BOSTON JUVENILE COURT AND CASE OF AN ENDANGERED CHILD: BRIBERY AND CORRUPTION TO DELAY PROCESS/PROCEEDINGS TO RETURN CUSTODY TO MS. OGECHI EKE (BLACK), CHILD WHO HAS BEEN UNDER DANGEROUS SHARED CARE AND CUSTODY OF THE MASS. DCF/DSS AND CRUEL FOSTER RECEIVERS.

BOSTON JUVENILE COURT AND CASE OF AN ENDANGERED CHILD:  BRIBERY AND CORRUPTION TO DELAY PROCESS/PROCEEDINGS TO RETURN  CUSTODY TO MS. OGECHI EKE (BLACK), CHILD WHO HAS BEEN UNDER DANGEROUS SHARED CARE AND CUSTODY OF THE MASS. DCF/DSS AND CRUEL FOSTER RECEIVERS.

London, UK  August 1, 2012

IN THE UNITED STATES, DCF/DSS TARGET ANY NON-WHITE  TALENTED/GIFTED/SMART /A/A+/B+ CHILD AND RELATED CHILD AND PARENT AND WATCH THEM  AND ASSIGN SECRET AGENTS TO FOLLOW THEM UP AND DOWN FROM THE BIRTH OF THE CHILD THROUGH 18 YEARS.

DCF SPEND SEVERAL MILLIONS OF DOLLARS TO  PAY SOCIAL SERVICE AGENCIES, EMPLOYERS, LANDLORDS AND REAL ESTATE COMPANIES, UTILITY COMPANIES TO SANCTION AND OVER BILL SERVICES TO IMPOVERISH PARENTS TO BRING ALLEGATIONS OF "UNABLE TO PROVIDE FOR THEIR FAMILIES" AND LEVERAGE ON THESE ALLEGATIONS TO SEIZE THEIR CHILDREN.

MS. EKE HAS MONEY AND PROVIDED SURPLUS FOOD, CLOTHES, SPECIAL AND BEAUTIFUL STUDY AND SLEEPING ROOMS FOR HER CHILD AND HERSELF,  EDUCATIONAL RESOURCES AND SOURCES, SHOES, ETC. ETC. ETC. MS. EKE DOES NOT DRINK ALCOHOL, SMOKE,  USE DRUG, ETC. HEALTH WISE  SHE IS SOUND AND HEALTHY AND TALENTED/ GIFTED/ SMART HAPPY YOUNG WOMAN AND WITHOUT RACIST MARKING AND SCORING IN U.S. SCHOOLS SHE IS A/A+/B+ STUDENT.

CHILD OF MS. EKE  WAS FOLLOWED FROM PREGNANCY TO BIRTH AND FEW MINUTES AFTER HER BIRTH THE TRAINED RACISTS WHO ARE AGENTS OF THE  DCF/DSS MOUNTED INSIDE AND OUTSIDE THE HOSPITAL, SCHOOL AND IMMEDIATE COMMUNITY RUSHED INTO THE NATAL OR MATERNITY WARD AND WHILE MS. EKE WAS IN POST-NATAL PAINS AND STRUGGLING WITH HERSELF WITHOUT ASSISTANCE BY THE NURSES, DCF AGENTS STARTED PANICKING THE WARD WITH, "WHERE IS THE CHILD IN DANGER!!!" BECAUSE UNDER FALSE ALERT THEY TELEPHONED EMERGENCY LINE AND SWIFTLY THE NEW BORN BABY  WAS SEIZED AND REMOVED TO UNKNOWN DESTINATION.

ACROSS THE UNITED STATES, OVER 95% OF THE STAFF STRENGHT IS WHITES AND NON-WHITES ARE UNSECURED IN  HEALTHCARE DELIVERY. PUBLISHERS HAVE SENT SEVERAL RECOMMENDATION TO THE GOVERNMENT OF AMERICA AND STATES TO REQUEST SCHOOL OF MEDICINE INCLUDING SCHOOL OF NURSING TO TRAIN NON-WHITES TO STIMULATE EQUITY IN THESE PROFESSIONS.


AS USUAL UNDER ALL WHITES STAFFED HOSPITAL, BLACKWOMAN, MS. EKE WAS ALONE AND IN THE UNITED STATES RARELY A WHITE PERSON WILL SPEAK OUT AGAINST THE MISTREATMENT OF NON-WHITES  BY WHITES MOSTLY UNDER THE PETITIONED CIRCUMSTANCE. AFTER SEVERAL STRUGGLES TO TAKE CUSTODY OF THE NEW BORN BABY THE PRESENT OR ANOTHER JUDGE RETURNED CUSTODY AND CARE OF THE NEW BORN CHILD TO HER MOTHER, MS. EKE.  THEREAFTER, THEY REORGANIZED TO UNLEASH THE ON-GOING DURABLE SEIZURE WHICH HAS DESTROYED THIS CHILD EDUCATIONALLY, SOCIALLY, PSYCHOLOGICALLY, CULTURALLY, ETC.


 THE WORK OF THE DCF/DSS AGENTS  INCLUDE BUT UNLIMITED TO CREATING STRONG EX-COMMUNICATION BY PROPAGANDA AND CALL  ALL NON-WHITES PEOPLE  WITH MENTAL HEALTH PROBLEM AND THE DANGEROUS PHYSICIANS AND NURSES THEY HAVE IN THE UNITED STATES HELP THEM TO FALSELY ENDORSE THE ALLEGATION TO FACILITATE SEIZURE OF THE TARGETED CHILDREN.

BRIBERY AND CORRUPTION AT BOSTON  JUVENILE COURT: WHAT IS BEHIND A PROCESS AND PROCEEDING IN WHICH CLERK OF COURT ALTERS DATE OR TIME OF HEARING OF SETTLED COURT SCHEDULE PRE-AGREED BY ALL PARTIES?  COULD THIS OCCUR WITHOUT ORGANIZED REASON?

THIS AN EMERGENCY CASE IN WHICH A BLACK CHILD UNDER THE SHARED RISKY CUSTODY AND CARE OF THE DEPARTMENT OF CHILDREN AND FAMILIES (DCF). REMEMBER THAT IN THE UNITED STATES OVER 99.9% OF THE CONGRESS OF THE UNITED STATES IS WHITES AND FROM THE ACTIVITY STANDPOINT OF THE DCF OR DSS,  SECRET PURPOSE FOR ESTABLISHING THIS AGENCY IS TO DESTROY NON-WHITES CHILDREN ESPECIALLY NON-WHITES THAT ARE TALENTED/ GIFTED/ SMART/A/A+/B+ CHILDREN. SEVERAL U.S. JUDGES HAVE CONTRIBUTED HUGE PART IN ENSURING MAXIMUM  DESTRUCTION OF THESE TALENTED/GIFTED/SMART /A/A+/B+  NON-WHITE CHILDREN TO SANCTION COMPETITIVENESS AGAINST WHITES IN JOB AND SERVICE MARKETS.

PUBLISHERS CALL ON THE UNITED NATIONS, GOVERNMENTS, LEADERS AND NGOS TO CAUSE URGENT DISCOVERY EXAMINATION WITHOUT PRIOR NOTICE ON THE JUVENILE COURTS ACROSS THE UNITED STATES.  EXTREME MAJORITY OF THE CHILDREN AND PARENTS BROUGHT TO THESE COURTS BY THE DCF/DSS IS NON-WHITES AND PUBLISHERS HAVE FOLLOWED SEVERAL CASES AND VIEWED THE ROLE OF JUDGES, DCF AND COURT WITH DISMAY EXTREMELY DISTURBING ACROSS THE SYSTEM.

MS. OKECHI EKE'S CHILD WHO WAS SECOND TIME FORCIBLY REMOVED BY THE DCF  IS TALENTED/GIFTED/SMART /A/A+/B+ CHILD BECAUSE OF THE EFFORTS OF HER MOTHER, MS. EKE. WHEN INTERNATIONAL EXPERTS REVIEWED WHAT MS.  EKE DID TO MAKE HER DAUGHTER BE TALENTED/GIFTED/SMART /A/A+/B+ CHILD THEY FOUND THAT SHE CONSTRUCTED  PRE-K THROUGH 3 CURRICULA  WHICH SHE DIVIDED INTO  STEP BY STEP STRAND AND WHEN THE CHILD WAS LESS THAN 3 YEARS SHE APPLIED FIRST STEP AND CONTINUED FURTHER AND FURTHER STEPS AND BEFORE THE CHILD WAS 4 YEARS SHE (CHILD) HAS STARTED GRADES 4 AND 5 BOOKS AND WRITING LETTER WITH UNDER OR GRADUATE  LEVEL HANDWRITING.

BEFORE THE HONOURABLE PRESIDING JUSTICE OF THIS COURT SHE READ PARAGRAPHS OF ONE OF THESE BOOKS.  SHOCKING THAT THIS JUDGE  DID NOT GIVE THIS CHILD TO MS. EKE  BUT THE JUDGE LED THIS CHILD INTO THE PRESENT DANGER AND ANONYMOUS INFORMATION DIRECTLY FROM THE CHILD 'S PRESENT SCHOOL  AND ENLARGED FROM THE FOSTER PARENTS  SIDE THROUGH THE CHILD, PUBLISHERS WERE TOLD THAT THE CHILD HAS LOST MAJORITY OF THE SOUND ACADEMIC GROUND  WHICH HER MOTHER HAS PLACED HER BEFORE THIS CRIMINAL AGENCY (DCF) REMOVED HER INTO VICIOUS AND UNLEARNED  HARMS WAY BECAUSE THE INFORMATION FURTHER ALLEGED THAT SHE IS USED TO  DO DIFFERENT TYPES OF CHILD LABOR AND ALL THE CURRICULA WHICH HER MOTHER TRANSFERED TO THE FOSTER PARENTS WERE DUMPED AND AFTER SCHOOL SHE IS FORCED TO DO TORTUROUS HARD LABOR WITHOUT TEACHING. OTHER SIDE OF THE INFORMATION SAID THAT DCF IS LOBBYING THE SCHOOL TO PREPARE DECEITFUL REPORT CARD WHICH IS DIFFERENT FROM THE OFFICIAL RESULT OF THE CHILD PURPOSED TO DECEIVE ONLOOKERS.

MS. EKE IS A GRADUATE OF NIGERIAN HIGHER INSTITUTION AND IN THE UNITED STATES SHE IS STUDYING PHARMACY AND WILL DO HER FINAL EXAMINATION SOON. AFTER REVIEW OF OVER 3,000 PAGES OF DOCUMENTS ON THIS CASE, PARTICULARLY MS. EKE'S EDUCATIONAL ENRICHMENT RESOURCES, PUBLISHERS FOUND NO REASON THIS COURT ALLOWED THIS   TALENTED/GIFTED/SMART /A/A+/B+ CHILD TO BE DESTROYED BY THESE CHILDREN MERCHANTS (DCF AND FOSTER PARENTS).

MS. EKE IS VERY SOUND AND ACADEMICALLY STRONG AND HER PRE-K - 12 CURRICULA ARE WHAT ALL PARENTS IN THE WORLD AND EDUCATION SECTORS NEED TO TAP INTO AND TO  RAISE STANDARDS OF EDUCATION UNDER THIS LEARNING MODULE. PARENTS AND STATE, DISTRICT AND FEDERAL DEPARTMENTS OF EDUCATION MUST  ATTEND MS. EKE'S LECTURE SERIES TO LEARN HOW TO JUMP THE STANDARDS OF EARLY AND POST EARLY CHILDHOOD EDUCATION.

SINCE NATIONAL AND INTERNATIONAL  CIVIL RIGHTS ORGANIZATIONS INDICATED INTEREST TO JOIN MS. EKE IN THIS CASE, JULY 31, 2012 WAS THE FIRST MEETING WITH THE JUDGE IN THIS CASE NOTHWITHSTANDING THAT THE HEARING WAS LIMITED TO REMOVAL OF THE SLEEPING ATTORNEY IN THE CASE, UNDER THE ILLEGAL COALITION TO DESTROY NON-WHITE CHILD,  THE CLERK OF THIS COURT, DCF, OPPOSITION ATTORNEYS, ETC ALTERED THE HEARING TIME FROM 2.00 PM TO 9.00 A.M.

FURTHER READINGS:


http://universal-fashion-art-music.blogspot.com/search?q=DCF+NOTICE+TO+THE+CONGRESS+OF+THE+UNITED+STATES4


______________________________________________________________________

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)
                      v.


Massachusetts Department of Children and Families (DCF)
                   Respondent/Plaintiff

________________________________________________________________________

 APPLICANT 'S, OGECHI EKE  VERIFIED EMERGENCY MOTION TO DISMISS ATTORNEY AMY MCMANUS GEARY FROM HER DAUGHTER'S CARE & PROTECTION CASE
________________________________________________________________________

Subject:   Care and Protection 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, moves seeking Order of this Honourable Court to allow Attorney Amy McManus Geary to withdraw her representation from this case because of the following reason:

1.     I want to represent myself in this case under the capacity of Pro se because the former carriage of my case has caused a considerable delay in return of the custody of my child to me. I read several briefs filed on my behalf and I found that the representation is weak and reliant on this I want to amend all motions and other pleadings to this Court to enable me request for Emergency Hearing to cause return of my child's custody immediately because my child is in danger, educationally, socially, economically, psychologically, etc.


2.    I have made considerable progress in Juvenile and other law studies and contacted
                                                            1
OGECHI EKE  V. DCF DOCKET NO.  CP10B0179          
several national and international lawyers, experts, civil rights activists, victims of similar persecution, etc. Based on my present experience, I found that I was not lawfully, equitably and strongly represented to reclaim custody of my child.


3.    Impacts of my under-representation and misrepresentation based on deliberate obstruction of justice and protection of the constitutional rights of my child before this Court extend to lack of properly informing this Court the extensive damage done to my child all of which has been swept under the rug and leaves my child in harms way. Prior to forcible removal of my child thus, my child was scholarly built by me and seen as TALENTED/SMART/GIFTED/A/B+ student and the Department of Education was ready to waive several grades and place her in grade 2 or 3.


4.    Information from anonymous research and investigation show that my TALENTED/SMART/GIFTED/A/B+  child has been down graded to k student because her present placement foster parents  failed, refused and neglected to meet the standard curriculum which I used to bring her to TALENTED/SMART/GIFTED/A/B+  and which are similar to what Finland and Limpt, Inc. (Education and Workforce Project) are doing to have the best standard of education in the world.  Education which I strongly consider as  the GATEWAY TO EVERY BETTER THINGS IN THE LIFE OF “MAN”, 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, private study and creativity, continuous and comprehensive assignments and evaluation,  play and interaction with other kids. All these processes are repeated daily. Majority of this educational background are lost in her on-going placement and she is  dragged down to  K student level instead of grade 3 which is the plan focus of my curriculum. I had over seven embedded curricula teaching structures -after school, recreation, several scholarly enrichment programs which flow by extension through weekend, school breaks and summer holidays (restating see Finland Education Project and LIMPT, INC. – Education and Workforce).


5.    Essential needs such as healthy meal, beverage, clothes, show of likeness to child, parental care and protection, teaching tool and out house teachers’ review, etc are also close to zero in this hostile placement. I have several clothes, shoes, toys, etc for my child. On picture day, my daughter who has over fifty shirts, jeans, dresses, shoes, etc wore dirty and thorn dress to take her picture. I have to rush to my apartment to get her beautiful. I will call this Honourable Court to grant discovery examination on the foregoing pleadings.


 6.   In this present placement, my child is psychologically and physically tortured and

                                                            2
OGECHI EKE V. DCF DOCKET NO.  CP10B0179          
Representation of my child to this Court on these harms is close to zero. In the past during
my visit I saw unattended open injury on her right hand and I ask her what happened to your hand and swiftly the foster parents shut me up and forcibly and immediately asked me to leave their home; and subsequently made it impossible to see my child including manufacturing allegation of trespass whereas during her singing engagement they (foster parents) invited me to show up to view her singing activity. Also on December 20, 2011 the foster parents asked me to attend a performance my daughter was performing at her school and upon arriving at the school, they accused me for trespassing.


etc. etc. etc.
                                                                                                                                                                                       
                             VERIFICATION


 Respectfully verified, signed and submitted under the pains and penalties of perjury this 19th   day of July 2012,

.
________________________________________
                    OGECHI EKE
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 above document were served up on the Attorney General of Mass electronically and U.S. Postal Service first class mail on April 13, 2012.                                                                              


Massachusetts Department of Housing and Community Development                                                                                                                                                                         c/o The Honourable Secretary of Justice and Attorney-General of                                                                                                                                                                    
                                                3



OGECHI EKE  V. DCF DOCKET NO.  CP10B0179          
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


____________________
   OGECHI EKE  


Date:   July 19, 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.

                                                       4


--------------------------------------------------------------------------------------------------
NOTION # 3
OGECHI EKE  V. DCF .  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/Advocate  - Defendant

                      v.

MASSACHUSETTS DEPARTMENT OF CHILDREN AND FAMILIES(DCF)
                   Respondent/Plaintiff
 _____________________________________________________________________
 PART NOTICE OF MOTION TO AMEND  DEFENDANT'S DEFENCE TO JOIN INTERVENOR AND HUMAN RIGHTS ADVOCATES PURSUANT TO MASS. CIVIL PROCEDURE RULE 24
______________________________________________________________

Subject:   Care and Protection 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, moves seeking Order of this Honourable Court,


 1.       to allow Dr. Phillip Chukwuma Ofume who has been at all material time highly acclaimed national and international Human Rights Leader and over 35 years experience in advocating for the rights of the Child in over 16 countries; National Coordinator of  LIMPT, INC  (EDUCATION AND WORK FORCE PROJECT); Nominee for The National President of the American Association for Affirmative Action (AAAA);  Presidential Candidate of Nigeria past and 2015;with strings of academic and professional qualifications and experiences ; etc  to join Defendant as intervenor and advocate in the matter of the Care and Protection of the Subject child ;


2.    In accordance with Defendant's  Motion filed with this Honourable Court, she restates that her ability to take carriage of her defence thus, acting as Pro se;


3.    Defendant, by and through her intervenors, advocates, and external attorneys respectfully requests this Court to grant short adjournment NOT LATER THAN August 10, 2012 to enable her amend all submissions filed on her behalf and to file with this Court a MOTION FOR SUMMARY JUDGMENT and same be marked up for final hearing  on Monday, August 20, 2012.    
                                                                                                                                                                               
                             VERIFICATION

 Respectfully verified, signed and submitted under the pains and penalties of perjury this 31st   day of July 2012,

                     SIGNED & FILED
___________________________________
           OGECHI EKE  (Defendant)

                   SIGNED & FILED
___________________________________
          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 above document were served up on the Attorney General of Mass electronically and U.S. Postal Service first class mail or Hand Delivery on  July 31, 2012 at.    
                                                                         
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

      SIGNED
 ____________________
   OGECHI EKE  

Date:   July 31, 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.

BOSTON JUVENILE COURT: JUDGE PAUL LEWIS V. MASS. COMMISSION ON JUDICIAL CONDUCT

NATIONAL AND INTERNATIONAL RELEASE ORDERED IMMEDIATELY

             COMMONWEALTH OF MASSACHUSETTS
 SUFFOLK, ss                                        BOSTON JUVENILE COURT
                                                                       Docket No.    CP10B0179
______________________________________________________________________
                             
             PHILLIP OFUME (LIMPT, INC. -                                                                                                                                              EDUCATION AND WORK FORCE PROJECT)
                    Appellant/ Intervenor - Defendant

                                 and

                        OGECHI EKE
               Defendant (Mother of the Subject Child/Pro se)
                                     v.
MASSACHUSETTS DEPARTMENT OF CHILDREN AND FAMILIES(DCF)
                   Respondent/Plaintiff
_________________________________________________________________________

DEFENDANTS' OGECHI EKE AND PHILLIP OFUME & ASSOCIATES' VERIFIED                     MOTION TO SUBMIT  WITNESS AND EXHIBIT PURSUANT TO F.R.C.P. 5.2.,                                    M.R.C.P. 34, 30,
_________________________________________________________________________

1.          Here comes Subject Child's "Biological Mother", Ms. Ogechi Eke and Dr. Phillip Ofume and Associates acting on behalf LIMPT, INC. et als in the above referenced matter and hereby respectfully submits the following list of intended witness, intervenors and exhibits in support of the proceedings mark up for hearing on September 25, 2012 and October 9, 2012 as ordered by the Honourable Presiding Justice Paul Lewis on September 6, 2012.

2.     Defendants request leave of this Court to protect the names and other particulars of the Subject Child and their  witnesses because of the following reasons:

2.a.            Plaintiff, DCF's  use  hired hit people, harassment, bribery and corruption, libel, slander, lies, racist conduct, deception, mischaracterization, attack on life and property (several attacks on mother of the subject child life and property) and related intolerance as path to destroy Subject Chlid's Mother and destroy and hold endless possession of the Subject Child.
2.b.      For example, in the only and major genesis of this case thus,  on September 30, 2004 under difficult conditions Ms. Eke delivered the Subject Child and she was very beautiful and healthy. Suddenly,  for no just, legal, factual, scientific, research and investigative reason the Igbo, Nigeria English Language Accent, culture and tradition differences between The United States and The Igbo of the Federal Republic of Nigeria was branded yelling and DCF was telephoned to seize the subject child and as usual for the children of non-whites the child was reported as being in eminent danger and must be removed.

 2.c.  A racist psychiatric doctor expanded these racist profiling, libel and mischaracterization by the doctors and nurses of this hospital and lied and less than one minute view of Ms. Eke led to recommendation of  mental health problem and  treatment for Ms. Eke as usual route in the United States to seize, hold possession  and destroy BEAUTIFUL/TALENTED/ SMART/ GIFTED/A/A+/B+ children of Non-whites (visit and see color and race demographic statistics of the Juvenile Courts across the United States. This mental health problem recommendation by this racist psychiatric doctor was issued without research and investigation and suddenly and instantly Ms. Eke was subdued by several irate or hostile men and women of the DCF and Ms. Eke was addicted with unknown medications and she was put to over 24 hours long sleep to enable DCF and health department create falsified medical record and look for racist court and judge to file petition for care and protection and  the new born subject child was seized and removed to unknown destination without Order of the Judge and to this present time no order has been disclosed in support of their action. Immediately, the Plaintiff, DCF used several social media, news letters,  several well paid agents, etc to spread the rumor inside and outside Ms. Eke's  schools, communities and neighborhood, workplace, church, friends, job search terrain of Ms. Eke, etc and place to place these agents spread the lies that Ms. Eke is a mad woman and under going mental health treatment and, for safety reason that public should maintain distance from her because she is armed and violent, etc.

3.             FOR THE FOREGOING FEAR DEFENDANTS' LIST OF WITNESS ARE AS FOLLOWS:

3.1.    Jonelle
3.2.   Vivia
3.3.   Chichi
3.4.  George
3.5.  Eddy
3. 6.  chuks
3. 7. Tin U
3.8. Mama
3.9.  Ogechi (leave of Court for opposition's and intervenor's cross- examination)
3.10.  Defendants reserve the right to call additional prospective witnesses, if necessary during the course of the intended trial with notice to the Plaintiff and others that my named parties to this case.
3. 11. All psychiatric doctors in this case September 30, 2004 through September 25, 2012 (leave of Court for Defendant' s, opposition's and intervenor's cross- examination)
3.12.   Attorney Amy M. Geary (leave of Court for Defendant's, opposition's and intervenor's cross- examination)
3.13.   Edith
3.14. Jillian
3.15.  May

4.            LIST OF PHYSICAL AND OTHER EXHIBITS

EXHIBIT                                         DESCRIPTION
_____________________________________________________________

  4.1.    Proof of Ms. Ogechi Eke's  Igbo, Nigeria nationality.

4.2.      Birth Certificate of the Subject Child and Birth Biography.

4.3.      Ms. Okechi Eke's proof of life without criminal record; 100% life as devout Christian Communion; Life without smoking, without use of alcohol, without use of hard substance and drugs; healthy and undisturbed life; life under community service; and without threat to herself and immediate and extended neighborhood and community.

4.4.       SERVICE PLAN, COMPLETION AND EXPERT REPORT - LOCATION OF CARE :   Roxbury Comprehensive Community Health Center - Mental Health Department.  Name of Provider:  Angela Bell, Ph.D. LMHC. Department of Children and Families (DCF),  and other collaborating predominantly white department refused to accept Dr. Bell's Expert assessment and evaluation conducted on Ms. Ogechi  Eke because the provider, Dr. Bell is a Black. In this case the Court, Judges and DCF staff are divided. One  part of the DCF staff said, “white attorneys and DCF staff are rejecting the report because as usual the provider is not a white and they want the child of a black woman Ms. Eke at all cost.” On September 4, 2012 the Haitian Court Investigator controlled by Judge Lewis (White) received copies of the mental health report of Dr. Bell and she (Haitian Court Inspector) promised to give the Report to Judge Lewis and on September 4, 2012 and under the conspiracy between DCF and this Court the purported Court Investigator censored 100% of the progress made by Ms. Eke including completion of the majority of the SERVICE PLAN including the falsified mental health treatment recommended by a racist mental health doctor on September 30, 2004.

4.5.    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  filed with this Court on August 15, 2012 (http://universal-fashion-art-music.blogspot.com/2012/08/america-threat-to-non-white-children.html). Affidavit of Compliance and Certificate of Service were filed with this Court on August 24, 2012. In this Motion see EXHIBITS  A & B which are list of EXHIBITS now serialized from the present list of Exhibits in which EXHIBIT B  is EXHIBITS 4.6 through EXHIBITS 4.118 and EXHIBIT A  is EXHIBITS 4.119 through EXHIBIT 4.235. EXHIBITS A & B are large resourceful educational materials which Ms. Eke used to make her child become TALENTED/SMART/GIFTED/A/A+/B+ student/child and now the longstanding racist conspiracy implemented by this Court, DCF, and Ms. Eke’s  former attorney has dragged these efforts of single Mother into the mud and the subject child who received several merit awards in mathematics, reading, writing, etc and the Department of Education aimed at promoting the subject child from K to Grade 2 or 3 but now at foster parents' home the subject child has been destroyed and returned to K because the foster parent do not believe in education and after school and other times this child is not taught and in place of teaching her (subject child) she is used to do indentured labor at the foster parents' child daycare business facility. The Congress of the United States which is over 99% white has been informed about the dirty or extra- judicial activities in this Court since 2004.

4.236.  Pending Complaint filed with Commonwealth of Massachusetts Commission on Judicial Conduct to remove Judge Paul Lewis from this case because of an overwhelming act of racial bias, allowing DCF to become the Judge of this Court; denial of Ms. Eke's opportunity to be heard and defended by her approved representatives that have knowledge of her case because 2004 through present her attorneys/lawyers have become excessively corrupt and work for the Plaintiff, DCF and acted in breach of 1st, 4th, 5th and 14th Amendments to the Constitution and Bill of Rights of the United States; ex-parte communication and absentia agreement, hearing, etc; obstruction of justice; failure to follow the law and highhanded incompetence; abuse of authority; conspiracy between Ms. Eke's attorney and court to earn corrupt agreement of permanent custody of Ms. Eke's ONLY child at the age of over 40 years; conspiracy and collusion; retaliation; bringing the judiciary into disrepute; fear plaintiff or DCF and sanction right of intervenors who have strong interest in this case pursuant to Mass.Civ.P.R. 24(a); sanction right to self-representation of Ms. Eke to recommend further corrupt attorney and to destroy her case Judge Lewis sanction her representatives that have been doing child care and protection cases inside and outside the United States and other cases inside and outside the United States; etc.etc.etc.

4.237.  Pending Complaint filed with OFFICE OF THE BAR COUNSEL OF THE BOARD OF BAR OVERSEERS against Attorney Amy Geary because of highhanded violation of 1st, 4th, 5th and 14th Amendments to the Constitution and Bill of Rights of the United States; forced Ms. Ogechi Eke to sign several documents without allowing her to peruse them and without providing to her copies of the documents she was forced to sign; barring Ms. Eke from attending majority of her and her child's court proceedings; worked for DCF and stay defence of Ms Eke’s  interest and her child's interest; failure to oppose oral and other motion filed by DCF; etc. etc etc.

4.238.      Documents/papers, testimonies and other Information relating to the birth and emerging conditions of the birth of the subject child in this U.S. Hospital including medical reports and post natal pains, stress, mistreatment by the doctors and nurses in this hospital.

4.239.      Leave of this  Court to request DCF to produce its documents or Order of the Honourable Presiding Judge or Order and documents of any other approved official of the Commonwealth of Massachusetts which empowered Plaintiff, DCF on September 30, 2004 to seize, command Ms. Eke's relations and friends to leave the hospital room where Ms. Eke and her baby ("subject Child"), relations and friends were placed,  drugged  Ms. Ogechi Eke, handcuff and subdued her,  put Ms. Eke to over 24 medicated sleep and removed her child ("Subject Child") to unknown destination  instead of placing the new born baby ("subject child") in care and protection of Ms. Eke's relations and friends and if possible continue to make Ms. Eke an inpatient in the hospital with assigned  case worker but DCF staff who make money by seizing children did not care about the Mother (“Ms. Eke”) of the Child .

4.240.       Clerk/Magistrate of this Court to produce its documents if any related document and order mentioned above and below.


4.241.       Unenforced Order of The Honourable Presiding Justice Paul D. Lewis dated on March 2, 2011 and Court Seal and summarized, " Custody is to remain with the Mother with the following conditions"(Judge Paul D. LewisE). Ms. ke is not aware of this Order because her attorney censored majority of the process and proceeding in this case. In August  2012 when her Attorney disclosed her documents, Ms. Eke did not violate any of the 9 conditions which Judge Lewis listed. Defendants desire to make this Exhibit "4.6." public and in part to steer up question before Judge Lewis on September 25, 2012 to the limited extent in issue whether after the Order of Judge Lewis dated March 2, 2011 allowing custody to remain with the Subject Child's Mother, Ms. Eke, what was the crime or violation committed by Ms. Eke which led to the re-seizure of the Subject Child in April 2011. This question will be directed to Judge Lewis. Ms. Eke brought ray of light into this onlooker or public interest question when she said that DCF conspired with this Court and her Attorney to re-seize her child because sometimes in April 2011 or thereafter that they (Judge, Court, DCF and her Attorney) said that it was unlawful for her to travel to Nigeria with her child to attend burial of her relatives because she will not have food to give to her child in Nigeria. The nine (9) conditions listed by Judge Lewis none of the condition place travel ban or restriction on Ms. Eke and the Subject Child or Ms. Eke's Child.  In the Commonwealth of Massachusetts and the United States of America will attendance of burial of relatives be regarded as crime to create Order of this Court to seize a child and place the child in "labor camp" called foster home where "foster parents"  use the Child as money making tool and make the child remain in danger economically, educationally, socially, and psychologically?

4.242. Jullian - Information reveals that the "foster parents" have in-house money making business of child day care and other businesses. Physical restatement of the Oral Testimony of the Subject Child before Ms. Eke because the foster parents have deeply used words of the mouth, Nigerian voodoo, and indentured labor to intimidate and torture the Subject child to the extent that sometimes Ms. Eke visit her Child in the home of the foster parents, the foster parents will be mounted closely face to face and the child will look at them and panic and afraid to talk and less than two minutes the Subject Child will turn her face on the angry looking 'foster parents" and the Subject Child will say, " I am going to work" and she will run towards the direction of the Child Daycare facility.

4.243.  Pursuant to Mass. General Law Section 12 Chapter 278A Title II Part IV, request the Clerk/Magistrate of this Court to produce documents relating to Order of this Court in April 2011 or sometime thereafter empowering DCF to re-seize the Subject Child and seizure which enlarges to present time. This Order must contain conditions which DCF, foster parents, caseworkers, etc must follow under the on-going temporary custody.

DCF'S  AND OTHER MULTIPLE AND UNATTENDED SERVICE PLANS SHORTLISTED BELOW AND COMMENT

4.244.   OUTLOOK OF THE CONDUCT OF THE DCF (2004 – 2012) AND COURT INVESTIGATOR (09/04/2012)

4.244.a.  On the multiple and unattended SERVICE PLANS short listed below Mother of the Subject Child, Ms. Eke told the experts listed below that the case workers have visited her several times and each time they visit her they spend major time in defending DCF and talk about nominating their psychiatric doctor to redo the service plan (mental health assessment and evaluations and completed (see EXHIBIT 4.1.). To know the parties in default, the NGOs mentioned below were assigned to investigate the conduct of the caseworkers, DCF, Mother of the Subject Child etc. These NGOs were allowed to observe two sessions, September 4, 2012 ( Court investigator of the Office of Judge Lewis) and September 14, 2012 (DCF).  The work of these NGOs was to observe the processes, proceedings,  outcome, progress and follow up on these SERVICE PLANS.  On September 14, 2012 at 4.00 p.m. two female who are  DCF staff visited Ms. Eke and they stayed with Ms. Eke and the Observers for over one hour without reviewing the SERVICE PLAN step by step to know whether or not Ms. Eke has completed the SERVICE PLAN and in place of reviewing the SERVICE PLAN they were busy criticizing Dr. Phillip C. Ofume, Mother of the Subject Child and hatefully criticizing  Dr. Bell, and suggesting that she (Dr. Bell) is not one of the doctors known and retain by the DCF. September 30,  2004 - September 14, 2012 the  DCF has created a plan directed at destroying, mischaracterizing and suppressing the efforts of the Mother of the Subject Child to find path to continue to hold custody of the subject child. The falsified Report of the Court Investigator is a good example of this corrupt practice and obstruction of justice conducts of the DCF, Court, Attorneys for the subject child, Mother of the subject child, DCF, etc.

4.244.b. Under further conspiracy between the court, DCF and department of health and human service, on September 4, 2012 a female Court staff came to Ms. Eke's apartment. This Court staff introduced herself as Secretary to Judge Lewis and also as Court Investigator. She dressed unprofessionally with in-home free clothes and bathroom slippers and looks like a staff harassed, abused,  mistreated and bullied at workplace and very scared of her immediate boss, Judge Paul Lewis and introduced herself before Ms. Eke and one of the NGOs’ experts working on Ms. Eke's  case. She inspected and took notes place to place across the Subject Child beautiful bed room, and saw several hundreds of shoes, clothes, teaching and learning books and other resources and went to Ms. Eke's bedroom and saw several hundreds of shoes, clothes, etc. She toured the very clean bath room, living room, kitchen, refrigerator and deep freezer and saw future several months stockpile of food (meat; fresh vegetables and fruits, cereals, milk, eggs, orange juice, apples, etc). What this Court Investigator said to Ms. Eke's representative in French Language is "Ms. Eke lives life like celebrities and better than several wealthy people in the United States..." (Translation).  When Ms. Eke's representative asked "what reason stands which influenced your Judge to order removal of this child from this heaven to the present hell"  She (Court Investigator) said, "that's the business of Judge Lewis"  Also on September 4, 2012  this Court Investigator took the following notes on the evaluation and assessment of the progress made on the SERVICE PLAN and improvement in Ms. Eke's career, employment and other stable efforts towards stabilization and self-sufficiency sufficient to carter for over five children such as,

"that 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"

2004 – present, to smell the dust of conspiracy between this Court, Court Investigator (09/04/2012), DCF, Foster Parents, the purported Court Investigator remain on track with the DCf, Court, Foster Parents, etc because the Court Investigator, DCF, Judge, and Foster Parent focused on the destruction of the Biological Mother, Ms. Ogechi Eke of the Subject Child and to further maintain this edge the Court Investigator censored the above past and present progress which Ms. Eke made and which the foster parents lack.

4.245.d. PROOF VIA THE CONDUCT OF THE FOSTER PARENTS ON SEPTEMBER 16, 2012 AT 3.00 P.M.

 Several months rolled by from the last visit to see the Subject Child when Ms. Eke was harassed and bullied and chased out of the Fostor Parents'  home and Ms. Eke was warned not to visit their home and that failure Ms. Eke will be charge for Trespass and put in jail because MS. Eke politely asked her child the cause of the deep cut on her hand. In the past visits by Ms. Eke any intervention by simple question on educational progress the foster parents who are always mounted less than three feet apart from the biological mother and her child or subject child will boast in anger to hear the biological mother ask question on educational and other progress in the child’s  life. Soon as such interventionary questions were asked the foster parents will request the biological mother to leave their home immediately  or they will call police on her. Because of several articles/Complaint  against this Court, DCF, Judge Lewis, and Foster Parents by several NGOs etc thus,  on September 16, 2012 the foster parents granted Ms. Eke one time right to see her own and only daughter at a Burger King Restaurant, a  location cited by the foster parents (a Reverend of the Trinity Church of Anglican Church) and some friends accompanied Ms. Eke. On September 16, 2012 Ms. Eke and her friends all of which are devout Christians from different Christian churches were shocked from what they observed on the cruelty of the foster parents and summarized as follows:

4.245.d.i.
The foster parents were late because they claimed that the Reverend had other assignments but the foster parents imposed 3.00 p.m. on Ms. Eke and Ms. Eke who is one of the Assistant Directors of the Fountain of Grace Church TV Program has to abandon her work in the Church to arrive at the Burger King at 2.45 p.m. At about 2.50 p.m. Ms. Eke and her friends were seated in the Burger King Restaurant and after several minutes past 3.00 p.m. only the foster mother arrived without foster father.

4.245.d.ii.
The seating positions of Ms. Eke and her friends were four cardinal point such as north, east, west and south to enable them see all locations and also to see the arrival of the child and the foster parents. Some  of Ms. Eke's friends know the child and the foster parents and their motor vehicle. Amazingly, when they arrived, one of Ms. Eke's friend saw them and they parked without exiting their vehicle and Ms. Eke and one of her friends who knows her child went out of the Burger King to welcome them and as they approached the foster parents' vehicle, the child was very happy and the child rush to open the door of the vehicle but swiftly the foster mother held the child and dragged her back to seat down and prevented Ms. Eke's child from exiting the vehicle to hug her mother. Ms. Eke and her friend approached the foster mother at the driver seat and greeted her and requested of the where about of the foster father, the foster mother said he will be late. The child continued her agitation to exit the vehicle to greet her mother and friend but the foster mother refused. Ms. Eke and her friend waived hands and the child waived back happily. Thereafter Ms. Eke and her friend went back into the Burger King Restaurant  to join other friends and they continued to wait for the foster father.

4.245.d.iii.
After several minutes running towards  4.00 p.m., the foster father arrived and he joined the foster mother and Ms. Eke's child and few minutes the foster parents and the subject child had brief meeting outside the Burger King Restaurant before they approached the Burger King Restaurant and entered inside and soon as they entered the restaurant, the child saw her mother and her friends and the child rushed out and she tried to raise or run towards her mother and her friends but the foster mother held her and again drew her back and cautioned the subject child for about one minute and they proceeded towards Ms. Eke and her friends and the child hugged  and hugged her mother and her friends, the foster parents  used something like sign language to remove the child from Ms. Eke and her friends.  Shocking to Ms. Eke, NGOs Representatives, and friends,  the foster parents said, "we are going" and the foster parents have stayed for less than 3 to 4 minutes and the subject child wanted to stay longer time  with her biological mother and her friends.

4.245.d.iv.
Ms. Eke's child started crying and when Ms. Eke  and her friends asked the child "why are you crying" the foster father talked over her chance to talk and explain why she was crying and the foster father lied and said, "she told her you are fat and growing tall as your were doing" and  Ms. Eke quickly denied such allegations. The subject child quickly responded and said, "that is not true" and the contra response of the child angered the foster parents and swiftly they removed the child and left.

4.245.d.v.
Ms. Eke and her friends cried and cried because the outlook and psychological appearances of the Subject Child show evidence of malnutrition,  indentured labor and hard labor and in research cases child could be growing shorter and shorter if the child is lifting heavy object, not given milk, stressed,  malnourished,  and  lack of child dietetic  food and nutrition service plan by experts,  mistreatment, harassment, bullying and related impacted ordeal which several children under cruel and money making foster parents suffer. The growth of the child is severely downwards, height strongly reduced and the photographs of the child before she was removed will remain supportive to this trend. Defendants request the Clerk/Magistrate of this Court to issue subpoenas on the foster parents and DCF to bring the Subject Child to the Court on September 25, 2012 and October 9, 2012.

4.246.e.    Comparative Photo album of the Subject Child past and present

4.247   COMPLETED SERVICE PLANS AND MANUFACTURED AND RE-MANUFACTURE SERVICE PLAN TO KEEP THE CHILD PERMANENTLY IN FOSTER CONDITION AS MONEY MAKING TOOL # SP ID: 3380873   Period 03/22/2012  to 09/22/2012; SP ID: 3298095 Period  10/11/2010 to 04/11/2011; SP ID: 3174765 Period 03/07/2008; SP ID: 3206982 Period 03/09/2009 -09/09/2009; SP ID: 3139825 Period 03/07/2008 to 09/07/2008; SP ID 3239786 Period 03/09/2009 -09/09/2009; SP ID: 3298095 Period 10/11/2010 - 04/11/2011; SP ID:3290648 Period 08/16/2010 -10/10/2010; SP ID: 3291140 Period 08/16/2010 -10/10/2010; ETC.

5.                 CONCLUSION/RELIEF
Restating that the present horrible conditions (torturous foster stay) 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 submission including motion for summary judgment (http://universal-fashion-art-music.blogspot.com/2012/08/america-threat-to-non-white-children.html) 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. Eke to enable her return the hope of this Child to where intended before she was forcibly removed and child's hope shattered.
Therefore sake of the foregoing, Applicants’witnesses be allowed and exhibits entered into evidence 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 17th  day of September 2012,

___________________________________
   OGECHI EKE  (Defendant)





 
-------------------------------------------------------------------                                                                                                          

      Phillip C. Ofume, Ph.D.
Intervenor/Advocate/Defendant
To:


Boston Juvenile Court
Clerk’s Office
24 New Chardon Street
Boston, MA 02114



                CERTIFICATE OF SERVICE
I, Phillip Ofume certify that a true copy of the DEFENDANTS' OGECHI EKE AND PHILLIP OFUME & ASSOCIATES' VERIFIED MOTION TO SUBMIT  WITNESS AND EXHIBIT was served up on all parties by  U.S. Postal Service first class mail or Hand Delivery on September 17, 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 Kathleen J. Moore
P. O. Box 558
Milton, MA 02186

Attorney Melaine Capwell
Department of Children and Families (DCF)
50B Park Street
Dorchester, MA 02122






 ____________________
      OGECHI EKE
Date:   September 17, 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), Nominee President, AAAA (Washington, DC, USA), LIMPT, INC. (EDUCATION & WORKFORCE PROJECT,  c/o Dr. Phillip Chukwuma Ofume – National Coordinator), etc.

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

1

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

                                    v.

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

                                                            1

 

OGECHI EKE  V. DCF DOCKET NO.  CP10B0179          

 

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.

                                                                                2

 

 

OGECHI EKE  V. DCF DOCKET NO.  CP10B0179          

 

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.

                                                                                                                3

 

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

                                                            4

 

OGECHI EKE  V. DCF DOCKET NO.  CP10B0179          

 

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

                                                            6

 

OGECHI EKE  V. DCF DOCKET NO.  CP10B0179          

 

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

                                                                        7

 

OGECHI EKE  V. DCF DOCKET NO.  CP10B0179          

 

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

                                                                        8

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.

                                                                                                9

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).

                                                                        10

 

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

                                                                        11

 

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

                                                                                                12

 

 

OGECHI EKE  V. DCF DOCKET NO.  CP10B0179          

 

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.

                                                                        13

 

 

OGECHI EKE  V. DCF DOCKET NO.  CP10B0179          

 

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

                                                                                                14

 

OGECHI EKE  V. DCF DOCKET NO.  CP10B0179          

 

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.

                                                          15

 

 

OGECHI EKE  V. DCF DOCKET NO.  CP10B0179          

 

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 –

                                                16

 

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

                                                                        17

 

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."

 

 

=================================================================================

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
1	K12 Math+:  Activity Book grade 1 semesters 1& 2		K12
2	K12 Math+:  Lesson Guide grade 1 semesters 1 & 2		K12
3	K12 Math+:  Activity Book grade 2 semesters 1 & 2		K12
4	K12 Math+:  Lesson Guide grade 2 semesters 1 & 2		K12
5	Language Arts 1:  Student Pages Semesters 1 & 2		K12
6	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
7	Phonics 1 Student Pages Semester 1 & 2	K12
8	Phonics 1 semester 1 & 2 Teacher Guide	K12
9	Phonics 2 Student Pages Semester 1 & 2	K12
10	Phonics 2 semester 1 & 2 Teacher Guide Phonics Works Video	K12
11	Primary Analogies Critical & Creative Thinking Book 1	Gae Brunner
12	Primary Analogies Critical & Creative Thinking Book 2	Jan Z. Olsen
13	Junior Great Books Volume 1: Grade 1 •          The Black Hen’s Egg •          The Mouse & the Wizard •        Imaginations	Pegasus Series
14	Junior Great Books Volume 2: Grade 1 •          Rumpelsiltskin •          Eeyore Has a Birthday and Two Great Presents •        “When I Grow Up”	K12
15	Junior Great Books Volume 3: Grade 1 •          The King of the Frogs •          Snow-White and the Seven Dwarfs •        “Mysterious Animals”	K12
16	Junior Great Books Volume 1: Grade 2 •          Chestnut Pudding •          The Pied Piper •        Fanciful Animals	K12
17	Junior Great Books Volume 2: Grade 2 •          The Mermaid Who Lost Her Comb •          Hansel & Gretel •        Special Places	K12
18	Junior Great Books Volume 3: Grade 2 •          Mother of the Waters •          Zlateh the Goat •        Secret Messages
19	Classics for Young Readers Volume 1	K12
20	Classics for Young Readers Volume 2	K12
21	Early Reading Comprehension in Varied Subject Matter Book A	Jane Ervin
22	Handwriting Without Tears 1st grade;	Jan Z. Olsen
23	Handwriting Without Tears 2nd Grade;	Jan Z. Olsen
24	Sylvester and the Magic Pebble	William Steig
25	Hooked on Phonics! 1st Grade	HOP Editors
26	Hooked on Phonics 2nd Grade	HOP Editors
27	Hooked on Phonics Master Reader	HOP Editors
28	Writing Homework	Scholastic Ref
29	Sciences 1 Student Pages  (Semesters 1 & 2)	K12
30	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
31	History 1 Student Pages (Semesters 1 & 2)	K12
32	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
33	Arts 1 Student Pages (Semesters 1 & 2)	K12
34	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
35	Beginning 2 Music Student Pages Volume 2  (Semesters 1 & 2)	K12
36	Let’s Sing Songbook Volume 2	K12
37	Music software	K12
38	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         K12

 

 

 

_________________________________________________________________________________

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 100th 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.