BOSTON HOUSING COURT: OFUME V. REV. & MRS. HECTOR - Civil Action Docket No. 13-CV-264

               COMMONWEALTH OF MASSACHUSETTS

                         BOSTON DISTRICT TRIAL COURT

       HOUSING COURT DEPARTMENT                CITY OF BOSTON DIVISION

Suffolk, ss.                                     Civil Action Docket No. 13-CV-264

                                                                                

___________________________________________________________________________________

                                    Phillip Ofume and Ofume family

                                                       Plaintiff

                                                                v.

                                 

                                     Cynthia Hector and Allan Hector

                                                        Defendants

                                    

                                          and

                                              National Grid (A/C # 52220-18340)

                                                       Defendant

                               NSTAR, Residential Electric Business (A/C #80-2221-603-1058)

                                       Defendant

                                Boston Water Commission

                                        Defendant

________________________________________________________________________________

          SUMMARY PROCESS AND AMENDED COMPLAINT

A.                      STATEMENT OF FACT

1.    Plaintiff, Dr. Phillip Ofume and his family reside in disputed apartment located at 41 Gallivan Boulevard #1 Dorchester, Massachusetts 02124. Defendants are residents of Massachusetts and the specific service civic addresses of the defendants are indicated below per defendant.

2.  In the United States Plaintiff, Dr. Phillip C. Ofume is campaigning  for the Presidents of Nigeria 2015 and American Association for Affirmative Action (AAAA) and Nigerian/American politicians oppose Dr. Ofume’s matchless, economic, social and civil programs which nigerians and americans prefer. See http://www.blogger.com/profile/08744093752636542613; http://limptinc.blogspot.com/2013/02/ international-movement-for-new-federal.html  ; http://limptinc.blogspot.com/2012/11/phillip-c-ofume-v-aaaa-civil-docket-no_22.html

3.    On before June 12, 2012 the Mass Department Housing and Community Development (DHCD) approved Plaintiff and his family for Temporary Family Shelter and they were advised to move their property of its Brockton Area Office at 75 Commercial Road Brockton, MA. On June 12, 2012 after Plaintiff and his family moved their properties to the DHCD Brockton Area Office at 75 Commercial Road Brockton, MA. 

4.   Because of this bid these political opponents have deeply adopted economic embargo/sanction, poor housing, homelessness, ex-communication and related cruel tool to disrupt his family and campaign to the extent that the present landlord is trying to add another homelessness to  render Plaintiff and his family 12^th homelessness since August 2009. On June 12, 2012 at about 4.00 pm he DHCD told Plaintiff and his family that their application for temporary family shelter has been denied and  Plaintiff and his family and their properties were abandoned in the office premises of the DHCD.

5.    On June 13, 2012 The Fountain of Grace Church found 41 Gallivan Boulevard #1 Dorchester, Massachusetts 02124 which is two small bedroom apartment which failed CMR fitness rule and as victims which have choice was forced to live in the broken apartment at the rate of $400.00 per month. Plaintiff and his family and the landlords entered into yearly lease agreement but disputed in part because the initial lease was $400.00 and when the landlords suspected that Plaintiff and his family have rich supporter (The Church of Jesus Christ of Latter-day Saints) to contribute some amount to pay their rent the Landlords raised the agreed ($400.00) to $750.00 per month (EXHIBITS A & A.1.).

6.    The bathroom was permanently blocked and for several months Plaintiff and his family spent over 15minutes digging out the water into the toilet before another members of the family will have space to bath and remove the water to enable other members of the family to get a place to bath.

7.      Severally, Plaintiff requested the defendants to remove fix and reconnect the hot water, mold, lead, fix the door, stove, heating system, fix window and fix and replace broken glass of back window and he did nothing. Several oral and written notices were sent to the landlords and they remain unheeded.

8.  The defendants viewed the conditions of the Plaintiff and his family as gold pot  and they commanded them to pay advance rent and threaten to use police to evict them because Mrs. Hector works with Boston Police Department.  In July 2012 they paid the defendants advance rent totally $1,928.09 (EXHIBIT B) to cover some utilities which the defendants use and the rents were advanced for the months of July 2012, August 2012 and September 2012.

9.   In After Plaintiff and his family  paid this amount with the help of their church, the defendants disconnected hot water, discounted bath: all the hot water inside and outside the bathroom in addition to several other defects mentioned above including unserviceable stove, mold, apartment without heat and without serviceable heating system, etc.

10.     In September 2012, after the defendants spent the advance payment which Plaintiff  paid to them they said some people told the  Plaintiff and his family have been evicted for several times and that before they can continue to live in their apartment Plaintiff and his family must pay one year advance rent. All the defects mentioned above have not been fixed.

11.     In July, August, September, October, November, December 2012, January, February, March 2013 Plaintiff reported to the Board of Health (Inspectional Services, Mayor’s Office, 2.1.1. hotline, Federal Environmental Protection Agency,  and nothing was done to fix all the defects mentioned to the limited extent that on December 16, 2012 (see attachment) after a formal Complaint was filed with the Honourable Commissioner of Energy, Electric Company came and the landlords allowed them to investigate the heat system and after this investigation the staff of the electric company told Plaintiff and his family that the landlord, Rev & Mrs. Hector are responsible for the unserviceable, hot water,  heat system and the electric company said that they have advised the landlords to fix the heat system. Several oral and written notices were sent to the landlords and they remain unheeded.

12.    In July 2012 following the visits of some electricity contracting firms and water commission to the landlords, and activities of construction workers inside and outside the basement, the electric company started sending to the Plaintiff and his family the high electric bills (over $400.00 per month) which are suspected to be the bills of the electric consumption of the tenants of the entire building comprising of Nos. 41 & 43 Gallivan Boulevard Dorchester, MA 02124. How is this bill consumed whereas in Plaintiff’s apartment, stove, hot water and heat are not working. Criminally, the landlord used nails, wood and other materials to block the doors to the utilities room and basement to prevent Plaintiff and his family from viewing the criminal and secret activities going on in the utilities room and basement. A staff of the City of Boston Inspectional Services Department Housing Inspection Division 1010 Massachusetts Avenue Boston MA saw this enforced blockade on the utilities room and basement and he said,  “this is unlawful and can not be done in the Commonwealth of Massachusetts.”

13.    In July 2012 the entire hot water system to Plaintiff’s apartment was disconnected. Plaintiff and his family filed oral and written complaints to the Commissioner of Energy, water commission, electric company, gas or national grid, etc but no hearing have been scheduled and Plaintiff continued to send reminders to the Commissioner of Energy, water commission, electric company, gas or national grid, etc

14.     June 2012 – December 2012 the bath was permanently blocked and we packed water after each bath into the toilet before another members of the family to use the bathroom/toilet and this ordeal sometimes caused Plaintiff and his family couple of tardiness to appointment and school. Several oral and written notices were sent to the landlords and remain unheeded.

15.    In September 2012 as all the defects mentioned above remain unattended and the Plaintiff and his family continued to suffer these ordeals, heartlessly, Rev & Mrs. Hector told Plaintiff  to pay one year rent before they can fix the majority of the defects mentioned in paragraph 1-7 above or they will use Police to remove their property into the street. Because this 12^th political homelessness since 2009 and the children are in their new schools trying to adjust after several relocations, Plaintiff and his family were forced to make forced decision to have roof over their head.

16.     Under this fear, Plaintiff and his family pleaded to pay advance of September 2012, October 2012, November 2012, December 2012, January 2013, February 2013, March 2013, and April 2013. After this payment of the sum of $3,825.32 in one single bank check, EXHIBIT C they refused to reconnect the hot water and we boiled water on the stove to enable my children bath and go to school and other places.

17.   Since July 2012, we have been using bitter cold water to wash dishes and do other household works.

18.   They worked on the gas oven in December 2012.

19.   They disconnected the cold and hot water in the shower and disconnected the hot water part of all taps in Plaintiff’s and family’s  apartment and there is no hot water in the entire apartment and Plaintiff and his family  have used cold water to do all works in the apartment and harmed by bitter cold water related pains.

20.     All the monies mentioned in paragraphs 1-19 above were not used to put the apartment into livable or habitable conditions. Children and parents get headache from mold and other bad living condition such as cold water, lack of heat, etc.

21.     After December 16, 2012 the landlords turn on the heat few times they observe that there are visitors in the apartment of the Plaintiff in order to justify these cruelties. Visitors to the apartment of the Plaintiff’s apartment are rare because for security reason and the major business of the Plaintiff is conducted electronically and it could take two weeks to see visitors in Plaintiff’s apartment. To prevent the Plaintiff and his family access to the utility room and basement the landlords used highly fortified objects to block the door to the utility room and basement.

B.        CLAIM AGAINST LANDLORDS, REV. & MRS. HECTOR CRUELTIES

                                                CLAIM #1

             Pursuant to M.G.L. c.186 sections 5, 14, 15(E), 19 the Tenants /Plaintiff’s

         and his family’s rights were cruelly violated and because of these violations

         Plaintiff and his family are qualified to recover all

         the rents paid to the landlords and additional punitive and fault base

         awards.

21.  Under homelessness and sleeping in the church worship building, on June 13, 2012 Plaintiff and his family seeking for any roof over their heads moved in 41 Gallivan Boulevard #1 Dorchester, Massachusetts 02124 with several defects mentioned above and without landlord and tenant pre-move in inspection. Several times, Plaintiff requested for inspection in the apartment because of the fraudulent claims of certain landlords against their tenants (Ofume v. RST Investment Group, etc – Mass Supreme Judicial Court (2012), Ofume v. Nancy Vigorito, MBHP, et als – The Supreme Court of the United State

22.  The landlords did not respect any tenancy rules. Plaintiff and his family have been intimidated by these landlords who are aware that Plaintiff and his family are vulnerable and have no place to leave but have no money to pay rent. Plaintiff has never owned the Landlords and they have paying landlords in advance to enable them remain under the roof. Plaintiff and his family have complied in all aspects with the

terms of the tenancy.

                                 CLAIM #2

                 Pursuant to M.G. L. c. 239 c. section 2A;

c. 186 Section 18 the landlords are wrongfully attempting

                 in retaliation to Plaintiff and his family’s complaints.

23.   The landlords tried to trigger eviction each time Plaintiff request that defects in his apartment should be fixed and they retaliate against Plaintiff and his family by requesting them to pay one year rent in advance and we they step up oral demand on Plaintiff and continued to bang on the Plaintiff’s door to demand immediate pay or they will call Boston Police to forcibly evict them from the apartment.

24.   The Landlords have used other retaliatory measures such requesting the Plaintiff and his family to send utility bill and house rent in a single check and when Plaintiff request them to give for such consolidated check or payment, they become infuriated and threatened Plaintiff with eviction. When Plaintiff contacted the utility companies to know whether the Landlords paid the utility their utility, national grid and nstar told Plaintiff and his family that the landlords did not pay such bills.

25.  Under this lease agreement the landlords pay for water, garbage, removal of snow, sanitation, all repairs, etc. Because the Plaintiff and his family and their church, The Church of Jesus Christ of Latter-day Saints were able to several advance rents, the harassed and bullied the Plaintiff and his family to take over water bill for the entire unmetered building and Plaintiff was forced to $300.00 and other water bills without payment receipts to the ugly extent that the landlords refused to issue payment receipts to the Plaintiff  for the payments referred to in paragraphs 8, 16, etc above. Plaintiff and his family did not fear because the landlord, Mr. Allan Hector told Plaintiff and his family that he is ordained reverend of the Fountain of Grace Church but Plaintiff and his family cast doubts  in July 2012 when the landlords started their satanic conducts thus, shutdown hot water in a family with six children and two adult parents, blocked the door to the utility room and basement and converted  their hot water, heat, etc into personal use and allow Plaintiff and his family to pay the bills, refused to unblock the sink of the bathroom and allow the Plaintiff and his family to do hard labor of removing dirty water after bath from the bath to the toilet to enable next family members take turn to bath,  refused to fix stove and allow Plaintiff to travel to distance to cook some meals, etc.etc. etc.  (EXHIBITS B & C)

26.    This defense entitles Plaintiff and his family to recovery of all rents paid and possession and continuation of payment of rent if all the defects cited by the Boston Inspectional Services are fixed to the extent even if the claim is presented as an originating claim or  counterclaim, it also entitles Plaintiff and his family to one to three times the rent or their actual damages whichever is greater and deems appropriate.

                             CLAIM #3

Pursuant to M.G.L. c. 239 Section 8A; c. 93A and

                     the implied warranty of habitability the landlord

                                     failed to make the apartment habitable and

                      permitted bad conditions to continue to exist.

27.    Plaintiff and his family have a claim because of past and present problems in or around the disputed apartment that the landlords and other defendants, NSTAR, National Grid and Boston Water Commission knew or ought to have known about, including but not limited to the following:

27.a.  Before moving in to the apartment, the landlords agreed to work on the blocked plumbing system which blocked flow of water from the bath to the drainage system, remove the mold, clean up the lead because of the under 6-year old child, fix the doors and windows, connect hot water, unblock the door to the utility room and basement, etc.

27.b.  The landlord refused to make the Plaintiff habitable and the worst retaliation is the disconnection of the hot water punitively to make habitation more and more toxic because several months when the stove was not working Plaintiff and his family were using small camping gas operated to boil hot water to enable their children and parents to bath and set out to school. Defendants, NSTAR, National Grid and Boston Water Commission knew about the hardship Plaintiff and his family were facing and failed and neglected to advise the landlord.

27.c.  From time to time, several children and adults were sick because of use of icy cold water, molded apartment, lack of heat, etc.

27.b.   During initial payment for move in, the landlords told the Plaintiff and his family that they will put door to block the people in the dining room and living room from seeing someone in the bedroom. They also promised to put keys and locks on the bedroom to adjacent door which Washroom because each time visitors want to open the washroom door they open bedroom which has no locks or key. The same breach of privacy occur on the second bedroom which is also adjacent to the washroom also without locks or keys.

28.  Plaintiff’s and his family’s claim entitles me to damages for the reduced value of my home, calculated as the difference between:  (a) the full market rental value of my apartment in good condition, and (b) the reduced value of my apartment in bad condition.  I am also entitled to damages for any other losses, injuries, or expenses resulting from bad conditions.

C.              CLAIM AGAINST LANDLORDS, NATIONAL GRID, NSTAR AND BOSTON

                 WATER COMMISSION

                                   CLAIM #4

29.   The landlords, national grid, NSTAR, and Boston Water Commission have grandiosely  interfered with the quiet enjoyment of Plaintiff’s and his family’s apartment.

M.G.L. 239 section 8A; c. 186 section 14 and c.93A

 30.  The landlords, national grid, NSTAR, and Boston Water Commission did the following:

30.a.  In July 2012 – present, Landlords and the Boston Water Commission conspired together to disconnect 100% of all the hot water taps and allowed Plaintiff and his family to suffer for over 9 months without hot water and lived in pains by using icy and bitter cold water without humane sense of direction that this action is in breach of the United States Constitution and Bill of Rights. Confidentially, the landlords told Plaintiff that soon as the Plaintiff and his family moved into the disputed apartment Boston Water Commission over billed the water consumption by 1000% above the previous bill to cause brawl or conflict between blacks and because the Plaintiff, Dr. Phillip C. Ofume is well known international expert in Anti-Racism, the landlord gave Dr. Ofume several pages of the commission’s falsified and racist bill and after research and investigation thus, swiftly Plaintiff filed complaint against Boston Water Commission and others with the Hon. Commission of Energy.

30.b. National grid, NSTAR,  and landlords operated under secrecy to the extent of blatantly refusing to response to question as to reason why they have drawn the winter fuel account of the Plaintiff when hot water has not been working since July 2012.

30.c.   National grid, NSTAR,  and landlords failed to render any account on reason why they combined the bills of the entire occupants at 41 & 43 Gallivan Boulevard and billed Plaintiff and his family over $400.00/mo as if Plaintiff and his family are operating a manufacturing company when one two bulbs and one refrigerator are working with electric supply.

D.                          CONCLUSION/RELIEF

WHEREFORE, Plaintiff and his family pray this Honorable Court to grant the following relief:

31.   On all the foregoing claims, award Plaintiff and his family double of the rent or the foregoing claim entitles Plaintiff and his family to one to three times the rent or their actual damages whichever is greater and deems appropriate by this Court and other payment in time and manner following:

31.a.  Advanced Check #1   (EXHIBIT B)

This Check was advanced to the Landlords under the poor conditions in the apartment:

June 13, 2012 ..............................................................$375.000 but $400.00 was received

July 1, 2012..............................................................................$750.00

August 1, 2012.........................................................................$750.00

Gas...........................................................................................$53.09 Gas Company refused to send full/complete bill.

TOTAL ADVANCE PAYMENT PAID TO THE : .............................................................$1, 928.09

31.b.   Advanced Check #2  (EXHIBIT C)

 September 1, 2012..........................................................................$750.00

October1, 2012.... ..........................................................................$750.00

November 1, 2012.........................................................................$750.00

Gas........................................................$85.32  Gas company refused to send full/complete bill

Electricity………………………………………………………………………………………$95.00(approx.)

TOTAL DUE: ......................................................................$2,325.32

Additional $1500.00 was added to $2,325.32  to cover part of our future rents which November 2012, December 2012, January 2013, February 2013, March 2013 and April 2013 and round up check amount consideration of the sum of $3,825.32 was received by the Landlords in October 2012. This payment was made to the Landlords and they spent over one month oversea and came without fixing majority of the defects mentioned above and non of the major life threatening defects such mold, hot water, heat, doors, etc were not fixed. In October 2012 the Landlords had seven months advance rent on hand and a person that claims Reverend of Christian church could be heartless and dangerous to leave innocent children, men and women to suffer under the terrible conditions stated above.

32.    On all claims aforementioned, award Plaintiff money damages, costs and such other relief this Honourable Court deems appropriate and stop the landlords from retaliation by use of police to evict plaintiff and his family asserting contra attack in nature unwarranted possession of the disputed apartment.

33.    Order the landlord to make all repairs to the defective conditions in family’s  apartment.

34.   Find that Plaintiff and his family not at fault by being forced by the threat of the Landlords to pay several months advance rent because of fear of homelessness and school and safety of the children and family in general. 

35.  Refund to the Plaintiff and his family all the rent paid to the landlords: June 2012 through April 2013.

36.    Because of the jurisdictional limitation of this Court to award monetary damage, Plaintiff and his family request partial general damage of $7,200.00 for the hardship Plaintiff and his family suffered and allow the Plaintiff and his family to proceed to the Superior Court to file additional Complaint.

37.    Other relief this court deems fit.

E.                     REQUEST FOR A JURY TRIAL

38.    Pursuant to Part 1, Article XV of the Declaration of Rights and M. G.L. 218 section 19B, Plaintiff and his family claim their rights to a jury trial.

Respectfully submitted,

__________________

 Phillip C. Ofume, Ph.D.   

       Plaintiff

P. O. Box 2416

Lynn, MA 01903

Tel. 617-606-1753, 781-479-9027

limptintinc@gmail.com,ofume.phillip@gmail.com,

globalaids_hivcureinteracion@yahoo.co.uk

             CERTIFICATE OF SERVICE

I, Dr. Phillip C. Ofume  hereby certify that on April 15, 2013, I delivered in hand a copy of this original Complaint and Amended Complaint to the defendants at:      

Rev. & Mrs. Cynthia & Allan Hector

41/43 Gallivan Boulevard #2 (2^nd floor)

Dorchester, MA  02124

Executive Director

National Grid (Legal Dept.)

220 Victory Road Dorchester, MA 02122 (617) 822-5400

Acting Executive Director – Mr. Henry F. Vitale

Boston Water Commission-BWSC (Legal Dept.)

 980 Harrison Ave.

Boston, MA 02119

Executive Director

NSTAR (Legal Dept)
One NSTAR Way
Westwood, MA 020

__________________

Dr.  Phillip C. Ofume

           

What APC Must do: By Jibrin Yunusa Lanval

What APC Must do: By Jibrin Yunusa Lanval
 

1. The APC must translate its manifesto as many
languages as possible.

2. The manifesto must be distributed across the entire
country, not just within the zones that are APC
strongholds, namely the North and Southwest.
 

3. The APC must immediately begin a registration
process across the entire country.
 

 4. The manifesto must ensure transparency in
membership subscription in the political process of
Nigeria.
 

 5. The APC should reach out to the public to register as
recorded members of the party.

6. It must ensure this registration is electronically
recorded and publicized to encourage more Nigerians
to join the cause.

7. It must generate revenue by charging a small fee for
membership forms and demanding a donation from all
its members. This way members will feel a part of the
process and automatically expect nothing but
transparency and inclusiveness in deciding the
direction of the party.

8. The APC must ensure the process of internal
democracy prevails, specifically enabling party
members to vote and not just the leaders of the party
or its delegates.

9. The APC must promise to do away with the habit of
imposing candidates against the will of its party
members and the Nigerian people.

10. It must respect the electoral process of the party
and candidates must accept losses, by promising to
unite behind the victorious candidate against the
opposition.

11. It must encourage its prospective candidates to
campaign on ideas and not violence or money politics.

12. The APC should continue to raise money by
engaging its members in the development of the party.

13. The APC must create a culture where party
members consistently donate to its treasury, no matter
how small the sum is.

14. The APC should organize events and initiative to
celebrate and appreciate the support of its dedicated
members.

15. The party must work to involve the over 70% of
Nigerians under the age of 40. And a first step is to
appoint a National Youth Leader that was not alive
during the Nigerian civil war, and have a strong social
media presence.

From: Jibrin Yunusa Lanval
(allprogressivec@gmail.com)
+2348034415788
Do you have any suggestion to add? Feel free APC is for
all of us —

— with Jibrin Yunusa Lanval.

 

Thank you,  Comrade Jibrin Yunusa Lanval. We in APC are blessed with talented strength and workforce.  APC is mass people’s global movement and because of this outstanding foundation  money will not be its problem. APC must not charge membership fees. As mass people’s party or movement, it can asked for goodwill donation effective penny donation which symbolic to purpose and it has given  our fundraising target multi-million dollars within set short period.  Now our Gallup pool show that over 121 million Nigerians will hit the road into APC.  2008 and 2012 organizing for America and change movement ideology gave Obama the edge under penny donation strategy.  When we call for penny donation we are targeting per person free will to give N1 which is out-coming  for N1 x 121 = N121million per hit because both poor and rich can give one naira under swift turnout.

Only new movement like APC can make it fast because the foundation membership of APC are good and are likable Nigerians and inside and outside Nigeria members and non-members are ready en-masse to support APC.

Posted by:

Dr. Phillip C. Ofume &  Associates and International Endowment for Democracy (EID)

http://limptinc.blogspot.com/2013/02/international-movement-for-new-federal.html  ; http://limptinc.blogspot.com/2012/11/phillip-c-ofume-v-aaaa-civil-docket-no_22.html ; http://www.blogger.com/profile/08744093752636542613HYPERLINK "http://www.blogger.com/profile/08744093752636542613;https://groups.google.com/forum/?fromgroups=";https://groups.google.com/forum/?fromgroups=#!topic/soc.org.nonprofit/z5q7G-Lt76c

International Movement For New Federal Union Of Nigeria (IMUN), INC.(1)

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International Movement For New Federal Union Of Nigeria (IMUN), INC.(1)

                                                                                                                         

                                                   Ofume & woman (1)

                                                           Presents… 

                            INTERNATIONAL MOVEMENT FOR NEW FEDERAL UNION OF       

                                                               NIGERIA (IMUN), INC.

                                   Articles of Organization     

            (Commonwealth of Massachusetts General Laws, Chapter 180)

   ARTICLE II (SUPPLEMENTAL STATEMENT - PURPOSE OF IMUN)\

1.   CAMPAIGN FOR GOOD GOVERNMENT IN NIGERIA UNDER NEW FEDERAL UNION WHICH WILL EMERGE DEMOCRATICALLY UNDER FIVE TIER SYSTEM OF GOVERNMENT TO REPLACE FORMER THREE TIER SYSTEM OF GOVERNMENT . TO ACHIEVE THIS OBJECT IMUN WILL ENGAGE IN HUMANITARIAN ACTIVITIES FROM GRASSROOT TO UPPER ROOT IN NATURE OF CHARITABLE ; EDUCATIONAL; SOCIAL ENRICHMENT PROJECT; ECONOMIC DEVELOPMENT; POOR PEOPLE AND MIDDLE CLASS EMPOWERMENT; COLLABORATION WITH PROFIT  AND NON-PROFIT ORGANIZATION ON VOLUNTEER BASIS; AND FUNDRAISING PROGRAMS. MEMBERS OF IMUN WILL RUN AND BE OPENED TO ACCEPT ELECTIVE AND APPPOINTMENT OFFICES INSIDE AND OUTSIDE NIGERIA.

2.  CAMPAIGN FOR GOOD GOVERNMENT IN NIGERIA UNDER NEW FEDERAL UNION. IMUN WILL HAVE OFFICES IN ALL SOVEREIGN COUNTRIES AND ALSO THOSE FUTURE COUNTRIES AGITATING FOR SELF-DETERMINATION. PURPOSE OF THIS GLOBAL CONNECTION IS TO COORDINATE ITS CAMPAIGN FOR AND REALIZATION OF GOOD GOVERNMENT IN NIGERIA. IMUN WILL NOT ENTERTAIN THE BELIEVE OF ENEMY COUNTRY AND IMUN WILL SUBSCRIBE TO THE BELIEVE THAT ALL COUNTRIES ARE FRIENDLY AND OPEN FRIENDLY AND DIPLOMATIC TIES WITH THEM.  MEMBERSHIP IS FREE AND  OPENED TO NIGERIANS AND NON-NIGERIANS.

3.   IMUN WANTS NEW FEDERAL UNION IN NIGERIA UNDER PEACEFUL ONE NIGERIA TO REPLACE THE PRESENT FORCED UNION WHICH IS BATTERED WITH WAR, CONFLICT, POLITICAL ASSASSINATION, BRIBERY AND CORRUPTION, BLOODSHED.  POVERTY, LACK OF LEADERSHIP, LOOTING AND FLIGHT, INTOLERANCE AMONG COMPATRIOTS, AND RELATED MISRULE. IMUN FOUND THAT 1914 - PRESENT, NIGERIA AND NIGERIANS IN THEORY AND PRACTICE HAVE REMAIN UNGOVERNABLE AND IMPOVERISHED BECAUSE OF THE EXCESSIVE FOREIGN BORNE PARTISAN POLITICS PRAWLED WITH MENACE OF  DICTATORIAL AND HIGHHANDED  POWER OF THE PRESIDENT, GOVERNORS, LGA CHAIRMEN/WOMEN; SENATE; FEDERAL REPRESENTATIVES; STATE ASSEMBLY MEMBERS;  POLITICAL PARTIES MEMBERS;ETC WHICH EMPOWER THEM TO COMMAND BANKS AND OTHER FINANCIAL INSTITUTIONS TO TRANSFER PUBLIC MONIES TO CITED DOMICILE AND FOREIGN ACCOUNTS.  MANDATE 2011 AND AMENDMENT WILL BE THE WORKING TOOL TO REALIZE GOOD GOVERNMENT IN NIGERIA 2015 AND THEREAFTER. CAMPAIGN FOR WOMEN PRESIDENT AND VICE-PRESIDENT INSIDE AND OUTSIDE NIGERIA IS GIVEN HIGH PRIORITY. (http://www.phillyimc.org/en/event/dr-phillip-chukwuma-ofume-president-nigeria-2011-complete-political-manifesto) 

4.  UNDER NEW FEDERAL UNION OF NIGERIA,  IMUN DESIRES TO  ELIMINATE LOOTING/FLIGHT AND  BRIBERY/CORRUPTION VIA REDUCTION OF THE EXCESSIVE POWER OF THE PRESIDENT, GOVERNORS, LGA CHAIRMEN/WOMEN, SENATE, FEDERAL REPRESENTATIVES, STATE ASSEMBLY MEMBERS,  POLITICAL PARTIES MEMBERS, ETC AND WITH CLOSE CHECK ON ANT-GOOD GOVERNMENT DIPLOMATIC ELEMENTS SUCH AS  DIPLOMATS,  LUGGAGES, AIRCRAFTS, DIPLOMATIC EQUITY AND COMPETITIVENESS AND OTHER FIXTURES OF PASSAGE AND INTERACTION BECAUSE THESE SOURCES HAVE BEEN PROFILED AS LOOTING/FLIGHT AND UNDER-DEVELOPMENT THOROUGHFARES WHICH HAVE IMPOVERISHED AND PLUNGED NIGERIA INTO WARS, CONFLICT, INSTABILITY, AND RELATED HARM. COUNTRY BY COUNTRY IMUN WILL OFFER EXPLANATIONS WHY THIS PLAN IS INEVITABLE IN ENSURING THE HOMELAND SECURITIES OF NIGERIA. (http://universal-fashion-art-music.blogspot.com/2011/07/america-uk-and-some-western-nations.html)

5.   SPONSORING PASSAGE OF FEDERAL, STATE AND LGA LEGISLATIVE BILLS THAT WILL REDUCE THE POWERS OF THE PRESIDENT, GOVERNORS, LGA CHAIRMEN/WOMEN; SENATE, FEDERAL REPRESENTATIVES, STATE ASSEMBLY MEMBERS;  POLITICAL PARTIES MEMBERS; ETC. TO MAKE THEM BE LIABLE FOR ANY OFFENCE COMMITTED LESS THAN ONE MINUTE SEQUEL TAKEN OATH OF OFFICE BECAUSE THE FORMER LAWS GIVE ENLARGED OPPORTUNITY TO THEM TO LOOT PUBLIC WEALTH AND REPATRIATE IT INTO HIDDEN OR SECRET FOREIGN ALLIES FINANCIAL INSTITUTIONS WITHOUT POSSIBILITY OF RECOVERY BECAUSE SEVERAL THERE ARE  IMMUNITIES PROTECTING THEM WHILE IN OFFICE BUT IF DAILY ACCOUNTABILITY IS FOLLOWED AND POWER TO THE MASSES TO QUESTION AND GET ANSWER ON THEIR  COMMONWEALTH  AND PROSECUTION COMMENCED WHILE IN OFFICE LOOTING WILL NOT BE POSSIBLE TO THE EXTENT THAT PRESIDENT AND OTHERS FEAR THE RAPT OF LAW WHILE IN OFFICE. THEY  MAY BE ABLE TO LOOT AND REPATRIATE OVER $45BILLION WHILE IN OFFICE AND SOON AS THEY LEAVE OFFICE RECOVERY OF THE LOOTS BECOMES GHOST AND LOOTS ARE SHARED BY ALLIES AND SAME ALLIES PLAN TO JAIL OR KILL  THEM TO SEAL THE LOCATION OF THE LOOTS AND PARTIES INVOLVED. 

6.   IMUN  WILL  PUSH FOR A FEDERAL LEGISLATION FOR NEW FEDERAL UNION  WHICH WILL  LEAD TO EMERGENCE OF FIVE TIER SYSTEM OF GOVERNMENT AS FOLLOWS:

   i.    Federal Authority  - Presidencies (President and Vice-President), 

         House of Senate and House of Representative

    ii.    State Authority - Governor, Deputy Governor, State House of

           Assembly

    iii.    Local Authority - Chairman and Deputy Chairman, Local House

            of Assembly

     iv.   Traditional Authority - Traditional House of Assembly

     v.   Religion, Labour, Student, Media/Entertainment, Women, Children, Senior Citizen  and other NGOs with Representative Unionist and lawmaking authorities and with full operational budget as i, ii, iii, and iv above  -  House of Commons

UNDER THE FIVE TIER FEDERATION OF NIGERIA 100% OF NIGERIA WILL BE GOVERNED AND FOLLOWED BY 100% QUALITY GOVERNANCE WATCH, MONITORING AND COMPLIANCE. HOUSE OF COMMON AND OTHERS HAVE RIGHT TO EXPOSE THE CONDUCT OF ANY LEADERS AND OTHERS WITHIN NIGERIA AND THEIR FOREIGN ALLIES WHILE TENURE IN OFFICE REMAINS IN FORCE. 

7.    NATIONAL MOBILIZATION TO FORM NEW FEDERAL UNION WHICH WILL BE MADE UP OF REPRESENTATIVE UNION WHICH WILL NEUTRALIZE THE WAR/CONFLICT PARANOID OF  POLITICAL PARTIES, RELIGION ORGANIZATION,INTER-UNIONISM, ETHNIC CONFLICT UNDER IMPORTED DIVIDE AND RULE, ETC. IMUN WILL FORM NATIONAL COALITION UMBRELLA REGISTERED WITH INDEPENDENT NATIONAL ELECTORAL COMMISSION OF NIGERIA (INEC) AND MEMBERS WILL RUN FOR NIGERIA’S   PRESIDENT, GOVERNORS, LGA CHAIRMEN/WOMEN, SENATE, FEDERAL REPRESENTATIVES, STATE ASSEMBLY MEMBERS, ETC.

8.    IMUN IS DEVOTED TO LOOK FOR QUALITATIVE STANDARDS EN ROUTE TO REALIZATION OF FIRST GOOD GOVERNMENT IN NIGERIA 1914 - PRESENT BY NEUTRALIZING PARTISAN POLITICS WITH SELECTION OF BEST ACTORS SUCH AS NIGERIANS ACROSS FEDERAL, STATE AND OTHERS WITHIN THE FIVE TIER STRUCTURE TO FORM NON-PARTISAN GOVERNMENT OF NIGERIA TO REMOVE STARVATION; POOR INFRASTRUCTURE;  LIFE LIVED WITHOUT EMPLOYMENT; HABITABLE HOUSING; SERVICE WITHOUT DIGNITY AND HONOR;  POLITICAL, ETHNIC, RELIGION AND OTHER FORMS OF PERSECUTION AND CONFLICT; ETC.

9.    NATIONAL PUSH FOR ALTERNATIVE JUSTICE MECHANISM TO DEAL WITH OLD AND NEW  ETHNIC, ECONOMIC, POLITICAL AND RELIGION CONFLICTS; EXCLUSION AND MARGINALIZATION OF THE MINORITIES WITHIN AND OUTSIDE MAJORITY ENTITIES - MONITORING EQUITY ON ACCESS TO RIGHT TO ALL SERVICES. RESOLUTION, RESTITUTION, PEACE AND RECONCILIATION OF ALL PAST AND PRESENT CONFLICTS IN THE EAST, MIDDLE BELT, NORTH, SOUTH/SOUTH, WEST, ETC. 

10.   IMUN WILL PUSH FOR  DIVERSIFICATION AND INDIGENIZATION  OF THE ECONOMIES OF NIGERIA WHICH WILL EMPLOY MAJORITY OF ABLE BODY OR EMPLOYABLE NIGERIANS - DIRECT COOPERATION BETWEEN EDUCATION AND INDUSTRY WILL PRODUCE OVER-SIZE JOBS BECAUSE MAJORITY OF THE GOODS AND SERVICES IMPORTED INTO NIGERIA WILL BE MADE IN NIGERIA. ALL GRADUATES (HIGH SCHOOL, DIPLOMA, DEGREE, ETC) WILL BECOME EMPLOYED OR SELF-EMPLOYED VIA EDUCATION AND INDUSTRY INTERACTIVE ENTREPRENEURSHIP PROGRAM. UNDER NEW FEDERAL UNION, EXPERTS WILL DESIGN MICRO BUSINESS AND PLACE A GIVEN GRADUATE AND OTHER ASSOCIATING GRADUATES AND OTHER EMPLOYEES AND MONITOR THEIR PERFORMANCE TIME TO TIME UNTIL THEY ARE ABLE TO TAKEOVER.  OIL/GAS AND OTHER NATURAL RESOURCES WILL BE INSTITUTIONALIZED AND ELEVATED TO BECOME LENDER TO AGRICULTURE, EDUCATION/TRAINING, SCIENCE/TECHNOLOGY, HEALTHCARE, ETC.

11.    UNDER LEGISLATIVE MECHANISM, IMUN WILL PUSH FOR NEW FORMS OF REGULATION AND COMPLIANCE IN THE POLICE, ARMY, NAVY, AIRFORCE, CUSTOM AND EXCISE, ETC. TO REALIZE SERVICE WITH HONOR, INTEGRITY, PRIDE, ADVANCEMENT, AND EMPOWERMENT OF OFFICERS AND THEIR FAMILIES. SEE BARACKS AND WHAT OFFICERS AND THEIR FAMILIES ARE SUFFERING. ACROSS NIGERIA WE HAVE VISITED BARACKS, TALKED TO OFFICERS AND THEIR FAMILIES AND IN SEVERAL CASES SALARIES ARE NOT ENOUGH TO FEED THEIR FAMILIES. DR. PHILLIP C. OFUME SAID, “WHAT DEPRIVES ALL THE LEADERS INCLUDING BUT UNLIMITED TO THE PRESIDENT, GOVERNORS, SENATORS, HON. MEMBERS OF FEDERAL AND STATE ASSEMBLIES , ETC FROM MAKING UNPROGRAMMED WALK-IN TO QUARTERLY OR YEARLY BUDGETS AND EXPENDITURES AND BARACKS TO SEE FAMILIES…WHAT STOPS THEM FROM CONTACTING VICTIMS DIRECTLY OR DESIGN DIRECT CONTACT UNION SYSTEM TO ENABLE THEM FEEL THE IMPULSE OF VICTIMS…”   UNDER THE NEW FEDERAL UNION, BIGMEN/ WOMEN WILL NOT DIVERT THE FUND PROVIDED FOR OFFICERS AND THEIR FAMILIES INTO PERSONAL POCKET AND LEAVE INNOCENT OFFICERS AND FAMILIES TO SUFFER.

12.    MANAGEMENT, SHARING AND INVESTMENT OF THE COMMONWEALTH OF NIGERIA TO ELIMINATE POVERTY, UNEMPLOYMENT, HOMELESSNESS, POOR HABITAT, ETC. IMUN CALLS FOR CUT WITH OVER 85% DOWN OF THE  COSTS OF PERISHABLE GOODS AND IMPACTS SHAMEFUL SITUATION TO THE PRESENT AND PAST GOVERNMENTS TO THE EXTENT THAT RICE, BEAN, TOMATOES, MEAT, ONION,  BUILDING MATERIALS, RENTS, MORTGAGE, MOTOR VEHICLES AND SPARE PARTS, MINES/POWER, COMMUNICATIONS, ETC ARE NO LONGER AFFORDABLE FOR THE LOWER AND MIDDLE CLASSES OF NIGERIA BECAUSE OF EXTERNALIZATION AND ABUSE OF THE MARKET OF NIGERIA AND LACK OF DIRECT FOCUS ON INTERACTION BETWEEN EDUCATION AND INDUSTRY, ALLOWING MASS EXODUS OF NIGERIAN EXPERTS AND OTHERS ACROSS NIGERIAN BORDERS INTO FOREIGN LAND WHERE THEY MADE TAXI DRIVERS AND INDENTURED WORKERS AND SERVANTS, ETC.  APART FROM RECALLING ALL NIGERIAN EXPERTS AND NON-EXPERTS, IMUN WILL TASK MEN AND WOMEN OF NIGERIA TO DOUBLE THE POPULATION OF NIGERIA BEFORE YEAR 2055 UNDER CHANGE OF THE PRESENT POOR CONDITIONS IN NIGERIA BECAUSE POVERTY AND HARDSHIP IMPEDE BABY BOOM.  

13.   IMUN SUPPORTS THAT UNDER THE GOVERNMENT OF DR. PHILLIP CHUKWUMA OFUME 2015 EDUCATION AND TRAINING PRE-K - HIGH SCHOOL WILL BE FREE FOR ALL AND TERTIARY LEVEL ALL POOR PEOPLE  AND CERTAIN MIDDLE CLASS FEES AND HOUSING WHILE IN TERTIARY INSTITUTION WILL BE FREE AND ENDOWMENT SUBSIDIES WILL BE APPLIED TO CERTAIN RICH NIGERIANS THAT ARE BELOW THE CAP OF LGA, STATE AND FEDERAL POVERTY LEVEL. THIS PROGRAM WILL BE CALLED BY AMENDED EDUCATION CONSTITUTION AND ACT, “NO NIGERIAN LEFT BEHIND IN EDUCATION” BECAUSE EDUCATION IS GATEWAY TO EVERY GOOD THING IN CHILD’S, MAN’S AND WOMAN’S LIFE. 

14.   IMUN WILL UPGRADE THE JOB READINESS AND COMPETIVENESS OF NIGERIA WHICH IS WEAK AND  LESS 13% AT PRESENT TO OVER 96% BECAUSE DIRECT COLLABORATION AND COOPERATION BETWEEEN EDUCATION AND INDUSTRY, RESTATING THAT FIVE TO EIGHT MONTHS TO GRADUATION, THE NEW FEDERAL UNION EXPERTS WILL CITE AND LOCALIZE GRADUATES INTO FUTURE JOBS AND IN SERVICE TRAINING AND THE ONES THAT DESIRE TO GROW AS ENTERPRENEURS WILL BE LOCALIZED IN BOTH DESIGN AND DEVELOPMENT OF PROJECT OF THE INTENDED ENTERPRISES. ADMISSION INTO  TERTIARY INSTITUTIONS WILL JUMP WITH OVER 30% YEARLY. AT THIS POINT IMUN WILL PUSH FOR THE CANCELLATION OF THE NATIONAL YOUTHS SERVICE CORP BECAUSE THE PROGRAM IS A WASTE OF TIME OF THE CAREER LIFESPERM OF A GIVEN GRADUATE AND PATH TO LOOK UP TO BETTER LIFE. WAREHOUSE FOR OVERSIZE EMPLOYMENT IS NEW FEDERAL UNION DESIGNED AND MONITORED SELF- EMPLOYMENT AND HIRED EMPLOYMENT IN AGRICULTURE, WATER, TOYS, UTENSILS,  HEALTHCARE, HOUSING, EDUCATIOIN, ELECTRICITY, COMMUNICATION, TRANSPORTATION (GOOD BYE TO OKADA), ETC INDUSTRIES UP TO 378 OTHER PIECES.  FOREIGN INDUSTRIES HAVE USED THESE PIECES TO CAUSE UNEMPLOYMENT, POVERTY, HUMAN EXODUS, ETC IN NIGERIA.  THE PRICE OF OVER 85% OF THE ESSENTIAL GOODS AND SERVICES WILL BE PUT DOWN TO LESS THAN 20% OR HALF BAG OF RICE WHICH NOW SALES ABOUT N3800.00 WILL GO DOWN TO LESS N60.00 BECAUSE OF MASS PRODUCTION OF RICE AND EXPORT WILL PUMP BILLIONS OF NAIRA INTO NIGERIA.

15.     NIGERIANS AND NON-NIGERIANS ARE CORDIALLY INVITED TO JOIN IMUN AND BE READY TO OPEN  AND OPERATE A CHAPTER OF IMUN IN YOUR COUNTRY, STATE, PROVINCE, COUNTY, DISTRICT, LOCAL GOVERNMENT AREA, AND MUNICIPALITY. IN JULY 2012 WHEN THE INTERNATIONAL COORDINATING WEBSITE, BLOGS, SOCIAL MEDIA, ETC WILL BE FULLY ACTIVATED YOU WILL BE DIRECTED ON HOW TO OPEN YOUR ACCOUNT AND HOW TO MANAGE IT. EFFECTIVE AUGUST 2012 THE DIRECTORS OF ALL THE 36 STATES OF NIGERIA INCLUDING ABUJA WILL START TO RECEIVE THEIR CERTIFICATE OF ADMINISTRATION (COA). 

International Administrators:

Phillip C. Ofume, Ph.D.  

 International Coordinator (Strategic  Policy/Practice                                                                                             of Politics of Unification and Unifification Politics)

Godson Etiebet, Ph.D.

 Researcher on Policy/Practice of Good Government

Cynthia H. Taylor, Ph.D. 

International Collaboration Developer

Alh. (Dr.) Farruk Mohammad - Strategic  Policy Researcher

Tan Ochollu, D.Lit. - Expansion  Project Developer  

Reid MacDonald, Ph.D.   -  Strategic Program Developer

Kris Kifindi Bunkheti, Ph.D.  Unification Policy and Practice

Jerome Tesfai, D. Min/Div 

Domestic Intervention Strategist

Francois Bourgeois & Pierre Bushel

International Human Rights Watch and Democracy 

AFRICAN CANADIAN HUMAN RIGHTS ASSOCIATION (ACHRA);

NETLINK INTERNATIONAL COMMUNICATION SYSTEM (NLICS);

INTERNATIONAL CAMPAIGN FOR NIGERIAN PEOPLE’S LIBERATION AND

DEMOCRACY(ICN-PLD); OIL AND CHEMICAL WATCH INTERNATIONAL (OCWI);

AFRICAN CANADIAN IMMIGRANT SETTLEMENT ASSOCIATION (ACISA);

INTERNATIONAL NETWORK FOR PEACE AND DEVELOPMENT IN AFRIK (NIPAD).

LIMPT, INC. (EDUCATION AND WORKFORCE PROJECT

MOVEMENT FOR EMANCIPATION OF THE NIGER DELTA

MASS DEPARTMENT OF HOUSING AND COMMUNITY DEV: DISCRIMINATE AGAINST EDUCATED NON-WHITES TO CAUSE FAMILY AND PROFESSIONAL INSTABILITIES

MASS DEPARTMENT OF HOUSING AND COMMUNITY DEV: DISCRIMINATE AGAINST EDUCATED NON-WHITES TO CAUSE FAMILY AND PROFESSIONAL INSTABILITIES

______________________________________________________________________

OFUME v. DHCD, RST ET ALS

                        COMMONWEALTH OF MASSACHUSETTS
Suffolk, ss.                       SUPERIOR COURT DEPARTMENT
                                          OF THE TRIAL COURT

CIVIL ACTION DOCKET NO.
_________________________________________________________________________

Phillip Ofume (on behalf Ofume family),
                    Petitioner (Pro se and Forma Pauperis)
                             v.
Mass Department of Housing and Community Development (DHCD) and Troy Lewis and RST Investment Group, Inc.
                   Respondents
_________________________________________________________________________________

Petition for Judicial Review from the Decision of the Agency Administrative
Hearing Officer, Ms. Barbara Boe Morgan dated on June 18, 2012,
Censored and Mailed on 11/15/2012 after Petitioner Protested and Petitioned the Agency (Exhibit A)   Adm. Agency Case No. 12-0633
_________________________________________________________________________

A.         RECORD AND PROCEDURAL HISTORY

Appellant: Dr. Phillip C. Ofume

Respondent: DHCD

Place of Hearing: Brockton Office of the DHCD

Hearing Officer: Ms. Barbara Boe Morgan

Hearing Date: 06/18/2012
                                    OFUME v. DHCD, RST ET ALS

                                                            2

Type of Application Denied: Family with Children Emergency Assistance (EA)

Decision issued on 8/10/2012 and censored but Appellant’s petition compelled the respondent to release the decision on November 15, 2012. See EXHIBITS A & B (Decision & Mailing Envelope and date mailed)

Reason for Appeal: Denied Appellant’s Application for Emergency Assistance of Family with family with American, Canadian and Nigerian Citizenships.

Present at the Hearing:
Phillip Ofume – Appellant
Paulette Sylvia – DHCD South Shore Regional Supervisor/Dept. Rep.
Paul Bowman: Department Representative
Troy Lewis – Landlord – Rep. of RST Investment Group
Filing Date: 6/13/2012
Hearing Date: 6/18/2012
Decision Date: 8/10/2012
______________________________________________________________________________

Before, Hearing Officer, Ms. Barbara Boe Morgan of the Commonwealth of Massachusetts Department of Housing and Community Development(DHCD) .

This Complaint is hereby given that the Petitioner, Dr. Phillip C. Ofume on behalf his Family (hereinafter, “Ofume family") in the above-captioned case, hereby appeals in nature seeking judicial review pursuant to Massachusetts General Laws CHAPTER 30(A), to this Court from the denial decision (attached – EXHIBIT A) of the Hearing Officer, Ms. Barbara Boe Morgan of the DHCD on the following grounds:


A.     FACT IN SUPPORT OF REVIEW OF THE ONLY REASON WHICH GENERATED DENIAL OF THE PETITIONER’S APPLICATION FOR EMERGENCY HOUSING ASSISTANCE (EA) : REOCCURRING PATH TO RENDER PETITIONER AND HIS FAMILY 11TH HOMELESS SINCE AUGUST 2009 TO IMPEDE CAMPAIGN FOR THE PRESIDENT OF NIGERIA AND CAMPAIGN FOR CIVIL LIBERTIES INSIDE AND  OUTSIDE THE NIGER DELTA REGION OF NIGERIA


                                                            3

OFUME v. DHCD, RST ET ALS

A.1. The United States Federal Bureau of Investigation (FBI) and related operatives are aware that Petitioner and his family bid for the President of Nigeria (ofume-woman.tumblr.com)
past and 2015 and that 2005 –present, the Government of the United States and Nigerian foreign and domestic oil/gas companies have adopted zero income or deadly sanction on the entire means of livelihood including homelessness as tool to impede their campaign for the President of Nigeria and civil liberties inside and outside the oil/gas rich and impoverished NIGER DELTA REGION OF NIGERIA. From Massachusetts to Virginia and back to Massachusetts, Petitioner has alerted these operatives when these oil/gas companies organized giving of bribe to the staff of the DHCD, DTA, JUDGES, LANDLORDS, CLERK/MAGISTRATE, ETC. October 20 & 21, 2005 to present time, Petitioner and his family have attended over 15 agency administrative hearings in the offices of the DHCD, DTA, etc and all the 15 hearings were politically and fraudulently denied and when brought to Courts through the Supreme Judicial Court and The Supreme Court of the United States for review, oil/gas monies take center stage either frustrated, landlords are bribed to render Petitioner and his family homeless to force them to leave the state in order to abandon the case. https://groups.google.com/forum/?fromgroups=#!topic/soc.org. nonprofit/HezWrBSYW14; http://universal-fashion-art-music.blogspot.com/search?q=DTA and the present landlord is also implicated and as usual the landlord is refusing to accept his rental money. To enable Petitioner and his family member have roof over their head, they encourage the landlord to accept about three months advance payment and when the advance payment expired on November 1, 2012, Petitioner persuaded him/her to take another three months, he/she disappeared as a tactic to avoid receipt of the money and the check remain uncashed for over one month and as usual Petitioner suspect that the landlord will re-surface maybe months latter to file notice to quit for non-payment of rent and other falsified allegations to render Petitioner and his family 11th no fault homelessness.  EXHBITS M & N.


A.2. Under the on-going energized political persecution, on before August 2011 Petitioner and his family negotiated and agreed on conditions imposed by the Respondents or Landlords to enable Petitioner and his family rent their family apartment located at 96 Walnut Street, Brockton, MA and the Petitioners liked the apartment even if the price was high and they  paid the landlords in full and also paid all charges imposed on them and move agreed for August 16, 2011 (EXHIBITS B & C). On August 16, 2011 the landlords politically forced petitioner and his family take highly vandalized apartment (Warren Avenue, #2 Brockton, MA 02301), with broken doors, windows, blocked toilet and bath, mold, multiple mice, cockroaches, without heat and unserviceable heating transformers, failed CMR Fitness, because of the safety of child declared inhabitable by the BOARD OF HEALTH and U.S. FEDERAL ENVIRONMENTAL PROTECTION AGENCY (FEPA), etc. (EXHIBITS D, E, F, G, H).  August 2011 through June 2012 on the disputed apartment (506 Warren Avenue, #2 Brockton, MA 02301), Petitioner and his family inherited all the defects cited and not cited by the BOARD OF HEALTH and also paid 100% of the  rents due to the Respondents or landlords (EXHIBITS I, J, K, L, M, N, O). Because of the impartial position of the Agency Hearing Officer, Petitioner request this court to reverse the decision appealed or petitioned.

Frivolously, Respondents lied when they said,

A.2.a. Frivolous Allegation #1 “On 6/12/12 the Department issued a Notice of Denial of Emergency Assistance (EA ) denying the Appellant’s request for EA shelter benefits because he
                                                            3

OFUME v. DHCD, RST ET ALS
was evicted from private, public or subsidized housing for destruction of property.”
EXHIBITS I, J, K, L, M, N, O are detailed disclosure of the facts to show that Petitioner and his family were not owing rent when the Respondents proceeded to Court to file Summary Process (Eviction) Summons and Complaint on November 7, 2011 (EXHIBIT B) to retaliate against Petitioner’s and his family’s Complaints to the BOARD OF HEALTH and U.S. FEDERAL ENVIRONMENTAL PROTECTION AGENCY (FEPA) to report the inhabitable conditions in the disputed apartment (EXHIBITS P & Q). Starting from August 17, 2011 to September 2011 Petitioners wrote several letters to  and telephoned the landlords several times to fix the multiple defects in the apartment and in retaliation the landlords filed Summary Process (Eviction) Summons and Complaint, and suspiciously the Respondents or Landlords sued Mr. Keynes Ofume who is one of the seven children of the Petitioner, Dr. Phillip C. Ofume and Keynes is not one of the negotiators and signatories to the yearly lease signed by the landlords and Dr. Phillip C. Ofume and Mrs. Maureen N. Ofume. Under these deceptions, lies and frivolousness thus, after The Presiding Honourable Justice Edwards  reviewed Petitioner’s and his family rent payment receipts and the Judge found that no rent is unpaid, thereafter, the Judge dismissed Respondents’ Summary Process (Eviction) Summons and Complaint dated November 7, 2011 but horribly the Presiding Judge dismissed the landlords’ Complaint without Prejudice instead of with prejudice. Under transparent and civilized judicial system where race, color, ethnicity etc lack chance, Judge cannot dismiss the Complaint without prejudice because the Judge found fraudulent, deceptive, and bad faith practices such as committing crime with boldness under oath when the landlords on their sworn Summary Process (Eviction) Summons and Complaint dated November 7, 2011 claimed that Petitioner and his family have paid SEPTEMBER 2011, OCTOBER 2011 AND NOVEMBER 2011 rents whereas they have paid these rents in full and over paid the landlords as follows:

A.2.a. i. PLAINTIFFS’ ANONYMOUS RECEIPT No. 734521 $2,600.00 (08/13/2011) EXHIBIT F

A.2.a. ii. PLAINTIFFS’ ANONYMOUS RECEIPT No. 734520 $40.00 (08/13/2011) EXHBIT G

A.2.a. iii. PLAINTIFFS’ ANONYMOUS RECEIPT No. 734743 4 $675.00 (9/16/2011) EXHIBIT H

A.2.a. iii. PLAINTIFFS’ ANONYMOUS RECEIPT No. 428788 $1,180.00 (11/1/2011) EXIBIT I

A.2.a. iv. PLAINTIFFS’ ANONYMOUS RECEIPT No. 428794 $170.00 (11/03/2011) EXHIBIT J

A.2.a. iv. Landlords’ Summary Process (Eviction) Summons and Complaint was dismissed with costs payable to the Ofume family and the soft punishment or reprimand the landlords got from the Judgment of The Honourable Presiding Justice Edwards was $8,200.00 (EIGHT THOUSAND, TWO HUNDRED DOLLARS) and rent reduction from $1,350.00 to $600.00 and the Judge Edwards granted Petitioner and his family’s protest to relocate out of this danger of
                                                            4
OFUME v. DHCD, RST ET ALS
lack of space for a family of 8 people, mold, lead, fungal, etc and according to the warning issued by the FEPA and BOARD OF HEALTH and Petitioner requested for time to relocate out to another apartment in June 2012 and Judge Edwards also granted Petitioner’s request.

A.2.a. v. After subtracting the award of $8,200.00 (EIGHT THOUSAND, TWO HUNDRED DOLLARS), Petitioner and his family paid all rents in full through May 2012 or relocation to 41 Gallivan Boulevard, Dorchester, MA 02124. The signed and sealed releases of the PLYMOUTH DEPUTY SHERIFF and the Clerk of the South East Housing Court , Brockton, MA 02301 shows that the Petitioner and his family are not owing any rents and that they did not destroy or vandalize Respondents’ or landlords’ properties. (EXHIBIT C, D & E).

A.2.b. Respondent’s Decision page 2 line 7 further raised another form of lies as follows:
Frivolous Allegation #2 “You were evicted from 506 Warren Avenue Apartment# 2 Brockton, MA 02301 for Non-Payment of Rent and Destruction of Property.”

A.2.c. In opposition, Petitioner states and affirm that he over paid rents at 506 Warren Avenue Apartment# 2 Brockton, MA 02301 and other bills, August 2011 through June 12, 2012 and the unserviceable thermostat claimed by the landlords were inherited by the Petitioner and his family from the broken, failed CMR fitness, with over 75 citations variously issued by the BOARD OF HEALTH and charges filed against the landlords.

A.3. OTHER FACTS IN SUPPORT OF REVIEW

A.3. a. Over thirty six days (36) DHCD requested for different unnecessary documents based on highly politicized verification activities to the extent that Petitioner submitted over eighty one (81) exhibits and on June 8, 2012 the final document was received by the Respondent or DHCD and on June 11, 2012 Respondent told Petitioner that his application has been approved and that on June 12, 2012 he should move his and family's luggage to the DHCD office in Brockton, MA at 8.00 a.m. for placement in shelter.

A.3. b . Early as 8.00 a.m. Appellant and his family were moved by members of their church (CHURCH OF JESUS CHRIST OF LATTER-DAY SAINTS) moved them to the DHCD office at 75 Commercial Street, Brockton, MA 02301.

A.3. c. . Between 8.00 - 3.00 pm Petitioner and his family waited to be placed in apartment but DHCD or Respondent abandoned Respondent and his family and at about 3.00pm Mr. Paul told Respondent that his application for EA is denied. He failed to announce this denial early. Respondent failed to give reason why they waited the last day and less than one hour to closing its office for the day and after the Petitioner and his family have vacated their apartment and moved into the premises of the DHCD to announce denial and after all the documents have been submitted and received by the Respondent and .
                                                            5
OFUME v. DHCD, RST ET ALS

4. The reason which Mr. Paul gave for denial was that the landlord told them that Appellant damage his heating thermostat cover whereas the maintenance person of the landlords removed the cover of the thermostat and when the Respondent and his family asked him why he removed it, he said that he was going to service it to make it work but he did not come back with the cover. When Appellant and his family were forced to occupy the apartment the cover of the thermostat and several other things in the apartment were some of the defects in the apartment which were cited by the BOARD OF HEALTH.

5. There were no prior move in inspections in the apartment and the Respondent did not request for discovery when they called the landlord on June 11 2012 and Appellant was in the office of the Respondent. After telephoning the landlord instantly Mr. Paul told Appellant that the Landlord told him that the eviction was because of non-payment of rent and not as result of property damage as claim to by Mr. Paul in contradiction. The landlord lied because the Appellant over paid the landlord and in the Judgment the Appellant and his family were awarded the sum of $8200.00. See EXHIBITS A, B, C, & D.

6. Appellant restates that the Heat Thermostat Covert was damaged prior to Appellant and his family occupation of the defective and broken apartment which failed fitness test of the BOARD OF HEALTH. See EXHIBIT G.
See EXHIBITS A, B, C, & D.

7. The Summary Judgment Agreement and Plymouth Sheriff papers did not mention property damage or amount against Appellant or judgment debtor and this moneyed action of the Respondent accepted the claim which was not entered in the final judgment. SEE EXHIBITS E & F.

8. That apartment which the Respondent paid for was not rented to the Respondent. On
August 16, 2011 at about 10.00 pm which was the day of move in the landlords forcibly placed Appellant and his family at 506 Warren Avenue, Apartment #2 Brockton, MA 02301.

9. On August 16, 2011 which is the day of move in, Appellant have exhausted the money they had during long stay in the hotel and large down payment for these apartment located at 96 Walnut Street Brockton, MA 02301.

10. At 506 Warren Avenue, Apartment #2 Brockton, MA 02301 there were several damages and few days of this forced occupation because the landlords refused to fix several defects in the apartment, Appellant filed Complaint with the BOARD OF HEALTH and two major inspections were conducted by the BOARD OF HEALTH on December 5, 2011 and January 4, 2012 and several follow up inspections on fitness. The reports of the BOARD OF HEALTH are hereto marked EXHIBITS A, B, C,& D.
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                        OFUME v. DHCD, RST ET ALS                        
11. As the politicized Respondents were looking for something to use to deny Appellant's application for EA they telephoned several people none of them said anything against the Appellant and his family. Since 2006 when Appellant started using EA Benefit they have not violated any CMR.
B. ALLEGATIONS NOS. 1 & 2 ABOVE ARGUED PER EXAMINATION OF FACTS - DESTRUCTION OF PROPERTY AND NON-PAYMENT OF RENTS
Respondent and its hearing officer and representatives relied on two uninvestigated allegations (Non-Payment of Rent and Destruction of Property) to dismiss and deny Appellant’s and his family application for EA. Below are factual disclosures of the lies told by the Respondent and its witness (Mr. Troy Lewis):

B.2.a. Frivolous and Misleading Allegation #1 “On 6/12/12 the Department issued a Notice of Denial of Emergency Assistance (EA ) denying the Appellant’s request for EA shelter benefits because he was evicted from private, public or subsidized housing for Destruction of Property.”

B. 2.a. INHERITED MASSIVE VANDALIZED PROPERTY AND OPPOSITION TO THE ALLEGATION OF DESTRUCTION OF PROPERTY

B.2.a.i. 100% of the vandalized and unserviceable property at 506 Warren Avenue Apartment #2 Brockton, MA were inherited by the Appellant because the apartment was vandalized, badly used by smokers, alcohol users. Appellant’s and his family’s forced Move-in (8/17/2011) and Summary Agreement Move-out (06/12/2012 because of mold and other dangerous elements to the health his children and entire family ) at 506 Warren Avenue Apt. #2 Brockton, MA 02301 were extra-judicially conducted by the respondents. Day and after move-in and move-out Respondents and Appellant did not conduct inspection on the disputed apartment and take inventory on the real and other properties and conditions in the apartment. Less than 72 hours of the time when Appellant and his family moved into the disputed apartment, Appellant contacted and invited the Respondent to the disputed apartment to view, list and sign the defects in the apartment and/or conduct formal inspection of the apartment under CMR and also take inventory of the apartment but the Respondents or landlords ignored the calls.

B.2.a.ii. Mr. Lewis received large amount of rental down payment money from the Plaintiff and his family pretending to be willing to rent out to them a decent apartment located at 96 Walnut Street, Brockton, MA but on the date (08/16/2012) of move in (night) when Plaintiff and his family checkout from the long self-paid hotel accommodation. Appellant and his family paid Mr. Lewis all the accommodation money they have, Mr. Lewis forced the Plaintiff and his family to take apartment located at 506 Warren Avenue, Brockton, MA which was invaded by mold, fungal, cockroaches, dirt, mice and other rodents; without heat and heating system, without serviceable doors, windows, keys, etc; apartment circled by indecent cartel where several people
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were shot and sealed; etc

B.2.a.iii. Other horrible and inhabitable conditions in the apartment (506 Warren Avenue, Apt. #2 Brockton, MA) are as follows:

B.2.a.iv. Restating that the Ofume family moved in August 17, 2011 about 11.00 p.m. without inventory taken and inspection conducted. Letters and personal meetings were made to request landlords to fix defect but plea remain unheeded.

B.2.a.v. All the defects stated above and below were inherited under rushed and nowhere to live occupancy. Oral and written Complaints put to the landlords to fix the multiple defects, they refused to fix the following major emergency defects:

B.2.a.vi. Ofume family lives in apartment  #2 and each time tenants in apartment #3 are bathing or using water there is pool of spelling and other forms of water coming down from the roof and flooding the Ofume family’s apartment particularly washroom and other spots of the apartment.

B.2.a.vii. Complainant or Ofume family is unable to bring in furniture, rugs and other goods and properties because of water drilling and something that looks like slime mold or fungus across the apartment which the family clean every 48 hours. The walls are easily blacken and with watery substances flowing out from the walls.

B.2.a.viii. Some windows are unserviceable and prone to fall and one went down two day when the family moved into the apartment.

B.2.a. ix. The family is in-charge of all utilities but there is no heat in apartment because 100% of the ancient transformers powered by gas are unserviceable and not working. Gas has been paid in full from month to month.

B.2.a.x. Some doors have cracks and unserviceable including the front entrance door which requires new keys.

B.2.a.xi. Majority of the fire alarms and carbon dioxide detector are not working;

B.2.a.xii. there are several bugs, cockroaches, rats, mice, and other animals;

B.2.a.xiii. Some of the transformers inside and outside living room are unserviceable to breakup and fall and one of thee Transformers can kill an adult .

B.2.a.xiv. Some of the transformers are unserviceable to the extent that they produce electrocution if touched.
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B.2.a.xv. Refrigerator is leaking and produces water which the family must clean from time to
OFUME v. DHCD, RST ET ALS
time.

B.2.a.xvi. Majority of the electric bulbs high and low are uncovered and the light shines into the children and adult eyes.

B.2.a.xvii. Several electric sockets are unserviceable and damaged for several years and with open current which could harm children and adult.

B.2.a.xviii. Because of the horrible moldy conditions of the majority of the rooms of the apartment including the living room, the family abandoned major part of the apartment.

B.2.a. ixx. Several occasion, the Ofume family has pleaded orally and in writing that the landlord find livable apartment for them but its plea remain unheeded by the landlord.

B.2.a. xx. Mr. Lewis refused to fix the multiple defects and also refused to refund the large rental money and deposit which Plaintiff and his family paid to him and Mr. Lewis requested them to sue him to recover their money.
etc.

B.2.a. ACTION TAKEN BY THE APPELLANT AND HIS FAMILY AFTER WRITING AND MEETING WITH THE RESPONDENTS AND MR. TROY LEWIS

B.2.a. xxi. After writing several letters to Mr. Lewis and his principals without fixing the defects and refunding the money Plaintiff and his family paid to Mr. Lewis, Plaintiff filed Complaint with the BOARD OF HEALTH /

B.2.a. xxii. Initially, the BOARD OF HEALTH was influenced by highly wealthy white landlords and late September 2011 when the BOARD OF HEALTH failed to conduct inspection after over one month following Plaintiff’s Complaint to the Board, late September 2011 Plaintiff petitioned the Mayor of the City of Brockton and the United States Federal Environmental Protection Agency (FEPA) . BOARD OF HEALTH in defending the white landlords shared the information on Plaintiff Complaint and the landlords became more and more infuriated and they lobbied Brockton Police Department and other tenants and some members of the neighborhood against Plaintiff.

B.2.a. xxiii. Mr. Lewis was angry because Appellant complained to the Board and FEPA and swiftly he retaliated and brought some people that claimed that they were police officers and they requested Plaintiff and his family to vacate the apartment and when Plaintiff threaten to call 911 they swiftly left.

B.2.a. xxiv. Angrily, early November 2011 the landlords or respondents further engaged filed
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Summary Process (Eviction) Summons and Complaint dated November 7, 2011 suspiciously and deceptively suing one child of the eight children of the Plaintiff who is not one of the two heads (Father and Mother) of the family of the Plaintiff and not party to the signature and negotiation of the Tenancy Lease signed between the landlords and Appellants or tenants.

B.2.a. xxv. Above mentioned action taken by the Plaintiff/defendants complies with the operating laws of the Commonwealth of Massachusetts also cited above and related legislation cited below including 105 CMR 410.

B.2.a. xxvi. Reliant on the horrible conditions inside and outside the apartment, violations cited on housing fitness are several, the landlords do not merit any rent in accordance with M.G.L. CHAPTER 239, SEC. 8A and they acted contrary to M.G.L. c. 186, § 18 because as no rent was outstanding and overdue, to the extent that the landlords received full and in possession of Defendants’ $1,350.00 and defects remain unfixed and the landlords are in-charge of some and major utilities (heat, hot water, etc) in the apartment, therefore the Landlords failed to pay utilities and Plaintiff/defendants took responsibility of payment of some utilities apportioned to the Landlords, therefore withholding of rent pending resolution of this complaint is appropriate and within the regulations of the Commonwealth of Massachusetts but the landlords continued to enjoy unmerited rents.

B.2.a. xxvii. Under this arm-twisting and imbalance tenancy, no recognition of Tenancy with a Lease particularly lack of sufficient notice and eviction without civil demand notice or NOTICE TO QUIT and intent to proceed to court and mandatory and other forms of notice to quit.
FAILING STATUTORY REGULATORY FITNESS (105 CMR 410.400) IN THE COMMONWEALTH OF MASSACHUSETTS

B.2.a. xxvii. Plaintiff and his family are large family of eight (8) people (now four adults and four children) and 506 Warren Avenue, Apartment #2 Brockton, MA 02301 is under size two bedroom for "each additional occupants" pursuant to 105 CMR 410.400. In accordance with Commonwealth of Massachusetts Regulation, 105 CMR 410.400 (A) the entire rooms failed the fitness test because the Minimum Square Footage for large occupants is 150 Square Feet of the Floor Space for its first occupant, and at least 100 Square Feet for each additional occupant, the Floor Space to be calculated on the basis of total habitable room area."

Measurements:

1st Room: First Occupant or Master Bedroom: 12ft 10Inches x 9ft.11Inches = 117ft . 9Inches failed test because Minimum Square Footage for large occupants is 150 Square Feet of the Floor Space for its first occupant or master bedroom

2nd Room: Additional Occupant : 12ft 8Inches x 9ft = 108ft . 8Inches passed test because
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OFUME v. DHCD, RST ET ALS
Minimum Square Footage for each additional occupants is 100 Square Feet of the Floor Space for its first occupant or master bedroom

3rd Room: Additional Occupant : 9ft.7 Inches x 7ft 8Inches = 64ft . 3Inches failed test because Minimum Square Footage for each additional occupants is 100 Square Feet of the Floor Space for its first occupant or master bedroom

4th Room: Additional Occupant : 12ft.2 Inches x 7ft 8Inches = 84ft . 10Inches failed test because Minimum Square Footage for each additional occupants is 100 Square Feet of the Floor Space for its first occupant or master bedroom

B.2.a. xxviii. The Defendants/Landlords deceived the Plaintiff and his family because under Regulations of the Commonwealth of Massachusetts large family like this with 8 members, can not be allowed to live in this type of apartment or two bedrooms apartment. 3rd and 4th rooms are closets for dumping things because bed and other furniture for standard bedroom cannot fit in there. This total cheating and criminal act. Reason of the foregoing the Court must request the landlords to refund all the rents paid and additional punitive damages because of what the Plaintiff suffer in living in squeezed apartment and all the citations issued and delivered by the BOARD OF HEALTH.

B.2.a. xxix. The first (Dec. 1, 2011) and second (Dec. 30, 2011) inspections conducted by the BOARD OF HEALTH show that majority of the defects cited in first and second inspectional reports have remain unfixed and below Plaintiff has shortlisted defects unfixed. It is risky for children and adults to live in a property with mold and several hundreds of mice, rats, cockroaches, bugs, etc. A terminator came to the apartment in late January 2012 and told Plaintiff that the landlords must retain a bricklayer to use cement to block several holes across the apartment which were created by mice and rats before he can set mice/rats traps. Nothing was done by the landlords.

B.2.a. xxx. Plaintiff and his family signed yearly lease with the landlords and without overdue and due rent on October 27, 2011 the landlords/defendants were influenced by the political opponents of the Plaintiff to proceed to the Court to terminate the yearly lease which has liability to defaulting parties the sum amount of $16, 000.00 which must be paid in full to parties violated (EXHIBIT ). Plaintiff requested the Court to review paragraph A of the page 1 to enforce paragraph A against the defendants for breach of this lease and the full amount be paid to the tenant/plaintiff. The Plaintiff is entitled to judgment of the balance amount on the lease.

B.2.a. xxxi. By virtue of the landlords, Defendants flagrant violations of the operating statutory and regulatory framework under the provisions of the laws of the Commonwealth of Massachusetts and regulations of the Board of Health of the City of Brockton, particularly 105 CMR 410.00 CHAPTER II (Minimum Standards of Fitness for Human Habitation ; G.L. CHAPTER 23B, SECTION 30; M.G.L. CHAPTER 186 SEC. 18; M.G.L. CHAPTER 111;
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OFUME v. DHCD, RST ET ALS
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 Landlord/defendants have caused Plaintiff and his deserving family members, irreparable harm for which there is no adequate remedy at law.

B. 2.b. OPPOSITION TO THE ALLEGATION OF NON-PAYMENT OF RENT
Frivolous and Misleading Allegation #2 “You were evicted from 506 Warren Avenue Apartment# 2 Brockton, MA 02301 for Non-Payment of Rent...”

B. 2.b.i. Question in Issue is whether Petitioner and his family were owning the Landlords when they proceeded to file Summary Process (Eviction) Summons and Complaintdated November 7, 2011in retaliation against the just step taken by them to file complaint to the BOARD OF HEALTH and U.S. FEDERAL ENVIRONMENTAL PROTECTION AGENCY (FEPA) because there are danger on the family’s children and adult lead, mold, rabbis, other fungal, several hundreds of mice, rats, cockroaches, bugs, etc

B. 2.b.ii. Very shocking Mr. Lewis and other Landlords of the disputed apartment fraudulently claimed NON-PAYMENT OF RENT as ground to file Summary Process (Eviction) Summons and Complaint whereas the history of the Plaintiff’s payment prior to their Summary Process (Eviction) Summons and Complaint is as follows:

B. 2.b.ii.A. PLAINTIFFS’ ANONYMOUS RECEIPT No. 734521 $2,600.00 (08/13/2011) EXHIBIT F

B. 2.b.ii.B. PLAINTIFFS’ ANONYMOUS RECEIPT No. 734520 $40.00 (08/13/2011) EXHBIT G

B. 2.b.ii. C. PLAINTIFFS’ ANONYMOUS RECEIPT No. 734743 4 $675.00 (9/16/2011) EXHIBIT H

B. 2.b.ii. D. PLAINTIFFS’ ANONYMOUS RECEIPT No. 428788 $1,180.00 (11/1/2011) EXIBIT I

B. 2.b.ii. E. PLAINTIFFS’ ANONYMOUS RECEIPT No. 428794 $170.00 (11/03/2011) EXHIBIT J

B. 2.b.ii. F. The soft punishment or reprimand the landlords got from the Judgment of The Honourable Presiding Justice Edwards was $8,200.00 (EIGHT THOUSAND, TWO HUNDRED DOLLARS) and rent reduction from $1,350.00 to $600.00 and the Judge Edwards granted Petitioner and his family’s protest to relocate out of this danger of lack of space for a family of 8 people, mold, lead, fungal, etc and according to the warning issued by the FEPA and BOARD
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OFUME v. DHCD, RST ET ALS
OF HEALTH and Petitioner requested for time to relocate out to another apartment in June 2012 and Judge Edwards also granted Petitioner’s request.

B. 2.b.ii. G. After subtracting the award of$8,200.00 (EIGHT THOUSAND, TWO HUNDRED DOLLARS), Petitioner and his family paid all rents in full through May 2012 or relocation to 41 Gallivan Boulevard, Dorchester, MA 02124. The signed and sealed releases of the PLYMOUTH DEPUTY SHERIFF and the Clerk of the South East Housing Court , Brockton, MA 02301 shows that the Petitioner and his family are not owing any rents and that they did not destroy or vandalize Respondents’ or landlords’ properties. (EXHIBIT C, D & E).

B. 2.b.ii. H. Before this case was settled under Summary Process Agreement, Petitioner and his family proceeded to the Plymouth County Superior Court to file Complaint against the Landlords, due to the limited jurisdiction of the South East Housing Court, in terms of recovery of the General and Special Damages estimated to be over $10million because of what Petitioner and his family suffered between August 17, 2011 and June 12, 2012 in an inhabitable apartment (506 Warren Avenue, Apt. #2, Brockton, MA 02301) which these cruel landlords forced them to take and same badly ruined by mold, lead, fungal and the vast evidence of defects stated in the aforementioned subparagraphsB.2.a.v. through,B.2.a. xxxi.


C. SUMMARY PROCESS AGREEMENT, (EXHIBIT J) DATED MARCH 7, 2012

C.1. Majority of the 15-paragraph Summary Process Agreement was breached with the lies, falsification, deception and racial hate of the landlords including EXHIBIT A which rendered Petitioner and his family 11th homeless, August 2009 – present.

C. 2.  Breach of paragraph 11 and other paragraphs of the  15-paragraph Summary Process Agreement sought Mandamus relief before The Commonwealth of  Massachusetts Supreme Judicial Court and granted and remanded to the Plymouth Superior Court, Brockton, MA.

D.                                              RELIEF

THEREFORE, for the foregoing reason, Petitioner and his family request this Court to reverse the decision of the Agency’s Hearing Officer and other Order Court deems appropriate..
ISSUED at Lynn, Massachusetts, this 1st day of December, 2012
______________________
Phillip C. Ofume, Ph.D. – Representative/Advocate for the Plaintiff,
Ofume Family

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CERTIFICATE OF SERVICE

I, Dr. Phillip C. Ofume, Representative/Advocate for the Applicant or co-applicant hereby certify that I have served the foregoing document, upon all parties, by hand delivery and mailing a copy, first class, postage prepaid to:

Ms. Barbara Boe Morgan
Mass Department of Housing and Community Development (DHCD)
100 Cambridge Street,
Boston, MA
_____________________
Phillip C. Ofume, Ph.D. – Representative/Advocate for the Ofume Family

DATED: December 01, 2012