Reply Brief — Stephen C. Stanko, Petitioner v. Bryan P. Stirling, Director, South Carolina Department of Corrections, et al.

No. 24-6420

(Capital Case)

IN THE

Supreme Court of the United States

STEPHEN C. STANKO, Applicant/Petitioner

v.

BRYAN STIRLING, Director, South Carolina Department of Corrections,

and Lydell Chestnut, Deputy Warden Broad River Correctional Institution,

Respondents

______________

REPLY BRIEF IN SUPPORT OF PETITION FOR WRIT OF CERTIORARI

______________

E. CHARLES GROSE, JR. (Fed ID 6072)

The Grose Law Firm, LLC

305 Main Street

Greenwood, SC 29646

(864) 538-4466 (tel)

charles@groselawfirm.com

JOSEPH J. PERKOVICH

Counsel of Record

Phillips Black, Inc.

PO Box 3547

New York, NY 10008

212.400.1660 (tel)

888.543.4964 (fax)

j.perkovich@phillipsblack.org

JOSEPH C. WELLING

Phillips Black, Inc.

100 N. Tucker Blvd., Ste. 750

St. Louis, MO 63101

314.629.2492 (tel)

888.543.4964 (fax)

j.welling@phillipsblack.org

Counsel for Applicant/Petitioner Stephen C. Stanko

i

TABLE OF CONTENTS

TABLE OF CONTENTS ..................................................................................................... ii

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

I. RESPONDENTS DEFEND THE FOURTH CIRCUIT’S MISCHARACTERIZATION OF MR.

STANKO’S § 3599(F) DUE PROCESS ISSUE, ENDORSING MISAPPLICATION OF

INAPPOSITE LAW TO DETERMINE WHETHER A COA IS REQUIRED........................ 2

A. A Timely Filed Rule 59(e) Motion Cannot Be Construed as an

Improper Second or Successive Habeas Petition. ......................... 4

B. Conflation of the § 3599(f) Issue with Rule 59(e) Confuses the

Timeline, Inaccurately Imputing the District Court’s Reliance

on Shinn v. Ramirez to its Pre-dating Denial of Stanko’s

Opportunity to Use Authorized Specialist Services. .................... 6

II. RESPONDENTS FAIL TO ENGAGE MEANINGFULLY WITH THE EGREGIOUS FACTS

AND LAW APPLICABLE TO DIGGS’S ACTUAL CONFLICT WHICH ADVERSELY

AFFECTED THE REPRESENTATION AND RELEVANT CIRCUMSTANCES OF STANKO’S

ALLEGED WAIVER. .................................................................................................... 7

A. Clearly Established Law Has Held that An Actual Self-Interest

Conflict Which Adversely Affects the Representation Requires

Reversal. ................................................................................................. 8

B. Rehearsal of the Trial Court Waiver Proceedings Do Not

Address Stanko’s Known Brain Damage or Show He Was

Properly Advised. ............................................................................... 10

III. CONCLUSION .................................................................................................... 11

ii

TABLE OF AUTHORITIES

Page(s)

Cases

Andrew v. White,

145 S. Ct. 75 (2025) ..................................................................................................... 8

Ayestas v. Davis,

584 U.S. 28 (2018) ...................................................................................................... 2

Banister v. Davis,

590 U.S. 504 (2020) ................................................................................................. 4, 5

Browder v. Director, Dept. of Corrections of Ill.,

434 U.S. 257 (1978) ..................................................................................................... 4

Cullen v. Pinholster,

563 U.S. 170 (2011) .................................................................................................... 6

Cuyler v. Sullivan,

446 U.S. 335 (1980) ................................................................................................. 7, 8

Harbison v. Bell

556 U.S. 180 (2009) ................................................................................................. 2, 7

Holloway v. Arkansas,

435 U.S. 475 (1978) .................................................................................................... 8

Michigan v. Jackson,

475 U.S. 625 (1986) .................................................................................................... 8

Mickens v. Taylor,

535 U.S. 162 (2002) ..................................................................................................... 8

Montejo v. Louisiana,

556 U.S. 778 (2009) ..................................................................................................... 8

MSP Recovery Claims, Series LLC v. Lundbeck LLC,

130 F.4th 91 (4th Cir. 2025) ....................................................................................... 5

Reid v. Angelone,

369 F.3d 363 (4th Cir. 2004) ...................................................................................... 5

Shinn v. Ramirez,

596 U.S. 366 (2022) .................................................................................................... 6

Shoop v. Twyford,

596 U.S. 811 (2022) ..................................................................................................... 7

iii

Stanko v. Stirling,

109 F.4th 681 (4th Cir. 2024) ............................................................................. 1, 2, 3

United States v. McRae,

793 F.3d 392 (4th Cir. 2015) ....................................................................................... 5

United States v. Schwarz,

283 F.3d 76 (2d Cir. 2002) ........................................................................................ 10

Wheat v. United States,

486 U.S. 153 (1988) ..................................................................................................... 9

Statutes

18 U.S.C § 3599(f) ................................................................................................ Passim

28 U.S.C. § 2244(b) ........................................................................................................ 4

28 U.S.C. § 2253 ................................................................................................... Passim

iv

Pursuant to Rule 15.6, Applicant/Petitioner Mr. Stanko, hereby replies to

Respondents’ Brief in Opposition (“Opp.”) to Mr. Stanko’s Petition for Writ of

Certiorari (“Pet’n”).

Respondents reproduce the Fourth Circuit’s mischaracterization of the

18 U.S.C § 3599(f) issue as one that is a matter of “the district court’s denial of Mr.

Stanko’s Rule 59(e) motion,” which “arose from the district court’s earlier grant of his

request for funding for brain imaging and expert analysis under § 3599(f).” Stanko v.

Stirling, 109 F.4th 681, 699 (4th Cir. 2024). This mischaracterization appears to stem

from Stanko’s broad issue in his COA that the district court erroneously denied the

motion to alter or amend the judgment. Opp. at 15 (citing COA4 49, Issue 2).

Regardless of the source of the confusion, this conflation of the § 3599(f) issue with

disposition of the Rule 59(e) motion led to application of an inapposite test and ignores

authority cited in the Petition firmly establish that a COA is not required because

this issue on appeal did not relate closely to the merits of the underlying petition for

habeas corpus.

Respondents similarly fail to engage meaningfully with the facts and

arguments related to the egregious actual self-interest conflict of trial counsel

William Diggs. On the merits, Respondents argue that there is no clearly established

federal law that actual conflicts of interest that adversely affect the representation

are “unwaivable.” Opp. at 22. They ignore clearly established law that there are only

two elements in actual conflict cases: actual conflict and adverse effect on the

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representation. Pet’n at 36–40. Respondents also fail to engage in the Petition

arguments that even if an actual conflict which adversely affects the representation

is waivable, it was not waived in this case in which Mr. Stanko, a defendant with a

history of brain damage and illness, was never properly advised on the consequences

of waiver. Opp. at 24; Pet’n at 40–41.

I.

RESPONDENTS DEFEND THE FOURTH CIRCUIT’S MISCHARACTERIZATION OF

MR. STANKO’S § 3599(F) DUE PROCESS ISSUE, ENDORSING MISAPPLICATION

OF INAPPOSITE LAW TO DETERMINE WHETHER A COA IS REQUIRED.

The Court of Appeals’ boiled down characterization was that it “denied a [COA]

on this [Rule 59] issue, but Stanko insists he does not need one to go forward.” Stanko,

109 F.4th. at 699–700. The court below does not specify this denial pursuant to

28 U.S.C. § 2253(c)(1) and elides any discussion of the controlling case of this Court

on the question of whether a COA is needed, Ayestas v. Davis, 584 U.S. 28 (2018),

despite that opinion’s refinement of the establishment in Harbison v. Bell that a COA

is not required for issues that do not comprise “the final order in a habeas corpus

proceeding.” 556 U.S. 180, 182 (2009). Respondents seem to identify the element of

the COA application most likely in question (supra), wherein Stanko enumerated the

district court’s broad “[f]ailing to correct its own errors” in “denying Mr. Stanko’s Rule

59(e) motion.” Opp. at 15. That facet of the COA application, however, in no way cast

the deprivation of the § 3599(f) specialist services as a merits issue—which it plainly

is not—and thereby one necessitating the granting of a COA in relation to a merits

determination of the district court. Harbison, 556 U.S. at 183 (cited in Stanko, 109

F.4th at 700).

2

While Respondents now invoke the Fourth Circuit’s phrasing of the COA

status, id. (quoting Stanko, 109 F.4th at 700 (“Stanko insists he does not need one to

go forward.”)), their current position departs from Respondents’ understanding of the

§ 3599(f) question manifested throughout the merits briefing in the Court of Appeals,

wherein they never argued that Stanko had insisted, let alone that he needed to

insist, that the § 3599(f) deprivation was tied to the district court’s failure to grant

the Rule 59(e) motion. Rather, Stanko directly argued, in “Issue 1” of his merits brief

(as one of two “Global Issues”) that the district court’s denial of his petition deprived

him of the entitlement to particular specialist services that the lower courts “had

already deemed ‘reasonably necessary’ under the standard governing 18 U.S.C. §

3599(f).”

Put simply, the issue on appeal is that the district court erred when it granted

summary judgment without affording Stanko the opportunity to use previously

authorized specialist services.1 The Fourth Circuit’s mischaracterization of this issue

as one involving the Rule 59(e) motion led to misapplication of an inapposite test

(whether the Rule 59(e) motion was “denied” or “dismissed”) as a substitute for

relying on firmly established precedent that disputes involving § 3599(f) funding are

not sufficiently related to the underlying habeas petition as to require a COA

pursuant to § 2253(c).

1 Respondents falsely claim “Stanko had failed to provide the district court with any explanation for

the delay in obtaining high resolution medical scans. Opp. at 14–15. In fact, the District Court was

privy to ex parte filings and ultimately granted the transport order for the imaging to be conducted on

March 3, 2024, just three weeks before it granted summary judgment. Pet’n at 35–36.

3

The Fourth Circuit’s analysis of the § 3599(f) deprivation and § 2253(c) suffers

from two points of confusion that Respondents’ arguments only compound.

A. A Timely Filed Rule 59(e) Motion Cannot Be Construed as an

Improper Second or Successive Habeas Petition.

First, the Court of Appeals confuses the function of Rule 59 in relation to

habeas corpus. As this Court has recently explained, Rule 59(e) affords a district court

the means to “‘reconsider the grant or denial of habeas corpus relief’ in the same way

it could review any other decision.” Banister v. Davis, 590 U.S. 504, 513 (2020)

(quoting Browder v. Director, Dept. of Corrections of Ill., 434 U.S. 257, 270 (1978)).

Browder has long provided that a motion to alter or amend under Rule 59(e)

“‘suspend[ed] the finality’ of any judgment, including one in habeas—thus enabling a

district court to address the matter again.” Banister, 590 U.S. at 513 (quoting

Browder, 434 U.S. at 270). This straight-forward understanding of Rule 59’s workings

further clarifies the distinction between reconsideration motions under that rule and

motions to reopen pursuant to . Civ. P. 60(b). As Banister put it amid a determination

of whether Rule 59 functioned in habeas corpus as a second or successive application

generally proscribed by 28 U.S.C. § 2244(b), “Rule 60(b) differs from Rule 59(e) in just

about every way that matters to the inquiry here.” 590 U.S. at 518. Justice Kagan,

writing for the Court explained:

Rule 59(e) derives from a common-law court’s plenary power to revise

its judgment during a single term of court, before anyone could appeal.

By contrast, Rule 60(b) codifies various writs used to seek relief from a

judgment at any time after the term’s expiration—even after an appeal

had (long since) concluded. Those mechanisms did not (as the term rule

did) aid the trial court to get its decision right in the first instance;

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rather, they served to collaterally attack its already completed

judgment.

Banister, 590 U.S. at 518–19 (citations omitted). Further per Banister, any “ruling on

the Rule 59(e) motion merges with the prior determination, so that the reviewing

courts takes up only one judgment.” 590 U.S. at 509 (quoted in MSP Recovery Claims,

Series LLC v. Lundbeck LLC, 130 F.4th 91, 112 (4th Cir. 2025)).

The Fourth Circuit’s approach in Stanko, as Respondents have recapitulated

it, fails to absorb Banister’s articulation of the relationship between the distinct Rule

59(e) and Rule 60(b) procedures, instead grafting a Rule 60(b) analysis from Reid v.

Angelone, 369 F.3d 363 (4th Cir. 2004), and United States v. McRae, 793 F.3d 392,

399 (4th Cir. 2015),2 onto its review of the district court’s final judgment denying the

§ 2254 action simply because Stanko took the routine step of moving for

reconsideration pursuant to Rule 59(e). Opp. at 16. That reconsideration motion

simply could not transform the § 3599(f) issue into a merits decision needing a COA

grant for consideration. Yet the Court of Appeals shifted the framework for any

contemplation of the specialist funding deprivation to the decision on the Rule 59(e)

2 In McRae, after summary judgment denying his habeas petition, and denial of a timely filed “petition

for rehearing and rehearing en banc, and a writ for certiorari,” the petitioner filed a Rule 60(b) motion.

McRae 793 F.3d at 396. To determine whether disposition of the Rule 60(b) motion was subject to the

COA requirement in § 2253, the Fourth Circuit noted that whether it was denied or dismissed may be

helpful because “[w]hile a denial of a Rule 60(b) motion may be sufficiently connected to the merits of

the underlying habeas proceeding, a dismissal is not.”). Id. at 399. Here, by contrast, the Fourth Circuit

applies that rule to the disposition of Stanko’s Rule 59(e) motion, not a subsequently filed Rule 60(b)

motion.

Further, even if a Rule 60(b) motion were at issue in this case, the mere fact of a denial would not be

dispositive. McRae only holds that dismissal means it could not possibly be sufficiently connected to

require a COA, but a denial means it may or may not be. Respondents incorrectly reason that denial

automatically means disposition was sufficiently related to the underlying merits without further

analysis. Opp. at 16.

5

motion rather than the denial of the habeas corpus petition and, in the process, folded

into its analysis the inapposite Rule 60(b) precedents noted above. This approach not

only utterly misunderstands the distinction between Rule 59 and Rule 60, it split

away that Court of Appeals from the other circuits that have spoken to the

relationship of Rule 59(e) and § 2254(c). Pet’n at 32-33.

B. Conflation of the § 3599(f) Issue with Rule 59(e) Confuses the

Timeline, Inaccurately Imputing the District Court’s Reliance on

Shinn v. Ramirez to its Pre-dating Denial of Stanko’s Opportunity

to Use Authorized Specialist Services.

Second, the Court of Appeals muddled the timeline governing the § 3599(f)

analysis. As set forth in the Petition, the district court’s § 3599(f) deprivation occurred

well before this Court decided Shinn v. Ramirez, 596 U.S. 366 (2022). Pet’n at 34–35.

Respondents bolster the Court of Appeals’ analysis wrongly situated within the

district court’s Rule 59(e) posture, defending the court’s reconsideration decision on

the basis that Shinn would render inadmissible any new evidence to emerge from the

§ 3599(f) specialist services. Opp. at 16–17. That argument cannot justify the initial

decision to deny Stanko’s habeas petition. More critically, the admissibility of

evidence developed via § 3599(f) raises a separate question from the entitlement to

the requisite resources for development in the first place. While Shinn extended

Cullen v. Pinholster, 563 U.S. 170 (2011), in relation to 28 U.S.C. § 2254(e)(2), it could

not have impaired the statutory entitlements under § 3599(f). Pet’n at 34.

Respondents conclusorily assert that stay and abeyance of district court proceedings

would not have been available to Stanko. Opp. at 17–18. That speculation is

6

unhelpful, as Respondents overstate the impact of this post-judgment authority on

foreclosing review. Pet’n at 31, 36 n.13.3

II.

RESPONDENTS FAIL TO ENGAGE MEANINGFULLY WITH THE EGREGIOUS FACTS

AND LAW APPLICABLE TO DIGGS’S ACTUAL CONFLICT WHICH ADVERSELY

AFFECTED THE REPRESENTATION

STANKO’S ALLEGED WAIVER.

AND

RELEVANT CIRCUMSTANCES

OF

As an initial matter, Respondents reargue the procedural bar theory accepted

by the state supreme court that the conflict issue was not preserved because either

Diggs failed to object to his own self-interest conflict or Stanko failed to act pro se to

object to the conflict despite his known brain anomalies. Opp. at 18. This theory is so

outlandish neither the district nor circuit court credited it. Cuyler v. Sullivan, 446

U.S. 335, 350 (1980) (an actual conflict which adversely affected the representation

even when the defendant “raised no objection at trial”).

On the merits, Respondents fail to address the Petition arguments showing

that “actual conflict and adverse effect” are the clearly established test for reversible

Sixth Amendment violation and that attorney self-interest conflicts have been found

to be per se unwaivable. Pet’n at 36–37. Instead, they rely on a theory that Stanko

waived the conflict, without addressing the lack of sufficient evidence of knowing,

voluntary, and intelligent waiver. Opp. at 19–22.

3 Similarly, Respondents, like the Fourth Circuit, rely on Shoop v. Twyford, 596 U.S. 811, 820 (2022),

(Opp. at 17), without Stanko’s arguments showing it is inapposite to the question at issue—viz., the

propriety of depriving Stanko of completing the authorized specialist services which is likely to

generate evidence admissible in the first instance in available state court proceedings, including

clemency. Pet’n at 34–35 (citing, inter alia, Harbison, 566 U.S. at 183–87.

7

A. Clearly Established Law Has Held that An Actual Self-Interest

Conflict Which Adversely Affects the Representation Requires

Reversal.

The Respondents ignore clearly established law in Holloway v. Arkansas, 435

U.S. 475 (1978),4 and Cuyler v. Sullivan, 446 U.S. 335 (1980). This Court recently

clarified that “clearly established federal law” is any holding of this Court, even when

it is applied to very different case facts. Andrew v. White, 145 S. Ct. 75, 81–83 (2025).

Instead of applying Holloway and Cuyler, Respondents rely on inapposite precedent

to bolster a position contrary to the one the State adopted in characterizing Diggs’s

conflict as “non-waivable.” App.172. These authorities are misdirected and rely on

cases of “potential conflicts” or even the “appearance of impropriety” rather than

actual conflicts which adversely affect the representation.5

For example, Respondents endorse the Fourth Circuit’s reliance on Montejo v.

Louisiana, 556 U.S. 778, 786 (2009) (Opp. at 22 n.4), which is a case modifying the

rule from Michigan v. Jackson, 475 U.S. 625 (1986) (holding that a defendant who

asserts the right to counsel at arraignment may not be questioned by police without

counsel present regardless of subsequent waiver of the right to have counsel present),

4 The Respondents repeatedly rely on a distortion of Holloway, saying that the Court “recognize[d]

conflict may be waived.” Opp. at 23, 24. They rely on footnote 5 of the opinion which states “a defendant

may waive his right to the assistance of an attorney unhindered by a conflict of interests.” Holloway,

435 U.S. at 483 n.5 (emphasis added). Those were not the circumstances in Holloway, id., nor in this

case, where Diggs’s actual conflict is undisputed.

They fail to mention Cuyler at all. See Opp. at ii.

5 This Court has recognized that because the potential for conflict “inheres in almost every instance of

multiple representation,” the trial court has a duty to provide the opportunity to inquire into whether

such “potential conflicts impermissibly imperil [the defendant’s] right to a fair trial. Cuyler, 446 U.S.

at 348, But an “actual conflict of interest means “precisely a conflict that affected counsel’s

performance—as opposed to a mere theoretical division of loyalties.” Mickens v. Taylor, 535 U.S. 162,

171 (2002). Here, it is uncontroverted that Diggs’s conflict of interest was actual.

8

by concluding that in states where arraignment counsel is appointed passively (that

is, with no affirmative assertion by the defendant), the defendant may waive the

presence of counsel at subsequent police interrogation. Significantly, Montejo does

not involve an actual or even potential conflict of interest. The Fourth Circuit claims

the Montejo holding is “analogous” without spelling out how a question ultimately

about admissibility of a confession or waiver of counsel “unhindered by conflicts”

(supra note 4) addresses the rule that reversal is required when there is an actual

conflict that adversely affected the representation.

Respondents also cite Wheat v. United States, 486 U.S. 153, 162–63 (1988).

Opp. at 22. But Wheat held that a court may refuse to accept waiver of potentially

conflicted counsel and affirmed denial of the defendant’s motion to substitute counsel

of his choice (who was representing a co-defendant who entered a guilty plea at

arraignment but was then still free to withdraw the plea). Respondents fail to say

how this authority is relevant at all. This Court’s holding was predicated on the

observation that the right to choose counsel is limited, and although representation

of co-defendants is “‘not per se violative of constitutional guarantees of effective

assistance of counsel,’” courts should strive to avoid such “possible conflicts of

interest.” Wheat, 486 U.S. at 160. Contrary to Respondents’ position here, Wheat

rejected that there is a “flat rule . . . in favor of counsel of choice,” which says “the

provisions of waivers by all affected defendants cures any problems created by the

multiple representation.” Id.

9

Respondents also ignore the important difference between an attorney selfinterest conflict and potential conflicts arising from simultaneous representation of

co-defendants. The Petition cites authorities showing a sharp demarcation: selfinterest conflicts are actual while simultaneous representation of co-defendants are

potential conflicts which may, at least in some circumstances, be waived. Pet’n at 37–

38 (citing, inter alia, United States v. Schwarz, 283 F.3d 76, 96 (2d Cir. 2002)).

Respondents fail to address this authority at all.

B. Rehearsal of the Trial Court Waiver Proceedings Do Not Address

Stanko’s Known Brain Damage or Show He Was Properly Advised.

Assuming the actual self-interest conflict was waivable—contrary to the

State’s position pre-trial, an emphatic view that the Fourth Circuit neglected to

acknowledge—Respondents chiefly rely on the hearings in the trial court discussing

the undisputed conflict of interest and conclude that Stanko’s assertions that he

wanted to keep Diggs on was a knowing, intelligent, and voluntary waiver of the

conflict. Opp. at 19–20.

These proceedings fail to acknowledge at all that Stanko was by then known

to have a highly anomalous brain which may have impaired his ability to waive the

conflict. The proceedings Respondents rely on should have raised red flags on this

point. Stanko said, for example, that he was satisfied with Diggs’s representation in

the Georgetown County case (Opp. at 19),6 but he also raised ineffective assistance of

counsel claims related to it and later vacillated on persisting with such claims. He

6 The District Court found it significant that at this hearing, Diggs was not in the courtroom, as if a

defendant’s right to the effective assistance of counsel can be healed by treating the defendant as pro

se by carrying on critical proceedings without the assistance of counsel at all.

10

also told the Horry County court he expected Diggs would learn from his mistakes

and substantively change the representation (App.125), but Diggs assured the court

he would not, informing them that he intended to rely on the same specialists and

would not seek funds to conduct mitigation investigation in this case (App.113–114).7

Neither Diggs nor the court nor any conflict-free counsel advised Stanko as to

the consequences of waiver: explaining Diggs’s personal reputational interest in

doubling down on his untenable NGRI defense which entailed presenting Stanko to

the jury as a psychopathic monster, that such an approach depended on Diggs’s

overruled motions challenging the constitutionality of the statute prohibiting this

type of defense, or that this defense was far outside the professional norms of capital

defense representation. At bottom, the hearings, discussed in greater detail in the

Petition (at 16–20), merely elicited that Stanko liked Diggs.

Respondents’ recitation of discussions of the conflict by different judges fails to

show how waiver of an actual conflict of interest based on the attorney’s own selfinterest that adversely affected the representation was knowing, voluntary, and

intelligent.

III.

CONCLUSION

For the foregoing reasons, Applicant/Petitioner Mr. Stanko, through

undersigned counsel, respectfully requests that this Court grant the petition for writ

7 The State also noted that Diggs “intends to offer a similar defense and similar mitigation utilizing

the same experts from the companion case” in its motion challenging the “non-waivable conflict.”

App.172–173.

11

of certiorari and either call for briefing and oral argument or summarily reverse the

opinion and remand for further proceedings.

Respectfully submitted,

/s/ E. Charles Grose, Jr.

E. CHARLES GROSE, JR. (Fed ID 6072)

The Grose Law Firm, LLC

305 Main Street

Greenwood, SC 29646

(864) 538-4466 (tel)

/s/ Joseph J. Perkovich

JOSEPH J. PERKOVICH

Counsel of Record

Phillips Black, Inc.

PO Box 3547

New York, NY 10008

212.400.1660 (tel)

888.543.4964 (fax)

j.perkovich@phillipsblack.org

/s Joseph C. Welling

JOSEPH C. WELLING

Phillips Black, Inc.

100 N. Tucker Blvd., Ste. 750

St. Louis, MO 63101

314.629.2492 (tel)

888.543.4964 (fax)

Counsel for Applicant/Petitioner

April 14, 2025

12