FIRST AMENDED COMPLAINT

480. Plaintiffs hereby incorporate by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
481. Defendant county agents placed children in the most restrictive environment when the law says they should be in the least restrictive environment

482. Plaintiffs allege law enforcement misconduct by the Defendants who are mandated to enforce the laws enacted to protect children, families abuse victims and trafficking victims from abuse. The abusers have used their arbitrary positions to further inflict harm on the victims and to scare them into silence when they want to come out and seek help.
483. The reason for the law enforcement misconduct has been attributed by the Plaintiffs to be negligence from the side of the Defendants who did not practice due diligence when hiring the agencies’ personnel. They also did not take time to train these people, nor do they hold them accountable when complaints are brought against them.
484. The Supreme Court held in Monell v Department of Social Services that municipal entities are subject to § 1983 liability, but not on the basis of respondeat superior. This means that the officer in breach of his duties will be liable for his actions solely. The municipal will not be liable for hiring an employee who became a constitutional wrongdoer.
485. However, since the municipality in this case did not perform due diligence to hire competent people for these positions and has not taken seriously complaints made against these officials it will be held liable for harm caused to the victims, children and families.
486. Law enforcement misconduct opens the doorway for the violation of several human rights and freedoms secured under the Fourteenth Amendment Rights.
487. The Plaintiffs have alleged that the officers in the agencies have bullied them into silence when they try to report abuse. These officers have also failed to help victims of abuse to come out of their environment of abuse to safer places.

488. Excessive force is the unreasonable use of force in a particular situation.
489. The Plaintiffs have alleged the use of unreasonable force by the state officials and even the police in handling their cases. The Plaintiffs aver that there are times they have been forced into signing consent forms that determine their parenting plans or reunification plans. The force came in form of threats which left the Plaintiffs with no choice other than to consent. The motive of the State officials was to use the consent forms to fulfil their illegal monetary desires and breach the contract immediately after they receive what they want thus leaving the parents or families without redress.
490. The Plaintiffs also describe scenarios where the state officials and police arrive at their place of residence and forcefully carry away their children. They have also been forced into enduring unfair treatment from these officials for a long time as they have nowhere to report.
491. The force appl ied has led to serious injuries to the children and their parents which is a violation of their 4th Amendment Rights and 8^th Amendment Rights and consequently their 14^th Amendment rights. The fourth amendment rights provide that each person is free from unreasonable searches and seizures. The Due Process Clause under the 14^th Amendment right protects pretrial detainees from excessive force that amounts to punishment. The Eight amendment rights secure citizens’ freedom from cruel and unusual punishment.
492. State officials are subject to § 1983 lawsuits when they use unreasonable force to handle people. In determining whether the rights under the Fourth Amendment apply the court will look into the reasonableness of the force applied.
493. Plaintiffs have alleged that the police officers sometimes came armed to collect the children from their homes. There has also been physical force used on parents to make them sign consent documents. Children have also undergone some form of force, for instance, threats, to stop them from reporting abuse. This is an unreasonable force that violated their Fourth Amendment Rights.
494. In Graham v Connor, the Supreme Court looked into the objective reasonableness applied by law enforcement officers. The Supreme Court held that all claims that law enforcement officers have used excessive force-deadly or not-in the course of an arrest, investigatory stop, or other ‘seizure’ of a free citizen should be analyzed under the Fourth Amendment and its ‘reasonableness’ standard, rather than under a ‘substantive due process’ approach. Therefore, State officials are subject to § 1983 lawsuits and are liable for breach of the Fourth Amendment rights when they use excessive force when enforcing an order or when they want to coerce a person to do something.

495. The Plaintiffs aver that they have been threatened with imprisonment for refusing to hand over their children to strangers. Children have also been placed in the most restrictive environments when taken away from their parents and their homes.
496. False imprisonment is used interchangeably with unlawful imprisonment and happens when a person intentionally restricts the movement of another without legal authority, legal justification or the consent of the person being detained.
497. The Plaintiffs have had endure the harsh treatments and conditions when their children have been detained by the State officials without warrants or court orders. It is not in the best interest of a child to keep them separate from their parents. It certainly is cruel to take a newborn child from their mother and detain them for prolonged periods of time without justified cause.
498. The Plaintiffs (Parents) have themselves been detained for questioning, to be threatened, for investigation, examining or search without proper warrants or court orders.
499. These amount to a violation of the Eight Amendment Rights which provide the right to be free from cruel and unusual punishment. Falsely imprisoning parents and their children or threatening to do so amounts to cruel and unusual punishment. It is also a violation of their Fourth Amendment Rights which protect them from unlawful and unreasonable search and seizure. As a result, their Fourteenth Amendment Rights have been violated from the detention and continued withholding of the Plaintiffs children without just cause or authority.
500. The § 1983 claim on false imprisonment applies where the State officials are acting contrary to the law by forcing the parents to perform a certain act or face imprisonment.

501. Under Section 1983 malicious abuse of process comes about where prosecution is initiated legitimately and is thereafter used for other purposes other than that which was intended by the law. This is where the prosecution law is used to extortionate demand or cause the surrender of a legal right.
502. The Plaintiffs have averred that the Defendants have on several occasions threatened them into consenting different processes which cause them and their children harm. The laws enacted to protect children, families and abuse victims including trafficking victims from harm have been used to inflict harm by the defendants. This is in cases where the Defendants have taken away the Plaintiffs’ children without justified cause and detained the children away from their parents. They have also arrested the Plaintiffs and conducted searches on them without warrants or court orders.
503. The Plaintiffs have endured situations where they have been forced into silence when they want to come out to report abuse by the State officials. The laws that were enacted to protect abuse victims and take them out of abusive environments are not implemented in situations where they are required as the Defendants have employed incompetent personnel who are conducting the abuse.
504. These officials are liable under Section 1983 and should be held accountable for their actions. However, the people in charge of hiring them and receiving these complaints do not take on due process to investigate these claims. This is what has led to the bullying of the defendants into silence.

505. The Restatement (Second) of Torts § 46 provides that: “(1) One who by extreme and outrageous conduct intentionally or recklessly causes severe emotional distress to another is subject to liability for such emotional distress, and if bodily harm to the other results from it, such bodily harm.”
506. Intentional infliction of emotional distress has four elements: outrageous conduct by defendant; the intention of causing, or reckless disregard of the probability of causing, emotional distress; actual suffering of severe or extreme emotional distress; and actual and proximate causation of the emotional distress by the defendant’s outrageous conduct.
507. Throughout this Complaint, Plaintiffs have demonstrated the outrageous manner in which their child(ren) were taken away from them without due process or regard for the law. The bond between a parent and a child runs deep through their hearts and minds and should not be broken without any substantial reason. Defendant took away Plaintiffs’ child(ren) without regard for the consequences of their actions upon Plaintiffs and their child(ren). Defendant knew what its actions were doing to Plaintiffs and their child(ren) but still continued to deprive Plaintiffs of their parental rights.
508. Defendant’s actions have caused untold mental anguish and emotional distress upon Plaintiffs and their child(ren). Plaintiffs have sunk into depression and anxiety due to the uncertainty of what is happening to their child(ren) after they have been taken away from them. Some Plaintiffs have no knowledge of the whereabouts of their children. Plaintiffs have had to seek professional help from therapists to help them deal with the suffering that Defendant has put them through. Since it is impossible to reverse their emotional distress and restore them to the mental state they were in before the actions of Defendant, Plaintiffs seek compensation.

509. The Plaintiffs have accused foster parents or even people they lived with (for instance a parent’s boyfriend) of sexually abusing their children. These children have been abused either once or repeatedly. The violation has been reported to relevant authorities, that is the state officials responsible for ensuring the care and protection of children. Surprisingly, there has been little to no follow-up on these claims.
510. It is these state officials that are placing children with sexual predators and are not responding to reports of sexual abuse to take the children out of these environments.
511. The law of protection of children, families and victims of abuse was formulated to mandate the officials to take victims of abuse out of the abusive environment. These officials are also mandated under the law to investigate cases of abuse and charge the offenders for their actions.
512. Not investigating the reports and allowing the children to remain in these homes where the sexual abuse continues is a violation of their human rights under the Fourteenth Amendment Rights. This undermines the dignity of the children and their right to protection from cruel and unusual treatment under their Eighth Amendment Rights
513. Under Section 1983 liability the State officials are liable for placing the children in harmful environments where they are sexually abused and do nothing to protect the children when the matter is reported. The foster parents will also carry liability under this section as they are mandated by the law to protect the children and not inflict harm on them.

514. To hold a State official liable for wrongful death under Section 1983 it should be proved that the Defendant’s actions caused the death of the victim.
515. In our case, the Plaintiffs have claimed being pushed into depression which has caused them to consider suicide. This is from both the parents and the children.
516. The Parents may sink into depression when their children are unlawfully taken away from them and they are restricted from seeing them. No Parent would be okay if they cannot be with their children and they are unjustly kept away from them.
517. Children also sink into depression when they are placed in harmful or hostile environments away from the love and care of their parents. They are forced to live in undignified conditions and they consider suicide as a means of stopping the pain.
518. Some of these children may die from being exposed to these harmful and toxic living environments. The injuries inflicted on the Parents when they are being threatened to agree to a particular situation can also be life-threatening and cost them their lives.
519. Death caused by these situations should be blamed on the Defendants who were aware of the suffering but did nothing to mitigate the situation. Laws have been enacted to take victims out of these situations. If the State officials do not apply these laws for the protection of the children, they should be held accountable for any death that occurs.

520. In Albright v Oliver it was determined by the court that for a claim of malicious prosecution succeed under Section 1983 it should be proved that there was (a) institution of a criminal prosecution; (b) without cause; (c) with malice; and (d) termination is in favor of the accused.
521. The Plaintiffs have accused the Defendants of arresting and detaining them without warrants or valid court order. This has been done to arbitrarily insert the power of the Defendants into coercing the Plaintiffs to follow their instructions.
522. The Defendants have also falsely accused the Plaintiffs of misconduct which under the law amounts to them being declared unfit to keep their children. They have also threatened the Plaintiffs into agreeing to different situation plans which do not favor the Plaintiffs all for the Defendants’ gain. For example, forcing the Plaintiffs to release their children to strangers. This is done to enrich the State officials who will benefit from more children being placed in foster care.
523. The Defendants have gone to extremes of working with court officials to formulate false charges of which the Plaintiffs are charged and the court orders that their children be taken from their homes.
524. There is little to no investigation conducted to ascertain these claims which leaves the Plaintiffs in a prejudiced situation where their innocence is not proved. The Defendants do not obtain warrants or court orders when arresting the Plaintiffs to prosecute them and if they do they acquire them through false pretense or by lying about the conduct of the Plaintiffs.
525. These actions are sufficient to prove that any prosecution that occurs is conducted maliciously to inflict harm on the Plaintiffs. As the direct and proximate result of the Defendants’ actions, Plaintiffs have suffered, and will continue to suffer, physical, mental, and emotional injury, all to an extent and in an amount subject to proof at trial. Plaintiffs have also incurred, and will continue to incur, attorneys’ fees, costs and expenses, including those authorized by 42 U.S.C. § 1988, to an extent and in an amount subject to proof at trial.

526. Plaintiffs hereby incorporate by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
527. The United States Court of Appeals for the Sixth Circuit has set forth five elements of fraud upon the court which consist of conduct: “1. On the part of an officer of the court; 2. That is directed to the ‘judicial machinery’ itself; 3. That is intentionally false, willfully blind to the truth, or is in reckless disregard for the truth; 4. That is a positive averment or is concealment when one is under a duty to disclose; 5. That deceives the court.” Demjanjuk v. Petrovsky, 10 F.3d 338, 348 (6th Cir. 1993).
528. The doctrine of fraud upon the court has been characterized “as a scheme to interfere with the judicial machinery performing the task of impartial adjudication, as by preventing the opposing party from fairly presenting his case or defense.” In re Coordinated Pretrial Proceedings in Antibiotic Antitrust Actions, 538 F.2d 180, 195(8th Cir. 1976) (citations omitted); see also Rozier v. Ford Motor Co., 573 F.2d 1332, 1338 (5th Cir. 1978) (holding “only the most egregious misconduct, such as bribery of a judge or members of a jury, or the fabrication of evidence by a party in which an attorney is implicated, will constitute a fraud on the court”). Additionally, fraud upon the court differs from fraud on an adverse party in that it “is limited to fraud which seriously affects the integrity of the normal process of adjudication.” Gleason v. Jandrucko, 860 F.2d 556, 559 (2d Cir. 1998).
529. “One species of fraud upon the court occurs when an ‘officer of the court’ perpetrates fraud affecting the ability of the court or jury to impartially judge a case.” Pumphrey v. Thompson Tool Co., 62 F.3d 1128, 1130 (9th Cir. 1995); see also Weese v. Schukman, 98 F.3d 542, 553 (10th Cir. 1996) (noting that “fraud on the court should embrace only that species of fraud which does or attempts to, subvert the integrity of the court itself, or is a fraud perpetrated by officers of the court” (citation omitted); Kerwit Med. Prods., Inc. v. N. & Instruments, Inc., 616 F.2d 833, 837 (11th Cir. 1980) (same).
530. In addition to the other State Defendants, the Federal Defendants are liable for this cause of action based on the following reasons. First, the US Government has several duties as documented in the US Constitution. The people of the US, through the Government, seek to form a more perfect union by establishing justice, ensuring domestic tranquility, providing for the common defense, promoting the general welfare, and securing the blessings of liberty to citizens and their posterity. The government is therefore mandated to exercise its authority directly by regulating, legislating, and issuing executive orders and court orders. It also grants authority to, and rescinds it from, government agencies and state and local governments.
531. Next, Joe Biden, as the President of the United States, is responsible for the execution and enforcement of the laws created by Congress. The President is both the head of state and head of government of the United States of America, and Commander-in-Chief of the armed forces. The primary duty of the president of the United States is to make sure that all U.S. laws are carried out and that the federal government runs effectively. He also directly oversees all agencies of the executive branch of government.
532. Kamala Harris is the Vice President of the United States. The office of the vice president is an integral part of the president’s administration. She is the president of the U.S. Senate, successor to the President, president’s advisor, congressional liaison, and representative of the president.
533. The Department of Health and Human Services is the United States government’s principal agency for protecting the health of all Americans and providing essential human services, especially for those who are least able to help themselves. The mission of the U.S. Department of Health and Human Services (HHS) is to enhance the health and well-being of all Americans, by providing for effective health and human services and by fostering sound, sustained advances in the sciences underlying medicine, public health, and social services.
534. The duties of Xavier Becerra, as the Secretary of the USDHHS, revolve around human conditions and concerns in the United States. This includes advising the president on matters of health, welfare, and income security programs. He is obligated to administer the Department of Health and Human Services to carry out approved programs and make the public aware of the objectives of the department.
535. The Department of Justice is mandated to enforce the law and defend the interests of the United States according to the law. The Department is also mandated to ensure public safety against threats both foreign and domestic. It also provides federal leadership in preventing and controlling crime, and seeking just punishment for those guilty of unlawful behavior. Lastly, it ensures fair and impartial administration of justice for all Americans.
536. XXXX, as the Attorney General, is the nation’s chief law enforcement officer. He leads the Justice Department. Under his leadership, the Department of Justice is dedicated to upholding the rule of law, keeping America safe, and protecting the civil rights of all Americans.
537. The foregoing work and/or role descriptions of the Federal Defendants give them supervisory roles over all agencies and authorities from the federal government, state governments, and county authorities. They should be forefront in championing the rights of the US Citizens,. Notably, they should formulate policies on protection of citizens’ rights in administrative duties of all government organs, and should device mechanisms to enforce the policies.
538. In the cases of all Plaintiffs, officers of the court made statements that were intentionally false in court with the intention of deceiving the courts and making them unable to make impartial decisions in regard to termination of parental rights of Plaintiffs. Court documents were fabricated to purposely mislead the courts to enter declarations and judgments that terminated Plaintiffs’ parental rights and took legal custody away from them.
539. The parents and child had a clearly established liberty interest in associating together. This right was violated where the defendants allegedly had no indication of any physical neglect of the child, no indication of any immediate threat to his welfare, and no indication of any criminal activity by his mother, where they only had third-hand hearsay where defendants refused to return the child, had not investigated to determine whether it was necessary to remove the child in the first place, and had not investigated the possibility of returning the child to his mother, grandmother, or anyone designated by the mother .Whisman V. Rinehart ( 8th Cir. 1997)
540. Child protection workers are subject to the 4th and 14th Amendment in the context of an investigation of alleged abuse or neglect are all government officials. The court ruled despite the defendants (Child protection Worker) exaggerated view of their powers ,the fourth Amendment applies to them, as it does to all other officers and agents of the state whose request to enter ,however begin or well-intentioned, are met by a closed door.
541. The fourth Amendment’s prohibition on unreasonable searches and seizures applies whenever an investigator, be it a police officer a DCFS employee, or any other agent of the state, responds to an alleged instance of child abuse, neglect, or dependancy.3:01-cv-7588 Walsh v. Erie County Department of Job and family Services.
542. A due process violation occurs when a state -required breakup of a natural Family is founded solely on a best interest analysis that is not supported by the requisite proof of parental unfitness. Quilloin v. walcott (1978) 434 U.S. 246,25541.
543. Plaintiff in Brokaw,305 F.3d 660 (8^th2002), brought suit against defendants in the child neglect office based on a conspiracy to take away her children. The seventh circuit held that Rooker-Feldman did not bar her claims significantly, and similarly to the case at bar, Brokaw alleged that “The defendants conspired -prior to any judicial involvement -to cause false child neglect proceedings to be filed .” Id. at 665.
544. The seventh Circuit specifically held that the plaintiff’ is not merely claiming that the decision of the state court was incorrect or that the decision violated her constitutional right; rather, she is alleging that the people involved in the decision to forcefully remove her from her home and her parents and subject her to the custody of {child Services) violated her constitutional rights, independently of the state court decision.
545. Up to 83% of all investigations are ultimately concluded to have involved no abuse or neglect. ONLY INNOCENT FAMILIES! We believe that parents have the fundamental right to the care, custody and control of their children so long as the child is not harmed.
546. Fraud Upon the Court
547. One of the most frequent ways Defendants obtain adverse judgements against parents is by committing fraud upon the court and intentionally offering “(a) misrepresentations (false representation, concealment, or nondisclosure); in their statements to the court.
548. Social workers are quasi court officials. Prosecutors, judges, children’s attorney and parents attorneys are all officers of the court. In Bulloch v. United States, 763 F.2d 1115, 1121 (10th Cir. 1985), the court stated “Fraud upon the court is fraud which is directed to the judicial machinery itself and is not fraud between the parties or fraudulent documents, false statements or perjury …. It is where the court or a member is corrupted or influenced or influence is attempted or where the judge has not performed his judicial function — thus where the impartial functions of the court have been directly corrupted.”
549. Appeals court have previously recognized a constitutional right under the Due Process Clause of the Fourteenth Amendment to be free from judicial deception and fabrication of evidence in the context of civil child custody cases. See Costanich v. Dep’t of Soc. and Health Servs., 627 F .3d 1101, 1108 (9th Cir. 2010) (“[D]eliberately fabricating evidence in civil child abuse proceedings violates the Due Process clause of the Fourteenth Amendment when a liberty or property interest is at stake “); Wallis v. Spencer, 202 F .3d 1126, 1142 (9thCir. 2000) (stating “parents have a right arising from the liberty interest in family association to be with their children while they are receiving medical attention” and “children have a corresponding right to the love, comfort, and reassurance of their parents while they are undergoing medical procedures”).
550. “To support a § 1983 claim of judicial deception, a plaintiff must show that the defendant deliberately or recklessly made false statements or omissions that were material to the finding ” KRL v. Moore, 384 F .3d 1105, 1117 (9th Cir. 2004)
551. A plaintiff who provides direct evidence of false statements can allege deliberate fabrication of evidence in violation of constitutional due process guarantees. See Costanich, 627 F.3d at 1108. “Reporting that a witness said something he or she did not cannot reasonably be characterized as a recording error or a misstatement,” but is instead fabricated evidence. Reynolds v. County of San Diego, 224 F. Supp. 3d 1034, 1055 (S.D. Cal. 2016) rev’d in part on other grounds sub nom. Reynolds v. Bryson, 716 F. App’x 668 (9th Cir. 2018) (citation omitted).
552. Furthermore, in the search warrant context, we have previously held that an omission of a fact necessary to establish probable cause presented a triable issue of material facts about whether that omission “amounted to at least reckless disregard for the truth.” Bravo v. City of Santa Maria, 665 F.3d 1076, 1088 (9th Cir. 2011). Examples of judicial deception in child protective custody cases are illuminating. In Reynolds, a district court held that omission of two words from medical notes was “[a]t worst . a reporting error or misstatement” and not sufficient evidence of deliberately or recklessly false statements or material. 224 F. Supp. 3d at 1056 (citation omitted). By contrast, in Costanich, we held that allegations that a social worker falsely claimed to have interviewed several witnesses in connection with a child protective custody case presented a triable issue of material fact that there was deliberate fabrication of evidence. 627 F.3d at 1112-14. In Greene v. Camreta, 588 F.3d 1011 (9th Cir. 2009), vacated in part, 563 U.S. 692 (2011), 661 F.3d 1201 (9th Cir. 2011), we held that “proof, in the form of [an] affidavit and deposition testimony, that [defendant] included false statements in his affidavit requesting a protective custody order,” id. at 1035, was sufficient to present a genuine issue of material fact of judicial deception to which qualified immunity did not apply and summary judgment was inappropriate, see id. at 1035-36.
553. The Plaintiffs have alleged judicial deception sufficient to meet the constitutional standard, if not the heightened pleading standard of Rule 9(b), to overcome the County’s motion to dismiss under Rule 12(b)(6). Finally, the alleged misrepresentation was material to granting of the juvenile court’s Orders.

554. Never do attorneys appointed by dependency courts reveal they speak to opposing counsel without informing client/plaintiffs; receive documents served on the parent’s behalf. Court officials have a practice of holding secretive hearings without knowledge of parents and having exparte hearings where they make arguments when the parents are not there to defend themselves.
555. In every case before your Honorable, these court appointed attorneys do not say objections as asked to do so. They defraud parents and children by pretending to be their advocate while working against them as much as possible.
556. Court appointed attorneys do not submit evidence on the plaintiffs’ behalf when asked to do so to help defraud the court and the client. 209. They regular ignore constitutional liberties to the extent of stating through their action and inaction that, “the constitution does not apply here” and “there is no time to argue the constitution”.
557. The written, stated, sworn, and understood definition of “representation” is nothing of this sort and is stated in the DOG BOOK Dependency handbook for attorneys, stating their role is to “make the process smoother” for opposing party; attorneys are not there to “represent” the parents but mitigate resistance. A fact which is never disclosed to distraught parents.
558. Court appointed attorneys do not contact or communicate with parents until 10 minutes before the 1st hearing. This violates the service of paperwork rules of court.
559. Similarly prosecutors are not working in the interest of justice but in the interest of the department and securing more wins and funds for the county agency they work for.
560. These attorneys are forced to follow department lead, which is unstated and unwritten, again at the department’s will, and have court watchers to make sure of this as training states from the Capacity Building in DC. In other words, if an attorney attempts to properly represent, the department can and will remove them.
561. Reunification services are provided to give kickbacks to preferred providers who go along with the department agenda. They are not provided in good faith as a protective measure to ensure safe homes.

562. Parents are indentured servants and are subject to peonage and involuntary servitude as they are human chattel forced to attend endless services that only benefit the provider’s bottom line.
563. Lives are disrupted and jobs are lost as Plaintiffs cannot hold regular jobs because they must contract with service providers of the departments choice that are inconvenient locations, do not offer the services parent needs, or have working hours that conflict with the work schedule of the Plaintiffs.
564. If Plaintiffs do not go to these services, they are threatened that their children will never come home. No consideration is made for parents who have made changes on their own without services.
565. Children are seized without warrants and return of them becomes the discretion of a social worker and not the imposed service completion.
566. Servitude is required for release of children. Social services forces housing and drug services for parents never convicted of drug offenses. The time and duration of services is capricious and ambiguous.

567. Even when parents complete the programs the DEFENDANTS will not provide the record to the court or claim the program was not effective as a way of intentionally misleading the court.
568. Courts tell the parents the wrong time to come to court. The deliberately tell them that their time is early in the morning but they do not call the parents’ court case until last as a way to lie to the parent.

569. Parent Plaintiffs are told by officers of the court that Juvenile Dependency is quasi-criminal or even civil in nature. Neither is fact, Juvenile dependency falls under administrative law, which is regulated by the APA and case law such as “Chevron”, which explains the deference given to agencies. A parent, when pro se or for mere understanding purposes cannot make sense of what is happening to them in court because the laws they seek for reference that has been spoken as superseding the venue is Civil or Quasi-criminal. Attorneys and the Courts do not disclose this as fact, tend to “pick and pull” statutes as they chose to benefit the agency, and ignore the law of the land we as Americans know, defend and have sacrificed all to retain.
570. Parents believe, and rightfully so, they will never see their children again if they do not comply with agency demands despite and in spite of innocence.
571. A court appointed attorney in dependency hearings tried to induce parents to rely on their sham services instead of going with the gut instinct and acting in their best interest.
572. These attorneys have a conflict of interest because they are paid by the county and do not benefit if the client wins or if trial/interactions are of short duration.
573. Keeping the peace with their peers in the Juvenile Court room rather than representing and presenting parents are of the most importance to them. This is made clear when all entities within the venue enjoy holiday parties and exchange gifts and even enjoy lunch breaks together. The “appearance” of impropriety exists, the fraud of the action commences soon after.
574. The fact is that all proceedings in juvenile dependency have pre-printed and predurational time frames. This in itself shows a factory-like process not an individualized service for families as clearly stated in the Family First Act and all legislative intent acts established by congress.
575. Children are seized without exigency in nearly every case before Your Honorable, and finding of unfitness in court has not been established prior to removal as Judicial Findings have established time again.
576. After which the return of children becomes contingent upon a service that is only rendered if admission of guilt is made. This is the parallel definition of extortion, to release bondage of kidnapping, child being held until services rendered by parent. Yet even at the end of a completion to demanded services, for the child to return, the agency retains discretion to actually return child to parent. The calculation to determine this then becomes the time already stolen and “best interest” with interest in monetary accumulation county prospectively can claim from child needs if kept in system.

577. Child Welfare, once contacted by them, causes a do or die situation for families. Plaintiff Parents who are told to do services or “reunification” which do not eventually reunite parents with their children as followed. Instead, they are forced into an open-ended contract made under duress which the social worker can use to manipulate the parent who initially believes they are operating in good faith.
578. As the direct and proximate result of the Defendants’ actions, Plaintiffs have suffered, and will continue to suffer, physical, mental, and emotional injury, all to an extent and in an amount subject to proof at trial. Plaintiffs have also incurred, and will continue to incur, attorneys’ fees, costs and expenses, including those authorized by 42 U.S.C. § 1988, to an extent and in an amount subject to proof at trial.

579. Plaintiffs hereby incorporate by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.

580. Parents’ attorneys conspired with the other defendants to not present an adequate defense for the parents. They threaten parents into taking plea deals by telling them they will never see their children against.

581. Defendant Government Agents owe a duty of care to their citizens. They must care because they took an oath to uphold the constitution and protect the citizens. They owe Plaintiffs a duty of loyalty and to diligently try to solve the problem within their powers and abilities. They have a lot of power and resources to address the issue and prevent it from happening.
582. Social workers also have a special relationship with Plaintiffs and are supposed to act in a way as to not harm the parents or act as enemy number one. They have a plethora of resources at their disposal to help families that they underutilize.
583. Truly helpful resources are sidelines while the most harmful and restrictive treatments they can think of are utilized.
584. They do not listen to clients or attempt to gather relevant facts as required by their job description (Exhibit Social Worker Job Ad). They do not understand cultural differences or help families. They create their own narrative that usually casts parents and children in their worst possible light and continue to deliberately antagonize them even as they can see they are experiencing emotional turmoil.

585. It is well-establish public policy that, social workers have an affirmative duty to work for the client’s best interest and welfare as consented to by the client.

586. Agents are often not trained on legal aspects of the job and don’t acquire adequate and appropriate trainings and discussions on how to protect the rights of clients.

587. Supervisors in higher positions like the DEFENDANTS are supposed to know the law and convey this knowledge to their subordinates. DEFENDANTS have recklessly disregarded having these training with agencies that they fund. When the agencies harm people with their conduct it is the fault and cause of the failure of the Defendants to train.
588. As in the police brutality cases, you must train officers on the consequences and ramifications of deadly force. They should know when it is necessary and when it is legal. Giving police a dangerous weapon and not telling them this disclosure is a failure to train which puts the public in danger.
589. In the same way, giving money and power to agencies to remove children from home and subject children and adults to endless rounds of therapy; but not training them on Constitutional rights, Federal Law, and State Law is like giving a loaded gun to these agencies to shoot and kill their citizens legally.

590. Social workers request excessive continuances that they not are against the law and harm children emotionally, but they show no sympathy.
591. Parents attorneys do not speak up against excessive continuances when the children should no longer be detained, and judges grant the orders. Yes, these is no disciplinary action taken if they do these things. Various boards and agencies pass the buck and assume no responsibility for ensuring due process of law. (Exhibits Letter to Greg Abbot, Letter to Consumer Affairs)
592. These individuals who hold positions of public trust attempt to separate children and families for as long as possible and then say that they children have a bond with the new caregivers. Again, they caused the situation and were deliberately trying to sever the familial bond which is a breach of fiduciary and social worker malfeasance.
593. Agencies do not reprimand social workers when they authorize medical treatments on children without the consent or notice of parents. Social workers have in these cases described practiced medicine and attempted diagnose parents with mental disorders and suggest they should be taking prescribed medication, even when medical professionals have said the contrary.

594. Even if providing services free of charge to parents, attorneys are still being compensated by the state. The law states that even when services are free agents must still behave with diligence, loyalty, and in the overall interest of the client.
595. Attorneys here give wrong and bad advice to parents like telling them to wait until the end to present evidence or appeal. Many times, parents lose appeals opportunities because of the wrong advice given by their attorney who is self-dealing and getting kickbacks from letting the case mature.
596. When Counties do not provide adequate notice to Plaintiffs about the nature of the hearings so Plaintiffs could be prepared for the hearing, and it be a meaningful hearing, attorneys encourage clients to disregard the prejudice and just let it happen.
597. Domestic violence victims have nowhere to turn because the social worker, police, attorneys, and judges are all corrupt.
598. As the direct and proximate result of the Defendants’ actions, Plaintiffs have suffered, and will continue to suffer, physical, mental, and emotional injury, all to an extent and in an amount subject to proof at trial. Plaintiffs have also incurred, and will continue to incur, attorneys’ fees, costs and expenses, including those authorized by 42 U.S.C. § 1988, to an extent and in an amount subject to proof at trial.

599. Plaintiffs hereby incorporate by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
600. Defendants breach their affirmative Duty to Protect when they cause harm to clients and show a deliberate disregard for their safety, consent, or wishes. Social workers who do the right thing are often quit, while the black hearted workers get promotions (See Exhibit 13)

601. Reunifications plans, also called service plans, are supposed to benefit the recipient but the only people who benefit are the providers. The Defendants made money from constantly referring the parent or child to another agency, who also makes money.

602. The contracts are unconscionable because parents cannot decline to participate and find their own provider or solve the problem themselves. The Defendants forced Plaintiffs to contract with theses ‘ministries’ or ‘agencies’ because if they do not cooperate, they will never see their children again. As described in the affidavits, parents and children are made to repeatedly receive services regardless of necessity or effectiveness, at the whim and arbitrariness of a social worker who has all the bargaining power. The government has delegated them this authority.

603. The agencies and service providers have more bargaining power and thus the contracts are void because they amount to involuntary servitude and a constitutional violation of all men and women being created equal and being able to make decisions for themselves.
604. Contract of Adhesion – the terms of the contract cannot be bargained for and one must accept all the terms and conditions.
605. Anticipatory Repudiation – even after completing the terms of the plan, social workers can change the plan at will, add new terms, or find another reason to completely derail the plan after Significant Performance by the parent or child.
606. Express Warranties – service providers have no incentive for their program to be effective because the less effective the program is, the longer the parent has to stay and the more clients they have. Even after attending these so-called therapies, social workers determine the therapy didn’t work and blame the client that they did not work instead of acknowledging, their therapy did not work is nothing more than quackery.
607. Implied Warranties – in all contracts there is an implied warranty of good faith and fair dealing under the common law; however, these contractors traffic human beings and destroy families with their services that do more harm than good. They know their services are harmful and use them any way which is bad faith and unfair dealing.
608. As the direct and proximate result of the Defendants’ actions, Plaintiffs have suffered, and will continue to suffer, physical, mental, and emotional injury, all to an extent and in an amount subject to proof at trial. Plaintiffs have also incurred, and will continue to incur, attorneys’ fees, costs and expenses, including those authorized by 42 U.S.C. § 1988, to an extent and in an amount subject to proof at trial.

609. Plaintiffs hereby incorporate by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
610. While Congress has not enacted a direct counterpart to § 1983, which authorizes claims for relief based on constitutional violations by state and local officials, the Supreme Court, in its seminal 1971 decision, Bivens v. Six Unknown Named Agents, recognized an implied claim for damages when federal law enforcement officers violate an individual’s Fourth Amendment rights. The Bivens claim is a personal-capacity claim against the officer(s) responsible for the constitutional violation.
611. Expanding on the Bivens framework, the Court held in Davis v. Passman that a damages claim could be asserted against federal officials for alleged violations of the equal protection principles of the Fifth Amendment.
612. It is crucial to emphasize that both Bivens and Davis underscored the judiciary’s primary responsibility for upholding federal constitutional rights. They emphasized that damages have historically served as the “ordinary remedy for an invasion of personal interests in liberty.”
613. The Court recognized, however, that the failure to acknowledge the Bivens damages remedy against federal officials could leave plaintiffs without a remedy. This is particularly relevant because constitutional claimants, similar to Webster Bivens and Shirley Davis, often lack claims for prospective relief. Additionally, they are typically unable to seek damages against the United States or federal governmental agencies due to sovereign immunity.
614. The Court did acknowledge that the Bivens remedy might be denied if Congress has created an “equally effective” alternative remedy or when “special factors counsel hesitation in the absence of affirmative action by Congress.”
615. In 1980, in Carlson v. Green, the Supreme Court extended the Bivens doctrine to a suit by the administratrix of a deceased federal prisoner. The complaint alleged that the failure of federal prison officials to provide adequate medical care violated the Eighth Amendment’s prohibition against cruel and unusual punishment. The Court recognized the Bivens claim even though the prisoner had an alternative remedy under the Federal Tort Claims Act (FTCA). The Court in Carlson found that (1) Congress did not intend for the FTCA to be the exclusive remedy.
616. When a plaintiff in a federal court is entitled to assert a Bivens claim for money damages based on an alleged constitutional violation by a federal official, the same procedures and legal principles that apply in § 1983 actions typically apply in the Bivens lawsuit. In Ashcroft v. Iqbal, the Supreme Court affirmed that “[i]n the limited settings where Bivens does apply, the implied cause of action is the ‘federal analog to suits brought against state officials under . . . 42 U.S.C. § 1983.”
617. As previously outlined, the Federal Defendants are liable for the allegations made in this Complaint for the following reasons. First, the United States Government, as outlined in the U.S. Constitution, has several enumerated duties. Through its actions and policies, it seeks to establish justice, ensure domestic tranquility, provide for the common defense, promote the general welfare, and secure the blessings of liberty for all citizens and their posterity. The government exercises its authority directly through regulation, legislation, executive orders, and court orders, as well as indirectly through government agencies and state and local governments.
618. Furthermore, Joe Biden, as the President of the United States, is entrusted with the responsibility for the execution and enforcement of laws created by Congress. As both the head of state and head of government, and as Commander-in-Chief of the armed forces, his primary duty is to ensure the effective operation of the federal government and the faithful execution of all U.S. laws. This includes direct oversight of all executive branch agencies.
619. Kamala Harris holds the office of Vice President of the United States, an integral part of the presidential administration. Her role encompasses various responsibilities, including serving as President of the U.S. Senate, successor to the President, presidential advisor, congressional liaison, and presidential representative.
620. The Department of Health and Human Services (USDHHS) is the principal agency of the United States government dedicated to safeguarding the health of all Americans and providing essential human services, particularly for those who are most vulnerable. USDHHS’s mission is to enhance the health and well-being of all Americans by delivering effective health and human services and promoting significant, sustainable advancements in the fields of medicine, public health, and social services.
621. As the Secretary of USDHHS, Xavier Becerra is entrusted with duties that relate to human conditions and concerns within the United States. These responsibilities include advising the President on matters of health, welfare, and income security programs. He is obligated to administer the Department of Health and Human Services, overseeing approved programs and communicating the department’s objectives to the public.
622. The Department of Justice (DOJ) is charged with enforcing the law and safeguarding the interests of the United States in accordance with legal principles. DOJ is tasked with ensuring public safety from both foreign and domestic threats, providing federal leadership in preventing and controlling crime, and pursuing just punishment for those found guilty of unlawful behavior. Additionally, it ensures fair and impartial administration of justice for all Americans.
623. Merrick B. Garland, serving as the Attorney General, assumes the role of the nation’s chief law enforcement officer and leads the Justice Department. Under his leadership, the Department of Justice is unwavering in upholding the rule of law, preserving the safety of America, and protecting the civil rights of all citizens.
624. The work descriptions of the Federal Defendants outlined above give them supervisory roles over all agencies and authorities within the federal government, state governments, and county authorities. They are expected to champion the rights of U.S. Citizens, formulate policies for the protection of citizens’ rights in the administrative duties of all government bodies, and establish mechanisms to enforce these policies.
625. Unfortunately, the Defendants have failed to fulfill their solemn obligations as delineated above. This failure is evident in the widespread violation of parental rights, including the forceful termination of parental rights, as outlined in this Complaint. These violations have persisted across many states, seemingly unaddressed by the federal government. Consequently, this Complaint is filed against the Federal Defendants.
626. As a direct and proximate result of the Defendants’ actions and/or inactions, Plaintiffs have suffered, and will continue to suffer, physical, mental, and emotional injuries, the extent and magnitude of which will be substantiated during trial. Additionally, Plaintiffs have incurred, and will continue to incur, attorneys’ fees, costs, and expenses, including those authorized by 42 U.S.C. § 1988, the exact amount of which will be demonstrated during the trial proceedings.

627. Plaintiffs hereby incorporate by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
628. 28 USC 1361 is the Mandamus Act which provides that the district courts shall have original jurisdiction of any action in the nature of mandamus to compel an officer or employee of the United States or any agency thereof to perform a duty owed to the plaintiff.
629. With this cause of action, Plaintiffs seek to have all Defendants compelled to perform their duties and obligations.
630. First, Plaintiffs have a clear right to the relief requested. Plaintiffs file this Complaint because the juvenile dependency scheme between the United States Federal Government, its agencies, the 50 states, their municipalities, their contractors, and private citizens have been fundamentally corrupted by malicious actors who have breached their fiduciary duty to the people and have broken their sworn oath to protect and uphold the Constitution. Instead of an being an honest service scheme to keep families together, strengthen communities, keep children safe and stop human trafficking, the Defendants abused, financed, or acquiesced to the absue of the child custody system in the United States, thus depriving families of their parental rights.
631. The US Government has several duties as documented in the US Constitution. The people of the US, through the Government, seek to form a more perfect union by establishing justice, ensuring domestic tranquility, providing for the common defense, promoting the general welfare, and securing the blessings of liberty to citizens and their posterity. The government is therefore mandated to exercise its authority directly by regulating, legislating, and issuing executive orders and court orders. It also grants authority to, and rescinds it from, government agencies and state and local governments.
632. Next, Joe Biden, as the President of the United States, is responsible for the execution and enforcement of the laws created by Congress. The President is both the head of state and head of government of the United States of America, and Commander-in-Chief of the armed forces. The primary duty of the president of the United States is to make sure that all U.S. laws are carried out and that the federal government runs effectively. He also directly oversees all agencies of the executive branch of government.
633. Kamala Harris is the Vice President of the United States. The office of the vice president is an integral part of the president’s administration. She is the president of the U.S. Senate, successor to the President, president’s advisor, congressional liaison, and representative of the president.
634. The Department of Health and Human Services is the United States government’s principal agency for protecting the health of all Americans and providing essential human services, especially for those who are least able to help themselves. The mission of the U.S. Department of Health and Human Services (HHS) is to enhance the health and well-being of all Americans, by providing for effective health and human services and by fostering sound, sustained advances in the sciences underlying medicine, public health, and social services.
635. The duties of Xavier Becerra, as the Secretary of the USDHHS, revolve around human conditions and concerns in the United States. This includes advising the president on matters of health, welfare, and income security programs. He is obligated to administer the Department of Health and Human Services to carry out approved programs and make the public aware of the objectives of the department.
636. The Department of Justice is mandated to enforce the law and defend the interests of the United States according to the law. The Department is also mandated to ensure public safety against threats both foreign and domestic. It also provides federal leadership in preventing and controlling crime, and seeking just punishment for those guilty of unlawful behavior. Lastly, it ensures fair and impartial administration of justice for all Americans.
637. Merrick B. Garland, as the Attorney General, is the nation’s chief law enforcement officer. He leads the Justice Department. Under his leadership, the Department of Justice is dedicated to upholding the rule of law, keeping America safe, and protecting the civil rights of all Americans.
638. The foregoing work and/or role descriptions of the Federal Defendants give them supervisory roles over all agencies and authorities from the federal government, state governments, and county authorities. They should be forefront in championing the rights of the US Citizens. Notably, they should formulate policies on protection of citizens’ rights in administrative duties of all government organs, and should device mechanisms to enforce the policies.
639. The other Defendants also have their own duties and obligations, which are unique to each of their offices.
640. As defined inBoothe v. Roofing Supply, Inc. of Monroe, 893 So.2d 123 (2005)  “arbitrary and capricious conduct is willful and unreasonable action without consideration or regard for the facts and circumstances.”
641. Arbitrary and capricious is a standard for judicial review and appeal, often seen in administrative law. Under this standard, the finding of a lower court will not be disturbed unless it has no reasonable basis, or if the judge decided without reasonable grounds or adequate consideration of the circumstances.
642. Although there is no set standard for an arbitrary and capricious decision, guidance can be found in Natural Resources Defense Council, Inc. v. United States EPA: “5 U.S.C. § 706(2)(A) authorizes the court to “set aside agency action … found to be … arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with the law.” Under this standard, a court must find a “rational connection between the facts found and the choice made” per Motor Vehicle Mfrs. Ass’n v. State Farm Mut. Auto. Ins. Co. (1983). The court must decide whether the agency considered the relevant factors and whether there has been a clear error of judgment; Citizens to Preserve Overton Park, Inc. v. Volpe, 401 U.S. 402, 416 (1971).
643. The Defendants removed Plaintiffs’ children, fincanced the removal, or acquiesced to the removal, without good cause. Those decisions, the actions and/or inactions of the Defendants were not only against the best interest of the children, but also violated the Plaintiffs’ due process rights.
644. Plaintiffs have no other adequate remedy available for the injuries and harm they suffered as a result of Defendants’ actions and/or inactions. No amount of monetary damages would sufficiently compensate Plaintiffs for the injuries they have suffered as a result of the allegations made herein.
645. The Defendants should therefore be compelled to perform all of their obligations and duties, to inter alia, recognize and protect the Plaintiffs’ rights under all laws, and to use the child custody system fairly and lawfully.

646. Plaintiffs hereby incorporate by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
647. There now exists, between the parties hereto, a dispute and controversy to which the Plaintiff and the Defendants are entitled to have a declaration of their rights and further relief relating to the facts and circumstances as set forth in this action.
648. Plaintiffs respectfully request this Honorable Court issue a declaratory judgment declaring that the actions and/or inactions of the Defendants violate the rights of Plaintiffs.

649. Officials are sheltered from suit, under a doctrine known as qualified immunity when their conduct “does not violate clearly established constitutional rights as a reasonable official, similarly situated, would have comprehended.” Harlow v. Fitzgerald, 457 US 800 (1982). The state employees’ actions of unlawfully taking away Plaintiffs’ children without following due process that involved proving by clear and convincing evidence that it was in the best interests of Plaintiffs’ children to terminate Plaintiffs’ parental rights violated a clearly established constitutional right, the Fourteenth Amendment. The familial right of association is embodied in the concept of liberty in the Fourteenth Amendment.
650. Qualified immunity protects an executive official who violated the plaintiffs federally protected right so long as the official did not violate clearly established federal law. In Saucier v. Katz, 533 US 194 (2001), the Supreme Court held that when qualified immunity is asserted as a defense, the court must first determine if the complaint states a violation of a federally protected right, and only if it does, then proceed to determine whether that right was clearly established.
651. Plaintiffs have stated violation of their Fourteenth Amendment rights by employees of various states acting under the color of law. The Fourteenth Amendment is a clearly established right which gives a fair and clear warning as follows: “No state shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any state deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.”
652. “The doctrine of qualified immunity protects Defendants from liability for civil damages unless a plaintiff pleads facts showing (1) that the official violated a statutory or constitutional right, (2) that the right was clearly established at the time of the alleged conduct.” Ashcroft v. al-Kidd, 563 US 731 (2011).
653. In the fact pattern of this Amended Complaint, Plaintiffs have stated facts showing that state employees across various states in the United States deprived Plaintiffs of their Fourteenth Amendment right by denying them the familial right of association embodied in the concept of liberty. The state employees unlawfully took away Plaintiffs’ children without proving that it was in the best interests of the children to terminate Plaintiffs’ parental rights by clear and convincing evidence. The Fourteenth Amendment was ratified in 1868. Therefore, it was established at the time the state employees deprived Plaintiffs of their Fourteenth Amendment right.
654. In Causey v. City of Bay City, 353 F. Supp. 2d 864 (2005), it was held as follows: “The Sixth Circuit has expanded that inquiry into a three-step sequential analysis when the qualified immunity defense is raised in a summary judgment motion brought after some discovery has been conducted, as here. “The first inquiry is whether the plaintiff has shown a violation of a constitutionally protected right; the second inquiry is whether that right was clearly established at the time such that a reasonable official would have understood that his behavior violated that right; and the third inquiry is `whether the plaintiff has alleged sufficient facts, and supported the allegations by sufficient evidence, to indicate that what the official allegedly did was objectively unreasonable in light of the clearly established rights.'” Tucker v. City of Richmond,388 F.3d 216, 220 (6th Cir.2004) (quoting Higgason v. Stephens, 288 F.3d 868, 876 (6th Cir.2002); Champion, 380 F.3d at 901) (citing Feathers v. Aey, 319 F.3d 843, 848 (6th Cir.2003)).” “In the civil sphere, we have explained that qualified immunity seeks to ensure that defendants “reasonably can anticipate when their conduct may give rise to liability,” , at 195, by attaching liability only if “[t]he contours of the right [violated are] sufficiently clear that a reasonable official would understand that what he is doing violates that right.” United States v. Lanier, 520 U.S. 259 (1997).
655. Throughout this Complaint, Plaintiffs have demonstrated how state employees of various states across the United States have deprived them of their Fourteenth Amendment rights. The state employees understood that their actions violated Plaintiffs’ Fourteenth Amendment rights but that did not stop them from executing their unlawful schemes of terminating Plaintiffs’ parental rights without proving that it was in the best interests of their children to do so by clear and convincing evidence. Plaintiffs have attached volumes of exhibits to prove the actions of state employees across various states alleged in this Complaint.
656. Under qualified immunity, “officials are not liable for bad guesses in gray areas, they are liable for transgressing bright lines.” Maciarello v. Sumner, 973 F.2d 295 (1992). The actions of state employees across various states where the causes of action in this Complaint took place were deliberate, intentional and outrageous. The employees could not prove by clear and convincing evidence that it was in the best interests of Plaintiffs’ children to terminate Plaintiffs’ parental rights. The state employees resorted to intentionally making false statements in court to deceive the courts, thereby making the courts unable to make impartial decisions that were fair. The employees also forged documents to lead the court to make orders, declarations, and judgments that terminated Plaintiffs’ parental rights.

657. Families need a nationwide temporary injunction on child removals to protect families from irreparable harms. Children need to be returned to biological families immediately while the details of the case are being debated as they have already suffered and been harmed for prolonged separation without due process.
658. Please restrain the Department of Health and Human Services and All State Courts from removing any more children from homes and holding the children of the people on this list.
659. [1] Even though jurisdictional finding may be based on substantial evidence, dispositional findings have a different focus and heightened burden of proof – clear and convincing evidence(§ 361 , subd. (c)(1); Conservatorship of O.B. (2020) 9 Cal.5th 989, 995-996, 1011.) This heightened standard is premised on the notion that even after parents have been found to have abused or neglected their children “keeping children with their parents while proceedings are pending, whenever safely possible, serves not only to protect parents’ rights but also children’s and society’s best interest. (In re D.P. (2020) 44 Cal.App.5th 1058, 1066-1067.)
660. [2] Even though children may be dependents of the juvenile court, they shall not be removed from their parents unless there is clear and convincing evidence of a substantial danger to the child’s physical health, safety, protection, or physical or emotional well-being and there are no “reasonable means” by which the child can be protected without removal. (§ 361, subd. (c)(1)) When considering if the child will be in substantial danger if permitted to remain in the parent’s custody, the court must consider not only the parent’s past conduct, but also current circumstances and the parent’s response to the conditions that gave rise to juvenile court intervention. (In re Alexzander C. (2017) 18 Cal.App.5th 438, 451-452.)

661. Preliminary Injunctive Relief is Necessary to Protect Against Irreparable Harm
662. The requested preliminary injunction is necessary to prevent irreparable harm during the pendency of the litigation. Without this relief, the court will be unable to render a meaningful judgment on the merits. If a preliminary injunction is not specifically requested in the complaint, the preliminary injunction must be related to the relief sought in the complaint. A district court lacks authority to grant a preliminary injunction that is not of the same character as the final relief sought in the underlying complaint. Omega World Travel v. Trans World Airlines, 111 F .3d 14, 16 (4th Cir. 1997).
663. The Court Has the Discretion to Grant Preliminary Injunctive Relief.
664. Plaintiffs’ motion for a preliminary injunction is properly within the Court’s discretion.
665. The preliminary relief requested is of the same character as the final relief sought in the complaint.
666. A Mandatory Injunction Is Necessary to Prevent Irreparable Harm.
667. Defendants’ refusal to take action will result in irreparable harm to Plaintiffs. A mandatory preliminary injunction is the only way to protect Plaintiffs from this harm and preserve the court’s ability to render a meaningful final judgment on the merits.
668. The Evidentiary Record Establishes the Need for Preliminary Injunctive Relief.
669. Plaintiffs’ request for preliminary injunctive relief is amply supported by the factual record. The affidavits and other evidence submitted by Plaintiffs demonstrate that Plaintiffs would suffer irreparable harm in the absence of injunctive relief.
670. Plaintiffs’ Affidavits Are Properly Considered on a Motion for a Preliminary Injunction.
671. Plaintiffs’ affidavits, which describe in detail why Plaintiffs would suffer irreparable harm in the absence of the requested injunctive relief, constitute proper evidence on a motion for a preliminary injunction. Formal evidentiary requirements do not apply to affidavits in support of a preliminary injunction, which may be based on hearsay or belief. Affidavits may be submitted in support of or in opposition to a motion for a preliminary injunction. Flynt Distributing Co., Inc. v. Harvey, 734 F .2d 1389, 1394 (9th Cir. 1984) (finding that a preliminary injunction may be granted on affidavits, even if the affidavits contain hearsay); Federal Sav. Loan Ins. Corp. v. Dixon, 835 F .2d 554, 558 (5th Cir. 1987) (finding that court’s reliance on affidavits in resolving motion for a preliminary injunction was not erroneous, even though the affidavits contained hearsay, as it is common for district courts to consider affidavits on a preliminary injunction and such relief may be granted based on evidence that would not be admissible at trial).
672. Because Plaintiffs Has Satisfied the Statutory Conditions, the Preliminary Injunction Should Be Granted.
673. Because the requested preliminary injunction is expressly authorized by statute and the statutory conditions are satisfied, the injunction may be granted without a showing of irreparable injury. A preliminary injunction may be granted without a showing of irreparable injury if the injunction is authorized by a statute. Securities & Exchange Commission v. Management Dynamics, Inc., 515 F.2d 801, 808 (2d Cir. 1975) (holding that SEC was not required to demonstrate irreparable injury to obtain an injunction authorized by statute); Trade Comm’n v. Consumer Def., LLC, 926 F.3d 1208, 1214 (9th Cir. 2019).
674. The Preliminary Injunction Is Necessary to Protect Civil Rights.
675. Because Defendants’ proposed actions will violate constitutionally-protected rights, Plaintiffs is likely to succeed on the merits of its claims. These violations of fundamental rights cannot be adequately compensated by money damages, and in fact, are presumed to cause irreparable injury. The preliminary injunction should therefore be granted. A court will grant a preliminary injunction when necessary to protect civil rights. Clemons v. Board of Education of Hillsboro, 228 F .2d 853, 857 (6th Cir. 1956) (injunction will issue to protect and preserve basic civil rights); Presbyterian Ch. v. Black Liberation Front, 303 F. Supp. 894, 901 (E.D. Mo. 1969) (preliminary injunction granted to enjoin violation of civil rights laws guaranteeing plaintiffs’ right to use their property for religious services). Irreparable injury may be presumed in cases involving certain deprivations of civil rights, including deprivation of First Amendment rights. Elrod v. Burns, 427 U.S. 347, 373 (1976).
676. A court will find that the civil rights plaintiff has established a likelihood of success on the merits when the defendant’s proposed actions will clearly violate constitutionally protected rights. Newsom v. Norris, 888 F.2d 371, 378 (6th Cir. 1989) (preliminary injunction was granted when plaintiffs established First Amendment violations); American Federation of Government Employees, Afl-Cio, Council 33 v. Meese, 688 F. Supp. 547, 548 (N.D. Cal. 1988) (compulsory drug testing enjoined as violation of Fourth Amendment “unless and until” plaintiff can show that such testing supersedes constitutional rights of employees).

677. Plaintiffs hereby incorporate by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
678. Title III of the ADA prohibits public accommodations from discriminating against individuals with disabilities. See 42 U.S.C. 12182(a). It expressly requires owners, operators, or lessees of public accommodations to take “such steps as may be necessary to ensure that no individual with a disability is excluded, denied services, segregated or otherwise treated differently because of the absence of auxiliary aids and services”. 42 U.S.C. 12182(b)(2)(A)(iii). Failure to take such steps amounts to prohibited discrimination unless the accommodation shows that providing the auxiliary aid or service would fundamentally alter the nature of the good, service, facility, privilege, advantage, or accommodation being offered or would result in an undue burden.
679. 28 C.F.R. § 36.302 (a) provides for the modifications in policies, practices, or procedures, to accommodate individuals with disabilities. Said provision states that:

680. 28 CFR 36.303(a) also provides for auxiliary aids and services for disabled individuals. Said provision states in pertinent part that:

681. 28 CFR 36.303(b) proceeds to define what includes an auxiliary aid. Accordingly, auxiliary aids may include “other effective methods of making aurally delivered information available to individuals who are deaf or hard of hearing”, “other effective methods of making visually delivered materials available to individuals who are blind or have low vision”, or “[o]ther similar services and actions”.
682. Further, 28 CFR 36.303(c)(1)provides for the need for effective communication for people with disabilities. This includes an obligation to provide effective communication to companions who are individuals with disabilities. According to said law, “‘companion’ means a family member, friend, or associate of an individual seeking access to, or participating in, the goods, services, facilities, privileges, advantages, or accommodations of a public accommodation, who, along with such individual, is an appropriate person with whom the public accommodation should communicate.”
683. It is also notable that “[t]he type of auxiliary aid or service necessary to ensure effective communication will vary in accordance with the method of communication used by the individual; the nature, length, and complexity of the communication involved; and the context in which the communication is taking place.” 28 CFR 36.303(c)(1)(ii).
684. “[T]he type of auxiliary aid that ensures ‘effective communication’ varies by context.” See Feldman v. Pro. Football, Inc., 419 Fed.Appx. 381, 391 (4th Cir. 2011). The DOJ’s Technical Assistance Manual for Title III also indicates that the type of auxiliary aid that ensures “effective communication” varies by context. See S. Dep’t of Justice, Civil Rights Division, The Americans with Disabilities Act: Title III Technical Assistance Manual III-4.3200. The regulation contemplates that, like the type of auxiliary aid, the content that must be communicated by auxiliary aids is also context-sensitive. What constitutes “full and equal enjoyment” of a place of public accommodation’s goods, services, facilities, and privileges necessarily varies based on what the place provides to visitors and consumers. See Feldman v. Pro Football, Inc., 419 F. App’x 381, 391 (4th Cir. 2011).
685. Further, the law permits a person with a disability to act as such person’s auxiliary aid, if such disabled person “specifically requests that the accompanying adult interpret or facilitate communication, the accompanying adult agrees to provide such assistance, and reliance on that adult for such assistance is appropriate under the circumstances.” See 28 CFR 36.303(c)(3)(ii).
686. In McGann v. Cinemark USA, Inc., 2016 U.S. Dist. LEXIS 45332 (W.D. Pa., Apr. 4, 2016),the Court held that the trial court had erred by determining that the requested tactile interpreter was not an auxiliary aid or service under the Americans with Disabilities Act (ADA). In the words of the Court, “tactile interpreter satisfied the definition of ‘auxiliary aid or service’”.
687. Also, in Feldman v. Pro Football, Inc., 419 F. App’x 381, 391 (4th Cir. 2011), the Fourth Circuit affirmed a grant of summary judgment in favor of deaf plaintiffs, holding that the ADA required the defendants to provide captioning of the lyrics of popular music played over the public address system at a stadium during professional football games.
688. It is instant action; the Plaintiffs have mild to severe disabilities. All of them have PTSD and suffer from inability to concentrate, which affects their reading comprehension, inability to sleep, and lack of/increased appetite. They therefore need electronic aids for communication and for preparing documents. They therefore belong to a specific class of people, which class needs protection.
689. When Plaintiffs file this action to seek legal redress for the hamr done against them bu the government, they were denied an opportunity to approach the court through auxiliary aids. The judge erroneously stated that one of the Plaintiffs, Melody Rogers, was illegally representing the pro se Plaintiffs and acting as their attorney. However, he Plaintiff did not hold herself out to be an attorney. She was only an auxiliary aid, considering the Plaintiffs’ disabilities.
690. Besides, in consideration of the Plaintiffs’ disabilities, the Courts failed to take such steps as may be necessary to ensure that the Plaintiffs were not excluded or denied the Court’s services. See 42 U.S.C. 12182(b)(2)(A)(iii). In the circumstances, the Plaintiffs had selected Melody Rodgers to be their auxiliary aid. As Plaintiffs have already stated above, the law permits an auxiliary aid for individuals with disabilities, to provide, inter alia, provide effective communication to companions who are individuals with disabilities. See 28 CFR 36.303(c)(1).
691. Further, as already stated above, the type of auxiliary services needed varies depending on the method of communication used by the individual; the nature, length, and complexity of the communication involved; and the context in which the communication is taking place. 28 CFR 36.303(c)(1)(ii). In this case, the Plaintiffs had mild to severe disabilities. They therefore need electronic aids for communication and for preparing documents. As the direct and proximate result of the Defendants’ actions and/or inactions, Plaintiffs have suffered, and will continue to suffer, physical, mental, and emotional injury, all to an extent and in an amount subject to proof at trial. Plaintiffs have also incurred, and will continue to incur, attorneys’ fees, costs and expenses, including those authorized by 42 U.S.C. § 1988, to an extent and in an amount subject to proof at trial.

692. Plaintiffs hereby incorporate by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
693. 42 U.S.C. 671 outlines the requirements for state plans for foster care and adoption assistance. The section specifies the requisite features of a state plan in order for a state to be eligible for payments under this part. The section also provides safeguards which restrict the use of or disclosure of information concerning individuals assisted under the State plan to purposes directly connected with the administration of the plan of the State.
694. The law requires States to make reasonable efforts to preserve and reunify families (i) prior to the placement of a child in foster care, to prevent or eliminate the need for removing the child from the child’s home; and (ii) to make it possible for a child to safely return to the child’s home. “Reasonable efforts” refers to activities of State social services agencies that aim to provide the assistance and services needed to preserve and reunify families.
695. CAPTA provides funding for programs that are designed to prevent child abuse and neglect.
696. Plaintiff challenges the said laws for the following reasons. First, the laws are broad and ambiguous. For instance, 42 U.S.C. 671 defines “Reasonable efforts” as activities of State social services agencies that aim to provide the assistance and services needed to preserve and reunify families. It does not go deeper to define the limits of what is reasonable or unreasonable. It is therefore possible for State actors to abuse the law by engaging in activities which are outrightly unreasonable. In the instant action, the State actors removed Plaintiffs’ children while relying on the said law. The State actors argue that their actions fall within what is reasonable as allowed under the law. However, such an interpretation harms Plaintiffs because it violates Plaintiffs’ parental rights. It follows; there is a heightened risk of the law to be abused by the state actors. It provides them a leeway to make arbitrary and capricious decisions that are an affront to what is just and fair in a democratic society. Also, the parents themselves may not be aware of what is within the reasonable standards.
697. Next, with regards to CAPTA, the law contains a long list of reporting and process requirements for states to be eligible. Though none have been declared non-compliant by the United States Children’s Bureau, an investigation by The Boston Globe and ProPublica published in 2019 found that the 50 states, the District of Columbia, and Puerto Rico were all out of compliance with the requirements to varying degrees. The report also found that underfunding of child welfare agencies and substandard procedures in some states caused failures to prevent avoidable child injuries and deaths.
698. Another report done by the Casey Family Programs[5] evidenced that there is limited evidence of the effectiveness of activities and programs funded by CAPTA grants. Although CAPTA requires that such programs be evaluated every two years, the only publicly available evaluation report is limited to a review of state plans, which are descriptive rather than evaluative.
699. It follows; there is a need to relook and/or evaluate the effectiveness of CAPTA in protecting children from abuse and neglect, while at the same time reconizing and protecting parental rights.
700. In light of the foregoing, Plaintiffs request a determination of unconstitutionality of the said statutes for their potential effects of violation of the rights of American citizens.

1. PRAYER FOR RELIEF

1. Declaratory relief;
2. An injunction against the Defendants ordering the Defendants to restore and enforce Plaintiffs’ rights to have custody of their children.

• A declaration of Unconstitutionality of 42 U.S.C. 671 and CAPTA.

1. An award for actual damages for violation of Plaintiffs’ rights as alleged herein;
2. Interest as provided by law;
3. An award of fees and costs;

• Such other relief as the Court deems just and proper.

1. Plaintiffs, representing themselves in pro-persona, hereby bring this action against Defendants UNITED STATES GOVERNMENT, JOE BIDEN, DEPARTMENT OF HEALTH AND HUMAN SERVICES, XAVIER BECERRA, DEPARTMENT OF JUSTICE, MERRICK B. GARLAND, et al, and allege as follow:

1. PRELIMINARY STATEMENT

2. The United States Children’s Bureau and the related juvenile justice system were established with the noble mission of providing safe and stable homes for children facing abuse and/or neglect in their homes. In response to the pressing need to protect children, numerous Acts of Congress have been enacted to safeguard their well-being, support struggling families, and combat human trafficking, a scourge that disproportionately affects vulnerable children.
3. The United States Department of Health and Human Services (USDHHS) and the Department of Justice bear the primary responsibility for upholding this solemn commitment on behalf of the American people, as mandated by their elected Congressional representatives. These federal agencies possess delegated authority, which they further entrust to the 50 states. Subsequently, the states delegate authority to local townships and municipalities to execute the objectives of these acts at the grassroots level.
4. The intricate framework governing child protection is shaped by a combination of Federal Laws, State Statutes, and Welfare Institutions Codes. Recognizing the sanctity of the right to parent, dependency proceedings are bound by the foundational principles of due process, including the provision of adequate notice and the assurance of a fair opportunity for parents to participate in these proceedings.
5. It is imperative to underscore that the due process rights extended to parents within the dependency system hinge on scrupulous adherence to procedural requirements. Even minor deviations from these procedures can yield prejudicial outcomes for all parties involved and result in enduring harm.
6. Across all 50 states of the United States of America, these laws are meticulously integrated into state statutes, later incorporated into municipality codes as Welfare Institutions Codes, and afforded distinct designations within state courts. These designations pertain to the orchestration of civil and criminal legal procedures linked to the implementation of these laws.
7. These laws comprehensively address and regulate various critical aspects, including:
8. The definition of child abuse
9. The definition of child neglect
10. The definition of imminent danger
11. The identification of circumstances qualifying as dangerous or high-risk for child abuse or neglect and those that do not meet these criteria
12. The delineation of the rights of children and families while children are under state custody
13. The process, rationale, and purpose of removing children from homes when they face imminent danger of abuse or neglect
14. The meticulous process for assessing risk and making determinations regarding the necessity for continued court intervention
15. The detailed procedures for permanency planning and the meticulous evaluation of the best interests of the child
16. The rigorous process and burden of proof essential for the termination of parental rights, should such a measure become necessary.
17. The United States Department of Health and Human Services, referred to as USDHHS, is currently under the leadership of Xavier Becerra. Within the purview of USDHHS, various bureaus are responsible for a range of critical functions, including:
18. USDHHS was originally established on October 17, 1979. Its inception followed the transfer of education functions to the newly created United States Department of Education as mandated by the Department of Education Organization Act. Subsequently, USDHHS assumed responsibility for crucial entities, including the Social Security Administration, agencies comprising the Public Health Service, and the Family Support Administration. Its overarching mission is to enhance the health, safety, and well-being of all Americans. USDHHS operates within the framework of several Acts of Congress:

19. The act is to help discourage dishonest dealings after it was found that up to 25% of the federal money paid for labor under prevailing wage rates was actually returned by the wage-earner as a kickbackto the employing contractor or subcontractor, or to Defendants .
20. Accordingly, the Act prohibits a federal contractor or subcontractor from inducing an employee into giving up any part of the compensation that he or she is entitled to under the terms of his or her employment contract.

21. The Act regulates how federal agencies make and enforce rules. It prevents arbitrary rulings. Notably,  the Act gives federal courts the power to review agency actions. It was based on the common law principles of judicial review that existed in 1946, and was seen as a way to balance the growth of federal agencies and their power with the rights and interests of the public.

22. The purpose of the Act was to turn the focus of the child welfare system toward keeping children safely with their families to avoid the trauma that results when children are placed in out-of-home care.
23. The Act was also created to increase the number of children who can remain safely at home with their families, and to ensure that the law provides families with greater access to mental health services, substance use treatment, and/or parenting skills courses.
24. This law significantly shifts how the country provides services for families and youth. In particular, it changed the role of community service providers, the way courts advocate and make decisions for families, and the types of placements that youth placed in out-of-home care experience.
25. The law also created the Title IV-E Prevention Services Clearinghouse, which maintains a continuously updated and comprehensive list of evaluated and tested prevention services and programs. States can use title IV-E funds toward these services and programs to help prevent disruption within families.

26. The USDHHS Office for Civil Rights administers the HIPAA Privacy and Security Rules. The HIPAA Privacy Rule describes what information is protected and how protected information can be used and disclosed. The HIPAA Security Rule describes who is covered by the HIPAA privacy protections and what safeguards must be in place to ensure appropriate protection of electronic protected health information
27. The USDHHS has 12 operating divisions, including nine agencies in the U.S. Public Health Service and three human services agencies. These divisions administer a wide variety of health and human services and conduct research.
28. The USDHHS also governs the state-level DHHS’, which in turn delegates responsibility to county or municipality DHHS’. The USDHHS Office of Intergovernmental and External Affairs hosts ten Regional Offices that directly serve state and local organizations. A President-appointed Regional Director leads each office. Each Regional Director ensures the Department maintains close contact with state, local, and tribal partners and addresses the needs of communities and individuals served through HHS programs and policies.
29. Many USDHHS-funded services are provided at the local level by state or county agencies, or through private sector grantees. Each state has its own Department of Health or Department of Public Health, which is responsible for implementing health policies and programs in accordance with federal and state laws and regulations.
30. According to the USDHHS website, in fiscal year 2022, USDHHS awarded approximately $784.4 billion in grant and cooperative agreement awards and $905.3 billion in other financial assistance. The budget for fiscal year 2021 proposed $94.5 billion in discretionary budget authority and $1.3 trillion in mandatory funding for USDHHS. USDHHS grants are provided directly to states, territories, tribes, and educational and community organizations
31. Further, the President’s Fiscal Year (FY) 2024 Budget seeks to advance the USDHHS’ mission to promote Americans’ health and well-being. USDHHS proposes $144.3 billion in discretionary and $1.7 trillion in mandatory proposed budget authority for FY 2024. This budget seeks to addresses urgent challenges the country is facing today—including a growing behavioral health crisis, need to prepare for future public health threats, and large arrival of unaccompanied children and refugees. The budget also seeks to secure a healthier, more vibrant future for all Americans by investing in expanded coverage and access to care; addressing the needs of those most at risk, including Indian country, children, families, and seniors; growing our health workforce; and advancing science to improve health.
32. The Unites States Department of Justice is overseen by Merrick Garland.
33. However, the laws that enabled the states and its related agencies to act on behalf of abuse victims and trafficking victims are presently being exploited by corrupt federal officials, state organizations, states courts, local municipalities, professionals, private citizens, and criminals alike.
34. By way of its customs, policies, and practices, Defendants have created a culture of corruption that fosters criminal activity and funds an unaccountable RICO conspiracy ring that trafficks children and families into a perpetual scheme of honest services fraud.
35. Plaintiffs’ and their families’ rights have been injured as a result of the Defendants customs, policies, and practices of:
    1. Negligently Hiring unqualified of Oversight Agents, Federal Officers
    2. Practice of not Supervising of Holding Accountable
    3. Practice of not Training
    4. Policy of not prosecuting criminals and perpetrators of domestic violent failure
    5. Customer, Policies, Practices, and Procedures of using judicial deception, honest services fraud by Xavier Bacerra and Merrick B Garland.
36. Defendants have failed to protect domestic violence victims to seek safety used to frustrate parents by terminating their parental rights without proof by clear and convincing evidence and/or by a preponderance of evidence that they have abused and/or neglected their child(ren).
37. Plaintiffs are biological parents of minor child(ren) whose parental rights were terminated without due process and whose minor child(ren) were taken away unjustly by way of state courts and municipal actors maliciously conspiring to commit fraud upon the court through perjury, intentional misrepresentations, omissions of exculpatory evidence, trickery, and duress.
38. Plaintiffs filed this suit to seek redress for the injustice they have suffered endlessly and mercilessly for years.
39. Plaintiffs also seek a civil injunction to stop the irreparable harm they are presently suffering and will likely continue suffer if this honorable court of justice abstains from intervening and protecting them from the malevolent abusers disguised as benevolent welfare officials.
40. This action is brought pursuant to 42 U.S.C. § 1983 to redress the deprivation under color of law of the rights of families and children as secured by the United States Constitution.
41. It also brought pursuant to 18 U.S.C. § 1346, 1347 to redress the deprivation of Honest Services Health Care Fraud and expose the massive cover up of the individuals involved in 18 U.S.C. § 4 Misprision of Felony which states “Whoever (owing allegiance to the United States), having knowledge of the actual commission of a felony cognizable by a court of the United States, conceals and does not as soon as possible make known the same to some judge or other person in civil or military authority under the United States, shall be fined under this title..”
42. This Complaint is brought because the dependency scheme between the Federal Government, its agencies, the 50 states, the municipalities, their contractors and the citizens of the United States has been fundamentally corrupted by malicious actors who have breached their fiduciary duty to the people and have broken their sworn oath the protect and uphold the Constitution.
43. Instead of an being an honest service scheme to keep strengthen families, keep children safe and stop human trafficking, the Children’s Bureau, the Department of Justice and its contractors (here forth referred to as ‘Defendants’) have created an “artifice or scheme to defraud” families to deprive them of their intangible right of honest services.
44. The Defendants have simultaneously created an “artifice or scheme” to defraud the United States’ health care benefits programs of trillions of tax-payer dollars, while using false and fraudulent pretenses, representations, and promises to gain custody and control over minor children who will then be trafficked under the guise of their welfare.
45. The Defendants have demonstrated a “pattern and practice of enacting and enforcing arbitrary and capricious policies and procedures that are contrary to what the state and federal laws indicate. They “maliciously defy bright line laws” because of the lack of accountability.
46. Defendants have abused the processes associated with laws and frustrated the intended purpose and spirit of the laws by those who created the law.  These bad actors who include judges, lawyers, police officers, social workers, health care professionals and sometimes average citizens have exploited the system and redesigned it into an instrument of coercion, retaliation and weaponry against victims who seek redress from abuse with these agencies.
47. Plaintiffs in this lawsuit are suing for the Intentional Infliction of Emotional Distress enacted upon them by the Defendants through their excessively cruel, humiliating, insurmountably corrupt,  fraudulent court schemes that illegally separated their families and deprived them of their right to life, liberty and the pursuit of happiness, family integrity, personal privacy, freedom of association, freedom of speech, freedom of privacy and access to reproductive health clinics without due process of law, but through arbitrary and capricious decision making.
48. Plaintiffs are also suing Defendants for: Disregarding Bright Line Laws, Failure to Supervise, Train, Pattern and Practice of Placing Children in the Most Restrictive Environment, Imminent Danger, Oaths to Secure a Warrant for Removal, Imprisonment of Parents and use of Court Sanctions, Detention Hearings, Jurisdictional Hearings, Intermediary Hearings, Permanency Planning, Social Worker Reports, Adequate Notice, Continuances, Least Restrictive Environment, Resources at their disposal that they do no utilize because they work, Promotion of Family and Marriage, Promotion of Kinship Care, Judicial Deception and Fraud Upon the Court, Conflicting Interests, Adversariness of Proceedings and Government Interest, Best Interest of the Child, Child Abuse and Foster Care Statistics, Arbitrary and Capricious, Medical Malpractice, Legal Malpractice, Honest Services Fraud, Breach of Fiduciary, Breach of Contract, Unconscionable Contracts, Interference with Interstate Commerce, Conspiracy, Neglect to Prevent.
49. At all times material, Plaintiffs had a constitutionally protected right under the Fourteenth Amendment to the U.S. Constitution to receive due process before their children were removed from their home.
50. Rewarding Failure to comply – they get to say they have too many children and their budget increases. This creates a loophole for bad actors to take advantage of in order to get more children on their docket and never have to improve or comply.

1. PARTIES

51. Plaintiff Melody J. Rodgers is a female adult of sound mind and a resident of [438 River Ridge Drive Wallace, North Carolina 28466].
52. Plaintiff Malachi Chapman is a male adult of sound mind and a resident of [470 Dekalb Ave Apt #8C Brooklyn, New York 11205].
53. Plaintiff Laurie Reynolds is a female adult of sound mind and a resident of [600 Victoria’s Cir St. Mary’s, Georgia, 31558 United States].
54. Plaintiff Tijana Vidanovic is a female adult of sound mind and a resident of [13066 Gridley St. Sylmar, California 91342].
55. Plaintiff Cecelia Evertez is a female adult of sound mind and a resident of [47 Poverty Hollow Road Newtown, Connecticut 06470].
56. Plaintiff Renesha Tomlin is a female adult of sound mind and a resident of [1501 Edith Blvd SE, Apartment 3 Albuquerque, New Mexico, 87102].
57. Plaintiff Dmitri Cash is a female adult of sound mind and a resident of [30 S. PLYMOUTH AVE. ROCHESTER, NY 14614].
58. Plaintiff Teresa Goin is a female adult of sound mind and a resident of [841 West Alpha Parkway Waterford, Michigan, 48328].
59. Plaintiff Raymond Sipult is a male adult of sound mind and a resident of [1323 N. Pershing s Wichita Kansas 67208].
60. Plaintiff Glenda Cody is a female adult of sound mind and a resident of [Denver St. El dorado, Kansas, 67042].
61. Keyona Bradley is a female adult of sound mind and a resident of [6429 E. Cottonwood Lane Wichita, Kansas 67207].
62. Plaintiff Kristen-Clark Hassel is a female adult of sound mind and a resident of [108 Plantation Court St. Mary’s, Georgia 31558].
63. Plaintiff Elizabeth Andrews is a female adult of sound mind and a resident of [5182 NW Miller Rd., Altha Florida 32421].
64. William O’Dell is a male adult of sound mind and a resident of [670 Elmwood Dr. Woodway, Texas 76712].
65. Emily O’Dell is a female adult of sound mind and a resident of [670 Elmwood Dr. Woodway, Texas 76712].
66. Plaintiff SAVE OUR CHILDREN TRUTH COMMISSION is a Civic and Social Organization that offers legal advocacy for families and helps end child trafficking in America. Its address is 201 W. Bayshore Blvd. Jacksonville, NC, 28540.
67. Defendant UNITED STATES GOVERNMENT, upon the Plaintiffs’ information and belief is the sovereign independent government of the UNITES STATES OF AMERICA.
68. Defendant JOE BIDEN, upon Plaintiffs’ information and belief is the President of the United States. Plaintiffs sue this Defendant in his individual and official capacity.
69. Defendant KAMALA HARRIS, upon the Plaintiffs information and belief is the Vice President of the UNITES STATES OF AMERICA and former Attorney General of California. Plaintiffs sue the said Defendant in her official capacity for damage and injunction from negligent supervision, neglect to prevent the abuse, corruption, and fraud rampant in subordinate agencies, and for continuing to fund the human trafficking scheme despite reports of the atrocities. Her address is: [U.S. Department of Justice 950 Pennsylvania Avenue, NW Washington, DC 20530-0001].
70. Defendant DEPARTMENT OF HEALTH AND HUMAN SERVICES, upon Plaintiff’s information and belief is a cabinet-level executive branch department of the U.S. federal government created to protect the healthof the U.S. people and providing essential human services.
71. Defendant XAVIER BECERRA, upon Plaintiff’s information and belief is the head of the United States Department of Health and Human Services. Plaintiffs sue the said Defendant in his individual and official capacity for negligent supervision, neglect to prevent the abuse, corruption, and fraud rampant in subordinate agencies, and for continuing to fund the human trafficking scheme despite report of the atrocities.
72. Defendant DEPARTMENT OF JUSTICE, upon Plaintiff’s information and belief is a cabinet-level executive branch department of the U.S. federal government tasked with the enforcement of federal law and administration of justice in the United States.
73. Defendant, MERRICK B. GARLAND, upon Plaintiff’s information and belief, is the Attorney General of the United States. Plaintiffs sue the said Defendant in his individual and official capacity for negligent supervision, neglect to prevent abuse, corruption, and fraud rampant in its subordinate courts, and for continuing to fund the human trafficking conspiracy despite being informed of the crisis.
74. Defendant JERRY MILNER (“MILNER”), upon Plaintiffs information and belief is the DIRECTOR OF THE CHILDREN’S BUREAU FOR THE ADMINISTRATION FOR CHILDREN AND FAMILIES. Plaintiffs sue the said Defendant in his individual capacity for damages and his official capacity for injunctive relief from negligent supervision, neglect to prevent the abuse, corruption, and fraud rampant in subordinate agencies, and for continuing to fund the human trafficking scheme despite reports of the atrocities. [ 330 C. St. SW Washington, DC 20201].
75. Defendant DOES, upon Plaintiffs information and belief, DOES are the UNITED STATES ASSISTANT SECRETARIES FOR ADMINISTRATION FOR CHILDREN AND FAMILY SERVICES from (2019-Present) and are sued in their individual and official capacities for injunctive relief for negligent supervision, neglect to prevent abuse, corruption, and fraud rampant in its subordinate courts, and for continuing to fund the human trafficking conspiracy despite being informed of the crisis. Their address is [330 C. St. SW Washington, DC 20001].
76. Defendant GAVIN NEWSOM (“NEWSOM”), upon Plaintiffs information and belief is the Governor of CALIFORNIA. Plaintiffs sue the said Defendant in his individual capacity for damages and his official capacity for injunctive relief from negligent supervision, neglect to prevent the abuse, corruption, and fraud rampant in subordinate agencies, and for continuing to fund the human trafficking scheme despite reports of the atrocities. His address is: [1021 0 Street, Suite 9000 Sacramento, California 95814].
77. Defendant JERRY BROWN (“BROWN”), upon Plaintiffs information and belief is the former Governor of CALIFORNIA. Plaintiffs sue the said Defendant in his individual capacity for damages and his official capacity for injunctive relief from negligent supervision, neglect to prevent the abuse, corruption, and fraud rampant in subordinate agencies, and for continuing to fund the human trafficking scheme despite reports of the atrocities. His most recently known address is: [1021 0 Street, Suite 9000 Sacramento, California 95814].
78. Defendant ELENI KOUNALAKIS (“KOUNALAKIS”), upon Plaintiffs information and belief is the Lieutenant Governor of CALIFORNIA. Plaintiffs sue the said Defendant in her individual capacity for damages and her official capacity for injunctive relief from negligent supervision, neglect to prevent the abuse, corruption, and fraud rampant in subordinate agencies, and for continuing to fund the human trafficking scheme despite reports of the atrocities. Her address is [1021 0 St., Suite 8730, Sacramento, California 95814].
79. Defendant GREG ABOTT (“ABOTT”), upon Plaintiffs information and belief is the Governor of TEXAS. Plaintiffs sue the said Defendant in his individual capacity for damages and his official capacity for injunctive rel ief from negligent supervision, neglect to prevent the abuse, corruption, and fraud rampant in subordinate agencies, and for continuing to fund the human trafficking scheme despite reports of the atrocities. His address is: [1100 San Jacinto Blvd., Austin, Texas, 78701]
80. Defendant DAN PATRICK (“PATRICK”), upon Plaintiffs information and belief is the Lieutenant Governor of TEXAS. Plaintiffs sue the said Defendant in his individual capacity for damages and his official capacity for injunctive relief from negligent supervision, neglect to prevent the abuse, corruption, and fraud rampant in subordinate agencies, and for continuing to fund the human trafficking scheme despite report of the atrocities. His address is: [1100 San Jacinto Blvd., Austin, Texas, 78701]
81. Defendant SUSANA MARTINEZ (“MARTINEZ”), upon Plaintiffs information and belief is the former Governor of NEW MEXICO. Plaintiffs sue the said Defendant in her individual capacity for damages and her official capacity for injunctive relief from negligent supervision, neglect to prevent the abuse, corruption, and fraud rampant in subordinate agencies, and for continuing to fund the human trafficking scheme despite reports of the atrocities. Her address is: [8301 Jefferson St NE Ste A Albuquerque, New Mexico 87113)
82. Defendant MICHELLE LUJAN-GRISHAW (“LUJAN-GRISHAW”), upon Plaintiffs information and belief is the Governor of NEW MEXICO. Plaintiffs sue the said Defendant in her individual capacity for damages and her official capacity for injunctive relief from negligent supervision, neglect to prevent the abuse, corruption, and fraud rampant in subordinate agencies, and for continuing to fund the human trafficking scheme despite reports of the atrocities. Her address is: [490 Old Santa Fe, Trail Room, Santa Fe, New Mexico 87501)
83. Defendant DOUG DUCEY (“DUCEY”), upon Plaintiffs information and belief is the Governor of ARIZONA. Plaintiffs sue the said Defendant in his individual capacity for damages and his official capacity for injunctive relief from negligent supervision, neglect to prevent the abuse, corruption, and fraud rampant in subordinate agencies, and for continuing to fund the human trafficking scheme despite reports of the atrocities. His address is: [1700 W. Washington St., Phoenix, Arizona 85007)
84. Defendant RON DESANTIS (“DESANTIS”), upon Plaintiffs information and belief is the Governor of FLORIDA. Plaintiffs sue the said Defendant in his individual capacity for damages and his official capacity for injunctive rel ief from negligent supervision, neglect to prevent the abuse, corruption, and fraud rampant in subordinate agencies, and for continuing to fund the human trafficking scheme despite reports of the atrocities. His address is: [400 S. Monroe St. Tallahassee, Florida 32399)
85. Defendant TOM WOLF (“WOLF”), upon Plaintiffs information and belief is the Governor of PENNSYLVANIA. Plaintiffs sue the said Defendant in his individual capacity for damages and his official capacity for injunctive relief from negligent supervision, neglect to prevent the abuse, corruption, and fraud rampant in subordinate agencies, and for continuing to fund the human trafficking scheme despite reports of the atrocities. His address is: [508 Main Capital Building, Harrisburg, Pennsylvania, 17120)
86. Defendant BRIAN KEMP (“KEMP”), upon Plaintiffs information and belief is the Governor of GEORGIA. Plaintiffs sue the said Defendant in his individual capacity for damages and his official capacity for injunctive relief from negligent supervision, neglect to prevent the abuse, corruption, and fraud rampant in subordinate agencies, and for continuing to fund the human trafficking scheme despite report of the atrocities. His address is: [206 Washington St., 111 State Capitol, Suite 203, Atlanta, Georgia 30334)
87. Defendant BILL LEE (“LEE”), upon Plaintiffs information and belief is the Governor of TENNESSEE. Plaintiffs sue the said Defendant in his individual capacity for damages and his official capacity for injunctive relief from negligent supervision, neglect to prevent the abuse, corruption, and fraud rampant in subordinate agencies, and for continuing to fund the human trafficking scheme despite reports of the atrocities. His address is: [State Capitol, First Floor, Suite 600 Dr. Martin Luther King Jr. Blvd Nashville, Tennessee 37243]
88. Defendant MICHEAL DUNLEAVY (“DUNLEAVY”), upon Plaintiffs information and belief is the Governor of ALASKA. Plaintiffs sue the said Defendant in his individual capacity for damages and his official capacity for injunctive relief from negligent supervision, neglect to prevent the abuse, corruption , and fraud rampant in subordinate agencies, and for continuing to fund the human trafficking scheme despite reports of the atrocities. His address is: [P .0. BOX 110001 Juneau, Alaska, 99811- 0001]
89. Defendant KATHLEEN LAURA KELLY (“KELLY”), upon Plaintiffs information and belief is the Governor of KANSAS. Plaintiffs sue the said Defendant in her individual capacity for damages and her official capacity for injunctive relief from negligent supervision, neglect to prevent the abuse, corruption, and fraud rampant in subordinate agencies, and for continuing to fund the human trafficking scheme despite reports of the atrocities. Her address is: [State House 300 South West 10th Ave, #241s, Topeka, Kansas 66612]
90. Defendant KATHY HOCHUL (“HOCHUL”), upon Plaintiffs information and belief is the Governor of NEW YORK. Plaintiffs sue the said Defendant in her individual capacity for damages and her official capacity for injunctive relief from negligent supervision, neglect to prevent the abuse, corruption , and fraud rampant in subordinate agencies, and for continuing to fund the human trafficking scheme despite reports of the atrocities. Her address is: [NYS State Capitol Building, Albany, New York 12224]
91. Defendant GRETCHEN WHITMER (“WHITMER”), upon Plaintiffs information and belief is the Governor of MICHIGAN. Plaintiffs sue the said Defendant in her individual capacity for damages and her official capacity for injunctive relief from negligent supervision, neglect to prevent the abuse, corruption, and fraud rampant in subordinate agencies, and for continuing to fund the human trafficking scheme despite reports of the atrocities. Her address is: [111 S. Capitol Ave., Lansing, Michigan 48933]
92. Defendant JACKEY LACEY (“LACEY”), upon Plaintiffs information and belief is the former Attorney General of LOS ANGELES COUNTY. Plaintiffs sue the said Defendant in her individual capacity for damages and her official capacity for injunctive relief from negligent supervision, neglect to prevent the abuse, corruption, and fraud rampant in the Los Angeles County Courts, and for continuing to fund the human trafficking scheme despite reports of the atrocities. Her most recently know address is [300 S. Spring St. Los Angeles CA 90013]
93. Defendant ROB BONTA (“BONTA”) upon Plaintiffs information and belief is the present Attorney General of LOS ANGELES County. Plaintiffs sue the said Defendant in his individual capacity for damages and his official capacity for injunctive relief from negligent supervision, neglect to prevent the abuse, corruption, and fraud rampant in the Los Angeles County Courts, and for continuing to fund the human trafficking scheme despite reports of the atrocities. His address is [300 5. Spring St. Los Angeles CA 90013-1230).
94. Defendant KEN PAXTON (“PAXTON”) upon Plaintiffs information and belief is the present Attorney General of Texas. Plaintiffs sue the said Defendant in his individual capacity for damages and his official capacity for injunctive relief from negligent supervision, neglect to prevent the abuse, corruption, and fraud rampant in the state Texas, and for continuing to fund the human trafficking scheme despite reports of the atrocities. His address is: [ P.O. Box 12548 Austin, Texas 78711-2548).
95. Defendant JAIMIE MASTERS (“MASTERS”), upon Plaintiffs information and belief is the present Commissioner of the Department of Family and Child Protective Services. Plaintiffs sue the said Defendant in her individual capacity for damages and her official capacity for injunctive relief from negligent supervision, neglect to prevent the abuse, corruption, and fraud rampant in the state of Texas, and for continuing to fund the human trafficking scheme despite reports of the atrocities. Her address is: [ P.O. Box 149030 Austin, Texas 78714-9030).
96. Defendant WILLIAM CLARK (“CLARK”), upon Plaintiffs information and belief is the PRESIDENT OF SAINT FRANCIS MINISTRIES. Plaintiffs sue the said Defendant in his individual capacity for damages for negligent supervision, neglect to prevent the abuse, corruption, and fraud rampant in the state of Texas, and for continuing to fund the human trafficking scheme despite reports of the atrocities. His address is: [509 E. Elm St., Salima, Kansas, 67401).
97. Defendant St. Francis Ministries [4155 E. Harry St., Wichita, Kansas, 67218).
98. Defendant Kids Central Inc Aka The Centers Inc. [901 Industrial Dr., Suite 200, Wildwood, Florida 34785).

99. Defendant MARICOPA COUNTY ARIZONA [301 W. Jefferson St., Phoenix, Arizona 85003).
100. Defendant SEBASTIAN COUNTY ARKANSAS [901 B. St. 5, Suite 209, Fort Smith, Arizona 72901). 87. Defendant SCOTT COUNTY ARKANSAS [100 W. 1^st Waldron, Arkansas 72958).
101. Defendant LOS ANGELES COUNTY CALIFORNIA [300 5. Spring St. Los Angeles California 90013).
102. Defendant RIVERSIDE COUNTY CALIFORNIA [3960 Orange St., Riverside, California 92501)
103. Defendant MONTEREY COUNTY CALIFORNIA [142 W. Alisal St., Suite A, Salinas, California 93901).
104. Defendant MARION COUNTY FLORIDA [601 SE 25^th, Ocala, Florida 34471).
105. Defendant MIAMI-DADE COUNTY FLORIDA (1350 NW 12^TH, Miami, Florida 33136).
106. Defendant ST. LUCIE COUNTY FLORIDA [411 5. 2No St., Fort Pierce Florida, 34509).
107. Defendant CAMDEN COUNTY GEORGIA [210 E. 4th St., Woodbine, Georgia, 31569).
108. Defendant LAURENS COUNTY GEORGIA [101 N. Jefferson St., Dublin, Georgia, 31021).
109. Defendant HUTCHINSON COUNTY KANSAS [120 SW 10th ^Ave, Topeka Kansas]. 97.
110. Defendant SEDGWICK COUNTY KANSAS (18th Judicial District of Kansas, 1900 E. Morris Wichita, Kansas 67211]. 98.
111. Defendant ST. MARY’S COUNTY MARYLAND [23110 Leonard Hall Dr., Leonardtown, Maryland, 20650).
112. Defendant KENT COUNTY MICHIGAN [8201 Ionia Ave NW, Grand Rapids, Michigan, 49503).
113. Defendant OAKLAND COUNTY MICHIGAN [1200 N. Telegraph Rd., West Wing-Building 14E Pontiac, Michigan, 48341)
114. Defendant BERNALILLO COUNTY NEW MEXICO [Steve Schiff District Attorney Building, 520 Lomas NW, Fourth Floor Albuquerque, New Mexico 87102).
115. Defendant KINGS COUNTY NEW YORK [350 Jay St. 16th Floor, Brooklyn, New York 11201).
116. Defendants MONROE COUNTY NEW YORK (47 5. Fitzhugh St. Rochester, New York 14614).
117. Defendant WASHINGTON COUNTY OHIO [205 Putnam St., Marietta, Ohio, 45750).
118. Defendant ALLEGHANY COUNTY PENNSYLVANIA [300 Fort Pitt Commons Building, 445 Fort Pitt Blvd., Pittsburg, Pennsylvania 15219].
119. Defendant MCLENNAN COUNTY TEXAS [219 N. 6th St. #200 Waco, Texas 76701].
120. Defendant BELL COUNTY TEXAS [1201 Huey Dr., Belton, Texas, 76513].
121. Defendant WICHITA COUNTY TEXAS [900 7th St. Wichita Falls, Texas, 76301].
122. Defendant BLOUNT COUNTY TENNESSEE [942 E. Lamar Alexander Pkwy., Blount County Justice Center, Maryville, Tennessee, 37804].

1. JURISDICTIONAL STATEMENT

123. This Court has subject matter jurisdiction under): 28 U.S. Code § 1331 because of the Federal Question of Law Jurisdiction and Art.1., section 9 clause 2 of the United States Constitution (suspension clause).
124. 28 U.S.C. § 1332 (2) because the matter of controversy is over $5,000,000.
125. 28 U.S. Code § 1332 (diversity of citizenship),
126. 28 U.S. Code § 1343 3 (a) (3), (civil rights), because additionally, plaintiff has a federal question of law regarding “Are the current juvenile dependency laws under state statutes unconstitutional?” [ See Troxel v. Granville (2000) 530 US 57, 147 L. Ed 2d 49, 120 S. Ct. 2054].
127. 28 U.S. Code § 1346 (United States as defendant).
128. 28 U.S.C. §1343, which provides that the District Court shall have original jurisdiction, exclusive of the States, of any action authorized by law to be commenced by any person:
129. To recover damages for injury to his person or property, or because of deprivation of any right or privilege of the citizen of the United States, by an act done in the furtherance of a conspiracy mentioned in 42 U.S.C. §1985;
130. To recover damages from any person who fails to prevent or to aid in preventing any wrongs mentioned in section 1985 of Title 42 which he had knowledge were about to occur and power to prevent;

• To redress the deprivation, under color of any State law, statute, ordinance, regulation, custom or usage, of any right, privilege or immunity secured by the Constitution of the United States or by any Act of Congress providing for equal rights of citizens or of all persons within the jurisdiction of the United States;

1. To recover damages or to secure equitable or other relief under any Act of Congress providing for the protection of civil rights, including the right to vote.
2. 28 U.S.C. §1355, which provides that “[t]he District Court shall have original jurisdiction, exclusive of the States, of any action or proceeding for the recovery of any fine, penalty, or forfeiture, pecuniary or otherwise, incurred under any Act of Congress…”
3. 28 U.S.C. §1357 because the District Court shall have original jurisdiction of any civil action commenced by any person to recover damages for any injury to his person or property on account of any act done to him, under any Act of Congress, for the protection or collection of any revenues, or to enforce the rights of citizens to vote in any state.
4. 28 U.S.C. §1361 because the District Court shall have original jurisdiction of any action in the nature of mandamus to compel an officer or employee of the United States to or any agency thereof to perform a duty owed to the plaintiff.
5. 28 U.S.C. § 1367. The U.S. District Court may also exercise supplemental jurisdiction over the plaintiff’s state law claims that arise from the same facts and circumstances
6. The following are the Congressional Acts that the defendants failed to adhere to but instead used to abuse and injure plaintiffs further:
7. The American Disabilities Act
8. 5 U.S.C. §§ 551–559 Administrative Procedure Act, was signed into law on June 11th 1946.
9. 42 U.S.C §5101 (2018) et seq; 42 USC 5116 et seq, and 45 CFR 1340. Child Abuse Prevention and Treatment Act
10. The Civil Rights Act of 1871.  Signed into law by President Ulysses s. Grant on April 20th 1871.
11. The Civil Rights Act of 1964
12. 12 U.S.C. § (1978). The Ethics in Government Act, (Signed into law by President Jimmy Carter on October 26th 1978.)
13. The Family First Prevention Services Act, 2018. This was signed into law on February 9th 2018.
14. The False Claims Act passed by Congress on March 2, 1863.
15. The Freedom of Access to Clinic Entrances Act of 1994. (Signed into law by President Bill Clinton on May 26, 1994)
16. 18 U.S.C. § (1951) The Hobbs Act
17. The Human Trafficking Prevention, Intervention, & Recovery Act. H.R. 350 – Human Trafficking prevention, intervention, and Recovery Act of 2015 114th Congress (2015-2016).
18. The Justice for Victims of Trafficking Act Preventing Sex Trafficking and Strengthening Families Act of 2014. Signed into law on Sep 29th, 2014, by President Obama.
19. The Preventing Sex Trafficking and Strengthening Families Act. Preventing sex Trafficking and Strengthening Families Act 42 USC 1305. Sept 29th, 2014.
20. 31 U.S.C. 3801-3812 – The Program Fraud Civil Remedies Act (PFCRA) enacted by congress in October of 1986.
21. 18 USC 1959-1964 – The Organized Crime Control Act- RICO. 9-110.000 – Organized Crime and Racketeering was signed into law on October 15th, 1970.
22. 31 U.S.C. §§ 3729 – 3733 –The Qui Tam False Claims Act – allows whistle-blowers to bring lawsuits against companies and individuals who defraud the Federal Government.
23. 42 USC 301- 1305 – The Social Security Act 4,1934.
24. The Stop Advertising Victims of Exploitation Act (SAVE ACT of 2014). This bill was introduced into the U.S. House of Representatives during the 113th U.S. Congress.
25. The Strengthening Child Welfare Response to Trafficking Act R. 469-114th congress (2015-2016)
26. 18 USC 1361 – The Take Care Act
27. The Tort Claims Act – Federal and State and [See Heath v. Cleary (9th Cir 1983) 708 F2d 1376, 1378]
28. The Trafficking Victims Protection Reauthorization Act H.R. 898 – 113th Congress (2013- 2014)
29. The Victims of Child Abuse Act Title II: Victims of Child Abuse act of 1990.
30. Venue is proper in this Court in accordance with 28 U.S. Code § 1391(b), which states that: “A civil action may be brought in – (2) a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred.”
31. All relevant facts, acts and incidents in support of plaintiffs’ causes of action took place inter-state throughout all states in the United States. Because of the diversity of citizenship, the above-mentioned court has jurisdiction and is the proper venue to bring a complaint.

1. MASS TORT FACTUAL ALLEGATIONS

159. The factual allegations shall be set out as per each Plaintiff.

160. Complainant contends that on or about February 2016, Theresa Mesa, a Social Worker, LADCFS, and LA Police Department Officers came to the Complainant’s home and removed the Complainant’s children without warrant, court order, or by providing reasonable efforts to prevent removal which is against the Welfare Institutions Code.
161. They committed perjury, swore a false oath, and filed false documents at a detention hearing by saying the Complainant’s children were in “imminent danger.”
162. They used excessive continuances, beyond the statute of limitations to find any reason they could to remove her children.
163. Complainant’s public defender, the children’s attorney, and the prosecutor all worked together to hurl malicious accusations and suppress any exculpatory evidence for her.
164. The courts of California then tried to maliciously prosecute Complainant in criminal court for defending herself and her children against an abuser.
165. She won her criminal case, but Los Angeles DCFS removed her two youngest children anyway and refused to return them despite not having any evidence of wrongdoing.
166. Plaintiff suffered emotional distress and severe insomnia because of these actions.
167. Social workers vaccinated complainant’s children without consent in violation of HIPPAA.
168. Higher courts ignored appeals and complaints from complainant, siding with the judge who was biased to the department.

169. The Complainant filed an affidavit stating that Maycock Tashana violated Soc. Serv. Law § 413. Notably, on or about January 25, 2017, Complainant’s child had a circumcision performed, and he had to return to Mount Sinai hospital on February 14, 2017, for a post-surgery appointment. During the weekend of February 12, 2017, the child was underdressed, and the child should have warmer clothing, especially after a blizzard. Complainant asked Maycock about the child’s appearance and wanted to make sure that lateness was not an issue for the upcoming appointment. Ms. Maycock became aggressive and cursing at Complainant and used inappropriate sentences to describe her displeasure about the appointment and she would not attend it.
170. In a previous fictitious petition, Ms. Maycock stated that she was being recorded during pick-ups and drop-offs. Complainant recorded the interaction, and she was portrayed as being something different than what was recorded. Upon the departure from Ms. Maycock, Complainant filled out one of her many Domestic Violence Reports. On the day of the doctor’s appointment, Ms. Maycock returned to the precinct after 36 hours to file a report. After receiving the report, she went to family court and obtained an order of protection against Complainant without being present or even looking into Complainant’s prior reports (12 reports unanswered by the court).
171. Claimant also alleges that Maycock is liable for Harassment and Identity theft (The reason why Claimant requested for pick up and drop offs at the 78 precincts because Ms. Maycock threatened her and she violated the tort defined in Domestic Violence Civil Laws Citation: Soc. Serv. Law § 459-a. Claimant contends that such act or acts have resulted in actual physical or emotional injury or have created a substantial risk of physical or emotional harm to Claimant. Along with committing the tort, Claimant further contends that Ms. Maycock has committed other torts such as assumption of risk (during pick-ups and drop-offs and the child has new bruises); suborning perjury (per Summers v. Tice); intentional and negligent misrepresentation (during the respondent’s affidavits); and fraud and related activity in connection with computers for illegal fillings for child support.
172. Complainant contends that Fried Alan, as Attorney, committed several torts under general duty. Accordingly, Complainant contends Fried is liable for suborning perjury, intentional and negligent misrepresentation, abuse of process and malicious prosecution, and conspiring both against Complainant’s human rights and constitutional rights when he suggested that Complainant must undergo a mental health analysis and another CPS visit.
173. Complaint also contends that Love Ayanna as the child’s lawyer, committed several torts under general duty. Accordingly, Complainant contends Fried is liable for suborning perjury, intentional and negligent misrepresentation, abuse of process and malicious prosecution, and conspiring both against Complainant’s human rights and constitutional rights when it was suggested that Complainant must undergo a mental health analysis and another CPS visit.
174. Complaint further states that Judith Waksberg, as the Presiding judge, unreasonably inflicted or allowed harm to be inflicted, or a substantial risk thereof, including the infliction of excessive corporal punishment in failing to provide the child with proper supervision or guardianship. Waksberg had a general duty to protect the constitution and protect others’ rights; she did not do that for Complainant. When Complainant asked for a subpoena from the 78th PCT, they documented Ms. Maycock’s unfortunate behavioral patterns and unhealthy attendance patterns. Accordingly, Complainant contends that the Judge committed an abuse of process and malicious prosecution. During multiple court appointments, Waksberg noticed that Ms. Maycock had a tardiness issue but she ignored it and this action violated assumptions of risk. It also proved that she was late on purpose, but it demonstrated the lack of conviction towards authority.
175. Complainant alleges that Fasone John, Child Support Magister, entered a fictitious order in the system against Complainant on September 23, 2019. Notably, Complainant has been taking care of the child in a private capacity via Citibank; the child has had this account since he was six months. Robin Maycock, who is the child’s grandmother, went down to Social services signed up for Medicaid and babysitting money. Such actions like this are in clear violations of multiple laws such as the Social Security Act (recently enacted on December 2020, section 203), Office of Inspector General (OIG), and Medicaid fraud. Complainant never submitted W’2 information, and they took Complainant’s income, which is another violation of the 4th amendment. Accordingly, Complainant contends Fasone is liable for suborning perjury, intentional and negligent misrepresentation, abuse of process and malicious prosecution, and conspiring both against Complainant’s human rights and constitutional rights.
176. Complainant contends that Hozer-Weber, Ana, Child Support Magister, Weber colluded with the Social Services attorney to seek rears from the time the order was filed since February 2019. As stated before, Complainant brought the fact that Tashana Maycock had fraudulently tried to abuse the system with two filled frivolous petitions; they were later dismissed due to no-shows from her. Complainant spoke about the bank account; he mentioned the agencies’ guidelines from the Social Security Act (recently enacted on December 2020, section 203), Office of Inspector General (OIG), and Medicaid fraud. Besides, he never submitted W’2 information, and they took Complainant’s income which is another violation of the 4th amendment. Accordingly, Complainant contends Weber is liable for suborning perjury, intentional and negligent misrepresentation, abuse of process and malicious prosecution, and conspiring both against Complainant’s human rights and constitutional rights.
177. Complainant contends that Landaverde Kathleen, Case Manager at the Appellant Court, had a general duty to submit court paperwork and not appear to infringe against Complainant’s right or collude with the opposing parties. Complainant did not ask for a case manager and does not know why he was given one after his first appeal. Complainant told Kathleen that he did not need a case manager. She proceeded to email Complainant all these rules regarding the court and why she is essential within Complainant’s appeal process. Accordingly, Complainant contends Kathleen is liable for suborning perjury, intentional and negligent misrepresentation, abuse of process and malicious prosecution, and conspiring both against Complainant’s human rights and constitutional rights.
178. Complainant contends that Maycock, Robin, the child’s Grandmother, committed multiple accounts of fraud, identity theft, Medicaid fraud, Child Support Fraud, in violation of 18 U.S. Code § 1030. She also committed suborning perjury and intentional and negligent misrepresentation (during the respondent’s affidavits).

Amber Brandt

179. Complainant contends that Ayoubi Yassir, her ex-husband, committed child abuse, document fraud, deprivation of rights, conspiracy, and child trafficking/child exploitation.
180. Complainant further alleges that Lopinski, Tom and Lisa, her Mother and stepfather, committed child abuse, document fraud, deprivation of rights, conspiracy, and child trafficking/child exploitation.
181. Complainant contends that Byrdsong, Kristen, an unlicensed commissioner, committed child abuse, document fraud, deprivation of rights, conspiracy, and child trafficking/child exploitation.
182. Complainant avers that Social Worker Beeri Ohn-Bar committed child abuse, document fraud, deprivation of rights, conspiracy, and child trafficking/child exploitation.
183. Complainant avers that Resource Officers Vargas/Rodrieguz and Serg Turner, committed child abuse, document fraud, deprivation of rights, conspiracy, and child trafficking/child exploitation, and violated the 5th and 14th amendment.
184. On May 2019 I went DCFS for help because my son then 10, my daughter then 8 and I were in and egregious abusive relationship/marriage.
185. Plaintiff’s ex busted/ bleed her son’s lip numerous times, uses corporal punishment on them, cold showers, sexually abuses my daughter to the point she is having early signs of liver failure, abused my son to the point of suicide attempts/psych hospitalizations.
186. Plaintiff told DCFS on June 2019 she informed DCFS that her children’s performance all around was improved when her ex was having less contact. Zayd and Farida stopped wetting the beds and Farida stopped having accidents, including school.
187. Accidents and anxiety sky rocketed when DCFC/BUSD school system/Burbank Police Dept/Ed Edelman Court forced/colluded/coerced/abused my children to be afraid to speak their truth and or continue.
188. Plaintiff had to homeschool Oct 2019 due to her children’s health. Yassir disregarded their health, took Plaintiff to court and told the commissioner he wants them in public school. Plaintiff had to ‘Immediately’ enroll them. Demanded a lawful definition of ‘Immediate’ and began to do so the next day.
189. On Dec 17th 2019 they had unlawful removal order for Zayd and Farida coupled by fraudulent statements by BPD.
190. On Dec 20th I finally learned they were stealing them and demanded to see Federal Warrant since they claimed they could take my son and daughter. I told DFCS they WILL NOT inflict the trauma on Zayd and them from their home and said I will meet them at the DCFS office.
191. The situation was emotional, however that is not the reason a warrant was not presented… there was never one. Beeri Ohn-Bar is well documented of putting my children in the arms of abuser grandparents, Tom and Lisa Lopinski and Yassir Ayoubi, an abusive sexual predator.
192. Plaintiff have not seen my son or daughter since March 16th 2020 nor spoken to them since Dec 2020.Anytime I attempt to protect my son or daughter and they report abuse, they or I or both are punished for it by ripping them from protective loving mother, cutting phone calls, visitations and imposing frivolous unlawful restraining orders.

Laurie Reynolds

193. Complainant avers that Reynolds, Mark, her Ex-Husband, violated her child’s rights, Gray Xavier, who he is a non-relative to, by invoking parental alienation, assault and battery with no criminal charges pressed against him. Mark also violated Complainant’s daughter’s federal right at the age of two by kidnapping and being registered at the National Center for Missing and Exploited Children as a result, denying her access to nursing for a week.
194. Complainant also contends that the Family integrity Program, under the Florida Department of Children and Families, violated at least five counts of the right to due process including the right to a shelter hearing when they removed Complainant’s children from the home of the other party after he fell into a coma and placed them into a home of former non-relatives without Complainant’s (mother’s) permission in November 2018. Human rights were violated when Complainant’s son, Gray, age 9, suffered assault and battery from the other party on March 7, 2019, and he expressed wanting to come home. Yet, they left him and Complainant’s daughter in the abuse by suggesting a permanent guardianship to the court.
195. Florida Department of Children and Families violated at least five counts of the right to due process including the right to a shelter hearing when they removed my children from the home of the other party after he fell into a coma and placed them into a home of former non- relatives without my (mother’s) permission in November 2018.
196. Human rights were violated when my son, Gray, age 9, suffered assault and battery from the other party on March 7, 2019 and he expressed wanting to come home. Yet, they left him and my daughter in the abuse by suggesting a permanent guardianship to the court.
197. Mark Reynolds, Laurie Reynolds the other party, in possession of Gray and Skye, attempted strangulation on me in St. Augustine, Florida in our home by grabbing me with his right hand, picking me up under the jaw, cutting off my air flow for three seconds, and throwing me to the ground. Because he gaslighted and threatened me, I did not file a police report.
198. September 2016: Mark Reynolds, Laurie Reynolds. We begin living separately under the same roof. I begin a DivorceCare class at Anastasia Baptist Church in St.Augustine.
199. August 2017: Parties: Laurie Reynolds, DivorceCare administrators, Jim and Sharon, A church member offered a safe house for the children and me to move to.
200. September 2017: Parties: Mark Reynolds, Laurie Reynolds, Gray and Skye, National Center for Missing and Exploited Children Hurricane Irma prompted all of us, including the other party, to leave the state. In Ohio, the other party was registered with the National Center for Missing and Exploited Children as he kidnapped my daughter and prevented her from nursing.
201. September 2017: Mark Reynolds, Richard Thibault Filed for dissolution of marriage from Mark Reynolds. September 2017:
202. Parties: Mark Reynolds, Katina (DCF worker, two unknown police officers)
203. My daughter Skye is returned after the FBI searched for him. I fled with the kids to the hidden safe house. DCF speaks to my son at Saint Augustine Public Montessori School before I came to pick him up. They stated they would help after I explained we were escaping domestic violence.
204. Many days later, at a meeting with Katina (last name unknown, DCF worker) two police officers show up, armed, and rip my kids away. I call my lawyer. He states there would be a shelter hearing the next day where Richard Thibault, private attorney, coerced me into signing the parenting plan against my will and without explaining my rights, denying my right to a trial.
205. October 2017: Parties: Richard Thibault, John M. Alexander, Mark Reynolds: The other party files an injunction stating I hit him in order to gain custody of the children. He gains custody.
206. January 2018: Parties: Florida DCF, Laurie Reynolds, Mark Reynolds, Judge John M. Alexander: A shelter hearing places the children further into the abusive home while I complete the parenting plan.
207. November 2018: Parties: Mark Reynolds, Laurie Reynolds, DCF, Judge John M. Alexander The other party falls into a prolonged coma. The judge files an order stating that placing my children without a shelter hearing was unlawful and highly disfavorable. My lawyer cites five counts of violating the right to due process including the right to a shelter hearing. The judge still leaves the children with these unknown non-relatives until the other party barely is released from the hospital, and in bad health, the children are placed back with him.
208. March 7, 2019: Parties: Gray Reynolds, Mark Reynolds, Saint Augustine Public Montessori School: My son, Gray, aged 9, is assaulted and battered by my ex-husband, his legal guardian, and a police report is filed against him by Saint Augustine Public Montessori School and his teacher, Ms. Charlene. The DCF investigator, Suzanne Hirst, left them in the abuse instead of bringing them home.
209. May 2019: Parties: Judge John Alexander, Laurie Reynolds, Mark Reynolds, Emily Earnest, Thompson
210. The dependency case is closed to a permanent guardianship for my ex-husband who abuses them even though two witnesses, including a DCF investigator, Thompson, declared I was safe for all three children and their younger brother Silas was never taken from me, and my daughter Skye was declared sage to be with me as well. Strangely, only my son Gray I was declared to be unsafe around due to emotional distress.
211. Two weeks later, the judge files an order for permanent guardianship for my son, Gray, who Mark Reynolds never adopted, and left my daughter there in a sibling placement, violating Florida statutes that a declaration of substantial.

Tijana Vidanovic

212. Complainant avers that Huang Joy, a Social Worker who was in training when Complainant’s case was going on, violated the 4th and 14th Amendment, and Basic Human Rights of Complainant and her Son, Sava Theodore.
213. Complainant contends that Gomez Danette, a Judge, violated Article 1, Article 2 and Article 5 of Human Rights and 14th Amendment.
214. On October 7th Los Angeles DCFS came to the Holly Cross Hospital in Mission Hills and detained than my newborn son due to my positive drug screening.
215. I immediately asked them for help and begged them not to take my son, but the CSW Baghdeserian told me that they can”t help me;and that he is there just to detain my son.
216. Afterwards, I went to Court got the case plan and after refusal of SW Huang’s help; I found all the needed help by myself and completed my whole case plane and much more by November of 2017.
217. Nevertheless, Judge Gomez involuntarily terminated my parental rights in December of 2018, without any given valid reason.
218. I was shocked to hear Judge’s decision and I asked her why she terminated my rights; on which she replied: “Because I said so!”
219. Therefore, my son and I unfairly inhumanly separated, not because I failed to do something, but because Judge Danette Gomez said so.
220. Judge Danette Gomez exceeded the bounds of reason by Court by ignoring substantial evidence that proves that I fulfilled all obligations set before me; It was reversible error to deny me reunification due to my completion of the case plan and my progress and the bond my son had with me.
221. The juvenile court found that Mother had changed her circumstances and carried her burden in proving her changed circumstances. (11 RT 417) 19 Sacramento v. Drew (1989) 207 Cal.App.3d 1287, 1297.)
222. It was an undisputed fact that I changed my circumstances. The Judge with a bias decided that return of custody of my son doesn’t serves in his best interest. With which my son’s attorney Tracy Hendrix strongly disagreed. My son’s GAL recommendation was immediate return of my son to my custody, and she is only one who observed my son while he was detained by Los Ángeles DCFS.
223. Therefore, her recommendation speaks volumes, especially considering that the bond study that I requested was denied every time and that Judge never even see my son and his interactions and good spirits with me vs his interactions and overall state while in DCFS custody and with foster parents, who failed in times to properly care for him, but we’re allowed to adopt him.
224. Judge Danette Gomez committed reversible error in finding that beneficial Parent- Child relationship was exception to adoption and then terminating my rights, without any explanation or proof of evidence why termination happened.
225. My son shared a beneficial Patent-Child relationship with me, making termination of my, parental rights erroneous and my son will be the one who is harmed by its severance.
226. My case is not an unique case and drug addiction is a serious issue, but recovery can and does happen. It has in my case. I reclaimed my life and I am living free from addiction. With continued and strong sobriety under my belt, and God in my life, I have four years free from addiction.
227. I completed an inpatient and outpatient substance abuse program. Today I have a sponsor and a commitment to AA/NA meetings and other groups.
228. My case demonstrated that I addressed the conditions that gave rise to dependency and that it was in my son’s best interest to be returned to me.
229. Judge Danette Gomez made an irreversible error by terminating my rights. In the alternative, as I proved that the benefit exception to adoption existed, Judge Gomez denied me the opportunity to remain a part of my son’s life and to provide and care for him as Mother should.

Cecelia Evertez

230. Complainant avers that Randolph, Kevin, a Judge in the termination of guardianship., violated Complainant’s rights under 1st, 4th, 5th and 14th Amendment of the Constitution of the United States of America.
231. Complainant further avers that Vincent Tinnerello, Supervisor, Department of Children and Families, violated Complainant’s rights under 1st, 4th, 5th and 14th Amendment of the Constitution of the United States of America.
232. Complainant contends that Bringman, Jennifer, Case Worker for Termination of Parental Rights, violated Complainant’s rights under 1st, 4th, 5th and 14th Amendment of the Constitution of the United States of America.
233. Complainant also avers that Roberts, Tasheedah, an Attorney, violated Complainant’s rights under 1st, 4th, 5th and 14th Amendment of the Constitution of the United States of America.
234. Cecelia and Antonio Evertez are the grandparents of Mariah E.- F. and Dora E. – F. On March 6, 2015 our Grandchildren were taken into custody by the Department of Children and Families (DCF). This case is predicated on false allegations and lies and every attempt to expose the truth was denied. The information contained herein is proof that the false allegations and lies are in violation of the Constitution as set forth in section 18 USC 242 deprivation of right and a violation of the 1st, 4th, 5th, and 14th amendment. Below is a sequence of events and the participants who took part in this case which led to an unwarranted termination of guardianship.
235. Judge Kevin Randolph was the presiding judge at the initial trial. Prior to the case going to trial all the attorneys including the prosecuting attorney agreed to dismiss the case if my Husband and I would agree to sign a no contest form.
236. My Husband and I agreed to sign the no contest form in order to be reunited with our Grandchildren.
237. However, in spite of this agreement Judge Kevin Randolph angrily rejected the no contest agreement and the case went to trial. The trial did not cover pertinent factors to establish our innocence or guilt by the defense attorneys or the prosecuting attorney. Pertinent to the trial was an allegation of sexual assault to one of my Grandchildren which was reported to the police by my Husband; this matter was not covered during the trial. There was a DCF employee who testified in Court regarding a safety agreement which was signed by my Husband. A third notable testimony at the trial was Family and Children’s Aid; the two therapists for my Grandchildren; MCCA and other service providers who testified in Court who were in favor of reunification (See Exhibit 1). Oddly, the trial was predominantly interceded with objections by Judge Kevin Randolph regarding incorrect cross examinations of witnesses by the attorneys. Judge Kevin Randolph ruled against our case and on December 23, 2015 my Grandchildren were committed to the Department of Children and Families.
238. Judge Kevin Randolph’s decision was based on allegations by DCF which were not covered during the trial and my Husband and I were unaware of many of these false allegations and lies to defend ourselves or ask our attorney to challenge these false allegations and lies. In Judge Kevin Randolph’s Memorandum of Decision, he states that I signed a safety agreement on July 13, 2012, this is not true (See Exhibit 2).
239. Further, Judge Kevin Randolph ‘s report of Ofori Koran, an investigative social worker, is incorrect. In meeting Ofori Koran his attire was unacceptable, he wore a wrinkled shirt which was slightly smelly. At that time, I had an 11 year old Granddaughter, Ofori Koran informed us of his engagement to get married and has a 2 ½ year old son. I felt compelled not to sign the safety agreement which Judge Kevin Randolph speaks of due to Ofori Koran’s attire, mannerism an of his lecture.
240. When Ofori Koran returned the next day, my Husband signed the safety plan solely because we came to the conclusion, we cannot allow our Daughter to have unsupervised visits to avoid further conflicts with DCF. When the trial ended, I distinctly remember Judge Kevin Randolph ask DCF if they were in favor of reunification of our Grandchildren and DCF replied they were in favor of reunification.
241. My Husband and I continued to comply with DCF’s service plan and we were very hopeful we would be reunited with our Grandchildren. My Husband and I could not afford to hire another attorney to appeal Judge Randolph’s decision, therefore, I attempted to be a pro se litigant.
242. Attorney Tasheedah Roberts became the attorney for my Grandchildren after the trial ended under the direction of Judge Kevin Randolph. Attorney Roberts replaced Attorney Bruce Schreiber who was in favor of reunification. As Attorney Roberts did not partake of the trial she missed out on the fundamental facts of the case. I had very little she would make arrangements to meet at my home; Attorney Roberts never fulfilled her promise. On another occasion, prior a judge making his entrance to the courtroom, I gave Attorney Roberts a list of rebuttals to the lies and misrepresentation by Jennifer Bringman, the DCF caseworker who was part of the TPR proceeding; Attorney Roberts did not respond to my list of rebuttals (See Exhibit 2). In an attempt to give Attorney Roberts my side of the story regarding the case, Attorney Roberts began to yell at me over and over again and said I was trying to entice an argument; nothing could be further from the truth. All in all, my case and it’s interaction with Attorney Robert was no more than 10 minutes of her time with me. Thereafter, my Grandchildren were adopted and had a name change without my knowledge.
243. On January 3, 2021 I submitted to the Court a Writ of Mandamus in the Interest of Justice and Immediate Relief (See Exhibit 8). This matter was addressed in Court on January 7, 2021 and was denied.
244. On January 12, 2021 I submitted to the Court a Motion of Reconsideration (See Exhibit 9) this Motion was denied. I now seek justice from the Federal Government of the United States of America for relief of injustice.
245. On April 8, 2016 my Husband and I met with Vincent Tinnerello, a supervisor at DCF. This meeting was at the suggestion of my therapist; therapy was a part of our service plan by DCF. My therapist thought a supervisor can resolve the issues with the foster care family as there were so many reasons to not have my Grandchildren in foster care. We were also hoping to increase our visitation to more than three days a week in our endeavor for reunification with our Grandchildren. There were many issues which were not in the “best interest of the children” in foster care – ring worms; front teeth chipped off; failing grades; poor attire and our Grandchildren were frequently placed in other foster homes by the foster family for family vacations, early school dismissals, etc. Vincent Tinnerello reacted unconcerned regarding these issues. “In the best interest of the children,” reacted very bizarrely and he abruptly left the room and this meeting set the stage for Termination of parental Rights (TPR).
246. In an email dated 9/14/2016 Jennifer Bringman informed me she is replacing our former caseworker, Shavonne Dash. My first in-person interaction with Jennifer Bringman was met by hostility by Jennifer Bringman in Court. Jennifer Bringman made a statement which was inaudible but she also stated she thinks my Husband and I allowed our Daughter to attend an in-home visit with our Grandchildren which is not true. Under the direction of Jennifer Bringman came an influx of additional false allegations and lies too numerous to list here, however, a brief list of Jennifer Bringman’s misinformation was distributed to all the attorneys (See Exhibit 3).
247. Additionally, Jennifer Bringman ignored her own organization’s findings whereas the State of Connecticut Department of Children and Families Investigation Protocol explicitly states the medical records of my Grandchildren were up to date. I, also, submitted to the Court an application to subpoena records to expose Jennifer Bringman’s lies regarding false statements of medical records. I also requested to get the testimony of the in-home service providers one of which was our previous case worker (See Exhibit 4).
248. It should also be understood that DCF and the Court will go to extreme measures to disrupt a family’s bond to the extent of being inhumane. For example, when our case changed to TPR we could no longer have in-home visits. DCF changed our weekly two-day unsupervised in-home visit plus a one day supervised visit to a one day three hour visit per week with supervision. This visit could not be in our home, the visit had to be supervised in a neighboring town. When winter approached, we could no longer go to parks and we could not find restaurants or other places to let us spend three hours together and our Granddaughter wanted to spend every moment of the three hours with us. My request to Jennifer Bringman and the Court for a one day in-door visit at our home was denied (See Exhibit 5).
249. Further, Jennifer Bringman and other members of DCF have successfully caused division in our family. For example, the oldest Granddaughter gradually stopped all visits with us. I explained this unusual behavior to my therapist and my therapist informed me to have family therapy; my Motion was denied by the Court (See Exhibit 6). My complaint to the Court dated 12/27/2017 was ignored (See Exhibit 7).
250. Another inhumane factor of DCF are the untrue comments DCF are telling my Grandchildren I said about them and the untrue made-up statements DCF will tell my Grandchildren I said about them; all to steer the case to their advantage.
251. Jennifer Bringman, DCF and the Family Court are relentless by any means in their endeavor to take Children.

Shanequa Austin

252. Complainant contends that Kimberly Cody, a Caseworker, violated Complainant’s Due process rights, Fraud, and perjury.
253. Complainant also avers that Dandera Rulhman, a Judge, violated Complainant’s Due Process rights, and intention to cause emotional harm when Complainant’s child’s life was never in danger.
254. Complainant further contends that Lindsay Crocetti, a Caseworker, committed perjury and fraud.
255. Complainant avers that Tessa, a caseworker, committed Fraud, Medical malpractice, and perjury.
256. Around December 6th 2015 I went to Strong hospital to get treatment for depression due to my baby cousin getting killed Kim Cody came to see me that Friday she informed that I don’t deserve to be a mother to my child because I suffer from Depression I told her she can’t remove my child based off that I asked her why didn’t she respect due process I was told she doesn’t have to respect due process because I’m mentally ill and anything she says about will hold immunity in court a couple months after Kim Cody got Tyshawn Parker removed from me with no warrant for the removal I never agreed to any contract in the beginning of my case so the removal wasn’t just because judge Rulhman never issued a warrant Kim cody said I Neglected my Son’s Health when he never missed a Doctor’s appointment.
257. Lindsay Crocetti Committed Purjury and fraud By saying My child has Fetal Alcohol Syndrome With no medical evidence She took my son for a private Behavior Health evaluation when he was 5 years old lindsay committed purjury in my family history far as my son biological assessment by saying everybody in my family suffer from Mental illinesses like my sister my mom and my brothers Lindsay Crocetti has also lied about my Mental Competence by saying I’m incompetent to parent my child because of my Mental health history she has lied on my Babyfather and said he doesn’t want to deal with me or want my baby in my care because of my Mental health.
258. Judge Rulhman removed my son Tyshawn 12-16-15 Due to purjury and Fraud No Due Process judge Rulhman placed my child on Mental health drugs without my consent knowing it’s against my Religous beliefs and knowing that it  will cause  harm to my child Tyshawn Parker tried to kill himself April 7th 2021 the doctors at Strong hospital discontinued his Ritalin he was on 32mgs every since he was 6 years old he was medicated every court Judge Rulhmann increased my son medication knowing it was causing harm to my child.
259. Tessa is a social worker from Strong Memorial Hospital.
260. May 10^th I met Tessa she kept trying to get me to say I had post-partum depression knowing I wasn’t depressed after I gave birth to my baby she kept harassing me telling me that I’m not leaving the hospital with my baby because my oldest son is foster care that has nothing to with my baby she told me I do drugs I don’t deserve my baby I told her if I really do drugs then why are you guys allowing me to breastfeed my baby I lived in the hospital with my baby for 2 months and CPS said Sadiaus life was in danger Tessa broke HIPPA by sharing my baby information with Lindsay Crocetti to plot and remove my baby from me.

Desiree Peterson

261. Complainant contends that Rodriguez, Roger, a Social worker, forcefully entered Complainant’s house, and forced Complainant to sign documents in violation of Complainant’s rights. Further, Complainant contends that Rodriguez is liable for several liabilities, inter alia, negligence, negligent infliction of emotional distress, violation of civil rights, violation of state civil rights, emotional distress, and negligent breach of duty.

Steven Bradley

262. 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.
263. 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.
264. 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.
265. 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.
266. 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.
267. 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.
268. 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.
269. The Complainant claims that Analysa Cortez, a parent aide, completely lied on several occasions to help keep Complainant’s son detained.
270. 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.
271. The Complainant contends that Jessica Welsh, a foster parent, neglected and abusing Complainant’s son while getting paid to keep him safe.

Mahogany Hunter

272. Complainant has been victimized by the department of child welfare on multiple occasions and has been the victim of human trafficking as all of her children have been placed in homes of abusers intentionally to cause mother’s emotional distress.
273. The department, juvenile court, and law enforcement conspired and coerced Complainant using threats of force to obtain custody of their children where they were later molested and abused.
274. State actors continued to harass, trespass, and illegally survey the complainant invading her privacy and quiet enjoyment of her domicile.

Renesha Tomlin

275. On April 30, 2013 10:13 am, a CYFD social worker came to my home to do a child welfare check and to advise me that Linda Johnson Hopkins was making allegations against ME such as the following I was feeding my 2 children at the time dog poop I was on recreational drugs such as meth coke crack cocaine pain pills and heroin that I also beat my kids and left them alone often. I then advised her that they were all false allegations. The social worker proceeded to accuse me herself. I started crying because the allegations where so horrible and I would never hurt my kids. I was confused on how someone could be so evil. I was also 7 months pregnant at the time the case worker then advised me that multiple people would be in contact with me in the near future to do further investigations. ” CYFD continued to harass me from that moment on”
276. Cops showed up at my house 3;30 pm checked to see if my children (Jordae, Jamari) had any visible marks on their bodies which showed that my children’s bodies had no type of injuries the cop also checked to see if I had food running water and clean clothes and a clean house the cop then stated to me that everything was fine on my end and that there would be no more further investigations and my case should be closing soon.
277. Then a CYFD social worker kept popping up at my house causing me stress she advised me that I needed to find a family member to sign my kids over to until my investigation was over because Linda J Hopkins kept calling her making false allegations still and she was sick of the phone calls interrupting her LIFE even though it showed no signs of my children being in any danger or any abuse was taking place in my home she had me move my kids to my dad’s house .all the stress put me into premature labor on May 24, 2013
278. On 24^th May at 10;00 pm I gave birth to my son Jareal Emanuel Tomlin with a c section because all the stress CYFD caused me made my body go into shock as I was in labor due to all the harassing the department was doing following the false allegations, they were receiving against me. My son’s heart rate dropped and had to be cut out of my stomach he had to be in the ICU for 3weeks due to being early I passed out in surgery. Once I woke the next morning the social worker was there looking at me she advised me that she was going to be in contact with me still because I had a newborn while my case was still open and that I needed to get in parenting classes and a drug program even though I was not on any drugs at the time. I had severe postpartum depression and the department of CYFD did not care.
279. On May 30^th, I went and signed up for parenting classes at healthy families and signed up at UNM Hospital for a drug program ‘it was hard to get in the program for drugs being that my urine samples I took were negative of any drugs it took me a good 10 hour process to get enrolled at the clinic but I got it done I then called the social worker at CYFD to inform her that I had did as she ask me to do then she advised me that she wanted me to bring the kids (Jordae and Jamari) to the department of CYFD address 300 San Mateo Blvd NE #800 so that the case workers could look at my kids one last time and my case would then be closed.my father and I arrived at CYFD AT approximately at 4;30 pm soon as I took my children up to the second floor the worker had me place my children into a room where she said they were just going to ask my kids questions once I stepped out the room the case worker proceeded to tell me I need to get off of the CYFD property because she was keeping my children. I started trying to get back in the room to get my children I begged them for answers to why they were doing this to my children and I they just stated that they could because they ran Albuquerque I refused to leave the office so CYFD social workers called the Albuquerque police department to remove me from the building I could hear my children screaming for me I was screaming for them it was the worst day of my life. After about a hour or so they drug me out of the office basically and then the social worker called me and said I could not return to the hospital to see my son that I had just had witch was still in the hospital unless a social worker was present. I asked her where was she placing my child.
280. It took some time for her to find my children a home she then stated that I needed to work a treatment plan that she would put together for me.it took them weeks to let me see my children again it was so horrible every night I woke up screaming and crying from the separation anxiety I experienced from my children being away from me. I couldn’t eat drink or anything I didn’t comb my hair get dressed anything I just laid in my bed I almost died if it wasn’t for my dad getting me up and helping me get dressed and the Lord keeping breath in my body I would of died from the pain I was feeling. I would call CYFD and they would inform me that I did not have a case worker anymore and they were so busy that they would let me know when I would get one. it took about 3weeks I finally got a call back from CYFD saying I finally had a new case worker, whose name was Elise.
281. On June 15 2013, I finally got a meeting with my new social worker by the time I got a appointment I had already went to several parenting classes and drug meetings at asap I informed my case worker that and she said that was good. Then my case worker informed me that I needed to start taking UAs Daily.
282. I could only see my children including my new born that was scheduled to be released from the hospital soon only one hour twice a week. The case worker then stated that I could no longer see my newborn or pump breast milk for him because he needed to get used to his foster parents because he wasn’t coming home to me his biological mother.
283. July 5 2013 – March 13 2013: The next 9 months of my life were very stressful, lonely, heart breaking, and painful for my children and I. I then did UAs for the next 9 months. All of my UAs were negative always so my PPW  Elise recommended that I start having supervised UAs. The stress of a stranger watching you use the restroom every day for no reason sucks makes you feel like a criminal, but that was nothing compared to the torture that my kids suffered. Then next 9 months my PPW   would meet with me every week twice a week for one hour to let me have visitations with my 3 children for just an HOUR at the visit my children would ask me what they did wrong and why ‘couldn’t they come home. My children would be Always hungry and my PPW   Elise would have to rip me away from my children because they would be holding on to me begging me to take them home, they even would make my children walk because they didn’t want me to see the foster parents that had my children afraid that I would hurt them my kids were with strangers it was so scary.
284. I finally got a lawyer appointed to me named Allison Peroni I went to see her on about august 23 2013. She went over all my paper work that I had completed at the time I had done everything that my PPW  Elise had asked as far as having clean UAs everyday completing a parenting class and having psych evaluation and seeing a drug counselor every week. Allison my lawyer could not understand why they took my children in the first place without any evidence of any abuse. Everywhere I went to get help it was so stressful explaining myself with no proof of child abuse I had to beg everyone I confided in with system and didn’t understand why they hadn’t been returned to me if I had completed what CYFD had demanded I did in order for my children to be returned home. The next few months I continued to do my UAs witch they were always clean and to follow my treatment program. we started going to court and each time we went to court I would have to listen to how my 2 older children were suffering such as they were waking up in the middle of the night and screaming they would urinate and defecate on themselves because my children wanted to come home to their mother and missed me dearly .my lawyer always presented all my documents stating that I had finished all of my treatment plan. The judge still would just ignore everything and let my children stay with strangers. We kept going back and forth to court I won each time we went the judge cited with me but my children still couldn’t come home.
285. CYFD would not let me bring my children gifts. They started making me and about 20 more mothers share our visits in one conference room because they had to many children in the system so the PPW’s were overwhelmed so we never got any privacy. I would bring toys and snacks for the other children because I would feel bad that they would want the things I brought for my own children. Soon the other PPW’s would complain to my PPW and she would inform me that I could no longer bring anything for any of the children. I was upset but kept it to my I just kept telling myself I just have to keep praying and my kids would be home when the Lord seen fit. The PPWs would treat you like crap my kid’s hand so many foster parents and I had so many PPWs it was so frustrating.my children and I would cry ourselves to sleep at night still do till this day 7 years later going on 8years my daughter’s hair was never combed and I showed them how to comb it her hair ended up falling all out. My kid’s clothes would be dirty have holes in them my poor babies looked like poor orphans, their spirits were so broken. I finally got a court date for my children to come home sometime in March 2014.
286. March 1-31 2014. Before my children were able to come home I had to have my hair cut so CYFD could get another drug sample.my PPW  never told me anything about it. I went in for a meeting and then someone informed me that they would be cutting my hair that day. Of course, I didn’t mind. I’ll do anything for my children that hair sample came back negative as well. When we went to our supposed to be my last court date my children’s lawyer tried to get my children to stay in foster care because the foster parents wanted to adopt my children. My kid’s lawyer and CYFD tried to lie on me some more but the judge was on my side this time and The Lord.
287. My children were to be returned to me within the next 2 weeks. I was so happy our nightmare was almost over I was thinking to myself yes CYFD can’t hurt us anymore boy was I wrong they were just getting started with their sick and twisted ways! My babies came home that same week around march 13 2014 2 weeks early because the foster parents’ daughter passed away suddenly. I agreed and was happy soon as my children were returned home CYFD started to harass me all over again when I was waiting for them to organizations to work on our reunification CYFD had me jumping throw hoops for them still.
288. It caused for my anxiety and postpartum to kick in again I was so overwhelmed I felt like I couldn’t be myself anymore it was so heart breaking everyday my kids would beg me to not go to school fear of never seeing me again and they begged to never go back to their foster parents. I was so depressed I didn’t realize I was slowly losing my self the Lord still gave me the strength to keep on going without him we wouldn’t of made it this far and I thank him every day. I never got around to meeting with any organizations to help my children and I due to the lies and bullcrap. CYFD kept putting me through. about a month later my PPW  called me stating come in after I dropped my kids off at school to come and meet so she could give me my paper work I’ve been waiting on stating that my children and I were done with CYFD .i got there and I waited for about an hour my PPW finally came out and got me she asked could she hold my 9month old son I agreed soon as she got him in her arms she took of running and locked herself in a room I was in shock once I came to I found myself trying to get in the room she had my baby locked in. about 4 other women were there two of them were pulling me back the other two stating for me to go upstairs for me to talk to who was in charge.
289. I finally listened because I wanted my baby. I went upstairs and was escorted into a room my PPW  entered the room with a blank stare and tears in her eyes. I start screaming asking her why are you doing this to my baby and I what did I do I’m doing everything you asked I just want my babies. I asked her where did she put my son that she had just taken out my arms minutes ago she stated that it wasn’t her doing it to me that her boss had made her do it. So I asked to talk to her boss and as soon as I asked that the Governor of Albuerque at the time comes in the room and states to me that she ran Albuquerque, New Mexico, and she wanted my children and she was taking them. I was so hurt I still was not leaving without my baby .so someone called the cops on me and had me escorted of the premises.
290. I went to go see if I could get my other 2children from school by the time I got there they we already kidnapped. I started to realize the reason they never wanted me to move them schools when I got them home was because CYFD’s plan was never really reunification they had to play like they were giving me my children back because I was the only mother that had beat CYFD so quickly and strongly and I believe I was the only African American in Albuquerque New Mexico to do so. I kept calling my PPW to get help and my lawyer I would get no answer from anyone my lawyer stated she could no longer represent me because CYFD said. Finally, approximately 3 weeks later, I got a call from my PPW stating that I had a visitation coming up with my kids. I went to the visitation and my kids were in shock and were asking me when could they come home. I turned to my PPW who was present at the time and I said can you let my children know why we are back here for no reason? my PPW  then grabbed my baby boy Jareal the 9month old form me once more and kicked me out of CYFD once again and stated that my visitations would no longer take place because of my attitude. I was so hurt stressed and traumatized.
291. Up on the 5 of July and I was so sick to my stomach I could not take it any more I wanted to see my babies. I went I was crying begging to talk to someone and no one would listen.my PPW  would not come down and speak to me. The receptionist called the police on me stating that I was trying to kill myself the police informed me that I needed to leave and I was to never come back or I would be thrown in jail. That left me so broken I explained to the cops my situation and they all worked for the governor so I felt like everyone was against me and it was all about money I slipped into a depression tried to kill myself a few times but the lord intervened and it never worked I was so sick of feeling dead inside. A year passed by so in 2015 I found myself at my lowest in life I started using methamphetamines. I was no longer myself CYFD had officially got me at my lowest like the wanted all along. I still went to my drug program and counseling despite everything I was going through my counselor decided I should start seeing a psychiatrist so I did I started to see Dr Romo at UNM hospital asap. he helped me out a lot got me back on track and sober again I started taking different medications that helped my mental so I did not feel like I needed the meth any more. We used to talk about all the trauma CYFD had caused me and that if my kids were returned or if I knew any information about them, I would be much better. I caught my kids lawyer talking to my neighbors a few times I told him that as well I don’t think that was appropriate.
292. September 26 2016: In 2016 Sept. 24, I had another baby we were home from the hospital for 2 days then CYFD was at my door 501 Dallas Street Se Apt B Zip 87108.stating that my2day old baby was in danger. CYFD came it was two social workers saying they needed to check on my baby because I had an open case. They came out everything was fine so they closed my case with just the newborn. Then I got a call finally from a new PPW  saying she took over my case and would like to go over a new treatment program to get my kids back it was all a bunch of lies again, Over the next few months I did the same things my last PPW   had me do years ago witch where DAILY UAs parenting class and counseling. I aced everything once again when we finally went to court almost a year later it was to terminate my parental rights. The day of court CYFD tried to get me to sign my rights over, which I would not do.
293. CYFD has all my ten PPWs get on the stand and fabricate lies about me and my whole case saying I never did anything to get my kids back and that I continually would bash them on Facebook and I tried to blow up CYFD’s buildings multiple times. I wasn’t allowed to present any of my evidence of the progress I had made all those years and the foster parents even lied on me and my children, nor could I have any of my witnesses testify on my behalf my family couldn’t even come to court with me. I was treated like a criminal after each court I had to be escorted to my car by police because CYFD workers and the foster parents said they all feared for their lives. It was so embarrassing and heart breaking knowing that these demons had my beautiful angels and there was nothing I could do except wait on the Lord to deliver me and my babies.at the end of trial I lost all rights wrong fully to me nor my children knew nothing about I was railroaded in the end.it has now been 6years since I’ve seen or talked to my children up until recently my oldest child Jordae has snuck and found me on social media.
294. We text as much as we can she has been informing me some of the torture that the foster mom has done to them over these years and still daily she puts her hands on my children and much more she has been suicidal since the Age 7 due to her depression of missing her mother. She has ten counselors she has reported the abuse but nobody is listening to her neither, my daughter and sons state that they want their mother still till this day.my children are all on different medications and have also been placed in mental homes numerous of times because after all these years they still ask to come home.
295. I’ve prayed for this day to come when we can all get the justice we deserve for so long I am so grateful for the angels sent to finally get my story told the trauma has caused me to suppress a lot of the traumatic incidence that CYFD has caused me and my children throughout these years but I today have wrote as much as my mind would let me bring up it will never get easier to be yourself again that person I was before CYFD came into my life is gone forever only thing I can focus on is healing my broken angels and freeing as much children as I can that are in bondage by telling my story and getting it public and making sure CYFD in Albuquerque New Mexico gets exposed so they can never ruin another family.

Dmitri Cash

296. Complainant’s constitutional rights were violated by the juvenile court of Monroe County, NY
297. In a juvenile court proceeding, court officers including the judge conspired to deprive complainant of rights to privacy and to be free from governmental interference in family and private life.
298. Complainant was deprived due process as false allegation with no substantiating evidence was used in a court proceeding and exculpatory evidence was suppressed.
299. Complainant’s rights to children were illegally terminated without merit or basis.
300. Complainant has suffered extreme emotional distress and a result of these willful and reckless conduct.
301. The actions by Defendants , state actors, and court officials were shocking to the conscious of any reasonable person.
302. The children have been harmed by this separation as well because they enjoyed a close bond and relationship with their parent.
303. Case workers committed perjury and swore false statements in order to kidnap claimant’s children under color law.
304. They filed the false paperwork to collect money for complainant’s children as wards of the state.

Markeef Royal and India McFarland

305. Monroe County juvenile court used perjury, falsified documents, and false statements to maliciously prosecute complainant and case marital strife.
306. County officials defrauded complainant by making illusory promises that his children would be returned if he completed the parenting courses and anger management classes he agreed to do.
307. Despite insufficient evidence and the presentation of evidence in the Complainant’s favor, the court still ruled against his children being returned home.
308. The judge is biased toward the county agency and refuses to provide the due process rights of claimant which are protected by the constitution.
309. Claimant was not allowed to visit children because of unsubstantiated allegations.
310. Claimant is being harassed and stalked by investigators on behalf of the agency which is disturbing his peace and familial relations.
311. New York State Family Services, Catholic Family Center for Chemical Dependency, and Rochester Regional Health conspired to traffic complainant and his children by making him a permanent patient, well past his need for services.
312. Social workers kidnapped complainant’s children and forced him to attend never ending classes repeatedly under color of law and threat of force.
313. The court breached the fiduciary duty to client and failed to provide him with a fair court trial and ameliorate any family issues. They indeed increased marital strain.

Teresa Goin

314. Complainant was deprived of constitutional rights by a Michigan court who maliciously prosecuted her and terminated the rights to her children because of her disability.
315. Though her case was appealed because the removal was contrary to the best interest of her children, she was still unable to get justice.
316. The court record reflects not substantiating evidence to support the claim by the agency, but the biased, conspiring judged terminated her parental rights any way.
317. The government agency and court conspired to suppress exculpatory evidence.
318. The created fraudulent documents in order to put complainant on the child abuse registry list even though she has never abused or neglected a child.
319. All actions taken by the court are facially unconstitutional a repugnant to the United States’ law.

Raymond Sipult

320. On September 14, 2019 at 12:55 pm, Wichita Police Department and D.C.F. took my children.
321. I called 911 cause I was being attacked by their mother. And we both went to jail for domestic Violence, for 72 hours (the charge was later amended to brawling). The children entered the system.
322. I have been fighting for 2 years now. I am at a loss of words how cps can still keep my children when I am the one who has stayed advocating for their freedom. And their mother wants to relinquish her parental rights and me. The child’s father does not.
323. Me and the mom have been broken up since the start of the case.. So, I am under impression were on separate case plans. I am currently at unsupervised Visitations.
324. And the children have not been released. And my mother has temp custody of my son and the sibling his sister is trying to be secretly adopted out (my mother faces threats by the social workers), just for being a good Grandmother.
325. I have been subjected to punishment by speaking up about the agency and have even filed a Habeas corpus and it got dismissed by courts. (Examples of Justice Denied).
326. I want my children to be able to come home to me where they have love and a stable home. As a single father who cares for them. I completed many classes and have submitted proof to the agency and the results I’ve experiences are shocking.
327. So far, I was given 2 Case plan goals of: Reintegration and I completed the permanency plans on those. Then SFM gave me a Permanency plan of adoption. Then I was like no I don’t agree with this. It seems they want to take my children cause I’m a good parent. I have gone to several attorneys and doctors and mental health professionals who have said that I’ve had adjustment disorder because the results of CPS taking my children and was cleared by psychotherapists to have no serious mental health issues at all.
328. I have gone through every loop and the documentation of falsifying reports tends to be a big practice SFM uses and one I never knew how deceitful they were in there lies and reports. They said many things that were not true and I tried to talk with the social workers about how they come to these conclusions.
329. I simply can say as a man who is a father and Ordained minister I’m almost to trail. And pre-trial and I’m afraid they will take my kids cause the state only has to have clear and convincing evidence. And they set the standard for the parent to meet the burden of proof 27 pages on the states motion to terminate my parental rights
330. This is madness and even though I’m at unsupervised visits Visitation staff still bother me by coming to my home residence during visits. I don’t know what to do it’s as if they want me to grovel at their feet. I was under impression if I was submissive to their Reintegration plans. I would get my kids back.
331. I have talked to everyone I can think of and have discovered many things that came to light. This is happening to so many people.

Loribeth Aaron

332. Loribeth Aaron is the loving foster mom of two angels.
333. After the parents of the girls were driven to suicide and drug addiction because of the juvenile courts, Loribeth became the consistent long-term mother to her daughters.
334. Without reason, the child welfare agency removed her children who were thriving and bonded with their permanent caregiver in their permanent home.
335. This was not in the best interest of the children because the children’s health began to deteriorate shortly after their removal from the complainant’s homes.
336. Children were needlessly separated and emotional traumatized.
337. Child welfare agents made false promises to complainant and used her home as a post while they shopped the children around to the highest bidders.
338. Child welfare agencies not only removed the children from a loving biological home, but they removed them from a loving foster whom with a loving mother who had provided for the children excellently.

Kenya Cloud

339. Duran informed me that a detective from crimes against children wanted to speak with me regarding my daughter Ahvaeah in the end she told me she never said anything about crimes against children and acted has if she didn’t know what I was talking about
340. Dave Peterson conspired with the juvenile court and county welfare department to take my kids prior to requesting a well child check.
341. They gave conflicting stories.
342. Veronica Hernandez, Supervisor perjured herself and stated untrue information in order to be given the removal of my children she named bio father and bio mother as the predators.
343. Amanda Veracka, Social worker, knowingly deceived client with closing the case also lied causing my kids to enter back in a foster home because she said the bio father was now who molested our daughter she has used the case to gain a higher position and has obstruction charger’s and several battery on house hold member charges and her husband is a police officer who pressed charges on her in 2019.
344. Kari has a vicious raft and allows the unlicensed caseworkers and social workers to cover up their gross negligence and has covered up her wrongs. Lied about everything she told me with the home being safe and continues to inflict mental abuse on my children and refuses to give credit to a completed treatment plan gave me legal custody of my two year but took her and my twins who were never apart of the case she has allowed her worker to place false allegations to take my girls putting another case on me.
345. Milos Marjanovic Gal failed all my children has known my children endured some type of abuse from the foster homes they were placed in has knowledge of my five year old being molested in a foster home by the adopted child. I have the paper where the caseworker is admitting where and how it took place.
346. Maryanne Dearchangles provided Ineffective council and altered a summons the original summons has the deputy stamped and the other is a signed in pen.

Keyona Bradley

347. On October 5 2020, I gave temporary custody of my children to my mother Karen Bradley due to my ill health. I was experiencing health complications from recent childbirth.
348. March 26 2021 7pm children were removed from my mom’s house Karen Bradley 1828 E. 22nd Street Wichita KS by Mikayla Russell Saint Francis Ministries with NO PAPERWORK or Warrant on an allegation of physical abuse perpetrated by Karen Bradley (grandmother).
349. Upon investigation these allegations prove false. I was told by supervisor Monique Lovelady the kids would be returned in 72 hours. As of the date of this document (5/26/21) I have received NO paperwork no written case plan and no documentation. I am not certain where my children are even placed.
350. My daughter Delightis Bradley (2013) reported to me at a visitation at Saint Francis Ministries in the presence of SFM workers, that she was touched in her private area on the date of 3/16/21 at a foster home in Hutchinson Kansas and SFM worker Candace Johnson told me NOT to report this to the police. I made a police report in Wichita KS
351. 21C015755 Detective Daniel Ribble 316-660-9457 ribble@sedgwick.gov and reported to DCF Hutchinson location and assigned to worker Bobby Jermera 620-860- 7336. Upon follow up Bobby Jermera did not follow up on investigation and abruptly quit the agency. The case was passed to Trevor Sandell (james.sandell@ks.gov) and Elisha Guest (elisha.guest@ks.gov). Trevor claimed in an email to Private Detective Kelly Patton that “a forensic interview was done and she denied any kind of sexual touching denied anything sexual happened. Spoke with siblings that were in their residence they denied anything happened. Interviewed both foster parents that were in the home and they denied anything happened. I spoke with Jammer [sic] and he sent me the law enforcement emails saying that they would investigate it if there was confirmed sexual abuse and there wasn’t so complete everything.
352. Ashton Gillett Wichita DCF worker was assigned to conduct a courtesy interview. She did a forensic interview with Delightis Bradley the little girl and the girl [sic] did not say any [sic] about any sexual acts just that she was afraid of the Dog. There was no discloser of any sexual abuse.
353. According to St. Francis all the children have been placed in foster homes in Wichita. From speaking with St. Francis, they were only there one or two nights then moved to a more permanent placement. I’m currently waiting for her notes and logs. Email by Trevor Sandell 4/1/21 to Detective Sergeant Keaton Berger #413 Reno County Sheriff’s office 206 W 1st Hutchinson, KS 67501 620-694-2735
354. 4/1/21 email from Kelly Roepka DCF (kelly.roepka@ks.gov) responds to Detective Berger that no sexual abuse was disclosed.
355. 4/1/21 email from Detective Berger “thank you for the information. I will file this case away then.”
356. According to my daughter Delightis (victim) and my other daughters Iceland and Diamond that witnessed the incident they have NEVER been questioned by any social worker or law enforcement about what happened to Delightis at the foster home in Hutchinson KS on 3/16/21.

Kristen-Clark Hassel

357. Hassell, Travis Collusion, 3 years of tax fraud, felony forgery of my signature over $50,000, conspiracy to do theft by taking over 11,400 with Meredith Rowland, slandering, domestic violence, abandonment, falsifying CPS reports, conspiracy, child abuse 7 counts, child neglect 7 counts, child abandonment 8 counts, spousal abandonment, falsifying police reports (VA, GA, AR), deformation of character, trying to sell a car illegally to Elissa Patterson, parental alienation, intentional infliction of emotional, mental, and financial stress, fraud, perjury, kidnapping, contempt of court on the $11,400 plus child support in October 2018, terroristic threats, harassment, intimidation, bullying, stalking.
358. Rowland, Meredith-Collusion, Conspiracy, conspiracy to commit a felony, conspiracy to falsifying 4 court reports, falsified 4 court reports, perjury, unethical relationship with my ex-husband Travis Hassell but husband at the time, breach of confidentiality, intentional infliction of emotional, mental, and financial stress on myself, Rick Cunningham and all 8 children, threatened my children, deformation of character, slandering, intentionally to destroy my character to Judge Green lied about me threatening her life, ex parte, perjury,  withholding evidence in report that would change outcome of divorce/custody case and DFCS case, intentional parental alienation with Isaac and Elizabeth Hassell, endangering my 8 children, financial fraud, food stamp fraud (illegally stopping  it),  Medicaid  fraud (illegally stopping it), identity theft, stalking, harassment on myself, Kaleb, Jeth, Nathan, rick, Kate, Helen, Vicki, Val, Val  II,  attempted forced entry into home with Jeth and  myself, threatened Jeth, Kaleb and Nathan with Juvi, threatened Jeth with jail, threatened me with speaking to the judge if I did not cooperate during an active hurricane, intimidation, bullying, stalking, religious discrimination, violation of oath of office.
359. Name Last, First Gonzalez-Oganawski, Collusion, perjury, threatened Jeth with jail, Kaleb and Nathan with juvey for obstruction of justice for withholding information they did not have, intimidation, bullying, harassment, stalking, attempted forced entry, falsifying court reports multiple, withholding evidence, slandering, deformation of character, fraud, intentional infliction of emotional, mental, and financial abuse/stress, cruelty, religious discrimination, violation of oath of office.
360. Judge Orville Green, Orville (Brent)- Religious discrimination, withholding evidence (email from Meredith Rowland GAL), allowing ex-parte, allowing me to be revictimized, collusion with DFCS/Jim Chamberlain and all parties involved with the plaintiff’s side, violation of the following Amendments of the US Constitution 1st,4th,5th, 6th, 7th, and 14th, (signing off on documents without reviewing appropriately) “biased”, not allowing evidence that would change the outcome, violating oath of office
361. Laurie Morton – Collusion, unwarranted entry, intentional infliction of emotional, mental, and financial stress, Social Security fraud, perjury, intentionally withholding my children from being returned to me, intentionally adding to case plans when already completed to withhold children, falsifying multiple court reports, malicious perjury, religious discrimination, slandering, falsifying court reports, fraud, terroristic threats, bullying, harassments, stalking, 9 counts of child endangerment, falsifying drug test, tampering with evidence, withholding evidence, violating oath of office.
362. Jim Chamberlain – Collusion, falsifying court reports, intentionally withholding evidence, ex parte, slandering, deformation of character, intentionally going against DCFS policies and regulations, not abiding by Families First Preservation Act signed into law by President Trump, not sharing witness list to my attorney or discovery info until during active court proceedings, “good olé boy system” with Judge O.B. Green, GAL Michael Perry and GAL Meredith Rowland also Travis Hassell, Claudia Stroud, Laurie Morton, Elissa Gonzalez- Oganawski, Victoria Sevilla, Shay Fullmer, all in collaboration with everyone, violating oath of office.

Elizabeth Andrews

363. In April of 2019 Charles Donald a CPI investigator removed my children from the hospital without a court order or even notifying me there was alleged abuse I found out 3 days after my kids removal the allegations and that my kids were placed in emergency shelter Charles Donald spoke to my kids without me present or without notifying me first I was informed the night before the shelter hearing at approximately 8 p.m. that I needed to be here in Bay County at the courthouse at 7 a.m. for the emergency shelter order which also happened to be the day of Good Friday and all courthouses closed due to national holiday. My case was out of Calhoun County not Bay County. Charles Donald failed to make any and all efforts to prevent removal. He never did a home study nor did he ever meet.
364. Charles Donald, investigator violated my 14^th and 4^th amendment rights among others.
365. He Removed children without a court order or doing a proper investigation, falsified documentation, spoke to my children without my permission or me present and violated confidentiality law.
366. I was wrongfully accused as allegations were proven false through the CPT team and still wouldn’t let my children come home because of their abuse of power and process/Broke the social workers code of ethics, Biased opinion and allowed to handle the case unfairly, right to due process, Abuse of power, violated 4 and 14^th Amendment, broke the social workers code of ethics Falsified documents, had biased opinion and handled the case unfairly, gave my children’s social security cards to foster parents, did not follow judge’s orders, and alienated me from my kids.

William and Emily O’Dell

367. I am the Father of Gwendolyn, Parker and William (Liam) O’Dell
368. This Declaration is being written in support of a motion to return the children to their parents. This is in reference to case number: 2019-1827-3
369. On May 23rd, I took my daughters Gwendolyn and Parker to school for Aloha day. Same as usual without issue. Took my wife Emily to work in Dallas with Liam in the backseat. Liam was so good on that 4-hour trek that I felt it necessary to treat him with Dairy Queen. I left to pick up the girls at 3:20 pm to arrive at the school as it let out at 3:25pm. When I was approached by CPI Erika Jackson. Mrs. Jackson informed me she interviewed my Children but did not state that there were witnesses or that it was recorded.
370. I was never informed prior to the interview that my children were interviewed, credentials were not properly displayed and no court order was present.
371. My children were detained by CPI Mrs. Jackson after the interview with myself and a phone interview with my wife. In which Erika was very rude and condescending.
372. I was never informed of the allegations as to why I was being interviewed or why my children were being detained. She only called her supervisor and informed me that it “is a removal.”
373. After the interview and during the interview I noticed that there was no recording that was being performed. I noticed this because no recording equipment was present during my interview to even suggest that my children’s interview was even recorded.
374. Law Enforcement was not present until the very end of the process that day. I arrived at the school at 3:25 and left at 5:36pm. Law enforcement was not there until I went to say goodbye to my children to which Gwendolyn made it clear she did not want to go with anyone else. As per TFC 261.105, 261.301(f)-(h) & TFC 261.3011 It is my belief that if she suspected the children were under physical abuse then law enforcement should have been contacted immediately to perform their own investigation and for them to be there during the children’s investigation as part of their investigation of these allegations. This is the first of several failures on Erika Jacksons part. With that said there was no Court order for the removal of my children and I felt strong armed into giving my children up to the state.
375. Afterwards, when she released me and I got to my car, Erika called me back to give me a receipt for the removal in which she needed help to fill out. This was the only time that I saw another CPS official in the office. I felt at this time that Erika was new and should have been shadowed as part of this process to make sure no foul play was committed on her part. Since she was alone, no court order was present and no recording was performed it left Erika to pretty much make any allegation that she felt necessary to make the situation seem as if Exigent circumstances were present. Which there were none.
376. At the first visitation in Temple, TX Gwendolyn stated to CPS/HST Stephanie (last name unknown) that “Daddy would never hurt us.” It was documented but never acknowledged.
377. I had only learned about the allegations upon receiving the first affidavit on June 3rd for the hearing on Jun 6th, 2019. As Erika Jackson Denied informing me of my allegations twice prior.
378. Also, in the affidavit Mrs. Jackson stated she came to the house then went to the school. She called the state of our house to be “In Chaos.” But when called to the stand she stated that she only went to the school. Which leads me to believe that she lied under oath or the court documents.
379. At that hearing, there was no evidence produced from CPS other than photos to which from articles of discovery were thrown out because CPS and the attorney failed to follow those protocols.
380. We were informed of the family plan over a month after that hearing and started right away once we received it and have been compliant ever since.
381. On November 1, we learned of new Allegations from Mrs. Kimberly Witt our case worker to the effect of Sexual Assault. She did not recommend any actions except the polygraph but claimed it may not be admissible.
382. On November 14^th, we received the new affidavit for the Nov 19th hearing. In it we found the true context.
383. Even though Mrs. Witt visited our house on October 25th, the first and only monthly check-up on us to date, we were never informed until a total of 30 calendar days later.
384. The evidence received in the affidavit suggests that spoliation took place through withholding the evidence of the report from Andrew Thompson with the Brett H. Pritchard Law Firm. Andrew did not receive notification and did not receive the information until he received the affidavit on November 5th.
385. At the November 19th hearing we were blindsided with this once again with which Mr. Price called Emily to the stand and proceeded entrapping my wife to make statements leading against or to incriminate me.
386. When questioned by Mr. Thompson, Mr. Price looked up Rule 504 over spousal privilege and stated that in section 4 in criminal proceedings my wife is subject to cross- examination. He failed to state that in subsection C (i) it states that in civil proceedings that the allegations (if proven) lead to a Criminal case the exemption stands and Emily would then be legally subject to cross-examination under that rule.
387. Which leads me to believe that once again a violation occurred.
388. During the questioning by Mr. Price, Emily exercised her 5th amendment right stating, “I plead the fifth.” Judge Mundkowski stated, “It doesn’t work like that, you have to answer the question, better yet, I order you to answer the question.” This was appalling and damaging to my wife’s character and emotional stability as it was a blatant attack by the judge to force her to answer a question even after she was told she could invoke the fifth amendment on any question see deemed unfit to answer.
389. CPS has claimed coaching of Gwendolyn and Parker by the Paternal grandparents Mark and Teresa O’Dell. The paternal grandparents had no knowledge of these allegations until Nov 4th and after they reported suspicious activity on the part of Cynthia, Gary and Katherine Snodgrass. To which after Mrs. Witt spoke to Cynthia about the reported concerns, Gary Snodgrass called and informed Mark and Teresa five days later, on Nov. 10th, that they are discontinuing their visitations. To this we believe that if there is no wrongdoing or anything to hide, then this retaliatory action should not have taken place.
390. Mark and Teresa were unaware of the new allegations until Nov 4th and the second forensic interview until the new affidavit was received on Nov 14th.
391. At this point in time CPS has claimed, on several occasions, that they have evidence but have not produced tangible evidence to any of the allegations at this time but have been persistent on pursuing corrective actions based on hearsay.
392. Activities have happened in the Foster home with “Big” Boys. Included in my video recorded evidence Parker and Gwen have mentioned names of three of those boys.
393. On Tuesday January 14th, 2020 It was confirmed that there is no recording of the interview Erika Jackson had with my children. This was the second confirmation and was confirmed by Detective Miller with the Waco Sheriff’s Dept. The first confirmation was from Kyle with the DFPS Office of Consumer Relations. Upon research this is a clear Violation of Texas State regulations of first TFC 261.311 not informing me that my children were interviewed and TFC’s 104.002 & 261.302(e). she failed to record and/or provide reason as to why the interviews were not recorded.
394. Throughout this case Mrs. Kimberly Witt has stated that children do not lie. When I placed a complaint based on a recorded statement made from Parker regarding abuse from Gary Snodgrass made with the Nevada CPS office and Las Vegas Metro police Abuse and Neglect unit. I forwarded audio evidence to all parties, including Mrs. Witt. Two days later I was informed by Mrs. Witt that the children said they lied, and that the investigation was being dropped. If children don’t lie and that there is tangible evidence, why drop the case? To this it is my firm and sound belief that CPS is choosing what they want to investigate and ignore pertinent evidence that shows that the children are in possible danger and neglecting their safety as conservators of my children. I feel due to this a motion to dismiss this case is necessary.
395. This has made me aware and fearful that my daughter may have been subject to this kind of violence under CPS care to which has prompted me into contesting these and all previous allegations.
396. On July 15th 2020, we started our final hearing that was gear and modeled towards Termination of my parental rights. Initially it started out as such with all testimonies defaming my character and the character of my wife. Cynthia Snodgrass testified that Emily O’Dell was unable to determine how to keep the children safe or care for the children properly as she was unable to determine a suitable “Boyfriend” and that I was narcissistic. Gary Snodgrass on the other hand testified that the children “Lie all the time” about hitting, kicking, pinching and biting each other. Once again CPI Erika Jackson perjured herself on the stand when she stated she went to the school, then our home and back to the school. Kimberly Witt testified that there was no evidence of maltreatment of the children and was backed by forensic interview performed by the Las Vegas Metropolitan Police Dept. She further noted that there were two forensic interview but when she attempted to get another one performed LVMPD declined and informed her that no prosecution would follow. Suggesting innocence.
397. On July 16th, LCSW Hannah Hartman testified that she was not a licensed therapist but in fact an intern. When asked how False memory could occur, she testified and confirmed that it can be caused by repetitive questioning, speech around the victim and gaslighting. During this day of proving no evidence of maltreatment.
398. On August 3rd 2020, Final day of the trial I was on the stand to continue my testimony. After several questions and what I would determine hostile prosecution, I testified to the truth even after the prosecution trying to twist the story around. Emily Testified that she in fact did believe the children that they were sexually and physically abuse but only in the foster home and not by myself. During Emily’s testimony it was once again brought up about the video regarding Parker who stated the sexual abuse and who committed it at the foster home in Austin. We played the video as it dictated to the court exactly where, who and what the children were taught. Our witnesses testified to the care and love that Both Emily and I gave to our children and the great care for their safety which was paramount in these witness testimonies. After all testimonies and closing argument, where our attorneys stated the Department have not met clear and convincing and had a Lack of Evidence to support the allegations against me. Judge Nikki Mundkowsky adjourned the trial stating it would take her a few days to go over the case and report her judgment.
399. August 4th 2020, we received the final judgement via email through our attorneys stating our Parental rights were terminated on two grounds, one being that we failed to keep the children safe or engaged in unsafe behavior; endangering the children’s safety, two being that we did not complete the required safety plan which is a form of servitude or exploitation. This ruling was based clearly on hearsay as will be proven upon submission of the Transcripts from the final hearing and the submission of several other KEY articles of evidence that were submitted for the final hearing.
400. This ruling based on hearsay is a clear attack on the constitutional rights of our family and a blatant act of treason as we are not the first family this has happened to. To rule on hearsay goes against any and all basis of our Constitution and violates the sanctity of the Nuclear Family structure as granted in our most basic and fundamental of rights.

1. CAUSES OF ACTION1“11 FIRST CAUSE OF ACTION

401. Plaintiffs hereby incorporate by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
402. 42 U.S. Code § 1983 provides as follows: “Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress, except that in any action brought against a judicial officer for an act or omission taken in such officer’s judicial capacity, injunctive relief shall not be granted unless a declaratory decree was violated or declaratory relief was unavailable.”
403. “To state a claim under § 1983, a plaintiff must allege the violation of a right secured by the Constitution and laws of the United States and must show that the alleged deprivation was committed by a person acting under color of state law.” West v. Atkins, 487 U.S. 42, 48 (1988); Flagg Bros. v. Brooks, 436 U.S. 149, 155 (1978); Gomez v. Toledo, 446 U.S. 635, 640 (1980).
404. In this lawsuit, Plaintiffs aver that their Fourteenth Amendment rights under the United States Constitution were violated by Defendants. Section 1 of the Fourteenth Amendment provides as follows: “All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the state wherein they reside. No state shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any state deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.”
405. Plaintiffs were deprived of the familial right of association embodied in the concept of liberty in the Fourteenth Amendment without due process. “Today we hold that the Due Process Clause of the Fourteenth Amendment demands more than this. Before a State may sever completely and irrevocably the rights of parents in their natural child, due process requires that the State support its allegations by at least clear and convincing evidence.” Santosky v. Kramer, 455 U.S. 745 (1982). For all Plaintiffs in this lawsuit, it was not proven that it was in the best interests of the minor child(ren) to terminate the parental rights of Plaintiffs. In that regard, their child(ren) were unlawfully taken from them without due process.
406. In United States v. Classic, 313 U. S. 299, 326 (1941), the U.S. Supreme Court held that a person acts under color of state law only when exercising power “possessed by virtue of state law and made possible only because the wrongdoer is clothed with the authority of state law.” The parental rights of Plaintiffs clothed under their Fourteenth Amendment were terminated by state employees acting under the authority of state law.
407. In addition to the other State Defendants, the Federal Defendants are liable for this cause of action based on the following reasons. First, the US Government has several duties as documented in the US Constitution. The people of the US, through the Government, seek to form a more perfect union by establishing justice, ensuring domestic tranquility, providing for the common defense, promoting the general welfare, and securing the blessings of liberty to citizens and their posterity. The government is therefore mandated to exercise its authority directly by regulating, legislating, and issuing executive orders and court orders. It also grants authority to, and rescinds it from, government agencies and state and local governments.
408. Next, Joe Biden, as the President of the United States, is responsible for the execution and enforcement of the laws created by Congress. The President is both the head of state and head of government of the United States of America, and Commander-in-Chief of the armed forces. The primary duty of the president of the United States is to make sure that all U.S. laws are carried out and that the federal government runs effectively. He also directly oversees all agencies of the executive branch of government.
409. Kamala Harris is the Vice President of the United States. The office of the vice president is an integral part of the president’s administration. She is the president of the U.S. Senate, successor to the President, president’s advisor, congressional liaison, and representative of the president.
410. The Department of Health and Human Services is the United States government’s principal agency for protecting the health of all Americans and providing essential human services, especially for those who are least able to help themselves. The mission of the U.S. Department of Health and Human Services (HHS) is to enhance the health and well-being of all Americans, by providing for effective health and human services and by fostering sound, sustained advances in the sciences underlying medicine, public health, and social services.
411. The duties of Xavier Becerra, as the Secretary of the USDHHS, revolve around human conditions and concerns in the United States. This includes advising the president on matters of health, welfare, and income security programs. He is obligated to administer the Department of Health and Human Services to carry out approved programs and make the public aware of the objectives of the department.
412. The Department of Justice is mandated to enforce the law and defend the interests of the United States according to the law. The Department is also mandated to ensure public safety against threats both foreign and domestic. It also provides federal leadership in preventing and controlling crime, and seeking just punishment for those guilty of unlawful behavior. Lastly, it ensures fair and impartial administration of justice for all Americans.
413. Merrick B. Garland, as the Attorney General, is the nation’s chief law enforcement officer. He leads the Justice Department. Under his leadership, the Department of Justice is dedicated to upholding the rule of law, keeping America safe, and protecting the civil rights of all Americans.
414. The foregoing work and/or role descriptions of the Federal Defendants give them supervisory roles over all agencies and authorities from the federal government, state governments, and county authorities. They should be forefront in championing the rights of the US Citizens,. Notably, they should formulate policies on protection of citizens’ rights in administrative duties of all government organs, and should device mechanisms to enforce the policies.
415. Plaintiffs indicate in these facts that county agents came to their home without a warrant and entered using coercion and force. This Intrusion Upon Seclusionis a violation of the first amendments right to privacy because one has an expectation of privacy and seclusion in one’s own home.
416. Plaintiffs were prevented from speaking with their children freely by monitoring their visits and telling parents what to say and not to say. The officials also took away visits if Plaintiffs expressed too much emotion or talked to their children truthfully about why they could not be together. This is a suppression of the First Amendment Right to Free Speech.
417. The Defendants also prevented children from communicating their true feelings and wishes with the court. On all occasion, children wished for the court to terminate jurisdiction and expressed this by crying and saying they wanted to be returned to their parents; however, the court suppressed this information and the children’s right to free speech.
418. Juvenile court judges and social workers conspired to prolong “dependency investigations” as a form of SLAPP or Strategic Lawsuit against Public Participation. Parents were told they could not discuss their case with anyone or criticize the court or agency. Judges issued gag orders while social workers and public defenders threatened parents that if they spoke out about the abuse they were experiencing, they would be sanctioned, thrown in prison, or would no longer get to visit their children.
419. The Defendants committed slander, libel, false light, defamation and perjury, by making, allowing the making of, and supervising the making of false statements about Plaintiffs. They shared, allowed the sharing of, and supervised the sharing of Plaintiffs’ Private Information by passing around case files.
420. The officials also violated Plaintiffs’ Fourth Amendment Right to be Free from Search and Seizure. The parents’ children were seized and detained from their parents.
421. Plaintiffs’ Eighth Amendment Right to be Free from Cruel and Unusual Punishment were also violated. Plaintiffs were falsely arrested and
422. Plaintiffs’ Fourteenth Amendment Rights to Due Process and Familial Association were also violated. Plaintiffs are informed and believe, and thereon allege that the right to familial association guaranteed under the Fourteenth Amendment is “clearly established” such that a reasonable social worker would know it is unlawful to remove a child from the care, custody, and control of her parent without good cause. In addition, there is a clearly established due process right not to be subjected to accusations on the basis of false evidence that was deliberately fabricated by the government, such that a reasonable social worker would know it is wrong to lie, fabricate evidence, and suppress exculpatory evidence.
423. The Defendants failed to provide reasonable efforts to prevent removal. The officials also failed to provide reasonable efforts to reunite families.
424. Commencing in approximately [year], and continuing until the present time, the Defendants were acting under color of state law when they acted, agreed and/or conspired to unlawfully examine, investigate, threaten, and make false reports resulting in the removal of the minor child from the custody of Plaintiff. The Defendants did so without proper justification or authority, and without probable cause. Further, Defendants’ actions were taken with deliberate indifference to Plaintiff’s rights, and without regard to the truth or falsity of the evidence presented to the court.
425. The Defendants maliciously conspired to violate the civil rights of Plaintiffs, including violation of Plaintiffs’ rights found in the Fourteenth Amendment of the United States Constitution, by, but not limited to, removing, detaining, and continuing to detain, [minor children] from the care, custody and control of their parents   , without proper or just cause and/or authority; by the use of coercion and duress to obtain, manufacture, and conceal evidence and testimony; and by maliciously falsifying evidence, and presenting fabricated evidence and perjured testimony to the court, and maliciously refusing to provide exculpatory evidence during the pendency of the dependency proceedings in violation of Government Code section 820.21, and violating the Constitutional rights of Plaintiff.
426. By these actions, the Defendants, and each of them, interfered and/or attempted to interfere with Plaintiffs’ constitutional rights to familial association under the Fourteenth Amendment, as well as those rights under applicable State Laws rising to the level of a constitutionally-protected right.
427. The Federal Defendants being the highest government authorities in the United States, had actual or constructive knowledge that the State and County officials were engaged in conduct that posed a pervasive and unreasonable risk of constitutional injury to citizens like the plaintiffs.
428. The Federal Defendants’ response to the knowledge was so inadequate as to show deliberate indifference to or tacit authorization of the alleged offensive practices.
429. There was an affirmative causal link between the Defendants’ inaction and the particular constitutional injury suffered by the plaintiffs.
430. As the direct and proximate result of the Defendants’ actions, Plaintiffs have suffered, and will continue to suffer, physical, mental, and emotional injury, all to an extent and in an amount subject to proof at trial. Plaintiffs have also incurred, and will continue to incur, attorneys’ fees, costs and expenses, including those authorized by 42 U.S.C. § 1988, to an extent and in an amount subject to proof at trial.
431. Federal Defendants and the respective state and county entities are vicariously responsible for the conduct of the SOCIAL WORKER DEFENDANTS, under Government Code section 815.2 and applicable other statutory and case law.

432. Plaintiffs hereby incorporate by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
433. 42 U.S. Code § 1985(3) states as follows:

434. In addition to the other State Defendants, the Federal Defendants are liable for this cause of action based on the following reasons. First, the US Government has several duties as documented in the US Constitution. The people of the US, through the Government, seek to form a more perfect union by establishing justice, ensuring domestic tranquility, providing for the common defense, promoting the general welfare, and securing the blessings of liberty to citizens and their posterity. The government is therefore mandated to exercise its authority directly by regulating, legislating, and issuing executive orders and court orders. It also grants authority to, and rescinds it from, government agencies and state and local governments.
435. Next, Joe Biden, as the President of the United States, is responsible for the execution and enforcement of the laws created by Congress. The President is both the head of state and head of government of the United States of America, and Commander-in-Chief of the armed forces. The primary duty of the president of the United States is to make sure that all U.S. laws are carried out and that the federal government runs effectively. He also directly oversees all agencies of the executive branch of government.
436. Kamala Harris is the Vice President of the United States. The office of the vice president is an integral part of the president’s administration. She is the president of the U.S. Senate, successor to the President, president’s advisor, congressional liaison, and representative of the president.
437. The Department of Health and Human Services is the United States government’s principal agency for protecting the health of all Americans and providing essential human services, especially for those who are least able to help themselves. The mission of the U.S. Department of Health and Human Services (HHS) is to enhance the health and well-being of all Americans, by providing for effective health and human services and by fostering sound, sustained advances in the sciences underlying medicine, public health, and social services.
438. The duties of Xavier Becerra, as the Secretary of the USDHHS, revolve around human conditions and concerns in the United States. This includes advising the president on matters of health, welfare, and income security programs. He is obligated to administer the Department of Health and Human Services to carry out approved programs and make the public aware of the objectives of the department.
439. The Department of Justice is mandated to enforce the law and defend the interests of the United States according to the law. The Department is also mandated to ensure public safety against threats both foreign and domestic. It also provides federal leadership in preventing and controlling crime, and seeking just punishment for those guilty of unlawful behavior. Lastly, it ensures fair and impartial administration of justice for all Americans.
440. Merrick B. Garland, as the Attorney General, is the nation’s chief law enforcement officer. He leads the Justice Department. Under his leadership, the Department of Justice is dedicated to upholding the rule of law, keeping America safe, and protecting the civil rights of all Americans.
441. The foregoing work and/or role descriptions of the Federal Defendants give them supervisory roles over all agencies and authorities from the federal government, state governments, and county authorities. They should be forefront in ensuring compliance with all laws. Notably, they should formulate policies on prevention of conspiracies in the delivery of administrative duties in all government organs and should device mechanisms to enforce the policies.
442. Plaintiffs aver that there was a conspiracy to deny them equal rights granted to them under the Fourteenth Amendment of the U.S. Constitution. The conspiracy involved using false written statements and affidavits as well as presentation of perjured oral testimonies in court.
443. 18 U.S. Code § 1621 provides that: “Whoever (1) having taken an oath before a competent tribunal, officer, or person, in any case in which a law of the United States authorizes an oath to be administered, that he will testify, declare, depose, or certify truly, or that any written testimony, declaration, deposition, or certificate by him subscribed, is true, willfully and contrary to such oath states or subscribes any material matter which he does not believe to be true; or (2) in any declaration, certificate, verification, or statement under penalty of perjury as permitted under section 1746 of title 28, United States Code, willfully subscribes as true any material matter which he does not believe to be true; is guilty of perjury and shall, except as otherwise expressly provided by law, be fined under this title or imprisoned not more than five years, or both. This section is applicable whether the statement or subscription is made within or without the United States.” In all instances, all statements were known by the Defendant to be materially false and were made under the color of state law.
444. The above-listed defendants have a policy, custom and pattern of practice, and act under color of law in their capacities as employees for local, county and state public entities, and on a daily basis falsify reports, to engage in acts of abuse of process, to defraud the general public by filing false reports in the juvenile courts for the County to justify excessive expenditures of taxpayers’ money and to fail to notify the courts as to the truth of matters which is that, the circumstances that brought the family to the attention of the court has been resolved, vastly improved, completed the reunification plan, or that there was no real detriment to begin with, and that the children are safe to return home.
445. Defendants conspired to deprive plaintiffs of their constitutional right to bring up their children without governmental interference and their right to bring up their child in Defendants and each of them, knowingly and willfully conspired, “acted in concert” and agreed among themselves to damage the Plaintiffs by depriving them of the privileges and rights within the Constitution of the United States of America.
446. Defendants also conspired to leave children in abusive situations and covered up real abuse in order to give rise to situations that would justify the need of an increased budget. These children were used as sacrificial lamb to boost statistics and show, “the dangers of what could happen if children were returned to their birth parents in general.” The scheme involved deliberately placing children with abusers and deliberately failing to prosecute the abuser despite evidence that they were the offending parent. This conspiratorial practice created the perfect storm of situations where the court and agency could continually be involved for longer periods of time.
447. Although, Plaintiffs do not have to allege every aspect of how the conspiracy was carried out the conspiracy went something like this. The Social worker gains knowledge of a family in crisis where children could potentially be in danger. Defendants participated with all other defendants and acted in concert, and denied plaintiff due process in the court, and Denied plaintiff right to bring up his child without governmental interference. All of the defendants caused the results of the constitutional rights violations, and each participated in the acts while acting under color of law.
448. Each Defendant “CAUSED” and “PARTICIPATED IN” the acts or omissions regarding the facts herein alleged either by “direct conduct, neglect or conspiracy”.
449. Defendants, and each of them, acting under color of state law, conspired to deprive, and did deprive, Plaintiff of her rights under the laws of the United States. Specifically, Defendants conspired to, and did: act, agree and/or conspire to unlawfully examine, investigate, threaten, and make false reports resulting in the removal of the minor child from the custody of Plaintiff. In addition, Defendants, and each of them, conspired to use trickery, duress, fabrication and/or false testimony or evidence, and failed to disclose exculpatory evidence in preparing and presenting reports and court documents to the court. The conduct of Defendants, and each of them, interfered with Plaintiff’s rights, including the right to familial association free from government interference as guaranteed by the Fourteenth Amendment of the Constitution of the United States.
450. Defendants, and each of them, engaged in said conspiracies for the purpose of depriving Plaintiffs of equal protection of the laws of the State of California and of the United States, and depriving them of their rights under the Constitutions of the United States and the State of California.
451. Defendants, and each of them, took several acts in furtherance of the conspiracy, including but not limited to, acting, agreeing and/or conspiring to unlawfully examine, investigate, threaten, and make false reports resulting in the removal of the minor child from the custody of Plaintiff; and by procuring false testimony, fabricating evidence, and failing to disclose exculpatory evidence in preparing and presenting reports and court documents to the court in relation to [minor child’s] dependency proceedings.
452. Plaintiffs did in fact suffer the deprivation of numerous rights granted to citizens of the United States, including those under the Fourth Amendment that protect against unreasonable seizure, and those under the Due Process Clause of the Fourteenth Amendment, which has been interpreted to protect the fundamental liberty interest of familial relations.
453. As the direct and proximate result of the Defendants’ actions, Plaintiff has suffered, and will continue to suffer, physical, mental, and emotional injury, all to an extent and in an amount subject to proof at trial. Plaintiff has also incurred, and will continue to incur, attorneys’ fees, costs and expenses, including those authorized by 42 U.S.C. section 1988, to an extent and in an amount subject to proof at trial.
454. On information and belief, SOCIAL WORKER DEFENDANTS acted with malice and with the intent to cause injury to Plaintiffs, or acted with a willful and conscious disregard to the rights of Plaintiffs in a despicable, vile and contemptible manner. Therefore, Plaintiffs are entitled to an award of punitive damages for the purpose of punishing SOCIAL WORKER DEFENDANTS, and to deter them and others in the future.
455. The Federal Defendants being the highest government authorities in the United States, had actual or constructive knowledge that the State and County officials were engaged in conduct that posed a pervasive and unreasonable risk of constitutional injury to citizens like the plaintiffs.
456. The Federal Defendants’ response to the knowledge was so inadequate as to show deliberate indifference to or tacit authorization of the alleged offensive practices.
457. There was an affirmative causal link between the Defendants’ inaction and the particular constitutional injury suffered by the plaintiffs.
458. As the direct and proximate result of the Defendants’ actions, Plaintiffs have suffered, and will continue to suffer, physical, mental, and emotional injury, all to an extent and in an amount subject to proof at trial. Plaintiffs have also incurred, and will continue to incur, attorneys’ fees, costs and expenses, including those authorized by 42 U.S.C. § 1988, to an extent and in an amount subject to proof at trial.

459. Plaintiffs hereby incorporate by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
460. 42 USC 1986. Action for neglect to prevent

461. The Defendants are liable for this cause of action based on the following reasons. First, the US Government has several duties as documented in the US Constitution. The people of the US, through the Government, seek to form a more perfect union by establishing justice, ensuring domestic tranquility, providing for the common defense, promoting the general welfare, and securing the blessings of liberty to citizens and their posterity. The government is therefore mandated to exercise its authority directly by regulating, legislating, and issuing executive orders and court orders. It also grants authority to, and rescinds it from, government agencies and state and local governments.
462. Next, Joe Biden, as the President of the United States, is responsible for the execution and enforcement of the laws created by Congress. The President is both the head of state and head of government of the United States of America, and Commander-in-Chief of the armed forces. The primary duty of the president of the United States is to make sure that all U.S. laws are carried out and that the federal government runs effectively. He also directly oversees all agencies of the executive branch of government.
463. Kamala Harris is the Vice President of the United States. The office of the vice president is an integral part of the president’s administration. She is the president of the U.S. Senate, successor to the President, president’s advisor, congressional liaison, and representative of the president.
464. The Department of Health and Human Services is the United States government’s principal agency for protecting the health of all Americans and providing essential human services, especially for those who are least able to help themselves. The mission of the U.S. Department of Health and Human Services (HHS) is to enhance the health and well-being of all Americans, by providing for effective health and human services and by fostering sound, sustained advances in the sciences underlying medicine, public health, and social services.
465. The duties of Xavier Becerra, as the Secretary of the USDHHS, revolve around human conditions and concerns in the United States. This includes advising the president on matters of health, welfare, and income security programs. He is obligated to administer the Department of Health and Human Services to carry out approved programs and make the public aware of the objectives of the department.
466. The Department of Justice is mandated to enforce the law and defend the interests of the United States according to the law. The Department is also mandated to ensure public safety against threats both foreign and domestic. It also provides federal leadership in preventing and controlling crime, and seeking just punishment for those guilty of unlawful behavior. Lastly, it ensures fair and impartial administration of justice for all Americans.
467. Merrick B. Garland, as the Attorney General, is the nation’s chief law enforcement officer. He leads the Justice Department. Under his leadership, the Department of Justice is dedicated to upholding the rule of law, keeping America safe, and protecting the civil rights of all Americans.
468. The foregoing work and/or role descriptions of the Federal Defendants give them supervisory roles over all agencies and authorities from the federal government, state governments, and county authorities. They should be forefront in championing the rights of the US Citizens. Notably, they should formulate policies on protection of citizens’ rights in administrative duties of all government organs, and should device mechanisms to enforce the policies.
469. Defendant Assistant Secretary for Children and Family Services continues to give billions of dollars to a system which fails to meet statutory requirements. Instead of not receiving any more Title IV funding, partnering states and communities continually get increased when they fail. Please see management scope in Exhibit 15 which indicates that the budget is currently $53 Billion dollars, yet not on the objectives have been achieved. Why would they ever change is failure is being rewarded?
470. Having stated a claim under the section 1985 above, the Plaintiffs therefore qualifies to state a claim pursuant to section1986. McCalden v. California Library Association, 955 F.2d 1214, 1223 (9th Cir. 1990)
471. Section 1986 imposes a good Samaritan duty on the defendants coupled with the strongest affirmative action duty for the enforcement of the 14th amendment rights and requires that the state officials in knowledge of the discriminatory nature of the family court procedures and the Department of Health and Human Services policies that intentionally inflict harm to families, must act to mitigate such harm from continuing.
472. The plaintiffs allege that the defendants had a “meeting of minds” to deprive the plaintiffs of their constitutional rights based on class and racial discriminative motives as the agents, social workers and judicial officials often target the poor, minority, and republic voting families to push forward their agenda of re-education, by defrauding the taxpayers of their dollars by pushing the children from these families through the foster system as alleged in the section 1985 claim above.
473. The Defendant Joe Biden, being the head of the federal government and the Head of State, has stood by idly, despite his advance knowledge that the defendant Xavier Becerra, the USDHHS, Merrick Garland, Gavin Newsom, related state officials and the United States Department of Justice violates the Fourteenth amendment rights of the plaintiff and all the members of the class and the American parents and families at large though their discriminative policies and practices. The President by overseeing the passage and the implementation of polices that deprive these groups of their rights to equal protection of the laws is liable pursuant to the section 1986.
474. The violations continue to target minorities and social classes throughout the president’s term in office. Xavier Baccara and Garland Merrick and the federal institutions they head are unrestrained despite the onslaught of politically motivated removal and termination of parent’s rights using threats of imprisonment and assault of parents and wrongful death that emanate from the authorities and personnel under the defendants’ authority and control.
475. The defendant Merrick Garland has failed to hold accountable and or, prosecute officer of the court even in cases where it is clear that they conspire against rights of parents by fabricating evidence, making falsified representation to court and Judges when they collude with police officer in order to deny this groups of parents and their children the equal protection of the law.
476. Under this claim the plaintiff must not show that the defendants themselves are not conspirators under 1985. The American civil right laws create liability when the defendant neither personally committed the neglect or engaged in a conspiracy to limit the plaintiff equal protection of law, nor acted with discriminatory intent. A negligent failure to protect by a state actor with the knowledge of section 1985 conspiracy and power to protect its victims is actionable.
477. The defendants and related state agents by reasonable diligence, through their offices and resources funded by the public for such purposes could have prevented the willful persecution of families. But, the defendants neglected and refused to prevent the actions and omissions leading to the physical and emotional injury to the plaintiffs and their children and to damage to their property. The defendants and related agents are therefore liable to the parties injured.
478. Defendants paid their sub-contractors Title IV funding even when they did not comply with statutory requirements – this represents a failure to discipline. This behavior also defeats the purpose of creating the statute because even when it is not followed, there is no consequence (See Exhibits – 10-11 -1 3). 130. Example Auditor’s report Exhibit 10 shows that even when more money is given, the systems do not correct the deficiencies.
479. As the direct and proximate result of the Defendants’ actions, Plaintiffs have suffered, and will continue to suffer, physical, mental, and emotional injury, all to an extent and in an amount subject to proof at trial. Plaintiffs have also incurred, and will continue to incur, attorneys’ fees, costs and expenses, including those authorized by 42 U.S.C. § 1988, to an extent and in an amount subject to proof at trial.

480. Plaintiffs hereby incorporate by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
481. Defendant county agents placed children in the most restrictive environment when the law says they should be in the least restrictive environment

482. Plaintiffs allege law enforcement misconduct by the Defendants who are mandated to enforce the laws enacted to protect children, families abuse victims and trafficking victims from abuse. The abusers have used their arbitrary positions to further inflict harm on the victims and to scare them into silence when they want to come out and seek help.
483. The reason for the law enforcement misconduct has been attributed by the Plaintiffs to be negligence from the side of the Defendants who did not practice due diligence when hiring the agencies’ personnel. They also did not take time to train these people, nor do they hold them accountable when complaints are brought against them.
484. The Supreme Court held in Monell v Department of Social Services that municipal entities are subject to § 1983 liability, but not on the basis of respondeat superior. This means that the officer in breach of his duties will be liable for his actions solely. The municipal will not be liable for hiring an employee who became a constitutional wrongdoer.
485. However, since the municipality in this case did not perform due diligence to hire competent people for these positions and has not taken seriously complaints made against these officials it will be held liable for harm caused to the victims, children and families.
486. Law enforcement misconduct opens the doorway for the violation of several human rights and freedoms secured under the Fourteenth Amendment Rights.
487. The Plaintiffs have alleged that the officers in the agencies have bullied them into silence when they try to report abuse. These officers have also failed to help victims of abuse to come out of their environment of abuse to safer places.

488. Excessive force is the unreasonable use of force in a particular situation.
489. The Plaintiffs have alleged the use of unreasonable force by the state officials and even the police in handling their cases. The Plaintiffs aver that there are times they have been forced into signing consent forms that determine their parenting plans or reunification plans. The force came in form of threats which left the Plaintiffs with no choice other than to consent. The motive of the State officials was to use the consent forms to fulfil their illegal monetary desires and breach the contract immediately after they receive what they want thus leaving the parents or families without redress.
490. The Plaintiffs also describe scenarios where the state officials and police arrive at their place of residence and forcefully carry away their children. They have also been forced into enduring unfair treatment from these officials for a long time as they have nowhere to report.
491. The force appl ied has led to serious injuries to the children and their parents which is a violation of their 4th Amendment Rights and 8^th Amendment Rights and consequently their 14^th Amendment rights. The fourth amendment rights provide that each person is free from unreasonable searches and seizures. The Due Process Clause under the 14^th Amendment right protects pretrial detainees from excessive force that amounts to punishment. The Eight amendment rights secure citizens’ freedom from cruel and unusual punishment.
492. State officials are subject to § 1983 lawsuits when they use unreasonable force to handle people. In determining whether the rights under the Fourth Amendment apply the court will look into the reasonableness of the force applied.
493. Plaintiffs have alleged that the police officers sometimes came armed to collect the children from their homes. There has also been physical force used on parents to make them sign consent documents. Children have also undergone some form of force, for instance, threats, to stop them from reporting abuse. This is an unreasonable force that violated their Fourth Amendment Rights.
494. In Graham v Connor, the Supreme Court looked into the objective reasonableness applied by law enforcement officers. The Supreme Court held that all claims that law enforcement officers have used excessive force-deadly or not-in the course of an arrest, investigatory stop, or other ‘seizure’ of a free citizen should be analyzed under the Fourth Amendment and its ‘reasonableness’ standard, rather than under a ‘substantive due process’ approach. Therefore, State officials are subject to § 1983 lawsuits and are liable for breach of the Fourth Amendment rights when they use excessive force when enforcing an order or when they want to coerce a person to do something.

495. The Plaintiffs aver that they have been threatened with imprisonment for refusing to hand over their children to strangers. Children have also been placed in the most restrictive environments when taken away from their parents and their homes.
496. False imprisonment is used interchangeably with unlawful imprisonment and happens when a person intentionally restricts the movement of another without legal authority, legal justification or the consent of the person being detained.
497. The Plaintiffs have had endure the harsh treatments and conditions when their children have been detained by the State officials without warrants or court orders. It is not in the best interest of a child to keep them separate from their parents. It certainly is cruel to take a newborn child from their mother and detain them for prolonged periods of time without justified cause.
498. The Plaintiffs (Parents) have themselves been detained for questioning, to be threatened, for investigation, examining or search without proper warrants or court orders.
499. These amount to a violation of the Eight Amendment Rights which provide the right to be free from cruel and unusual punishment. Falsely imprisoning parents and their children or threatening to do so amounts to cruel and unusual punishment. It is also a violation of their Fourth Amendment Rights which protect them from unlawful and unreasonable search and seizure. As a result, their Fourteenth Amendment Rights have been violated from the detention and continued withholding of the Plaintiffs children without just cause or authority.
500. The § 1983 claim on false imprisonment applies where the State officials are acting contrary to the law by forcing the parents to perform a certain act or face imprisonment.

501. Under Section 1983 malicious abuse of process comes about where prosecution is initiated legitimately and is thereafter used for other purposes other than that which was intended by the law. This is where the prosecution law is used to extortionate demand or cause the surrender of a legal right.
502. The Plaintiffs have averred that the Defendants have on several occasions threatened them into consenting different processes which cause them and their children harm. The laws enacted to protect children, families and abuse victims including trafficking victims from harm have been used to inflict harm by the defendants. This is in cases where the Defendants have taken away the Plaintiffs’ children without justified cause and detained the children away from their parents. They have also arrested the Plaintiffs and conducted searches on them without warrants or court orders.
503. The Plaintiffs have endured situations where they have been forced into silence when they want to come out to report abuse by the State officials. The laws that were enacted to protect abuse victims and take them out of abusive environments are not implemented in situations where they are required as the Defendants have employed incompetent personnel who are conducting the abuse.
504. These officials are liable under Section 1983 and should be held accountable for their actions. However, the people in charge of hiring them and receiving these complaints do not take on due process to investigate these claims. This is what has led to the bullying of the defendants into silence.

505. The Restatement (Second) of Torts § 46 provides that: “(1) One who by extreme and outrageous conduct intentionally or recklessly causes severe emotional distress to another is subject to liability for such emotional distress, and if bodily harm to the other results from it, such bodily harm.”
506. Intentional infliction of emotional distress has four elements: outrageous conduct by defendant; the intention of causing, or reckless disregard of the probability of causing, emotional distress; actual suffering of severe or extreme emotional distress; and actual and proximate causation of the emotional distress by the defendant’s outrageous conduct.
507. Throughout this Complaint, Plaintiffs have demonstrated the outrageous manner in which their child(ren) were taken away from them without due process or regard for the law. The bond between a parent and a child runs deep through their hearts and minds and should not be broken without any substantial reason. Defendant took away Plaintiffs’ child(ren) without regard for the consequences of their actions upon Plaintiffs and their child(ren). Defendant knew what its actions were doing to Plaintiffs and their child(ren) but still continued to deprive Plaintiffs of their parental rights.
508. Defendant’s actions have caused untold mental anguish and emotional distress upon Plaintiffs and their child(ren). Plaintiffs have sunk into depression and anxiety due to the uncertainty of what is happening to their child(ren) after they have been taken away from them. Some Plaintiffs have no knowledge of the whereabouts of their children. Plaintiffs have had to seek professional help from therapists to help them deal with the suffering that Defendant has put them through. Since it is impossible to reverse their emotional distress and restore them to the mental state they were in before the actions of Defendant, Plaintiffs seek compensation.

509. The Plaintiffs have accused foster parents or even people they lived with (for instance a parent’s boyfriend) of sexually abusing their children. These children have been abused either once or repeatedly. The violation has been reported to relevant authorities, that is the state officials responsible for ensuring the care and protection of children. Surprisingly, there has been little to no follow-up on these claims.
510. It is these state officials that are placing children with sexual predators and are not responding to reports of sexual abuse to take the children out of these environments.
511. The law of protection of children, families and victims of abuse was formulated to mandate the officials to take victims of abuse out of the abusive environment. These officials are also mandated under the law to investigate cases of abuse and charge the offenders for their actions.
512. Not investigating the reports and allowing the children to remain in these homes where the sexual abuse continues is a violation of their human rights under the Fourteenth Amendment Rights. This undermines the dignity of the children and their right to protection from cruel and unusual treatment under their Eighth Amendment Rights
513. Under Section 1983 liability the State officials are liable for placing the children in harmful environments where they are sexually abused and do nothing to protect the children when the matter is reported. The foster parents will also carry liability under this section as they are mandated by the law to protect the children and not inflict harm on them.

514. To hold a State official liable for wrongful death under Section 1983 it should be proved that the Defendant’s actions caused the death of the victim.
515. In our case, the Plaintiffs have claimed being pushed into depression which has caused them to consider suicide. This is from both the parents and the children.
516. The Parents may sink into depression when their children are unlawfully taken away from them and they are restricted from seeing them. No Parent would be okay if they cannot be with their children and they are unjustly kept away from them.
517. Children also sink into depression when they are placed in harmful or hostile environments away from the love and care of their parents. They are forced to live in undignified conditions and they consider suicide as a means of stopping the pain.
518. Some of these children may die from being exposed to these harmful and toxic living environments. The injuries inflicted on the Parents when they are being threatened to agree to a particular situation can also be life-threatening and cost them their lives.
519. Death caused by these situations should be blamed on the Defendants who were aware of the suffering but did nothing to mitigate the situation. Laws have been enacted to take victims out of these situations. If the State officials do not apply these laws for the protection of the children, they should be held accountable for any death that occurs.

520. In Albright v Oliver it was determined by the court that for a claim of malicious prosecution succeed under Section 1983 it should be proved that there was (a) institution of a criminal prosecution; (b) without cause; (c) with malice; and (d) termination is in favor of the accused.
521. The Plaintiffs have accused the Defendants of arresting and detaining them without warrants or valid court order. This has been done to arbitrarily insert the power of the Defendants into coercing the Plaintiffs to follow their instructions.
522. The Defendants have also falsely accused the Plaintiffs of misconduct which under the law amounts to them being declared unfit to keep their children. They have also threatened the Plaintiffs into agreeing to different situation plans which do not favor the Plaintiffs all for the Defendants’ gain. For example, forcing the Plaintiffs to release their children to strangers. This is done to enrich the State officials who will benefit from more children being placed in foster care.
523. The Defendants have gone to extremes of working with court officials to formulate false charges of which the Plaintiffs are charged and the court orders that their children be taken from their homes.
524. There is little to no investigation conducted to ascertain these claims which leaves the Plaintiffs in a prejudiced situation where their innocence is not proved. The Defendants do not obtain warrants or court orders when arresting the Plaintiffs to prosecute them and if they do they acquire them through false pretense or by lying about the conduct of the Plaintiffs.
525. These actions are sufficient to prove that any prosecution that occurs is conducted maliciously to inflict harm on the Plaintiffs. As the direct and proximate result of the Defendants’ actions, Plaintiffs have suffered, and will continue to suffer, physical, mental, and emotional injury, all to an extent and in an amount subject to proof at trial. Plaintiffs have also incurred, and will continue to incur, attorneys’ fees, costs and expenses, including those authorized by 42 U.S.C. § 1988, to an extent and in an amount subject to proof at trial.

526. Plaintiffs hereby incorporate by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
527. The United States Court of Appeals for the Sixth Circuit has set forth five elements of fraud upon the court which consist of conduct: “1. On the part of an officer of the court; 2. That is directed to the ‘judicial machinery’ itself; 3. That is intentionally false, willfully blind to the truth, or is in reckless disregard for the truth; 4. That is a positive averment or is concealment when one is under a duty to disclose; 5. That deceives the court.” Demjanjuk v. Petrovsky, 10 F.3d 338, 348 (6th Cir. 1993).
528. The doctrine of fraud upon the court has been characterized “as a scheme to interfere with the judicial machinery performing the task of impartial adjudication, as by preventing the opposing party from fairly presenting his case or defense.” In re Coordinated Pretrial Proceedings in Antibiotic Antitrust Actions, 538 F.2d 180, 195(8th Cir. 1976) (citations omitted); see also Rozier v. Ford Motor Co., 573 F.2d 1332, 1338 (5th Cir. 1978) (holding “only the most egregious misconduct, such as bribery of a judge or members of a jury, or the fabrication of evidence by a party in which an attorney is implicated, will constitute a fraud on the court”). Additionally, fraud upon the court differs from fraud on an adverse party in that it “is limited to fraud which seriously affects the integrity of the normal process of adjudication.” Gleason v. Jandrucko, 860 F.2d 556, 559 (2d Cir. 1998).
529. “One species of fraud upon the court occurs when an ‘officer of the court’ perpetrates fraud affecting the ability of the court or jury to impartially judge a case.” Pumphrey v. Thompson Tool Co., 62 F.3d 1128, 1130 (9th Cir. 1995); see also Weese v. Schukman, 98 F.3d 542, 553 (10th Cir. 1996) (noting that “fraud on the court should embrace only that species of fraud which does or attempts to, subvert the integrity of the court itself, or is a fraud perpetrated by officers of the court” (citation omitted); Kerwit Med. Prods., Inc. v. N. & Instruments, Inc., 616 F.2d 833, 837 (11th Cir. 1980) (same).
530. In addition to the other State Defendants, the Federal Defendants are liable for this cause of action based on the following reasons. First, the US Government has several duties as documented in the US Constitution. The people of the US, through the Government, seek to form a more perfect union by establishing justice, ensuring domestic tranquility, providing for the common defense, promoting the general welfare, and securing the blessings of liberty to citizens and their posterity. The government is therefore mandated to exercise its authority directly by regulating, legislating, and issuing executive orders and court orders. It also grants authority to, and rescinds it from, government agencies and state and local governments.
531. Next, Joe Biden, as the President of the United States, is responsible for the execution and enforcement of the laws created by Congress. The President is both the head of state and head of government of the United States of America, and Commander-in-Chief of the armed forces. The primary duty of the president of the United States is to make sure that all U.S. laws are carried out and that the federal government runs effectively. He also directly oversees all agencies of the executive branch of government.
532. Kamala Harris is the Vice President of the United States. The office of the vice president is an integral part of the president’s administration. She is the president of the U.S. Senate, successor to the President, president’s advisor, congressional liaison, and representative of the president.
533. The Department of Health and Human Services is the United States government’s principal agency for protecting the health of all Americans and providing essential human services, especially for those who are least able to help themselves. The mission of the U.S. Department of Health and Human Services (HHS) is to enhance the health and well-being of all Americans, by providing for effective health and human services and by fostering sound, sustained advances in the sciences underlying medicine, public health, and social services.
534. The duties of Xavier Becerra, as the Secretary of the USDHHS, revolve around human conditions and concerns in the United States. This includes advising the president on matters of health, welfare, and income security programs. He is obligated to administer the Department of Health and Human Services to carry out approved programs and make the public aware of the objectives of the department.
535. The Department of Justice is mandated to enforce the law and defend the interests of the United States according to the law. The Department is also mandated to ensure public safety against threats both foreign and domestic. It also provides federal leadership in preventing and controlling crime, and seeking just punishment for those guilty of unlawful behavior. Lastly, it ensures fair and impartial administration of justice for all Americans.
536. Merrick B. Garland, as the Attorney General, is the nation’s chief law enforcement officer. He leads the Justice Department. Under his leadership, the Department of Justice is dedicated to upholding the rule of law, keeping America safe, and protecting the civil rights of all Americans.
537. The foregoing work and/or role descriptions of the Federal Defendants give them supervisory roles over all agencies and authorities from the federal government, state governments, and county authorities. They should be forefront in championing the rights of the US Citizens,. Notably, they should formulate policies on protection of citizens’ rights in administrative duties of all government organs, and should device mechanisms to enforce the policies.
538. In the cases of all Plaintiffs, officers of the court made statements that were intentionally false in court with the intention of deceiving the courts and making them unable to make impartial decisions in regard to termination of parental rights of Plaintiffs. Court documents were fabricated to purposely mislead the courts to enter declarations and judgments that terminated Plaintiffs’ parental rights and took legal custody away from them.
539. The parents and child had a clearly established liberty interest in associating together. This right was violated where the defendants allegedly had no indication of any physical neglect of the child, no indication of any immediate threat to his welfare, and no indication of any criminal activity by his mother, where they only had third-hand hearsay where defendants refused to return the child, had not investigated to determine whether it was necessary to remove the child in the first place, and had not investigated the possibility of returning the child to his mother, grandmother, or anyone designated by the mother .Whisman V. Rinehart ( 8th Cir. 1997)
540. Child protection workers are subject to the 4th and 14th Amendment in the context of an investigation of alleged abuse or neglect are all government officials. The court ruled despite the defendants (Child protection Worker) exaggerated view of their powers ,the fourth Amendment applies to them, as it does to all other officers and agents of the state whose request to enter ,however begin or well-intentioned, are met by a closed door.
541. The fourth Amendment’s prohibition on unreasonable searches and seizures applies whenever an investigator, be it a police officer a DCFS employee, or any other agent of the state, responds to an alleged instance of child abuse, neglect, or dependancy.3:01-cv-7588 Walsh v. Erie County Department of Job and family Services.
542. A due process violation occurs when a state -required breakup of a natural Family is founded solely on a best interest analysis that is not supported by the requisite proof of parental unfitness. Quilloin v. walcott (1978) 434 U.S. 246,25541.
543. Plaintiff in Brokaw,305 F.3d 660 (8^th2002), brought suit against defendants in the child neglect office based on a conspiracy to take away her children. The seventh circuit held that Rooker-Feldman did not bar her claims significantly, and similarly to the case at bar, Brokaw alleged that “The defendants conspired -prior to any judicial involvement -to cause false child neglect proceedings to be filed .” Id. at 665.
544. The seventh Circuit specifically held that the plaintiff’ is not merely claiming that the decision of the state court was incorrect or that the decision violated her constitutional right; rather, she is alleging that the people involved in the decision to forcefully remove her from her home and her parents and subject her to the custody of {child Services) violated her constitutional rights, independently of the state court decision.
545. Up to 83% of all investigations are ultimately concluded to have involved no abuse or neglect. ONLY INNOCENT FAMILIES! We believe that parents have the fundamental right to the care, custody and control of their children so long as the child is not harmed.
546. Fraud Upon the Court
547. One of the most frequent ways Defendants obtain adverse judgements against parents is by committing fraud upon the court and intentionally offering “(a) misrepresentations (false representation, concealment, or nondisclosure); in their statements to the court.
548. Social workers are quasi court officials. Prosecutors, judges, children’s attorney and parents attorneys are all officers of the court. In Bulloch v. United States, 763 F.2d 1115, 1121 (10th Cir. 1985), the court stated “Fraud upon the court is fraud which is directed to the judicial machinery itself and is not fraud between the parties or fraudulent documents, false statements or perjury …. It is where the court or a member is corrupted or influenced or influence is attempted or where the judge has not performed his judicial function — thus where the impartial functions of the court have been directly corrupted.”
549. Appeals court have previously recognized a constitutional right under the Due Process Clause of the Fourteenth Amendment to be free from judicial deception and fabrication of evidence in the context of civil child custody cases. See Costanich v. Dep’t of Soc. and Health Servs., 627 F .3d 1101, 1108 (9th Cir. 2010) (“[D]eliberately fabricating evidence in civil child abuse proceedings violates the Due Process clause of the Fourteenth Amendment when a liberty or property interest is at stake “); Wallis v. Spencer, 202 F .3d 1126, 1142 (9thCir. 2000) (stating “parents have a right arising from the liberty interest in family association to be with their children while they are receiving medical attention” and “children have a corresponding right to the love, comfort, and reassurance of their parents while they are undergoing medical procedures”).
550. “To support a § 1983 claim of judicial deception, a plaintiff must show that the defendant deliberately or recklessly made false statements or omissions that were material to the finding ” KRL v. Moore, 384 F .3d 1105, 1117 (9th Cir. 2004)
551. A plaintiff who provides direct evidence of false statements can allege deliberate fabrication of evidence in violation of constitutional due process guarantees. See Costanich, 627 F.3d at 1108. “Reporting that a witness said something he or she did not cannot reasonably be characterized as a recording error or a misstatement,” but is instead fabricated evidence. Reynolds v. County of San Diego, 224 F. Supp. 3d 1034, 1055 (S.D. Cal. 2016) rev’d in part on other grounds sub nom. Reynolds v. Bryson, 716 F. App’x 668 (9th Cir. 2018) (citation omitted).
552. Furthermore, in the search warrant context, we have previously held that an omission of a fact necessary to establish probable cause presented a triable issue of material facts about whether that omission “amounted to at least reckless disregard for the truth.” Bravo v. City of Santa Maria, 665 F.3d 1076, 1088 (9th Cir. 2011). Examples of judicial deception in child protective custody cases are illuminating. In Reynolds, a district court held that omission of two words from medical notes was “[a]t worst . a reporting error or misstatement” and not sufficient evidence of deliberately or recklessly false statements or material. 224 F. Supp. 3d at 1056 (citation omitted). By contrast, in Costanich, we held that allegations that a social worker falsely claimed to have interviewed several witnesses in connection with a child protective custody case presented a triable issue of material fact that there was deliberate fabrication of evidence. 627 F.3d at 1112-14. In Greene v. Camreta, 588 F.3d 1011 (9th Cir. 2009), vacated in part, 563 U.S. 692 (2011), 661 F.3d 1201 (9th Cir. 2011), we held that “proof, in the form of [an] affidavit and deposition testimony, that [defendant] included false statements in his affidavit requesting a protective custody order,” id. at 1035, was sufficient to present a genuine issue of material fact of judicial deception to which qualified immunity did not apply and summary judgment was inappropriate, see id. at 1035-36.
553. The Plaintiffs have alleged judicial deception sufficient to meet the constitutional standard, if not the heightened pleading standard of Rule 9(b), to overcome the County’s motion to dismiss under Rule 12(b)(6). Finally, the alleged misrepresentation was material to granting of the juvenile court’s Orders.

554. Never do attorneys appointed by dependency courts reveal they speak to opposing counsel without informing client/plaintiffs; receive documents served on the parent’s behalf. Court officials have a practice of holding secretive hearings without knowledge of parents and having exparte hearings where they make arguments when the parents are not there to defend themselves.
555. In every case before your Honorable, these court appointed attorneys do not say objections as asked to do so. They defraud parents and children by pretending to be their advocate while working against them as much as possible.
556. Court appointed attorneys do not submit evidence on the plaintiffs’ behalf when asked to do so to help defraud the court and the client. 209. They regular ignore constitutional liberties to the extent of stating through their action and inaction that, “the constitution does not apply here” and “there is no time to argue the constitution”.
557. The written, stated, sworn, and understood definition of “representation” is nothing of this sort and is stated in the DOG BOOK Dependency handbook for attorneys, stating their role is to “make the process smoother” for opposing party; attorneys are not there to “represent” the parents but mitigate resistance. A fact which is never disclosed to distraught parents.
558. Court appointed attorneys do not contact or communicate with parents until 10 minutes before the 1st hearing. This violates the service of paperwork rules of court.
559. Similarly prosecutors are not working in the interest of justice but in the interest of the department and securing more wins and funds for the county agency they work for.
560. These attorneys are forced to follow department lead, which is unstated and unwritten, again at the department’s will, and have court watchers to make sure of this as training states from the Capacity Building in DC. In other words, if an attorney attempts to properly represent, the department can and will remove them.
561. Reunification services are provided to give kickbacks to preferred providers who go along with the department agenda. They are not provided in good faith as a protective measure to ensure safe homes.

562. Parents are indentured servants and are subject to peonage and involuntary servitude as they are human chattel forced to attend endless services that only benefit the provider’s bottom line.
563. Lives are disrupted and jobs are lost as Plaintiffs cannot hold regular jobs because they must contract with service providers of the departments choice that are inconvenient locations, do not offer the services parent needs, or have working hours that conflict with the work schedule of the Plaintiffs.
564. If Plaintiffs do not go to these services, they are threatened that their children will never come home. No consideration is made for parents who have made changes on their own without services.
565. Children are seized without warrants and return of them becomes the discretion of a social worker and not the imposed service completion.
566. Servitude is required for release of children. Social services forces housing and drug services for parents never convicted of drug offenses. The time and duration of services is capricious and ambiguous.

567. Even when parents complete the programs the DEFENDANTS will not provide the record to the court or claim the program was not effective as a way of intentionally misleading the court.
568. Courts tell the parents the wrong time to come to court. The deliberately tell them that their time is early in the morning but they do not call the parents’ court case until last as a way to lie to the parent.

569. Parent Plaintiffs are told by officers of the court that Juvenile Dependency is quasi-criminal or even civil in nature. Neither is fact, Juvenile dependency falls under administrative law, which is regulated by the APA and case law such as “Chevron”, which explains the deference given to agencies. A parent, when pro se or for mere understanding purposes cannot make sense of what is happening to them in court because the laws they seek for reference that has been spoken as superseding the venue is Civil or Quasi-criminal. Attorneys and the Courts do not disclose this as fact, tend to “pick and pull” statutes as they chose to benefit the agency, and ignore the law of the land we as Americans know, defend and have sacrificed all to retain.
570. Parents believe, and rightfully so, they will never see their children again if they do not comply with agency demands despite and in spite of innocence.
571. A court appointed attorney in dependency hearings tried to induce parents to rely on their sham services instead of going with the gut instinct and acting in their best interest.
572. These attorneys have a conflict of interest because they are paid by the county and do not benefit if the client wins or if trial/interactions are of short duration.
573. Keeping the peace with their peers in the Juvenile Court room rather than representing and presenting parents are of the most importance to them. This is made clear when all entities within the venue enjoy holiday parties and exchange gifts and even enjoy lunch breaks together. The “appearance” of impropriety exists, the fraud of the action commences soon after.
574. The fact is that all proceedings in juvenile dependency have pre-printed and predurational time frames. This in itself shows a factory-like process not an individualized service for families as clearly stated in the Family First Act and all legislative intent acts established by congress.
575. Children are seized without exigency in nearly every case before Your Honorable, and finding of unfitness in court has not been established prior to removal as Judicial Findings have established time again.
576. After which the return of children becomes contingent upon a service that is only rendered if admission of guilt is made. This is the parallel definition of extortion, to release bondage of kidnapping, child being held until services rendered by parent. Yet even at the end of a completion to demanded services, for the child to return, the agency retains discretion to actually return child to parent. The calculation to determine this then becomes the time already stolen and “best interest” with interest in monetary accumulation county prospectively can claim from child needs if kept in system.

577. Child Welfare, once contacted by them, causes a do or die situation for families. Plaintiff Parents who are told to do services or “reunification” which do not eventually reunite parents with their children as followed. Instead, they are forced into an open-ended contract made under duress which the social worker can use to manipulate the parent who initially believes they are operating in good faith.
578. As the direct and proximate result of the Defendants’ actions, Plaintiffs have suffered, and will continue to suffer, physical, mental, and emotional injury, all to an extent and in an amount subject to proof at trial. Plaintiffs have also incurred, and will continue to incur, attorneys’ fees, costs and expenses, including those authorized by 42 U.S.C. § 1988, to an extent and in an amount subject to proof at trial.

579. Plaintiffs hereby incorporate by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.

580. Parents’ attorneys conspired with the other defendants to not present an adequate defense for the parents. They threaten parents into taking plea deals by telling them they will never see their children against.

581. Defendant Government Agents owe a duty of care to their citizens. They must care because they took an oath to uphold the constitution and protect the citizens. They owe Plaintiffs a duty of loyalty and to diligently try to solve the problem within their powers and abilities. They have a lot of power and resources to address the issue and prevent it from happening.
582. Social workers also have a special relationship with Plaintiffs and are supposed to act in a way as to not harm the parents or act as enemy number one. They have a plethora of resources at their disposal to help families that they underutilize.
583. Truly helpful resources are sidelines while the most harmful and restrictive treatments they can think of are utilized.
584. They do not listen to clients or attempt to gather relevant facts as required by their job description (Exhibit Social Worker Job Ad). They do not understand cultural differences or help families. They create their own narrative that usually casts parents and children in their worst possible light and continue to deliberately antagonize them even as they can see they are experiencing emotional turmoil.

585. It is well-establish public policy that, social workers have an affirmative duty to work for the client’s best interest and welfare as consented to by the client.

586. Agents are often not trained on legal aspects of the job and don’t acquire adequate and appropriate trainings and discussions on how to protect the rights of clients.

587. Supervisors in higher positions like the DEFENDANTS are supposed to know the law and convey this knowledge to their subordinates. DEFENDANTS have recklessly disregarded having these training with agencies that they fund. When the agencies harm people with their conduct it is the fault and cause of the failure of the Defendants to train.
588. As in the police brutality cases, you must train officers on the consequences and ramifications of deadly force. They should know when it is necessary and when it is legal. Giving police a dangerous weapon and not telling them this disclosure is a failure to train which puts the public in danger.
589. In the same way, giving money and power to agencies to remove children from home and subject children and adults to endless rounds of therapy; but not training them on Constitutional rights, Federal Law, and State Law is like giving a loaded gun to these agencies to shoot and kill their citizens legally.

590. Social workers request excessive continuances that they not are against the law and harm children emotionally, but they show no sympathy.
591. Parents attorneys do not speak up against excessive continuances when the children should no longer be detained, and judges grant the orders. Yes, these is no disciplinary action taken if they do these things. Various boards and agencies pass the buck and assume no responsibility for ensuring due process of law. (Exhibits Letter to Greg Abbot, Letter to Consumer Affairs)
592. These individuals who hold positions of public trust attempt to separate children and families for as long as possible and then say that they children have a bond with the new caregivers. Again, they caused the situation and were deliberately trying to sever the familial bond which is a breach of fiduciary and social worker malfeasance.
593. Agencies do not reprimand social workers when they authorize medical treatments on children without the consent or notice of parents. Social workers have in these cases described practiced medicine and attempted diagnose parents with mental disorders and suggest they should be taking prescribed medication, even when medical professionals have said the contrary.

594. Even if providing services free of charge to parents, attorneys are still being compensated by the state. The law states that even when services are free agents must still behave with diligence, loyalty, and in the overall interest of the client.
595. Attorneys here give wrong and bad advice to parents like telling them to wait until the end to present evidence or appeal. Many times, parents lose appeals opportunities because of the wrong advice given by their attorney who is self-dealing and getting kickbacks from letting the case mature.
596. When Counties do not provide adequate notice to Plaintiffs about the nature of the hearings so Plaintiffs could be prepared for the hearing, and it be a meaningful hearing, attorneys encourage clients to disregard the prejudice and just let it happen.
597. Domestic violence victims have nowhere to turn because the social worker, police, attorneys, and judges are all corrupt.
598. As the direct and proximate result of the Defendants’ actions, Plaintiffs have suffered, and will continue to suffer, physical, mental, and emotional injury, all to an extent and in an amount subject to proof at trial. Plaintiffs have also incurred, and will continue to incur, attorneys’ fees, costs and expenses, including those authorized by 42 U.S.C. § 1988, to an extent and in an amount subject to proof at trial.

599. Plaintiffs hereby incorporate by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
600. Defendants breach their affirmative Duty to Protect when they cause harm to clients and show a deliberate disregard for their safety, consent, or wishes. Social workers who do the right thing are often quit, while the black hearted workers get promotions (See Exhibit 13)

601. Reunifications plans, also called service plans, are supposed to benefit the recipient but the only people who benefit are the providers. The Defendants made money from constantly referring the parent or child to another agency, who also makes money.

602. The contracts are unconscionable because parents cannot decline to participate and find their own provider or solve the problem themselves. The Defendants forced Plaintiffs to contract with theses ‘ministries’ or ‘agencies’ because if they do not cooperate, they will never see their children again. As described in the affidavits, parents and children are made to repeatedly receive services regardless of necessity or effectiveness, at the whim and arbitrariness of a social worker who has all the bargaining power. The government has delegated them this authority.

603. The agencies and service providers have more bargaining power and thus the contracts are void because they amount to involuntary servitude and a constitutional violation of all men and women being created equal and being able to make decisions for themselves.
604. Contract of Adhesion – the terms of the contract cannot be bargained for and one must accept all the terms and conditions.
605. Anticipatory Repudiation – even after completing the terms of the plan, social workers can change the plan at will, add new terms, or find another reason to completely derail the plan after Significant Performance by the parent or child.
606. Express Warranties – service providers have no incentive for their program to be effective because the less effective the program is, the longer the parent has to stay and the more clients they have. Even after attending these so-called therapies, social workers determine the therapy didn’t work and blame the client that they did not work instead of acknowledging, their therapy did not work is nothing more than quackery.
607. Implied Warranties – in all contracts there is an implied warranty of good faith and fair dealing under the common law; however, these contractors traffic human beings and destroy families with their services that do more harm than good. They know their services are harmful and use them any way which is bad faith and unfair dealing.
608. As the direct and proximate result of the Defendants’ actions, Plaintiffs have suffered, and will continue to suffer, physical, mental, and emotional injury, all to an extent and in an amount subject to proof at trial. Plaintiffs have also incurred, and will continue to incur, attorneys’ fees, costs and expenses, including those authorized by 42 U.S.C. § 1988, to an extent and in an amount subject to proof at trial.

609. Plaintiffs hereby incorporate by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
610. While Congress has not enacted a direct counterpart to § 1983, which authorizes claims for relief based on constitutional violations by state and local officials, the Supreme Court, in its seminal 1971 decision, Bivens v. Six Unknown Named Agents, recognized an implied claim for damages when federal law enforcement officers violate an individual’s Fourth Amendment rights. The Bivens claim is a personal-capacity claim against the officer(s) responsible for the constitutional violation.
611. Expanding on the Bivens framework, the Court held in Davis v. Passman that a damages claim could be asserted against federal officials for alleged violations of the equal protection principles of the Fifth Amendment.
612. It is crucial to emphasize that both Bivens and Davis underscored the judiciary’s primary responsibility for upholding federal constitutional rights. They emphasized that damages have historically served as the “ordinary remedy for an invasion of personal interests in liberty.”
613. The Court recognized, however, that the failure to acknowledge the Bivens damages remedy against federal officials could leave plaintiffs without a remedy. This is particularly relevant because constitutional claimants, similar to Webster Bivens and Shirley Davis, often lack claims for prospective relief. Additionally, they are typically unable to seek damages against the United States or federal governmental agencies due to sovereign immunity.
614. The Court did acknowledge that the Bivens remedy might be denied if Congress has created an “equally effective” alternative remedy or when “special factors counsel hesitation in the absence of affirmative action by Congress.”
615. In 1980, in Carlson v. Green, the Supreme Court extended the Bivens doctrine to a suit by the administratrix of a deceased federal prisoner. The complaint alleged that the failure of federal prison officials to provide adequate medical care violated the Eighth Amendment’s prohibition against cruel and unusual punishment. The Court recognized the Bivens claim even though the prisoner had an alternative remedy under the Federal Tort Claims Act (FTCA). The Court in Carlson found that (1) Congress did not intend for the FTCA to be the exclusive remedy.
616. When a plaintiff in a federal court is entitled to assert a Bivens claim for money damages based on an alleged constitutional violation by a federal official, the same procedures and legal principles that apply in § 1983 actions typically apply in the Bivens lawsuit. In Ashcroft v. Iqbal, the Supreme Court affirmed that “[i]n the limited settings where Bivens does apply, the implied cause of action is the ‘federal analog to suits brought against state officials under . . . 42 U.S.C. § 1983.”
617. As previously outlined, the Federal Defendants are liable for the allegations made in this Complaint for the following reasons. First, the United States Government, as outlined in the U.S. Constitution, has several enumerated duties. Through its actions and policies, it seeks to establish justice, ensure domestic tranquility, provide for the common defense, promote the general welfare, and secure the blessings of liberty for all citizens and their posterity. The government exercises its authority directly through regulation, legislation, executive orders, and court orders, as well as indirectly through government agencies and state and local governments.
618. Furthermore, Joe Biden, as the President of the United States, is entrusted with the responsibility for the execution and enforcement of laws created by Congress. As both the head of state and head of government, and as Commander-in-Chief of the armed forces, his primary duty is to ensure the effective operation of the federal government and the faithful execution of all U.S. laws. This includes direct oversight of all executive branch agencies.
619. Kamala Harris holds the office of Vice President of the United States, an integral part of the presidential administration. Her role encompasses various responsibilities, including serving as President of the U.S. Senate, successor to the President, presidential advisor, congressional liaison, and presidential representative.
620. The Department of Health and Human Services (USDHHS) is the principal agency of the United States government dedicated to safeguarding the health of all Americans and providing essential human services, particularly for those who are most vulnerable. USDHHS’s mission is to enhance the health and well-being of all Americans by delivering effective health and human services and promoting significant, sustainable advancements in the fields of medicine, public health, and social services.
621. As the Secretary of USDHHS, Xavier Becerra is entrusted with duties that relate to human conditions and concerns within the United States. These responsibilities include advising the President on matters of health, welfare, and income security programs. He is obligated to administer the Department of Health and Human Services, overseeing approved programs and communicating the department’s objectives to the public.
622. The Department of Justice (DOJ) is charged with enforcing the law and safeguarding the interests of the United States in accordance with legal principles. DOJ is tasked with ensuring public safety from both foreign and domestic threats, providing federal leadership in preventing and controlling crime, and pursuing just punishment for those found guilty of unlawful behavior. Additionally, it ensures fair and impartial administration of justice for all Americans.
623. Merrick B. Garland, serving as the Attorney General, assumes the role of the nation’s chief law enforcement officer and leads the Justice Department. Under his leadership, the Department of Justice is unwavering in upholding the rule of law, preserving the safety of America, and protecting the civil rights of all citizens.
624. The work descriptions of the Federal Defendants outlined above give them supervisory roles over all agencies and authorities within the federal government, state governments, and county authorities. They are expected to champion the rights of U.S. Citizens, formulate policies for the protection of citizens’ rights in the administrative duties of all government bodies, and establish mechanisms to enforce these policies.
625. Unfortunately, the Defendants have failed to fulfill their solemn obligations as delineated above. This failure is evident in the widespread violation of parental rights, including the forceful termination of parental rights, as outlined in this Complaint. These violations have persisted across many states, seemingly unaddressed by the federal government. Consequently, this Complaint is filed against the Federal Defendants.
626. As a direct and proximate result of the Defendants’ actions and/or inactions, Plaintiffs have suffered, and will continue to suffer, physical, mental, and emotional injuries, the extent and magnitude of which will be substantiated during trial. Additionally, Plaintiffs have incurred, and will continue to incur, attorneys’ fees, costs, and expenses, including those authorized by 42 U.S.C. § 1988, the exact amount of which will be demonstrated during the trial proceedings.

627. Plaintiffs hereby incorporate by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
628. 28 USC 1361 is the Mandamus Act which provides that the district courts shall have original jurisdiction of any action in the nature of mandamus to compel an officer or employee of the United States or any agency thereof to perform a duty owed to the plaintiff.
629. With this cause of action, Plaintiffs seek to have all Defendants compelled to perform their duties and obligations.
630. First, Plaintiffs have a clear right to the relief requested. Plaintiffs file this Complaint because the juvenile dependency scheme between the United States Federal Government, its agencies, the 50 states, their municipalities, their contractors, and private citizens have been fundamentally corrupted by malicious actors who have breached their fiduciary duty to the people and have broken their sworn oath to protect and uphold the Constitution. Instead of an being an honest service scheme to keep families together, strengthen communities, keep children safe and stop human trafficking, the Defendants abused, financed, or acquiesced to the absue of the child custody system in the United States, thus depriving families of their parental rights.
631. The US Government has several duties as documented in the US Constitution. The people of the US, through the Government, seek to form a more perfect union by establishing justice, ensuring domestic tranquility, providing for the common defense, promoting the general welfare, and securing the blessings of liberty to citizens and their posterity. The government is therefore mandated to exercise its authority directly by regulating, legislating, and issuing executive orders and court orders. It also grants authority to, and rescinds it from, government agencies and state and local governments.
632. Next, Joe Biden, as the President of the United States, is responsible for the execution and enforcement of the laws created by Congress. The President is both the head of state and head of government of the United States of America, and Commander-in-Chief of the armed forces. The primary duty of the president of the United States is to make sure that all U.S. laws are carried out and that the federal government runs effectively. He also directly oversees all agencies of the executive branch of government.
633. Kamala Harris is the Vice President of the United States. The office of the vice president is an integral part of the president’s administration. She is the president of the U.S. Senate, successor to the President, president’s advisor, congressional liaison, and representative of the president.
634. The Department of Health and Human Services is the United States government’s principal agency for protecting the health of all Americans and providing essential human services, especially for those who are least able to help themselves. The mission of the U.S. Department of Health and Human Services (HHS) is to enhance the health and well-being of all Americans, by providing for effective health and human services and by fostering sound, sustained advances in the sciences underlying medicine, public health, and social services.
635. The duties of Xavier Becerra, as the Secretary of the USDHHS, revolve around human conditions and concerns in the United States. This includes advising the president on matters of health, welfare, and income security programs. He is obligated to administer the Department of Health and Human Services to carry out approved programs and make the public aware of the objectives of the department.
636. The Department of Justice is mandated to enforce the law and defend the interests of the United States according to the law. The Department is also mandated to ensure public safety against threats both foreign and domestic. It also provides federal leadership in preventing and controlling crime, and seeking just punishment for those guilty of unlawful behavior. Lastly, it ensures fair and impartial administration of justice for all Americans.
637. Merrick B. Garland, as the Attorney General, is the nation’s chief law enforcement officer. He leads the Justice Department. Under his leadership, the Department of Justice is dedicated to upholding the rule of law, keeping America safe, and protecting the civil rights of all Americans.
638. The foregoing work and/or role descriptions of the Federal Defendants give them supervisory roles over all agencies and authorities from the federal government, state governments, and county authorities. They should be forefront in championing the rights of the US Citizens. Notably, they should formulate policies on protection of citizens’ rights in administrative duties of all government organs, and should device mechanisms to enforce the policies.
639. The other Defendants also have their own duties and obligations, which are unique to each of their offices.
640. As defined inBoothe v. Roofing Supply, Inc. of Monroe, 893 So.2d 123 (2005)  “arbitrary and capricious conduct is willful and unreasonable action without consideration or regard for the facts and circumstances.”
641. Arbitrary and capricious is a standard for judicial review and appeal, often seen in administrative law. Under this standard, the finding of a lower court will not be disturbed unless it has no reasonable basis, or if the judge decided without reasonable grounds or adequate consideration of the circumstances.
642. Although there is no set standard for an arbitrary and capricious decision, guidance can be found in Natural Resources Defense Council, Inc. v. United States EPA: “5 U.S.C. § 706(2)(A) authorizes the court to “set aside agency action … found to be … arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with the law.” Under this standard, a court must find a “rational connection between the facts found and the choice made” per Motor Vehicle Mfrs. Ass’n v. State Farm Mut. Auto. Ins. Co. (1983). The court must decide whether the agency considered the relevant factors and whether there has been a clear error of judgment; Citizens to Preserve Overton Park, Inc. v. Volpe, 401 U.S. 402, 416 (1971).
643. The Defendants removed Plaintiffs’ children, fincanced the removal, or acquiesced to the removal, without good cause. Those decisions, the actions and/or inactions of the Defendants were not only against the best interest of the children, but also violated the Plaintiffs’ due process rights.
644. Plaintiffs have no other adequate remedy available for the injuries and harm they suffered as a result of Defendants’ actions and/or inactions. No amount of monetary damages would sufficiently compensate Plaintiffs for the injuries they have suffered as a result of the allegations made herein.
645. The Defendants should therefore be compelled to perform all of their obligations and duties, to inter alia, recognize and protect the Plaintiffs’ rights under all laws, and to use the child custody system fairly and lawfully.

646. Plaintiffs hereby incorporate by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
647. There now exists, between the parties hereto, a dispute and controversy to which the Plaintiff and the Defendants are entitled to have a declaration of their rights and further relief relating to the facts and circumstances as set forth in this action.
648. Plaintiffs respectfully request this Honorable Court issue a declaratory judgment declaring that the actions and/or inactions of the Defendants violate the rights of Plaintiffs.

649. Officials are sheltered from suit, under a doctrine known as qualified immunity when their conduct “does not violate clearly established constitutional rights as a reasonable official, similarly situated, would have comprehended.” Harlow v. Fitzgerald, 457 US 800 (1982). The state employees’ actions of unlawfully taking away Plaintiffs’ children without following due process that involved proving by clear and convincing evidence that it was in the best interests of Plaintiffs’ children to terminate Plaintiffs’ parental rights violated a clearly established constitutional right, the Fourteenth Amendment. The familial right of association is embodied in the concept of liberty in the Fourteenth Amendment.
650. Qualified immunity protects an executive official who violated the plaintiffs federally protected right so long as the official did not violate clearly established federal law. In Saucier v. Katz, 533 US 194 (2001), the Supreme Court held that when qualified immunity is asserted as a defense, the court must first determine if the complaint states a violation of a federally protected right, and only if it does, then proceed to determine whether that right was clearly established.
651. Plaintiffs have stated violation of their Fourteenth Amendment rights by employees of various states acting under the color of law. The Fourteenth Amendment is a clearly established right which gives a fair and clear warning as follows: “No state shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any state deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.”
652. “The doctrine of qualified immunity protects Defendants from liability for civil damages unless a plaintiff pleads facts showing (1) that the official violated a statutory or constitutional right, (2) that the right was clearly established at the time of the alleged conduct.” Ashcroft v. al-Kidd, 563 US 731 (2011).
653. In the fact pattern of this Amended Complaint, Plaintiffs have stated facts showing that state employees across various states in the United States deprived Plaintiffs of their Fourteenth Amendment right by denying them the familial right of association embodied in the concept of liberty. The state employees unlawfully took away Plaintiffs’ children without proving that it was in the best interests of the children to terminate Plaintiffs’ parental rights by clear and convincing evidence. The Fourteenth Amendment was ratified in 1868. Therefore, it was established at the time the state employees deprived Plaintiffs of their Fourteenth Amendment right.
654. In Causey v. City of Bay City, 353 F. Supp. 2d 864 (2005), it was held as follows: “The Sixth Circuit has expanded that inquiry into a three-step sequential analysis when the qualified immunity defense is raised in a summary judgment motion brought after some discovery has been conducted, as here. “The first inquiry is whether the plaintiff has shown a violation of a constitutionally protected right; the second inquiry is whether that right was clearly established at the time such that a reasonable official would have understood that his behavior violated that right; and the third inquiry is `whether the plaintiff has alleged sufficient facts, and supported the allegations by sufficient evidence, to indicate that what the official allegedly did was objectively unreasonable in light of the clearly established rights.'” Tucker v. City of Richmond,388 F.3d 216, 220 (6th Cir.2004) (quoting Higgason v. Stephens, 288 F.3d 868, 876 (6th Cir.2002); Champion, 380 F.3d at 901) (citing Feathers v. Aey, 319 F.3d 843, 848 (6th Cir.2003)).” “In the civil sphere, we have explained that qualified immunity seeks to ensure that defendants “reasonably can anticipate when their conduct may give rise to liability,” , at 195, by attaching liability only if “[t]he contours of the right [violated are] sufficiently clear that a reasonable official would understand that what he is doing violates that right.” United States v. Lanier, 520 U.S. 259 (1997).
655. Throughout this Complaint, Plaintiffs have demonstrated how state employees of various states across the United States have deprived them of their Fourteenth Amendment rights. The state employees understood that their actions violated Plaintiffs’ Fourteenth Amendment rights but that did not stop them from executing their unlawful schemes of terminating Plaintiffs’ parental rights without proving that it was in the best interests of their children to do so by clear and convincing evidence. Plaintiffs have attached volumes of exhibits to prove the actions of state employees across various states alleged in this Complaint.
656. Under qualified immunity, “officials are not liable for bad guesses in gray areas, they are liable for transgressing bright lines.” Maciarello v. Sumner, 973 F.2d 295 (1992). The actions of state employees across various states where the causes of action in this Complaint took place were deliberate, intentional and outrageous. The employees could not prove by clear and convincing evidence that it was in the best interests of Plaintiffs’ children to terminate Plaintiffs’ parental rights. The state employees resorted to intentionally making false statements in court to deceive the courts, thereby making the courts unable to make impartial decisions that were fair. The employees also forged documents to lead the court to make orders, declarations, and judgments that terminated Plaintiffs’ parental rights.

657. Families need a nationwide temporary injunction on child removals to protect families from irreparable harms. Children need to be returned to biological families immediately while the details of the case are being debated as they have already suffered and been harmed for prolonged separation without due process.
658. Please restrain the Department of Health and Human Services and All State Courts from removing any more children from homes and holding the children of the people on this list.
659. [1] Even though jurisdictional finding may be based on substantial evidence, dispositional findings have a different focus and heightened burden of proof – clear and convincing evidence(§ 361 , subd. (c)(1); Conservatorship of O.B. (2020) 9 Cal.5th 989, 995-996, 1011.) This heightened standard is premised on the notion that even after parents have been found to have abused or neglected their children “keeping children with their parents while proceedings are pending, whenever safely possible, serves not only to protect parents’ rights but also children’s and society’s best interest. (In re D.P. (2020) 44 Cal.App.5th 1058, 1066-1067.)
660. [2] Even though children may be dependents of the juvenile court, they shall not be removed from their parents unless there is clear and convincing evidence of a substantial danger to the child’s physical health, safety, protection, or physical or emotional well-being and there are no “reasonable means” by which the child can be protected without removal. (§ 361, subd. (c)(1)) When considering if the child will be in substantial danger if permitted to remain in the parent’s custody, the court must consider not only the parent’s past conduct, but also current circumstances and the parent’s response to the conditions that gave rise to juvenile court intervention. (In re Alexzander C. (2017) 18 Cal.App.5th 438, 451-452.)

661. Preliminary Injunctive Relief is Necessary to Protect Against Irreparable Harm
662. The requested preliminary injunction is necessary to prevent irreparable harm during the pendency of the litigation. Without this relief, the court will be unable to render a meaningful judgment on the merits. If a preliminary injunction is not specifically requested in the complaint, the preliminary injunction must be related to the relief sought in the complaint. A district court lacks authority to grant a preliminary injunction that is not of the same character as the final relief sought in the underlying complaint. Omega World Travel v. Trans World Airlines, 111 F .3d 14, 16 (4th Cir. 1997).
663. The Court Has the Discretion to Grant Preliminary Injunctive Relief.
664. Plaintiffs’ motion for a preliminary injunction is properly within the Court’s discretion.
665. The preliminary relief requested is of the same character as the final relief sought in the complaint.
666. A Mandatory Injunction Is Necessary to Prevent Irreparable Harm.
667. Defendants’ refusal to take action will result in irreparable harm to Plaintiffs. A mandatory preliminary injunction is the only way to protect Plaintiffs from this harm and preserve the court’s ability to render a meaningful final judgment on the merits.
668. The Evidentiary Record Establishes the Need for Preliminary Injunctive Relief.
669. Plaintiffs’ request for preliminary injunctive relief is amply supported by the factual record. The affidavits and other evidence submitted by Plaintiffs demonstrate that Plaintiffs would suffer irreparable harm in the absence of injunctive relief.
670. Plaintiffs’ Affidavits Are Properly Considered on a Motion for a Preliminary Injunction.
671. Plaintiffs’ affidavits, which describe in detail why Plaintiffs would suffer irreparable harm in the absence of the requested injunctive relief, constitute proper evidence on a motion for a preliminary injunction. Formal evidentiary requirements do not apply to affidavits in support of a preliminary injunction, which may be based on hearsay or belief. Affidavits may be submitted in support of or in opposition to a motion for a preliminary injunction. Flynt Distributing Co., Inc. v. Harvey, 734 F .2d 1389, 1394 (9th Cir. 1984) (finding that a preliminary injunction may be granted on affidavits, even if the affidavits contain hearsay); Federal Sav. Loan Ins. Corp. v. Dixon, 835 F .2d 554, 558 (5th Cir. 1987) (finding that court’s reliance on affidavits in resolving motion for a preliminary injunction was not erroneous, even though the affidavits contained hearsay, as it is common for district courts to consider affidavits on a preliminary injunction and such relief may be granted based on evidence that would not be admissible at trial).
672. Because Plaintiffs Has Satisfied the Statutory Conditions, the Preliminary Injunction Should Be Granted.
673. Because the requested preliminary injunction is expressly authorized by statute and the statutory conditions are satisfied, the injunction may be granted without a showing of irreparable injury. A preliminary injunction may be granted without a showing of irreparable injury if the injunction is authorized by a statute. Securities & Exchange Commission v. Management Dynamics, Inc., 515 F.2d 801, 808 (2d Cir. 1975) (holding that SEC was not required to demonstrate irreparable injury to obtain an injunction authorized by statute); Trade Comm’n v. Consumer Def., LLC, 926 F.3d 1208, 1214 (9th Cir. 2019).
674. The Preliminary Injunction Is Necessary to Protect Civil Rights.
675. Because Defendants’ proposed actions will violate constitutionally-protected rights, Plaintiffs is likely to succeed on the merits of its claims. These violations of fundamental rights cannot be adequately compensated by money damages, and in fact, are presumed to cause irreparable injury. The preliminary injunction should therefore be granted. A court will grant a preliminary injunction when necessary to protect civil rights. Clemons v. Board of Education of Hillsboro, 228 F .2d 853, 857 (6th Cir. 1956) (injunction will issue to protect and preserve basic civil rights); Presbyterian Ch. v. Black Liberation Front, 303 F. Supp. 894, 901 (E.D. Mo. 1969) (preliminary injunction granted to enjoin violation of civil rights laws guaranteeing plaintiffs’ right to use their property for religious services). Irreparable injury may be presumed in cases involving certain deprivations of civil rights, including deprivation of First Amendment rights. Elrod v. Burns, 427 U.S. 347, 373 (1976).
676. A court will find that the civil rights plaintiff has established a likelihood of success on the merits when the defendant’s proposed actions will clearly violate constitutionally protected rights. Newsom v. Norris, 888 F.2d 371, 378 (6th Cir. 1989) (preliminary injunction was granted when plaintiffs established First Amendment violations); American Federation of Government Employees, Afl-Cio, Council 33 v. Meese, 688 F. Supp. 547, 548 (N.D. Cal. 1988) (compulsory drug testing enjoined as violation of Fourth Amendment “unless and until” plaintiff can show that such testing supersedes constitutional rights of employees).

677. Plaintiffs hereby incorporate by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
678. Title III of the ADA prohibits public accommodations from discriminating against individuals with disabilities. See 42 U.S.C. 12182(a). It expressly requires owners, operators, or lessees of public accommodations to take “such steps as may be necessary to ensure that no individual with a disability is excluded, denied services, segregated or otherwise treated differently because of the absence of auxiliary aids and services”. 42 U.S.C. 12182(b)(2)(A)(iii). Failure to take such steps amounts to prohibited discrimination unless the accommodation shows that providing the auxiliary aid or service would fundamentally alter the nature of the good, service, facility, privilege, advantage, or accommodation being offered or would result in an undue burden.
679. 28 C.F.R. § 36.302 (a) provides for the modifications in policies, practices, or procedures, to accommodate individuals with disabilities. Said provision states that:

680. 28 CFR 36.303(a) also provides for auxiliary aids and services for disabled individuals. Said provision states in pertinent part that:

681. 28 CFR 36.303(b) proceeds to define what includes an auxiliary aid. Accordingly, auxiliary aids may include “other effective methods of making aurally delivered information available to individuals who are deaf or hard of hearing”, “other effective methods of making visually delivered materials available to individuals who are blind or have low vision”, or “[o]ther similar services and actions”.
682. Further, 28 CFR 36.303(c)(1)provides for the need for effective communication for people with disabilities. This includes an obligation to provide effective communication to companions who are individuals with disabilities. According to said law, “‘companion’ means a family member, friend, or associate of an individual seeking access to, or participating in, the goods, services, facilities, privileges, advantages, or accommodations of a public accommodation, who, along with such individual, is an appropriate person with whom the public accommodation should communicate.”
683. It is also notable that “[t]he type of auxiliary aid or service necessary to ensure effective communication will vary in accordance with the method of communication used by the individual; the nature, length, and complexity of the communication involved; and the context in which the communication is taking place.” 28 CFR 36.303(c)(1)(ii).
684. “[T]he type of auxiliary aid that ensures ‘effective communication’ varies by context.” See Feldman v. Pro. Football, Inc., 419 Fed.Appx. 381, 391 (4th Cir. 2011). The DOJ’s Technical Assistance Manual for Title III also indicates that the type of auxiliary aid that ensures “effective communication” varies by context. See S. Dep’t of Justice, Civil Rights Division, The Americans with Disabilities Act: Title III Technical Assistance Manual III-4.3200. The regulation contemplates that, like the type of auxiliary aid, the content that must be communicated by auxiliary aids is also context-sensitive. What constitutes “full and equal enjoyment” of a place of public accommodation’s goods, services, facilities, and privileges necessarily varies based on what the place provides to visitors and consumers. See Feldman v. Pro Football, Inc., 419 F. App’x 381, 391 (4th Cir. 2011).
685. Further, the law permits a person with a disability to act as such person’s auxiliary aid, if such disabled person “specifically requests that the accompanying adult interpret or facilitate communication, the accompanying adult agrees to provide such assistance, and reliance on that adult for such assistance is appropriate under the circumstances.” See 28 CFR 36.303(c)(3)(ii).
686. In McGann v. Cinemark USA, Inc., 2016 U.S. Dist. LEXIS 45332 (W.D. Pa., Apr. 4, 2016),the Court held that the trial court had erred by determining that the requested tactile interpreter was not an auxiliary aid or service under the Americans with Disabilities Act (ADA). In the words of the Court, “tactile interpreter satisfied the definition of ‘auxiliary aid or service’”.
687. Also, in Feldman v. Pro Football, Inc., 419 F. App’x 381, 391 (4th Cir. 2011), the Fourth Circuit affirmed a grant of summary judgment in favor of deaf plaintiffs, holding that the ADA required the defendants to provide captioning of the lyrics of popular music played over the public address system at a stadium during professional football games.
688. It is instant action; the Plaintiffs have mild to severe disabilities. All of them have PTSD and suffer from inability to concentrate, which affects their reading comprehension, inability to sleep, and lack of/increased appetite. They therefore need electronic aids for communication and for preparing documents. They therefore belong to a specific class of people, which class needs protection.
689. When Plaintiffs file this action to seek legal redress for the hamr done against them bu the government, they were denied an opportunity to approach the court through auxiliary aids. The judge erroneously stated that one of the Plaintiffs, Melody Rogers, was illegally representing the pro se Plaintiffs and acting as their attorney. However, he Plaintiff did not hold herself out to be an attorney. She was only an auxiliary aid, considering the Plaintiffs’ disabilities.
690. Besides, in consideration of the Plaintiffs’ disabilities, the Courts failed to take such steps as may be necessary to ensure that the Plaintiffs were not excluded or denied the Court’s services. See 42 U.S.C. 12182(b)(2)(A)(iii). In the circumstances, the Plaintiffs had selected Melody Rodgers to be their auxiliary aid. As Plaintiffs have already stated above, the law permits an auxiliary aid for individuals with disabilities, to provide, inter alia, provide effective communication to companions who are individuals with disabilities. See 28 CFR 36.303(c)(1).
691. Further, as already stated above, the type of auxiliary services needed varies depending on the method of communication used by the individual; the nature, length, and complexity of the communication involved; and the context in which the communication is taking place. 28 CFR 36.303(c)(1)(ii). In this case, the Plaintiffs had mild to severe disabilities. They therefore need electronic aids for communication and for preparing documents. As the direct and proximate result of the Defendants’ actions and/or inactions, Plaintiffs have suffered, and will continue to suffer, physical, mental, and emotional injury, all to an extent and in an amount subject to proof at trial. Plaintiffs have also incurred, and will continue to incur, attorneys’ fees, costs and expenses, including those authorized by 42 U.S.C. § 1988, to an extent and in an amount subject to proof at trial.

692. Plaintiffs hereby incorporate by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
693. 42 U.S.C. 671 outlines the requirements for state plans for foster care and adoption assistance. The section specifies the requisite features of a state plan in order for a state to be eligible for payments under this part. The section also provides safeguards which restrict the use of or disclosure of information concerning individuals assisted under the State plan to purposes directly connected with the administration of the plan of the State.
694. The law requires States to make reasonable efforts to preserve and reunify families (i) prior to the placement of a child in foster care, to prevent or eliminate the need for removing the child from the child’s home; and (ii) to make it possible for a child to safely return to the child’s home. “Reasonable efforts” refers to activities of State social services agencies that aim to provide the assistance and services needed to preserve and reunify families.
695. CAPTA provides funding for programs that are designed to prevent child abuse and neglect.
696. Plaintiff challenges the said laws for the following reasons. First, the laws are broad and ambiguous. For instance, 42 U.S.C. 671 defines “Reasonable efforts” as activities of State social services agencies that aim to provide the assistance and services needed to preserve and reunify families. It does not go deeper to define the limits of what is reasonable or unreasonable. It is therefore possible for State actors to abuse the law by engaging in activities which are outrightly unreasonable. In the instant action, the State actors removed Plaintiffs’ children while relying on the said law. The State actors argue that their actions fall within what is reasonable as allowed under the law. However, such an interpretation harms Plaintiffs because it violates Plaintiffs’ parental rights. It follows; there is a heightened risk of the law to be abused by the state actors. It provides them a leeway to make arbitrary and capricious decisions that are an affront to what is just and fair in a democratic society. Also, the parents themselves may not be aware of what is within the reasonable standards.
697. Next, with regards to CAPTA, the law contains a long list of reporting and process requirements for states to be eligible. Though none have been declared non-compliant by the United States Children’s Bureau, an investigation by The Boston Globe and ProPublica published in 2019 found that the 50 states, the District of Columbia, and Puerto Rico were all out of compliance with the requirements to varying degrees. The report also found that underfunding of child welfare agencies and substandard procedures in some states caused failures to prevent avoidable child injuries and deaths.
698. Another report done by the Casey Family Programs[5] evidenced that there is limited evidence of the effectiveness of activities and programs funded by CAPTA grants. Although CAPTA requires that such programs be evaluated every two years, the only publicly available evaluation report is limited to a review of state plans, which are descriptive rather than evaluative.
699. It follows; there is a need to relook and/or evaluate the effectiveness of CAPTA in protecting children from abuse and neglect, while at the same time reconizing and protecting parental rights.
700. In light of the foregoing, Plaintiffs request a determination of unconstitutionality of the said statutes for their potential effects of violation of the rights of American citizens.

1. PRAYER FOR RELIEF

1. Declaratory relief;
2. An injunction against the Defendants ordering the Defendants to restore and enforce Plaintiffs’ rights to have custody of their children.

• A declaration of Unconstitutionality of 42 U.S.C. 671 and CAPTA.

1. An award for actual damages for violation of Plaintiffs’ rights as alleged herein;
2. Interest as provided by law;
3. An award of fees and costs;

• Such other relief as the Court deems just and proper.