Petition for Writ of Certiorari — Christopher Veto, Petitioner v. The Boeing Company

Supreme Court briefMay 5, 2026

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No. 25- 1^10

In the

Supreme (Court of the llintcii States

VETO,

Petitioner,

v.

THE BOEING CO,

Respondent.

On Petition for a Writ of Certiorari to the

United States Court of Appeals for the Ninth Circuit

PETITION FOR A WRIT OF CERTIORARI

Christopher C. Veto, Pro Se

5345 Falls Way, Apartment G

Buena Park, CA 90621

(657) 252-7189

christophercveto@gmail.com

121056

$

COUNSEL PRESS

(800) 274-3321 • (800) 359-6859

i

QUESTION(S) PRESENTED

The following are questions that we provide for the

Supreme Court of the United States which we hold in

great regard:

(1) Despite Muscarello (1998) and Kyllo (2001), there

was illicit Narcotics use at the Boeing Long Beach facility

Building 800 by Nergal Daniel and others, aided and

abetted by Ryan H. Gardner (then manager) in 2023 who

wrongly said, “Marijuana is legal in California.” Does the

United States Constitution, an original document of fixed

historical meaning, including The Interstate Commerce

Clause Art. 1 Sec. 8, The Ex Post Facto Clause Art. 1 Sec.

9, and The Supremacy Clause Art 6 Sec. 2, invoking 21

USC 802, apply to the state of California and to Boeing

which operates in California?

(2) What is the penalty to Boeing for violating their

obligation to disclose reports of Narcotics at the Boeing

Long Beach facility in 2023 to the US Department of

Justice?

(3) What is the penalty to Boeing for then Boeing

Director Sean Woodward threatening me, a whistleblower,

with Violence?

(4) What is the penalty to Boeing for continuing to place

commercial aviation customers on contract after being

notified of the presence of illegal drugs at the Boeing Long

Beach facility in 2023?

(5) What right does Boeing have to allow managers to

pressure the Other Designation Authorization (ODA), a

ii

stand-in for the Federal Aviation Administration years

after the 737 MAX incidents of 2018 and 2019, wherein

neither the Other Designation Authorization (ODA) nor

the Work-In-Progress boards were intended to be used in

the way that profits are placed in competition with safety

where profits are emphasized and safety is subverted?

(6) Our Article I Section 8 patent system grants a

limited-time monopoly in order to promote the progress

of science and useful arts. Does Boeing operate as a

Monopoly in the commercial aviation industry, thereby

eliminating the concept of excellence through competition,

wherein the remedy is a divestiture? How many patents

can a company hold until it has created a Monopoly in its

industry? How can a company prioritize safety, when their

Intellectual Patent Valuation Tool provides weighting

for inventions that add luster and prestige to the Boeing

brand?

(7) Does the Export-Import Bank provide unfair

marketplace advantage to Boeing over other US-based

Defense companies when it grants $811 Million to

Boeing in loan guarantees for US aviation exports, as it

did in 2022, wherein the unfair marketplace advantage

eliminates the concept of excellence through competition?

Does unfair marketplace advantage between US-based

Defense companies, where one US-based company is

favored over other US-based companies, comprise their

ability to best provide safety against foreign danger?

(8) What right does the US 9th Circuit Court of Appeals,

a Court which derives its authority from the Supreme

Court of the United States under Article III of the United

States Constitution, have to redefine the judicial backstop

Hi

by grafitti-ing our case as a “diversity” termination,

despite the fact that “diversity” is nowhere mentioned in

any of briefs?

(9) Suppose the US 9th Circuit Court of Appeals ruled

in our favor, rather than for the Defendant Boeing whose

employees at the Boeing Long Beach facility are engaging

in the use of Illegal Drugs, does a Federal Court of

Appeals have the ability to create a nation-wide injunction

on illegal activity and companies which promote illegal

activity?

iv

LIST OF PARTIES

Christopher C. Veto (Plaintiff)

The Boeing Co. (Defendant). Stock Ticker Symbol: BA

Any expansion to the list of parties, as indicated in

suggested remedies, would fall under the purview of the

Supreme Court.

V

RELATED CASES

Veto v. The Boeing Co., No. 8:24-cv-00509-DOC-KESx,

U.S. District Court Central District of California Southern

Division. Judgment entered Oct. 23, 2024.

Veto v. The Boeing Co., No. 24-7060, U.S. Court of Appeals

for the Ninth Circuit. Judgment entered Feb. 6, 2026.

TABLE OF CONTENTS

Page

i

QUESTION(S) PRESENTED ......................

LIST OF PARTIES

iv

RELATED CASES........................................

v

TABLE OF CONTENTS

vi

TABLE OF APPENDICES

vii

TABLE OF CITED AUTHORITIES

......... viii

OPINIONS BELOW

JURISDICTION

1

............. 1

CONSTITUTIONAL, STATUTORY PROVISIONS,

AND ORDERS INVOLVED

1

STATEMENT OF THE CASE

2

REASONS FOR GRANTING THE PETITION

37

CONCLUSION

44

vii

TABLE OF APPENDICES

Page

APPENDIX A — MEMORANDUM OF

THE UNITED STATES COURT OF

APPEALS FOR THE NINTH CIRCUIT,

SUBMITTED FEBRUARY 6,2026 ................ la

APPENDIX B — ORDER OF THE

UNITED STATES DISTRICT COURT,

CENTRAL DISTRICT OF CALIFORNIA,

SOUTHERN DIVISION, DATED

OCTOBER 23, 2024 ........................................ 6a

viii

TABLE OF CITED AUTHORITIES

Page

CASES:

Chevron Corp v. Pennzoil Co.,

974 F.2d 1156 (1992)

39

District of Columbia v. Heller,

554 U.S. 570 (2008)

12

Dobbs v. Jackson Women’s Health Organization,

597 U.S. 215 (2022)

8,39

Gibbons v. Ogden,

22 U.S. 1(1824)

Kyllov. United States,

533 U.S. 27 (2001)

Loder v. City of Glendale,

14 Cal. 4 th 846(1997)

20

4,11,12,38,42

6,42

Loper Bright Enterprises v. Raimondo,

603 U.S. 369 (2024)

11

Lujan v. Defenders of Wildlife,

504 U.S. 555 (1992).......................................... .39

Marbury v. Madison,

5 U.S. 137 (1803)

11

McCulloch v. Maryland,

17 U.S. 316 (1819)

20

McDonald v. City of Chicago,

561 U.S. 742 (2010)

12

IX

Cited Authorities

Page

McDonnell Douglas Corp. v. Green,

411 U.S. 792 (1971)..................................................38

Muscarello v. United States

524 U.S. 125(1998)...................................... 4,38,42

New York State Rifle & Pistol Association, Inc.

v. Bruen,

597 U.S. 1 (2022)

........................................ 12

Payne v. Tennessee,

501 U.S. 808 (1991)...............................

42

Planned Parenthood of Greater Washington and

North Idaho v. US Department of Health and

Human Services,

946 F.3d 1100 (2020)........................................... 38-39

Planned Parenthood of Southeastern

Pennsylvania v. Casey,

505 U.S. 833 (1992).......................

39

Talbot v. Jansen,

3 U. S. 133 (1795)................................................... 20

United States v. Peters,

9 U.S. 115 (1809).................................................... 20

Ware v. Hylton,

3 U.S. 199 (1796).................................................... 20

West Virginia v. EPA,

597 U.S. 697 (2022)................................................. 39

X

Cited Authorities

Page

STATUTES AND CONSTITUTIONAL PROVISIONS:

Colorado

Amendment 20 (2000)............................................ 40

Amendment 64 (2012)............................................ 40

Connecticut

Senate Bill 1201 (2022) ...............................

40

Public Act 21-1(2021)...........................................40

Delaware

HB 1(2023)................................

40

HB 2 (2023) ....................................................... 40

Guam

Public Act 101-0027 (2020)..................................... 40

Illinois

Public Act 101-0027 (2020)....................................40

Maine

Maine Medical Marijuana Act (1999)................... 40

Maine Medical Use of Cannabis Act (1999)........... 40

Cited Authorities

Page

Maryland

House Bill 556(2023)............................................. 40

Senate Bill 516 (2023)........................................... 40

Massachusetts

Act to Ensure Safe Access to Marijuana (2017)... .40

Adult-Use Marijuana Regulation Law (2016)........ 40

Michigan

Michigan Regulation and Taxation of Marihuana

Act (2018)................................................................ 41

Michigan Medical Marihuana Act (2008),............. 41

Minnesota

Minnesota Cannabis Act (2023)...................

41

Missouri

Amendment 3 (2022)

.................................. 41

Montana

Initiative 190 (2020).............................................. 41

Nevada

Initiative to Regulate and Tax Marijuana (2016).. .41

xii

Cited Authorities

Page

New Jersey

Cannabis Regulatory, Enforcement Assistance,

and Marketplace Modernization Act (2021).......... 41

New Mexico

Cannabis Regulation Act (2021)............................ 41

New York

Marihuana Regulation and Taxation Act (2021) .. .41

Northern Mariana Islands (CNMI)

Taulamwaar Sensible CNMI Cannabis Act of 2018

(2018).................................................................... 41

Ohio

Senate Bill 56 (2025).............................................41

Oregon

Control, Regulation, and Taxation of Marijuana

and Industrial Hemp Act (2014)..............................41

Oregon Medical Marijuana Act (1998)................... 41

xiii

Cited Authorities

Page

Rhode Island

Rhode Island Cannabis Act (2022).......................... 41

U.S. Virgin Islands

2023 Virgin Islands Cannabis Use Act (2023)........ 41

Vermont

Act 86 (2018)..........................................

42

Act 164 (2020)......................................................... 42

Ex Post Facto Clause Art. 1 Sec. 9............................... 3

Interstate Commerce Clause Art. 1 Sec. 8................... i

Supremacy Clause Art. 6 Sec. 2................................... 3

U.S. Const, amend. 2.................................................... 12

U.S. Const. Art. VI...................................................... 10

U.S. Const. Art. 1 Sec. 8................................................ 3

U.S. Const. Art. 1 Sec. 9..................

3

U.S. Const. Art. 6 Sec. 2................................................ 3

XIV

TABLE OF CITED AUTHORITIES

Page

STATUTES

20 USC 232.5.......................................................... 4,42

20 USC 660.................................................................... 4

21 USC 802............................................ 3,38,39,42,43

39 CFR 233.8................................................................4

49 CFR Part 40............................................................. 4

Aircraft Certification Safety and Accountability

Act of 2020

Sections

102................................................................. ....6

105........................................................................ 6

114........................................................................ 6

118........................................................................ 6

125........................................................................ 6

133........................................................................ 6

California Adult Use of Marijuana Act (2016)

AB 1646 (2022)..................

40

AB 1706 (2022)....................................................... 40

AB 1885 (2022).................................................... ..40

AB 1894 (2022)....................................................... 40

AB 2188 (2024)....................................................... 40

AB 2210 (2024)....................................................... 40

TABLE OF CITED AUTHORITIES

Page

AB 2568 (2022)...................................................... .40

AB 2925 (2022)....................................................... 40

SB 1186 (2022)

.................................... 40

SB 1326 (2022) ........................................................40

OTHER AUTHORITIES

Amy Coney Barrett’s, Listening to the Law.............. 11

Puerto Rico

42-2017 (2017)........................................................ 42

Sewell et al. The Effect of Cannabis Compared

with Alcohol On Driving (2009) National Institute

of Health............................................................. 3

US DOT Section 5-5................................................ 3,39

US DOT Section 8110.48.......................................... 3,39

Washington

Initiative 502 (2012)...............................

42

Washington, DC

Legalization of Possession of Minimal Amounts of

Marijuana for Personal Use Initiative of2014 (2014).. .42

Petitioner respectfully prays that a writ of certiorari

issue to review the judgment below.

OPINIONS BELOW

The opinion of the United States court of appeals

appears at Appendix A to the petition and is unpublished.

The opinion of the United States district court appears

at Appendix B to the petition and is unpublished.

JURISDICTION

The date on which the United States Court of Appeals

decided my case was February 6th, 2026.

The jurisdiction of this Court is invoked under 28

U. S. C. §1254(1).

CONSTITUTIONAL, STATUTORY

PROVISIONS, AND ORDERS INVOLVED

Art. 1 Sec. 8

Art. 1 Sec. 9

Art. 6 Sec. 2

20 USC 660

21 USC 802

28 USC 1254(1)

39 CFR 233.8

49 CFR Part 40

8110.48 Section 5-5

CACI4603/4605

Cal. Lab. Code § 232.5

Cal. Lab. Code § 1102.5

Cal. Lab. Code § 6310

Cases, Statues, and Propositions to be overturned are

noted in Section 10 Suggested Remedies.

STATEMENT OF THE CASE

Mr. Veto’s case was most recently on appeal to the US

9th Circuit Court of Appeals regarding the wrongful use

of illicit Narcotics (i.e. illegal drugs) by Nergal Daniel and

others at the Boeing Long Beach Building 800 at 4060

N. Lakewood Boulevard, aided and abetted by Ryan H.

Gardner (then manager) in 2023. This case includes Mr.

Veto’s wrongful separation for raising this issue, resulting

in the US Equal Employment Opportunity Commission

(EEOC) acknowledging Boeing’s retaliation against Mr.

Veto by the EEOC issuing a Charge of Discrimination at

both federal at state levels as well as providing Mr. Veto

with a letter indicating my Right to Sue. This is the case

where Sean Woodward maliciously threatened Mr. Veto

with violence for raising this issue, the case where Nergal

Daniel nefariously blew illicit Narcotics in Mr. Veto’s face

on the walk to Panini Kabob grill on 12/14/2022 for the

end-of-the-year luncheon, the case where Vinh Nguyen

3

and Mr. Veto concurrently observed illicit Narcotics on

Boeing property on 3/27/2023, the case where Boeing took

down their knowledge base article KB0010916 (Drug-free

Workplace) which provides the phone number for the

drug reporting hotline, interfering with the ability of any

employee to report illicit Narcotics at Boeing. As seen in

the recent trip to Davos, Switzerland, Boeing’s disregard

for safety, rather than a commitment to safety as part of

the 737 MAX return-to-service campaign, is now affecting.

Air Force One, and hundreds of passengers have lost their

lives due to tragedies like Jeju Air (Flight 2216), Air India

(Flight 171), and UPS (Flight 2976). More broadly across

the transportation industry, ten people are dying every

day due to Marijuana-related car accidents.1 This is the

case where Mr. Veto’s observation of illicit Narcotics was

corroborated by Mr. Nick Mata, an armed security guard

stationed within Building 800. The issues in the case

include (1) Illegal Drugs by Nergal Daniel and others; (2)

Pressuring of the Other Designation Authorization (ODA),

a stand-in for the FAA; (3) Threats of Violence by then

director Sean Woodward; (4) Retaliatory Actual Malice by

Ryan H. Gardner as well as Nergal Daniel; (5) Obstruction

by Linda Lam as well as the Drug reporting Knowledge

Base hotline; (6) Hundreds of Deaths; (7) Subversion of

safety including US DOT Provision 8110.48 Section 5-5

as well as Go4Zero (Boeing’s flagship safety campaign);

(8) Subversion of the US Constitution, including Art 1.

Sec 8, Art. 1 Sec. 9, and Art. 6 Sec. 2 thereby invoking 21

USC 802; and (9) Graffiti of our case by someone in the

1. “motor vehicle accidents...killed 38,588 people in 2006...

the percentage of road traffic accidents in which one driver tested

positive for marijuana ranges from 6% to 32%” Sewell et al. The

Effect of Cannabis Compared with Alcohol On Driving (2009)

National Institute of Health.

4

courthouse at the 9th Circuit attempting to re-define the

judicial backstop. Mr. Veto also qualifies under Labor

Code 6310 and 1102.5; furthermore, the case has also

discussed 49 CFR Part 40, 20 USC 660, 232.5, and 39

CFR 233.8. Despite Muscarello (1998) and Kyllo (2001),

there was illicit Narcotics use at the Boeing Long Beach

facility Building 800 by Nergal Daniel and others, aided

and abetted by Ryan H. Gardner (then manager) in 2023

who wrongly said, “Marijuana is legal in California.”

As follows are the criteria of which Ryan H. Gardner

sought to evaluate the performance of Boeing Program

Management Engineers for the 2023 year, announced on

3/21/2023:

1. “Working Together Principles

2. Communication

3. LEAN Principles Embodiment

4. Project Management

5. Competitiveness

6. Proposal Feedback Loop

7. Skyline Capacity Management

8. Internal Deliverable OTD

9. External Deliverable OTD

10. ECM OTD”

OTD, used here three times, stands for “On Time

Delivery.” ECM stands for “Engineering Change Memo.”

These criteria are yet another example of the egregiously

poor judgment of Ryan H. Gardner, placing profits in

competition with safety where profits are emphasized and

safety is subverted. Furthermore, Mr. Veto had notified

Ryan H. Gardner of the presence of ILLEGAL DRUGS at

the Boeing Long Beach facility prior to Ryan H. Gardner

5

providing these instructions to the Program Management

Engineers.

In regards to the wrongful pressuring of the Other

Designation Authorization (ODA) in 2023, a stand-in for

the Federal Aviation Administration (FAA) years after

the horrific 737 MAX tragedies of 2018 and 2019, Mr. Veto

was suspended from working at Boeing Long Beach by

Ryan H. Gardner within ten days of Mr. Veto learning

from his colleague, Mr. Von Zabern, that Alex Malley,

who was invited to the daily 9AM status standup meetings

hosted by Ryan H. Gardner, was a member of the ODA.

The communication of this detail to Mr. Veto transpired

within earshot of Ryan H. Gardner’s cubicle.

In addition to the sworn affidavit by Mr. Nick Mata,

Mr. Veto’s co-worker Vinh Nguyen was directly asked

about Vinh Nguyen and Mr. Veto’s co-observation, during

walking, of illegal drugs at Boeing Long Beach. As follows

is an excerpt from the Deposition of Vinh Nguyen:

...MR. KEEGAN:

Okay.

(Pause in the proceedings.)

MR. DAVIS:

Back on record.

BY MR. DAVIS:

Q So, Mr. Nguyen, just to clarify the record, when

you walked over to the Kroft with Mr. Veto sometime in

March of 2023, it’s your understanding you don’t recall

having a conversation about the smell of marijuana;

is that correct?

6

A Correct. I don’t’ remember - I don’t remember

the conversation we had.

Q So it’s possible that conversation took place. What

you’re saying is I just don’t recall it; right?

A Yes.

MR. DAVIS:

this time.

Okay. I have no further questions at

MR. KEEGAN:

No questions for the witness.

(The deposition concluded at 1:29 P.M.)

Boeing violated the Aircraft Certification Safety and

Accountability Act of 2020: Sections 102, 105, 114, 118,

125, and 133.

Notes from Boeing’s Corporate Investigator confirm

Boeing’s obstruction:

“...Veto evaded questions, and over elaborated on

non-relevant items. Veto’s answers were not succinct.

Veto was speaking in a emphatic tone, and at times

spoke erratically. CI had to stop the interview multiple

times to engage Veto and refocus.”

As was presented to the Ninth Circuit Court of

Appeals, “Marijuana remains illegal under federal law”

(Loder v. City of Glendale (1997)), and federal law applies

to every state.

During the proceedings of lower-level courts, The

Boeing Co. failed to answer basic questions, failed to

7

produce easily obtainable documents, failed to meet courtissued due dates, and was less than honest with the Court.

Review of Memorandum Issued by

9th Circuit Court of Appeals (Appendix A)

Upon review of the Memorandum issued by 9th

Circuit Court of Appeals, Mr. Veto provided the following

analysis:

Upon review of the (Not For Publication) Memorandum

from the United States Court of Appeals For The Ninth

Circuit dated 2/6/2026, I can provide the following

statement:

I say the following with great reverence for the

Court...

As noted in my e-mail on 2/5/2026, our case was

grafitti’d with the statement, “Appeal of a summary

judgment in favor of The Boeing Company in a diversity

wrongful termination action” before the case was reviewed

by the US 9th Circuit Court of Appeals on 2/3/2026.

On page 4, the Memorandum of 2/6/2026 implies that

I do not have good faith, and the authors are wrong.

On page 3, the Memorandum states that I, “...lacked

an objectively reasonable belief that my complaints of

smelling marijuana at the workplace disclosed a violation

of state or federal law.”

However, I specifically mentioned the Interstate

State Commerce Clause to three people from Boeing

8

security who asked to speak with me in a conference

room after relocating to a new desk on 4/4/2023. I also

mentioned Article VI (the Supremacy Clause of the US

Constitution) on the phone call with the Boeing Corporate

Investigator named Linda Lam on 5/5/2023. Even when

then manager Ryan H. Gardner stated, “Marijuana is

legal in California,” I clearly replied to him that it was not.

On page 3, the Memorandum states that “Veto also

confirmed that fourteen employees who worked in the

immediate vicinity of that coworker did not indicate that

they suspected any marijuana use.”

However, we received the Deposition of Vinh Nguyen

who also observed the occurrence of Narcotics at the

Boeing Long Beach facility on 3/27/2023. Specific to

Nergal Daniel, Nergal mentioned in his Deposition that

he has used drugs in the past. The Memorandum also

does not mention the Event Witness Matrix (EWM) which

accounts for each event to which witnesses could attest.

On page 5, the Memorandum oddly cites a 2020 Planned

Parenthood case in the footnote despite the fact that the

US Supreme Court heroically ruled quite differently on

inhumane practices performed by organizations such as

Planned Parenthood in Dobbs (2022).

Furthermore, on page 2, the Memorandum seeks to

rely upon “the ‘reasonable cause’ standard;” however,

neither a standard, nor a stare-decisis based test, nor the

Retaliatory Actual Malice of Ryan H. Gardner prevents

us from looking at the US Constitution.

On page 3, the Memorandum states that there was “no

evidence corroborating any of Veto’s complaints;” however

9

illicit Narcotics were corroborated by Mr. Nick Mata - an

armed security guard - as well as by Vinh Nguyen - a

co-worker in Building 800 - in his Deposition.

On page 4, the Memorandum states that Mr. Nick

Mata’s declaration is “not specific enough;” however this

suggestion is insincere. Mr. Mata was an armed security

guard for the Boeing Long Beach facility Building 800

located at 4060 N. Lakewood Boulevard from 2022-2023.

On page 5, the Memorandum states the “Veto’s

complaints to his supervisor and security personnel were

primarily concerned with allowing him to move his desk

or work remotely and demonstrated no express concerns

about workplace safety.”

However, moving to a new desk was initially suggested

by then manager Ryan H. Gardner who then later took back

the offer for me to move away from Nergal Daniel despite

the fact that I observed numerous instances of others

moving desks. You can see in the document submitted to

Ryan H. Gardner and Sean Woodward on 3/22/2023, that

I specifically state, “I have never used a drug in my life;

I am not intending offense in this request; I believe that

this request is best for me and best for Boeing.” It is worth

noting that in the interim between moving to a new desk

on 4/4/2023 and being placed on suspension on 4/12/2023,

I learned that Boeing was wrongfully pressuring the ODA

(Other Designation Authorization, a stand-in for the FAA

following the 737 MAX incidents of 2018 and 2019 which

occurred prior to me joining the Avionics group in Boeing

Long Beach) since Alex Malley was routinely invited

by Ryan H. Gardner to the 9AM Daily Status Standup

Meetings and that Alex Malley was an Engineering Unit-

10

Manager wherein Engineering Unit-Managers were part

of the ODA. In fact, a news article from USA Today on

9/12/2025 titled “FAA says Boeing should pay $3.IM in

fines over door failure and other safety lapses” provides

corroborating evidence of Boeing pressuring the ODA, and

we know that the ODA is not supposed to be pressured in

anyway per guidance from the Executive Council. In fact,

in one meeting, Mr. Alex Malley announced that he was

stepping down from being a manager; however, stepping

down from being a manager is not the same as stepping

down from being an Engineering Unit-Manager (E-UM).

Oddly, when Mr. Malley made this announcement, he

stated that it would be “best for him and best for Boeing”

which is same language that I had previously used in

my written statement to Ryan H. Gardner and Sean

Woodward on 3/22/2023. In addition, during my phone

call with Linda Lam on 5/5/2023, I stated that Boeing

should be a drug-free workplace due to (i) the Interstate

Commerce Clause, (ii) Article VI (the Supremacy Clause),

(iii) Go4Zero (the name of Boeing’s safety initiative), (iv)

Boeing Job Descriptions, and (v) Boeing E-mail (wherein

Boeing e-mail addresses include “[US]” for US Citizens,

again invoking the relevance of US Federal Law).

The Memorandum ignores the bad faith of Boeing

in that Boeing was fined for stealing technology from

electrical startup Zunum (24-5212, 24-5751) as reported

in the Seattle Times on 6/7/2024.

The Memorandum ignores that both the US Equal

Employment Opportunity Commission (EEOC) as well

as the Occupational Health and Safety Administration

(OSHA) independently confirmed that Boeing retaliated

against me. I was referred to the US Department of Labor,

11

the EEOC, and OSHA, after connecting with the office

of the Honorable Senator Mike Lee of Utah, and Utah is

a member of the 9th Circuit as well as the United States.

The US Supreme Court recently overturned Chevron

in the Landmark case of Loper Bright Enterprises v.

Raimondo (2024) since Executive Branch agencies were

effectively creating new regulations without the input of

Congress. ... Separation of Powers does not mean that

each of the three branches acts as its own government

such that the judiciary can ignore the executive branch,

meaning the findings of retaliation from the EEOC and

OSHA. Separation of Powers does mean...a law passed

by Congress being reviewed under the supremacy of the

US Constitution via the practice of judicial review (see

Marbury v. Madison (1803)).

The Memorandum ignores that I stated multiple

times to the Court that “Marijuana remains illegal under

Federal Law” and that “Marijuana is illegal for a reason.”

From the amazingly brilliant Justice Amy Coney

Barrett’s book Listening to the Law, we see that the Court

has indeed upheld the illegality of Marijuana in Kyllo v.

United States (2001).

We believe that this case is worthy of the writ of

certiorari. To graffiti our case, as mentioned on 2/5/2026,

imperils our likelihood of bringing this case to the United

States Supreme Court.

Safety, the tragic loss of life which we seek to prevent,

and the US Constitution which we seek to uphold, all

support the writ of certiorari.

12

Consider an example from the Landmark decisions

pertaining to the 2nd Amendment. In this regard,

the US Supreme Court upheld the 2nd Amendment in

Heller (2008), McDonald (2010), andBruen (2022). Some

Constitutional scholars may in good faith believe that

these three cases provided different protections for the

2nd Amendment: that Heller (2008), as an example, applied

toWashington, DC; whereas that McDonald (2010) applied

to all of the United States. Some Constitutional scholars

may instead in good faith believe that these three cases

reaffirmed the 2nd Amendment for all of the United States

(including Washington, DC) on three occasions.

Despite Kyllo (2001) there was illicit Narcotics use at

the Boeing Long Beach facility Building 800 by Nergal

Daniel and others, aided and abetted by Ryan H. Gardner

(then manager), in 2023.

Review of Motion for Summary Judgment

(Appendix B)

Mr. Veto provided the following analysis:

Errors in the Motion For Summary Judgment from

the United States District Court Central District of

California Southern Division (Case No. 8:24-cv-00509DOC-KESx, Filed 10/23/24) are as follows:

1. The author says, “Starting December 2022” and then

cites Id.#10-ll (p.,1 Line 9). [Appendix B, p. 7a]

However, there are no documents to substantiate this

date. The first report was made in 2023. If you look at the

13

e-mail sent on 8/23/2024,1 say, “Obviously some members

of the security guard have lied.” Our testimony from Nick

Mata indicates security received other reports in the

past, but the other security guards claimed ignorance.

Furthermore, the document referenced in that e-mail (p.

85) provides Williams’ statement that reports were made

in “Dec 2022” which is false. The Defendant is incapable

of substantiating this fact because no report was made

at that time.

2.

The author says, “Mr. Gardner immediately spoke to

the janitor but observed no signs of marijuana odor

or impairment. Id #19” (p. 1, Lines 21-22). [Appendix

B, p. 8a]

However, I have highlighted the logical fallacy in my

e-mail sent on 10/1/2024: “How is it possible that Sean

Woodward at once found the janitor in question - among

the numerous janitors on the roster - and that she did not

exhibit signs of Narcotics use?”

3.

The author says, “Plaintiff then asked Mr. Gardner to

move his desk location away from Mr. Daniel because

of the alleged marijuana smell. Mr. Gardner initially

denied but eventually accommodated this request. Id.

#22, 25” (p. 2, Lines 1-3). [Appendix B, p. 8a]

However, I have rebuked this assertion in my e-mail

on 9/14/2024: “Ryan H. Gardner first suggested over the

phone and while he was on paternity leave that I could

move desks. Then when Ryan H. Gardner returned from

paternity leave and there was an opportunity to actuate

this suggestion, Ryan H. Gardner instead said he [was]

only joking. In context, I had observed 16 other employees

14

move desks, and some were working at other sites.” This

is yet another example of retaliatory actual malice.

4.

The author says, “...in a college dorm in 2009” (p. 3,

Line 8). [Appendix B, p. 8a]

However, this should say 2008.

5.

The author says, “Plaintiff submitted handwritten

notes to the building’s security guards about the

perceived smell of marijuana in and around the office

building. Id. #27.”

However, this is misleading. These forms were

provided to me from security. Furthermore, as mentioned

in my e-mail on 9/5/2024, “I should point out an observation

made during the deposition that it was interesting that

the security guards had to retrieve additional statement

forms, noted on my second hand-written statement on

4/7/2024, implying that perhaps additional statement

forms were being submitted to them beyond those that I

was submitting.”

6.

The author says, “Senior Corporate Investigator,

Linda Lam” (p. 3 Lines 17-18) and later uses the word

“investigated” (p. 8, Line 12). [Appendix B, p. 9a, 16a]

However, as stated in my e-mail on 8/5/2024, “I

prefer not to promulgate Boeing’s narrative in the form

of the report written by the Corporate Investigator who

obstructed my reporting and wrote her report in bad faith

as evidenced by, and in subversion of the best interests

of the general public, her omission of my reporting the

technical safety issue of the 115 Volt Sheddable Bus: an

15

issue initially raised to me by a member of the Boeing

Technical Fellowship. As mentioned in my e-mail on

6/1/2024, and stated at that time in the context of Ryan

H. Gardner perjuring himself before the Court, though

also applicable here, “It is wrong to approve of flawed

documents.”

7.

The author says, “Plaintiff subsequently filed a

complaint with Occupational Safety and Health

Administration (“OSHA”), which informed him that

his complaints did not constitute a protected activity

under Section 11(c) of the Occupational Safety and

Health Act of 1970. Id. #46.” (pp. 3-4, Lines 26-26,

1-2). [Appendix B, p. 10a]

However, as mentioned in my correspondence with

The Honorable Congresswoman Michelle Steel (Tab 16),

“Unfortunately, Mr. Rodriguez categorized the complaint

as an 11c which I believe is the category for Retaliation.

Even though individuals at The Boeing Company did

retaliate against me for reporting Narcotics use by Boeing

employees at the Boeing Long Beach Building 800 facility

in 2023,1 am concerned that triaging this complaint as an

11c - instead of other categories - prevented OSHA from

investigating this issue.”

8.

The author says, “Plaintiff’s complaints were not

objectively reasonable when he made them because

Plaintiff admits he never saw any drug use at work,

never saw smoke, and never saw any drugs or drug

paraphernalia at work.” (p. 6, Lines 20-22). [Appendix

B, p. 13a]

However, safety observations are not limited to sight.

As an example, nationwide an additive called “mercaptan”

16

is added to natural gas - which is otherwise odorless - to

alert citizens of a leak.

9.

The author says, “No other coworkers near Plaintiff

reported a marijuana smell, saw marijuana use, or

suspected marijuana use in the workplace.” [p. 6,

Lines 24-25]. [Appendix B, p. 14a]

However, there are several problems with this

statement. First, no other observations are required.

Second, when asked whether it was possible that Mr. Veto

asked Mr. Nguyen, “Did you smell that?” and Mr. Nguyen

said, “Weed” on the walk to the Kroft on 3/27/2023, Mr.

Nguyen emphatically said under oath, “Yes.” Third, Mr.

Mata has produced a signed affidavit acknowledging that

there were other reports in the past few years at the

Boeing Long Beach facility Bldg. 800 located at 4060 N.

Lakewood Blvd.

10. The author says, “Mr. Mata’s declaration, however,

does not support Plaintiff’s complaints as objectively

reasonable because it does not state when those

other complaints were made and does not state that

the complaints were about the smell of marijuana or

marijuana use. Plaintiff’s Compendium of Evidence

in Opposition to Motion for Summary Judgment at 14

(Dkt. 23). Mr. Mata’s declaration provides no detail at

all about the other complaints to show that they were

similar to Plaintiff’s complaints or that they were

ultimately substantiated. Id. Even if admissible, this

bare statement from Mr. Mata is not enough to make

Plaintiff’s complaints reasonable” (p. 7, Lines 3-10).

[Appendix B, p. 14a]

17

However, we should note that as Plaintiffs we adhered

in good faith to the requests of the Discovery process. In

contrast, the Defendants did not adhere in good faith to

the Discovery process. As noted in me e-mail on 9/7/2024,

“Also as noted in my e-mail on 8/30/2024, ‘My e-mail from

8/5/2024 shows how the opposing counsel has left our

Documents requests unfulfilled. The same e-mail also

conveys how Gardner is the one who has been slandering

and who has not been respecting privacy.’”

Further, as stated in my e-mail on 8/29/2024, “Please

note that although I do believe in complying with the rules

of discovery, I also hold true to the First Amendment issue

of compelled speech which I have previously expressed to

you through e-mail on 4/29/2024 which says the following:

‘Request for Document No. 17 [my resume] is completely

inappropriate and an example of the opposing counsel

- a hostile party - soliciting compelled speech which is

antithetical to the First Amendment of American Rule

of Law.’”

Further, as noted...on 10/11/2024, “Allied Objected

to everything as confidential.” Our subpoena to Allied

Universal was drafted in good faith in order to provide

helpful insights for the Court. The author claims Mr.

Mata’s testimony is a “bare statement” within the context

of allowing our subpoena to go ignored.

11.

The author provides a criteria for the Plaintiff to

show that “the retaliation was intentional” (p. 7, Line

26). [Appendix B, p. 15a]

However, as stated in my e-mail on 10/23/2024:

When looking at the document called “BOEING 000095BOEING_000386.pdf” the following observation is made:

18

Ryan H. Gardner implies prejudice with his use of

“person of color” on page 69. When you look at page

70, you can see that Ryan H. Gardner says, “Veto was

suspended without pay about 18 days ago,” which provides

an indication as to when this report was written.

When you look at my timeline, Timeline_V7.pdf, you

can see that I was placed on unpaid leave of absence on

4/12/2023, implying that Ryan H. Gardner wrote that

statement after 4/12/2023.

However, when you look at the document that I sent to

Ryan H. Gardner and Sean Woodward on 3/22/2023, found

in BOEING_000095-BOEING_000386.pdf (page 58), you

can see that I said, “These odors came to be before Karla,

Alexandra, and De’Andre moved to the area where I sit.”

Karla, Alexandra, and De’Andre - whom I defended - are

all of racial minority heritage, and Ryan H. Gardner knew

this. This context demonstrates the egregiously poor

judgment of Ryan H. Gardner: his willful Retaliatory

Actual Malice. In context, retaliation by Boeing against

me has also been independently stated by the Equal

Employment Opportunity Commission (EEOC) as well

as by the Occupational Safety and Health Administration

(OSHA).

Furthermore, the whole reason why the counsel of

Ogletree is involved in this case is because of the Charge

of Discrimination issued by the U S. Equal Employment

Opportunity Commission of Boeing’s wrongful retaliation

against me. Specifically, see Notice of Right to Sue (Tab

5, p. 2).

12. The author says, “Plaintiff’s reports do not constitute

a protected activity because they were not about

19

‘unsafe working conditions... in their employment or

place of employment.’ Cal. Lab. Code § 6310. None of

complaints of marijuana odor were about workplace

safety” (pp. 7-8, Lines 27-28,1-2). [Appendix B, p. 15a]

However, I explicitly denoted the hazards to OSHA

(Tab 18).

Furthermore, the author neglects the fact that I

explicitly cited Go4Zero in my interview in 2022 (interview

mentioned in my e-mail to you on 4/11/2024 which states,

Boeing needs “...more people (not less)”); whereas the

leadership of Boeing Long Beach kept the Go4Zero flag

in the basement of Building 800.

Furthermore, I explicitly cited the Go4Zero campaign

in my call with Linda Lam, who continuously obstructed

me, on 5/5/2023. As stated in my e-mail on 6/23/2024,

“Regarding Item AC in the Event Witness Matrix

(EWM): In the 292 page document sent to us by the opposing

counsel titled ‘BOEING_000095-BOEING_000386.pdf, ’

you can see from Linda Lam’s notes on pages 65-67 as

well as pages 245-246 that she did not record the technical

issue I conveyed to her of the 115 Volt Sheddable Bus.”

Moreover, the author omitted the following:

13. Breach of Agreement with the Department of Justice

which I have cited in my e-mail on 8/3/2024.

14. Violations of the American Bill of Rights (First,

Fourth, Fifth, and Sixth Amendments) as stated in

my e-mail on 4/29/2024.

20

15. Sean Woodward’s threat of violence: “You are heading

towards a cliff.”

16. The Supremacy Clause (US Constitution Art. VI)...

[and] Ryan H. Gardner wrongly said, “Marijuana is

legal in California.” ...

Review of Defense Boeing Submitted

to 9th Circuit Court of Appeals

Upon review of the Defense Boeing submitted to

the 9th Circuit Court of Appeals, Mr. Veto provided the

following analysis:

Boeing glosses over the fact that there have been

hundreds of fatalities and injuries involving Boeing

aircraft in the time since 3/22/2023 when I submitted

my concern to Ryan H. Gardner and Sean Woodward in

writing (see BoeingIncidentReport_V7.xlsx).

Boeing glosses over the fact that Federal Law is the

Supreme Law of the Land. ...Gibbons v. Ogden (1821^)

and McCulloch v. Maryland (1819) support this view.

Furthermore, the supremacy of federal law has been

championed since the beginning.

Chief Justice John Jay - Ruled in favor of the

supremacy clause by honoring the Treaty of Paris of 1783

[Ware v. Hylton (1796)]. This case was argued by John

Marshall.

Chief Justice John Rutledge - Honored the “general

law of nation [singular]” in Talbot v. Jansen (1795)

21

Chief Justice Oliver Ellsworth - Ruled in favor of

the supremacy clause in advisory opinion to Johnathan

Trumbull stating, “all

Treaties made under the

authority of the United States shall be supreme laws of

the land.”

Chief Justice John Marshall - Asserted Federal Law

over state law in United States v. Peters (1809).

To be clear, the Constitution says, “This Constitution

and the Laws of the United States which shall be made in

Pursuance thereof; and all Treaties made, or which shall

be made, under the Authority of the United States, shall

be the supreme Law of the Land.”

As stated in EEOC Explanation of the Facts_V7.pdf,

Ryan H. Gardner wrongly stated that “Marijuana is legal

in California” seeking to advance a position that violates

American Rule of Law. As follows is an excerpt from the

Deposition of Ryan H. Gardner:

...A. Back East

Q. Maryland?

Q. Between the fall of 2022 and spring of 2023, do

you know if there was a change in the security guard

roster for Building 800?

A.

I don’t know

Q. When Mr. Veto made a complaint to you about

drugs and the times he made an oral complaint, did you

ever say something to him, like, “You don’t want to be

the boy that cried wolf”?

22

A.

I don’t’ recall.

Q. So it’s possible you said it; you just don’t recall?

MR. KEEGAN:

The question is argumentative

THE WITNESS:

something I would say.

I don’t think that would be

BY MR. DAVIS:

Q. Okay. Did you ever tell Chris in front of Mr.

Von Zabern, “We’re really putting Chris through the

ringer”?

A.

I don’t recall saying that.

Q. Do you know who Diego Lupercio is?

A.

No.

Q. Did you ever tell Mr. Veto that when he was

talking to you about one of his complaints about

drug use you told him that Nergal Daniel smoked and

that cigarettes were legal in California? Did you say

something like that?

A. Yes. Something to that effect.

Q. Now, does Boeing have a zero tolerance policy

about tobacco use in the workplace at the Boeing Long

Beach facility?

23

A. If you smoke, you have to go out to public property.

Q. Do you have chew tobacco?

A.

No.

Q. Can you chew on premises, or do you have to

take that out too?

MR. KEEGAN:

I think it is if it’ tobacco.

BY MR. DAVIS:

Q. So that’s not even allowed?

A. Yeah.

Q. Does Nergal Daniel smoke?

MR. KEEGAN:

foundation.

Calls for speculation. Lacks

THE WITNESS: I’ve never seen him smoke a

cigarette. I believe he may have in the past. I think...

Boeing asserts that there is no malice, yet they

gloss over the following:

• Nergal Daniel nefariously blew Narcotics in my face

on the walk to Panini Kabob grill on 12/14/2022 for

the end-of-the-year luncheon.

• Ryan H. Gardner saying, “We are really putting Chris

through the wringer.”

24

• Ryan H. Gardner saying, “This is turning into the boy

who cried wolf.”

• Sean Woodward (then Ryan H. Gardner’s boss),

threatening me by saying, “You are heading towards

a cliff” despite Boeing training 82033 Threat

Management: How to Recognize and Report (82033)

and 82069 Threat Management to Advanced Threat

Awareness Training -101 Course

• Ryan H. Gardner implying prejudice towards

“people of color” in the document BGEING_000095BGEING_000386.pdf, despite the fact that I pointed

out how the odors occurred prior to Karla, Alexandra,

and De’Andre moving to the area where I sat. My

impression of the justice system is that it knows no

race, and that is represented in the blindfold worn

by Lady Justice as well as many other places (like E

Pluribus Unum).

• Ryan H. Gardner sticking out his tongue at the entire

group during a meeting and saying, “Because I’m a

manager.”

• Nergal Daniel attempting to impugn my character by

suggesting during his deposition that I was envious of

him.

• Even the latest document sent is mocking me by

stating “anti-drug” in quotation marks. The state

of California passed Prop 36 with bi-partisan vote

because law-abiding Citizens are fed up with the drug

cartels.

25

•

Ryan H. Gardner perjuring himself before the Court.

• Boeing blocking me from applying to a different

position.

• The US Equal Employment Opportunity Commission

indicating Boeing’s retaliation against me and

providing me with a Right to Sue at State and Federal

levels as well as a Charge of Discrimination by Boeing

against me.

Boeing asserts that I never made a bona fide safety

complaint, yet glosses over the following:

• The fact that I clearly championed the Go4Zero safety

campaign during my interview with Ryan H. Gardner

and a man named Andy whom Ryan stated he knew

from high school at the Boeing Long Beach facility in

2022.

• Boeing took down their knowledge base article

KB0010916 (Drug-free Workplace) which provides

the phone number for the drug reporting hotline,

interfering with the ability of any employee to report

Narcotics at Boeing.

•

Linda Lam obstructing my safety report.

• The fact that I informed a member of the law

department (see event AD from EventWitnessMatrix_

V7.pdf).

• The fact that the Boeing Long Beach facility stored

their Go4Zero safety flag in the basement which had

a closed cafeteria and low foot traffic.

26

• The wrongful pressuring of the ODA by the daily 9AM

standup meetings hosted by Ryan H. Gardner.

• Awarding me in the past for a safety initiative to add

speed bumps to the parking lot of the Huntington

Beach facility.

• The fact I was attempting to file a patent with Robert

“Eric” Gonzales called AirFax which would help to

improve the safety of the vehicle, and that on or around

April 2023, Mr. Darren Gold angrily shouted to Mr.

Veto, “Don’t tell me about the risks!”

• Boeing’s wrongful separation prevented me from

attending Seek, Speak, and Listen.

• That I cited the Supremacy Clause when conveying the

issue to Linda Lam as well as an additional safety issue

of the 115V sheddable bus whose report we found to

be flawed in that she failed to take note of the 115 volt

sheddable bus issue notwithstanding her continuing to

obstruct my reporting; and that I reported the issue

of Narcotics at the Boeing Long Beach facility to the

Federal Aviation Administration.

Boeing asserts a lack of evidence but glosses over

the following:

• Vinh Nguyen’s testimony under oath. When I asked

him, “Did you smell that?” Vinh Nguyen specifically

said, “weed” while he and I were still on Boeing

property and on the walk to lunch.

• Sworn affidavit by security guard Nick Mata indicated

drugs at Boeing Long Beach.

27

Boeing

Long Beach

Narcotics

witnessed

3/27'2023

Nergal Daniel

used Narcotics

12/14^022

M - 0 If

EK :| l|SI

wHSe.

Figure 1: Map showing location where

Veto and Vinh Nguyen concurrently

observed narcotics on Boeing property.

• A marijuana growth facility was found in Victorville

which is where Nikhil (whom recommended Nergal

Daniel to Boeing) took Boeing employees for a tour of

the Boeing facility in that area.

• https://www.vvng.com/marijuana-dispute-leads-tocartel-style-mass-shooting-in-adelanto-6-bodiesfound-5-men-arrested/

• Nergal Daniel stating in his deposition that he has

used drugs in the past.

• A lack of honesty by Ryan H. Gardner:

o Ryan H. Gardner said that I cornered someone in

a stairwell and demanded a promotion. Everything

28

about that is a lie, both the cornering part and the

demanding promotion part.

o Ryan H. Gardner said that he knew me from

REACH, but that is not true. When I was a summer

intern in El Segundo, REACH was led by Ms.

Kelsey Sargent out of Huntington Beach. It wasn’t

until after 2015 when I took on a leadership role in

REACH but not in a capacity that connected me to

Ryan H. Gardner.

o As you can see from the...USB [delivered]

on 12/28/2023. ...The flaw in the statement of

Sean Woodward when he and Ryan H. Gardner

unprofessionally met with me on 3/22/2023 in a

conference room within earshot of Nergal Daniel

is that Sean Woodward definitely found the janitor

in question (whom I have referenced in my written

statement of 3/22/2023). How is it possible that Sean

Woodward at once found the janitor in question among the numerous janitors on the roster - and

that she did not exhibit signs of Narcotics use?

Ryan H. Gardner is also at fault due to his wrongful

statement of false accusations.

o Another factual inaccuracy by Boeing is found on

page 62 of the document titled “BOEING_000001BGEING_000094.pdf” which says “3/14 - Ryan

receives text message from Chris. Elevator behind

Chris smells like Marijuana. Security noted it. 10

minutes later Ryan followed up in the elevator.

Smelled nothing.” However, there was no elevator

behind me. The elevators were centrally located in

Building 800, and the floor map would confirm this.

29

o Ryan H. Gardner’s wrongful actions further

prevented me from including Mr. Karthik Shankar.

Ryan H. Gardner initially said that I would be

working from home on 4/12/2024 and to grab

everything that I would need to work remotely. Once

I reached home, Ryan H. Gardner informed me that

I was being placed on Suspension. This was one of

Ryan H. Gardner’s many lies to the detriment of

me, of Boeing, and of the general public.

o A list of additional lies by Gardner is found in the

document titled Defendant Interrogatories and

Document Response_V3.xlsx, including item 1

where Gardner is maliciously smearing my name.

• A lack of honesty by Nergal Daniel:

o Mr. Nergal Daniel mentioned in deposition that

he was named a lead, but I am not sure to what

he was referring.

o If you look at the EEOC Explanation of the Facts,

you will see that an example of discrimination

is when Ryan H. Gardner exclusively selected

Nergal Daniel, Anthony Ho, himself, and Eric

Gonzales to approve of changes to the capacity

planner - leaving out others to easily do the same,

including Sr. Project Management Engineers

Mr. Mike Hargrave and Mr. Fred Von Zabern.

However, it is my firm belief that Ryan H. Gardner

assigned this schema after I raised the issue of

Nergal Daniel’s use of Narcotics.

o Perhaps instead Nergal Daniel was referring

to the 1 instance when he was asked to lead a

30

group meeting while Ryan H. Gardner was out

of office. However, this meeting also occurred

after raising the issue of Narcotics use by Nergal

Daniel to Ryan H. Gardner. In this meeting that

Nergal was asked to lead, Mr. John Getsy asked

Nergal a number of pointed questions. In context,

note that Mr. John Getsy was most always silent

during meetings. I remember thinking at that

time that perhaps Mr. John Getsy (who sat within

the vicinity of Nergal Daniel) was also unhappy

with Nergal Daniel’s actions.

Nergal Daniel’s deposition is full of lies, and this

highlighted line of questioning is one of the most glaringly

obvious examples.

[As follows is an excerpt from the Deposition of Nergal

Daniel]

...A. I’m trying to remember. Safety something. I

can’t remember the last Q. But that’s a portal -

A.

System. Yeah.

Q. on the computer?

MR. KEEGAN:

Let each other finish, you guys.

THE WITNESS:

It’s a website.

BY MR. DAVIS:

31

Q. You log into the website to make a complaint?

Is that what you do?

A.

I have never used it. I don’t know.

Q. But that’s what you were trained to do if you

needed to?

A.

I believe so, yes.

Q. Okay. Had anyone from - well, let me strike

that. Where you work at the Long Beach facility, you

work in the 800 building; is that correct?

A. I think that’s it, yes. I’m trying to remember.

Yes, it is.

Q. Okay. IS there a restaurant nearby that Boeing

facility called The Kroft or The Hangar and The Kroft

or something like that?

A. Yes.

Q. Have you ever gone there for lunch?

A. Yes.

O. When you started with Boeing up until April of

2023, was there ever a period of time where new projects

could not be claimed by Phase 2?

MR. KEEGAN: The question lacks foundation.

32

Go ahead and answer, if you understand the question.

BY MR. DAVIS:

Q. Go ahead.

A.

I’m not sure what the question is.

Q. Do you know what a Phase 2 is of avionics?

A. Yes.

Q. And projects are claimed to be completed. Was

there ever a period of time that employees claimed these

projects started?

A.

I’m not sure.

Q. Do you recall walking to the - or going to

lunch at the Kroft and on your way back approaching

Mr. Veto and - approaching him and blowing smoke

in his face?

A.

No, I do not.

Q. Are you a cigarette smoker?

A.

I used to be, yes.

Q. You used to be?

A. Yes...

33

Nergal Daniel knew that Boeing Global Services in

Long Beach was sending proposals to commercial airline

customers for modification and/or conversion after drugs

were reported in the workplace.

Below are numerous examples to highlight this lie.

(1) The Proposal Team (Phase 1) and the Execution

Team (Phase 2) were both managed by Ryan H. Gardner

at that time (2023), and both teams sat on the fourth floor

of building 800 at 4060 N. Lakewood Boulevard in Long

Beach, California.

(2) Metrics for outgoing proposals and accepted

proposals were routinely presented during group

meetings which were held on a recurring basis, including

even the one meeting which Nergal Daniel himself was

asked to lead by Ryan H. Gardner in an instance when

Ryan H. Gardner was out of office. This was the meeting

when John Getsy asked Nergal Daniel a number of pointed

questions as mentioned in my email to you on 9/17/2024.

(3) New projects were posted almost every day on

our internal system around 2:00 PM PST which is where

Nergal Daniel himself found new projects.

(4) New projects were posted on sticky notes and

discussed in the 9AM daily work-in-progress standup

status meetings hosted by Ryan H. Gardner which are

the same meetings where the E-UM was wrongly present

even though the E-UM’s are part of the ODA, and the

ODA is not supposed to be pressured in any way (see

EEOC Explanation of the Facts...). Remember that the

ODA was created as a stand-in for the Federal Aviation

34

Administration in the aftermath of the tragic 737 MAX

incidents of 2018 and 2019.

(5) New projects were discussed between me, Mr.

Fred Von Zabern, and Mr. Robert “Eric” Gonzales, and

Mrs. Eloise Driver for the Air Canada passenger-tofreighter conversion campaign as Air Canada continued

to request additional projects for proposal.

(6) New projects were being distributed by Mr. Charles

“Mike” Hargrave as part of a UPS project campaign that

would take priority over some of other projects according to

Ryan H. Gardner (see Tab 23, scan 10).

(7) Data related to proposal of the project, its

acceptance date, the assigned project manager, and even

the actual contractus made available for any project

manager in the PMdb (Project Management Database)

system used as one of the primary systems to manage a

project’s completion.

(8) New projects classified as “Jetstream” (meaning

projects able to be quickly completed) were posted on

sticky notes and discussed in the Jetstream Kanban room

that was being managed by Mr. Robert “Eric” Gonzales.

(9) New projects that met the criteria of “Jetstream”

could only be claimed by newer project managers towards

the tail-end of March as mentioned by Ryan H. Gardner in

an e-mail to all Phase 2 Project Managers, meaning that

new Jetstream projects were being offered.

(10) Nergal Daniel makes the claim on page 9 that

he was promoted to Senior manager and now managing

35

“A little bit over 20 people,” but this would imply that he

was now directly managing the Phase 1 employees since

there were far less than twenty employees by Phase 2

alone, meaning that Nergal Daniel would be fully aware

of their on-going proposal activity without any cessation

despite either reports of Narcotics or the Software NonCompliance Matrix. Projects were postponed due to the

Software Non-Compliance Matrix, but there was never

a cessation in proposals sent to the commercial aviation

customers.

(11) Nergal Daniel was one of the four employees

whom Ryan H. Gardner authorized to manage the project

Capacity Planner which led to Nergal Daniel attending

new project kickoff meetings over WebEx (see EEOC

Explanation of the Facts...).

Boeing attempts to attack my credibility by

suggesting that I am not a Whistleblower:

I was explicitly treated as a Whistleblower by United

States Congress as well as the US Equal Employment

Opportunity Commission.

Boeing states that I never saw an employee

appearing impaired:

However they gloss over the fact that the janitor who

was one of the individuals who used Narcotics walked into

a kitchen that was closed down due to COVID.

Boeing glosses over the numerous examples of

egregiously poor judgment by Ryan H. Gardner including

having an ODA in the same 9AM daily status standup

meeting with Nergal Daniel.

36

Boeing glosses over Ryan H. Gardner sticking out his

tongue at the group during a group meeting to taunt us.

Boeing glosses over Nergal Daniel stating that he

would literally sit down next to an employee until that

employee signed off on their task.

Boeing glosses over that Mr. Fred Von Zabern, who

sat adjacent to Nergal Daniel and said he (Fred) may have

lost his sense of smell, had an angry outburst towards

Armen Hovanesian.

Boeing glosses over that Ryan H. Gardner said that

Nergal smokes; that Nergal Daniel was doing drugs rather

than cigarettes; and that tobacco too would have been a

violation of Boeing policy.

Boeing glosses over Sean Woodward meeting to

discuss this issue in a conference room located within

close proximity to Nergal Daniel’s desk.

Boeing attacks my credibility of witnessing college

students using Narcotics in Washington, D.C.

Those students were busted by the police and

subsequently remanded to a substance abuse class by The

George Washington University.

*

*

*

Aerospace is not the place for Narcotics, nor is

anyplace. Marijuana is illegal for a reason. The opposing

counsel should be ashamed of themselves and disbarred.

This group of bad actors seeks to undermine Federal Law.

37

The US Supreme Court says EQUAL JUSTICE UNDER

LAW rather than simply EQUAL JUSTICE.

*

*

*

*

The Supremacy Clause is a National Strength. Its

three pillars of the US Constitution, Treaties and Federal

Law have been championed by Justices like the first four

Chief Justices as well as ordinary Americans. But when

the pretenses of those addicted to illegal drugs seek to

subvert the Supremacy of Federal Law, who then would

place trust in American Treaties?

REASONS FOR GRANTING THE PETITION

Veto vs. The Boeing Co. is a case of National

Significance for the following reasons:

1.

Hundreds of people have lost their lives due to

horrific tragedies like Jeju Air (Flight 2216), Air

India (Flight 171), and UPS (Flight 2976). Even MD11 is linked to Boeing Southern California through

the Airworthiness Directive of the US Department

of Transportation (2024-28780). More broadly across

transportation, ten people are dying every day due to

Marijuana related car accidents.

2.

Boeing has a sole monopoly on the production of

Air Force One, and Air Force One is now incurring

electrical problems as seen on the trip to Davos

Switzerland (1/21/2026). Boeing has approximately

150,000 employees; whereas Microsoft of 2000 had

approximately 39,100 employees. Standard Oil of 1911

had 60,000 employees.

38

3.

The California Central District Court seeks to

undermine the United States Constitution by

subverting the Supremacy of Federal Law. Marijuana

remains illegal under federal law (21 USC 802).

4.

Despite Muscarello (1998) and Kyllo (2001), there was

illicit Narcotics use at the Boeing Long Beach facility

Building 800 by Nergal Daniel and others, aided and

abetted by Ryan H. Gardner (then manager) in 2023

who wrongly said, “Marijuana is legal in California.”

5.

Boeing has national programs customers. At Boeing

Long Beach, customers included the US Marine

Corps and President Trump’s personal 757-200; yet

both were assigned lower customer priority than

Beijing Airlines.

6.

The number one issues of the 2024 Election was

securing the US-Mexico border, and people like El

Chapo depend on people like Ryan H. Gardner to say

that Marijuana is legal.

7.

The Central District Court invokes the McDonnell

Douglas three-part burden shifting framework in

an attempt to refute Cal. Lab. Code Section 6310.

However, as recent as 2025, Justice Thomas of the

Supreme Court has expressed the desire to revisit the

1973 McDonnell Douglas case to determine whether

its burden-shifting framework remains a workable

and useful evidentiary tool.

8.

The 9th Circuit attempts to revive its 1992 era of

jurisprudence in its memorandum by citing Planned

Parenthood of Greater Washington and North Idaho

39

v. US Department of Health and Human Services

(2020) which bases its reasoning on Lujan v. Defs.

of Wildlife (1992). The California Central District

also seeks to revive the 9th Circuit’s 1992 era of

jurisprudence by citing Chevron Corp v. Pennzoil

Co (1992) in its Motion for Summary Judgment.

Whether by West Virginia v. EPA (2022) which cites

Lujan (1992) or by Dobbs (2022) which cites Planned

Parenthood v. Casey (1992), the Supreme Court of

the United States is not reviving the 9th Circuit’s

jurisprudence of the 1992 era.

9.

Two Boeing CEOs have testified on Capitol Hill in

highly publicized Congressional Hearings. In the

testimony of Mr. Calhoun, it was confirmed that

Boeing does retaliate against Whistleblowers.

10. Boeing has been imperiling safety by creating contracts

for modification and conversion of commercial aviation

vehicles which were not compliant with the provisions

of US DOT Section 8110.48 Section 5-5.

Suggested Remedies

Mr. Veto seeks a unanimous (9-0) ruling in his favor

since a unanimous ruling sends the strongest message to

the drug cartels.

Suggested remedies are as follows:

1.

Mr. Veto invites the support of the Congressional

Research Service (CRS) to identify relevant attempts

on a state-by-state basis to create state laws that

undermine Federal Law (21 USC 802) in order to

40

declare those attempts as unconstitutional under the

Constitution of the United States.

Recommended State and U.S. Territory Statutes

to Rule Unconstitutional:

Alaska: Ballot Measure 2 (2014), AS 17.38 (2014)

Arizona: Prop 207 (2020), Prop 203 (2010)

California: California Adult Use of Marijuana Act

(AUMA) (2016), AB 1706 (2022), AB 1646 (2022), AB 1885

(2022), AB 1894 (2022), AB 2210 (2024), AB 2188 (2024),

AB 2568 (2022), AB 2925 (2022), SB 1186 (2022), SB 1326

(2022), Prop 47 (2014)

Compassionate Use Act of 1996 (1996)

Colorado: Amendment 20 (2000), Amendment 64 (2012)

Connecticut: Senate Bill 1201 (2022), Public Act 21-1 (2021)

Delaware: HB 1 (2023), HB 2 (2023)

Guam: Public Act 101-0027 (2020)

Illinois: Public Act 101-0027 (2020)

Maine: Maine Medical Marijuana Act (1999), Maine

Medical Use of Cannabis Act (1999)

Maryland: House Bill 556 (2023), Senate Bill 516 (2023)

Massachusetts: Act to Ensure Safe Access to Marijuana

(2017), Adult-Use Marijuana Regulation Law (2016)

41

Michigan: Michigan Regulation and Taxation of

Marihuana Act (2018), Michigan Medical Marihuana Act

(2008)

Minnesota: Minnesota Cannabis Act (2023)

Missouri: Amendment 3 (2022)

Montana: Initiative 190 (2020)

Nevada: Initiative to Regulate and Tax Marijuana (2016)

New Jersey: Cannabis Regulatory, Enforcement

Assistance, and Marketplace Modernization Act (2021)

New Mexico: Cannabis Regulation Act (2021)

New York: Marihuana Regulation and Taxation Act (2021)

Northern Mariana Islands (CNMI): Taulamwaar

Sensible CNMI Cannabis Act of 2018 (2018)

Ohio: Senate Bill 56 (2025)

Oregon: Control, Regulation, and Taxation of Marijuana

and Industrial Hemp Act (2014); Oregon Medical

Marijuana Act (1998)

Puerto Rico: 42-2017 (2017)

Rhode Island: Rhode Island Cannabis Act (2022)

U.S. Virgin Islands: 2023 Virgin Islands Cannabis Use

Act (2023)

42

Vermont: Act 86 (2018), Act 164 (2020)

Washington: Initiative 502 (2012)

Washington, DC: Legalization of Possession of Minimal

Amounts of Marijuana for Personal Use Initiative of 2014

(2014)

2. The opposing legal counsel attempts to invoke

Creighton v. City of Livingston (2009) to invalidate

claims under Labor Code Section 6310. However, as the

US Supreme Court has said in Payne v. Tennessee (1991),

“stare decisis is not an inexorable command.” This case

should overturn Creighton (2009) since that case employs

a magic words test that has no foundation in Constitutional

Law and in fact leads to a less perfect union. Creighton

(2009) is incompatible with The Supremacy Clause, 21

USC 802, Muscarello (1998), Kyllo (2001), Loder (1997),

Hentzel (1982), and Cal Labor Code 232.5.

3. This case places an immediate injunction on work

performed by The Boeing Co. at the Boeing Long Beach

location located at 4060 N. Lakewood Boulevard Long

Beach, CA 90808.

4. This case seizes all vehicles under contract with the

US Government to be built, serviced, or modified at a

Boeing Southern California facility (including Long Beach,

Seal Beach, and Victorville, not excluding Huntington

Beach and El Segundo) by The Boeing Co. and transfers

ownership of those vehicles to the US Government.

5. This case places an immediate injunction on any

non-US based customer being ranked as the number one

priority of Boeing.

43

6. The Federal Aviation Administration (FAA) is re­

instated to provide oversight of The Boeing Co., and the

Other Designation Authorization (ODA), Boeing’s attempt

to self-regulate, is disbanded.

7. Any US-based manufacturer is authorized to enter

into contract for the production an Executive Branch

Cabinet-level aircraft, including Air Force One, without

any limitations of currently held patents by The Boeing

Co.

8. Front-line Engineering Managers at The Boeing Co.

will no-longer be evaluated on the basis of creating a Long

Range Business Plan.

9. Boeing Commercial Airlines (BCA), Boeing Global

Services (BGS), Boeing Defense Systems (BDS), and

Boeing Research and Technology (BR&T) are to

disband into separate corporations where wholly-owned

subsidiaries (e.g., Millennium Space Systems, AvionX,

ArgonST, HorizonX, Aurora Flight Sciences, and Hughes

Research Lab) are to reside with entities other than BCA

or BGS, and disbanded corporations are not to share the

same facilities.

10. Ryan H. Gardner, Sean Woodward, and Nergal

Daniel are held accountable for subversion of Federal

Law: 21USC 802. Ryan H. Gardner, Sean Woodward, and

Nergal Daniel are prohibited from practicing engineering.

11. The Boeing Co., and its representation as disbanded

corporations, is prohibited from conducted business with

the Export-Import Bank for a period of 10 years.

44

12. The Boeing Co. is fined in the amount of $20 million

made payable to Mr. Veto.

CONCLUSION

Mr. Veto is grateful to the Article III Justices of

the Supreme Court of the United States whose excellent

writing abilities have led to lasting landmark rulings.

The petition for a writ of certiorari should be granted.

Respectfully submitted,

Christopher C. Veto, Pro Se

5345 Falls Way, Apartment G

Buena Park, CA 90621

(657) 252-7189

christophercveto@gmail.com

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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