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

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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

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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.

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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.

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OGECHI EKE  V. DCF DOCKET NO.  CP10B0179          

 

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

 

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

 

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

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submitted and served upon Plaintiff or her Attorney.

 

 

 B.                        MEMORANDUM

 

                     THREE-PRONG QUESTION IN ISSUE/ANALYSIS    

 

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

                       

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

 

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

 

 

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OGECHI EKE  V. DCF DOCKET NO.  CP10B0179          

 

                                                BACKGROUND

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

 

                            Ms.  Ogechi Eke (Mother of Subject Child)

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

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

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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

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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

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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.

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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).

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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

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

 

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

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

                                ARGUMENT

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

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

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

 

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

 

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

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

 

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

 

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

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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.

MASS.SUPREME JUDICIAL COURT: PETITION FOR A WRIT OF MANDAMUS RELIEF

COMMONWEALTH OF MASSACHUSETTS

                                                        SUPREME JUDICIAL COURT

                                                                CIVIL ACTION SJC. NO.

____________________________________________________________________

PHILLIP OFUME

               Petitioner/Defendant (Pro se & Forma Pauperis)

                                   v.

THE CLERK/MAGISTRATE OF THE COURTS AND HOUSING                                                                               SPECIALISTS (Massachusetts Southeastern Housing Court,                                                                                        Brockton Session)                           

                 Respondents

________________________________________________________________________

LEAD CASE:

PHILLIP OFUME

               Appellant/Defendant (Pro se & Forma Pauperis)

                                   v.

RST INVESTMENT GROUP, INC. and                                                                                                                                     LANDLORD CONNECTION    

                            Appellees/Plaintiffs

 LOWER COURT CIVIL ACTION DOCKET  NO. 12H83SP00493BR

 LOWER COURT CIVIL ACTION DOCKET  NO. 11H83CV00790BR (Appellant's

                                                

OFUME V. CLERK/ MAGISTRATE

CounterClaim)

LOWER COURT CIVIL ACTION  DOCKET NO.  PLCV2011-01539-B  (Appellant's CounterClaim)

_____________________________________________________________________________

Verified Petition for A Writ of Mandamus Relief under the Massachusetts General Law chapter 249, § 5 and Fed. R. App. P. 21 on The Clerk of Courts and Magistrate and Housing Specialists all of the, Massachusetts Southeastern Housing Court, Brockton Session.

_____________________________________________________________________________

Procedural History/Structure/Action

Before: The Presiding Honourable Associate Justice Willbur P. Edwards

A.             Parties and Certificate of Interest and Interested Persons:

1.   The undersigned representative, Dr. Phillip C. Ofume issues this Certificate and  certifies that the following listed persons have an interest in the outcome of this case and their actions in this case are apportioned accordingly as stated below. These representations are made in order that the Judges of this Court may evaluate possible recusal and request the Respondents to transmit all records of proceedings below including tapes and transcripts October 2011 through June 2, 2012 to the Massachusetts  Appeals Court.

2.    PHILLIP OFUME (Appellant/Defendant  - Pro se & Forma Pauperis) is the Petitioner.

3.      Clerk of Courts and Magistrate and Housing Specialists are Respondents and officials of the Southeastern Housing Court, of the County of Plymouth Trial Courts.

4.     RST INVESTMENT GROUP, INC. & LANDLORD CONNECTION  are Appellees/Plaintiffs/Landlords   

 5.     The Honorable WILLBUR P. EDWARDS, is an Associate Judge of the Southeastern Housing Court,

                                                                                2

OFUME V. CLERK/ MAGISTRATE

Brockton Session  for the County of Plymouth of the States of Massachusetts  is the trial judge and the judge against whom the Petition for a Writ of Mandamus is directed.

6.        The Honorable WILLBUR P. EDWARDS, Associate Judge of the Southeastern Housing Court, Brockton Session  for the County of Plymouth of the States of Massachusetts  conducted preliminary and conclusion  proceedings in this case which led to realization of EXHIBIT A with 15 paragraphs. Between March 7, 2012 - June 29, 2012  Plaintiffs/Landlords/Appellees breached all the 15 paragraphs of EXHIBIT A. Petitioner's NOTICE OF APPEAL is about breach of EXHIBIT A and enable Appeals Court terminate EXHIBIT A because of random violations. Because  of loss of judicial trust and credibility in the Southeastern Housing Court, Brockton, MA this Court to order all proceedings sanctioned by EXHIBIT A  and Petitioner's and family's CounterClaims to continue in the Massachusetts Appeals Court and Suffolk County Superior Court, Boston Session because Petitioner and his family now reside in Suffolk  County and because their FORMA PAUPERIS conditions will impede their efforts to pursue these cases in distance court.

7.          With self claimed power, the Clerk of Courts and Magistrate and Housing Specialists saw non-fault NOTICE OF APPEAL of Petitioner, as usual they refused, neglected and failed to file the appeal for onward transmission to the MASSACHUSETTS APPEALS COURT pursuant to Massachusetts Rules of Appellate Procedure, Rules 3 & 4. October 2011 through June 6, 2012 the Respondents have been resistance and rejected several court brief which Petitioner desires to file with the Court below or petitioned.

B.         PURPOSE AND REMEDY OF A WRIT OF MANDAMUS IS REQUIRED IN THIS CASE.

8.      Petitioner, Dr. Phillip Chukwuma  Ofume pursuant to Fed. R. App. P. 21, applies to this Court for a Writ of Mandamus directing the Respondents to immediately transmit Petitioner's NOTICE OF APPEAL and RECORD OF PROCEEDINGS below to Mass Appeals Court.  Petitioner attempted to allow  further return of the package of the NOTICE OF APPEAL to the Respondents  to correct their  ignorance, but each time and continually they effectively refused to accept Petitioner's NOTICE OF APPEAL and that they would take no action to transmit the documents to the Mass Appeals Court.

9.          Based on expanded hate, racial discrimination, bribery and corruption in the Southeastern Housing Court Brockton, MA it is clear and highly indisputable in this Supreme Judicial Court that in the Southeastern Housing Court, Brockton, MA where the Respondent, Judges and Staff are in support of the rich plaintiffs/landlords/appellees are closely united against the Petitioner and his family  and court where several shameful extra-judicial processes and proceedings have taken place will not allow appeal to move forward to enable court above use just rule to realize justice in the interest of the petitioner

                                                                                                3

OFUME V. CLERK/ MAGISTRATE

and public.

 10.       EXHIBIT A is in 15 paragraphs and Appellees/Landlords/Plaintiffs have breached all the paragraphs of EXHIBIT A therefore the purpose of EXHIBIT A is defeated and must be terminated and fully annulled and the damage caused by these violation is irreparable to the extent that Petitioner and his family now live in the Church and children may loss their school jurisdiction and parents and their children have suffered unspeakable pains and suffering due to failure of justice below occasioned by the action of the respondents/landlords. 

10.       Indisputably, a person is entitled to a writ of mandamus when he can show he lacks alternative means to obtain relief and that he has a clear and indisputable right to the writ. See In Re American Airlines, Inc., 972 F.2d 605, cert. denied sub. nom., Northwest Airlines Inc. v. American Airlines, 113 S.Ct. 1262 (1993). In this case, presiding Judge is very smart/talented but the Respondents placed a high wall between parties and the Judge and impede the work of the Judge. Please see also Weber v. U.S. Dist Court for C.D. of Calif., 9 F.3d 76, 78 (9th Cir. 1993) (in this case Mandamus is appropriate where court lacked authority under process distraction, censorship and obstruction and fear to reprimand unruling staffs).

C.          STATEMENT OF MAJOR FACT

 Nature of Process and Proceeding Petitioned:

11.     LOWER COURT CIVIL ACTION DOCKET  NO. 12H83SP00493BR . Paragraphs 2 to 38 of the Petitioner's NOTICE OF APPEAL show that the Appellees/landlords arm twisted Petitioner and his family and dumped them in inhabitable apartment (506Warren Ave #2 Brockton, MA 02301) different from the apartment (96 Walnut Street, Brockton, MA 02301) which they negotiated and paid for and date (8/16/2011) set for move in. When the conditions (100% mold infected, no heat, damaged doors, windows, sockets, thermostat, etc), insects and bugs invaded, etc.

12.     Petitioner and his family wrote several letters to the landlords to request them to fix the multiple defects in the imposed or force to occupy apartment but all the letters were ignored. Petitioner filed Complaint with the BOARD OF HEALTH.

 13.  Without rent owing, in retaliation, effective November 2011 the landlords/Appellees filed two politically generated Court Eviction Complaints and falsely claiming fictitious rents as plot to render Petitioner and his family the 9th homeless since August 19, 2009.

14.     The two Court Eviction Complaints were dismissed because the payment receipts of the Petitioners/Tenant /Defendant and his family show in his Opposition to the Landlords' Eviction

                                                            4

OFUME V. CLERK/ MAGISTRATE

Complaints  that they are  not owing the Plaintiffs/Landlords/ Respondents and the Landlords were not reprimanded and sanctioned by the Judge for lying  reliant up on Petitioner's Motion.

15.      After the dismissal of the  two Court Eviction Complaints of the Landlords, the LOWER COURT CIVIL ACTION DOCKET  NO. 11H83CV00790BR ; Petitioner and his family filed counter-claim ( LOWER COURT CIVIL ACTION DOCKET  NO. 11H83CV00790BR ); and because the housing court lacks jurisdiction to entertain the volume of the intended claim, Petitioner/Appellant and his family filed  Supplemental CounterClaim ( LOWER COURT CIVIL ACTION  DOCKET NO.  PLCV2011-01539-B  -The Plymouth County Superior Department).

16.  The Counter-Claims mentioned above  forced the Plaintiffs/Landlords/Respondents to call for mediation and thereafter EXHIBIT A which is SUMMARY PROCESS FOR JUDGMENT AGREEMENT with 15 paragraphs was signed and issued but March 7, 2012 through present time , the Plaintiffs/Landlords/Respondents  violated all the 15 paragraphs and Petitioners/Tenant /Defendant filed Complaints based on each breach and the Clerk/Magistrate made serial appeal impossible by refusing to prepare and issue written decision/order based on the oral Orders of the Judge to enable Petitioner file appeal. 

17.   Petitioner and his household suffered extensively as result of Plaintiffs/Landlords/ Respondents  flagrant violation of EXHIBIT A and this Petition is made because after Petitioner and his family vacated the disputed apartment based on the new date issued by the Plymouth County Sheriff, Plaintiffs/Landlords /Respondents carried out erratic revolutionary action in serious violation of EXHIBIT A particularly paragraph 11 when the landlords/appellees/plaintiffs forged several documentary allegations and break into Petitioners/Tenant /Defendant's and his family's APPLICATION FOR EMERGENCY HOUSING ASSISTANCE (EA) FAIR HEARING and they were allowed to falsely testify for several minutes against the Petitioner and his family  before THE MASSACHUSETTS DEPARMENT OF HOUSING AND COMMUNITY DEVELOPMENT (DHCD).

18.    EA was filed because in breach of para 11 of EXHIBIT A the Plaintiffs have issued and posted bad references on the Massachusetts landlords Association forum and no landlord agreed to rent apartment to Petitioners/Tenant /Defendant and his family. See pages 2 to 38 of the NOTICE OF APPEAL (attached) which as usual the Clerk of Courts and Magistrate and Housing Specialists refused to accept and file and prepare record of proceedings and transmit it to the Massachusetts Appeals Court to the other extent that they refused to present the NOTICE OF APPEAL to the Presiding Hon. Justice and Court Administrator.

19.    Opposition of the Petitioner  relating to the cruelty and mistreatment of the Petitioner and his

                                                                                5

OFUME V. CLERK/ MAGISTRATE

family was made  pursuant to G.L. CHAPTER 23B, SECTION 30; M.G.L. CHAPTER 186 SEC. 18; M.G.L. CHAPTER 111; COMMONWEALTH OF MASSACHUSETTS SANITARY, CODE CHAPTER 11; MINIMUM STANDARDS OF FITNESS FOR HUMAN HABITATION; 105 CMR 410.000; M.G.L. CHAPTER 239, SEC. 8A;  5th and 14^th Amendments of the Constitution of the United States and also vested in Bill of Rights; Tenancy with a Lease; on October 27, 2011 no rent was owing when Landlords rushed to Court to start filing Court Eviction NOTICE TO QUIT and other preliminary steps under TENANCY WITH A LEASE were not followed to present good case; after the landlords received first/last months, August 2011, September 2011, and October 2011 rents,  they rushed to Court to file NOTICE OF EVICTION without prior Notice to Quit under this type of Lease. EXHIBIT A  March 7, 2012 Summary Judgment Agreement totally violated; failure or dismissal  of the two frivolous and falsified eviction Complaints filed by the appellees and docketed as CIVIL ACTION DOCKET  NO. 12H83SP00493BR must be referenced. Petitioner/Appellant and his family respected EXHIBIT A and vacated disputed apartment and the Plymouth County Sheriff extended the date for the Appellant and his family to vacate the apartment to June 12, 2012.

D.                    CONCLUSION/RELIEF

 Based upon the foregoing, Petitioner, Dr. Phillip C. Ofume respectfully requests this Court to issue a Writ of Mandamus alone or in the alternative  to direct the Honorable Judge Willbur P. Edwards to issue Order on the Respondent, Clerk/Magistrate and Housing Specialists and other staff to assemble all records of proceedings including Petitioner's NOTICE OF APPEAL and tapes/transcripts and forward them to the Massachusetts Appeals Court.

Respectfully submitted,

_______________________

 Phillip C. Ofume, Ph.D.

P.  O.   Box 2416

Lynn, MA 01903

Tel. (781) 479-9027

E-mail: ofume.phillip@gmail.com

DATED: July 4, 2012.

                                                                                6

OFUME V. CLERK/MAGISTRATE ET AL

CERTIFICATE OF SERVICE

I, Dr. Phillip C. Ofume, one of the Appellants/Plaintiffs in this case  PETITION FOR A WRIT  OF MANDAMUS hereby certify that I have served  the foregoing, Notice of Appeal  upon all parties and their agents, representatives and attorneys, by electronic mail, hand delivery and first class U. S. Postal Service at:

C/o Mr. Troy Lewis

RST Investment Group & Landlord Connection

561 Main Street

Brockton, MA 02301

Clerk/Magistrate and Housing Specialist

SOUTHEASTERN HOUSING COURT

215 Main Street Suite  169

Brockton, MA 02301

_____________________

 Phillip C. Ofume, Ph.D.  

P.  O. Box 2416

Lynn, MA 01903

Tel.  781-479-9027

E-mail.:  limptintinc@gmail.com

Date: 7/9/2012

  

                                                                          7

THE ATTORNEY-GENERAL OF MASS: PROTECTING WHITE FRAUDS AND RETALIATION AGAINST BLACK COMPLAINANT

The Fraud reported against white company, located at: http://universal-fashion-art-music.blogspot.com/2012/02/carrabbas-italian-grillosi-restaurant.html and when this Black employee reported further fraud which was found in the office of the Department of Unemployment Assistance (DUA),  the unemployment assistance paid to this Black claimant was stopped on July 17, 2012. Swiftly, the Black employee or claimant file appeal and demanded urgent hearing but nothing has been done as to effort to mark up the appeal  for hearing. Now the Black claimant, who care for his family (7 children and 2 parents) is now struggling under $0.00/month. Representative for the Claimant, Dr. Phillip Chukwuma Ofume has telephoned and wrote to the DUA without taken in the circumstance to set down this appeal for hearing.

++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++


KEYNES O. OFUME V. DEPARTMENT OF UNEMPLOYMENT ASSISTANCE (DUA)
                                                                                                   Date:  07/16/2012
                                      Re.   Replacement Check Request

http://universal-fashion-art-music.blogspot.com/2012/02/carrabbas-italian-grillosi-restaurant.html

The Honourable Secretary of Justice and Attorney-General of the Commonwealth of Massachusetts has issued Order/Decision requesting Claimant to proceed to Court to Claim amount of salaries and other wages embezzled and fraudulently converted by the Employer, Carrabbass Italian Grill Restaurant et als. See Ofumes v.  Tim Laporte et als Docket No.  SUCV2012-02372-A and see http://universal-fashion-art-music.blogspot.com/2012/02/carrabbas-italian-grillosi-restaurant.html

 A.                       PAYMENT HISTORY

1.    II/19/2011 - 5/05/2012 ......................................................................$994.00

2.    12/10/2011 - 02/11/2012.....................................................................$994.00

3.      03/03/2012 - 03/10/2012...................................................................$284.00

4.     03/31/2012  - 04/07/2012....................................................................$284.00

5.     05/12/2012 .......................................................................................$284.00

6.     06/09/2012 -  06/16/2012..................................................................$242.00

7.     O6/23/2012 - 06/26/2012................................................................$121.00

B.                                         DEFICIT PAYMENT HISTORY
DUA  has been very secretive in disclosing the actual amount assessed based on claimant's condition. History of payment above shows that DUA has unknown power to alter payment discretionarily including dropping payment to add cloud to payment due to claimant. Assessment and evaluation sheet informed claimant that he will be paid $284.00 weekly. Reliant upon this data we will compute amount paid and amount unpaid running November 2011 through para 7 above.

November 11, 2011 through 06/26/2012:   32 weeks and 6 days  = $9372.00
Amount paid:   $2919.00
Unpaid Amount:  $6,453.00

How much is DUA deducting for federal and state taxes?

Respectfully submitted:


________________________
Keynes O. Ofume - Claimant

Prepared by:  LIMPT, INC. (EDUCATION & WORKFORCE PROJECT)

______________________
  Phillip C.  Ofume, Ph.D.   - National Coordinator

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


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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.