Reply Brief — Christina Alessio, Petitioner v. United Airlines, Inc., et al.

NO. 23-224

Sn the

Supreme Court of the United States

at OL

CHRISTINA ALESSIO,

Petitioner,

Vv.

UNITED AIRLINES, INC.,

Respondent.

On a Petition for a Writ of Certiorari to the

Court of Appeals of Ohio, Cuyahoga County

REPLY BRIEF OF PETITIONER

Christina Alessio

Petitioner Pro Se

1970 N. Cleveland-Massillon Road

Unit 589

Bath, OH 44210

(330) 338-7052

November 2, 2023

SUPREME COURT PRESS + (888) 958-5705 + BOSTON, MASSACHUSETTS

RECEIVED

NOV - 7 2023

FREE CObSTUS:

i

TABLE OF CONTENTS

Page

TABLE OF AUTHORITIES ..............ccccsscceeeesseeseceeees li

REPLY BRIEF ON

PETITION FOR CERTIORART ...0.........ccceceeeeee 1

CONCLUSION... ecceseeectseececetsesesssssesecseeneseeessees 13

i

TABLE OF AUTHORITIES

Page

CASES

Christina Alessio v. United Airlines, Inc, et al.,

SUPREME COURT OF OHIO,

Case No. 2023-0072 (April 11, 2028)....... ee ceecesseseee 3

Christina Alessio v. United Airlines, Inc.,

SUPREME COURT OF THE UNITED STATES,

Case No. 19-395 (September 19, 2019)..... 1, 3, 6, 9, 12

CONSTITUTIONAL PROVISIONS

UNITED STATES CONSTITUTION ........... 2,9, 12

STATUTES

49 U.S.C. § 5124... 2, 3, 5, 6, 7, 9, 10, 11, 12

JUDICIAL RULES

Sup. Ct. R. 15.6... ccessscssscssssscessesesssesesecssseeeseeeeeaes 1

S. Ct. Prac. R: 7:08(B)(4) senwcussucapovasspussspsancevanassecsesates 3

REPLY BRIEF ON

PETITION FOR CERTIORARI

With respect, and per Rule 15.6, Petitioner

may file a “REPLY BRIEF’ to call attention to New

Points declared in the Respondents “BRIEF IN

OPPOSITION”.

Respectfully, Counsel for the Respondent filed

a “BRIEF IN OPPOSITION” on October 11, 2023, with

the SUPREME COURT OF THE UNITED STATES,

in Response to the Petitioner’s Request to Grant a

“Writ of Certiorari’, Seeking for 100% Transparency

to the Chemical Substance Products used inside

the Respondent’s Commercial Aircraft Cabins, for

Cleaning, Disinfecting, Sanitizing and Air-Freshening,

which is the Petitioners Global Work Environment.

A Work Environment with a Duty and Responsibility

to Ensure a Safe Environment for the General Air-

Traveling Public.

With respect, Petitioner’s “REPLY BRIEF filed

on November 2, 2023, is addressing New Points

adding Insight, Clarity and Understanding from the

Respondent’s Counsels written “BRIEF IN OPPOSI-

TION” for a Sincere, Mindful Judicial Review for

Granting the Petitioner a Writ of Certiorari.

The Contents of Petitioner’s “REPLY BRIEF’

calls Attention to Counsels Written “BRIEF IN

OPPOSITION” for the Respondent. Respectfully,

Adding Again as in Case No. 19-395 (Ref., Table

of Authorities, page ii) is being Summarized by

the “Facts of this Case” that are 3 Fold:

Respectfully,

1. To Communicate a Mindful Focus on the UIltimate Responsibility under the UNITED STATES

CONSTITUTION: To Protect the People.

2. Exposure of Chemical Substance Products

in the Aircraft Cabin Approved by the Respondent. A

Question that Still Needs Answered, as to Whether or

Not this Chemical Routine Practice is “In Compliance”

with the Statutes.

The Federal Question:

Is the Respondent “In Compliance” with the

Hazard Material Transportation Act (HMTA)

Title 49 U.S.Code 5124, Forbidding Hazards

onboard the Aircraft?

3. Oversight and Legislation by America’s

118th Congress:

New Legislation is Needed for a Fair, Right and

Just Intention, “To Protect the People” with a

Knowing and Willful Transparent Offical Congressional

“Certificate of Compliance”, from the Past to the

Present Suspicious Chemical Substance Products

used for Cleaning, Disinfecting, Sanitizing and Air

Freshening, Inside the Aircraft Cabin, being Inhaled

by the General Air-Traveling Public.

PETITIONER’S REPLY

REQUESTING ATTENTION:

NEW POINTS:

“ARGUMENT / REASONS TO DENY PETITION”,

written by the 2023, Counsel for the Respondent:

I. “The Petition should be denied because

there are no “compelling reasons” for granting

certiorari in this case.” (page 6, of the BRIEF IN

OPPOSITION)

Respectful Compelling Reason #1

SUPREME COURT OF THE UNITED STATES

Case No. 19-395, (a different Counsel for the Respondent) wrote on page 6, to the “BRIEF IN OPPOSITION”:

“ARGUMENT / REASONS TO DENY PETITION

I. The Petition should be denied because

there are no “compelling reasons for granting

certiorari in this case.”

Respectful Compelling Reason #2

YOUR HONOR and with great respect, the

Supreme Court of Ohio (SCO) Declined to Accept

Case No. 2023-0072, the Petitioner’s (Appellant)

Due Process to be Heard. Final Judgment was in

Reference to S.Ct. Prac. Rule 7.08 (B)(4).

Respectfully the Supreme Court Practice Rule,

communicates there is No Great General Public

Interest.

Respectfully and on the Contrary, Petitioner

Believes this Case is of Great General Public Interest.

Petitioner’s Work Environment is Global.

SCOTUS Case No. 19-395, was about Requesting

100% Transparency to the Aircraft Cabin

Chemical Substance Products and an Answer to

Federal Law, HMTA Title 49 U.S.Code 5124,

forbidding hazard materials onboard the Aircraft.

Was/Is the Respondent is “In Compliance”? The

Question has Never Been Answered by the

Judical Branch and the Case was Denied on or

about the Same Day, Centers for Disease Control and

Prevention (CDC) Confirmed the First Case of

Coronavirus (COVID-19) in the United States of

America, Resulting in a Global Pandemic.

Respectfully, the Federal Question Needs Answered

with 100% Transparency to Protect the People, The

General Air-Traveling Public.

Respectful Compelling Reason #3

YOUR HONOR and with great respect, Ohio

Bureau of Workers’ Compensation (BWC) signed a

Wavier regarding Case No. 23-224. The BWC, does

not Intend to File a Response.

In Addition, the Respondent Continues to Refuse

an Independent Medical Examination (IME) Requested

by the Petitioner to the Chemical Substance

Products used inside the Aircraft Cabin.

Respectfully, if the Respondent (Employer)

refuses an IME to the Petitioner and the Petitioner

(Employee), is Responsible for the Customers in this

Unique and Particular Work Environment, what is

this Saying About the Respondent (Employer) with

Respect to the Customers, in the Aircraft Cabin, the

Petitioners (Employee) Work Environment?

Respectful Compelling Reason #4

YOUR HONOR and with great respect, 2 BILL

PROPOSALS were mailed to Ohio Representatives of

Congress, Notorized and Certifed: May 15, 2020 and

July 10, 2020, during the Outbreak of Coronavirus

(COVID-19). Reference: SCOTUS Case No. 23-224,

App. 69a-79a.

Respectful Compelling Reason #5

YOUR HONOR and with great respect, to be

Clear and for the Record it has been Communicated

to the Best of the Petitioner’s Ability and Understanding, that the Respondent Knowingly and Willfully

Approves the Use and Exposure of Inhaled “Chemical

Substance Products” in the Aircraft Cabin, with

Labels that State: “HAZARDS TO HUMANS AND

DOMESTIC ANIMALS.”

Respectful Compelling Reason #6

YOUR HONOR and with great respect, the

Petitioners Job Duty, Responsibility, and Obligation

is to Ensure a Safe Environment in the Aircraft Cabin

and to Communicate any Safety Concerns up the

Leadership Chain until Resolved. The Safety Concern

is Not Resolved without 100% Transparency to the

Aircraft Cabin Products and a “Certificate of Compliance” from our 118th Congress that In Fact the

Respondent is following the Rule of Law, Federal

Law: (HMTA) Title 49 U.S.Code 5124, forbidding

hazard materials (Exposing and being Inhaled)

onboard the Aircraft.

Respectful Compelling Reason #7

YOUR HONOR and with great respect, No One,

No Industry, is or should be Above Federal Law.

EQUAL JUSTICE UNDER THE LAW.

Respectful Compelling Reason #8

YOUR HONOR and with great respect, the Petitioner reached out for a Third Party Opinion: The

Equal Employment Opportunity Commission (EEOC)

which Communicates in the NOTICE OF RIGHTS

Letter dated April 18, 2017 (SCOTUS Case No. 19-395:

Petitioner’s App., 94a-95a. Also, provided in this Case

No. 23-224: Petitioner’s App., 44a-45a.), the Inability

to Certify that the Respondent is In Compliance

with the Statutes. Respectfully, the Question still

Needs Answered, this is a Federal Law, (HMTA) Title

49 U.S.Code 5124. With Respect, is the Respondent

In Compliance with the Statutes Knowingly and

Willfully Using and Exposing “Chemical Substance

Products” in the Aircraft Cabin, Inhaled by the General Air-Traveling Public?

Respectful Compelling Reason #9

YOUR HONOR and with great respect, You Are

What You Inhale.

If you Inhale Cigarette Smoke, results are Cancer.

If you Inhale Marijuana Smoke, results are you

get High.

If you Inhale Pollen, results are Sneezing,

Coughing, Allergies.

If you Inhale Peanut Dust, Allergic results are

Unhealthy.

And if you Inhale Chemicals, results are

Unhealthy, Irritation and Damage to the Body.

However, if you Inhale GOD-CREATED MOTHER

EARTH GROWN Lemons, results are Healthy anda

Better Mood.

How is Routine Use and Exposure of “Chemical

Cleaning, Disinfectants, Sanitizers and Air-

Fresheners” in the Aircraft Cabin for “The General

Air-Traveling Public to Inhale’, without 100%

Transparency, Safe? Especially without Protective

Measures, No Ability to follow the First Aid Procedures

to Remove From and Seek Fresh Air, is just Simply Not

an Option in this Unique and Particular Environment.

Respectfully, how _is the Respondent “In Compliance” with (HMTA) United States Code 5124, Federal

Law? Respectfully, the Question still Needs Answered.

With this Type of Chemical Exposure Routine of

Cleaning, Disinfecting, Sanitizing and Air-

Freshening Inhalation (in between every single flight,

numerous times a day) (Ingredients Not Applicable),

to “Chemical Substance Products” chosen for inside

the Aircraft Cabin, how is this not a blatant physical

assault on the General Air-Traveling Public’s Health?

Respectful Compelling Reason #10

Are the Commercial Aircraft Cabin Chemical

Substances used for Cleaning, Disinfecting, Sanitizing

and Air-Freshening, Sanction Products’?

The General Air-Traveling Public deserves the

Truth with 100% Transparency. The Government

Works for the General Public. This Includes the General Air-Traveling Public.

A “Certificate of Compliance” is being Respectfully Requested by our 118th Congress, providing

100% Transparency.

This Case is about: “Right to Know” and “Need

to Know”.

Provide Commercial Air-Traveler’s with a List of

the Aircraft Cabin Products, for Cleaning, Disinfecting,

Sanitizing and Air-Freshening with Safety Data Sheets

and Approval by our Government, the Legislative

118th Congress, with a “Certificate of Compliance”.

Respectfully, Petitioner believes this type of

Routine Use and Exposure of “Chemical Substance

Products” inside the Aircraft Cabin without 100%

Transparency, a contributing result of Acute

Airsickness with Unhealthy Side Effects, in Addition

to Chronic Illnesses and Disease, upto and including

Cancer, Covid-19 or even Another Global Pandemic.

Respectful Compelling Reason #11

YOUR HONOR and with great respect, the Law

Must be Followed.

EQUAL JUSTICE UNDER THE LAW.

It is Against the Law to Inhale Cigarette Smoke

on the Aircraft.

Is it then, Against the Law to Spray or Wipe Down

Tray Tables throughout the Cabin with “Chemical

Substance Products”, with Labels that Read:

“PRECAUTIONARY STATEMENT: HAZARDS

TO HUMANS AND DOMESTIC ANIMALS.” ?

Respectful Compelling Reason #12

Petitioner believes in The United States of

America and our Founding Fathers, in Upholding THE

UNITED STATES CONSITUTION: To Protect

the People.

The General Public.

And in this Case: The General Air-Traveling

Public.

Respectful Compelling Reason #13

YOUR HONOR and with great respect, the

Counsel for the Respondent in this Case No. 23-224

communicates on page 10 of the Respondent’s BRIEF

IN OPPOSITION:

“III. The Petition should also be denied

because the HMTA does not provide for a private

cause of action.”

Petitioners respectful response:

SCOTUS Case No. 19-395: A different Counsel

for the Respondent communicates on page 8, in the

“BRIEF IN OPPOSITION”:

“II. The Petition should also be denied

because the HMTA does not provide for a private

cause of action.”

Petitioners Respectful Continued Response:

This Case, is not about a private cause of action.

Rather, a Public Cause of Action.

Respectfully, Petitioner believes that if Congress did not intend to create a private cause of action,

there needs to be a Public Cause of Action under

(HMTA) Title 49 U.S.Code 5124, for the General Air-

Traveling Public, in coordination and due to No

“Certificate of Compliance” from Congress, No

Transparency from the Respondent to the

“Chemical Substance Products” Used, Exposed

and Inhaled inside the Aircraft Cabin, of which are

Approved by the Respondent with Ingredients,

Not Applicable. The United States of America,

Legislative Branch respectfully, Needs to Uphold

their Oath of Office, Truly, to THE UNITED STATES

CONSTITUTION: To Protect The People.

YOUR HONOR and with great respect, Petitioner is requesting America’s Judicial Branch to

10

require America’s Legislative Branch to confirm

that the Respondent is “In Compliance” with (HMTA)

Title 49 U.S.Code 5124, providing 100% Transparency.

Respectfully, how or why would the Legislative

Branch pass an amendment to ban federal mask

mandates on Commercial Flights, before providing

100% Transparency with Exposure to Aircraft Cabin

Chemical Products?

With Respect, Petitioner believes that this is an

example of putting the Cart before the Horse.

Petitioner believes the Hazard Material Transportation Act (HMTA) Title 49 U.S.Code 5124 is being

violated without a “Certificate of Compliance” from

our 118th Congress. To provide 100% Transparency

to the Aircraft Cabin Products Inhaled used for

Cleaning, Disinfecting, Sanitizing and Air-Freshening

with Safety Data Sheets, for the Safety and Health of

the General Air-Traveling Public.

Petitioner is Respectfully Suggesting Non-

Toxic, Chemical-Free, 100% Safe and 100% Transparent Aircraft Cabin Products for Cleaning,

Disinfectants (Not Pesticides), Sanitizers and Air-

Freshening (Mother Earth) Products for the

Safety and Health of the General Air-Traveling

Public.

Respectful Compelling Reason #14

Counsel for the Respondent is simply trying to

Protect their Client.

Petitioner Pro se, has a Duty and Responsibility

to Ensure a Safe Environment in the Aircraft Cabin,

and is simply trying to Protect the Safety and Health

of All Flight Crew and Customers, Simply Requesting

11

100% Transparency to the Chemical Substance

Products Used, Exposed and Inhaled in the Aircraft

Cabin for Cleaning, Disinfecting, Sanitizing and Air-

Freshening with Safety Data Sheets, Simply for the

Sake of the General Air-Traveling Public.

THIS CASE IS ABOUT:

While the Respondents Office is on the Ground.

the Petitioners Office is in the Sky, at 30,000 feet.

1. A Much Needed “Answer to a Federal Law

Question”, from the Highest Court in the Land of

America, the SUPREME COURT OF THE UNITED

STATES, Judical Branch.

Federal Question:

Is the Respondent “In Compliance” with HMTA

Title 49 U.S.Code 5124, forbidding hazard materials

onboard the Aircraft, when Respondent Approves the

Use, Exposure and Inhalation of “Chemical Substances”

being Sprayed and Tray Tables Wiped with Products

that State: “HAZARDS TO HUMANS AND DOMESTIC

ANIMALS”, inside the Aircraft Cabin?

2. A Much Needed “Certificate of Compliance’,

from America’s 118th Congress, providing 100%

Transparency from the Respondent, to the Aircraft

Cabin Chemical Substance Products regarding

HMTA Title 49 U.S.Code 5124, that In Fact the Respondent is “In Compliance” with Federal Law, once

Created and Presently to, “Protect the People”, by

our Legislative Branch.

With the Greatest Respect, may THE

SUPREME COURT OF THE UNITED STATES,

in the Interest of the General Public’s Air-Travel

12

Safety and Health, Grant the Petitioner’s Writ of

Certiorari.

RELEVANT STATUTE and CASES:

THE UNITED STATES CONSTITUTION: To

Protect the People.

Federal Law Statute:

Hazard Material Transportation Act (HMTA)

49 U.S. Code 5124.

Relevant Cases:

SUPREME COURT OF THE UNITED STATES

Case No.19-395.

SUPREME COURT OF OHIO

Case No. 2023-0072.

Respectfully, any further STATUTE or CASE

referenced and communicated by the Counsel for the

Respondent in the written “BRIEF IN OPPOSITION’,

Petitioner is Requesting the Court Rule of all other

References to be Dismissed, unless 2 Factors Apply,

giving Merit for a Fair, Right, True and Just Comparison.

Factor 1. Federal Law.

The Case must be a Federal Law, not State or Local.

Factor 2. Location of Environment.

Location of the Environment must be Air-Travel

(Commercial Public Transportation).

Respectfully, Petitioner believes any true

comparison would have to be a Case Location in

Public Transportation, “To Protect the People”.

13

Re

CONCLUSION

Respectfully, for the Foregoing Reasons Submitted in Good Conscience and Good Faith, may THE

SUPREME COURT OF THE UNITED STATES, Find

Merit in Granting the Petitioner’s Writ of Certiorari.

Respectfully submitted,

Christina Alessio

Petitioner Pro Se

1970 N. Cleveland-Massillon Rd.

Unit 589

Bath, OH 44210

(330) 338-7052

November 2, 2023

BLANK PAGE

SUPREME COURT

PRESS