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)





 
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      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.