universal-fashion-art-music et allied products: August 2012

NATIONAL AND INTERNATIONAL RELEASE ORDERED IMMEDIATELY

OGECHI EKE V. DCF DOCKET NO. CP10B0179

COMMONWEALTH OF MASSACHUSETTS

Suffolk, ss

Boston Juvenile Court

Civil Docket No. CP10B0179

_____________________________________________________________

OGECHI EKE

Applicant/Defendant (Pro se)

and

PHILLIP OFUME (LIMPT, INC. - EDUCATION AND WORK FORCE PROJECT)

Intervenor - Applicant/Advocate - Defendant

MASSACHUSETTS DEPARTMENT OF CHILDREN AND FAMILIES(DCF)

Respondent/Plaintiff

________________________________________________________________________________

APPLICANTS, OGECHI EKE AND PHILLIP OFUME'S VERIFIED JOINT EMERGENCY MOTION AND MEMORANDUM FOR SUMMARY JUDGMENT AS TO URGENT RETURN OF CUSTODY TO PARENT, OGECHI EKE PURSUANT TO Fed. R. Civ. P. 56

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and Local Rule 56 of the Mass. R. Civ. P.; .G.L. c. 18 sec. 2 (A)(D); 1st , 4th , 5th and 14th Amendments to the Constitution and Bill of Rights of the United States; Mass. Sup. Court Rule 9A(b)(5); Mas Juv. Ct. Standing Order 2-07; CHINS, G.L. c. 119 §§39E-H); Emergency custody hearing (G.L. c. 119, §24; Convention on the Rights of the Child - Parts I & II (General Assembly resolution 44/25 of 20 November 1989; Equal Protection Clause of the Fourteenth Amendment to the United States Constitution,Title IX of the Education Amendments of 1972, 20 U.S.C. §§ 1681–1688 (―Title IX‖),and the Massachusetts Human Rights Act, United States Constitution, Title IV of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000c–2000c-9 (―Title IV‖) and NO CHILD LEFT BEHIND ACT (2001); Ofumes v. DCF - Hampden County Juvenile District Court, Holyoke Session, Docket No. CP 11H0011; etc.

________________________________________________________________________________

Subject: Care, Protection, return of custody to parent, summary judgment of the Subject child (name reserved pursuant to U.S. Constitution and Bill of Rights and United Nations Convention on the Rights and Protection of the Child). Ms. Ogechi Eke (hereinafter, “Mother“) the mother of the subject child and Applicant-Intervenor move seeking Order of this Honourable Court to grant their Motion for Summary Judgment because of the following reasons:

A. STATEMENT OF MOTION/BRIEF ANALYSIS

Pursuant to the above mentioned local, federal and international laws and for the reasons set forth in the attached Memorandum, Applicants, Ogechi Eke and Phillip Ofume hereby move this Court for the entry of summary judgment.

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As set forth more fully in the accompanying Memorandum of Law, argument, exhibits and fact at the close of the DCF's extensive unnecessary, 100% rumor and hear say and public fund exhausting research and investigation; gold digging inexperience and partisan psychiatric examiner/evaluator and caseworkers, etc without supervising the anti-education, care and protection activities of the foster caregiver that claim that education is not important in the life of the child and that child should be used as bull to work and make money.

This careless conduct led to simultaneous destruction of highly talented/smart/gited/A/A+/ B+ student (subject child) who was raised, home schooled and taught by parent, Ms. Ogechi Eke but at present DCF, foster caregiver and other staff and secret agents or informants of the Department of Children and Families (DCF) have destroyed Ms. Eke's child because they are not interested in education, care and protection of the subject child's education, maintenance, security, healthcare, etc to the threatening level that the subject child who was TALENTED/SMART /GIFTED/A/A+/B+ student and recommended for advanced grade promotion from K with two scholarly jumps to grades 2 or 3 becuase of the subject child mother's scholarly teaching and learning curricula (EXHIBITS A & B below). Horribly, the subject child is now dropped below pre-K where she was at the age of 3 and placed in the present class of K instead of grade 3 which the scholarly plan constructed under EXHIBIT A & B would place her at the present age of 7.11 years. The recent picture (EXHIBIT C) shows that she is in K class instead of grade 2 or 3. Very painfully, in this class she is a big girl and other students are small kids. There is a wide academic gap between her past work when she was with Ms. Eke and now with furious money making foster caregivers or nigerian pastor and his wife who use subject child to work several hours per day seven days a week in their child care center and gospel church to make money to build empire in Nigeria and forgot about the educational achievement of the subject child.

OGECHI EKE V. DCF DOCKET NO. CP10B0179

In this matter, purpose of Summary Judgment is met because there is no genuine dispute as to any material fact. Accordingly, summary judgment in defendants' favor is appropriate on Respondent/Plaintiff's claims for damages, because there is no material dispute -- indeed, there is no evidence at all -- that defendants violated Plaintiff's "clearly established" constitutional rights.

At present, single Mother of the subject child Ms. Ogechi Eke has beautiful apartment, full time jobs and she works with the Commonwealth of Massachusetts Department of Human services and she is one of the Media/TV Assistant directors of the largest Gospel Churches in Canton, MA (Fountain of Grace Church). Because of EXHIBITS A, B, etc below experts have recommended her to be parents and moms instructor and role model particularly on how to raise their children and make them become TALENTED/SMART /A/A+/B+ frpm age to age through grade school and into tertiary institution. Now under the help of international and national experts, professional, institutions of learning and others Ms. Eke is now making efforts ro incorporate a Profit Corporation which will hire over time several hundreds of staff to write, publish and print pre-k through tertiary institution high standard educational curricula, text books and other step by step education and training resources. Additionally, she is doing further education and saving money to continue and complete her Pharmacy course program in academic year 2013/2014 and place her child (subject child) in one of the best private or suburban schools in the United States. Within 72 hours pursuant to Emergency custody hearing (G.L. c. 119, §24) Applicants request this Court to select unbiased Court inspector to review the progress mentioned above as final review to return full and permanent custody of the subject child to Ms. Ogechi Eke.

WHEREFORE, the Applicants/Defendants/Intervenor, Ogechi Eke and Phillip Ofume (LIMPT, INC. - EDUCATION AND WORKFORCE PROJECT), request this Honourable Court to grant their Motion for Summary Judgment because subject child is in eminent danger educationally, socially, economically and psychologically. In support of this Motion, Applicants/Defendants/Intervenor submit their Verified Memorandum of of Law, argument, exhibits and other material references/evidences which are hereto adequately incorporated and

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submitted and served upon Plaintiff or her Attorney.

B. MEMORANDUM

THREE-PRONG QUESTION IN ISSUE/ANALYSIS

1. Whether the action or conduct of this Court, former Attorney of Ms. Eke and DCF is not racially and politically motivated because the subject child is detained and been ex-communicated and being destroyed educationally, socially, .

2. Under the Constitution and Bill of Rights of the United States and the United Nations Conventions on the rights of the Child, Women and Parents, reliant on seizure and foster placement of no fault subject child and pains suffered by no fault mother, whether this Court erred when they allowed ONLY rummor, hearsay, gossip, nigerian oil/gas political persecution directed against the Biafrans or Igbos of Nigeria under which DCF's leaders earn extra means of livelihood, confussion encountered by inexperience Psychiatric Evaluator on cultural differences between Nigeria and America, etc to determine and influence the position of this Court.

2. Whether this Court erred when it failed, refused and neglected to consider that Ms. Ogechi Eke is academically, professionally, health wise, etc sound and excelled above several of the mothers and parents in the United States and world in general and also considering efforts which Ms. Eke made in EXHIBITS A & B and/or the past and present effort to make the subject child TALENTED/GIFTED/SMART/A/A+/B+ student and at the tender age of 5 she was able to publicly and in-doorly and before or in front The Honourable Presiding Justice Lewis read and explain grade 8 book called Mrs. Piggle-Wiggle Chapter books -Reading level: Ages 8 & up. 128 pages by Betty Mac Donald.

. 5

OGECHI EKE V. DCF DOCKET NO. CP10B0179

BACKGROUND

Purpose of presenting direct, accurate and personal statement of fact and evidence, victims' personal statement and evidence are cited verbatim as follows:

Ms. Ogechi Eke (Mother of Subject Child)

3. "... I am university graduate and have strings of academic and professional qualifications and additionally, in 2004, I was a 4th year pharmacy school at Mcphs and same time I was pregnant and worked at a community pharmacy. In Sept. 30^th 2004, I was delivered of a beautiful baby called Jillian George. Days later, I was admitted (Pre-eclampsia) to the BWH in Boston from school, the same place I had my baby, I had a poor delivery without pre-natal care and treatment equitably desired by all mothers notwithstanding political affiliation, race, and color because DCF infiltrated the rank and file of the staff and blackmailed me and called me a bad person as path to seize my beautiful child. Then I was vulnerable, with no or limited support and I could not question things that were wrong. Unlike now when several experts inside and outside law body, civil rights leaders and organizations, United Nations, immediate and extended families, christian brothers and sisters, etc are behind me and support me to fight these criminals (DCF and its secret agents) that have tortured me physically and psychologically to extent of injecting dangerous medications into me which made me to sleep over 24 hours and when I woke up and found that my new born baby has been abducted and removed by DCF/DSS without my permission and given to heartless stangers called foster caregiver when I was sound and healthy and highly educated to care and protect my baby...

4. On the incident mentioned in paragraph 1 above what I am able to figure out before DCF drugged and put me on long medicated sleep is that one friend Marie-Jonelle Durvne was carrying when I was under uncared or unattended post-natal severe acute pains and I as may recall, shortly after, a group of persons identified as DCF staff swarm into my room, they asked Marie-Jonelle to leave, they took away my baby without any explanation to me, they tied me up to a bed and used a hard restraint on me. I asked the reason for taking away my baby and why they were doing what they were doing to me. My question attracted more brutality, I was

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injected and that was all I knew.

3. I woke up the next day and asked for my baby- no one answered a word. A “Good Samaritan” I would call this person, now told me that I have been declared insane and that they have been warned to keep off me and be careful the way they went to my room or answered any questions. The hospital staff has also stopped calls to get through to my room. I asked the “Good Samaritan” the reason for labeling me so, and she said she is telling me these things because she did not see me as a danger nor do I look insane to her. I thanked her. I was too sick and too weak. The Pre-eclampsia was still there. I do not have a history of blood pressure either in my family, but my BP went off the roof because of the harassment, bullies and other forms of psychological tortures melted on me by the DCF and its errand runners. I was finally discharged from the BWH hospital and I was told to go in search of my newborn child. I was very sore, I was bleeding heavily and I had to go in search of my child, my only child. I was still in Pharmacy school; my school did not make allowance for me to make up missed assignment and the DCF has taken the school captive of any rational focus as to teaching and learning directions and the school did nothing to help me under my maternity or post natal conditions.

4. I was assigned a lawyer, by name Amy Geary and she was doing my case without serving me the papers she filed in Court and she allowed DCF to continue to seize and hold my child; I had a social worker by name Natalie. I had the support of Mrs. Juliet Achebe. Till this day, I did not know why the DCF (then DSS) took my child. The state lawyer had told me that I was accused of negligence. I told her that I was on hospital admission ill from Pre-eclampsia and postpartum pains (surgical stitches). The DSS case was later closed (and quickly too).

5. Jillian and I continued our lives. In 2006, events at my school made me to report the racial antagonization which I was going through and which brought to the Civil Rights Commission. My school Mcphs was making the learning environment very hostile and toxic for me. My report which I laws latter forced to withdraw made a target; I was now a target of retaliation in

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breach Mass. Law 151B §4(4) and §4(4A). §4(4). I took some time off based my Dr.’s

recommendation.

6. . Sometime in 2006, and there was this social worker who identified herself as Carol Powers. When Carol Powers came to my home, she called me to a negotiation table right in my home, she has been sent and that she knew about the case with Mcphs but she added and said, “ it did not matter.” Ms. Powers said to me right there in my home, “If you agreed to plead insanity, you will be fine and this case would be closed.” In response, I shared with her one of the life lessons my father taught me, and the lesson is this, “if you are not guilty of a thing, never, never admit to that thing, regardless the weight of persecution which suffer, never say yes, when the answer is a no.” Carol Power, then said, “since you have refused the easy way out, (plead insanity) I will ruin your life with my pen.” And with those words, Ms. Powers left my apartment. I called her to find out the outcome of her visit, I met a wall; I asked to speak to her boss, I met a wall and after that I have constantly met walls after walls, lies, after lies, deception after deception, with the DCF officials.

7. When DCF (DSS at that that time) came to me, they said I was accused of yelling at my child because of milk. I told them that we don’t do milk at that stage. That Jillian was not bottled feeding. The allegation was later changed to that I said I will blind Jillian’s eyes with pepper and apply pepper to her vagina. I almost passed out when I heard this wicked allegation because in my family inside and outside Nigeria, we talk and teach a child what is right and wrong and this continuous talking makes better change because spanking tries to radicalise children and hardens them. I asked the present foster caregivers of my child

OGECHI EKE V. DCF DOCKET NO. CP10B0179

what brought deep cut on the wrist of my child and I was surprised that the foster caregivers bullied and harassed and asked me, “who gave you the authority to question our child” and they requested me to leave their home or they will call police on me. I told the DSS and they did not send any feed back to me.

8. Now, Jillian was attending pre-school at Parker Hill ABCD Headstart, it was steps away from Mcphs, my school. Usually, I drop her off and walk to school. She was doing good, initially there were no complaint, out of the blues, very unkind allegations were being written against my child, a child that was not even 3 years of age; the school wanted her to be acting like a 12 year old. For no reason, the DCF arranged that Jillian be transferred to Jamaicaplain ABCD, whose Director was Joyce Tanner( Joyce Tanner’s close relative was David Tanner of Mcphs) I objected strongly because, there was no reason to move Jillian from Parker Hill ABCD Headstart; my school, Mcphs was at Longwood and Parker ABCD was a stone throw away.

9 She was now at Jamaicaplain ABCD. JP Headstart constantly and consistently endangered Jillian. Jillian’s standard of education was seriously affected because the foster caregivers refuse to take my after school teaching and learning resources and each time I visit my child and talk about education, the caregivers would harassment and force me to leave their home or they will call for police on me.

10. In 2011, we had lost 11 family members in 2years. By this time, I was homeschooling Jillian. I bought a ticket and our luggage was tagged to Nigeria-our final destination and the DCF’s mounted spies were in full force around Jillian and

I and they followed us here and there. When we got to Canada, we were prevented from boarding Lufthansa airline. We were left stranded at the airport (a foreign country) me and my six year old Jillian had nowhere to go and no one was there to explain to us. The next day, a group of people came to us and whispered that they had been asked to bring us back to Boston. I wanted to know who, (Ms. Geary was well informed that we were traveling, and she okayed it) I insisted that we were going to home to attend a funeral of our family members. We were accused of being illegal immigrants to Canada and said we must be deported now. I was asked, “How did you expect to feed this child when you get to Nigeria?”what??? Was all I could say? We were returned back to Boston and my bank card was charged for returning us back to Boston. As soon as we were returned, to Boston, Amy Geary quickly contacted me and said that DCF is asking for an immediate hearing. It was then; Jillian was taken away from me and placed in the custody of the Rev. & Mrs. Azubuine. After wards, I was told I could travel if I wanted.

OGECHI EKE V. DCF DOCKET NO. CP10B0179

11. In 2011, we had lost 11 family members in 2years. By this time, I was homeschooling Jillian. I bought a ticket and our luggage was tagged to Nigeria-our final destination. When we got to Canada, we were prevented from boarding Lufthansa airline. We were left stranded at the airport (a foreign country) me and my six year old Jillian had nowhere to go and no one was there to explain to us. The next day, a group of people came to us and whispered that they had been asked them to bring us back to Boston. I wanted to know who, (Ms. Geary was well informed that we were traveling, and she okayed it) I insisted that we were going to home to attend a funeral of our family members. We were accused of being illegal immigrants to Canada and said we must be deported now. I was asked, “How did you expect to feed this child when you get to Nigeria?”what??? Was all I could say? We were returned back to Boston and my bank card was charged for returning us back to Boston. As soon as we were returned, to Boston, Amy Geary quickly contacted me and said that DCF is asking for an immediate hearing. It was then; Jillian was taken away from me and placed in the custody of the Rev. & Mrs. Azubuine. After wards, I was told I could travel if I wanted.

12. On December 20^th2011, the Azubuine’s invited me to attend a performance at Jillian’s school (Winter Hill Community). The Azubuine’s told me it was at 8am and I went to Jillian’s school hoping to meet them there. I learned from her teacher that the event was by 10am and that I could wait in the hall. Now, I have never gone to Jillian’s school before now. I went because I was invited. I took pictures and left. A week later I went to visit my child, the Azubuine’s spiting me, and they told me that Jillian’s school had filed a trespassing report at the police station. I contacted my state lawyer, who initially told me that the police was not contacted for any reason, when I insisted, she told me that yes, that the police was contacted but that no police report was filed; she later changed her story; this is the norm, with Ms. Geary, she changes her story, she misinforms me, misleads me and works against me her clients (I have several e-mails to prove this)

11. On December 20^th2011, the Azubuine’s invited me to attend a performance at Jillian’s school (Winter Hill Community). The Azubuine’s told me it was at 8am and I went to Jillian’s school hoping to meet them there. I learned from her teacher that the event was by 10am and that I could wait in the hall. Now, I have never gone to Jillian’s school before now. I went because I was invited. I took pictures and left. A week later I went to visit my child, the Azubuine’s spiting me, and they told me that Jillian’s school had filed a trespassing report at the police station. I contacted my state lawyer, who initially told me that the police was not contacted for any reason, when I insisted, she told me that yes, that the

police was contacted but that no police report was filed; she later changed her story; this is the norm, with Ms. Geary, she changes her story, she misinforms me, misleads me and works against me her clients (I have several e-mails to prove this).

OGECHI EKE V. DCF DOCKET NO. CP10B0179

JURISDICTIONAL STANDPOINT

12. This Court has overwhelming jurisdictions,( personal and subject matter ) to hear and grant Applicants' Motion. Summary Judgment maybe filed if any party in the case found that, there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law. Since 2004 there is no pending dispute in this case from the disclosure provided by the former Counsel for the defendant, Ms. Ogechi Eke and Ms. Eke has been put in the dark without disclosure of the document filed in her defense and also document filed by the Plaintiff, DCF.

13. Actions of the Counsel for Ms. Eke and the Court violate 5th and 14th Amendments to the Constitution and Bill of Rights of the United States and the failure of the counsel in staying visitation, investigation and research on the subject child to the extent of allowing DCF and the foster care providers, violate US and United Nations Convention and Bill of Rights and Universal Declaration on the Rights of the child, parent and family; Equal Protection Clause of the Fourteenth Amendment to the United States Constitution, Title IX of the Education Amendments of 1972, 20 U.S.C. §§ 1681–1688 (―Title IX‖),and the Massachusetts Human Rights Act, United States Constitution, Title IV of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000c–2000c-9 (―Title IV‖) and NO CHILD LEFT BEHIND ACT (2001); Ofumes v. DCF - Hampden County Juvenile District Court, Holyoke Session, Docket No. CP 11H0011; etc. For example during one of the few visitations Ms. Eke was allowed make, she found a deep cut on the wrist of her child and both caregivers would not allow the subject child’s mother a minute privacy and as they positioned them directly in a circle of the subject child, foster caregivers and Ms. Eke, Ms. Eke asked her daughter what happened to your wrist and swiftly the caregivers bullied her and shut up and requested her to leave their home or they will call police on her. She rushed out because they trying to fights her and frame up allegation against her. Ms. Eke reported the injury to DCF and nothing was done as to sending further information to the

OGECHI EKE V. DCF DOCKET NO. CP10B0179

Applicant, Ms. Eke. The injury has deformed subject child’s hand. Ms. Eke request this Court cause a direct discovery examination on the hand or wrist of her daughter and reason her level of education has drastically dropped.

14. Further readings on rights of the child, parent, family, etc.

Fed. R. Civ. P. 56 and Local Rule 56 of the Mass. R. Civ. P.; .G.L. c. 18 sec. 2 (A)(D); 1st , 4th , 5th and 14th Amendments to the Constitution and Bill of Rights of the United States; Mass. Sup. Court Rule 9A(b)(5); Mas Juv. Ct. Standing Order 2-07; CHINS, G.L. c. 119 §§39E-H); Emergency custody hearing (G.L. c. 119, §24; Convention on the Rights of the Child - Parts I & II (General Assembly resolution 44/25 of 20 November 1989; Equal Protection Clause of the Fourteenth Amendment to the United States Constitution, Title IX of the Education Amendments of 1972, 20 U.S.C. §§ 1681–1688 (―Title IX‖),and the Massachusetts Human Rights Act, United States Constitution, Title IV of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000c–2000c-9 (―Title IV‖) and NO CHILD LEFT BEHIND ACT (2001); Ofumes v. DCF - Hampden County Juvenile District Court, Holyoke Session, Docket No. CP 11H0011; United Nations Universal Declaration of Human Rights (Dec. 10, 1948); etc.

ARGUMENT

Applicants respectfully request leave of this Court to assign numbers to each paragraphs of their argument because of past experience in their cases when several paragraphs were missing.

15. In applying the Rules of this Court and other local rules and Federal rules, in return custody proceedings, question maybe asked whether the destination of the proposed return is in the best interest of the subject child. In this case two questions have been resolved thus, that in the home of the wealth seeking foster caregivers, the subject child is in severe acute danger educationally, socially, economically, psychologically, etc. The destination where she will be returned is

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similar to "heaven" and is her nuclear parent's or mother's home where she was enjoying her life and excelling and sound educationally, socially, economically, psychologically, with freedom of association and speech, etc.

16. Additionally, at present, single Mother of the subject child Ms. Ogechi Eke has beautiful apartment, several hundreds of educational toys , books and other learning resources, several clothes and shoes to wear and reconnect her previous wealthy life style under her mom’s effort; Ms. Eke has full time jobs and she works with the Commonwealth of Massachusetts Department of Human services and under extra income she is one of the Media/TV Assistant directors of the largest Gospel Churches in Canton, MA (Fountain of Grace Church). Because of EXHIBITS A, B, etc below experts have recommended her to be parents and moms instructor and role model particularly on how to raise their children and make them become TALENTED/SMART/A/A+/B+ from age to age through grade school and into tertiary institution. Now under the help of international and national experts, professional, institutions of learning, countries and others Ms. Eke is now making efforts to incorporate a Profit Corporation which will hire over time several hundreds of staff to write, publish and print pre-k through tertiary institution high standard educational curricula, text books and other step by step education and training resources. Also Ms. Eke is doing further education and saving money to continue and complete her Pharmacy course program in academic year 2013/2014 and place her child (subject child) in one of the best private or suburban schools in the United States.

17. Within 72 hours pursuant to Emergency custody hearing (G.L. c. 119, §24) Applicants/defendants/intervenor request this Court to select unbiased Court inspector to review the progress mentioned above as final review to return full and permanent custody of the subject child to Ms. Ogechi Eke.

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18. The present condition of the subject child is heading to severe form of destruction bitterly Ms. Eke's child has lost almost all the strong academic background which she had prior to the forcible removal to this maximum prison called foster home, where the DCF consented to for the foster caregivers to spank her and to use Ms. Eke’s child assisting in the foster caregiver's child daycare facility. This child labor has deprived the subject child access to right to do her homework and engage in remedial or catch-up lessons. As part learning component, of EXHIBITS A & B, during the summer holidays, Ms. Eke enrolls her child (subject child) in one of the best summer school.

19. Case of ); Ofumes v. DCF - Hampden County Juvenile District Court, Holyoke Session, Docket No. CP 11H0011 is one of the most cited cases in the United States because it shows how DCF place TALENTED/GIFTED/SMART/A+/A/B+ students in foster care where they are used like bull to destroy their educational achievement. Five children were removed from this family on January 31, 2011 and placed them in scattered foster families where children between the ages of five years and 12 years were used to dig snow and one school days they make to go to school and be late for over two hours. The pastor who took the five year and twelve-year children designed a damaging and criminal plan in the foster home. Each day apart from making the 12-year child to go late for over two hours , each day soon as she comes from school, the pastor and his wife make sure she did not do her school assignment and they will remove her to the Spanish Church where she does not hear and understanding Spanish used in the church to conduct services.

20. Ms. Eke's EXHIBITS A & B which are an in-home accelerated teaching and learning program is the best option for the United States to raise standards of education Pre-K - Tertiary Institution and if possible world in general (see Finland). Few visitations allowed by the school, fired attorney, caregiver and DCF because of the secret kept around subject child, parent, Ms. Eke tested her child to know the level she is but less than two minutes of the simple academic question/answer and

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writing the caregivers rushed into the testing and disrupted the testing and forced Ms. Eke to leave the foster caregivers' home and warned Ms. Eke not to visit their home and that failure they will accuse her of trespassing into the foster care home and also warned her not to visit subject child's school. The few testing which lasted less than two minutes comparatively shows that the subject child has lost her education in foster stay and if urgent removal to parent is not made, she will drop out from school and forced her to enter the DCF and intended caregiver planned trap for TALENTED/SMART/A/A+/B+ non-whites victims which is boy/girl friend circle which will lead to teen pregnancy to enable the caregivers start to dig addition gold through foster babies or children's state welfare or benefits. Criminally, caregivers under DCF program try to target victims' education to destroy it.

21. DCF'S politically designed and defective care and protection system, they (foster caregiver and DCF) are interested in large public monies shared between the caregiver and DCF under pretense of providing for the subject child but these monies allow them to buy secret beautiful castles oversea. When Ms. Eke visited her school when she was doing a performance and Ms. Eke has to take some of her beautiful clothes. When she arrived there she found that the clothes the subject child wore was old and stained and improper for such outreach appearance and Ms. Eke has to go change her unfitting clothes with the ones she brought.

22. Academically, the Subject child earned this downfall because the teaching and learning curricula which mother of the subject child put in place was suppressed and in place she is forced to do child labor or domestic work and providing care which adults are supposed to provide in the foster caregiver's home daycare business; etc.

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23. Reason that several experts have found that the case of the subject child is case of child human and constitutional rights case and subject child now forcibly placed in danger of money making child merchants (DCF and foster caregiver) or nigerian pastor, Emergency Order in nature of Immediate Return of Custody to Subject Child Mother, Ogechi Eke be issued because the subject child identified by cause docket number above be immediately and urgently adjudicated in need of care and protection and committed to the custody of her Mother, Ogechi Eke and/or any other appropriate order to be made pursuant to Fed. R. Civ. P. 56 and Local Rule 56 of the Mass. R. Civ. P.; .G.L. c. 18 sec. 2 (A)(D); 1st , 4th , 5th and 14th Amendments to the Constitution and Bill of Rights of the United States; Mass. Sup. Court Rule 9A(b)(5); Mas Juv. Ct. Standing Order 2-07; CHINS, G.L. c. 119 §§39E-H); Emergency custody hearing (G.L. c. 119, §24; Convention on the Rights of the Child - Parts I & II (General Assembly resolution 44/25 of 20 November 1989; Equal Protection Clause of the Fourteenth Amendment to the United States Constitution,Title IX of the Education Amendments of 1972, 20 U.S.C. §§ 1681–1688 (―Title IX‖),and the Massachusetts Human Rights Act, United States Constitution, Title IV of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000c–2000c-9 (―Title IV‖) and NO CHILD LEFT BEHIND ACT (2001); Ofumes v. DCF - Hampden County Juvenile District Court, Holyoke Session, Docket No. CP 11H0011; etc.

24. In LIMPT, INC. (EDUCATION AND WORKFORCE PROJECT), within researchers and investigators' works in computing number of the predominantly non-white victims appearing before the Juvenile Courts across the United States they found that the US Congress, politicians, civil liberties organization are aware that DCF is secretly created to destroy non-whites and under these activities TALENTED/SMART/GIFTED /A/A+/B+ students and parents are DCF's focus and they fight hard to distroy them because they will earn education to take their jobs (Ofumes v. DCF –

OGECHI EKE V. DCF DOCKET NO. CP10B0179

Hampden County Juvenile District Court, Holyoke Session, Docket No. CP 11H0011) and Ofume et al v. Holyoke Police Department et al - Plymouth County Superior Court, Docket No. 1260.

25. From experts (Limpt, Inc., Dr. Phillip Chukwuma Ofume, Dr. Kifindi Bunkheti, etc) research and investigation point of view on Nigerian and African nuclear and extended families system culture, they found that the reaction of Ms. Ogechi Eke in 2004 through out each political plot organized and implemented by the DCF and its irate child merchants to seize her gold (subject child) is normal reaction of all responsible, caring and loving Nigerian and African mothers or parents. Commonwealth of Massachusetts and its agencies (DCF et als) selected weak and inexperience Psychiatric Evaluator and caseworkers that know nothing about oversea culture and civilization. The reaction of Ms. Eke is exemplary of good, excellent, caring and loving mothers and parents. Relatively, the silly behaviors of Americans if reviewed by oversea or Nigerian Psychiatric evaluators may be rated as mental health behaviors.

26. Birthday, March 15, 1969 through presents Ms. Ogechi Eke has never had any mental and related health problems and at all material time she has been TALENTED/ SMART /GIFTED /A/A+/B+ university graduates. In the United States she has completed over four (4) years of Pharmacy course and she disengaged from the Pharmacy course program because of the harassment, bullying and physical/ psychological tortures directed against her by the DCF and its secret/overt informants. The action of the DCF is a vicious retaliation by the DCF and its agents following Ms. Eke's petitions to the government of the Commonwealth of Massachusetts and its agencies (Human Rights Commission et als) to complain against her persecution, harassment, bullying and physical/ psychological tortures. Day of the birth of the subject child on September 30, 2004 DCF mounted its agents or informants in the hospital where the subject child was born with the intention to create trouble as path to seize her child. This experience several Nigerians and other non-white has had in the United States.

27. Sectors to sectors, place to place, Ms. Eke continues to answer questions on what she did to make her child TALENTED/ SMART /GIFTED /A/A+/B+ student at the age of 4. Age-4

subject child was reading tertiary level books tom the extent that she read **Mrs. Piggle-Wiggle Chapter books*** Reading level: Ages 8 & up. 128 pages by Betty Mac Donald** Jillian Read this Book at age 5!!!!! – read same before Judge Lewis. Ms. Eke said "... see EXHIBITS A & B and in answering public question on what she did make her child excel to this high level, she said, “what I do day to day to put my daughter top of her class are to give her healthy food, allow rest and sleep after school, sound teaching with quality curriculum, teach by practical example, private study and creativity, continuous and comprehensive assignments and evaluation, play and interaction with other kids, etc."

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EXHIBITS A & B : Jillian’s Books for Home School (Core curriculum Only) Learning Coach is Mom (Ogechi Eke)

EXHIBIT B. 1, 2, 3, Through 115 by Ms. Ogechi Eke (Mother of Subject Child)

Book Title

Author

K12 Math+: Activity Book grade 1 semesters 1& 2

K12

K12 Math+: Lesson Guide grade 1 semesters 1 & 2

K12

K12 Math+: Activity Book grade 2 semesters 1 & 2

K12

K12 Math+: Lesson Guide grade 2 semesters 1 & 2

K12

Language Arts 1: Student Pages Semesters 1 & 2

K12

Language Arts 2: Student Pages Semesters 1 & 2

Language Arts Books (Literature or literal Study)

POMPEII Buried Alive	Edith Kunhardt
Wagon Wheels	Barbara Brenner
The Long Way to a Newland	Joan Sandin
Clara and the Bookwagon	Nancy Smiler Levinson
Chang' s Paper Pony	Eleanor Coerr
Sam the Minuteman	Nathaniel Benchley
George the Drummer Boy	Nathaniel Benchley
The Bears On Hemlock Mountains	Alice Dalgliesh
Now I am Six	Scholastic
Surprises (Poems by)	Lee Bennett Hopkins
No Fighting. No Biting	Maurice Sendak
The Long Way WestWard	Joan Sandin
Little Bear	Else Holmelund Minarik
The First Thanksgiving	Linda Hayward
A Picture of Harold’s Room	Crockett Johnson
Danny the Dinosaur	Syd Hoff
The Tales of Amanda Pig	Jean Van Leeuwen
Buddy. The First Seeing Dog	Eva moore
Te Josefina Story Quilt	Eleanor Coerr
Tye May and the Magic Brush	Molly Garrett
Frog and Toad are Friends	Arnold Lobel
Bedtime for Frances	Russell Hoban
Sam Bangs & Moonshine	Evaline Ness
Harry and the Lady Next Door	Gene Zion
Crow Boy	Taro Yashima
Robin Hood (chapter book)	Annie Ingle
Winnie-the-Pooh	A.A Milne
Knights of the Round Table	Gwen Gross
Peter Pan	J.M. Barrie
Ready…Set…Read!	Joanna Cole
*Other Books: Mrs. Piggly Wiggly, Too many to list; Jillian is a voracious Reader; Her she has a Reading Log (Over 150 books before she was snatched away.*

Language Arts Supplements

Listen, My Children (Poems for First Graders) A Core Knowledge K12

Listen, My Children (Poems for Second Graders) A Core Knowledge K12

The Legend of Blue Bonnet - Tomie DePaola

The Hundredth Name -------Shulamith Levey Oppenheim

Sundiata ---------------------- David Wisniewski

K12

Phonics 1 Student Pages Semester 1 & 2

K12

Phonics 1 semester 1 & 2 Teacher Guide

K12

Phonics 2 Student Pages Semester 1 & 2

K12

Phonics 2 semester 1 & 2 Teacher Guide

Phonics Works Video

K12

Primary Analogies Critical & Creative Thinking Book 1

Gae Brunner

Primary Analogies Critical & Creative Thinking Book 2

Jan Z. Olsen

Junior Great Books Volume 1: Grade 1

• The Black Hen’s Egg

• The Mouse & the Wizard

• Imaginations

Pegasus Series

Junior Great Books Volume 2: Grade 1

• Rumpelsiltskin

• Eeyore Has a Birthday and Two Great Presents

• “When I Grow Up”

K12

Junior Great Books Volume 3: Grade 1

• The King of the Frogs

• Snow-White and the Seven Dwarfs

• “Mysterious Animals”

K12

Junior Great Books Volume 1: Grade 2

• Chestnut Pudding

• The Pied Piper

• Fanciful Animals

K12

Junior Great Books Volume 2: Grade 2

• The Mermaid Who Lost Her Comb

• Hansel & Gretel

• Special Places

K12

Junior Great Books Volume 3: Grade 2

• Mother of the Waters

• Zlateh the Goat

• Secret Messages

Classics for Young Readers Volume 1

K12

Classics for Young Readers Volume 2

K12

Early Reading Comprehension in Varied Subject Matter Book A

Jane Ervin

Handwriting Without Tears 1^st grade;

Jan Z. Olsen

Handwriting Without Tears 2nd Grade;

Jan Z. Olsen

Sylvester and the Magic Pebble

William Steig

Hooked on Phonics! 1^st Grade

HOP Editors

Hooked on Phonics 2nd Grade

HOP Editors

Hooked on Phonics Master Reader

HOP Editors

Writing Homework

Scholastic Ref

Sciences 1 Student Pages (Semesters 1 & 2)

K12

Sciences 2 Student Pages (Semesters 1 & 2)

Science Supplements

*A Weed is a Flower ------------------------ Aliki

*Weather (poems for All Seasons) -------- Lee Bennett Hopkins

*Bright and Bold (Animals Alphabet Book⇾ Celebration Press

*What is the World Made of? Stage 1 & 2

( All About Solids, Liquids, and Gases)-- Kathleen W. Zoehfeld

*Let’s Go Rock Collecting stage 2 ------ Roma Gans

*What Happens to a Hamburger? Stage2------- Paul Showers

What Makes a Magnet? Stage 2-------------Franklyn M Branley

Why Frogs Are Wet ------------Judy Hawes

Down Comes The Rain -------------Franklyn M Branley

Flash, Crash, Rumble, and Roll -------------Franklyn M Branley

K12

History 1 Student Pages (Semesters 1 & 2)

K12

History 2 Student Pages (Semesters 1 & 2)

History Supplements

The Trojan Horse (How the Greeks Won the War) - Emily Little

Mummies ------------------------------------------Joyce Milton

Fossils stage 1& 2: ( Tell of Long Ago) -------- Aliki

Knights In Shining Armor -----------------------Gail Gibbons

K12

Arts 1 Student Pages (Semesters 1 & 2)

K12

Arts 2 Student Pages (Semesters 1 & 2)

Arts Supplement

How Artists See Play .----------- Collen Carroll

How Artists See Animals by------------ Collen Carroll

Come Look with me: Exploring Landscape Art with Children- Gladys Blizzard

Come Look with me: World of Play--- Gladys Blizzard

K12

Beginning 2 Music Student Pages Volume 2 (Semesters 1 & 2)

K12

Let’s Sing Songbook Volume 2

K12

Music software

K12

Music Supplement

• Music: Let’s Listen Volume 2

• Music: Let’s Sing Volume 2

• Music: Let’s Learn Music Volume 1 Video

• Music: Let’s Learn Music Volume 2 Video

• Music: Let’s Rhythm

• Tambourine

• Drums

• Keyboard/piano

• Instructional DVD

K12

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EXHIBIT A .1, 2, 3, Through 232 strands

Jillian’s Reading Log by Ms. Ogechi Eke (Mother of Subject Child)

Week of 9/27/2009 to 10/4/2009
HOP books 24books in all- from Kindergarten Edition	HOP Books
14 Books from Cat Tick –Tock Gets a Pal	HOP Books
10 Books from Dad and Sam Kim Kangaroo	HOP Books

Week of Oct13. 2009
*Mon:* Hop on Pop
*Tues:* The Cat in the Hat	Dr. Seuss
*Wed:* Minnie and Moo Wanted Dead or Alive	Denys Cazet
*Thur:* Green Eggs and Ham	Dr Seuss
*Fri:* Fred and Ted Like to Fly	Peter Eastman
*Sat:* My Car Trip	Sindy Mckay
*Sun:* Three Little Bears (4books in one pack)	David Martin
*My comment for the Week of Oct. 11. 2009* Wed. Book was hard: try reading it again. Jillian answered 90% of the questions *My goal for Jillian:* fluency in reading; answer 100% of the questions; sustain Jillian’s reading interest.

Week of Oct18. 2009
*Mon:* Goldilocks and the Three Bears	Jerry Smath
*Tues:* The Three Little Pigs	Jerry Smath
*Wed:* Are You still Mad	Ellen Weiss
*Thur:* One Smart Goose	Caroline Jayne Church
*Fri:* Little Bears Friend	Maurce Sendak
*Sat:* Mumps Story Gabby is Hungry	Beverly Randell Michele Dufesne
*Sun:* Frog and Toad Adventure Days with Frog and Toad	Arnold Lobel Arnold Lobel
Week of Oct 25. 2009
*Mon:* Fox in Socks	Dr. Seuss
*Tues:* Bath time for Biscuits	Alyssa Satin Capucilli
*Wed:* Biscuits and the Baby	Alyssa Satin Capucilli
*Thur:* A Snout for Chocolate	Denys Cazet
*Fri:* The Case of the Cat’s Meow	Crosby Bonsall
*Sat:* My Car Trip	Sindy Mckay
*Sun:* Detective Dog and the Lost Rabbit Book Slam Dunk (In the Dark)	David Martin Hop Book 17

Week of Nov.1 2009
*Mon:* How the Grinch Stole Christmas	Dr. Seuss
*Tues:* Bath Time for Biscuits	Denys Cazet
*Wed:* Chicka Chicka Boom Boom	Bill Martin
*Thur:* A Snout for Chocolate	Denys Cazet
*Fri:* Fly Guy Fly	Ted Arnold
*Sun:* Yertle the Turtle	Dr. Seuss
Week of Oct8. 2009
*Mon:* Are You My Mother	P.D. Eastman
*Tues:* The Tooth Book	Dr. Seuss
*Wed:* Mouse Soup	Arnold Lobel
*Thur:* What do You Hear When Cows Sing & Other Silly Riddles	Marco & Giulio Maestro
*Fri:* Sammy the Seal	Syd Hoff
*Sat:* Big Egg	Molly Coxe
*Sun:* Inauguration Day Too Much Toothing	Lauren Brown Sanford Hoffman

Week of Nov.15. 2009
*Mon:* American History for Children(DVD)	The History Channel (2005)
*Tues:* African American Life	The History Channel (2005)
*Wed:* American Independence	The History Channel (2005)
*Thur:* Native American Life	The History Channel (2005)
*Fri:* Martin Luther King Jr.
*Sat:* The Presidents	The History Channel (2005)
*Sun:* The United States Constituting	The History Channel

Week of Nov.22. 2009
*Mon:* Early to Bed, Early to Rise)	Benjamin Franklin
*Tues:* Let’s Explore the Rainforest Level 2 (ages 6-7years)
*Wed:* Baby’s Story time (15 Best story levels)	Arco Guthrie
*Thur:* Little Rats Sets Sail	Monika Bang-Campbell
*Fri:* Three Stores You Can Read to Your Teddy Bear	Sara Swan Miller
*Sat:* Andy Shane and the Very Bossy Dolores Star buckle	Jennifer Richard Jacobson
*Sun:* Dr. Seuss ABC	Dr. Seuss

Week of Nov.29. 2009
*Mon:* Arthurs Reading Trick	Marc Brown
*Tues:* Hare and Rabbit: Friends Forever	Julia Noonan
*Wed:* Equal Rights for All	American History
*Thur:* United Flag	The History Channel
*Fri:* National Observances	The History Channel
*Sat:* Early Settlers	The History Channel
*Sun:* Us Songs and Hymns	The History Channel

Week of Dec.1 2009
*Mon:* Arthurs Reading Trick	Marc Brown
*Tues:* Hare and Rabbit: Friends Forever	Julia Noonan
*Wed:* Equal Rights for All	American History
*Thur:* United Flag	The History Channel
*Fri:* National Observances	The History Channel
*Sat:* Early Settlers	The History Channel
*Sun:* Us Songs and Hymns	The History Channel

Week of Dec.1 2009
*Mon:* Pooh Makes Growing-Up Fun	Disney Books
*Tues:* Feelings and Emotions
*Wed:* The 100^th Day of School	Angela Shelf Medearis
*Thur:* Mighty Spider	Jean Day Zallinger
*Fri:* Wake Me Up in Spring	James Preller
*Sat:* I am Water (Scholastic Reader (Level 1)	Jean Marzollo
*Sun:* I am a Seed (Hello Reader)	Jean Marzollo

Week of Dec.6 2009
*Mon:* Stories of Dogs	Russell Punter
*Tues:* One Saturday Afternoon	Barbara Baker
*Wed:* The Man on A Unicycle & Other Stories	Elizabeth Bram
*Thur:* Ice is Whee	Carol Greene
*Fri:* The Birthday Tree	Paul Fleischman
*Sat:* Big World Small World	Jeanine Titherington
*Sun:* Little Rat Sets Sail	Monika Bang-Campbell

Week of Dec.13 2009
*Mon:* Monkeys and the Universe (Chapter Book)	Kate Banks
*Tues:* The Carrots Seed	Ruth Krauss
*Wed:* The Little Red Hen (Nursery Classics)	Tony Palazzo
*Thur:* What’s So Great About Nice	Jacquelyn Reinach
*Fri:* Don’t Eat Too Much Turkey	Miriam Cohen
*Sat:* Ready Readers: Giant Collection 10-in-1-Collection	Preschool-Grade1
*Sun:* Buster and Phoebe. Thje Greast Bone Game	Liz Bechtole

Week of Dec.20 2009
*Mon:* The Perfect Christmas Picture	Fran Manushken
*Tues:* Treasured Tales (Snowhite)	A Parragan Publishing
*Wed:* Chicken Soup With Rice	Maurice Sendak
*Thur:* Green Eggs and Ham	Dr. Seuss
*Fri:* Are You a Spider	Judy Anen & Judy Humphries
*Sat:* Disney’s Story Book Collection( Beauty and the Beast)	Disney Storyland Treasury
*Sun:* Disney’s Story Book Collection( Sleeping Beauty) Beast)	Disney Storyland Treasury

Week of Dec.27 2009
*Mon:* There’s A Bird on Your Head	Mo Willems
*Tues:* The High-Rise Private Eyes: The Case of the Troublesome Turtle	Cynthia Rylant
*Wed:* Today I Will Fly	Mo Willems
*Thur:* A Kiss For Little Bear	Maurice Sendak
*Fri:* Arthur’s Hiccups	Marc brown
*Sat:* Disney’s Story Book Collection( Lion King)	Disney Storyland Treasury
*Sun:* Nate The Great and The Big sniff ( Chapter Book)	Marjorie et al

Week of Jan.3 2010
*Mon:* The Teacher From the Black Lagoon	Mike Thaler
*Tues:* On the Thinks You Can Think I Can Read With My Eyes Closed	Dr. Seuss Dr. Seuss
*Wed:* Minnie And Moo Go To Paris	Denys Cazet
*Thur:* How Do Dinosaurs Go To School	Jane Yolers
*Fri:* Gorillas Gentle Giants of the Forest	Joyce Milton
*Sat:* Disney’s Story Book Collection( Pinocchio )	Disney Storyland Treasury
*Sun:* Go, Dog, Go!	P.D Eastman

Week of Jan.10.2010: Chapter Book galore!!!!
*Mon:* Junie B. Jones Is Not a Crook	Barbara Parks
*Tues:* Amelia Bedelia And The Surprise Party	Peggie Parish
*Wed:* Oliver and Amanda And The Big Snow	Jean Van Leewen
*Thur:* Crocodile! Crocodile	Margaret Mahy
*Fri:* Winnie the Pooh And Some Bees	Stephen Krensky
*Sat:* Amelia Bedelia 4 Mayor	Herman Parish
*Sun:* Amanda Pig and Her Big Brother Oliver	Jean Leewen

Week of Jan.17.2010: Chapter Book galore!!!!
*Sat:* Disney’s Story Book Collection( Noah’s Ark )	Disney Storyland Treasury
*Sat:* Disney’s Story Book Collection( The Ugly Duckling )	Disney Storyland Treasury
*Sat:* Disney’s Story Book Collection( Alice In Wonderland )	Disney Storyland Treasury
*Sat:* Disney’s Story Book Collection( Cinderella )	Disney Storyland Treasury
*Sat:* Disney’s Story Book Collection( Peter Pan )	Disney Storyland Treasury
*Sat:* Disney’s Story Book Collection( Sleeping Beauty )	Disney Storyland Treasury
*Sat:* Disney’s Story Book Collection(Beauty and the Beast )	Disney Storyland Treasury

*It was Not all books, We sang, yes, we danced, Christ was with us*	*Jillian by heart knew these & more*
Pop Goes the weasel	Classic Nursery Rhythms
Jack and Jill	Classic Nursery Rhythms
If you’re Happy and You Know It	Classic Nursery Rhythms
Five Little Monkeys	Classic Nursery Rhythms
Pat-a-Cake	Classic Nursery Rhythms
Three Blind Mice
Baa, Baa, Black Sheep
Hot Cross Burns
Oh Dear What Can The Matter Be
Little Miss Muffet
Little Jack Horner
Twinkle, Twinkle Little Star
Polly Put that kettle On
30 Days hath September
I’m a Little Teapot
The Cow Who Jumped Over The moon
Humpty Dumpty
Old McDonald Had Farm
Hey Diddle, diddle
To Market, To Market
Pease Porridge Hot
Jack Sprat
Sing A Song of Six Pence
Do Your Eyes Hang Low
Jack Be Nimble, Jack be Quick
Hickory, dickory dock	Classic Nursery Rhythms
We Read Bible Stories Too, We Read the Holy Bible!!!!	The Holy Bible, the infallible Word of God
*Veggies Tales Bible StoryBook* King Solomon King David Queen Esther Samuel Samson Noah and The Ark The Creation The 10 Commandments	VeggieTales

The List is inexhaustible, once Jillian learned to read, she ran with books to school, to church, at the subway, she could not stop!
Blizzard of the Blue Moon	Mary Pope Osborne
December Secrets	Paatrica Reilly Giff
The Boxcar Children Books 1-4	Gertrude Chandler Warner

Mrs. Piggle-Wiggle Chapter books* Reading level: Ages 8 & up. 128 pages by Betty Mac Donald ** Jillian Read this Book at age 5!!!!! – read before Judge Lewis	Betty MacDonald

CONCLUSION/RELIEF

The present horrible conditions of the subject child afore stated determine what she will become in the future and that DCF is not in dispute with anything in this case and no steps have been taking since over one year of the rumor base cause of removal and as such the subject child must be returned to Ms. Ogechi Eke to enable her return the hope of this Child to where intended before she was forcibly removed.

Therefore sake of the foregoing, Applicants’ Motion must be granted and subject child be returned to Ms. Eke and other order Court deems fit.

VERIFICATION

Respectfully verified, signed and submitted under the pains and penalties of perjury this 14th day of August 2012,

___________________________________

OGECHI EKE (Defendant)

___________________________________

Phillip C. Ofume, Ph.D.

Intervenor/Advocate

To:

Boston Juvenile Court

Clerk’s Office

24 New Chardon Street

Boston, MA 02114

CERTIFICATE OF SERVICE

I, OGECHI EKE certify that a true copy of the APPLICANTS, OGECHI EKE AND PHILLIP OFUME'S VERIFIED JOINT EMERGENCY MOTION AND MEMORANDUM FOR SUMMARY JUDGMENT AS TO URGENT RETURN OF CUSTODY TO PARENT, OGECHI was served up on the Attorney General of Mass and other parties by U.S. Postal Service first class mail or Hand Delivery on August 14, 2012.

Massachusetts Department of Housing and Community Development c/o The Honourable Secretary of Justice and Attorney-General of the commonwealth of Massachusetts Attention, Attorney of Record Gwen A. Werner Department of Justice (Litigation) One Ashburton Place Boston, MA 02108 -1518 Phone: (617) 727-2200

Attorney Amy McManus Geary, Esq

P.O. Box 248

North. Quincy MA 02171

Kathleen J. Moore

____________________

OGECHI EKE

Date: August 14, 2012

cc. President Barack Obama, Vice-President Joseph Biden, H.E. United Nations High Commissioner for Human Rights, Counsels for DCF, Child and Foster Parents, The Hon. Secretary and Attorney-General of the United States, Eric H. Holder, Jr., Hon. Secretary of State, Senator Hilary Clinton, H.E. Secretary General of the United Nations, Bakim Moon, Executive Director, UNICEF, Chair, Amnesty International (Intl. Secretariat, London, UK), Executive Director, Human Rights Watch (USA), President, AAAA (Washington, DC, USA), LIMPT, INC. (EDUCATION & WORKFORCE PROJECT, c/o Dr. Phillip Chukwuma Ofume – National Coordinator), etc.

universal-fashion-art-music et allied products

Wednesday, August 22, 2012

AMERICA: THREAT TO NON-WHITE CHILDREN AND PARENTS BY DSS/DCF