CLASS ACTION FOR INJUNCTIVE AND DECLARATORY RELIEF

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF WASHINGTON DC

 

SAVE OUR KIDS COMMISION IN 

REPRESENTATION OF THE PARENTS                       Civil Action No._________

OF THE UNITED STATES                                        

Plaintiff,

v.

U.S. DEPARTMENT OF JUSTICE 

950 Pennsylvania Ave., N.W. 

Washington, D.C. 20530,

Defendant.

 

CLASS ACTION FOR INJUNCTIVE AND DECLARATORY RELIEF

 

  1. This is a class action under Class Action Fairness Act of 2005 (CAFA), against the U.S. Department of Justice for the Lack of accountability of the judicial system and judicial oversight; backing the corrupt judicial system in Honest Services Fraud; Conspiracy to Deprive Rights; False Light; Abuse of Process; Perjury; Intentional Infliction of Emotional Distress; Stalking; Harassment; Trespassing; violation of HIPPA standards; violation of 28 USC, 42 USC 1983 and William Wilberforce Trafficking Victims Protection Reauthorization Act; and violation of 18 USC 1506. 
  2. This case seeks declaratory relief that DOJ is in violation of its own mission to enforce the law and defend the interests of the United States according to the law; to ensure public safety against threats foreign and domestic; to provide federal leadership in preventing and controlling crime; to seek just punishment for those guilty of unlawful behavior; and to ensure fair and impartial administration of justice for all Americans. The Plaintiff also seeks a universal injunction against the DOJ for the Unconstitutional acts alleged herein.

 

JURISDICTION AND VENUE

  1. The Federal Court has Jurisdiction under 28 U.S.C. 1491 and Class Action Fairness Act of 2005 (CAFA) which  permits federal courts to preside over certain class actions in diversity jurisdiction where the class comprises at least 100 plaintiffs; and where there is at least “minimal diversity” between the parties. Moreover, the Class Action Fairness Act of 2005 (CAFA) confers jurisdiction on federal courts over certain class actions in which any defendant and any class member are citizens of different states. This Court has original jurisdiction over Plaintiffs under the First Amendment of the United States Constitution, which guarantees Plaintiffs their constitutional right of free speech. Such jurisdiction lies within 28 U.S.C. § 1331. This is a class action brought in diversity between the Class of Plaintiffs and Defendant UNITED STATES, wherein jurisdiction lies under 28 U.S.C. § 1332. 

 

PARTIES & CLASS ACTION ALLEGATIONS

  1. The Plaintiff brings this action on behalf of aggrieved Parents and citizens of the United States of America residing in different states of United States of America. 
  2. Plaintiff is informed and believes, and on that basis alleges, that this class of persons consists of approximately ten [10] persons.
  3. The claims set forth in this complaint are common to each member of the class at least regarding the subjection of the members’ children to the foster system where the children’s rights are denied under the color of law.
  4. Plaintiff is a proper representative of this class of persons because, as will be more fully shown below, plaintiff is a member of the class described in Paragraph 6 above. The claims that Plaintiff is asserting in this complaint are typical of the claims of all members of the class. The claims of plaintiff are not subject to any unique defenses nor does any interest of plaintiff in this litigation conflict with any other member of the class.
  5. The claims set out below are proper for certification as a class action under the provisions of Rules 23(b)(1)(A) or 23(b)(1)(B) or 23(b)(2) or 23(b)(3) of the Federal Rules of Civil Procedure.
  6. The questions of law and fact common to the class predominate over any questions affecting individual members because all members claim the subjection of their children to the foster system where the children’s rights are denied under the color of law
  7. The class action is superior to other available methods of adjudication because there are over five (5) members in the proposed class, and repeated individual litigation of the common issues shared by all class members would reduce the amount of recovery available to each member, particularly since establishing the liability of the Defendant and its conspirators will be relatively costly and time-consuming when compared to the amount of each, individual claim.
  8. The Defendant is the United States Department of Justice.

 

FACTUAL BACKGROUND

  1. Save Our Kids Commission, submits this Complaint on behalf of a class of parents experiencing traumatic events of their children forcefully taken away and being submitted to the sexually, mentally, and physically abusive foster system with the mutual plotting and planning of Family Court judicial system and Police officials dealing the investigations of the matter of children. 
  2. These departments, with the help of each other forcefully separate the children from their biological families and place them in the foster homes. It is from these shelter homes where the children are being trafficked and abused under the color and kind shelter of law that is apparently meant to protect these innocent souls and deprive them of their right to due process under the U.S. Constitution. 

 

Specific Allegations by the Parents 

  • Steven Bradley (First Complainant)
  1. The Complainant filed an affidavit stating that Rhonda L Christephore, an Arizona DCS investigator, showed up at the hospital with two armed police officers and a phoney court order and committed armed kidnapping of the newborn baby. She perjured herself on court documents, without any proof of the allegations.
  2. The Complainant contends that Abigail Johnson is part of the fraudulent case against her. Abigail is a co-conspirator in the kidnapping of her newborn under color of law. 
  3. The Complainant contends that Marsha Devorah Garrett-Mhuto, a case manager on the case from Arizona DCS, let the Complainant’s son be abused in foster home. Besides, Abigail tried to label the Complainant’s son autistic. Also, Marsha allowed the Complainant’s son to be shot with twelve (12) vaccines against the Complainant’s will.
  4. The Complainant further contends that Velora Louise Vincent, a case manager, was in charge of the kidnapping for the first (seven) 7 months. Velora also ignored the abuse and neglect the Complainant son suffered in foster care. Finally, Velora drafted fraudulent documents claiming the Complainant had no parenting skills.
  5. The Complainant contends that Kristin Rene Culbertson, a Judge assigned to her case, ignored actual evidence and rules to take and keep children. She approved the kidnapping after the fact. Further, the Judge ignored every document that Complainant has led on record and ignored proof of the abuse to Complainant’s son. Besides, she is tracking children under color of law. 
  6. The Complainant contends that Kathleen Erin Martoncik, the Assistant Attorney General, Prosecutor, and lawyer built a fraudulent case against the Complainant to keep and sell the Complainant’s newborn.
  7. The Complainant claims that Mathew Laura, Guardian ad litem claiming to speak for Complainant’s son, left the Complainant’s son speechless, leaving him in foster care and not letting him come home. Besides, the GAL Knows of the abuse and neglect but does nothing to protect the Complainant’s son.
  8. The Complainant claims that Analysa Cortez, a parent aide, completely lied on several occasions to help keep Complainant’s son detained.
  9. The Complainant contends that Jeremy Welsh, a foster parent, neglected and abused Complainant’s baby from the time the baby was taken to foster care. 
  10. The Complainant contends that Jessica Welsh, a foster parent, neglected and abusing Complainant’s son while getting paid to keep him safe.
  11. Finally, the Complainant contends that on or about May 2015, Theresa Mesa, a Social Worker, LADCFS, and LA Police Department Officers came to the Complainant’s home and removed the Complainant’s children without providing reasonable efforts to prevent removal which is against the Welfare Institutions Code. They also committed perjury at the detention hearing by saying the Complainant’s children were in “imminent danger.”
  12. The Parents in this class action collectively filing this Complaint against the United States Department of Justice for the Lack of accountability of the judicial system and judicial oversight and backing the corrupt judicial system in Honest Services Fraud, Conspiracy to Deprive Rights, False Light, Abuse of Process, Perjury, Intentional Infliction of Emotional Distress, Stalking, Harassment, Trespassing, violation of HIPPA standards, violation of 28 USC, 42 USC 1983 and William Wilberforce Trafficking Victims Protection Reauthorization Act, and violation of 18 USC 1506.
  13. The DOJ is in violation of its own mission to enforce the law and defend the interests of the United States according to the law; to ensure public safety against threats foreign and domestic; to provide federal leadership in preventing and controlling crime; to seek just punishment for those guilty of unlawful behavior; and to ensure fair and impartial administration of justice for all Americans.
  14. Parents have lost their confidence over the Department of Justice and its subordinate departments due to corruption, bribery and imminent threat of child abuse, trafficking and harm to their children. The Defendant’s subordinate departments including but not limited to the family courts, police departments, and foster care system obtain child custody orders and use them for child trafficking and child abuse by obtaining the said orders from the court through various frauds. The kickbacks, Perjury, bribery, corruption, and Non-Disclosure of relevant facts to the court by the perpetrators are common crimes in taking child from their parents through fraud. 

 

CAUSES OF ACTION

 

FIRST CAUSE OF ACTION

(Violation of Title 18, U.S.C., Section 249)

  1. The allegations set forth in paragraphs 1 through 27 are re-alleged and incorporated herein by reference.
  2. The Defendant, either individually or through conspirators willfully permitted the perpetration of bodily injury to the Parents’ children. 
  3. The Defendant and/or its conspirators planned to commit, or committed the crime, because of the actual or perceived race, color, religion, national origin of the children.
  4. The crime occurred within federal and territorial jurisdiction.
  5. As a result of Defendant’s actions and/or inactions, the Parents have lost their children. Besides, the fundamental rights of the children have been gravely infringed. 

 

SECOND CAUSE OF ACTION

Violation of Title 18, U.S.C., Section 241

  1. The allegations set forth in paragraphs 1 through 32 are re-alleged and incorporated herein by reference.
  2. The Defendant conspired with other individuals to allow the perpetration of the acts alleged herein. 
  3. Such conspiracy hampered the free enjoyment of fundamental rights and/or privileges secured to the parents and children by the Constitution or the laws of the United States.
  4. As a result of Defendant’s actions and/or inactions, the Parents have lost their children. Besides, the fundamental rights of the children have been gravely infringed. 

 

THIRD CAUSE OF ACTION

Violation of Title 18, U.S.C., Section 242

  1. The allegations set forth in paragraphs 1 through 36 are re-alleged and incorporated herein by reference.
  2. The Defendant, its agents, and conspirators, while acting under color of law, willfully deprived or caused to be deprived from the Parents and their children those rights, privileges, or immunities secured or protected by the Constitution and laws of the U.S.
  3. Notably, Defendant’s subordinate departments including but not limited to the family courts, police departments, and foster care system obtain child custody orders corruption and bribery, and use the orders for child trafficking and child abuse, imminent threat of child abuse, child trafficking and harm to the children.
  4. As a result of Defendant’s actions and/or inactions, the Parents have lost their children. Besides, the fundamental rights of the children have been gravely infringed. 

 

FOURTH CAUSE OF ACTION

Violation of Title 42, U.S.C., Section 14141

  1. The allegations set forth in paragraphs 1 through 40 are re-alleged and incorporated herein by reference.
  2. The Defendant, as a governmental authority, or agent thereof, engaged (either individually or through its conspirators) in a pattern or practice of conduct by officials or employees of any governmental agency with responsibility for the administration of juvenile justice or the incarceration of juveniles that deprived the children of rights, privileges, or immunities secured or protected by the Constitution or laws of the United States.
  3. Notably, the Defendant, individually or together with the conspirators, allowed the subjection of and/or subjected the children to child trafficking and child abuse, imminent threat of child abuse, child trafficking and harm to the children.
  4. As a result of Defendant’s actions and/or inactions, the Parents have lost their children. Besides, the fundamental rights of the children have been gravely infringed. 

 

FIFTH CAUSE OF ACTION

Violations of the False Claims Act

  1. The allegations set forth in paragraphs 1 through 44 are re-alleged and incorporated herein by reference.
  2. The Defendant and its conspirators knowingly supported or caused to be supported the culprits by not taking them to accountability which was the main responsibility of the defendant. In doing so, defendant has become the part of the crimes committed by its subordinates.
  4. The Defendant and its conspirators knowingly made, used, or caused to be made or used, a false record or statement to get a false or fraudulent claim paid or approved by the Government. 
  5. The United States, unaware of the falsity of these claims, records, and statements made by the Defendants, and in reliance on the accuracy thereof, paid money to Defendants for the fraudulent acts in the form of Salary. The United States and the general public have been damaged as a result of Defendant’s violations of the False Claims Act.

 

RELIEF SOUGHT

For the reasons set forth above, Parents, respectfully requests this court:

  1. Grants a universal injunction because of the Defendant’s facially unconstitutional acts.
  2. To Investigate the Defendants and its subordinates and bring them accountable for the above-said crimes and corruption against the law-abiding citizens to whom they had duty to care, as a result of its conduct under the False Claims Act. 
  3. Declares that the actions and/or inactions of the Defendant and its conspirators infringed on the rights of the parents and the children.
  4. Parents pray that Investigation to be initiated against the Defendant for all the crimes they have been and they are committing against the parents and children whom they had duty to care and protect their right., 
  5. Provide for expeditious proceedings in this action;
  6. Retain jurisdiction of this action to ensure no agency records are wrongfully withheld;
  7. Award the plaintiffs its costs and reasonable attorneys’ fees in this action; and
  8. Grant such other relief as the Court may deem just and proper.

 

Respectfully Submitted by,

 

Save Our Kids Commission.

CERTIFICATE OF SERVICE

I hereby certify that on [ENTER DATE], copies of the foregoing document have been sent to the Defendant in the following address:

 

    U.S. DEPARTMENT OF JUSTICE 

950 Pennsylvania Ave., N.W. 

Washington, D.C. 20530,

Defendant.

 

Save Our Kids Commission

At Legal writing experts, we would be happy to assist in preparing any legal document you need. We are international lawyers and attorneys with significant experience in legal drafting, Commercial-Corporate practice and consulting. In the last few years, we have successfully undertaken similar assignments for clients from different jurisdictions. If given this opportunity, we will be able to prepare the legal document within the shortest time possible.