cir.
Ct.
case
directly
v.
FEHA
violation(s)
preemption
Kewit's
twosteps
judicial
both
lower
an
courts
subject
matter
failed
removal
Central
or
Angeles'
Superior
3.)
a
federal
to
federal
question
qualifier
to
a
law
California's
FEHA
4.)
Did
of
Appeals,
Los
granted
the
merits
violation(s)
Central
a
numerous,
Los
Protection
Under
The
Law
5.)
Did
The
Law
violation
In
6.) Did Los
of Appeals,
These
respondent's
petitioner
claim
from
Cir.
or
conflicts,
when
lower
complaint,
of
California
28 U.S.C
written
Superior
when
the
Duty),
of
The
Court
§
requests,
FEHA
Appeals,
to
courts,
Los
public
counsel,
based
solely
on
an
when
appellant's
to
a
district
complaint
is
face
legally
Law
violation
The
Ninth
proven
or
Cir.
when neither
plaintiff's
plaintiff's
Equal
Ct.
court
?
Equal
the
pleaded
remand
violation (s)
commit
violation (s),
or
1447 (c),
Court, violates
California's
properly
jurisdiction,
Under
Protection
court
Los
Under
denied
Angeles
The
appellant
District
n
?
Central District of California Court or The Ninth
an Equal Protection Under The Law violation or
neither
court,
written
requests,
alleging
Breach
of
Los
matter
a
Protection
against
status
of
Equal
when
7. J Did
subject
FEHA
Pauperis
face
Contract
violation (s),
union
the
Employment
Angeles
Ct.
on
of
FEHA
labor
remove
California's
Angeles'
commit
California's
with
to
jurisdiction
or
Ct.
decision.
or
Forma
violation
Cir.
conflicts
informal
to
Court
Law
The Ninth
direct
District
conflict
' back'
for
or
?
removal
in
plaintiff
(Breach
complaint
request
of
?
Ninth
Court
The
are
awards
an
Angeles'
plaintiff
support
state-court
presented
claim,
created
(substantial) test, to
decisions
Cir.
?
court,
state
when
matter
used
automatically
decide
conflict,
Ninth
preemption
Under
Ct.
subject
decisions,
question,
complaint,
be
the
decision
Cir.
California's
decisions, using the
California
Protection
statutes,
Court
of
related
affirmed
jurisdictions
complete
District
Equal
directly
motion
Ninth
complete
dependent
Angeles'
commit
related
their
substantially
Los
plaintiff
District of
Equal
supported
Burnside
Do
Central
an
or
Presented
addressed
Fair
plaintiff
Representative
numerous,
Duty
Cir. Ct.
California's
informal,
against
plaintiff's
?
Angeles
County
2018
Pro
Per
litigants
(including petitioner),
had
their
Summary - Judgement
Se
Clinic
zero
or
Los
Angeles
Clinic,
(Los Angeles'Public Counsel),
extremely
Public
California's
8.) Did
of
Opposition - motions,
limited
2018
Pro
Counsel,
an
Equal
FEHA
violation(s)
Los
Angeles'
Central
Appeals,
commit
FEHA
unexpectedly
alternative
County
affected,
Per
options,
between
Federal
Pro
The
Law
violation
Court
or
The
Se
or
?
District
of
California
numerous
court
records,
alleging
Contract
Duty
violation,
Angeles'
available
Under
addressed
Los
closure,
Protection
court
Employment
weeks
Angeles
Protection
of
with
plus
Los
Equal
Breach
Federal • Pro
and
neither
in
Angeles
litigants
an
allegations,
Los
ten (10)
communication
when
violation(s),
by
Under
The
Law
plaintiff,
Ninth
violation
informal,
or
plaintiff
Ct.
California's
written
Defendant/Appellee's
against
Cir.
committed,
employment
a
rights
?
9.) Did
Central
District
of
of Appeals, commit a Breach Of The
Fair Dealing Duty or California's FEHA
to
fully
or
decisions
?
10.)
Did
of
Appeals,
Los
California's
written
completely,
and
Angeles'
committed
FEHA
addressed
Central
an
video
copy
of
Court
or
Implied Covenant
violation(s), when
plaintiff's
District
Equal
violation(s),
California
of
Protection
complaint
California
Under
The
Cir.
Ct.
Of Good Faith And
the lower courts failed,
issues
Court
The
Ninth
in
or
Law
the
The
lower
Ninth
violation
courts
Cir.
or
when
neither
court
fulfill
plaintiff
request
for
his
September
13,
2017
deposition
transcript
a
?
Ct.
list
[x] All
parties
appear
[ ] All
parties
DO
A
in
NOT
list
of
all
parties
subject
of
this
petition
the
caption
appear
in
to
of
of
the
case
on
the
cover
caption
of
the
case
on
court
whose
judgement
is
Court.
Judgement
entered
February
27,
U.S.
Supreme
Court.
of
Workers,
the
the
proceeding
as
following:
is
parties
in
RELATED
Vaca
v.
Sipes,
No. 114,
Caterpillar
Inc.
v.
June
1987.
U.S.
Supreme
the
page.
the
cover
page.
the
CASE
1967.
9,
Builders
Court
&
of
Contractors
Appeals
Balcorta
v.
for
Ninth
the
Burnside
Williams,
for
Twentieth
v.
Circuit.
Kobold
v.
Appeals
for
Good
the
Local
the
Ninth
Judgement
entered
Samaritan
Ninth
302
Circuit.
No.
20,
Judgement
entered
No. 95-16202,
U.S.
entered
March
27,
98-56547,
U.S.
Court
of
Appeals
Appeals
for
the
U.S. Court
of
6,
1997.
2000.
U.S.
Court
of
2007.
Medical
Judgement
No.
April
04-57134,
June
Elec.
Judgement
Corp.,
entered
Regional
Circuit.
Intern,
Fox-Film
Pacific Corp.,
Judgement
86-526,
v.
Century
Circuit.
Kiewit
Ninth
No.
Center,
entered
No. 13-35528,
August
9,
2016.
TABLE
OF
CONTENTS
OPINIONS BELOW.
1
JURISDICTION
2
CONSTITUTIONAL AND STATUTORY PROVISIONS INVOLVED
3
STATEMENT OF THE CASE,
6
REASONS FOR GRANTING THE WRIT.
19
CONCLUSION
26
INDEX
APPENDIX
A
:
Decision
of
U. S. Court
APPENDIX
B
:
Decision
of
U. S.
APPENDIX
C
:
Order
of
U. S. Court
APPENDIX
D
Copy
of
Respondent's
APPENDIX
E
Copy
of
Plaintiff's
APPENDIX
F
Copy
of
Respondent
APPENDIX
G
:
Copy
of
Plaintiff
APPENDIX
H
:
Copy
of
Ninth
APPENDIX
I
:
Copy
of
Ninth
Cir.
APPENDIX
J
:
Copy
of
Ninth
Cir.
APPENDIX
K
Copy
of
Plaintiff's
APPENDIX
L
Copy
of
Respondent
APPENDIX
M:
APPENDIX
N
:
:
:
:
California's
:
Copy
of
Fair
TO
Of
Appeals
District
Of
Central
Appeals
For
AT&T - CWA
The
District
The
2012
2017
Court
Ninth
Of
Ninth
CBA
Circuit.
California.
Circuit
Article
Complaint
Removal
1
Denying
and
Capture
Granted
Docket
Fee
Letter.
Public
Counsel
Request
Form.
Public
Counsel
Request
Denial - Docket
Ct.
District
Ninth
Court
Time
Cir.
Ct.
Page
Appeal.
Extension
Answer
No.
Motion.
Brief
and
Housing
Act-Partial.
Deposition
Transcript
Request.
Page
9.
Rehearing.
Article
Motion.
Court
Employment
Plaintiff's
25,
Superior
District
For
Court
Janurary
Cir.
APPENDICES
7.05.
TABLE
'OF
AUTHORITIES
CITED
PAGE
CASE
Balcorta
v.
208
F. 3d
Builders
&
109
Caterpillar
482
v.
v.
Pacific
1053
Inc.
v.
Williams,
U.S. 386
(U.S. 1987)
Good
Samaritan
v.
Sipes,
386
U.S.
AND
,7,11.
Local
302
Intern,
of
Elec.
Workers,
6.
Corp.,
6, 7.
(9th cir. 2007)
1024
171
Corp.,
(9th Cir. 1997)
F. 3d
F. 3d
STATUTES
1353
Kiewit
832
Film
(9th Cir. 2000)
Contractors
v.
491
Vaca
1102
F. 3d
Burnside
Kobold
Twentieth ' Century-Fox
NUMBER
7, 8, 9,10.
Regional
(9th Cir. 2007)
(1967)
Medical
Center,
13.
14.
RULES
U.S. Const, amend. XIV
7, 9,10,11,12,14,15,16,17.
28
U.S.C.
§
1331
8.
28
U.S.C.
§
1367
,8.
29
U.S.C.
§
185
8.
-29—UtS.£—§—185(a)
8t
29
U.S.C.
§
185(b)
.9.
29
U.S.C.
§
185 (c)
,9.
28
U.S.C.
§
1447 (c)
29
U.S.C.
§§
151-169
Cal. Gov. Code
§§
,8,11.
7,10,11,12,13,14,15,16,17.
12900 -12996
,7,17.
NLRB
§
8
(b)(1)(A)
NLRB
§
8
(b) (1) (A)
Breach
of
repersentative
Duty
NLRB
§
8
(b)(1)(A)
Breach
of
Employment
Contract
Duty
NLRB
§
8
(b) (1) (A)
Breach
of
the
Covenant
of
Fair
7,10,11,12,13,14,15,16,
Dealing
Duty
Implied
17.
14.
15.
Good
.8,10,11,13,14,15,16,17.
Faith
and
IN THE
SUPREME COURT OF THE UNITED STATES
PETITION FOR WRIT OF CERTIORARI
Petitioner respectfully prays that a writ of certiorari issue to review the judgment below.
OPINIONS BELOW
[>0 For cases from federal courts:
The opinion of the United States court of appeals appears at Appendix _A
the petition and is
to
[ ] reported at
; or,
[ ] has been designated for publication but is not yet reported; or,
[x] is unpublished.
The opinion of the United States district court appears at Appendix JL
the petition and is
[ ] reported at
; or,
[ ] has been designated for publication but is not yet reported; or,
[x] is unpublished.
[ ] For cases from state courts:
The opinion of the highest state court to review the merits appears at
Appendix_____ to the petition and is
[ ] reported at
J or,
[ 1 has been designated for publication but is not yet reported; or,
[ ] is unpublished.
The opinion of the _
appears at Appendix
court
to the petition'and is
; or,
[ ] reported at
[ ] has been designated for publication but is not yet reported; or,
[ ] is unpublished.
1.
to
• JURiSDSGTTOM
[X] For cases from federal courts:
The date on which the United States Court of Appeals decided my case
was MA-Rch lb xoxo_________ #
[ ] No petition for rehearing was timely filed in my case.
[XI A timely petition for rehearing was denied by the United States Court of
Appeals on the following date: Toly A,-ao3&
, and a copy of the
order denying rehearing appears at Appendix
[X] An extension of time to file the petition for a writ of certiorari was granted
to and including
is n-M-icio (date) on
(date)
in Application No. __ A
• CoVl'D-H‘6,0 DAYS AUTOMATAc EXiEMS'iCti
The jurisdiction of this Court is invoked under 28 U. S. C. § 1254(1).
[ ] For cases from state courts:
The date on which the highest state court decided my case was
A copy of that decision appears at Appendix______
[ ] A timely petition for rehearing was thereafter denied on the following date:
_________ '____________ , and a copy of the order denying rehearing
appears at Appendix
[ ] An extension of time to file the petition for a writ of certiorari was granted
to and including____
(date) on
(date) in
Application No.__ A
The jurisdiction of this Court is invoked under 28 U. S. C. § 1257(a)
a
CONSTITUTIONAL
U.S. Const, amend. XIV.
subject
the
to
the
abridge
shall
any
process
born
or
jurisdiction
thereof,
are
citizens
of
state
shall
they
reside.
the privileges
deprive
law;
nor
No
or
immunities
of
person
life,
deny
to
the
laws.1
28
§
1331.
Original
jurisdiction
of
all
the United
States.
this chapter
is
not
dependent
28
§
1367.
Supplemental
U.S.C.
subsections
any
civil
shall
related
to
part
of
of
States,
the
United
States
and
of
make
or
enforce
any
law
which
citizens
the
of
the
United
States;
nor
property,
without
due
within
its
expressly
of which
the
district
jurisdiction
the
courts
arising
amount
in
' (a)
Except
original
all
other
jurisdiction,
the
district
claims
that
are
so
original
jurisdiction
that
they
form
or controversy
under
Article
III
of
the
supplemental jurisdiction
shall
include
claims
that
case
after
removal
generally,
the
of
defect
other
than
lack
days
after
basis
be
additional parties.1
any
made
section
within
1446(a).
30
If at
any
United
States
involve
the
(Appendix F)
time
'A
motion
to
remand
of
subject
matter
the
filing
of
notice
before
final
judgment
the
it
be
costs
any
the
expenses,
including
attorney
copy
the
State
removal.
A
certified
clerk
to
the
clerk
of
proceed
with
such
case.
29
U.S.C.
§
185.
Suits
29 H.S.C.
§
185
(a) .
contracts between
an
of
the
fees,
incurred
as
order
of
remand
shall
be mailed
court.
The
State
court
may
by
and
Venue,
against
amount,
and
a
industry affecting
commerce
as
defined
may
brought
States
having jurisdiction
be
of
the
parties,
3
labor
and
employer
organizations,
result
of
by
there
and
the
upon
(Appendix A, B, C, F)
an
labor
a
of
appears
that the district court lacks subject matter jurisdiction, the case shall
remanded. An order r emanding the case may require payment of just
actual
in
such
the action
Procedure
under
(Appendix F)
statute,
1447 (c),
removal
of
within
in
same
must
sections
Federal
§
jurisdiction
other
otherwise by
of
case on
of
in
intervention
the
treaties
provided
joinder
U.S.C.
original
as
Such
28
have
controversy.1
Constitution.
or
equal
laws, or
under
have
over
shall
Constitution,
questions
courts
the
and
J, K, M, N)
provided
jurisdiction
or
district
Jurisdiction,
as
in
liberty,
' The
federal
upon
have supplemental
United
under
or
claims
the
arising
INVOLVED
the
A, B, C, E, F, H,
Jurisdiction,
actions
(c)
action
courts
(Appendix
Jurisdiction
(b) and
of
any person
of
civil
naturalized
any
protection
U.S.C
PROVISIONS
persons
state
of
STATUTORY
' All
state wherein
shall
AND
labor
in
(Appendix F).
organizations.
citizerisfii p7 'Su its
organization
in
this
for
violation
representing
chapter,
or
of
“
employees
in
between
any
district
court
of
the
without
respect
to
the
amount
any
United
in
such
controversy
or
29
§
U.S.C.
without regard -to
citizenship
employees in
an
or
be
sued
in
the
courts
as
of
district
industry
in
only
against
organization
be
enforceable
29
U.S.C.
by
or against
§
against
185
any
(c),
labor
entity
the
organization
the
a
an
labor
affecting
commerce
affect
its agents.
and
United
in
behalf
Any
the
United
court
of
an
entity
as
member
Jurisdiction,' For
the
labor
of the
against its assets, and shall not
(Appendix F)
or his assets.
purposes
of
courts
actions
and
of
the
United
labor
organization
(1)
or
(2)
office,
or
agents
are
engaged
in
Congress
enacted
the
officers
employee members.'
(Appendix
employers,
to
labor
management practices,
workers,
encourage collective
businesses
and
the
bargaining,
rights
and
harm
which
of
to curtail certain
the general
can
(Appendix
U.S. economy.
the
States,
F)
29 U.S.C. §§ 151-169, NATIONAL LABOR RELATIONS ACT,
National Labor Relations Act ("NLRA") in 1935 to protect
of
proceedings
principal
duly authorized
welfare
be enforceable
its
which
and
shall
it
maintains
in
sector
whom
against a
a
organization
private
employees
of
which such
and
organization
money judgment
States
this
jurisdiction
in
its
such
in
have
district
for
defined
district
in
acting
to
as
this
the
be
in any district
representing or
deemed
in
courts shall
employees
(Appendix F)
and
individual
organizations
Any
States.
district
the
parties.1
entity
for
agent;
Any labor organization
commerce as defined in
and any employer whose activities
shall be
bound by the acts of
may sue
represents
of- the
185 (b).
Responsibility
for
acts
of
suit; enforcement of money judgments,'
purposes
of
which represents
chapter
chapter
the
A, B, C, E, F, H,
J,
K, M, N )
(1) to restrain
NLRB 5 8(b)(1)(A),
of the rights guaranteed in section 7
or
this
of
paragraph shall not
rules
own
(Appendix
with
impair
respect to
A, B, C, E, F, H,
the
the
right
union
has
duty
union
or
not-fairly,
in
virtually
every
action
as your
operating
representative,
cannot
to
exclusive
of
labor
this
in
title]:
organization
retention
of
Representative Duty,
in good faith, and
to represent
good
faith, and
that
a
including
all
union
the exercise
Provided, That
to prescribe
membership
halls.
process
a
grievance
or because you are not
ordinarily apply to rights
a
a
member of
worker can
in
because
a
have
without
whether
dealing
bargaining,“handling
example,
M
You
discrimination.
may take
collective
For
employees-
without
hiring
refuse
a
or
employees
its
therein.
J, K, M, N )
Your
to
[section 157
acquisition
NLRB § 8 (bj (1) (A), Breach of Fair
be represented by your union fairly,
the
(A)
coerce
a
right
to
discrimination.
members
of
the
This
duty
applies
with
an
employer
grievances,
and
union which represents you
you have criticized union officials
the union, But the duty does not
enforce independently - such as filing a
workers' compensation
claim - or
to
for
discipline members
NLRB
§
8 (b) (1) (A).
Act
forbids
the
exercise
of
improve
terms
activity.
Similarly,
the
Breach
National
restraining,
or
joining
from
working
of employment,
or
refraining
conditions
rights.
8(b)(1)(A),
Breach
Duty,
' An
will
in
good
faith
using
shifty
means
may
(Appendix
of
the
implied obligation
and
understood.
employment
employment
agencies,
that
to
assumes
with
The
apprenticeship
or
discrimination
FEHA
is
the
on
mental
to
a
the
labor
organizations,
person
or
doing
race
or
disability
any
of
Fair
contract
their
party
color; religion;
medical
conditions.
any
practice
forbidden
with
or
respect
testifying,
or
assisting
in
intended
to
reflect
the desires
judgment
proceedings
by
and
persons
5
It
marital
over the
age
FEHA
under
the
FEHA...the
positions
status;
40;
also prohibits
Act
of
or
of
the
strengths
aids,
prohibits
origin
by
the National
reasonable
national
The
who
act.
medical condition;
to
statute
entity
a discriminatory
related
are
parties
employers,
or
by the courts as to what
A, B, C, E, F, H, J, K, M, N )
the
and
California
opposing
governmental
Faith
principal
childbirth,
a
Good
the
pregnancy,
than
of
other
and
rather
in
what
age,
bargainingis
employees
denying
orientation;
of
labor
such
or
sexual
complaint,
any
a
breaking
or
a
from
in
to
without
sex
for
assisting
together
another
physical
against
or
employees
one
ancestry,
retaliation
disability;
that
programs and
coerces
based
Relations
A, B, C, E, F, H, J ,K, M, N )
discrimination covering
compels,
Labor
coerce
Covenant
avoid obligations,
(Appendix
or
right
E)
Implied
deal fairly
12900 -12996 .
prohibiting
not restrain
union's
coercing
or
these
employment
' The
the
E)
forming,
of
incites,
with,
(Appendix
purposes,
Dealing
abets,
interfering
Duty,
as
organizing,
and
§5
rules.'
Contract
organizations
Cal. Gov. Code
own
affairs - such
to
§
obviously
union
collective bargaining
NLRB
word,
its
labor
exercise
act
of
rights relating
for
internal
violating
employers from
organization
to
or
for
filing
outcome
the
parties
Labor
Relations
Board
or fair
results.'
(Appendix
or
STATEMENT
In
petitioner
OF
THE
CASE
judgement,
there
are
crucial
courts
Court
and
The
Ninth
Circuit
Court
of
Constitutional
and
Statutory
and
directly
related
to
patitioner
legal
District
decisions,
overlooked
to
Provisions
the
detriment
decisions
Appeals,
from
in
Los
conflict
Ninth
Angeles
with
U.S.
Ct.
case
Cir.
positions.
ARGUMENTS:
CBA
denotes
collective
bargaining
NLRB
denotes
National
Labor
Relations
Board.
NLRA
denotes
National
Labor
Relations
Act.
Argument
" Not
No.
every
1:
Wrongful
claim
which
agreement.
Complete
requires
a
labor-management
agreement
is
Local 302
added)
of
Elec.
Workers,
Central
District
of
petition's
state-court
Los
Angeles'
authority
as
Intern,
on
element
(APPENDIX
No. 4
D,
Preemption - Substantial
court
necessarily
California
on
petitioner's
defendant
sent
to
January 25, 2017 complaint.)
jurisdiction claim, ^ed to the
The
Cir.
2007 Burnside
v.
judicial
test process,
for courts
sole
purpose
jurisdiction,
According
(Breach
by
virtue
Kiewit
determing
the
presence
when
weighting
the
term
of
Burnside's
first
Employment
of
state
Builders
based
an
25,
&
of
federal
Contract
2017,
alteration
v.
(emphsis
jurisdiction
element,
filed
copy
a
Contractors
(9th Cir. 1997)
their
Employment
Janurary
language
listed
complaint
of
plaintiff's
decision.
of
to
of
the
The district court breach of employment contract
LMRA, subsection 301, complete preemption -
dependent
Ninth
to
1353,1357
Court,
plaintiff,
substantially
two-step
F.3d
Breach
refer
preempted",
109
(four),
to
Dependent.
Pacific
Corp.
case
to
use, as
judicial
or
absence
of
'complete
decision,
federal
factor:
whether
an
Contract)
involves
a
conferred
not
a
by
right
CBA. The
for
a
the
question
preemption. '
test
law,
established
guidelines,
asserted
district
court
upon
cause
an
analysis
of
action
employee .
of
plaintiff
cause—of—actions—involves—Californians—EEHA—rights__NOT—respondents—201-2—CBA-----rights.
Otherwise,
analyzing
the
Burnside's
district
court judge
would
have
ended
second
test
(substantially
dependent)
factor.
the
Lueck
line
of
301
inquiry
into
whether
" To
prevent
such
evasion,
its
progeny
require,
first,
an
G
section
the
his-
analysis,
preemption
asserted
cause
before
cases
of
and
action
involves
a
a
right
If
CBA.
conferred
the
2007)
(emphsis
According
by
virtue
of
state
law-,
not
by
exists solely as a result of the CBA, then the claim
our analysis ends there...If such dependence exists, then the
preempted, and
claim is preempted
law",
employee
right
is
state
an
upon
by
section
301;
if
v.
Kiewit
Pacific
Corp.,
Burnside
not,
then
491
the
claim
F.3d
can
proceed
1053,1059,1060
under
(9th Cir.
added)
substantally
to
Burnside second test factor:
can be resolved by look[ing]
dependent'
" whether
means
to versus interpreting the CBA.",
the claim
1053,1060 (9th Cir. 2007) (alteration
Burnside v. Kiewit Pacific Corp., 491 F.3d
added) (emphasis added) and not by the number of times or subject matters, a
a collective bargaining agreement.
look at' or ' refer to
court may need to
The Ninth Cir. previously
complete preemption, the
more than ' consider,'
Century-Fox Film Corp.,
stressed that, •" in
term interpret is
the context of subsection
defined narrowly~it means
301
something
or 'apply'", Balcorta v. Twentieth
or ' refer to
208 F.3d 1102,1108 (9th Cir. 2000) (alteration in orginal) (emphasis
added)
When
a
court
to
apply something more than
respondent mandatory 2012
look
at'
CBA,
Article
or
1 refer
to'
7.05
A
this
case.
3
or
' apply
(Appendix E)
or ' consider
incompletion, then a court will discover petitioner's breach of employment contract
element can be resolve without a court interpreting respondent CBA. Therefore,
petitioner
believes
complete
preemption
do
not
apply
in
petitioner's Breach of Employment Contract element, can be resolved,
without interpreting respondent's 2012 CBA, leads to Los Angeles Central District
of California Court and The Ninth Cir. Ct.'s, unlawful, recorded, breach of
Since
employment
contract,
federal
can not
stand,
without
America
judicial
system.
Petitioner
LMRA
believes,
does
not
and
jurisdiction
inflicting
the
preempt
a
district
any
this
matter jurisdiction over
cause of action.", Caterpillar
claim
national,
court
civil
29
151-169
U.S.C.
NLRB
§
§§
8
uniformity
minutes
order
decisions,
impact
onto
confirmed,
" If
of
plaintiff's
claims,
then
the
court
lacks
because
plaintiff
does
not
have
a
Inc.,
v.
Williams,
12900 -12996
(b) (1) (A)
preemption
action
—U.S.-Const. amend.-XIV-
§§
complete
negative,
added)
Cal. Gov. Code
and
7
482
U.S.
386,392(1987)
the
subject
federal
(emphsis
NLRB
Fair
§
8
(b) (1) (A)
Dealing
Argument
removal
No.
motion
question
district
back
to
complete
preemption
decision,
F,
of
defendant's
28
U.S.C.
Los
questions
raised
Minutes
Order
resolve,
without
matter
U.S.C.
issue
statute
remand
U.S.C.
Court,
sent
to
plaintiff,
Title:
Jurisdiction:
Central
District
by
defendant,
in
and
plaintiff's
interpreting
185
to
not
apply to
of
California
breachof
district
CBA,
Title:
Suits
petitioner
'by/
and
court
3.
Local
9504
petitioner
employment
behalf,
went
directly
interest,
during
defendant,
the
respondent
petitioner's
185 (a)
(FEHA)
petitioner
complaint
"
The
plaintiff
return
left
federal
legal
Motion,
U.S.C.
§§
removal.
claim
is
based
1367
dated / time
stamped
copy
petitioner's complaint,
denied
all
federal
24, 2018
Civil
contract (element No. 4),
can
district
be
court
claim
for
organizations:
Do
not
An
petitioner's
mandatory
Kennedy,
against
petitioner
185
damages
in
owe
to
then
Amount
and
Citizenship:
complaint
zero
Appeals
for
the
Ninth
on
petitioner,
Venue,
are
actions,
suit against
statute
there
of
separate
a
the
and
grievance
employment
on
collective
2015
best
based
invalid
union
proceedings.
§§
petitioner's
labor
lack
usage,
because
claim.
president
U.S.C.
the
labor
because
petitioner's
grievance
29
share
Title:
complaint,
district
to
suppress
2015
use
appropriate
state-law
the
to
labor union,
an
to
parties
wants
§
to
court September
' against'
A
U.S.C.
for
removed any
complaint,
Article 7.05
29
qualifying
Court,
employment
defendant
a
28
Do
the
decisions,
qualifier,
Removal
unfiled
procedure,
is
state-court
without
an
with
185
defendant's
jurisdiction.
§
§§
Faith ■ and
1447 (c)
and
defendant
Removal.)
§
185
§§
pretain
petitioner's
Good
2018
order,
Cause
participated
If
of
24,
301
Show
U.S.C.
of
motion,
subsection
a
28
Superior
masked
September
removal
LMRA,
29
Angeles'
subject
directly
Covenant
Removal.
court
1331.
1331
because
have
Angeles
Notice
§
cause
under
S§
district
established
should
Los
U.S.C.
The
show
legally
court
Respondent's
29
Court
decision.
a
(APPENDIX
Implied
Superior
state-court,
28
the
Improper
state-court,
or
The
on
2:
court
defendant's
of
Duty
district
The
Breach
is
U.S.C.
definition.
Do
grounded
bargaining
29
not, apply
in
agreement
to
California's
is
involved
in
federal
question(s)
legally
recognized
by
Circuit
reversed,
holding
that
case
court.
Court
was
improperly
were
not
of
removed...The
grounded,
either
court
directly
determined
or
8
that
indirectly,
respondents' state-law
upon
rights
or liabilities
the
claims
created
by
the
collective-bargaining
agreement...Since
require interpretation or application of
concluded that the complaint did not
respondents'
did
not
the collective-bargaining agreement..the
arise under § 301 and was not
court
removable to federal court.", Caterpillar'- Inc.
(1987) (alterations in original) (emphsis added)
29
U.S.C.
of
suit;
§
Title:
enforement
complaint,
any
185 (b)
because
United
of
Responsibility
money
petitioner's
States
Court,
for
judgement:
labor
because
union
U.S.C. §
185 (c)
Title:
Jurisdiction:
lacks subject
Williams,
acts
of
not
have
if
482
U.S.
386,390,391
enity
for
currently
apply
to
represent
petitioner
a
a
of action
agent;
not
do
enforcement of money judgement will apply
decision than the lower courts decisions.
29
v.
Do
petitioner
cause
state-law
review
claim.
produce
Do not apply to
matter jurisdiction.
purposes
petitioner's
interest,
in
The
a
different
petitioner's
complaint,
because the district Court
based on defendant
failure to establish a single federal question, recognized by Los Angeles' Central
District of California Court, to qualify as federal jurisdiction ground and a
complaint face, federal question,
interpreting respondent CBA.
"a
defendant
that
asserts
arising
cannot,
what
under
is
federal
jurisdition
qualified
merely
by
injecting
a
plainly
a
state-law
claim,
an
action
action
into
one
defenses
do not provide a basic, for removal.", Caterpillar
394 (1987) (alteration in original)(emphsis added)
Inc. v.
Williams,
482
U.S.
386,
28
U.S.C.
" in
any
civil
action
of
which
the
district
have
supplemental
over
all
court
other
Supplemental
have
claims
original
complaint,
because
erroneously
awarded
itself
of employment
CBA.
All
of
contract
respondent's
state-court
appeals.
claim,
failed
judicial
Petitioner's
well-pleaded
remand
Cir.
Ct.
before
Court,
district
a
national,
records,
negative,
so
related
to
Los
Angeles'
Central
District
matter
jurisdiction,
based
subject
Ninth
court
shall
element
state-court
and
claim,
without
federal
statutes
review
or
requests,
final
appellate
uniformity
Jurisdiction:
jurisdiction,
that are
petitioner's
since
into
the
without
federal
Title:
long
question
transform
reslovable
that
1367
has
federal
is
decided
§
law...Congress
element,
legal
claim".
having
used
stated
was
removal
onto
U.S. Const, amend. XIV
<1
apply
of
California
on
a
to
to
Court,
resolvable
interpret
breach
defendant's
remove petitioner
challenged by petitioner filed
are
impact
not
to
judgement
courts'
Do
jurisdiction
in
his
district
finalized.
Los
decisions,
can not
America
judicial
court
Angeles
system.
stand,
and
Superior
without
• 29
U.S.C.
NLRB
§
NLRB
§
Dealing
§§
151-169
8
(b) (1) (A)
8
(b) (1) (A)
Argument
No.
3:
Failed
Los
Angeles'
Central
The
presence
or
well-pleaded
when
Breach
of
the
Implied
Covenant
of
Good
Faith
and
Fair
confirmed,
"
Duty
a
complaint
of
which
is
believes
complaint
his
2012 CBA,
Court,
Inc.
to
on
v.
September
jurisdiction
provides
presented
Caterpillar
individual
California
Claim.
federal-question
rule,'
question
Jurisdiction
of
complaint.",
Petitioner
invalid
District
absence
federal
pleaded
Federal
that
24,
is
federal
2018
govened
by
jurisdiction
exist
the
face
of
the
Williams,
482
U.S.
386,392 (1987)
the
plaintiff's
consist
of
zero (0)
federal questions
dispute
the
district
court
federal
'
only
properly
and
an
jurisdition
claim
decision.
Since
plaintiff's
breach
of
employment
interpreting
respondent
CBA,
jursidiction
grounds
proceed
Defendant
refusal
led
plaintiff
to
to
released
language
and
federal
district
cause
a
court
of
contract
duty,
can
be
the
district
court,
lacks
subject
any
court
govern
by
in
participate
breach
plaintiff
of
with
from
any
or
federal
laws
legal
resolved,
federal
laws.
2012
CBA
grievance
contract
duty
claim.
obligations,
without
matter
procedure,
Respondent
under
defendant
2012
order,
failed
to
directly
element
federal
standing,
Angeles
Superior
Court
CBA
CBA
jurisdictions.
24,
breach
employment
of
parties
employment
September
addressed' plaintiff's
as
fully
file
behavior,
The
to
then
2018
civil
action
No. 4 (four),
on
District
of
Court,
minutes
contract
petitioner’s
Los
listed
complaint.
The
Central
contract
element,
as
complete
preexmption.
California
ground(s)
The
district
court's
federal
not
stand,
without
a
for
federal
jurisdiction
national,
used
jurisdiction,
claim
negative,
U.S. Const, amend. XIV
U.S.C.
NLRB
§
§§
8
and
151-169
(b) (1) (A)
to
breach
then
complete
uniformities
system.
29
plaintiff's
impact
of
employment
awarded
defendant
preemption
decision,
onto
America
can
judicial
NLRB
§
8
Dealing
(b)(1)(A)
Argument
No.
Los ■ Angeles'
4:
Failure
Central
dismissing
ALL
Angeles
district
court
activating
28
28
U.S.C.
U.S.C.
jurisdiction,
§
the
Implied
Covenant .of
Good
Faith
and
Fair
failed
24,
2018
Civil
defendant's
federal
questions,
should
have
moved
Los
away
any
federal
jurisdiction: claim
and
toward
court
remand
order,
subject
§
district
defendant
motion,
removal
was
civil
not
minutes
plaintiff
should
motion.
The
directly
addressed
order
decisions,
complaint
back
to
district court September
24,
2018
plaintiff's
judgements.
Therefore,plaintiff
's
summer
judgement
to
state-court,
summary
believes
the
2018
decisions.
24,.
overlooked
decision,
same
can not
onto
America
judicial
The
court
also
opined
court
held
that
California
state
federal
Los
statutes
in
gave
Notice
the
Angeles
District
Angeles
Superior
Court.
to
solitify
judge
should
have
acted
remand
plaintiff
judicial
decretion
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and
stand,
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by
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motion
The
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judgement
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Of
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order,
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upon
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back
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remand,
negative,
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impact
system.
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law
not
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the
motion written
using
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Century
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from
Twentieth
courts,
Angeles
remand
was
of
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2018
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lack
defendant's
24,
nonnegotiable
for
on
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Minutes
1447 (c)
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Throughout
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materized
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Remand.
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1447 (c)
occurred,; based
used
of
To
District
Order,
A
Breach
Duty
collective
Labor
right,
Code
and
required
Fox-Film
bargaining
for
Corp.,
§
that
agreement's
201.5
created
interpretation
resolution
of
208
F.3d
1102,1105
the
Implied
wages,
an
of
Balcorta's
" The
district
independent,
the
collective
bargaining
claims.",
Balcorta
(9th Cir. 2000)
(emphsis
v.
added)
U.S. Const, amend. XIV
29
U.S.C.
§§
151-169
NLRB
§
8
(b) (1) (A)
NLRB
§
8
(b) (1) (A)
Dealing
Argument
Breach
of
Covenant
Duty
No.
5:
Request
For
Public
11
Counsel - Denied.
of
Good
Faith
and
Fair
- Plaintiff
wanted
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1024,1036,1037 (9th Cir. 2016)
(alteration added)- (emphasis added) ■
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(b) (1) (A)
fair
dealing
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there are clear and convincing facts
petitioner belives
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of
good
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faith
believes
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lower courts. Petitioner's informal Ninth Cir. Ct. briefs and
appellate court
7.05 A 3 noncompliance actions, written in
overlooked by the
respondent's Article
concerning
record, will lead a court to consider,
are few legal penaties associated with
whether
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or
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defendant
noncompliance
behavior, when dealing
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with employees' working rights. These workers' . rights are
petitioner's courts records. Petitioner believe there are enough written facts in
the lower courts records, concerning respondent breach of the Covenant of Good
Faith
and
Fair
Petitioner
Dealing
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REASONS
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and
other
against
Southwestern
There
CEOs
and
relationships,
accusations,
will
to
personal
Americans.
When
based
unhealthy
events
class
unfairness
courts
in
corporations
charity
working
to
California, of bias, against some working class
treatment, towards America's business class corporations.
there
petitioner's
petitioner
system
Pacific
Bell
headquarter
because
in
SBC
in
1997
liberal
business
(AT&T
values
model
in
San
atmosphere,
values.
metropolitan,
maintain
available
California
SBC
in
cities,
conservative
San
Diego
and
that
image.
Orange
naturally
SBC
fits
SBC
conservative
County
conservative
lifestyles..
As
petitioner
ponded,
SBC's
San
Francisco
SBC
business
objectives,
for
their
San
San
Francisco
is
power.
California
condense,
area
past
Francisco. The
a consistent, violator
Francisco's
filthy,
corrupt
and
current
powerful
Court
of
mixture
of
political
alleys
and
dirty,
back
realization,
working
class
towards
America
working
class
Gaining
a
increased,
through
Californians,
highest
created a
he
quickly
realized
location.
pure
political
politicians,
Appeals,
is
lives
located
and
judicial
in
and
state
around
in
San
Francisco.
decades,
San
There's
power
and
money,
for
secret,
high
society
world,
is
huge
part
of
working
class
Californians.
corrupt
status
real
selection,
sense
mixture,
among
of
advance
hard
a
hopelessness
desperate
to
their
paying jobs
positions, to
became
more
difficult,
as
America's
oligarchy
social
their
San
operating
under
futures,
children
avoid
in
for
the
common
upward ' mobilities, .
parents,
back-breaking
status.
financial
across
our
of
Circuit
darkness, without any reproach. This
core sickness, that produces poverty
This
Francisco
California
Ninth
headquarter
all
country
edge
sectors.
biology, bloodlines
3io
and
these
California
corruption
structures
bloodlines
are
main
levels,
rooted
concerns,
deep,
are
control
and
If
Supreme
the
total
power,
Court
discover,
petitioner
judicial
system
over
select
was
America
daily
exsitence.
petitioner
case
for
(and
other Pro Per litigants),
(multiple
times
Los
Angeles
Appeals).
Ninth
Cir.
Ct.
of
and
his
family
loss
their
Petitioner's . wrongful
in
Purposely
true
petitioner
termination
claim,
is
worst
civil
action
our
time.
These
long
pro
bono
without upfront
full
seriously
David
strenght
of
employees,
petitioner legal
federal
institution,
our
verses
Goliath
America
story,
is
testimony
from
courts
Petitioner's
Angeles
Federal
dinner
receiving
handshakes
Lady Justice's
Flight.
members
U.S.
Supreme
to
and
the
Court.
legal
judicial
and
back
pats,
and
fair
judgement
blind
extension
motion,
requesting
Se
Clinic' to
reopen,
from
Angeles
to
silence
business
parties
or
held
prevented
in
system.
information
Counsel,
Powerful
Fight
time
Pro
Los
options:
fight,
any
greatest
through
two
prevented
America
Example:
Public
discussion
claim,
at
lower
receive
court
of
with
California
to
any
actions
considering
petitioner'scomplaint.
provided
of
civil
type
plaintiff
plaintiff's complaint
have
worthy
the
hard
left
aligned
in
sacrifice.
plaintiff
A
times
work and
as
stand,
multiple
either way,
respects,
we
and
unpurposely,
concerning
Here
court
California
through
system
payment,
through
quickly
earned
beliefs,
or
will
values,
courts
from
district
court
life
judicial
service
the
victimized
The
attorneys,
review,
County
and
2018
guidance
correctly
file
Pro
from
Pro Per
its
Per
Los
more
ten-plus
an
Federal
summary
to
weeks
litigants,
Angeles
litigants'
time
allow
Los
closure,
would
EQUAL
opportunity
Pro
Clinic
Se
judgement
opposition
motions.
After
defendent
countless
legal
pathway
for
/or
statutory
provisions
a
conflicts,
occurred
at
complaint
proceeded
legal
fair
violations and
is
a
reached
a
tipping
Through
petitioner'sQuestions
petition,
lies
favorable
through
Plaintiff
his
point
litigant,
claimed
conducted
inside
U.S.C.
1367
§
Los
and
Angeles
29
at their
Show
185,
a\
judgement,
to
appellate
decisions,
a
solid
plaintiff
constitutional
court
as
reflections
Cause
listed
to satisfy
grievance
corruption
Statements
Court,
fair
and
case
petitioner
structure.
business
and
Superior
U.S.C. §
due
representing
complaint.
Defendent
intact,
judicial
provoking
Example:
remain
court
thoughts
petitioner's
a
defendant
Presented
concerning
prevent
related
between pure
decisions,
to
directly
California's
class
bare,
blocks,
justice decision
each
working
road
of
upon
Removal
statutes
superior
claim,
that
and
blind justice.
the
Case
California's
Motion
sections of
lower
courts
hearing,
28
U.S.C.
§ 1331,
28
court
legal
grounds,
to
to
grant ‘ removal,
Los
Angeles
district- court,
against
an
angry
presiding
judge,
judgement.
of
None
defendant's
federal
invoked
statutes, in
validated in
cause removal motion hearing, were
Written then filed, in the district court
record
The
also
Central
question
District
raised,
Court,
ruled
against,
24,
every
2018.
bogus
federal
Left
defendant, through their summary judgement motion,
cause removal motion, without any federal question jurisdiction.
constantly,
requested
his
plaintiff's
informal
briefs,
through
§
California
September
on
show
Superior Court,
court decision.
by
defendant's show
Althought plaintiff
state-case,
28 U.S.C.
of
Los Angeles
the district
1447(c),
to
remand
complaint,
both
petitioner
be
lower
complaint
remand
courts
back
back
to
failed
to
Los
Angeles
to
activate
Superior Court, based on a lack of subject matter jurisdiction in the district
court. The district court claimed subject matter jurisdiction, under the plaintiffs
well-pleaded
dependent
complaint
on
rule.
Cited
defendant's
breach
of
employment
contract
is
substantially
CBA.
substantial dependent' decision
The Ninth Cir. Ct.'s 2007 Burnside decision, set
guidelines, for the court, to determine complete preemption claims. Substantial
dependent decisions ARE NOT judicial discretion options, at The Ninth Cir. Ct. of
Appeals.
Petitioner
arguments
against
the
district
court
complete
Presented
and
Petitioner filed an In Forma Pauperis request
appeal the district court decision. The district
substantial questions, by issuing a granted In
form
located under his petition's Questions
Question No. 1 and Arguement No. 1.
Ninth
At
Cir.
the
Ct.
of
Appeals.
Ninth
Cir.
Ct.,
Appellant
denied,
by
but
counsel,
was
had
the
his
Statements
with
the
of
claim,
are
the
Case,
district
court,
court judge agreed, plaintiff
Forma Pauperis appeal form
first
appellate
preemption
opportunty
court,
because
to
have
to The
to
receive
a
public
the
appellate
court
claimed, appellant filed his district court, In Forma Pauperis status (to represent
himself), with The Ninth Cir. clerk office, Petitioner argument against the court
public counsel decision, is . located under his petition's Questions Presented and
Statement
of
The
Ninth
Cir.
with
lower
courts
the
Ct.
Question
Case,
current
In
Forma
No. 5
practice
of,
Pauperis
current
litigants in the appellate court
public counsel request practice,
govern
under
Pro Per
The
Ninth
Cir.
.Ct.
and
of
Arguement
denying
status,
poverty
access
to
No. 5.
stricken
public
geography territory. The
is detrimental to every
Appeals.
A3L
Pro Per
counsel,
litigants,
affects, all
Ninth Cir. Ct.
Pro Per litigants
■ Petitioner's
petition,
issues,
multiple
other
related
Respondent
and
are
of
ten
mis-usages
of
directly
subjects
have
punitive
challenge
consist
from
to
to
by
created
upheld,
by
There
are
reasons
over
turned,
at
our
judicial
system.
corporate
federal
systems
corruption
accelerant
for
society
fever
pitch
higher
successful
their .dinner
Cir.
Ct.
decisions,
rate,
greater
than
opinion
for
and
a
normal
are
working
our
bed
witnessing,
collapsed.
frustations
hair
man
their
reasons
was
judge knew
unnessessary
seated
for
for
being
any
court
in
Ninth
other
Cir.
appellate
Ct.
writings,
high
are
some
form
fuel
masquerading
as
pitch
folks
and
Americans,
pillars'
of
tipping
points,
simutaneously
roils
into
eerie
feelings
Romans
as
their
high
level
systems
the
of
of
his
Court,
felt,
a
corruption
and
is
betting,
there
our
pitch
folk
years
journey,
into
our
courtroom
number
74,
citizens.
willing to
structures.
beginning
save
Petitioner
her,
five
listen
as
he
end
of
defendant
presentation,
complaint
is
a
case
state
to
from
the
two facts: Plaintiff
federal statutues.
rate,
contributing
everybody,
At
ratio
hate
(people's court)
above
a reputation
to
class
removal.
have
as
working
Superior
Angeles
legally
due
from
Inside
and
used
real-time,
the
friends
us,
a
at
political
corporations
unfairness,
of
buildings,
lies
America
legal
socialites.
legal
Burning
Petitioner optimism
judicial system.
petitioner
around
class
her
language
sense
rock
in
and
crumblings
strong
are enough working class Americans,
brothers and tyranny oligarchy social
Los
The
prevent
parties
Ninth
decisons
contractural
Some
judicial
case
by
to
conclusion.
provisions
petition.
1.0.Us,
slapping
Petitioner's
Ct.
bonded
back
ratio
institutions
tourch holders, as
gigantic bonefire.
great
The
reasons,
statutory
Cir.
petitioner's
outstanding
by
and
Ninth
corruption and judicial activist
Ninth Cir. judicial problems.
America's
are
a
America
why
a
involves system
factors to The
Americans
all
advancing
laws,
inside
millions
redeem
constitutional
related
listed
seventeen (17)
laws,
protected
matter,
(10)
defendant
and
a
white
attorney,
the
wise
defendant
state
old
inserted
The wise old judge closing remarks, remained inside petitioner mind, throughout
these proceedings: ' Counsel, this is a state case, but I granted your removal
motion
to
second
apple
bite
Those
remarks
seemed
meanings,
federal
when
the
court,
If you lose
state court.
in
fair
judge
to
plaintiff.
spoke
his
in
federal
Plaintiff
words,
33
but
court,
I
did not
fully
plaintiff
will
left
not
allow
you
understand
their
court
a
with
a
sense
of
a
fair
Petitioner
sense
(reasons
for
decision,
which
led
his
to
judicial
his
of
unfairness,
petition).
allowed
breach
but
federal
to
disagrees
contract
jurisdiction,
plaintiff thought
check
and
court
and
The
Ninth
Cir.
Ct.
the
federal
judge
for
writing
a
detailed
the
district
judge
thoughts
follow
Petitioner
of
of
in
commends,
plaintiff
overall,
system
began
Plaintiff
decisions.
preemption's
decisions,
judgement.
balance
with
the
district
court
primary
and
the
district
court
will
allow
plaintiff an
process,
that
complete
secondary
writing
jurisdiction
was
fair
opportunity
and
to
our
state
disagreements.
Plaintiff
was
request
for
a
public
filing
a
clarification
from
wrong.
relationships
with
ability
to
a
page
decisions.
first
fair
stated
The
appellate
Cir.,
dealt
court
denied,
then
prevented
appellant
or
not,
appellant
felt
appellee
personal
corrupt
courts
employees,
the
Next
came
affirming
the
issues
court
from
True
possiblely,
Basically,
Ninth
which
motion.
process.
any,
decision
counsel,
some,
addressing
final
The
inside
rebuke,
the
the
appellate
district
court
appellant's
arrived
court,
as
a
was
with
appellant
affecting
appellant
condescending,
findings,
without
four (4)
directly
Informal
opening
and
reply
timely
filed
rehearing
without
any
briefs.
motion
denial.
Once
again,
petitioner
is
a
Pro Per
litigant,
meaning,
training,
representing
the
worst
type
of
civil
action
claim (wrongful
competing
against
top
notch
law
firm
and
very
possible,
personal
and
/
judicial
a
employees,
Petitioner
is
with
still
legally
standing,
against
is
towards
respondent
legal
positions,
complaint,
because,
with
every
and
past
legal
violation,
that
The
district
labor
union,
Petitioner's
example
positions,
advanced
court
civil
produced
petitioner
minutes
a
very
a
iil
court
curiousity,
duty
and
breach
of
union
or
defendant,
These
missing
solid
the
decisions
constitutional
to
The
helpful
legal
NLRB
§
to
respondent
grounds
for
alleged,
employment
contract
duty
would
revealed,
missing
court
ask petitioner's
lead
a
to
breach
charges,
petitioner's
defendant
statutory
current
appeal
Court
front
door.
allegation
against
his
best
legal
interest.
positions,
An
why
theses
steps
was hot
completed.
Plaintiff's
responses,
will
lead a
court
to
breach
fair
<3 V
of
of
is
unlawful
fair
between
mandatory
defendant,
a
of
an
and
liable
8 (b) (1) (A).
petitioner
steps will
or
respondent.
decisions
strenght
collusion.
into
have
court
Supreme
government
with
towards
employment
represent
Just
court
to
petitioner
to
under
testament
petitioner
was
practices
favorable
confirms,
failing
emplloyment
those
order
union
established
relatioships
legal
termination),
corrupted
business
all
complaint
for
clearly
a
favorable
labor
that
or
recognized
representative
petitioner's
grievance
steps.
labor
union
or
labor
union
or
representative
duty
labor
defendant
and/or
breach
of- employment
courts,
decided
to
contract
dismiss
SBC/AT&T/PACIFIC BELL,
while
union
respondent
runs
roughshot
In
petitioner
own
case,
a
charges,
notorious
members'
his
decisions,
petitoner
have
employees,
duty
local
CBA
the
district
of
wrongfully
employees'
shamefully,
workers'
to
forced
respondent
A
3
a
satisfy
and
CWA
union
stand
idle,
when
rights.
failed
to
appellate
terminating
Article 7.05
grievance precedure,
ARBITRATION on petitioner behalf,
and
unproven.
representatives,
UNION
union
as
history
local
over
but
to
FAILURE
contractual
fulfill
TO
their
FILE
obligations
FOR
to
petitioner.
Petitioner is
betting,
not
a
local
field
office
(LFO),
level,
due
to
absent
a
an
single
dismissal
respondent
suits,
former employee,
advanced
corporation
passed
of
strong
his
employment
rights,
current
against
respondent
disdan
a
reading
the
evindences
inside
petitioner
superior
and
a
court
judicial
to
correct
workers'
will
wrong.
Petitioner
is
employment
fighting
rights
for
and
and
future
labor
for
workers'
rights
to
fair
of
petitioner's
Questions
Presented
and
his
petition.
employment.
Petitioner is
requesting
Statements
of
In
petitioner
closing,
the
full
Case
sections
of
will
lightly
touch
requests
to
the
to
rebutt
respondent slew
created
and
Petitioner
multiple
deposition
transcripts
copy,
context
deposition
statements,
support
respondent
legal
positions,
negative
uniformity
impact,
onto
Thanks
for
upon
lower
can not
America
one
other
courts for
a
filed,
stand.
in
issue
free
of
the
without
in
video
his
and
misleading and
lower
courts
inflecting
a
petition.
written
out
of
records,
to
national,
judicial system.
reading.
A—
Byron
Lee
//- / 7 - 2-oZe>
Date
IS
CONCLUSION
The petition for a writ of certiorari should be granted.
Respectfully submitted,
VXRort L££
Date: 11 -17-
36
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