Reply Brief — Chaldean Coalition, Inc., Petitioner v. San Diego County Independent Redistricting Commission, et al.

No. 25-577

In the

Supreme Court of the United States

CHALDEAN COALITION, INC.,

Petitioner,

v.

THE COUNTY OF SAN DIEGO INDEPENDENT

REDISTRICTING COMMISSION, THE COUNTY OF

SAN DIEGO, AND CYNTHIA PAES,

Respondents.

On Petition for a Writ of Certiorari to the

Court of A ppeal of the State of California,

Fourth A ppellate District, Division One

REPLY BRIEF FOR PETITIONER

Paul M. Jonna

Counsel of Record

Charles S. LiMandri

Jeffrey M. Trissell

LiMandri & Jonna LLP

P.O. Box 9120

Rancho Santa Fe, CA 92067

(858) 759-9930

pjonna@limandri.com

Counsel for Petitioner

120942

A

(800) 274-3321 • (800) 359-6859

i

TABLE OF CONTENTS

Page

TABLE OF CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . i

TABLE OF CITED AUTHORITIES . . . . . . . . . . . . . . . ii

REPLY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1

ARGUMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

I.

The Decision Below is Contrary to this

Court’s Racial Gerrymandering Decisions

from Shaw through Alexander . . . . . . . . . . . . . . 2

II. This Case is an Excellent Vehicle to Address

Questions of Nationwide Importance . . . . . . . . . 8

CONCLUSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

ii

TABLE OF CITED AUTHORITIES

Page

CASES

Abbott v. League of United Latin Am. Citizens,

146 S. Ct. 418 (2025) . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Ala. Legislative Black Caucus v. Alabama,

575 U.S. 254 (2015) . . . . . . . . . . . . . . . . . . . . . 6, 7, 8, 10

Alexander v. S.C. State Conf. of the NAACP,

602 U.S. 1 (2024) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2, 3

Am. Fed’n of State, Cty. & Mun. Emps. v.

Metro. Water Dist.,

24 Cal. Rptr. 3d 285 (Ct. App. 2005) . . . . . . . . . . . . . 12

Bethune-Hill v. Virginia State Board of Elections,

580 U.S. 178 (2017) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Bost v. Ill. State Bd. of Elections,

607 U.S. --, No. 24-568, 2026 WL 96707

(U.S. Jan. 14, 2026) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

C.I.R. v. McCoy,

484 U.S. 3 (1987) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Cooper v. Harris,

581 U.S. 285 (2017) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Gaffney v. Cummings,

412 U.S. 735 (1973) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

iii

Cited Authorities

Page

Gratz v. Bollinger,

539 U.S. 244 (2003) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Harris v. Ariz. Indep. Redistricting Comm’n,

578 U.S. 253 (2016) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

League of United Latin Am. Citizens v. Perry,

548 U.S. 399 (2006) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Louisiana v. Callais,

145 S. Ct. 2608 (2025) . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Miller v. Johnson,

515 U.S. 900 (1995) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Perez v. Abbott,

250 F. Supp. 3d 123 (W.D. Tex. 2017) . . . . . . . . . . . . . 7

Plumley v. Austin,

574 U.S. 1127 (2015) . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Republican Nat’l Comm. v.

Democratic Nat’l Comm.,

589 U.S. 423 (2020) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Ricci v. DeStefano,

557 U.S. 557 (2009) . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Rodriguez v. Mun. Ct.,

102 Cal. Rptr. 45 (Ct. App. 1972) . . . . . . . . . . . . . . . . 12

iv

Cited Authorities

Page

Shaw v. Reno,

509 U.S. 630 (1993) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Students for Fair Admissions, Inc. v.

President & Fellows of Harvard Coll.,

600 U.S. 181 (2023) . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Tangipa v. Newsom,

-- F. Supp. 3d --, No. 25-cv-10616, 2026 WL

110585 (C.D. Cal. Jan. 14, 2026) . . . . . . . . . . . . . . . . 7, 8

United States v. Gen. Motors Corp.,

384 U.S. 127 (1966) . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Van Buren v. United States,

593 U.S. 374 (2021) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Wis. Legislature v. Wis. Elections Comm’n,

595 U.S. 398 (2022) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

STATUTES

U.S. Const. amend. XIV . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Cal. Civ. Proc. Code § 1090 . . . . . . . . . . . . . . . . . . . . . . . 12

OTHER AUTHORITIES

BIPOC, Dictionary.com, https://www. dictionary.

com/browse/bipoc (last visited Feb. 3, 2026) . . . . . . . 5

v

Cited Authorities

Page

Brief of Massachusetts, California, et al., as Amici

Curiae in Support of Respondents, Students

for Fair Admissions, Inc. v. President &

Fellows of Harvard Coll., 600 U.S. 181 (2023) . . . . . . 1

Richard C. Chen, Summary Dispositions As

Precedent, 61 Wm. & Mary L. Rev. 691 (2020) . . . 2, 8

Antonin Scalia & Bryan A. Garner, Reading Law:

The Interpretation of Legal Texts 2 32

(Thomson West, 2012) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Sup. Ct. R. 32.3 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

1

REPLY

The prevailing ideology in California regarding race

relations is not particularly novel or foreign: it is that

colorblindness is inherently racist and counterproductive.

See, e.g., Brief of Massachusetts, California, et al., as

Amici Curiae in Support of Respondents, Students for

Fair Admissions, Inc. v. President & Fellows of Harvard

Coll., 600 U.S. 181 (2023). That is a commonly held position,

but it is anathema to the Equal Protection Clause.

Relying on this philosophy, Respondent County of

San Diego Independent Redistricting Commission set

out explicitly to create a BIPOC majority-minority county

supervisorial district. And in so doing, it had to decide

whether to fracture the El Cajon area by placing some

areas that use an “El Cajon” street address in the Central

District 4 and other areas in the East County District 2.

Fracturing this area would have the unfortunate effect

of increasing the population deviation between those two

districts and splitting the Chaldean community, and so

was strongly opposed by the residents of El Cajon. But,

after a lengthy debate focused solely on this one question,

the Commission decided to fracture the area of El Cajon

by placing the census designated place of Rancho San

Diego in the Central District 4. The explicit basis for

this: because of Rancho San Diego’s African-American

population, it belonged in the BIPOC Central District 4.

See Pet.6-14.

The question presented in the petition is whether

“ the Equal Protection Clause of the Fourteenth

Amendment [is] violated when the explicit basis for

the placement of a geographic area in one district over

another, exacerbating the population deviation between

2

the two districts, is the racial composition of that area.”

Pet.i. Yet the Redistricting Commission largely ignores

the actual question, discussing the population equality

between the two supervisorial districts on only one page,

BIO.28, and completely ignores the statements of actual

Commissioners about their intent. What the Commission

does not address—because it cannot—speaks volumes.

Instead, the Commission devotes nearly the entirety of

its brief to raising procedural arguments, none of which

are particularly difficult to overcome.

Summary reversal is most appropriate in cases that

are “important but not complex,” and when granting

certiorari would “serve the valuable purpose of clarifying

the contours of key legal standards.” Richard C. Chen,

Summary Dispositions As Precedent, 61 Wm. & Mary

L. Rev. 691, 722 (2020). Here, the lower courts’ decision

to ignore the direct statements of legislative intent was

clearly erroneous and should be “[s]ummarily correct[ed]”

by this Court, Wis. Legislature v. Wis. Elections Comm’n,

595 U.S. 398, 401 (2022), with the admonition that the

presumption of legislative good faith is overcome in the

case of a “confession of error.” Alexander v. S.C. State Conf.

of the NAACP, 602 U.S. 1, 8 (2024).

ARGUMENT

I.

The Decision Below Is Contrary to this Court’s

Racial Gerrymandering Decisions from Shaw

through Alexander

1. “It is a sordid business, this divvying us up by

race.” League of United Latin Am. Citizens v. Perry,

548 U.S. 399, 511 (2006) (Roberts, C.J., concurring).

Thirty years ago, this Court explained that “district lines

3

obviously drawn for the purpose of separating voters by

race require careful scrutiny under the Equal Protection

Clause regardless of the motivations underlying their

adoption.” Shaw v. Reno, 509 U.S. 630, 645 (1993)

(emphasis added). But the Court further clarified that

“[n]o inquiry into legislative purpose is necessary” in the

context of “[e]xpress racial classifications. Id. at 632.

Under that “careful scrutiny,” when a challenger

presents direct evidence of the intent of the “mapmakers,”

Cooper v. Harris, 581 U.S. 285, 299 (2017), it can only be

given dispositive weight for which it would be impossible

for the court to “reach[] any conclusion other than that

race was the predominant factor in drawing [the] District.”

Miller v. Johnson, 515 U.S. 900, 918 (1995). It “amounts

to a confession of error.” Alexander, 602 U.S. at 8. And

once that predominance conclusion is reached, “[r]acial

classifications are simply too pernicious to permit any

but the most exact connection between justification and

classification.” Louisiana v. Callais, 145 S. Ct. 2608 (2025)

(Thomas, J., dissenting) (quoting Gratz v. Bollinger, 539

U.S. 244, 270 (2003)).

2. Here, the evidence was direct, overwhelming, and

unrebutted. In a specific discussion in advance of a specific

vote, Commissioner Ponds, assisted by Commissioner

Dostal, stated directly that he drew the final maps and

that he placed the El Cajon sub-area of Rancho San Diego

in the Central District 4 because of its African-American

population:

My intent was particularly to do two things: To

move [the City of] El Cajon, um, into District 2

as part of the East County area, and also to sort

of consolidate, um, the BIPOC community into

4

District 4. And that included the three areas

and also the adjustment made by, um, FLO

Analytics. And that was the purpose and the

intent of creating that Scenario 3b. Thank you.

App.162a; https://bit.ly/4ofMvLn at 10:40–11:30.

As Commissioner Dostal further explained:

[ M ] y u nde r st a nd i ng of t h i s m ap t h at

Commissioner Ponds, it was on his motion,

Spring Valley, Paradise Hills, Casa de Oro,

[Rancho] San Diego, having nothing to do

with [the City of] El Cajon—[the City of] El

Cajon is a separate issue from this particular

issue—was a community of interest to the Black

community, the historical Black community in

this area. So, I just want to remind everybody

about that.

App.195a-196a; https://bit.ly/4oQApbK at 2:43:23–2:44:55.

The Commission then debated two rival maps with

a single difference: 1) Rancho San Diego in the Central

District 4, coined Scenario 3b, or 2) Rancho San Diego in

the East County District 2, a de facto Scenario 3c. During

this debate, some Commissioners argued that Rancho

San Diego needed to be in the East County District 2

to equalize the population deviation between the two

districts, and other Commissioners argued that it needed

to be in the Central District 4, despite exacerbating the

population deviation, because of its African-American

population. Pet.9-13; App.162a-175a.

5

These facts were undisputed and present a pure

question of law: whether exacerbating the population

deviation between two districts on an explicitly racial basis

violates the Equal Protection Clause’s guarantees against

racial gerrymandering and in favor of equal voting strength.

See Harris v. Ariz. Indep. Redistricting Comm’n, 578 U.S.

253, 263 (2016) (a violation occurs where “illegitimate

considerations were the predominant motivation behind

the plan’s deviations from mathematically equal district

populations.”).

In response, Respondent Redistricting Commission

fails to grapple with the statements of Commissioners

Ponds, Dostal, Inman, Garcia, Surban, or Diaz. Instead,

completely ignoring their statements, the Commission

simply points to the state trial court’s conclusion that

Respondent used “BIPOC” as a term of art “to refer to

immigrant and refugee” communities of interest. BIO.31

(quoting App.99a). “BIPOC,” of course, means “Black,

Indigenous, and People of Color.” See BIPOC, Dictionary.

com, https://www. dictionary.com/browse/bipoc (last

visited Feb. 3, 2026). And this conclusion is odd because

“‘there is a presumption against’ reading a provision

contrary to the ordinary meaning of the term it defines.”

Van Buren v. United States, 593 U.S. 374, 404-05 (2021)

(Thomas, J., dissenting) (quoting Antonin Scalia & Bryan

A. Garner, Reading Law: The Interpretation of Legal

Texts 232 (Thomson West, 2012)).

Regardless, the California Court of Appeal did

not adopt this strained interpretation of “Black,

Indigenous, and People of Color.” Instead, the Court of

Appeal concluded that the Redistricting Commission’s

“references ‘at times’ to the central district as a ‘BIPOC

6

district’ [did not necessarily] show[] race was the factor

that predominated over other, permissible factors.”

App.45a-46a. But like the trial court, it disregarded

Commissioners’ statements about Rancho San Diego on

the basis that even an expressly stated racial intent with

respect to where to place Rancho San Diego alone was

legally irrelevant. App.46a.

The Redistricting Commission accuses Petitioner

Chaldean Coalition of “mischaracteriz[ing]” the Court

of Appeal’s opinion in noting that the Court of Appeal

acknowledged that the Commission “directly stat[ed]

that Rancho San Diego was included in the central

district because of its African American community.”

BIO.16; Pet.15. But that is precisely what the opinion

does: it acknowledges the problem but then quickly moves

past it to accept the Commission’s argument that these

statements are irrelevant under the broader analysis

required by Bethune-Hill v. Virginia State Board of

Elections, 580 U.S. 178 (2017). See App.46a.

Before this Court, the Commission reiterates that point,

arguing that Bethune-Hill precludes a “myopic focus” on

the debate and vote over Rancho San Diego. BIO.29-30. But

Bethune-Hill was not a one-person, one-vote case. Recourse

to it ignores that “an equal population goal” “is part of the

redistricting background, taken as a given, when determining

whether race, or other factors, predominate in a legislator’s

determination as to how equal population objectives will

be met.” Ala. Legislative Black Caucus v. Alabama, 575

U.S. 254, 272 (2015). The California Court of Appeal did

not understand how to analyze a one-person, one vote claim

when the illegitimate motivation for deviation from equality

was racial, and so applied the same analysis as a traditional

7

racial gerrymander. App.36a-39a. The Commission offers

nothing more, arguing merely that its good faith should be

presumed because the deviation was less than 10%. BIO.28.

This Court, however, has explained that in “the ordinary

sense of th[e] word,” population equality is always the most

“predominant” criterion. Ala. Legislative Black Caucus,

575 U.S. at 272-73. When it is subordinated to “illegitimate

considerations”—including race—Equal Protection is

violated. See Perez v. Abbott, 250 F. Supp. 3d 123, 208

(W.D. Tex. 2017) (“In short, Plaintiffs argue that the State

intentionally discriminated against minority voters by

overpopulating minority districts and underpopulating

Anglo districts. Such a practice is, of course, an illegitimate

redistricting factor.”) (citing Gaffney v. Cummings, 412 U.S.

735, 751-52 (1973)).

3. This term, the Court has permitted both Texas’s

and California’s mid-decade redistricting to proceed. As

preliminary injunction cases seeking adjudication on the

Court’s interim docket, they both prominently faced the

issue that “federal courts should ordinarily not alter the

election rules on the eve of an election.” Bost v. Ill. State

Bd. of Elections, 607 U.S. --, No. 24-568, 2026 WL 96707,

at *4 (U.S. Jan. 14, 2026) (quoting Republican Nat’l Comm.

v. Democratic Nat’l Comm., 589 U.S. 423, 424 (2020) (per

curiam)).

But also in both cases, the scope of the “presumption

of legislative good faith” was a central issue. See Abbott v.

League of United Latin Am. Citizens, 146 S. Ct. 418, 419

(2025); Tangipa v. Newsom, -- F. Supp. 3d --, No. 25-cv10616, 2026 WL 110585, at *11 (C.D. Cal. Jan. 14, 2026). And

because that presumption played such a prominent role,

8

as stated by Judge Lee, “the contours of the presumption

of good faith may require further explanation by the

Supreme Court.” Tangipa, 2026 WL 110585, at *36 (Lee,

J., dissenting). Indeed, in the California redistricting case,

both the majority and dissent examined the same direct

evidence in the form of statements by the map drawer

and drew opposite conclusions from them. Compare id.

at *18-21; with id. at *37-43 (Lee, J., dissenting).

A summary reversal here could be used to great benefit

by “fill[ing] in the contours of general legal standards,”

which “acquire meaning through their application to a

series of cases.” Chen, supra, at 697. For many lower

courts, the reach of the presumption of legislative good

faith is ambiguous. For other courts, the question of when

the racial predominance test is met is also unclear. This

Court should clarify that this case met those standards.

II. This Case is an Excellent Vehicle to Address

Questions of Nationwide Importance

1. As part of its lengthy raising of procedural

strawmen, the Redistricting Commission first argues that

Petitioner Chaldean Coalition lacks associational standing.

BIO.19-25. According to the trial court, Petitioner

submitted insufficient evidence that its constituents

have control over it. These facts are necessary because

Chaldean Coalition, Inc. is not organized as a traditional

membership nonprofit. See BIO.20-21 (citing App.90a92a). The trial court did not find, and the Redistricting

Commission does not argue, that Chaldean Coalition

could not submit this evidence on remand or in response

to a request from this Court. See Ala. Legislative Black

Caucus, 575 U.S. at 270 (citing Sup. Ct. R. 32.3).

9

But, as indicated in the Petition, Chaldean Coalition’s

evidence should have been more than adequate. See Pet.30.

In a verified response to an interrogatory to “IDENTIFY

all the members of PETITIONER Chaldean Coalition,”

Petitioner explained:

The Chaldean Coalition is a coalition, it

encompasses both Chaldean associations and

individuals and has been growing since its

inception. As of the date of these responses, the

Coalition consists of 1,315 households covering

5,787 individuals. It also consists of all major

Chaldean organizations in San Diego County.

Petitioner’s ow n freedom of association

interests, and its supporters’ privacy interests,

preclude Petitioner from identify ing its

individual members outside the context of

a stipulated protective order. Moreover, the

term “member” is undefined and vague. In a

significant sense, Petitioner represents the

interests of all individual Chaldeans countywide. However, Petitioner understands that

Respondent has a legitimate interest in testing

Petitioner’s standing to bring claims on behalf

of its supporters. Thus, Petitioner identifies its

board members and the associations that are

part of the Coalition. If Respondent enters into

a protective order and identifies a plausible need

for the identities for all individuals who are a

part of the Coalition, Petitioner will consider

identifying those individuals.

10

10.AA.2080-82. The parties did enter into that protective

order and Chaldean Coalition then produced its list of

30,000 members. See App.91a.

The Redistricting Commission misleadingly states

that “the trial court found the evidence established … [i]n

discovery responses the Coalition identified no members

of its organization.” BIO.20 (citing 10.AA.2082). The

Commission cites to the underlying discovery responses,

not the trial court, because there is no such finding in

the trial court’s statement of decision. See App.90a-92a.

And the description of the discovery is equally false. In

addition to directors and associations, Petitioner identified

three exemplar members—pending entry of the protective

order—chosen for their residence in a relevant area:

• Aziz Razoky 4800 Block of Mt. Helix Dr.

La Mesa, CA 91941 (Casa de Oro-Mt. Helix

CDP; Central District 4)

• Garvin Garmo 3500 Block of Brittany Court

Jamul, CA 91935 (Jamul CDP; East County

District 2)

• Steve Mattia 10600 Block of Busch St.

Spring Valley, CA 91978 (Spring Valley

CDP; Central District 4)

10.AA.2083. In the absence of any basis to suspect that

these members lack control over Chaldean Coalition, its

evidence was adequate. Students for Fair Admissions,

Inc. v. President & Fellows of Harvard Coll., 600 U.S. 181,

201 (2023); Ala. Legislative Black Caucus, 575 U.S. at 270.

11

2. The Redistricting Commission then argues that

Chaldean Coalition wrongly cites to paragraphs in two

declarations to which the trial court sustained evidentiary

objections. BIO.16-17; Pet.8 (citing Decl. of Father Michael

Bazzi ¶¶ 23, 27-37 (Mar. 23, 2023) (7.AA.1364-73); Decl.

of Fabian Valdez ¶¶ 27-57 (Mar. 17, 2023) (7.AA.1447-69)).

The trial court did sustain some objections to sentences

in those declarations, but did not sustain any relevant

objections. Rather, the trial court admitted the vast

majority of those declarations, including Mr. Valdez’s

description of how he mapped the 30,000 members of

Chaldean Coalition. See 9.AA.1758-1821 (82 evidentiary

objections); App.87a (ruling on objections).

In a similar fashion, the Commission next states that

Chaldean Coalition failed to preserve its arguments before

the Court of Appeal. BIO.32-35 (citing App.40a, 42a-43a,

46a, 64a-65a). As stated in the petition for rehearing

before the Court of Appeal, which resulted in significant

modifications to the opinion, Chaldean Coalition did not

fail to preserve those arguments. See App.61a-66a. But, in

any event, none of the arguments cited by the Commission

as waived include the argument presented to this Court.

See BIO.32-35.

3. Lastly, the Redistricting Commission argues

that this is a poor vehicle because the action is “steeped

in extensive state-law procedural nuances” and resulted

in an “unpublished disposition.” BIO.3. The Commission

never clarifies what those “procedural nuances” are but,

as Chaldean Coalition explained, the procedure used here

“is a feature not a bug.” Pet.28.

12

Under a California petition for writ of mandate, the

trial court’s role is to perform a bench trial on paper by

reviewing written evidence submitted by the parties. See

Am. Fed’n of State, Cty. & Mun. Emps. v. Metro. Water

Dist., 24 Cal. Rptr. 3d 285, 296 (Ct. App. 2005). In cases of

significant factual dispute, the trial court can and should

empanel a jury. Cal. Civ. Proc. Code § 1090. But otherwise,

the role of the trial court is not “to try issues of fact but

only questions of law.” Rodriguez v. Mun. Ct., 102 Cal.

Rptr. 45, 49 (Ct. App. 1972). In the context of a “paper

case,” where any factual determinations were made upon

reviewing declarations, the clear error standard of review

“plays only a restricted role.” United States v. Gen. Motors

Corp., 384 U.S. 127, 142 n.16 (1966).

As to the unpublished nature of the decision, which

the Redistricting Commission repeatedly notes, BIO.1,

3, 16, 19, 25, 30, that “carries no weight” in this Court’s

certiorari analysis. C.I.R. v. McCoy, 484 U.S. 3, 7 (1987);

see also Ricci v. DeStefano, 557 U.S. 557, 576 (2009). Given

the constitutional rights at stake, that “the decision below

is unpublished … is yet another disturbing aspect of the

[Court of Appeal’s] decision, and yet another reason to

grant review.” Plumley v. Austin, 574 U.S. 1127 (2015)

(Thomas, J., dissenting from denial of certiorari).

13

CONCLUSION

The Court should grant the petition.

Respectfully submitted,

Paul M. Jonna

Counsel of Record

Charles S. LiMandri

Jeffrey M. Trissell

LiMandri & Jonna LLP

P.O. Box 9120

Rancho Santa Fe, CA 92067

(858) 759-9930

pjonna@limandri.com

Counsel for Petitioner