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.
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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.
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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
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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)
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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)
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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.
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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.
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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.