Petition for Writ of Certiorari — Christina Alessio, Petitioner v. United Airlines, Inc., et al.

No. 23-. qj}\

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Supreme Court of tfjc QSntteti States

~r,\

CHRISTINA ALESSIO,

Petitioner,

v.

UNITED AIRLINES, INC.,

Respondent.

On a Petition for a Writ of Certiorari to the

Supreme Court of Ohio

PETITION FOR WRIT OF CERTIORARI

Christina Alessio

Petitioner Pro Se

1970 N. Cleveland-Massillon Road

Unit 589

Bath, OH 44210

(330) 338-7052

September 1, 2023

SUPREME COURT PRESS

♦

(888) 958-5705

♦

Boston, Massachusetts

1

QUESTIONS PRESENTED

Introduction: With Great Respect this Case is

about Life, Liberty and the Pursuit for Righteousness

at 30,000 feet.

Federal Law Fact: Federal Rule of Law, Title

49 U.S. Code 5124, Forbids Hazard Materials onboard

the Aircraft.

National/Global Significant Fact: The

Respondent willfully Approves the Use of “Chemical

Substance Products” inside the Aircraft Cabin for

Cleaning, Sanitizing, Disinfecting and Air-Freshening,

with No Oversight providing Verification and Certifi­

cation with an Official Government Document

“Certificate of Compliance” from the Legislative

Branch, that the Respondent Is or Is Not. In Fact

Following the Rule of Law.

10 Respectful Federal and State Questions

1. With Respect, does the Rule of Law under

Title 49 U.S. Code 5124, Apply to the Respondent?

2. With Respect, is the Respondent in Compli­

ance with the Statutes, referring to Title 49 U.S.

Code 5124?

3. With Respect, may the Petitioners Writ of

Certiorari have Merit to be Granted when the Sub­

stantial Federal Questions above to this Case, have

Never been answered by the Lower Courts?

4. With Respect, may the Petitioners Writ of

Certiorari have Merit to be Granted when the

Supreme Court of Ohio (SCO) Declines to Accept

Jurisdiction of the Appeal, Pursuant to S.Ct.Prac.R.

7.08(B)(4)? (App.la)

11

5. With Respect, do you believe products

used to Clean, Sanitize, Disinfect and Air-Freshen

the Aircraft Cabin should be Transparent, No

Secrets, with complete List of Ingredients made

available, for a better Air-Quality Environment?

6. With Respect, may the Petitioners Writ of

Certiorari have Merit to be Granted when there are

Chemical Exposures from Cleaning, Sanitizing,

Disinfecting and Air-Freshening Products used inside

the Aircraft Cabin, willfully Approved by the Respon­

dent, some with labels that have a “PRECAUTION­

ARY STATEMENT: HAZARDS TO HUMANS AND

DOMESTIC ANIMALS.”?

7. With Respect, may our United States of

America 118th Congress, please Inspect and Provide

the Respondent and Air*Travelers with an Official

Government Oversight Document: “Certificate of

Compliance”. Including a Complete “Aircraft Cabin

Product List with 100% of the Ingredients”, Required

for “Safety and Healthcare in the Aircraft Cabin”?

8. With Respect may the Supreme Court of the

United States (SCOTUS), Case No. 19-395, Respect­

fully Submitted on September 19, 2019, Before a Global

Pandemic. have Merit for Respectfully Granting the

Petitioner’s Second Writ of Certiorari. for a Judicial

Review of the Facts and Law, when the Petitioners

Work Environment is Global?

9. With Respect, may this Second Petition for

Writ of Certiorari, have Merit to be Granted when the

Supreme Court of the United States (SCOTUS)

Denied, first Case No. 19-395, Petition for Rehearing

on January 21. 2020. the same approximate if not the

day, Centers for Disease Control and Prevention

Ill

(CDC) announced and Confirmed the First Case of

the Coronavirus (COVID-19) in the United States of

America?

10. With Respect, may the Continuance of this

Case which Holds NATIONAL/GLOBAL SIGNIF­

ICANCE, have Merit for Granting the Petitioners

Second Writ of Certiorari?

IV

LIST OF PROCEEDINGS

Supreme Court of Ohio

Case No. 2023-0072

CHRISTINA ALESSIO, Plaintiff-Appellant,

v. UNITED AIRLINES, INC, ETAL.,

Defendants-Appellees

Date of Order Entry: April 11, 2023

Court of Appeals, Ohio Eighth Appellate District

County of Cuyahoga

Case No. 111449

CHRISTINA ALESSIO, Plaintiff-Appellant,

v. UNITED AIRLINES, INC, ETAL.,

Defendants-Appellees.

Date of Opinion and Journal Entry:

December 15, 2022

Court of Common Pleas, Cuyahoga County, Ohio

Case No. CV-21-949578

CHRISTINA ALESSIO, Plaintiff-Appellant,

v. UNITED AIRLINES, INC ETAL.,

Defendants-Appellees.

Date of Journal Entry: March 31, 2022

V

TABLE OF CONTENTS

Page

QUESTIONS PRESENTED..............................

1

LIST OF PROCEEDINGS.................................

IV

TABLE OF AUTHORITIES..............................

Xll

PETITION FOR A WRIT OF CERTIORARI....

1

OPINIONS BELOW..........................................

1

JURISDICTION..................................................

2

CONSTITUTIONAL AND STATUTORY

PROVISIONS INVOLVED.........................

2

STATEMENT OF THE CASE...........................

9

REASONS FOR GRANTING THE PETITION...... 18

CONCLUSION.

23

VI

TABLE OF CONTENTS - Continued

Page

APPENDIX TABLE OF CONTENTS

Opinions and Orders

Order of the Supreme Court of Ohio

(April 11, 2023).................................................. la

Order of the Supreme Court of Ohio

Denying Motion for Reconsideration

(June 6, 2023).................................................... 2a

Journal Entry and Opinion of the

Court of Appeals of Ohio Eighth

Appellate District, County of Cuyahoga

(December 15, 2022).........................................

3a

Journal Entry

(December 16, 2022)......................................... 13a

Journal Entry Granting Motion for

Summary Judgment in Favor of the

Defendant-Appellee, United Airlines, Inc.

(March 31, 2022)................................................ 15a

Vll

TABLE OF CONTENTS - Continued

Page

Case Documents

Memorandum in Support of Jurisdiction of

Plaintiff-Appellant Christina Alessio

(January 19, 2023)............................................ 17a

Motion for Reconsideration of

Plaintiff-Appellant Christina Alessio

(April 17, 2023).................................................. 33a

Letter from (FAA) Federal Aviation

Administration (June 2, 2016)...................... 40a

Letter from (OSHA) U.S. Department of

Labor (September 19, 2016)........................... 41a

EEOC Dismissal and Notice of Rights

(April 18, 2017).................................................. 44a

Letter from Ohio Senator Sherrod Brown

(July 22, 2015)................................................... 46a

Letter from Ohio Senator Sherrod Brown

(May 25, 2017)................................................... 47a

Letter from Ohio Congresswoman

Marcia L. Fudge (July 31, 2015)................... 48a

Letter from Defendant-Appellee United

Airlines Inc., Response to Subpoena

(January 7, 2016)............................................... 50a

Letter from Plaintiff-Appellant

Christina Alessio to Executive Branch,

(DOJ) Department of Justice

(March 1, 2018)............................................. 52a

vni

TABLE OF CONTENTS - Continued

Page

Letter from Plaintiff-Appellant

Christina Alessio to Executive Branch,

(DO J) Department of Justice

(November 13, 2018).....................................

58a

Letter from Plaintiff-Appellant

Christina Alessio to Executive Branch,

(DOJ) Department of Justice

(January 7, 2020)...........................................

63a

Letter from Christina Alessio to the

Legislative Branch, Ohio Senators and

Congresswomen (May 15, 2020)...............

69a

Letter from Christina Alessio to the

Legislative Branch, Ohio Senators and

Congresswomen (July 10, 2020)...............

73a

Alessio Petition for Rehearing in

Supreme Court, Excerpts

(December 19, 2019)......................................

80a

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT

Oral Argument Audio in Transcript

(November 16, 2022).....................................

87a

Transript of Oral Argument....................

90a

Plaintiffs Memorandum in Opposition to

Defendants Motion for Summary

Judgment (February 2, 2022)..................... 113a

Addendum In Opposition to Defendants

Motion for Summary Judgment

(February 7, 2022)......................................... 132a

IX

TABLE OF CONTENTS - Continued

Page

Exhibits

EXHIBIT 3

Letter from Defendant-Appellee

Attorney on Appellant’s Request for

(IME) Independent Medical

Examination (December 2, 2020).........

137a

EXHIBIT 4

Quote from United Airlines CEO,

Scott Kirby on Vaccines......................

139a

EXHIBIT 6

Ohio Workers’ Compensation Law

2.2 Employers’ Obligation...................

141a

EXHIBIT 7

VSSR Record of Proceedings

(May 21, 2021)..........................................

143a

EXHIBIT 8

FEDERAL LAW 49 U.S.C. 5124

“Notice to travelers”.............................

147a

EXHIBIT 18

Definition of Chemical Weapon........

148a

EXHIBIT F

Irregular Operation Report #207207

(August 14, 2021).....................................

149a

EXHIBIT T

OSHA Safety and Health Concern

Submitted (August 24, 2021)................

153a

Docket Details

Docket Details

159a

X

TABLE OF CONTENTS - Continued

Page

America, the Jury

AMERICA, THE JURY Third Sequel..

173a

CHAPTER ONE Ohio Industrial Commission

District Hearing, Transcript

(October 30, 2020)................................

178a

CHAPTER TWO Ohio Industrial Commission

Staff Hearing, Transcript

(January 22, 2021)................................

211a

CHAPTER THREE Petition for Rehearing,

Case No. 19-395 with Docket List

(December 19, 2019).............................

251a

CHAPTER FOURConclusion and Photos....................

260a

CHAPTER FIVE - The Question.....

265a

CHAPTER SIX - The Verdict..........

266a

AMERICA, THE JURY Fourth Sequel

267a

CHAPTER ONE Ohio Industrial Commission

Staff Hearing, Transcript

VSSR (Violation of Specific

Safety Requirement)

(February 18, 2021)..............................

271a

XI

TABLE OF CONTENTS - Continued

Page

CHAPTER TWO Ohio Industrial Commission

Staff Hearing, Transcript

Reset VSSR (Violation of Specific

Safety Requirement)

(May 21, 2021)........................................

279a

CHAPTER THREE - The Conclusion

310a

CHAPTER FOUR - The Question.....

316a

CHAPTER FIVE - The Verdict...........

317a

AMERICA, THE JURY Fifth Sequel......

318a

CHAPTER ONE Six Clarifications and Corrections

Unable to Communicate in Staff Hearing:

America, The Jury - Third Sequel

322a

CHAPTER TWO Ohio Industrial Commission

District Hearing, Transcript

(March 5, 2021)....................................

329a

CHAPTER THREE Ohio Industrial Commission

Staff Hearing, Transcript

(April 15, 2021)....................................

364a

CHAPTER FOUR - Conclusion......

403a

CHAPTER FIVE - The Question....

418a

CHAPTER SIX - The Verdict.........

419a

j

Xll

TABLE OF AUTHORITIES

Page

CONSTITUTIONAL PROVISIONS

United States Constitution.................

4

United States Constitution, Article V.

8, 13

STATUTES

28 U.S.C. § 1257

1,2

49 U.S.C. § 5124

i, 1, 9, 16, 18, 19

JUDICIAL RULES

S. Ct. Prac. R. 7.08(B)(4)

19

1

n

PETITION FOR A WRIT OF CERTIORARI

May the Supreme Court of the United States

be Pleased with the Petition For Writ of Certiorari,

Respectfully Submitted by Petitioner, Christina Alessio

(Plaintiff, Appellant).

In Pursuant to 28 U.S. Code 1257, Petitioner

believes this Code provides the Ability For Writ of

Certiorari, a Meaningful Judicial Review from the

Final Decision made from the Lower State Court.

YOUR HONOR and with Great Respect, this

Case is about Life, Liberty and the Pursuit for

Righteousness at 30,000 feet.

May the Rule of Law and the Facts of this

Case, be Respectfully Submitted for a Meaningful

Judicial Review under Title 49 U.S. Code 5124,

which Forbids Hazard Materials onboard the

Aircraft.

OPINIONS BELOW

Petitioner is Respectfully Seeking Review of

the Following Orders:

The Journal Entry and Opinion of the Ohio

Court of Appeals, dated December 15, 2022, (App.3a).

The Order of the Supreme Court of Ohio, Case

No. 2023-0072, dated April 11, 2023, (App.la).

2

*

JURISDICTION

The Entry of the Supreme Court of Ohio was

entered on April 11, 2023, (App.la). A timely filed

petition for reconsideration was denied on June 6,

2023, (App.2a). Petitioner believes this Court has

Jurisdiction under 28 U.S. Code 1257.

*

CONSTITUTIONAL AND

STATUTORY PROVISIONS INVOLVED

49 U.S. Code § 5124

A person knowingly violating section 5104(b) or

willfully or recklessly violating this chapter or a

regulation, order, special permit, or approval issued

under this chapter shall be fined under title 18,

imprisoned for not more than 5 years, or both;

except that the maximum amount of imprison­

ment shall be 10 years in any case in which the

violation involves the release of a hazardous

material that results in death or bodily injury to

any person.

(b) Knowing Violations.—For purposes of

this section—

(1) a person acts knowingly when—

(A) the person has actual knowledge of the

facts giving rise to the violation; or

3

(B) a reasonable person acting in the circum­

stances and exercising reasonable care

would have that knowledge; and

(2) knowledge of the existence of a statutory

provision, or a regulation or a requirement

required by the Secretary, is not an element

of an offense under this section.

(c) Willful Violations.—For purposes of this

section, a person acts willfully when—

(1) the person has knowledge of the facts

giving rise to the violation; and

(2) the person has knowledge that the conduct

was unlawful.

(d) Reckless Violations.—

For purposes of this section, a person acts

recklessly when the person displays a delib­

erate indifference or conscious disregard to

the consequences of that person’s conduct.

As respectfully understood, a person knowingly

violating, and/or willfully, recklessly violating this

chapter, regulation or order shall be fined $250,000

and/or prison 5 years; in any case which involves a

violation or the release of hazardous materials that

results in death or bodily injury to any person. The

person has knowledge of the facts to the violation.

• The person acts willfully to the violation with

the knowledge of the facts.

• The person has knowledge that the conduct is

unlawful.

4

• The person acts recklessly and displays delib­

erate disregard to the consequences of that

person’s conduct.

YOUR HONOR and with great respect, Please

note for the record:

Federal Law 49 U.S.C. § 5124 is placarded in

the terminal at every podium/gate before you board

Respondents Aircraft. For example, at the Cleveland

Hopkins International Airport the placard states in

part:

“Advice to passengers

Federal law forbids the carriage of hazardous

materials aboard aircraft in your luggage or

on your person.”

‘It’s the law: you must declare your hazard­

ous materials to the airline or air package

carrier. A violation of the Federal Hazardous

Materials Regulations (49 CFR Parts 171180) can result in 5 years imprisonment and

penalties of $250,000 or more (49 U.S.C. §

5124).”

UNITED STATES CONSTITUTION:

To Protect the People.

5

INTRODUCTION

Respectfully, this Case is Not about the Petitioner.

Petitioner has Already Won her Case.

THE WIN: Petitioner, Now has the Ability to

Protect from Chemical Inhalation Exposure with

Personal Protective Equipment (PPE).

This Case Continues and Carries On: TO WIN “FOR THE PEOPLE”.

Petitioner has a Job Duty and Responsibility to

Ensure a Safe Environment in the Aircraft Cabin

“For the People”. This Case is about, <eWe the

People”. The Air'Traveling Public, is being Exposed

to Chemical Substance Products used for Cleaning,

Sanitizing, Disinfecting and Air-Freshening the Aircraft

Cabin. Chemical Substance Products, willfully Approved

by the Respondent with No Transparency, other than

labels that read: “PRECAUTIONARY STATEMENT:

HAZARDS TO HUMANS AND DOMESTIC ANIMALS.”

Respectfully, Petitioner believes this Case

involves A Substantial Constitutional Question that

is of Great General and Public Interest.

Substantial Federal Question: Is the

Respondent in Compliance with Title 49 U.S.

Code 5124 using Chemical Substance Products

inside the Aircraft Cabin that reads “Hazards to

Humans and Domestic Animals” with No

Transparency for the Air-Traveler to Protect? Feder­

al Law Forbids Hazard Materials onboard the

Aircraft, a Respectful FACT.

6

Let the Petitioner Be On The Record:

23 Work Injuries Documented from 2010 to

2019, due to Chemical Inahalation Exposure

with No Personal Protective Equipment (PPE)

furnished by Respondent.

All 23 Work Injury Claims were Denied and

Disallowed.

PPE is Now Allowed and No more Injuries to

Chemical Inhalation Exposure.

Worked during the Coronavirus, COVID"19

Global Pandemic.

Never called off work once, from COVID‘19.

Never got COVID-19.

During COVID-19, wore PPE to avoid Chem­

ical Inhalation Exposure on the Aircraft.

Would not get the COVID-19 Vaccine, be­

cause of a Sincerely Held Religious Belief

against the COVID-19 Vaccine.

Due to Petitioners Religious Belief Not to get

the COVID-19 Vaccine, Petitioner was put

on a Personal Leave by the Respondent with

No Pay. No Health Benefits from approxim­

ately November 13, 2021 until April 20, 2022.

Respectfully, is this a Violation of Title VII

of the Civil Rights Act of 1964? A Federal

Law that Prohibits Employment Discrimina­

tion based on Race, Religion and National

Origin.

7

• Petitioner is presently on a Performance

Warning by Inflight Management for

communicating a Safety and Health Concern.

• Federal Labor Law Posting Requirements

have Expired in Inflight Crew Rooms across

the United States Country. Example: EEOC

“Know Your Rights: Workplace Discrimina­

tion is Illegal” Notice.

(Mandatory Revision Effective 6/27/2023)

Respectfully, the Federal/State Law Required

Posters are Outdated and Inconsistent in

Inflight Crew Rooms across our U.S. Country.

• DOCKET DETAILS for CASE #: CV-21-949578

Filing Date: 07/07/2023

Docket Description: COMPLAINT EXHIBIT

(EXHIBIT 0) Is in ERROR.

. 1.

EXHIBIT O: Was filed on 07/07/2021.

2.

EXHIBIT O: Is a Respectful Letter to

Corporate at UNITED AIRLINES, re­

garding Notice of Appeal filed on

07/07/2021.

Addressed to the following:

Mr. Scott Kirby, CEO

Mr. Brett Hart, President

Mr. Oscar Munoz, Executive Chairman

Mr. Robert Milton, Chairman of the

Board of Directors of United Airlines

Holdings

8

3.

EXHIBIT O: Was designated as only

the Letter. However, EXHIBITS “M” and

“N” (All Public Court Revorts-Transcripts.

Published and Unpublished) have been

incorporated into EXHIBIT 0, and all 3

EXHIBITS (M, N, and O) are Unavail­

able for Viewing on the Public Docket.

• Petitioner is Thankful for PPE in the Work

Environment, and Avoids Chemical Inhal­

ation Exposure in Every Way Possible,

Gaining Back Great Health and Quality of

Life.

• Respectfully, the Petitioner believes in

Article V of the United States Consti­

tution. An Attack against One is an Attack

against All. <cWe the People” Need Trans­

parency and Protection. Especially, in the

Petitioners Particular and Unique Work

Environment.

9

*

STATEMENT OF THE CASE

Petitioner is the Plaintiff, Appellant, in this Case.

Respondent is the Defendant, Appellee, in this

Case.

Petitioners Work Environment is Commercial

Air-Travel.

Petitioner is a Flight Attendant.

Petitioners Job Duty and Responsibility is to

Ensure a Safe Environment for the Air-Traveler in

the Aircraft Cabin.

Petitioner has Evaluated what has Happened

and is Applying What has been Learned, for a Safer

and Healthier Air-Travel Experience.

The FACTS as the Petitioner knows them:

1. Federal Law 49 U.S. Code 5124: Forbids

Hazard Materials onboard the Aircraft, (App.2aApp.4a).

2. There are Products used inside the Aircraft

Cabin that state on the label: PRECAUTIONARY

STATEMENT: HAZARDS TO HUMANS AND

DOMESTIC ANIMALS.

3. There is no “Certificate of Compliance” by

the Legislative Branch, that the Airline Industry Is

or Is Not. In Fact Following the Rule of Law under

Title 49 U.S. Code 5124. A Substantial Federal Ques­

tion that still Needs Answered by the Court.

4. Equal Employment Opportunity Commis­

sion (EEOC), could not Certify that the Respondent

10

is in Compliance with the Statutes. In specific to this

Case: 49 U.S. Code 5124. (App.2a-App.4a)

5. Record of Proceedings, Staff Hearing Officer

communicates: “the need for federal regulations

regarding air quality and use of cleaning products in

the air planes for the safety/good of the airlines

workers and the public at large. ” (App.22a)

6. Federal Aviation Administration (FAA) communicates: “Unfortunately, this is not an FAA issue.”

(App.40a)

7. Occupational Safety and Health Administration

(OSHA) communicates: “While OSHA does not have a

standard that regulates general indoor air quality,

workers potentially exposed to cleaning or air freshener

products that were used in the aircraft in a duration

and frequency more than what a typical consumer

would use the cleaning and air freshener products,

and thus exposed to a potential health hazard, must

be included in their employer’s hazard communication

program. The employer’s hazard communication pro­

gram must include maintaining and making available

safety data sheets, training employees on the hazards

of the chemicals to which they are actually or poten­

tially exposed, as well as identifying any appropriate

protective measures, such as gloves for hand protec­

tion. ” (App.42a)

8. 2014 is the only Hazard Communication Module

(Program) required by the Respondent or Not Qualified

to Fly. It did Not include a Complete List of the

Product Names of Chemical Substance Exposures in

the Aircraft Cabin. With Respect, No Complete List

by Product Name with each Products (SDS) Safety

Data Sheet.

11

9. Ohio Senator, thanks for getting in touch

with his office regarding hazardous materials used in

cleaning supplies upon commercial flights. (App.46a,

App.47a)

10. Ohio Congresswoman, thanks for contacting

her concerning the presence of hazardous materials

on airlines. (App.48a, App.49a)

11. Respondent communicates in a Subpoena

Response that they do not manufacture any of the

cleaning products in question and therefore do not

have a list of ingredients. (App.50a, App.51a)

12. Three Letters, Notarized, to the Executive

Branch and Addressed to the Department of

Justice (DOJ). March 1, 2018, November 13, 2018 and

January 7, 2020. See Something, Say Something:

Chemicals onboard Aircraft, Health and Safety to the

Global Air_Traveling Public, Requesting a “Certifi­

cate of Compliance” with the Rule of Law.

Respectfully, Petitioner received No Results to

Protect the Air~Travelins Public. (App.52a-App.68a)

13. Two Bill Proposals, Notarized, to the Legis­

lative Branch of four Ohio State Representatives,

Senators and Congresswomen. May 15, 2020 and

July 10, 2020, amidst the COVID-19 Global Pan­

demic, Requesting 100% Transparency to the AirQuality in the Aircraft Cabin. Respectfully, Petitioner

received No Results to Protect the Air-Traveling Public.

(App.69a-App.79a)

14. SCOTUS Case No. 19"395, Petition for Re­

hearing was Denied on January 21, 2020. (App.80aApp.87a, App.251a-App259a)

12

15. CDC Confirms First Coronavirus Case in the

United States of America on or about, January 21,

2020.

16. No Daily Personal Protective Equipment (PPE)

was Furnished to Protect from Chemical Exposures

(PPE Masks) in the Workplace Environment, the

Aircraft, from Petitioners date of hire in 1998 to 2019

(21 years). PPE was Not Furnished by the Respondent

to Chemical Inhalation Exposures, until the Coronavirus, COVID-19 Global Pandemic.

17. Respondent willfully Approves Chemical

Substances of Cleaning, Sanitizing, Disinfecting and

Air-Freshening Products for the Aircraft Cabin without

100% Transparency to the Air-Traveler.

18. Ohio BWC Law Chapter 2.2 Employers

Obligation, to Protect the Employee from Harm. The

Duty to Provide a Safe Workplace (Chemical

Exposure). The Duty to Provide Safe Equipment to

Perform the Work (PPE). The Duty to Warn Workers

of Dangers the Employees might not reasonably be

expected to perceive (Chemical Exposure). The Duty

to Make and Enforce Rules that would promote

Employee Safety (An Annual Continuing Qualifi­

cation and Communication Module with updates

Providing all Product Names including SDS to the

Products used in the Aircraft Cabin). (App.l41a)

Note: Respectfully, PPE was Not Furnished to

Protect Petitioner from Chemical Inhalation Exposure.

Even Petitioners Doctor Recommendations, to Protect

from Work Injury from Chemical Inhalation Exposures

were Denied and communicated as Insufficient” by

the Respondent, in the Respondents Reasonable

Accommodation Program.

13

19. Respondent Denies Petitioner’s Request

for an (IME) Independent Medical Examination. Is

this obstruction of Justice? (App.l37a-138a)

Respectfully, if the Respondent Doesn't Care about

the Petitioner’s Health Request for an IME, to the

Chemical Exposure in the Aircraft Cabin, what is

this saying about the Respondent, to the People the

Petitioner is Responsible for in the Aircraft Cabin?

Article V (App.36a)

20. During COVID-19, the Respondent Man­

dated the COVID"19 Vaccine Stating: “we have no

greater responsibility to you and your colleagues than to

ensure your safety when you are at work, and the facts

are crystal clear . . . everyone is safer when everyone

is vaccinated." (App.l39a-140a)

21. Respondent Due to Petitioner’s Sincerely

Held Religious Belief about getting the COVID-19

Vaccine, Petitioner was then put on an Unpaid

Personal Leave of Absence, by the Respondent with

No Pay and No Health Benefits from approximately

November 13, 2021 to April 20, 2022.

22. Record of Proceedings communicate:

Violation of Specific Safety Requirement (VSSR)

has been Allowed. (App.l43a-146a)

23. Definition of Chemical Weapon. Using

Formulated Chemicals to Inflict Death or Harm on

Humans. A Chemical Weapon can be any Toxic

Chemical that can Cause Death, Injury, Incapacitation

or Sensory Irritation through its Chemical Action.

(App.l48a)

24. Irregular Operation Report (IOR)

#207207. A copy went to the Respondent and the

14

Association of Flight Attendants (AFA). August

14, 2021, the Narrative: Hazard Communication.

“During Pre-Flight Safety Check, a total of 5 Clorox

Disinfectant Wipes (large dispensers) were on board

the Aircraft in the First Class section. On the back of

the label, the Chemical Substance Product states: “

PRECAUTIONARY STATEMENT: HAZARDS TO

HUMANS AND DOMESTIC ANIMALS.” The Safety

Data Sheet gives an EPA Pesticide Registration

Number. Respondent still willfully Approves this

Product onboard the Aircraft. No Further Response

from Respondent. Today the Disinfectant Wipes are

still onboard the Aircraft. (App.l49a-152a)

25. OSHA Complaints — Communicating 49

U.S.C. 5124, (App.2a-4a) Federal Law Forbids Hazard

Materials on board the Aircraft. Yet, Disinfectant Wipes

stating “HAZARDS TO HUMANS” are still onboard

the Aircraft. Petitioner has Respectfully Filed at

least 6 OSHA Complaints and have received on April

4, 2023, per an email request, the Complaint

Numbers and Dates for the Record.

Complaint No.

Date

1942611

1957001

1644648

1301426

1008560

911974

9/2/22

1/19/22

8/17/20

1/18/18

8/6/15

12/11/14

Respondent gave a Satisfactory Response, OSHA

then Closed the Complaint. All OSHA Complaints

have been Closed. OSHA’s email has been Respectfully

Submitted to the Ohio BWC under Petitioners last 3

15

Work Injury Claims, Date of Injuries: 10/6-8, 2019 to

Preserve the Record.

Respectfully adding OSHA Complaint No.

1770737 letter response dated June 9, 2021.

Address from:

OSHA Chicago South Area Office

8505 W. 183rd Street, Suite C

Tinley Park, IL 60487

26. Petitioner Requested an Oral Argument at

the Court of Appeals, and was held on November

16, 2022, in the Main Courtroom at 10:30am., Case

No. CA-22-111449. An Audio of the Oral Argument

can be requested from the Court of Appeals. With

Respect, Respondent’s (Appellee) Attorney could not

answer the Honorable Judges Question: “When was

the protective equipment provided.? (App.l05a)

27. Oral Argument at the Court of Appeals,

November 16, 2022, Petitioners Response to the

Honorable Judge Question: ‘What exactly are you

asking us today? What do you want us to do?

Petitioners (Appellant) Response: “I would like a

hundred percent transparency. I would like all the

names of the products that are used inside the aircraft

cabin for cleaning, disinfecting, sanitizing and air

freshening with safety data sheets to be made one

hundred percent transparent so in this environment it

is proven to be safe not just for the flight attendants

and the pilots, but for the customers that we are

responsible for. ” (App.94)

28. Oral Argument at the Court of Appeals,

November 16, 2022, Petitioner (Appellant) has Three

Questions that have yet to be Answered by the

16

Respondent (Appellee). 1. What are the Ingredients

to the Chemical AirFreshener used inside the Aircraft

Cabin, Substances state: Not Applicable. 2. Why wasn’t

Personal Protective Equipment (PPE) furnished by

the Appellee to Protect the Appellant from Chemical

Inhalation Exposure? 3. Why wasn’t an Independent

Medical Examination (IME) ever conducted by the

Appellee with a total of 23 Work Injury Claims filed

with the BWC due to Chemical Inhalation Exposure

from 2010 to 2019, when Safety is Top Priority?

(App.93a-94a)

29. Respondents (Appellee’s) Memorandum in

Opposition to Jurisdiction of Petitioners (Appellant’s)

Notice of Appeal, dated February 17, 2023, communi­

cates: ‘This case presents no Ohio Constitutional

question and is not an issue of public or great

general interest.”

30. Respectfully, Most Honorable Judge Sean

C. Gallagher, AJ, communicates in the Opinion

dated December 15, 2022 the following:

“13. At oral argument before this court, Alessio

offered a well-meaning and passionate concern about

airline safety for both employees and the traveling

public. While that concern is genuine, we are

constrained to follow the law that

applies to this case.”(App.lla)

31. In the SCOTUS Case No. 19-395,

(App.20a) No Private Cause of Action Under

Title 49. Respectfully, may there be a Public Cause

of Action Under Title 49, amidst the Global Pan­

demic, with No Transparency to the Chemical Sub­

stance Products (by Name with Safety Data Sheets)

17

used inside the Aircraft Cabin for the Global AirTraveling Public’s Safety and Health?

Is 100% Transparency of the Chemicals,

Air-Travelers are being exposed to, an impossible

mission due to the Fear of Public Scrutiny?

(SCOTUS Case No. 19-395, App.lOOa)

32. For the Record:

Petitioner has Requested and Paid for All Court

Reports, both District Hearings and Staff Hearings,

of the Testimonies to the Petitioners Work Injuries,

Due to Chemical Inhalation Exposure with No Personal

Protective Equipment (PPE Masks) Furnished by the

Respondent.

Respectfully, Petitioner has Self Published the

Public Court Report Transcripts for the Respectful

Truth be Told. The Last Book to be Published is the

Fifth Sequel.

With respect, awaiting the Outcome of the Peti­

tion For Writ of Certiorari with the Supreme

Court of the United States, Final Judgment.

33. Respectfully, may the Air-Traveling Public

please have 100% Transparency to the Chemical

Substance Products used inside the Aircraft Cabin for

Cleaning, Disinfecting, Sanitizing and Air-Freshening

with Safety Data Sheets? Respectfully, because

SAFETY IS TOP PRIORITY.

18

REASONS FOR GRANTING THE

PETITION

U.S. CONSITITUTION: To Protect the People.

YOUR HONOR and with Great Respect, this

Case is Sincerely about Principle and that All Must

Follow the Rule of Law.

Equal Justice Under the Law.

YOUR HONOR and with Great Respect, the

Substantial Federal Question Needs Answered by

the Court. Respectfully, Is the Respondent in Compli­

ance with the Statute, Title 49 U.S. Code 5124, (App.

2a-App.4a) Federal Law Forbids Hazard Materials

onboard the Aircraft, when Respondent is willfully

Allowing Chemical Substance Products for Cleaning,

Sanitizing, Disinfecting and Air-Freshening the Air­

craft Cabin, without being 100% Transparent to the

Product Names and Safety Data Sheets for the AirTravelers Safety and Health?

Respectfully, may every HONORABLE JUSTICE

of the SUPREME COURT Conclude that there is a

Significant Loophole and Conflict of Law whereby the

EEOC could Not Certify the Respondent is in Com­

pliance with the Statutes. Respectfully, and as the

Petitioner believes, this Case is of Great General and

Public Interest.

During the COVID-19 Global Pandemic, the

Respondent’s “CleanPlus Program”, provided No

Product Names with Safety Data Sheets for the AirTraveler’s Protection against Products used in the

Aircraft Cabin, that Kill Viruses and Bacteria. Products

19

onboard the Aircraft that State: “HAZARDS TO

HUMANS” Why is this? How can this be without

100% Transparency to the Air-Traveler?

This Case has NATIONAL AND GLOBAL

SIGNIFICANCE.

Federal: Supreme Court of the United States

(SCOTUS) Case No.19-395. (App.lOOa)

State: Supreme Court of Ohio (SCO) Case No.

2023-0072. (App.la). Respectfully, why no answer?

S.Ct.Prac.Rule 7.08(B)(4): In specific: (a) “The

appeal does not involve a substantial constitu­

tional question and should be dismissed; (b) The

appeal does not involve a question of great

general or public interest.”

Respectfully, the Petitioner does believe that

this Case is of Great General and Public Interest.

Chemical Inhalation Exposure happens at 30,000

feet, with No Transparency to the Chemical Substance

Products used inside the Aircraft Cabin for: Cleaning,

Sanitizing, Disinfecting and Air_Freshening. With

respect, No Names of Products. No Safety Data

Sheets, for the Air-Traveling Public’s Knowledge to

Protect from Illness and Injury. Please, Protect the

Air-Traveling Public with 100% Transparency.

Respectfully, still to this day from the First

Request to the 116th Congress, to where we are

today with the 118th Congress, the Air-Traveling

Public still has not been provided a “Certificate of

Compliance” that in fact the Airline Industry is

following the Rule of Law, Title 49 U.S.C. 5124.

20

100% Transparency is being Respectfully

Requested for the Air-Traveling Public, to Chemical

Products Exposed in the Aircraft Cabin for Cleaning,

Sanitizing, Disinfecting and Air-Freshening used inside

the Aircraft Cabin with Safety Data Sheets, so AirTravelers Know How Best to Protect their Safety and

Health.

Petitioner has Already Won her Case. The Ability

to Protect from Chemical Inhalation Exposure with

Personal Protective Equipment (PPE) has given Health

back to the Petitioner. Respectfully, this Petition

for Writ of Certiorari, is about the Air-Travelins

Public, who the Petitioner has a Job Duty and Res­

ponsibility to Ensure a Safe Environment. “We the

People” (Air-Travelers), Need 100% Transparency to

Aircraft Cabin Chemical Product Exposures.

With Respect, Petitioners Writ of Certiorari

has Merit to be Granted when the Federal Questions

have Never been answered.

WHO wants another Global Pandemic?

Petitioner believes in God the Father Almighty,

Creator of Heaven and Earth. The Creator of Us All

and Will Hold Each and Everyone of Us Accountable

for Our Actions in Our Life. Petitioner believes God

Greatly Forbids Harm and is Watching Very Closely

to Us All.

To Intentionally Harm People to Make a Profit,

is a Crime.

Therefore, Just to be Sure the Global Airline

Industry has No Part in Any Worldwide Breakout or

Wrong Doing, there Needs to be 100% Transparency,

21

Accountability to the Aircraft Cabin Products with

Safety Data Sheets.

A Great Idea for Worldwide Hotel Lobby and

Rooms Too!

Non-Toxic & Chemical Free!

Makins the World a Healthier and Better Place

to Be!

The Time has Come for 100% Transparency.

Petitioners Case has Merit.

The Credible Argument in Granting the

Petition For Writ of Certiorari, is as follows:

•

Chemical Exposure in the Aircraft Cabin

Environment.

•

Civil Justice for the Air-Traveler with

Transparency.

•

Commercial Aviation Industry Accountability.

•

Respondent (Employer) to Petitioner

(Employee) Relationships.

•

Petitioner who has been repeatedly con­

fronted with A Substantial Federal Ques­

tion that goes left Unanswered by the Courts,

while the Petitioners Job Duty and Respon­

sibility to Ensure a Safe Environment,

Remains a Safety and Health Issue for the

Air-Traveler without Transparency.

•

Safety is Top Priority.

YOUR HONOR and with Great Respect, Peti­

tioner is giving a Second Ideal Opportunity for Reso­

lution, Action and Outcome, with New Legislation and

Reform for 100% Transparency.

22

100% Safe, 100% Transparent Aircraft Cabin

Products for the Safety, Health, Dignity and Respect

that the Global Air-Traveling Public deserves.

YOUR HONOR and with Great Respect,

Petitioner will be Self-Publishing the Last of Five

Sequels. communicating in its Conclusion Chapter,

the Supreme Court of the United States Final

Judgment.

Respectfully, the Air-Traveling Public’s Safety

and Health is once again in your Most Honorable

Hands. May We All Please Agree Together that Under

the UNITED STATES CONSTITUTION: We

Must, with No Other Further Agenda, Honestly and

Truly “Protect the People”.

UNITED STATES CONSTITUTION:

“Protect the People”

23

CONCLUSION

For the Foregoing Reasons, in Good Conscience

and in Good Faith, may the Supreme Court of the

United States Grant this Respectful and Meaningful

Petition for Writ of Certiorari.

Respectfully submitted,

Christina Alessio

Petitioner Pro Se

1970 N. Cleveland-Massillon Rd. #589

Bath, OH 44210

(330) 338-7052

September 1, 2023