EXACTLY THE MEANING OF "OCCUPY PROTEST" AND THE FAILURE OF EQUITABLE RIGHT TO U.S. COMMONWEALTH
November 25, 2011
Commissioner of the Massachusetts Department of Transitional Assistance (DTA) is unable to perform including control the fund pushed to her to manage the department because she lack the requisites to proffer result such as check and balance to stop improper delivery of the intended services..
Bribery and corruption are done openly and fearlessly of any interceding law. Color, Race, Political Affiliation, and related intolerance determine who gets benefits. DTA puts all blames on President Barack Obama and his government claiming that fund is no longer forthcoming.
The case below is in part political case but DTA failed to claim reason this large family was denied food stamps and other benefits within its service jurisdiction pending employment authorization doc and employment.
In several urban and mixed urban schools(Mass case) poor students that fall below district/county/ state/federal poverty level are forced to pay for free breakfast and launch. Each day these children are harassment to pay money for meal and failure they will remain starved morning through closing time.
The meals (morning and evening) are very poor and worth nothing. See the meals in suburban or white school. Several students want to stop school because of daily print out demand notice and it is circulated openly and in an intimidating manner and this intimidation creates stereotype and shyness and compelling shame to disengagement from school.
These demand notices have no names and signature of the school authority or author of the news letter. Also demands for payment are made on almost all poor people's school supplies. FBI has been put on notice and one of the recipients of this complaint.
Obstruction of Justice/Civil Rights Campaign: Retaliatorily, for example, the offices of the mayors of Holyoke, Lynn and Brockton have forced the landlords of the premises where LIMPT, INC. and Publishers occupy and courts to conduct swift eviction of the corporation and staff. The order has been carried out from city to city. Brockton eviction is on-going.
_________________________________________________________________________________
COMMONWEALTH OF MASSACHUSETTS
Brockton, ss.
SUPERIOR COURT DEPARTMENT
OF THE TRIAL COURT
CIVIL ACTION NO.
________________________________________________________________________________
Phillip Ofume (self and on behalf his family) Plaintiff (Pro se & Forma Pauperis)
v.
Massachusetts Department of Transitional Assistance (DTA)
Defendant
_____________________________________________________________________________
COMPLAINT FOR EMERGENCY TEMPORARY INJUNCTIVE RELIEF FOR CONTINUATION OF TAFDC/FOOD STAMP BENEFITS AND PAYMENT OF UNPAID BENEFITS TO NEEDY FAMILIES WITH CHILDREN PURSUANT TO M.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; Humanitarian Ground with direct reference to Snyder v. Phelps and Public Interest; ________________________________________________________________________________
Phillip Ofume, Plaintiff, on behalf his family moves this Honourable Court for Emergency Temporary Injunctive Relief, nature of continuation of TAFDC/Food Stamp benefits and payment of unpaid benefits to Plaintiff and eligible family members pursuant to M.G.L. c. 18 sec. 2 (D); 1st , 4th , 5th and 14th Amendments to the Constitution and Bill of Rights of the United States; Humanitarian Ground with direct reference to Snyder v. Phelps and public interest; because of the reasons stated below particularly the present conditions of the Plaintiff and his family. Two Appeals made in March 2011 and May 2011, DTA’s Hearing Office refused to hear the appeals and also refused to grant benefits including emergency benefits. EXHIBITS A.1 and B.1
A. PARTIES
1. Phillip Ofume, Plaintiff and his family are family of nine (9) people (hereinafter, “two parents and seven children”) and resident of Brockton, Massachusetts within the jurisdiction of this honourable Court. Plaintiff is a potential presidential candidate campaigned and campaigning for the President of Nigeria 2007, 2011 and 2015. Opponents use agencies and other services providers and they have several billions of dollars to fight Plaintiff and they have adapted homelessness and cruel economic sanction ($0.00
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OFUME V. DTA
income) and persecution as tools to disrupt his campaign 2007 and 2011.
2. Defendant, Department of Transitional Assistance (DTA) is agency of the Commonwealth of Massachusetts.
B. FACT AND ANALYSIS
3. Plaintiff and other dependent family members and wife are 9 (two parents and seven children) without income to the extent effective November 7, 2011 only reduced rate on cooking gas was allowed or granted and major services in support of core means of livelihood such as Employment Authorization Documents (EAD), food stamp and cash benefit pending employment, etc. were denied. EXHIBITS F & G. EXHIBITS F & G are part of Ofume v. NEFWC et al Docket No. 11-1260 before this Court and particularly Plaintiff’s Motion for Waiver, EXHIBITS A to N.
4. Plaintiff and their family members are Convention Refugees and Prisoners of Conscience adopted oversea by the United Nations High Commission for Refugees (UNHCR) and Amnesty International (Intl. Secretariat, London, UK) and they have right to work and receive other transitional services pending employment. EXHIBIT H is part of Ofume v. NEFWC et al Docket No. 11-1260 and particularly Plaintiff’s Motion for Waiver EXHIBITS A to N and incorporated in support of this Complaint.
5. Without reason USCIS Nebraska Service Center directed that no Employment Authorization Document (EAD) be granted all members of the family. Punitively, only one year of six years of their residence in US EAD was granted parents and two children (April 29, 2010 – April 29, 2011). January 1, 2011 renewal application was made and after nine months denied and Motion for Reconsideration filed and pending before USCIS’s Commissioner. EXHIBITS I & J. EXHIBITS I and J are part of Ofume v. NEFWC et al Docket No. 11-1260 and particularly Plaintiff’s Motion for Waiver EXHIBITS A to N
6. Without legal reason, Massachusetts Department of Transitional Assistance (DTA) commanded stay of grant of services such as, food stamps to adult and under 18-year children, cash benefits, etc. suspected as path to design child removal forum under the allegation that Plaintiff is unable to provide for their family whereas the government sanction employment authorization documents which is key to providing for the family. November 2011 is the ninth month when application for these services were made in Lynn and Brockton DTA district offices but no hearing has been conducted. Full transfer , Lynn, MA to Brockton, MA has been made but no assistance has been granted including expedite food stamps to
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OFUME V. DTA
under 18 years children pending appeal, EAD and employment. EXHIBIT A.
7. On October 29, 2011 one family member ( child) who was working was stopped because of failure of the USCIS Nebraska Service Center to renew his and others EAD. His Employer is CARRRABBAS ITALIAN GRILL EXHIBIT K [1 Newbury St # A Peabody Tel. (978) 535-3600].EX. K is part of Ofume v. NEFWC et al Docket No. 11-1260 and particularly attached with Plaintiff’s Motion for Waiver EXHIBITS A to N
8. Now the income of all the children is $0.00 because the governments of Canada and US refused to pay their benefits. Income of one US born child is $0.00. No consideration was made under humanitarian ground. Parents’ income is $0.00. Is possible in US and Mass for Children born in US and Canada and other children who are lawful immigrants in US and under 18 be denied food stamps and other services when parents are not working? Whether is possible for families small and large to live and survive under $0.00.
9. Plaintiff and his family have rents and utility arrears because Department of Housing and Community Development (DHCD) and DTA, January 31, 2011 – present, have not responded to Plaintiffs’ request for Transfer of Plaintiffs’ shelter benefits from Holyoke to present apartment pending reconsideration of their application for EAD and employment. The statutory time line for agency to respond to this type of application has long past. See on-going case before this Court upon which Motion/relief for Waiver of all costs are filed/sought, Docket No, 11-1260 and Motion for Waiver of all costs. EXHIBIT L. Under Document Reduction Act EXHIBITS E to M are the same and hereto incorporated and be referenced and will not be duplicated.
10. Parents have adequately and satisfactorily met their obligation as parents by earning score of academic and professional qualifications which include but unlimited to Doctorat du 3e Cycle (DEA, D.E.Phil), Lyon France; Doctorat du 3e Cycle (DEA), Lyon France; Scolarite au Doctorat du 3e Cycle (S.Dr.), Lyon France; M.Sc. (1/2) Lyon France; M.Phil., Lyon France; B.Phil., Lyon France; D.E.F. (Lyon/Geneva); Post-doctoral studies: Ph.D. (Min.) (on-going) NY USA; Juris-doctor, Canada/USA (on-going with over 35 years law study, practice, research, and investigation). NCMP - Mediation Negotiation and Conflict Management ( Dalhousie University ,Law School); NCMP - Negotiation and Conflict Resolution (Dalhousie University, Law School) ; NCMP -Advanced Mediation (inter-governmental and large corporate body mediation and conflict management and resolution, (Dalhousie University, Law School); Cert. Info Tech. – Mass and Strategic Communications; etc Phillip Ofume speaks English, French and Nigerian languages.
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OFUME V. DTA
B. COMPLAINT AND JURISDICTION
11. Plaintiff and his family members are qualified to receive TAFDC and food stamp pending approval of their Employment Authorization Documents (EAD) and employment. Citizenship and Immigration statues determine right to benefits in the United States or TAFDC/Food Stamp benefits in the afore-mentioned case. TAFDC/Food Stamp benefits. Non-citizen eligible applicant for these benefits must be refugee, asylee, parolee, under-18 child with lawful immigrant parents, etc. See paragraph 15 below.
12. Plaintiff and his family are US/Canadian Citizens, refugee, asylee, parolee, under-18 child with lawful immigrant parents in US for over six years and with pending Application for Permanent Residence. EXHIBITS C, D, E, F, G, H & I. (Refugee certificates, 1-94 & Alien Registration Number, Proof of Asylee, US and Canadian Birth Certificates, Proof of over six years residence, Copies and receipt of Application for Permanent Residence, etc.).
C. ARGUMENT
Plaintiff seeks leave of the Court to assign numbers to his argument.
13. Department of Transitional Assistance (DTA) is a very corrupt agency and corrupt in elevated and diverse scope . (http://www.google.com/search?hl=en&q= BRIBERY++%26++CORRUPTION%3A+ COMPLETE+DEFINITION+%26+PRACTICE+IN+BOTH+ANCIENT+&btnG=Google+Search&aq=f&oq=). When politics and personal interest determination overrule good law of America or rules and regulations or partition of who and who are conservative/republican party and democratic party; white, black, hispanic, moderate and non-moderate in the colonized world, etc., DTA becomes tool for exclusion and marginality, repression, persecution, racial discrimination, racism, xenophobia and related intolerance. Plaintiff has visited offices of the DTA and related agency in other states. Color and who you are give applicants services. Caseworkers careless about the operating rules and regulations and openly while Plaintiff observed, several services were approved without eligibility documents. Plaintiff and his family have surplus or over the eligibility documents without assistance granted. What eligibility documents are better than US birth certificate, UNHCR Certificates and other official documents issued by the government of America, etc but services or benefits were denied Plaintiff and his family.
14. Plaintiff and his family fall deeply under district, county, state and federal poverty level because of failure of the government of America to grant them EAD and the income of the family is $0.00.
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OFUME V. DTA
Punitively, under $0.00 income , Plaintiff’s children in Brockton Public School K-12 are requested to pay for reduced and free breakfast/launch. Petitions reversed this cruelty about two weeks ago but they continued to demand money or payment of arrears. SHORT EXHIBITS M, N & 0.
15. Restating that this family is nine (9) people (7 children and 2 parents). EAD is pending before USCIS Commissioner and families under this condition are granted transitional assistance. In Brockton, MA on October 20 & 21, 2005 the same politics was experienced by the Plaintiff and his family when applications for food stamps and TAFDC were made and denied on the next day Brockton, DTA office. Plaintiff proceeded to THE SUPERIOR COURT LAWRENCE, MA and before the first Motion Day DTA rushed to issue food stamps and cash benefits and Plaintiff recall the Order of the woman Honourable Justice who boldly declared, “right to benefits is based on immigration status” See Ofume v. DTA (April 2006).
16. In mid-March 2011 when Plaintiff’s political opponents used savage method to prevent entering of Plaintiff’s candidacy on the ballot for Nigeria’s Federal Election April 2011, the DTA approved Plaintiff’s Application for Food Stamp and TAFDC EXHIBIT A. In May 2011 when Plaintiff inaugurated campaign for Election 2015, swiftly DTA sent letter of Termination of Plaintiff’s food stamps and TAFDC, EXHIBIT B. Plaintiff appealed the termination and punitively to drill the family to food bank and soup table where Plaintiff and his family could be harmed and eliminated without stitches. To adequately implement this murderous political action, other providers joined Plaintiff’s opponents and severed all services and proceeded to court file eviction notice. See EXHIBIT A which is part of the matter pending before this , Ofume v. NEFWC et al Docket No. 11-1260 and particularly Plaintiff’s Motion for Waiver EXHIBITS A to N.
17. But M.G.L. c. 18 sec. 2 (A)(D) did not dictate these ugly actions of the DTA because without this intolerance the law empowering the services of DTA is well made but political interest has distorted this pious law and it speaks for itself as follows:
“Section 2. (A) The department shall provide and administer throughout the commonwealth a comprehensive transitional assistance financial assistance program, including the following services: the provision of financial assistance to those in economic need and the determination
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OFUME V. DTA
of eligibility for the categorical public assistance provided under the Federal-State programs;
… and other forms of financial assistance to families and individuals as needed.
In order that said services be adapted, organized and coordinated to meet the needs of certain population groups, each community service center shall provide financial assistance programs for:
(a) families, children and unmarried parents, which program shall, among other objectives, serve to assist, strengthen and encourage family life for the protection and care of children, assist and encourage the use by any family of all available resources to this end;…
(d) provide the range of transitional assistance financial assistance services on a fair, just and equitable basis to all people in need of such services;
(D) Subject to appropriation, the department shall administer a program of emergency assistance to needy families with children and pregnant woman with no other children, subject to and in accordance with the provisions of the Social Security Act of 1935, as defined in 42 USC 606(e), to provide benefits to avoid destitution or to provide living arrangements in a home. The commonwealth shall accept matching funds from the appropriate federal authorities for said program.
Said program of emergency assistance shall assist eligible families to prevent destitution or to
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OFUME V. DTA
provide living arrangements in the home.
The department shall promulgate rules and regulations to establish the levels of benefits available under the program and to ensure simplicity of administration in the best interest of needy recipients. Such benefits shall include, but not be limited to, the following:—
(a) for the prevention of the loss of housing, the actual liability up to three times the monthly rental or mortgage liability;
(b) for the prevention of utility shutoffs or for the resumption of utility services, up to three months of the actual service liabilities;
(c) for the provision of home heating assistance, up to three months of the actual fuel liabilities.
The department shall promulgate regulations which would authorize the department to make payments for a fourth month of rent, utility or fuel arrearages if the commissioner certifies in writing that the family would otherwise become homeless, or be without utilities or fuel.
(d) for the prevention of homelessness, temporary shelter as necessary to alleviate homelessness when such family has no feasible alternative housing available, up to the maximum period subject to federal reimbursement; storage of furniture for up to thirty days; moving expenses of up to one hundred and fifty dollars; advance rent payments of one
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OFUME V. DTA
month’s rent; and security deposit not to exceed one month’s rent.
The department shall establish procedures, consistent with federal law, to require applicants for the program to also submit an application for federal energy assistance where appropriate. No benefits for a particular emergency shall be provided to an applicant family under the emergency assistance program when benefits are available within seven days of application under the federal assistance program to meet such particular emergency.
A needy family shall be eligible for assistance under the emergency assistance program if its income is within the income limits for the program of aid to families with dependent children established pursuant to chapter one hundred and eighteen.
Emergency assistance shall not be granted to a family who, at any time within one year immediately prior to the filing of an application for emergency assistance, has made an assignment or transfer of real or personal property for the purpose of becoming eligible for such assistance.”
E. CONCLUSION/SUMMARIZED RELIEF
Reference to foregoing, the Court should grant the relief sought which are continuation of the family’s benefit and payment of all unpaid benefits. Because of the past and present hardship Plaintiff and his household have suffered and would suffer if this Relief is denied.
VERIFICATION OF COMPLAINT
I, Dr. Phillip Ofume, Plaintiff, one of the parents and representative of the Ofume family hereby respectfully verify, sign and submit the foregoing Complaint and/or that the foregoing facts and evidence are true and correct under the
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OFUME V. DTA
pains and penalties of perjury.
_______________________
Dr. Phillip C. Ofume & Co.
P.O. Box 2416 Lynn, MA 01903
Tel. (781) 479-9027,
E-mail: limptintinc@gamail.com
To:
Clerk/Magistrate of the Court (Civil Sessions)
Plymouth County Superior Court
72 Belmont St.
Brockton, MA 02301
Contact information and other particulars of the Defendant:
Massachusetts Department of Transitional Assistance (DTA)
c/o The Honourable Secretary of Justice and Attorney-General of
the commonwealth of Massachusetts
Department of Justice (Litigation)
One Ashburton Place
Boston, MA 02108 -1518
Phone: (617) 727-2200
Further copies to:
President Barack H. Obama
President of the United States of America
1600 Pennsylvania Avenue, NW
Washington, DC 20500
Vice- President Joseph Biden,
Washington Office:
Eisenhower Executive Office Bldg.
Washington, DC 20501
Honourable Eric H. Holder, Jr.
US Secretary of Justice and Attorney General,
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OFUME V. DTA
U.S. Department of Justice
950 Pennsylvania Avenue, N.W.
Office of the Assistant Attorney General, Main
Washington, D.C. 20530
The Chief of Immigration Judge
The Assistant Chief of Immigration Judge
OFFICE OF THE CHIEF IMMIGRATION JUDGE
5107 Leesburg Pike, Suite 2500
FALLS CHURCH,
Virginia, USA 22041
Ms. Mary Patrice Brown, Acting Counsel
Office of Professional Responsibility
950 Pennsylvania Avenue, N.W., Suite 3266
Washington, D.C. 20530
His Excellency, High Commissioner
United Nations High Commission for Refugees (UNHCR)
Headquarters,
Geneva, Switzerland
His Excellency, High Commissioner
United Nations High Commission for Human Rights (UNHCHR)
Headquarters,
Geneva, Switzerland
10
Friday, November 25, 2011
Monday, November 21, 2011
NIGERIA'S RACE FOR THE PRESIDENCY 2015 WILL BE ROUGH. DR. PHILLIP CHUKWUMA OFUME BELIEVES IN ROUGH RIDE.
NIGERIA'S RACE FOR THE PRESIDENCY 2015 WILL BE ROUGH. DR. PHILLIP CHUKWUMA OFUME BELIEVES IN ROUGH RIDE.
November 21, 2011
NIGERIA'S RACE FOR THE PRESIDENCY 2015 WILL BE ROUGH. DR. PHILLIP CHUKWUMA OFUME BELIEVES IN ROUGH RIDE. U.S. judicial system and other sectors captured by the Anglo/Dutch Oil/Gas company and others as one of their errand runners. See the dirty action of these sectors against Dr. Phillip C. Ofume and his family since 2005. Dr. Ofume can not open bank and other monetized accounts in the United States since the inauguration of campaign 2015. Bank and other accounts allowed prior to inauguration of campaign 2015 were severely monitored and blocked. All donations to alternative accounts blocked and returned. Dr. Ofume and family's application for U.S. Employment Authorization Document (EAD) denied and reopened/pending before the USCIS Hon. Commissioner. This family is legally employable across the United States. Dr. Ofume and his NGOs believe that all these state activities put in place by the Hon. Secretary of State, Hilary Clinton are not power, can not stop a rat, can not stop democracy and campaign for civil liberties. These bullying activities may downside and overturn the role of America in global campaign for democracy, good government and human rights.
_________________________________________________________________________________
BROCKTON SUPERIOR COURT DEPARTMENT: OBSTRUCTION OF JUSTICE, PLAINTIFF OPPOSES UNWARRANTED CONSOLIDATION OF UNRELATED CASES
November 19, 2011
This an emergency interlocutory Complaint with Motion for Short Order seeking Temporary Injunctive Relief on DHCD and the Complaint/Motion ought to be taken swiftly to stop incessant political eviction and homelessness summary process trial on November 23, 2011 to evict Plaintiff from no fault apartment which is the 8th political eviction and homelessness in less than two years against Nigeria's Presidential Candidate 2015 in-exile, Dr. Phillip Chukwuma Ofume and his family. http://www.phillyimc.org/en/ event/dr-phillip-chukwuma-ofume-president-nigeria-2011-complete-political-manifesto
Simple Order on DHCD to pick up its forgotten responsibility is what the Court should issue on DHCD. The landlord, RST Investment Company (white) want DHCD to sign the lease because they don’t trust Plaintiff (Black).
Under the command of the Hon. US Secretary of States, without overdue rent and mandatory notice to quit per one year lease legislation, white landlord proceeded to court and used his/her reserved properties (court staff and sheriff – over 97.8% whites) to quickly process and sign eviction summons and served a Blackman and his family in time when the cold and snow seasons are corrosively in force in Massachusetts.
What reason stays behind mind that this landlord did not issue this notice in hot/warm season or summer? Answer is that they want the Department of Children and families (DCF) or Department of Social Services (DSS ) to seize the children of the Plaintiff to be seized and to destroy this black family which has 100% smart/talented/ gifted/A/A+/B+ Children. Cold/snow seasons are the seasons when DCF uses criminal sympathy to seize the children of non-whites. Secretly, seizure and destruction of the children of this political bloc are major reasons the Congress and other lawmakers of the United States created DCF in the United States of America. Non-whites are the major target of DCF’s clandestine and other operations..
These whites know that the court, police and sheriff (97.8% whites) are their properties and the court is severely corrupt and that Blackman has no security in the court. Judges, Attorneys/lawyers, Court Clerks, Court and other officials, etc are none of its own.
Order of this Court sought is properly within its complete jurisdiction, subject/personal jurisdictions to transfer soft and meritoral responsibility to DHCD or takeover an outstanding shelter benefits (over seven months unused and renewable shelter benefits).
Thorough research shows clear faces of possible OBSTRUCTION OF JUSTICE, and reason PLAINTIFF OPPOSES UNWARRANTED CONSOLIDATION OF UNRELATED CASES.
Consolidation will destroy the four different law suits such as 1. Police arrest, improper and punitive handcuff, parade of children and adult before the public, charges, and prosecution; 2. transfer of family unused shelter benefits from city to city; 3. unlawful impounding, seizure, confiscation and possession of properties and goods valued over $60million; 4. payment of child and adult benefits.
People of justice and just rule, how are all these cases similar and bear same fact and evidence to warrant merger or consolidation? Across the United States particularly district/county/state courts several Blacks like the Plaintiffs lack security within the judicial system.
Majority of the courts is with the horns of white judges and attorneys/lawyers at the rate of over 98% in horn of global multi-cultural/racial/ethnic/color federation. If these cases were filed by whites, this Judge will not use the phrase, "there are the same."
There is deliberate delay in issuance of summons upon defendants. This court is suspected to be involved in this serial political eviction which involves hasty engineering to render Plaintiff homeless as track to re-seize Plaintiff's children by the defendants, Department of Children and Families (DCF) et al.
Reason of the foregoing, Publishers will move immediately to file Complaint via test of horizontal remedy because section 3B(A) of the CJC will waste time.
Further research unearthed excellent fact/evidence to the extent that the Presiding Hon. Justice (name reserved) was former Commissioner of the Department of Social Services (DSS) or Defendants which changed its name to DCF because of crime against humanity which comes with and follows this name (DSS) to the sand.
Researched/Investigated/Published:
Phillip Ofume, Ph.D. Chair, National & International Policy Research
Council; Head, Law Reform and Litigation and Security Policy Council;
Candidate in Exile - Nigeria's Presidential Election 2015; National
Chair, Canadian Sociology and Anthropology Association -Anti-Racism
Committee (p)
.
Godson Etiebet, Ph.D. Researcher, (Policy/Good Government) National
and International Policy Research Council Coordinator, Europe Section,
Switzerland
Cynthia H. Taylor, Ph.D./Alh. (Dr.) Farruk Mohammad Strategic
Development Researchers - International Policy Research Council,
Middle East Project
Tan Ochollu, D.Lit. Principal Researcher, (Strategic Development)
National and International Policy Research Council Director of Asia
Project
Reid MacDonald, Ph.D. Coordinator, North America Section
Kris Kifindi Bunkheti, Ph.D. - Sept 2007 - present continued to be
detained/imprisoned by the PM of Canada Stephen Harper Researcher
(Language/Culture), National and International Policy Research Council
York University (Department of History) Toronto, Ontario Canada (p)
Jerome Tesfai, D. Min/Div Principal Researcher, Policy and Practice in
Government and Foreign Interveners - Africa Project
Francois Bourgeois/Pierre Bushel
International Human Rights Watch and Democracy - St. Etienne, France
Send Comment to: Ihrwa4re...@hotmail.com for Europe Section
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).
Contact:
P. O. Box 25153 Halifax, Nova Scotia Canada B3M 4H4 Phone: (902)
832-3559 Fax: (902) 832-3558 E-mail:
federr...@hotmail.com,sis_mc...@hotmail.com for North/South Americas ;
Africa ; Middle East ; Asia ; Australia ; etc.
In the United States of America:
Dr. Phillip C. Ofume
Websites: "Dr. Phillip Ofume";
etc E-mail: globalaids_hivcureinteract...@yahoo.co.uk ,
confid1...@hotmail.com
Disclaimer: We have experienced series of high handed cyber attacks
such as deleting of words and sentences from our write-ups; distorting
and confusing the meaning of our letters/report/advertisement/
articles; returning and destroying our e-mail and snail mail; changing
and distorting write-ups on-line; importing strange ideas into our
write-ups; etc. In the light of this, we hereby advise you to
disregard the activities of these cyber-vultures and contact us for
signed hard copies directly from the Publishers.
-------------------------------------------------------------------------------------------------------------------------
COMMONWEALTH OF MASSACHUSETTS
Brockton, ss.
SUPERIOR COURT DEPARTMENT
OF THE TRIAL COURT
CIVIL ACTION NO.
_______________________________________________________________________________
Phillip Ofume (self and on behalf his family) Plaintiff (Pro se & Forma Pauperis)
v
Massachusetts Department of Housing and
Community Development (DHCD) - Division of
Housing Stabilization and Self-sufficiency (DHS)
Defendant
Community Development (DHCD) - Division of
Housing Stabilization and Self-sufficiency (DHS)
Defendant
_________________________________________________________
COMPLAINT FOR EMERGENCY TEMPORARY INJUNCTIVE RELIEF FOR TRANSFER OF SHELTER BENEFITS FROM HOLYOKE TO BROCKTON, MA TO AVERT POLITICALLY NDUCED FURTHER HOMELESSNESS VIA SWIFT EVICTION UNDER ON-GOING SUMMARY PROCESS/ PROCEEDINGS BEFORE BROCKTON DISTRICT COUR. RELIEF SOUGHT PURSUANT TO M.G.L. c. 23B, section 30;106 CMR. s. 309.010 309.020 309.021 309.030 309.039 309.040 309.047 309.050; Section 8 U.S. Housing Voucher Reform Act.
_____________________________________________________________
COMPLAINT FOR EMERGENCY TEMPORARY INJUNCTIVE RELIEF FOR TRANSFER OF SHELTER BENEFITS FROM HOLYOKE TO BROCKTON, MA TO AVERT POLITICALLY NDUCED FURTHER HOMELESSNESS VIA SWIFT EVICTION UNDER ON-GOING SUMMARY PROCESS/ PROCEEDINGS BEFORE BROCKTON DISTRICT COUR. RELIEF SOUGHT PURSUANT TO M.G.L. c. 23B, section 30;106 CMR. s. 309.010 309.020 309.021 309.030 309.039 309.040 309.047 309.050; Section 8 U.S. Housing Voucher Reform Act.
_____________________________________________________________
A. COMPLAINT AND RELIEF PROFILE
Here comes, Phillip Ofume, Plaintiff, and moves this Honourable Court for Emergency Temporary Injunctive Relief, nature of Transfer of Shelter Benefits from Holyoke, MA to Brockton, MA and seeks further temporary injunctive relief under humanitarian and compassionate ground aimed at stopping endless politically imposed homelessness and horrifying economic persecution directed against the Plaintiff and his family because of his bid for the President of Nigeria 2007, 2011 and 2015 and further urgent consideration of stopping the on-going trump up and moneyed Summary Eviction Proceedings filed by the Landlord (506 Warren Avenue Apartment #2 Brockton, MA 02301) pending and returnable for November 23, 2011 before Brockton District Court (EXHIBIT A) pursuant to M.G.L. c. 23B, section
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PHILLIP OFUME V. DHCD
30;106 CMR. s. 309.010 309.020 309.021 309.030 309.039 309.040 309.047 309.050; Section 8 U.S. Housing Voucher Reform Act . Defendant is aware that the eviction action of its Vendors (New England Farm Workers Council et al) on January 31, 2011was illegal, extra/pre-judicial, administratively incorrect and unconstitutional but Defendant allowed Plaintiff and his family to be punitively drifting from homeless to homeless. The eviction of the Plaintiff on January 31, 2011 by the vendors of the Defendant is politically manifested and Counsel (Mr. Michael E. Malamut) for the Defendant tasked its Vendor, that its action is , “based on lack of subject matter jurisdiction, lack of personal jurisdiction, insufficient process, insufficient service of process, failure to state a claim upon which relief may be granted, and failure to exhaust administrative remedies.”(January 28, 2011) EXHIBIT B:
A. PARTIES
1. Plaintiff and his family are family of nine (9) people (hereinafter, “two parents and seven children”) and resident of Brockton, Massachusetts within the jurisdiction of this honourable Court. Plaintiff is a potential presidential candidate campaigned and campaigning for the President of Nigeria 2007, 2011 and 2015. Opponents have several billions of dollars to fight him and they have adapted homelessness and cruel economic sanction and persecution as tools to disrupt his campaign.
2. Defendant, Department of Housing and Community Development("DHCD"), Division of Housing Stabilization and Self-sufficiency ("DHS") is agency of the Commonwealth of Massachusetts.
B. UNARGUABLE MATERIAL FACTS AND JURISDICTION
3. Apartment (basement) located at 177 Sargeant Street (B) Holyoke, MA 01040 was granted Plaintiff and his family by the Defendant (Massachusetts Department of Housing and Community Development - DHCD) on September 03, 2010 under Family Shelter Program hosted by the Division of Housing Stabilization and Self-sufficiency Program pursuant to M.G.L. Part I Title II Chapter 23B Sect. 30; 106 CMR 309.040(C); and M.G.L. c. 18 section 2 and the amortization period was September 3, 2010 through September 3, 2011 and maybe renewed if the housing stabilization and self-sufficiency programs for the client, family have not be completed within the initial period. EXHIBIT C.
4. On September 3, 2010 when the shelter was issued to the Plaintiff and his family, the Vendor made them to sign some documents which the vendor uses to get district, state, and federal monies and other
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services for families and homeless people. Vendor said that there were no other documents to sign and caseworker advised Plaintiff and his family to work hard to find job and permanent housing by themselves.
5. On September 6, 2010 two members of Plaintiff’s family (hereinafter, “Mother and son”) traveled to Lynn, Peabody, Boston, Worcester and Salem to attend job interviews and thereafter, they were hired and this effort angered Defendant’s vendor because families and homeless people are multi-million dollars bounty for the vendors. The tag placed on Plaintiff and his family is classified as licensee but with rights under the Constitution and Bill of Rights of the United States. Internally and secretly, they (vendors) don’t want families and homeless people to meet housing stabilization and self-sufficiency target which will make them (clients or licensees) leave the shelter.
6. On September 9, 2011, surprisingly, vendor emerged with several documents and issued force-to-sign threat with eviction notice should Plaintiff fails to sign several in-house rules which the vendors created and because of the threat homelessness and movement of his children to another school district within six days of registration, Plaintiff signed the ones he could sign immediately and abide by the rules but anger of the vendor persisted because Plaintiff and his family are en route to housing stabilization and employment self-sufficiency and independence. EXHIBIT D
7. Swiftly and cruelly, Vendor terminated Plaintiff’s shelter (177 Sargeant Street (B) Holyoke, MA 01040) by forging and duplicating violation in several fictitious parts and administratively, Plaintiff appealed the termination notices served on him but under political alliance with Plaintiff’s political opponents, Vendor without the consent of its employer (hereinafter, Defendant) ignored all the administrative processes and proceedings and duplicated the proceedings and commenced new Complaint at the Springfield Superior Department.
8. Plaintiff filed Motions in opposition for want of jurisdiction of the subject matter and when the Superior Court department in Springfield exhibited multiple signs of failure of justice and corruption Plaintiff filed Motion for Change of Venue but the presiding Judge forced and forced the summary process and proceedings to evict Plaintiff and his family on January 31, 2011. The same horrible, rushed, terrorizing and moneyed court summary process and proceedings to evict Plaintiff and his family were commenced and achieved in the Massachusetts Northeast Housing Court (Lynn Session) on August 3, 2011and immediately Plaintiff and his family relocated to Brockton, MA Plaintiff’s political opponents led by the Anglo-Dutch Oil/Gas Company (hereafter, “Shell Company”) moved to Brockton with millions of dollars and captured the District Court, Sheriff, etc and signed eviction summary process and
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proceedings to evict Plaintiff and his family without probable cause advisement, swiftly to be returned for eviction on November 23, 2011.
9. In Springfield Superior Court, majority of the documents filed by the Plaintiff was censored and failed to reach the desk of the Judge where action will be taken. Everything happened within a period less than one month eviction was carried out when appeals and stay of execution were pending and active within the statutory appeal period.
10. The first decision/order was made on January 24, 2011 and within 48 hours Plaintiff filed Motion for Reconsideration, and also filed NOTICE OF APPEAL AND EMERGENCY MOTION FOR STAY OF EXECUTION (to both courts below and above) and requested the Clerk to forward records of proceedings to Massachusetts Court of Appeals, Boston, MA. Copies of these documents were forwarded to the Mass Court of Appeals as an ID pending transmission of these records by the Clerk below. The Chief Justice of the Commonwealth of Massachusetts Trial Court (Administration) was severally petitioned. 2006 – 2008, below several cases filed by Plaintiff and his NGOs were mismanaged by agencies and trials courts and “mandamus” petitions and proceedings remain stocked and unattended before the Commonwealth of Massachusetts Supreme Judicial Court and the Supreme Court of the United States. This severe form of corruption led to case article and publication.
11. While the Clerk continued to censor records of proceedings, information revealed that on January 27, 2011 in a rush the Judge denied Plaintiff’s Motion for Reconsideration. Further information stated that the appealable decision/order was mailed from Springfield, MA by regular mail on January 28, 2011 and the mail will spend about two to three days to arrive in Holyoke, MA where Plaintiff lived. Before January 31, 2011 NOTICE OF APPEAL AND EMERGENCY MOTION FOR STAY OF EXECUTION to Massachusetts Court of Appeals and services made below and above and parties but under this politically maneuvered moneyed action, on January 31, 2011 the vendor paid Holyoke Police and Sheriff to evict Plaintiff in disrespect of the power and relevance of the operating judicial system.
C. PRELIMINARY ARGUMENT
COUNT 1
EMERGENCY TEMPORARY INJUNCTIVE RELIEF
12. Campaign for democracy, civil rights and bid for the President of Nigeria 2007, 2011 and 2015 are cumulative, being the core reason, the persecution in the United States, Canada, Togo and Nigeria has no
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PHILLIP OFUME V. DHCD
lapse but escalates from severe to severe. For example, August 2009 through 2011, Plaintiff and his family were rendered homeless for over seven times in Massachusetts and Virginia, children were seized and punished, Employment Authorization Documents and other services were denied. Now the income of the family (parents and children including child born in the United States) is $0.00. Foreign politicians and their allies opponents of the Plaintiff, Department of Children and Families (DCF) and clandestine child adopters which the Canadian Government has exposed per massive disclosures dated September 2, 2011 as being thieves who have October 2005 through present, drew and stole over $150,000.00 (ONE HUNDRED AND FIFTY THOUSAND CANADIAN DOLLARS) of Plaintiff’s children benefits and at same time fight to influence landlords, courts and service providers to create homelessness as thoroughfare to seize these children as further alternative route to elude this theft and prosecution have commenced another eviction proceedings in Brockton, MA on October 25, 2011 to re-seize these children. When related case was reported at Brockton Police Department, officers intimidated Complainant and branded her psychiatric and lunatic patient. EXHIBITS A {(Eviction Notion, 10/25/11) & M (Order of the Presiding Justice of The Holyoke Juvenile Court, 02/08/2011)}.
13. Somehow like chameleon style, on January 28, 2011 the Commonwealth of Massachusetts ( Defendant) filed further CounterClaim against the action of its Vendor to exonerate it’s from the administrative procedural disobedience of its Vendor. Motion Appearance, 01/28/2011 EXHIBITS E.
14. The eviction of the Plaintiff on January 31, 2011 by the vendor of the Defendant is politically manifested and Counsel (Mr. Michael E. Malamut) for the Defendant tasked its Vendor, that its action is , “based on lack of subject matter jurisdiction, lack of personal jurisdiction, insufficient process, insufficient service of process, failure to state a claim upon which relief may be granted, and failure to exhaust administrative remedies.”(January 28, 2011). EXHIBIT E
15. The Family Shelter under dispute is active from September 3, 2010 to September 3, 2011 and the Plaintiff and his family used the shelter benefits upto January 31, 2011 at 9.45 a.m. and renewable. Seven (7) months of the initial shelter benefits are unused and must be transferred to 506 Warren Avenue, Apartment 2, Brockton, MA 02301. The particulars of the Landlord is RST INVESTMENT GROUP LLC (Landlord Connections) 561 Main Street, Brockton, MA 02301 Tel. (508) 586-7368. Homeless trips from Lynn to the present homeless are questioned as to whether there is reason Defendant did not transfer the benefit as an abortive velum to stop the homeless and seizure of Plaintiff’s children pursuant to M.G.L. c. 23B sec. 30 et al.
16. The position of the Defendant in para 14 is subject to exemplification question whether Defendant
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PHILLIP OFUME V. DHCD
erred for watching Plaintiff and his family pass through hell without transferring the family’s unused shelter benefits in order to save them from drifting into further homelessness as the present landlord is trying to do under this longstanding “moneyed political lottery.” Defendant allowed Plaintiff’s children to be seized by the Department of Children and Families (DCF) without providing Voucher to place them in Hotel pending locating the family into another emergency shelter pursuant to M.G.L. c. 23B sec. 30.
COUNT II
D. ARGUMENT
REASON M.G.L. c. 23B s. 30 UNDER EMERGENCY HOUSING ASSISTANCE PROGRAM MUST BE INVOKED TO PREVENT FURTHER HOMELESSNESS, SUFFERING OF CHILDREN AND PARENTS AND SEIZURE OF CHILDREN
17. Incessant or over seven evictions in less than two years, frequent change of the schools of Plaintiff’s children fail to meet the standards of the civilization of America particularly 1st and 4th Amendments to the Constitution and Bill of Rights of the United States. Action of selfish and cruel politicians against Plaintiff and his family has captured a large array of national and international public and distorted the district, state and federal judicial systems of the United States of America. Governments of Canada and America are at fault because they allowed invaders to take center stage to abuse Plaintiff and his family to the ugly extent of allowing children and highly qualified and employable parents to live under $0.00 income as if America is the poorest country and as result their children were seized. EXHIBIT M.
18. . No answer as to why a hardworking family could be severely published for working hard to leave emergency shelter and relief the Commonwealth from further costs by finding job. If the mandates of the Defendant are Housing Stabilization and Self-sufficiency Program it is off-correctness for this family to be punished, rendered homeless and seize its children. On September 3, 2010 Defendant granted Plaintiff and his family a temporary emergency family shelter located at 177 Sargeant Street Basement, Holyoke, MA 01040 through a Vendor mentioned above. The shelter assistance is one year and renewable. Under Housing Stabilization and Self-sufficiency Program, two members of the Plaintiff traveled to Lynn, Peabody, Boston, Worcester and Salem to attend job interviews and thereafter, they were hired. Because of this good efforts, Defendant’s Vendor terminated the emergency shelter and ignored the advice of the Defendant and on January 31, 2011 evicted Plaintiff and his family and seized their children. Defendant opposed the action of its vendor but since January 31, 2011 the Defendant has not transferred the unused shelter benefit to Lynn or Brockton.
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PHILLIP OFUME V. DHCD
HUMANITARIAN AND COMPASSIONATE GROUND
19. Plaintiffs and other dependent family members and wife are 9 (two parents and seven children) without income to the extent effective November 7, 2011 only reduced rate on cooking gas was allowed or granted and major services in support of core means of livelihood such as Employment Authorization Documents (EAD), food stamp and cash benefit pending employment, etc. were denied. EXHIBITS F & G.
20. Plaintiffs and their family members are Convention Refugees and Prisoners of Conscience adopted oversea by the United Nations High Commission for Refugees (UNHCR) and Amnesty International (Intl. Secretariat, London, UK) and they have right to work and receive other transitional services pending employment. EXHIBITS H
21. Without reason USCIS Nebraska Service Center directed that no Employment Authorization Document (EAD) be granted all members of the family. Punitively, only one year of six years of their residence in US EAD was granted parents and two children (April 29, 2010 – April 29, 2011). January 1, 2011 renewal application was made and after nine months denied and Motion for Reconsideration filed and pending before USCIS’s Commissioner. EXHIBITS I & J.
22. Without legal reason. Massachusetts Department of Transitional Assistance (DTA) commanded stay of grant of other services such as child benefits, food stamps to adult and under 18-year children, cash benefits, etc. suspected to design child removal forum. November 2011 is the ninth month when application for these services were made in Lynn and Brockton DTA district offices but no hearing has been conducted. Full transfer , Lynn, MA to Brockton, MA has been made but no assistance has been granted including expedite food stamps assistance to under 18 years children pending appeal, EAD and employment.
23. On October 29, 2011 one family member ( child) who was working was stopped because of failure of the USCIS Nebraska Service Center to renew his and others EAD. His Employer is CARRRABBAS ITALIAN GRILL EXHIBIT K [1 Newbury St # A Peabody Tel. (978) 535-3600].
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24. Now the income of all the children is $0.00 because the governments of Canada and US refused to pay their benefits. Income of one US born child is $0.00. No consideration was made under humanitarian ground. Parents’ income is $0.00. Is possible in US and Mass for Children born in US and Canada and other children who are lawful immigrants in US and under 18 be denied food stamps and other services when parents are not working? Whether is possible for families small and large to live and survive under $0.00.
25. Plaintiffs have rents and utility arrears because Department of Housing and Community Development (DHCD) January 31, 2011 – present, has not responded to Plaintiffs’ request for Transfer of Plaintiffs’ shelter benefits from Holyoke to present apartment pending reconsideration of their application for EAD and employment. The statutory time line for agency to respond to this type of application has long past. See on-going case before this Court upon which Motion/relief for Waiver of all costs are filed/sought, Docket No, 11-1260. EXHIBIT L.
26 . Parents have adequately and satisfactorily met their obligation as parents by earning score of academic and professional qualifications which include but unlimited to Doctorat du 3e Cycle (DEA, D.E.Phil), Lyon France; Doctorat du 3e Cycle (DEA), Lyon France; Scolarite au Doctorat du 3e Cycle (S.Dr.), Lyon France; M.Sc. (1/2) Lyon France; M.Phil., Lyon France; B.Phil., Lyon France; D.E.F. (Lyon/Geneva); Post-doctoral studies: Ph.D. (Min.) (on-going) NY USA; Juris-doctor, Canada/USA (on-going with over 35 years law study, practice, research, and investigation). NCMP - Mediation Negotiation and Conflict Management ( Dalhousie University ,Law School); NCMP - Negotiation and Conflict Resolution (Dalhousie University, Law School) ; NCMP -Advanced Mediation (inter-governmental and large corporate body mediation and conflict management and resolution, (Dalhousie University, Law School); Cert. Info Tech. – Mass and Strategic Communications; etc Phillip Ofume speaks English, French and Nigerian languages.
27. Deeply, at present Plaintiffs and their entire household fall under U.S. state and federal poverty levels, unable to pay rents, court costs, utilities, mailing and transportation, etc. because of the political action sponsored and paid by lead Plaintiff’s political opponents because of the greed aimed at acquiring oil/gas in Plaintiffs’ native place of origin, THE NIGER DELTA REGION of Nigeria which is direct retaliatory manifestation as an opposition to lead Plaintiff’s bid for the President of Nigeria 2007 – 2015 and campaign for civil liberties . Issue maybe raised as to whether the injury which Plaintiffs and other members of their family suffer exemplifies part or any of America’s democratic civilization? The answer is No. the world.
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PHILLIP OFUME V. DHCD
E. CONCLUSION/SUMMARIZED RELIEF
Reliant on the foregoing including EXHIBIT B, consciously reasoned that the Defendant is aware that the eviction action of its Vendors (New England Farm Workers Council et al) on January 31, 2011was illegal, extra/pre-judicial, oversight and wild claims, administratively incorrect and unconstitutional but Defendant allowed Plaintiff and his family to be punitively drifting from homeless to homeless, suffer seizure and removal of their children into cruel hands where the children suffered pains and hardship thus in this Complaint, Plaintiff and his family seek no additional costs for what they suffered and Plaintiff strongly request this Honourable Court to issue Order upon Defendant to continue the Shelter benefits at 506 Warren Avenue Apartment #2, Brockton, MA 02301 immediately effective November 1, 2011 pursuant to M.G.L. Part I Title II Chapter 23B Sect. 30; 106 CMR 309.040(C); and M.G.L. c. 18 section 2 and renewable pending USCIS’s grant of Employment Authorization Document (EAD) and employment and purpose of urgent consideration based on timing of EXHIBIT A to stop Plaintiff’s and family’s further homelessness and seizure/removal of their children.
VERIFICATION OF COMPLAINT
I, Dr. Phillip Ofume, Plaintiff, one of the parents and representative of the Ofume family hereby respectfully verify, sign and submit the foregoing Complaint and/or that the foregoing facts and evidence are true and correct under the pains and penalties of perjury.
_______________________
Dr. Phillip C. Ofume & Co.
P.O. Box 2416 Lynn, MA 01903
Tel. (781) 479-9027,
P.O. Box 2416 Lynn, MA 01903
Tel. (781) 479-9027,
E-mail: limptintinc@gamail.com
To:
Clerk/Magistrate of the Court (Civil Sessions)
9
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PHILLIP OFUME V. DHCD
Plymouth County Superior Court
72 Belmont St.
Brockton, MA 02301
72 Belmont St.
Brockton, MA 02301
Contact information and other particulars of the Defendant:
Massachusetts Department of Housing and Community Development
c/o The Honourable Secretary of Justice and Attorney-General of
the commonwealth of Massachusetts
Department of Justice (Litigation)
One Ashburton Place
Boston, MA 02108 -1518
Phone: (617) 727-2200
the commonwealth of Massachusetts
Department of Justice (Litigation)
One Ashburton Place
Boston, MA 02108 -1518
Phone: (617) 727-2200
Further copies to:
President Barack H. Obama
President of the United States of America
1600 Pennsylvania Avenue, NW
Washington, DC 20500
President Barack H. Obama
President of the United States of America
1600 Pennsylvania Avenue, NW
Washington, DC 20500
Vice- President Joseph Biden,
Washington Office:
Eisenhower Executive Office Bldg.
Washington, DC 20501
Honourable Eric H. Holder, Jr.
US Secretary of Justice and Attorney General,
U.S. Department of Justice
950 Pennsylvania Avenue, N.W.
Office of the Assistant Attorney General, Main
Washington, D.C. 20530
The Chief of Immigration Judge
The Assistant Chief of Immigration Judge
OFFICE OF THE CHIEF IMMIGRATION JUDGE
5107 Leesburg Pike, Suite 2500
FALLS CHURCH,
Virginia, USA 22041
Ms. Mary Patrice Brown, Acting Counsel
Office of Professional Responsibility
950 Pennsylvania Avenue, N.W., Suite 3266
Washington, D.C. 20530
10
Washington Office:
Eisenhower Executive Office Bldg.
Washington, DC 20501
Honourable Eric H. Holder, Jr.
US Secretary of Justice and Attorney General,
U.S. Department of Justice
950 Pennsylvania Avenue, N.W.
Office of the Assistant Attorney General, Main
Washington, D.C. 20530
The Chief of Immigration Judge
The Assistant Chief of Immigration Judge
OFFICE OF THE CHIEF IMMIGRATION JUDGE
5107 Leesburg Pike, Suite 2500
FALLS CHURCH,
Virginia, USA 22041
Ms. Mary Patrice Brown, Acting Counsel
Office of Professional Responsibility
950 Pennsylvania Avenue, N.W., Suite 3266
Washington, D.C. 20530
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PHILLIP OFUME V. DHCD
His Excellency, High Commissioner
United Nations High Commission for Refugees (UNHCR)
Headquarters,
Geneva, Switzerland
His Excellency, High Commissioner
United Nations High Commission for Human Rights (UNHCHR)
Headquarters,
Geneva, Switzerland
11
United Nations High Commission for Refugees (UNHCR)
Headquarters,
Geneva, Switzerland
His Excellency, High Commissioner
United Nations High Commission for Human Rights (UNHCHR)
Headquarters,
Geneva, Switzerland
11
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