Petition for Rehearing — Peter Williams, Petitioner v. Environmental Protection Agency, et al.

No. 23-1059

In the Supreme Court of the United States

PETER WILLIAMS,

Petitioner,

v.

ENVIRONMENTAL PROTECTION AGENCY, ET AL.,

Respondents.

ON PETITION FOR WRIT OF CERTIORARI

TO THE U.S. COURT OF APPEALS

FOR THE DISTRICT OF COLUMBIA CIRCUIT

PETITION FOR REHEARING

LAWRENCE J. JOSEPH

Counsel of Record

1250 Connecticut Ave. NW

Suite 700-1A

Washington, DC 20036

202-355-9452

ljoseph@larryjoseph.com

Counsel for Petitioner

TABLE OF CONTENTS

Table of Authorities.................................................... ii

Petition for Rehearing ................................................ 1

Statement of the Case ................................................ 2

Reasons to Grant Rehearing ...................................... 3

I. This Court’s Harrow decision is an

intervening, controlling precedent that

affects the justiciability of petitioner’s claims. ... 5

II. Rehearing is required to avoid issue

preclusion’s denying the forum the Clean Air

Act and APA provide............................................ 6

III. This Court should “GVR” the case to the

Court of Appeals. ................................................. 7

A. APA action is viable. ..................................... 7

B. Declaratory relief is available, even if

other review is unavailable. .......................... 8

C. The nonjurisdictional nature of the 60day provision allows consideration of

issues such as prudential ripeness. .............. 9

D. The APA and § 307(d) apply different

timing criteria to EPA’s action—and

inaction—on administrative petitions. ....... 10

Conclusion ................................................................ 11

Certificate of Counsel ............................................... 12

ii

TABLE OF AUTHORITIES

Cases

Abbott Labs. v. Gardner,

387 U.S. 136 (1967) ............................................... 8

Adamo Wrecking Co. v. United States,

434 U.S. 275 (1978) ............................................... 1

Amoco Oil Co. v. EPA,

501 F.2d 722, 731 (D.C. Cir. 1974) ..................... 10

BellSouth Corp. v. FCC,

162 F.3d 678 (D.C. Cir. 1998) ............................... 3

Bennett v. Spear,

520 U.S. 154 (1997) ............................................... 8

Business Roundtable v. SEC,

905 F.2d 406 (D.C. Cir. 1990) ............................... 3

California v. Texas,

141 S.Ct. 2104 (2021) ............................................ 9

Clean Water Action Council of Northeastern

Wisconsin, Inc. v. United States EPA,

765 F.3d 749 (7th Cir. 2014) ................................. 2

Cohen v. Beneficial Indus. Loan Corp.,

337 U.S. 541 (1949) ............................................... 8

Cort v. Ash,

422 U.S. 66 (1975) ................................................. 3

Cutter v. Wilkinson,

544 U.S. 709 (2005) ........................................... 1, 5

Dickinson v. Zurko,

527 U.S. 150 (1999) ............................................. 10

Doe v. McMaster,

355 S.C. 306 (2003) ............................................... 3

Dozier v. Ford Motor Co.,

702 F.2d 1189 (D.C.. Cir. 1983) ............................ 6

iii

Durfee v. Duke,

375 U.S. 106 (1963) ............................................... 6

Eisen v. Carlisle & Jacquelin,

417 U.S. 156 (1974) ............................................... 8

Envtl. Def. Fund, Inc. v. Ruckelshaus,

439 F.2d 584 (D.C. Cir. 1971) ............................... 8

EPA v. EME Homer City Generation, L.P.,

572 U.S. 489 (2014) ............................................... 2

Growth Energy v. EPA,

5 F.4th 1 (D.C. Cir. 2021) ..................................... 2

Harrow v. DOD,

144 S.Ct. 1178 (2024) ............................ 1-2, 5-6, 11

Idaho v. Coeur d’Alene Tribe of Idaho,

521 U.S. 261 (1997) ............................................... 4

In re Tennant,

359 F.3d 523 (D.C. Cir. 2004) ............................... 9

Interstate Commerce Comm’n v. Bhd. of

Locomotive Eng’rs, 482 U.S. 270 (1987) ............. 11

Lawrence v. Chater,

516 U.S. 163 (1996) ............................................ 5-7

Louisiana Envtl. Action Network v. Browner,

87 F.3d 1379 (D.C. Cir. 1996) .......................... 9-10

Mathews v. Eldridge,

424 U.S. 319 (1976) ............................................... 8

Mike Hooks, Inc. v. Pena,

313 F.2d 696 (5th Cir. 1963) ................................. 6

Miller v. Harco Nat’l Ins. Co.,

274 Ga. 387 (2001) ................................................ 3

Nat’l Airlines, Inc. v. C.A.B.,

392 F.2d 504 (D.C. Cir. 1968) ............................... 8

Nat’l Labor Relations Bd. Union v. Fed. Labor

Relations Auth., 834 F.2d 191 (D.C. Cir. 1987) . 11

iv

Powell v. McCormack,

395 U.S. 486 (1969) ............................................... 9

Safari Club Int’l v. Jewell,

842 F.3d 1280 (D.C. Cir. 2016) ............................. 8

Steffel v. Thompson,

415 U.S. 452 (1974) ............................................... 9

Tr. Co. of Ga. v. State,

109 Ga. 736 (1900) ................................................ 3

Zukerman v. United States Postal Serv.,

64 F.4th 1354 (D.C. Cir. 2023) ............................. 9

Statutes

Administrative Procedure Act

5 U.S.C. §§551-706 ........................... 3-4, 6-8, 10-11

5 U.S.C. § 555(b) ....................................................... 10

5 U.S.C. § 559 ........................................................... 10

5 U.S.C. § 706(1) ....................................................... 10

5 U.S.C. § 706(2)(A) .................................................. 10

28 U.S.C. § 1291 ......................................................... 8

28 U.S.C. § 2106 ......................................................... 5

All Writs Act,

28 U.S.C. § 1651(a) ............................................... 9

28 U.S.C. § 2201(a) ..................................................... 9

28 U.S.C. § 2202 ......................................................... 9

Federal Tort Claims Act,

28 U.S.C. §§ 2671-2680 ......................................... 7

Clean Air Act,

42 U.S.C. §§ 7401-7675 ....................... 1-4, 6. 10-11

42 U.S.C. § 7607(b) ................................................... 10

42 U.S.C. § 7607(b)(1) ................................................ 1

42 U.S.C. § 7607(d) ...................................... 4, 7, 10-11

42 U.S.C. § 7607(d)(1) .......................................... 4, 10

v

42 U.S.C. § 7607(d)(1)(a)-(u) ...................................... 4

Rules, Regulations and Orders

Sup. Ct. R. 44.2 ................................................. 1-2, 5-6

Other Authorities

Charles Warren, Federal and State Court

Interference, 43 HARV. L. REV. 345 (1930) ............ 4

1

PETITION FOR REHEARING

Pursuant to this Court’s Rule 44.2, petitioner

Peter Williams respectfully seeks rehearing of the

Court’s denial of his petition for a writ of certiorari.

Under this Court’s supervening decision in Harrow v.

DOD, 144 S.Ct. 1178 (2024), the Clean Air Act’s 60day time within which to petition for review, 42 U.S.C.

§ 7607(b)(1), is a claims-processing rule. Because the

60-day provision is not the jurisdictional bar on which

the Court of Appeals dismissed Williams’ petition, a

“GVR” Order granting, vacating, and remanding is

the best course to evaluate several issues unique to

the Clean Air Act generally and to the specific

program under which Williams petitions to review

action by the Environmental Protection Agency and

its Administrator (“EPA”). While this Court would

have jurisdiction to review those merits issues in the

first instance, the Court is “a court of review, not of

first view,” Cutter v. Wilkinson, 544 U.S. 709, 718, n.7

(2005). In Harrow, this Court held that 60-day

provisions like the one at issue here are claimsprocessing rules, not limits on a Court of Appeals’

subject-matter jurisdiction. Harrow, 144 S.Ct. at

1181. That warrants a GVR order here.

Further, the District of Columbia Circuit’s special

place within the Clean Air Act’s judicial-review

program1 warrants its input on how to proceed, now

that Harrow upends that court’s longstanding

See 42 U.S.C. § 7607(b)(1) (review of nationally applicable

rules channeled to the D.C. Circuit); Adamo Wrecking Co. v.

United States, 434 U.S. 275, 283-84 (1978) (review channeled to

the “single court intimately familiar with administrative

procedures” to “insur[e] that [the Clean Air Act’s] substantive

provisions … would be uniformly applied” nationwide).

1

2

position that the 60-day provision is jurisdictional. See

Clean Water Action Council of Northeastern

Wisconsin, Inc. v. United States EPA, 765 F.3d 749,

751-52 (7th Cir. 2014) (citing the D.C. Circuit’s history

of incorrectly applying the 60-day provision as

jurisdictional). Williams raised this issue in opposing

EPA’s motion to dismiss his petition as

jurisdictionally untimely, but he did not raise it in his

petition for a writ of certiorari.2 Thus, under Rule 44.2,

the non-jurisdictional nature of the Clean Air Act’s 60day provision would be an “other substantial grounds

not previously presented” that justifies rehearing,

even without Harrow.

STATEMENT OF THE CASE

This is a case of mistaken identity in which

Williams applied as an individual, but—by letter

dated March 31, 2022, and noticed in the Federal

Register on April 5, 2022—EPA chose to interpret his

application to be on behalf of a defunct corporation.

Through counsel, on April 20, 2022, Williams quickly

petitioned EPA administratively to reconsider EPA’s

error, but EPA has not acted on the administrative

petition for reconsideration in over two years. What is

worse, the program in question involves an annual

allocation so that each new year that EPA delays

correcting its now-obvious legal and factual error

delays Williams’ entrance into the program.

Compare Pet.’s Opp’n to Mot. to Dismiss 19 (Apr. 17, 2023)

(citing Clean Water Action Council of Northeastern Wisconsin,

765 F.3d at 751-52, and EPA v. EME Homer City Generation,

L.P., 572 U.S. 489, 512 (2014)) with Order (July 7, 2023) (citing

Growth Energy v. EPA, 5 F.4th 1, 12–13 (D.C. Cir. 2021)) (Pet.

App. 2a).

2

3

Specifically, EPA’s denial of Williams application

assumes that his trade name (“New Era Group”) as an

individual made the applicant the defunct Georgia

corporation New Era Group, Inc., which EPA

considers ineligible for the program. Using “New Era

Group” as a “dba” or trade name cannot equate an

individual applicant with the corporation:

An individual doing business under a trade

name is clearly a sole proprietor distinct

under Georgia law from a corporation in

which that individual holds stock.

Miller v. Harco Nat’l Ins. Co., 274 Ga. 387, 390 (2001);

see also BellSouth Corp. v. FCC, 162 F.3d 678, 684

(D.C. Cir. 1998) (“it is obvious that there are

differences between a corporation and an individual

under the law”). Moreover, “[c]orporations are

creatures of state law,” Cort v. Ash, 422 U.S. 66, 84

(1975); Business Roundtable v. SEC, 905 F.2d 406,

412 (D.C. Cir. 1990); Doe v. McMaster, 355 S.C. 306,

313 (2003); Tr. Co. of Ga. v. State, 109 Ga. 736, 755

(1900), and no relevant provision of law equates

individuals with corporations.

REASONS TO GRANT REHEARING

The Clean Air Act’s control over so many facets of

the national economy and even daily life make it

critical that federal courts ensure the judicial review

that Congress enacted, consistent with constitutional

and prudential guidelines. Under the circumstances,

rehearing is warranted for several important reasons.

1. The nonjurisdictional nature of the Clean Air

Act’s 60-day provision allows flexibility for courts to

consider not only declaratory relief, see Section III.B,

infra, but also final APA action not acknowledged by

the agency. See Section III.A, infra.

4

2. With the 60-day claims-processing rule taken

outside the jurisdictional question, the Clean Air Act

and APA may allow more opportunity for a court to

consider the questions on prudential justiciability

that Williams raised below, which the D.C. Circuit did

not consider. See Section III.C, infra.

3. The court of appeals applied cases under the

Clean Air Act generally, without distinguishing that

the bulk of major EPA actions that fall under the Act’s

abbreviated review procedures under § 307(d), see 42

U.S.C. § 7607(d)(1)(a)-(u) (listing the EPA actions

subject to § 307(d)) while EPA actions like this matter

that remain subject to the Administrative Procedure

Act, 5 U.S.C. §§ 551-706 (“APA”), instead. That “APA

versus § 307(d)” distinction bears on the timing of

judicial review of EPA action on petitions for

administrative reconsideration. See Section III.D,

infra.

4. The multiplicity of suits resulting from the

D.C. Circuit’s ruling and EPA’s inaction would

irreparably harm Williams. See, e.g., Idaho v. Coeur

d’Alene Tribe of Idaho, 521 U.S. 261, 273-74 (1997)

(“federal court’s equitable jurisdiction [can be]

necessary to avoid … [the] possibility of [a]

multiplicity of suits causing irreparable damage”)

(interior quotations omitted, textual alterations in

original, ellipsis added, citing Charles Warren,

Federal and State Court Interference, 43 HARV. L. REV.

345, 377-78 (1930)).

These important reasons justify this Court’s granting

a GVR order to allow the D.C. Circuit to begin to

resolve these issues.

5

I. THIS COURT’S HARROW DECISION IS AN

INTERVENING, CONTROLLING

PRECEDENT THAT AFFECTS THE

JUSTICIABILITY OF PETITIONER’S

CLAIMS.

A rehearing of the denial of a petition for a writ of

certiorari is appropriate to consider “intervening

circumstances of a substantial or controlling effect”

relative to the petition. Sup. Ct. R. 44.2. Furthermore,

this Court may modify any judgment brought before

it, and vacate and remand that case to the court below

“as may be just under the circumstances.” 28 U.S.C. §

2106. Although the Court gainfully could take the case

on the merits, GVR to the D.C. Circuit is appropriate

for that court to consider—in the first instance—the

merits and additional justiciability issues Williams

raises, now that the 60-day provision is not

jurisdictional under Harrow. See Cutter, 544 U.S. at

718 n.7; Lawrence v. Chater, 516 U.S. 163, 167 (1996).

GVR orders have “become an integral part of this

Court’s practice,” which the Court has issued when a

recent decision affects the outcome of another case

seeking the Court’s review. Id. at 166. In Lawrence,

this Court found that the petitioner should have the

opportunity to have his claim reviewed by the lower

court following an administrative re-interpretation of

the statute under which the petitioner sought relief.

516 U.S. 174-75. This Court found that a GVR order

was particularly appropriate in that case because the

intervening change in administrative interpretation

could have been outcome determinative to the

petitioner. Id. at 174. “Giving Lawrence a chance to

benefit from it furthers fairness by treating Lawrence

like other future benefits applicants.” Id. at 175.

6

Likewise, in this case, the Court’s Harrow

decision is a significant intervening change that

undermines the D.C. Circuit’s jurisdictional basis to

dismiss Williams’ petition. With jurisdiction set aside,

other issues come into focus, including whether a

court could consider Williams’ argument that his

petition for administrative reconsideration rendered

the EPA action prudentially unripe vis-à-vis the 60day claims-processing rule for judicial review,

whether his APA action for the denial of the then-new

2023 allocation was a sufficiently final APA action to

allow APA review, and whether declaratory relief was

available even if Clean Air Act and APA review were

not.

Under Lawrence and Rule 44.2, Williams’ request

for rehearing should be granted and the D.C. Circuit’s

judgment vacated and remanded for reconsideration

under this Court’s Harrow decision.

II. REHEARING IS REQUIRED TO AVOID

ISSUE PRECLUSION’S DENYING THE

FORUM THE CLEAN AIR ACT AND APA

PROVIDE.

Jurisdictional dismissal can have issue-preclusive

impact as between the parties, even if the dismissal is

erroneous. Mike Hooks, Inc. v. Pena, 313 F.2d 696, 699

(5th Cir. 1963) (“whether right or wrong,

[jurisdictional] decision[s] cannot ordinarily be

attacked collaterally”); Dozier v. Ford Motor Co., 702

F.2d 1189, 1191 (D.C.. Cir. 1983) (Scalia, J.); Durfee v.

Duke, 375 U.S. 106, 111 (1963). Petitioner is entitled

to rehearing under Rule 44.2. Without a rehearing,

petitioner Williams could arguably lose the right to

have his claims heard under the petition-for-review

process that the Clean Air Act provides. The D.C.

Circuit’s refusal to accept jurisdiction, if upheld,

7

would compel petitioner to litigate his claim first in

district court—to compel EPA to act—then in the

Court of Appeals to challenge EPA’s action.

In this action, EPA has already wrongly withheld

allocations for the 2022 and 2023 allocation years. In

a new action, Williams challenges the 2024 year, and

the 2025 year is forthcoming. For each allocation year

that passes, petitioner either will forever lose

allocations for that year or he will need to bring a

separate action to recover for years unlawfully

withheld or denied. Unless this Court grants the

petition for rehearing, petitioner will remain in limbo,

with his claims potentially fading into oblivion.3

III. THIS COURT SHOULD “GVR” THE CASE

TO THE COURT OF APPEALS.

“Whether a GVR order is ultimately appropriate

depends further on the equities of the case[.]”

Lawrence, 516 U.S. at 167-68. Here, the equities urge

that petitioner receive a GVR order. As in Lawrence,

“the GVR order can improve the fairness and accuracy

of judicial outcomes while at the same time serving as

a cautious and deferential alternative to summary

reversal in cases whose precedential significance does

not merit our plenary review.” Id. at 168.

A. APA action is viable.

Unlike for EPA actions under § 307(d), the APA

applies to EPA actions outside § 307(d). When an APA

action involves periodic relief—such as the annual

allocations here—the APA allows treating inaction as

to a single year as final agency action as to that year.

Petitioner has filed a claim under the Federal Tort Claims

Act, 28 U.S.C. §§ 2671-2680, against the EPA staff who denied

him allocations for the 2022 and 2023 allocation years. Whether

petitioner will recover damages remains an open question.

3

8

See, e.g., Safari Club Int’l v. Jewell, 842 F.3d 1280,

1289 (D.C. Cir. 2016) (“the findings represented the

agency’s final decision that no permit would issue for

the 2014 calendar year”); Nat’l Airlines, Inc. v. C.A.B.,

392 F.2d 504, 511 (D.C. Cir. 1968) (“effective

deprivation of petitioners’ rights” constitutes final

action); Envtl. Def. Fund, Inc. v. Ruckelshaus, 439

F.2d 584, 589 n.8 (D.C. Cir. 1971) (“test of finality for

purposes of review is … whether it imposes an

obligation or denies a right with consequences

sufficient to warrant review”). That is enough to

reverse the dismissal of Williams’ petition for review.

Specifically, finality has two prongs: (1) a

consummated decisionmaking process, and (2) the

agency action is “one by which rights or obligations

have been determined, or from which legal

consequences will flow.” Bennett v. Spear, 520 U.S.

154, 177-78 (1997) (interior quotations omitted).

Courts interpret finality in a “pragmatic” and

“flexible” way, Abbott Laboratories v. Gardner, 387

U.S. 136, 149-50 (1967), “rather than a technical

construction.” Cohen v. Beneficial Indus. Loan Corp.,

337 U.S. 541, 546 (1949) (construing 28 U.S.C. §

1291); Mathews v. Eldridge, 424 U.S. 319, 331 n.11

(1976) (analogizing Cohen and § 1291 to statutory

finality).

Courts

must

evaluate

“competing

considerations underlying all questions of finality –

the inconvenience and costs of piecemeal review on

the one hand and the danger of denying justice by

delay on the other.” Eisen v. Carlisle & Jacquelin, 417

U.S. 156, 171 (1974). EPA’s APA action was final.

B. Declaratory relief is available, even if

other review is unavailable.

Once within a federal court’s jurisdiction, the

court also “may declare the rights and other legal

9

relations of any interested party seeking such

declaration, whether or not further relief is or could

be sought.” 28 U.S.C. § 2201(a). While the Declaratory

Judgment Act does not extend the jurisdiction of the

federal courts, California v. Texas, 141 S.Ct. 2104,

2115 (2021), a court otherwise with jurisdiction “may

grant declaratory relief even though it chooses not to

issue an injunction or mandamus.” Powell v.

McCormack, 395 U.S. 486, 499 (1969); Steffel v.

Thompson, 415 U.S. 452, 457 n.7 (1974); Zukerman v.

United States Postal Serv., 64 F.4th 1354, 1366 (D.C.

Cir. 2023); In re Tennant, 359 F.3d 523, 531 (D.C. Cir.

2004) (“declaratory judgment … could be entered only

‘in a case of actual controversy within [our]

jurisdiction’” such as mandamus under the All Writs

Act) (quoting 28 U.S.C. § 2201(a), alteration in

original). In addition, “[f]urther necessary or proper

relief based on a declaratory judgment or decree may

[also] be granted, after reasonable notice and hearing,

against any adverse party whose rights have been

determined by such judgment.” Id. § 2202. With

jurisdiction now established, Williams should have

the opportunity to seek declaratory relief.

C. The nonjurisdictional nature of the 60day provision allows consideration of

issues such as prudential ripeness.

Before finding a challenge to EPA’s initial denial

untimely for not being filed within 60 days of the

Federal Register notice on April 5, 2022, a court could

find that—when Williams filed his petition for

administrative reconsideration—a challenge was not

ripe. A lack of constitutional or prudential ripeness

would stall the 60-day clock until the claim ripened:

We have held in other cases involving the

confrontation between a statutory bar and a

10

claim not yet prudentially ripe that a time

limitation on petitions for judicial review can

run only against challenges ripe for review.

Our reading of 42 U.S.C. § 7607(b) does not

contradict this precedent.

Louisiana Envtl. Action Network v. Browner, 87 F.3d

1379, 1385 (D.C. Cir. 1996) (internal quotations and

alterations omitted). The factual elements of EPA’s

denial of Williams’ application require not only the

factual development that his administrative petition

provided, but potentially also EPA’s application of its

unique new-entrant rule to those facts.

D. The APA and § 307(d) apply different

timing criteria to EPA’s action—and

inaction—on administrative petitions.

Perhaps because most Clean Air Act litigation has

involved the major programs listed in § 307(d)(1),

there is not much law on how the APA applies to EPA

action outside § 307(d). While § 307(d)’s procedures

are a form of “APA-lite,” the two standards obviously

differ in some ways, or Congress would not have taken

the time to draft § 307(d)’s abbreviated procedures.

For action outside § 307(d), the APA applied before

Congress enacted § 307(d), Amoco Oil Co. v. EPA, 501

F.2d 722, 731 (D.C. Cir. 1974) (quoting 5 U.S.C. §

706(2)(A)), and § 307(d)’s enactment did nothing to

change that. 5 U.S.C. § 559 (APA applies to post-APA

statutes unless expressly exempted); Dickinson v.

Zurko, 527 U.S. 150, 154-55 (1999).

The APA requires a response to Williams’ petition

for administrative reconsideration and provides

judicial review to “compel agency action unlawfully

withheld.” 5 U.S.C. §§ 555(b), 706(1). The action

reviewed when EPA acts (or fails to act) on a petition

11

for administrative reconsideration under the APA is

the latter act (or failure to act) of withholding or

denying reconsideration, not the original action that a

petitioner asks an agency to reconsider. Interstate

Commerce Comm’n v. Bhd. of Locomotive Eng’rs, 482

U.S. 270, 284-85 (1987); Nat’l Labor Relations Bd.

Union v. Fed. Labor Relations Auth., 834 F.2d 191,

195-196 (D.C. Cir. 1987). That future action is the

final agency action that the APA reviews when an

agency denies an administrative petition, and that

final agency action had not occurred by June 6, 2022

(i.e., EPA’s claimed cut-off for Williams to have sought

review).

It is important for the D.C. Circuit to resolve how

the claims-processing rule applies to APA actions

outside § 307(d), even if Williams were to have claim

barred under the Clean Air Act’s claims-processing

rule and to have APA and declaratory relief denied.

CONCLUSION

The Court should grant the petition for rehearing

and issue a GVR for reconsideration of the dismissal

under Harrow.

June 24, 2024

Respectfully submitted,

LAWRENCE J. JOSEPH

Counsel of Record

1250 Connecticut Ave. NW

Suite 700-1A

Washington, DC 20036

202-355-9452

ljoseph@larryjoseph.com

Counsel for Petitioner

12

CERTIFICATE OF COUNSEL

Pursuant to this Court’s Rule 44.2, petitioner’s

counsel certifies that the Petition for Rehearing is

restricted to the grounds specified in the rule with

substantial grounds not previously presented.

Counsel certifies that this Petition is presented in

good faith and not for delay.

June 24, 2024

Respectfully submitted,

LAWRENCE J. JOSEPH

Counsel of Record

1250 Connecticut Ave. NW

Suite 700-1A

Washington, DC 20036

202-355-9452

ljoseph@larryjoseph.com

Counsel for Petitioner