Petition for Writ of Certiorari — Calvin M. Costanza, Petitioner v. Florida Marine Transporters, LLC

NO. 25-_____

In the

Supreme Court of the United States

CALVIN M. CONSTANZA,

Petitioner,

v.

FLORIDA MARINE TRANSPORTERS, LLC,

Respondent.

__________________________

On Petition for a Writ of Certiorari to the

Louisiana Court of Appeal First Circuit

PETITION FOR A WRIT OF CERTIORARI

John M. Robin

Counsel of Record

LAW OFFICES OF JOHN M. ROBIN

600 Covington Center

Covington, LA 70433

(985) 893-0370

johnmrobin@johnmrobinlaw.com

December 17, 2025

SUPREME COURT PRESS

Counsel for Petitioner

♦

(888) 958-5705

♦

BOSTON, MASSACHUSETTS

i

QUESTION PRESENTED

Whether under 46 U.S.C.A. § 30104 (The Jones

Act) relaxed causation standard, requiring only that

the employer’s negligence play “any part, even the

slightest, i.e. featherweight standard” in producing

injury, applies to toxic tort claims involving scientific

causation, or whether a plaintiff must meet the heightened Daubert v. Merrell Dow Pharmaceuticals, Inc.,

509 U.S. 579, 113 S.Ct. 2786, 125 L.Ed.2d 469 (1993)

style requirement for dose response and threshold

exposure evidence.

ii

PARTIES TO THE PROCEEDINGS

Petitioner and Plaintiff-Appellant below

●

Calvin Constanza

Respondent and Defendant-Respondent below

●

Florida Marine Transporters, LLC

iii

LIST OF PROCEEDINGS

Supreme Court of the Louisiana

No. 2025-C-00649

Calvin M Constanza v.

Florida Marine Transporters, LLC

Final Order: September 24, 2025

_________________

Louisiana Court of Appeal, First Circuit

No. 2024-CA-0913

Calvin M. Constanza v.

Florida Marine Transporters, LLC

Final Opinion: April 17, 2025

Rehearing Denial: May 1, 2025

_________________

22nd Judicial District Court for the Parish of

St. Tammany State of Louisiana Division “A”

No. 2017-12934

Calvin M. Constanza v.

Florida Marine Transporters, LLC

Final Judgment: May 16, 2023

iv

TABLE OF CONTENTS

Page

QUESTION PRESENTED .......................................... i

PARTIES TO THE PROCEEDINGS ......................... ii

LIST OF PROCEEDINGS ......................................... iii

TABLE OF AUTHORITIES ...................................... vi

PETITION FOR A WRIT OF CERTIORARI ............. 1

OPINIONS BELOW ................................................... 1

JURISDICTION.......................................................... 2

STATUTORY PROVISION INVOLVED ................... 2

INTRODUCTION ....................................................... 4

STATEMENT OF THE CASE .................................... 7

REASONS FOR GRANTING THE PETITION ....... 12

I.

ENTRENCHED CIRCUIT SPLIT ........................... 12

II. CONFLICT WITH SUPREME COURT PRECEDENT .. 13

III. NATIONAL IMPORTANCE................................... 13

CONCLUSION.......................................................... 14

v

TABLE OF CONTENTS – Continued

Page

APPENDIX TABLE OF CONTENTS

OPINIONS AND ORDERS

Order Denying Petition for Writ of Certiorari,

Supreme Court of the Louisiana

(September 24, 2025).......................................... 1a

Order Denying Petition for Rehearing,

Louisiana Court of Appeal, First Circuit

(May 1, 2025) ...................................................... 2a

Opinion, Louisiana Court of Appeal, First Circuit

(April 17, 2025) ................................................... 3a

Edwards, J., concurring ................................... 25a

Judgment, 22nd Judicial District Court for the

Parish of St. Tammany State of Louisiana

(May 16, 2023) .................................................. 26a

Judgment, 22nd Judicial District Court for the

Parish of St. Tammany State of Louisiana

(January 9, 2023).............................................. 28a

REHEARING ORDER

Written Reasons for Judgment, 22nd Judicial

District Court for the Parish of St. Tammany

State of Louisiana (December 14, 2022) .......... 30a

vi

TABLE OF AUTHORITIES

Page

CASES

TABLE OF AUTHORITIES

Adkins v. Marathon Petroleum Co., LP,

105 F.4th 841 (6th Cir. 6/24/24) ........................ 12

Bommarito v. Penrod Drilling Corp.,

929 F.2d 186 (5th Cir.1991) ................................ 5

Chisholm v. Sabine Towing and Transp. Co.,

679 F.2d 60 (5th Cir. 1982) ........................... 6, 11

Clark v. Kellogg Brown & Root, LLC.,

414 Fed. Appx. 623 (5th Cir. 2011) ............... 6, 11

Daubert v. Merrell Dow Pharmaceuticals, Inc.,

509 U.S. 579, 113 S.Ct. 2786,

125 L.Ed.2d 469 (1993) ........................................ i

Douglas v. Chem Carriers Towing, LLC,

409 F.Supp.3d 570 (E.D. La. 2019) ..................... 6

Ferguson v. Moore–McCormack Lines, Inc.,

352 U.S. 521, 77 S.Ct. 459,

1 L.Ed.2d 515 (1957) ......................................... 10

Garrett v. Moore McCormack, Inc.,

317 U.S. 239, 63 S.Ct. 246,

87 L.Ed. 239 (1942) ............................................. 4

Gautreaux v. Scurlock Marine,

107 F.3d 331 (5th Cir. 1997) ......................... 4, 10

In re Deepwater Horizon BELO Cases,

No. 20-14544, 2022 WL 104243

(11th Cir. Jan. 11, 2022) ................................... 13

Joyce Wales & Jerry Wales, v. Mike Hooks,

Inc., Terry Shawback, and Venture

Transport, Inc., 2001 WL 34673094 (E.D.

La. 2001) .............................................................. 4

vii

TABLE OF AUTHORITIES – Continued

Page

Knight v. Kirby Inland Marine, Inc.,

482 F.3d 347 (5th Cir. 2007) ............................. 12

Mahnich v. Southern Steamship Co.,

321 U.S. 96, 88 L.Ed. 561,

64 S.Ct. 561 (1944) .............................................. 4

Martin v. John W. Stone Oil Distrib., Inc.,

819 F.2d 547 (5th Cir. 1987) ............................... 6

O’Neill v. Seariver Mar., Inc.,

246 F.App’x 278 (5th Cir. 2007) .......................... 6

Rogers v. Missouri Pac. R. Co.,

352 U.S. 500, 77 S.Ct. 443,

1 L.Ed.2d 493 (1957) ............................... 5, 10, 13

Sentilles v. Inter–Caribbean Shipping Corp.,

361 U.S. 107, 80 S.Ct. 173,

4 L.Ed.2d 142 (1959) ........................................... 5

Thibodeaux v. Ensco Offshore Co.,

300 F.Supp.3d 792 (W.D. La. 2017) .................... 6

Torrejon v. Mobil Oil Co.,

2003-1426 (La. App. 4 Cir. 6/2/04),

876 So.2d 877 writ denied, 2004-1660

(La. 9/24/04) ......................................................... 6

Whitlock v. Pepsi Americas,

527 Fed. Appx. 660 (9th Cir. 2013) ................... 12

Wills v. Amerada Hess Corp.,

379 F.3d 32 (2d Cir. 2004) ................................. 12

viii

TABLE OF AUTHORITIES – Continued

Page

STATUTES

28 U.S.C. § 1257(a) ..................................................... 2

46 U.S.C. § 30104 (The Jones Act) ...... i, 2, 3, 5, 10, 14

Federal Employers’ Liability Act (FELA) ................ 10

OTHER AUTHORITIES

Grant Gilmore and Charles L. Black, Jr.,

THE LAW OF ADMIRALTY (2nd ed. 1975) .............. 5

Martin J. Norris,

THE LAW OF SEAMEN, Vol. 2 (5th ed. 2003) ........... 5

1

PETITION FOR A WRIT OF CERTIORARI

Petitioner, Calvin M. Costanza requests this Court

to issue a writ of certiorari to reverse and remand the

decisions below. The opinion of the highest state court

to review the merits appears at App.2a to the petition

and is unpublished.

OPINIONS BELOW

1. 22nd Judicial District Court for the Parish of

St. Tammany, No. 2017-12934 “Calvin M. Costanza v.

Florida Marine Transporters, LLC” Judgment dated

January 9, 2023 (App.27a) dismissing Plaintiff’s claims

against Defendant, Florida Marine Transporters, LLC

and Judgment, denying Plaintiff’s Motion for a New

Trial rendered May 16, 2023.

2. Louisiana First Circuit Court of Appeal No.

2024-CA-0913 “Calvin M. Constanza v. Florida Marine

Transporters, LLC, Judgment dated April 17, 2025

(App.2a) affirming the judgment of the trial court

dismissing all of Calvin M. Constanza’s claims with

prejudice, as well as the judgment denying Plaintiff’s

motion for a new trial and judgment denying Plaintiff/Appellant’s application for rehearing rendered May

1, 2025.

3. Louisiana Supreme Court No. 2025-C-00649

“Calvin M Constanzav. Florida Marine Transporters,

LLC” writ application denied on September 24, 2025.

(App.1a).

2

These opinions were not designated for publication.

JURISDICTION

The date on which the Louisiana Supreme Court,

the highest state court, decided this case was September 24, 2025. (App.1a). Louisiana Supreme Court

rules to not allow for an application for rehearing on a

writ application. Therefore, all appeal avenues have

been pursued and a Petition for Writ of Certiorari is

the only remedy left to Petitioner.

The jurisdiction of this Court is invoked under 28

U.S.C. § 1257(a).

STATUTORY PROVISION INVOLVED

46 U.S.C.A. § 30104

(Formerly cited as 46 App. USCA § 688)

§ 30104. Personal injury to or death of seamen

(a)

In General.-A seaman injured in the course of

employment or, if the seaman dies from the

injury, the personal representative of the seaman may elect to bring a civil action at law,

with the right of trial by jury, against the

employer. Laws of the United States regulating

recovery for personal injury to, or death of, a

railway employee apply to an action under this

section.

3

(b)

Limitation on recovery by aquaculture workers.-

(1) In general.-For purposes of subsection (a),

the term “seaman” does not include an individual who(A) is an aquaculture worker if State

workers’ compensation is available to

such individual; and

(B) was, at the time of injury, engaged in

aquaculture in a place where such individual had lawful access.

(2) Aquaculture worker defined.-In this subsection, the term “aquaculture worker” means

an individual who(A) is employed by a commercial enterprise

that is involved in the controlled

cultivation and harvest of aquatic plants

and animals, including(i)

the cleaning, processing, or canning

of fish and fish products;

(ii) the cultivation and harvesting of

shellfish; and

(iii) the controlled growing and harvesting of other aquatic species;

(B) does not hold a license issued under

section 7101(c); and

(C) is not required to hold a merchant

mariner credential under part F of

subtitle II. (West)

4

INTRODUCTION

Historically, courts have regarded a life at sea as

difficult. A seaman’s life is rarely described as an

easy or comfortable one. In many cases, seamen perform arduous and hazardous labor, with abbreviated

crews, ten to twelve hours a day, seven days a week,

for three to four months at a time. Seaman are subjected to isolation, difficult duty, and a high rate of

accidents and injuries. Admiralty decisions have continued to acknowledge this hazardous vocation by

maintaining the legal concept that seamen are wards

of admiralty, See Garrett v. Moore McCormack, Inc.,

317 U.S. 239, 246, 63 S.Ct. 246, 251, 87 L.Ed. 239

(1942) and Joyce Wales & Jerry Wales, v. Mike Hooks,

Inc., Terry Shawback, and Venture Transport, Inc.,

2001 WL 34673094 (E.D. La. 2001) Therefore, admiralty

courts have long established a humanitarian approach

in favor of recovery.

The Jones Act imposes a duty on the employer of

a seaman to provide him with a safe place to work.

Mahnich v. Southern Steamship Co., 321 U.S. 96, 88

L.Ed. 561, 64 S.Ct. 561 (1944) A Jones Act seaman is

entitled to recover damages when his employer’s

negligence, in whole or in part, caused his injury.

Gautreaux v. Scurlock Marine,107 F.3d 331 (5th Cir.

1997). The legal standard regarding the level of

causation under the Jones Act is different than that

required for other torts and under the general maritime law, such as for unseaworthiness and products

liability claims.

5

“Under the Jones Act, a seaman is only required

to prove that the employer’s negligence was “a” cause

of his injury, regardless of how slight; whereas, under

the general maritime law, a seaman is required to

prove the traditional tort proximate cause standard. 2

Martin J. Norris, THE LAW OF SEAMEN § 30:40 (5th ed.

2003). This significant distinction was first articulated

in the seminal case Rogers v. Missouri Pac. R. Co., 352

U.S. 500, 77 S.Ct. 443, 1 L.Ed.2d 493 (1957). In Rogers,

the Supreme Court reasoned that the test is whether

the employer’s negligence played any part, “even the

slightest” in producing the injury or death for which

damages are claimed . . . The Rogers holding of negligent acts playing any part, no matter how slight, was

adopted as “the simple rule of physical causation” to

reduce the injured employee’s burden of establishing a

case under traditional proximate cause standards.

This burden of proving causation, as the Fifth Circuit

has characterized it, is “very light” or “featherweight.”

Bommarito v. Penrod Drilling Corp., 929 F.2d 186,

188 (5th Cir.1991).

This featherweight causation standard has been

analogized to a “special brand of res ipsa loquitur,”

which is a rule of permissible inferences from unexplained events. Grant Gilmore and Charles L. Black,

Jr., THE LAW OF ADMIRALTY § 6–36 (2nd ed. 1975). The

featherweight causation standard is equally applicable

when the medical expert evidence does not establish a

definite answer as to what caused the plaintiff’s injury.

Sentilles v. Inter–Caribbean Shipping Corp., 361 U.S.

107, 80 S.Ct. 173, 4 L.Ed.2d 142 (1959) (holding that

the jury may draw casual inferences based on varying

and inconclusive medical evidence and noting distinction between legal and medical causation).” See also

6

Torrejon v. Mobil Oil Co., 2003-1426 (La. App. 4 Cir.

6/2/04), 876 So.2d 877, 891-892, writ denied, 20041660 (La. 9/24/04), 882 So.2d 1125 where the court

held that under the Jones Act, a seaman is only required to prove that the employer’s negligence was “a”

cause of his injury, regardless of how slight.

. . . [A] seaman’s burden to prove causation between his employer’s negligence and

his injury is “very light.” O’Neill v. Seariver

Mar., Inc., 246 F. App’x 278, 280 (5th Cir.

2007) (quoting Martin v. John W. Stone Oil

Distrib., Inc., 819 F.2d 547, 548 (5th Cir.

1987)).

Douglas v. Chem Carriers Towing, LLC, 409 F.Supp.3d

570, 575 (E.D. La. 2019).

“[T]he standard is one of ‘producing cause’ rather

than ‘proximate cause’ and . . . the burden of proof is

‘featherweight.’ Thus, two concepts come into play

here-the type of causation that must be shown

(producing) and the plaintiff’s burden to show cause

(featherweight).” Clark v. Kellogg Brown & Root, LLC.,

414 Fed. Appx. 623, 626 (5th Cir. 2011), citing Chisholm v. Sabine Towing and Transp. Co., 679 F.2d 60, 62

(5th Cir. 1982).” Thibodeaux v. Ensco Offshore Co., 300

F.Supp.3d 792, 801 (W.D. La. 2017).

7

STATEMENT OF THE CASE

On June 27, 2017 Calvin M. Constanza filed a

Jones Act and General Maritime suit against Florida

Marine Transporters, LLC (hereinafter “FMT”). At all

times pertinent hereto, Constanza was employed by

FMT as a Jones Act seaman. While in the course and

scope of his employment with Florida he was exposed

to toxic and carcinogenic substances which caused

Constanza to contract Hodgkin Lymphoma.

On October 24, 2017 Constanza filed a First Supplemental and Amending Petition adding PBC Management, LLC as a Defendant, alleging it was also an

employer of Constanza On October 30, 2017 Constanza

filed his Second Supplemental and Amending Petition

adding Houston Casualty Company as the insurer of

FMT.

On April 19, 2019, Constanza filed Third Supplemental and Amending Petition adding the plea of ‘res

ipsa loquitor” On December 23, 2019, Constanza filed

his Fourth Supplemental and Amending Petition

adding as an additional claim for damages his fear of

contracting future cancer due to his exposure to hazardous materials and vapors during his employ with

FMT.

On August 21, 2021 Constanza filed his Fifth

Supplemental and Amending Petition adding a claim

for punitive damages against FMT due to the intentional or wanton and reckless disregarding for the

safety of Costanza by instructing its crewmembers,

tankermen and/or tankerman trainees not to wear

available personal protective equipment at all times

8

when there was a possible exposure to toxic chemicals

and vapors. On August 27, 2021 Constanza filed an Ex

Parte Motion to Withdraw his previously filed Fifth

Supplemental and Amending Petition and requested

it be stricken from the record.

A Judge trial was conducted on July 11, 2022

through July 14, 2022. Constanza’s Post-Trial Memorandum providing a detailed description of the pertinent testimony and applicable law was filed on September 28, 2022. Written reasons for judgment were filed

on December 14, 2022. A Judgment was filed on January 9, 2023. Constanza filed a Motion for a New Trial

with Rule to Show Cause and Memorandum on January 17, 2023. At the hearing on Constanza’s Motion

for a New Trial, the Judge denied the motion opining

that he could not make a connection in his mind that

Constanza’s cancer was caused by exposure when he

was working for FMT. The Court further opined that

his ruling encompassed Constanza’s fear of cancer.

The Court of Appeal affirmed the trial court’s

judgment and denied Constanza’s application for a

rehearing. The Louisiana Supreme Court denied

Constanza’s writ application.

Mr. Costanza worked for Florida Marine Transporters/PBC Management from February 2011 to

March 2012 as a Jones Act seaman on various barges.

He was a deckhand and then a tankerman. Benzene

was aboard the barges during the time Mr. Costanza

worked for Florida Marine Transporters.

Mr. Costanza was not adequately warned by

Florida Marine/PBC of the hazards associated with

benzene exposure, and Mr. Costanza was not provided

with protective equipment. Florida Marine Trans-

9

porters did not monitor the barges for benzene exposure

levels. Florida Marine Transporters did not enforce

rules regarding personal protective equipment, which

resulted in Calvin Costanza being repeatedly exposed

to benzene.

On or about January of 2015, Mr. Costanza was

diagnosed with Hodgkin’s lymphoma. Dr. Burke

Brooks, Calvin Costanza’s treating physician and Oncologist, testified that benzene can cause Hodgkin’s

lymphoma.

Based on the testimonies of Plaintiff’s experts,

Mike Harris, Ph.D., industrial hygienist, and Dr.

Patricia Williams, board certified toxicologist, benzene

exposure can cause Hodgkin’s lymphoma (general

causation) and that Calvin Costanza’s exposure to

benzene while working for Florida Marine caused his

Hodgkin’s lymphoma (specific causation). The testimony

of Dr. Williams, Dr. Brooks and Mr. Harris established

the “featherweight” standard of causation sufficient

for Mr. Constanza to recover damage for his exposure to

benzene.

The district court and the court of appeal improperly applied the “proximate” causation standard

instead of the “featherweight” causation standard to

Costanza’s Jones Act claim. Despite Costanza’s

arguments in favor of the “featherweight” standard,

the District Court made no mention of the

“featherweight” standard at any point in its opinion

despite it being an issue of first impression and its

application disputed by Defendant. Despite this testimony, the trial court disregarded this evidence finding

that the methodology employed by FMT’s expert, Dr.

Stock was superior and more convincing that that

employed by Mr. Constanza’s expert. Dr. Williams. This

10

is not the criteria to determine causation in a Jones

Act case. Even the slightest evidence that benzene

could have caused Mr. Constanza’s Hodgkin’s Lymphoma required the Court to find causation.

The standard of proof for causation in Jones Act

cases has been recited many times in this circuit’s

precedent. Our most definitive statement of the

law is found in Gautreaux v. Scurlock Marine,

107 F.3d 331 (5th Cir. 1997) where the en banc

court articulated the standard as follows:

A seaman is entitled to recovery under the

Jones Act . . . if his employer’s negligence is

the cause, in whole or in part, of his injury.

In their earlier articulations of [this standard

of] liability, courts had replaced the phrase

“in whole or in part” with the adjective

“slightest.” In Rogers v. Missouri Pacific R.

Co., 352 U.S. 500, 506 [77 S.Ct. 443, 1 L.Ed.2d

493] (1957), the Supreme Court used the

term “slightest” to describe the reduced standard of causation between the employer’s negligence and the employee’s injury in [Federal

Employers’ Liability Act (“FELA”)] cases. In

Ferguson v. Moore–McCormack Lines, Inc.,

352 U.S. 521, 523, 77 S.Ct. 459, 1 L.Ed.2d

515 (1957), the Court applied the same standard to a Jones Act case, writing, “‘Under

this statute the test of a jury case is simply

whether the proofs justify with reason the

conclusion that employer negligence played

any part, even the slightest, in producing the

injury or death for which damages are

sought.’” (quoting Rogers, 352 U.S. at 506, 77

S.Ct. [443]). 107 F.3d 331, 335 (5th Cir. 1997)

11

(en banc). We have explained that the standard is one of “producing cause” rather than

“proximate cause” and that the burden of

proof is “featherweight.” Chisholm v. Sabine

Towing & Transp. Co., 679 F.2d 60, 62 (5th

Cir. 1982). Thus, two concepts come into

play here—the type of causation that must

be shown (producing) and the plaintiff’s

burden to show that cause (featherweight).”

Clark v. Kellogg Brown & Root L.L.C., 414 F. App’x 623,

626 (5th Cir. 2011)

It is submitted that Mr. Constanza proved both

general and specific causation regarding his contracting

Hodgkin’s Lymphoma as a result of exposure to

benzene while employed by FMT. Therefore it was

error for the Trial Court and the Court of Appeal to

disregard the evidence presented by Plaintiff in light

of the featherweight burden in Jones Act cases to

prove causation.

12

REASONS FOR GRANTING THE PETITION

I.

Entrenched Circuit Split

The United States Fifth Circuit Court of Appeal

requires rigorous scientific proof of general and specific

causation, rejecting “any exposure”. In toxic tort cases,

the Fifth Circuit demands a two-step process in examining the admissibility of causation evidence with

admissible expert opinions for general and specific

causation. Knight v. Kirby Inland Marine, Inc., 482

F.3d 347 (5th Cir. 2007)

The United States Sixth Circuit Court of Appeal

applies the Jones Act’s “slightest cause” standard

broadly, allowing claims to proceed with less stringent

proof. Adkins v. Marathon Petroleum Co., LP, 105

F.4th 841 (6th Cir. 6/24/24)

The United States Second Circuit rejects contention that the standards for admissibility under

Daubert are relaxed in cases brought under the Jones

Act and demands strong expert testimony, rejecting

presumptions like the Pennsylvania Rule. Wills v.

Amerada Hess Corp., 379 F.3d 32, 38 (2d Cir. 2004)

The United States Ninth Circuit is more permissive, allowing expert testimony of toxic chemicals

without precise dose quantification. Whitlock v. Pepsi

Americas, 527 Fed. Appx. 660 (9th Cir. 2013)

The United States Eleventh Circuit has ruled

that in a toxic-tort case, a plaintiff must establish both

general and specific causation through admissible,

reliable expert testimony and requires proof of

threshold exposure levels. In re Deepwater Horizon

13

BELO Cases, No. 20-14544, 2022 WL 104243, at *2

(11th Cir. Jan. 11, 2022)

This split in the circuits leaves seamen subject to

different causation burdens depending on geography, undermining uniformity in maritime law.

II. CONFLICT WITH SUPREME COURT PRECEDENT

In Rogers v. Missouri Pacific R.R., 352 U.S. 500,

77 S.Ct. 443, 1 L.Ed.2d 493 (1957) the Court held that

under FELA (incorporated into the Jones Act), a

plaintiff need only show that negligence played “any

part, even the slightest”) The Fifth and Eleventh

Circuits’ heightened requirements effectively rewrite

the statutory standard, creating a barrier inconsistent

with Rogers.

III. NATIONAL IMPORTANCE

Thousands of seamen and maritime workers are

exposed to toxic substances (asbestos, benzene, crude

oil, dispersants) The split creates forum shopping and

inequitable outcomes: a claim viable in the Sixth

Circuit may be dismissed in the Fifth. Uniformity is

especially critical in maritime law, where Congress

intended consistent national standards.

14

CONCLUSION

The Court should grant certiorari to resolve the

entrenched split and clarify whether the Jones Act’s

relaxed causation standard applies fully in toxic tort

cases, or whether courts may impose heightened scientific causation requirements. Only this Court can

restore uniformity and ensure that seamen receive the

protections Congress intended.

Respectfully submitted,

John M. Robin

Counsel of Record

LAW OFFICES OF JOHN M. ROBIN

600 Covington Center

Covington, LA 70433

(985) 893-0370

johnmrobin@johnmrobinlaw.com

Counsel for Petitioner

December 17, 2025