LIMPT, INC.

MASS COURT OF APPEALS & SUPREME JUDICIAL COURT: CORRUPTION OF THE JUDGES & CLERKS PUTS CITIZENS IN DANGER

_______________________________________________________________________

OGECHI EKE V. DCH DOCKET NOS. CA 2013-P-0791, SUCV 2012-4516 – A & CP10B0179

COMMONWEALTH OF MASSACHUSETTS

APPEALS COURT

______________________________________________________________________

CIVIL APPEAL NO.2013-P-0791

LOWER COURT CONSOLIDATED CIVIL ACTION DOCKET NOS. SUCV 2012-4516 – A & CP10B0179

______________________________________________________________________

OGECHI EKE

Petitioner/Defendant (Pro se)

and

PHILLIP OFUME (LIMPT, INC. -

EDUCATION AND WORK FORCE PROJECT)

Intervenors /Child Civil Rights Advocate

MASSACHUSETTS DEPARTMENT OF CHILDREN AND FAMILIES (DCF)

Respondent/Plaintiff

_______________________________________________________

ON APPEAL FROM THE FINAL JUDGMENT (10/09/2012) OF THE PRESIDING HONOURABLE JUSTICE PAUL LEVIS OF THE BOSTON JUVENILE COURT DENYING THE BIOLOGICAL PARENT’S RIGHT TO REGAIN CUSTODY AND CARE OF HER ONLY CHILD

________________________________________________________________

BRIEF OF THE APPELLANT AND INTERVENORS/CHILD CIVIL RIGHTS ADVOCATES

________________________________________________________________

Ms. Ogechi Eke

143 Columbia Road Apt. #11

Dorchester, MA 02121

Tel. (617-436-3589

E-mail:emayoge@yahoo.com

OGECHI EKE V. DCH DOCKET NOS. CA 2013-P-0791, SUCV 2012-4516 – A & CP10B0179

July 5, 2013

A. STATEMENT OF ISSUES

1. In public interest question, law particularly local and international laws of freedom of movement and association whether it is unlawful to travel to Nigeria to attend burial when there were no court and other Order placing travel restriction on parent and her child.

2. Should any Court in the United States remand an enfant an deprive the right to her biological parents because the child was accompanying her biological parents to their country of origin (hereinafter “Nigeria”).

3. Between 2004 and April, 2011 which is about seven(7) years of no fault care and custody by the single Parent, Ms. Ogechi Eke and about 24hours to/from Canada whether the respondent established a case of child abuse which warrants removal of this child in April 2011.

4. Whether the Judges below erred when they found no case of Child abuse against the biological mother and failed to return custody to the biological mother.

5. Whether the Judges below erred for keeping the subject child in foster care when they (Judges) found via the confession of the subject child of eminent child abuses by the foster parents including subject child’s confession that the over 60 years reverend foster father sleeps with the 8-year beautiful female subject child and also use the child for hard in-door labor in which the child is paid about $1.00 per day and slowly losing her prior education excellence.

B. STATEMENT OF THE CASE

6. Ms. Ogechi Eke is a Nigeria; Appellant graduated at the Nigerian University of Agriculture and she moved to the United States and in 2004 she was 4^th year student at the Massachusetts College of Pharmacy (MCPHS) and there was persecution against her and she filed Complaint with the Human Rights Commission and MCPHS retaliated aggressively and call in the Respondent, DCF in breach of 1^st Amendment of the Constitution of the United States and M.G. L. c. 186 Section 18.

7. In September 2004 Appellant was pregnant and the subject child was delivered on September 30, 2004. Under the pending persecution at MCPHS petitioned her to the respondent (DCF), her child was seized by DCF and MCPHS few days later following the birth of her child but few days later her Child was returned to her by The Honourable Justice Paul Lewis after several national and international protests.

8. Between 2004 and March 2011 Appellant was in full no-fault and permanent custody and care of her only child and/or without any allegation of child abuse. On before March 2, 2011 DCF and MCPHS steer-up hateful and unfounded allegations against the Appellant and her child. On March 2, 2011 there was a hearing and Judge Lewis denied their Motion and on March 2, 2011 Judge Lewis ordered that custody of the subject continued to remain with Ms. Eke (EXHIBIT A). Early April 2011 Appellant received emergency information from Nigeria with alert that family member died and Appellant and other members of their family were recalled to attend the burial in Nigeria.

9. Appellant and her child (subject child) prepared and bought flight ticket Boston to Abuja, Nigeria via Canada and Germany (EXHIBITS Q,R).

OGECHI EKE V. DCH DOCKET NOS. CA 2013-P-0791, SUCV 2012-4516 – A & CP10B0179

10. Appellant informed her Attorney, Amy Geary before they (Appellant and her child) departed from Boston. Appellant’s Attorney (Amy Geary) who was suspected for certain complicity in the custody case of the subject child passed allegation to the defendant and on the day of their departure the Respondent lobbied the airliners and other passage authorities to block them (Ms. Ogechi Eke and subject child).

11. In Canada the airlines and other mounted and paid operatives stopped them and within 24 hours they were returned to Boston immediately and the Respondent, DCF rushed to Judge Lewis and for no just reason, there was an emergency hearing and Appellant’s Child was seized and placed in the on-going abusive foster parents because Appellant and her daughter attempted to travel to Nigeria to attend family burial (see Ogechi Eke v. Air Canada et als – U.S. District Court of the District of Massachusetts).

C. PRELIMINARY STATEMENT OF ARGUMENT

Appellant requests leave of this Court to assign numbers to all the paragraphs and sub-paragraphs of this Argument to secure the content of her brief.

12. Courts and Judges below failed to take any position on whether between September 2004 and April 2011 there were any child abuse allegations brought against Ms. Eke. If there is no child abuse case or allegation against her what case has been established against Ms. Eke to warrant removal of her only child and place such a smart/gifted/brilliant/talented child in abusive foster care.

OGECHI EKE V. DCH DOCKET NOS. CA 2013-P-0791,SUCV 2012-4516 – A & CP10B0179

13. If Courts and Judges below failed to take any position on para 12 above next strand is whether travelling to Nigeria to attend family burial is a crime which could lead to seizure of the subject child.

14. If Courts and Judges below failed to take any position on para 13 above next and final question is whether there is any travel ban or restriction on Ms. Eke and the subject child in the ENTIRE Decisions of Judge Lewis dated March 2, 2011 and other decisions of Judge Lewis and other Judges since 2004 and before April 2011. Particularly between March 2, 2011 and April 2011 when Ms. Eke and the subject child were returned from Canada to Boston were there any child abuse allegations against Ms. Eke to trigger seizure of the subject child? There was no child abuse case or allegations.

15. Actions of Judge Lewis and DCF are severe violation of the 1^st, 5^th, 14^th Amendment of the Constitution and Bill of rights of the United States to the destructive extent that on before and after April 2011 the child was seized because of the secret and deceptive activities between Ms. Eke’s attorney and DCF and Ms. Eke was not allowed to attend meetings, appear during majority of the hearing and negotiations before the court below ; read and see documents (agreements, court briefs, affidavits, etc) filed in court and submitted to parties and others by Attorney Amy Geary. To block these evidences, the clerk and Judge Lewis over ruled the rights of Ms. Eke and her Intervenors to get the large transcripts in this case which is detailed history of the proceedings between 2004 and present in the Boston Juvenile Court.

OGECHI EKE V. DCH DOCKET NOS. CA 2013-P-0791,SUCV 2012-4516 – A & CP10B0179

16. Actions of Judge Lewis and DCF are severe violation of the 1^st, 5^th, 14^th Amendment of the Constitution and Bill of rights of the United States to extent that Appellant was not informed when her ONLY child was secretly sold to a Nigerian Reverend Father and an Indigenous African American foster mother who is the wife of this reverend father who are supported by the Court below to abuse and destroy her child. From court to court protection was extended to Judges, Foster Parents, schools attended by the subject child, Clerks/Magistrates, DCF, MCPHS, etc to cover the abuses the subject child has been suffering.

D. STATEMENT OF FACT

17. On before 2004 Ms. Ogechi Eke, mother of the subject child was a Pharmacy Student at the Massachusetts College of Pharmacy and Health Sciences (MCPHS) and Appellant was pregnant and she was facing a serious persecution at MCPHS because complaint against MCPHS to the Human Rights Commission, her disfavored Nigerian ethnic group in the United States and her campaign for child and woman rights and the complicity in Nigeria/Biafra civil war 1967-1970 have earned her severe forms of persecution at MCPHS. To implement this persecution, MCPHS collaborated with the DCF, Court below and others.

18. The subject child was delivered on September 30, 2004.

19. Under the pending persecution at MCPHS, Ms. Eke’s college petitioned her to the respondent (DCF) and her child was seized by DCF and MCPHS few days later following the birth of her child but few days after the seizure, the Boston Juvenile Court returned her Child to her.

OGECHI EKE V. DCH DOCKET NOS. CA 2013-P-0791,SUCV 2012-4516 – A & CP10B0179

20. Between 2004 and March 2011 Appellant was in full and permanent custody and care of her child without any allegation of child abuse.

21. On before March 2, 2011 DCF and MCPHS steer up hateful and unfounded allegations against the Appellant and her child. On March 2, 2011 there was a hearing and Judge Lewis denied their Motion and on March 2, 2011 Judge Lewis ordered that custody of the subject continued to remain with Ms. Eke (EXHIBIT A).

22. Early April 2011 Appellant received emergency information from Nigeria with alert that family member died and Appellant and other members of their family were recalled to attend the burial. Appellant and her child (subject child) prepared and bought flight ticket Boston to Abuja, Nigeria via Canada and Germany.

23. Appellant informed her Attorney, Amy Geary before they (Appellant and her child) departed from Boston. Appellant’s Attorney who was suspected for certain complicity in the custody case of the subject child passed allegation to the defendant and on the day of their departure the defendant lobbied the airliners and other passage authorities to block them.

24. In Canada the airlines and other mounted and paid operatives stopped them and within 24 hours they were returned to Boston immediately the defendant rush to Judge Lewis and for no just reason, there was an emergency hearing and Appellant’s Child was seized and placed in the on-going abusive foster parents because Appellant and her daughter attempted to travel to Nigeria to attend family burial.

25. Appellant’s Nigerian ethnic place of origin is some of the opponents inside and outside the college. When the persecution reached life-threatening level Ms. Eke petitioned the college and the academic staff to the Civil Rights Commission and The Governor of Massachusetts. Receipt of the papers of the investigation angered the Massachusetts College of pharmacy and the Department of Social

OGECHI EKE V. DCH DOCKET NOS. CA 2013-P-0791,SUCV 2012-4516 – A & CP10B0179

Services or Department of Children and Families.

26. Action taken under 1st and 5th Amendments to the Constitution and Bill of Rights of the United States was construed as MENTAL HEALTH issue and swiftly Ms. Eke was expelled from the Massachusetts College of Pharmacy without assessment and evaluation of the allegation.

27. The allegation of insanity stated above forced Appellant to attend mental health assessment and evaluation and conducted by expert with Ph.D. degree. Prior to October 9, 2012, to dismiss the falsified mental health allegation of the Massachusetts College of Pharmacy, Ms. Eke attended mental health assessment and evaluation. SERVICE PLAN, COMPLETION AND EXPERT REPORT - LOCATION OF CARE: Roxbury Comprehensive Community Health Center - Mental Health Department is herewith incorporated in support of this brief and petition for review. Name of Provider: Angela Bell, Ph.D. LMHC. Department of Children and Families (DCF), and other collaborating predominantly white department refused to accept Dr. Bell's Expert assessment and evaluation conducted on Ms. Ogechi Eke because the provider, Dr. Bell is a Black. For rejecting expert mental health evaluation and assessment because of race, color, political affiliation, religion and related intolerance is what several courts and Judges in the United States will oppose (EXHIBIT B).

28. On before October 9, 2012 the Department of Children and Families (DCF) told Judge Lewis that the Massachusetts College of Pharmacy (MCPHS) told them that Ms. Eke was excluded from the College of Pharmacy because she is "a mad woman" and Judge Lewis did not ask the DCF to show any evidence of its allegation such as Health Center - Mental Health Department where MCPHS got the assessment and evaluation that the Appellant was examined and found to be “a mad woman”. Judge Lewis agreed and Judge Lewis said, "Madam (Ms. Ogechi Eke) my judgment is that custody remains as it is" with these abusive foster parents.

29. The action of Judge Lewis and DCF angered Roxbury Comprehensive Community Health Center and Mental Health Department and

OGECHI EKE V. DCH DOCKET NOS. CA 2013-P-0791,SUCV 2012-4516 – A & CP10B0179

the Director of the Center, Ms. Coonie B. Cohen (white). In further opposition, Ms. Coonie B. Cohen signed the assessment/evaluation report of Dr. Bell (Black) on November 26, 2012. EXHIBIT C.

30. Judge Lewis saw one fake and falsified mental health allegation paper on September 30, 2004 which was created by one Daniel Audet on emergency with the intention to remove and hold custody of the child of the Appellant after Ms. Eke was drugged , handcuffed and put to sleep for over 24 hours under the moneyed sponsorship by MCPHS and DCF.

31. The paper forged by Daniel Audet was overruled by Judge Lewis few days after the subject child was removed few days in September 2004. Between October 2004 and October 2012 MCPHS and DCF have not presented before Judge Lewis any mental health assessment/evaluation to override the expert report of Dr. Bell (Black) and re-certified on November 26, 2012. EXHIBIT C.

32. Between long period of October 2004 and April 2011 the Appellant Ms. Eke made her ONLY daughter a smart/talented/gifted/A+/A/B+/honor/merit academic award winner.

33. The Presiding Honorable Justice Paul Lewis is aware that between October 2004 and early April 2011 when appellant was in full custody and care of her only child that there was no fault in terms of care, protection, and other forms of parental presence in the entire life of her child and that her child was happy, and acquired excellent educational level with several academic awards and economically above what the wealthy can do for its child. In this Brief see EXHIBITS D, E, F, G, H, I, J, K, L, M, N, O, etc. which are “heaven on earth”, personal and physical environments where Ms. Eke cared and protected her child.

34. Appellant, Ms. Ogechi Eke said, “what I do day to day to put my daughter top of her class are to give her healthy food, allow rest and sleep after school, sound teaching with quality curriculum, teach by practical example, private study and creativity, continuous and

OGECHI EKE V. DCH DOCKET NOS. CA 2013-P-0791,SUCV 2012-4516 – A & CP10B0179

comprehensive assignments and evaluation, play and interaction with other kids, etc."

35. EXHIBITS A through P : Jillian’s Books for Home School (Core curriculum Only) Learning Coach is Mom (Ogechi Eke)EXHIBIT P. 1, 2, 3, Through 115 by Ms. Ogechi Eke (Mother of Subject Child) as follows:

Book Title

Author

K12 Math+: Activity Book grade 1 semesters 1& 2

K12

K12 Math+: Lesson Guide grade 1 semesters 1 & 2

K12

K12 Math+: Activity Book grade 2 semesters 1 & 2

K12

K12 Math+: Lesson Guide grade 2 semesters 1 & 2

K12

Language Arts 1: Student Pages Semesters 1 & 2

K12

Language Arts 2: Student Pages Semesters 1 & 2

Language Arts Books (Literature or literal Study)

POMPEII Buried Alive	Edith Kunhardt
Wagon Wheels	Barbara Brenner
The Long Way to a Newland	Joan Sandin
Clara and the Bookwagon	Nancy Smiler Levinson
Chang' s Paper Pony	Eleanor Coerr
Sam the Minuteman	Nathaniel Benchley
George the Drummer Boy	Nathaniel Benchley
The Bears On Hemlock Mountains	Alice Dalgliesh
Now I am Six	Scholastic
Surprises (Poems by)	Lee Bennett Hopkins
No Fighting. No Biting	Maurice Sendak
The Long Way WestWard	Joan Sandin
Little Bear	Else Holmelund Minarik
The First Thanksgiving	Linda Hayward
A Picture of Harold’s Room	Crockett Johnson
Danny the Dinosaur	Syd Hoff
The Tales of Amanda Pig	Jean Van Leeuwen
Buddy. The First Seeing Dog	Eva moore
Te Josefina Story Quilt	Eleanor Coerr
Tye May and the Magic Brush	Molly Garrett
Frog and Toad are Friends	Arnold Lobel
Bedtime for Frances	Russell Hoban
Sam Bangs & Moonshine	Evaline Ness
Harry and the Lady Next Door	Gene Zion
Crow Boy	Taro Yashima
Robin Hood (chapter book)	Annie Ingle
Winnie-the-Pooh	A.A Milne
Knights of the Round Table	Gwen Gross
Peter Pan	J.M. Barrie
Ready…Set…Read!	Joanna Cole
*Other Books: Mrs. Piggly Wiggly, Too many to list; Jillian is a voracious Reader; Her she has a Reading Log (Over 150 books before she was snatched away.*

Language Arts Supplements

Listen, My Children (Poems for First Graders) A Core Knowledge K12

Listen, My Children (Poems for Second Graders) A Core Knowledge K12

The Legend of Blue Bonnet - Tomie DePaola

The Hundredth Name -------Shulamith Levey Oppenheim

Sundiata ---------------------- David Wisniewski

K12

Phonics 1 Student Pages Semester 1 & 2

K12

Phonics 1 semester 1 & 2 Teacher Guide

K12

Phonics 2 Student Pages Semester 1 & 2

K12

Phonics 2 semester 1 & 2 Teacher Guide

Phonics Works Video

K12

Primary Analogies Critical & Creative Thinking Book 1

Gae Brunner

Primary Analogies Critical & Creative Thinking Book 2

Jan Z. Olsen

Junior Great Books Volume 1: Grade 1

• The Black Hen’s Egg

• The Mouse & the Wizard

• Imaginations

Pegasus Series

Junior Great Books Volume 2: Grade 1

• Rumpelsiltskin

• Eeyore Has a Birthday and Two Great Presents

• “When I Grow Up”

K12

Junior Great Books Volume 3: Grade 1

• The King of the Frogs

• Snow-White and the Seven Dwarfs

• “Mysterious Animals”

K12

Junior Great Books Volume 1: Grade 2

• Chestnut Pudding

• The Pied Piper

• Fanciful Animals

K12

Junior Great Books Volume 2: Grade 2

• The Mermaid Who Lost Her Comb

• Hansel & Gretel

• Special Places

K12

Junior Great Books Volume 3: Grade 2

• Mother of the Waters

• Zlateh the Goat

• Secret Messages

Classics for Young Readers Volume 1

K12

Classics for Young Readers Volume 2

K12

Early Reading Comprehension in Varied Subject Matter Book A

Jane Ervin

Handwriting Without Tears 1^st grade;

Jan Z. Olsen

Handwriting Without Tears 2nd Grade;

Jan Z. Olsen

Sylvester and the Magic Pebble

William Steig

Hooked on Phonics! 1^st Grade

HOP Editors

Hooked on Phonics 2nd Grade

HOP Editors

Hooked on Phonics Master Reader

HOP Editors

Writing Homework

Scholastic Ref

Sciences 1 Student Pages (Semesters 1 & 2)

K12

Sciences 2 Student Pages (Semesters 1 & 2)

Science Supplements

*A Weed is a Flower ------------------------ Aliki

*Weather (poems for All Seasons) -------- Lee Bennett Hopkins

*Bright and Bold (Animals Alphabet Book⇾ Celebration Press

*What is the World Made of? Stage 1 & 2

( All About Solids, Liquids, and Gases)-- Kathleen W. Zoehfeld

*Let’s Go Rock Collecting stage 2 ------ Roma Gans

*What Happens to a Hamburger? Stage2------- Paul Showers

What Makes a Magnet? Stage 2-------------Franklyn M Branley

Why Frogs Are Wet ------------Judy Hawes

Down Comes The Rain -------------Franklyn M Branley

Flash, Crash, Rumble, and Roll -------------Franklyn M Branley

K12

History 1 Student Pages (Semesters 1 & 2)

K12

History 2 Student Pages (Semesters 1 & 2)

History Supplements

The Trojan Horse (How the Greeks Won the War) - Emily Little

Mummies ------------------------------------------Joyce Milton

Fossils stage 1& 2: ( Tell of Long Ago) -------- Aliki

Knights In Shining Armor -----------------------Gail Gibbons

K12

Arts 1 Student Pages (Semesters 1 & 2)

K12

Arts 2 Student Pages (Semesters 1 & 2)

Arts Supplement

How Artists See Play .----------- Collen Carroll

How Artists See Animals by------------ Collen Carroll

Come Look with me: Exploring Landscape Art with Children- Gladys Blizzard

Come Look with me: World of Play--- Gladys Blizzard

K12

Beginning 2 Music Student Pages Volume 2 (Semesters 1 & 2)

K12

Let’s Sing Songbook Volume 2

K12

Music software

K12

Music Supplement

• Music: Let’s Listen Volume 2

• Music: Let’s Sing Volume 2

• Music: Let’s Learn Music Volume 1 Video

• Music: Let’s Learn Music Volume 2 Video

• Music: Let’s Rhythm

• Tambourine

• Drums

• Keyboard/piano

• Instructional DVD

K12

_________________________________________________________________________________

EXHIBIT A .1, 2, 3, Through 232 strands

Jillian’s Reading Log by Ms. Ogechi Eke (Mother of Subject Child)

Week of 9/27/2009 to 10/4/2009
HOP books 24books in all- from Kindergarten Edition		HOP Books
	14 Books from Cat Tick –Tock Gets a Pal		HOP Books
	10 Books from Dad and Sam Kim Kangaroo		HOP Books

	Week of Oct13. 2009
	*Mon:* Hop on Pop
	*Tues:* The Cat in the Hat		Dr. Seuss
	*Wed:* Minnie and Moo Wanted Dead or Alive		Denys Cazet
	*Thur:* Green Eggs and Ham		Dr Seuss
	*Fri:* Fred and Ted Like to Fly		Peter Eastman
	*Sat:* My Car Trip		Sindy Mckay
	*Sun:* Three Little Bears (4books in one pack)		David Martin
	*My comment for the Week of Oct. 11. 2009* Wed. Book was hard: try reading it again. Jillian answered 90% of the questions *My goal for Jillian:* fluency in reading; answer 100% of the questions; sustain Jillian’s reading interest.

	Week of Oct18. 2009
	*Mon:* Goldilocks and the Three Bears		Jerry Smath
	*Tues:* The Three Little Pigs		Jerry Smath
	*Wed:* Are You still Mad		Ellen Weiss
	*Thur:* One Smart Goose		Caroline Jayne Church
	*Fri:* Little Bears Friend		Maurce Sendak
	*Sat:* Mumps Story Gabby is Hungry		Beverly Randell Michele Dufesne
	*Sun:* Frog and Toad Adventure Days with Frog and Toad		Arnold Lobel Arnold Lobel
	Week of Oct 25. 2009
	*Mon:* Fox in Socks		Dr. Seuss
	*Tues:* Bath time for Biscuits		Alyssa Satin Capucilli
	*Wed:* Biscuits and the Baby		Alyssa Satin Capucilli
	*Thur:* A Snout for Chocolate		Denys Cazet
	*Fri:* The Case of the Cat’s Meow		Crosby Bonsall
	*Sat:* My Car Trip		Sindy Mckay
	*Sun:* Detective Dog and the Lost Rabbit Book Slam Dunk (In the Dark)		David Martin Hop Book 17

	Week of Nov.1 2009
	*Mon:* How the Grinch Stole Christmas		Dr. Seuss
	*Tues:* Bath Time for Biscuits		Denys Cazet
	*Wed:* Chicka Chicka Boom Boom		Bill Martin
	*Thur:* A Snout for Chocolate		Denys Cazet
	*Fri:* Fly Guy Fly		Ted Arnold
	*Sun:* Yertle the Turtle		Dr. Seuss
	Week of Oct8. 2009
	*Mon:* Are You My Mother		P.D. Eastman
	*Tues:* The Tooth Book		Dr. Seuss
	*Wed:* Mouse Soup		Arnold Lobel
	*Thur:* What do You Hear When Cows Sing & Other Silly Riddles		Marco & Giulio Maestro
	*Fri:* Sammy the Seal		Syd Hoff
	*Sat:* Big Egg		Molly Coxe
	*Sun:* Inauguration Day Too Much Toothing		Lauren Brown Sanford Hoffman

	Week of Nov.15. 2009
	*Mon:* American History for Children(DVD)		The History Channel (2005)
	*Tues:* African American Life		The History Channel (2005)
	*Wed:* American Independence		The History Channel (2005)
	*Thur:* Native American Life		The History Channel (2005)
	*Fri:* Martin Luther King Jr.
	*Sat:* The Presidents		The History Channel (2005)
	*Sun:* The United States Constituting		The History Channel

	Week of Nov.22. 2009
	*Mon:* Early to Bed, Early to Rise)		Benjamin Franklin
	*Tues:* Let’s Explore the Rainforest Level 2 (ages 6-7years)
	*Wed:* Baby’s Story time (15 Best story levels)		Arco Guthrie
	*Thur:* Little Rats Sets Sail		Monika Bang-Campbell
	*Fri:* Three Stores You Can Read to Your Teddy Bear		Sara Swan Miller
	*Sat:* Andy Shane and the Very Bossy Dolores Star buckle		Jennifer Richard Jacobson
	*Sun:* Dr. Seuss ABC		Dr. Seuss

	Week of Nov.29. 2009
	*Mon:* Arthurs Reading Trick		Marc Brown
	*Tues:* Hare and Rabbit: Friends Forever		Julia Noonan
	*Wed:* Equal Rights for All		American History
	*Thur:* United Flag		The History Channel
	*Fri:* National Observances		The History Channel
	*Sat:* Early Settlers		The History Channel
	*Sun:* Us Songs and Hymns		The History Channel

	Week of Dec.1 2009
	*Mon:* Arthurs Reading Trick		Marc Brown
	*Tues:* Hare and Rabbit: Friends Forever		Julia Noonan
	*Wed:* Equal Rights for All		American History
	*Thur:* United Flag		The History Channel
	*Fri:* National Observances		The History Channel
	*Sat:* Early Settlers		The History Channel
	*Sun:* Us Songs and Hymns		The History Channel

	Week of Dec.1 2009
	*Mon:* Pooh Makes Growing-Up Fun		Disney Books
	*Tues:* Feelings and Emotions
	*Wed:* The 100^th Day of School		Angela Shelf Medearis
	*Thur:* Mighty Spider		Jean Day Zallinger
	*Fri:* Wake Me Up in Spring		James Preller
	*Sat:* I am Water (Scholastic Reader (Level 1)		Jean Marzollo
	*Sun:* I am a Seed (Hello Reader)		Jean Marzollo

	Week of Dec.6 2009
	*Mon:* Stories of Dogs		Russell Punter
	*Tues:* One Saturday Afternoon		Barbara Baker
	*Wed:* The Man on A Unicycle & Other Stories		Elizabeth Bram
	*Thur:* Ice is Whee		Carol Greene
	*Fri:* The Birthday Tree		Paul Fleischman
	*Sat:* Big World Small World		Jeanine Titherington
	*Sun:* Little Rat Sets Sail		Monika Bang-Campbell

	Week of Dec.13 2009
	*Mon:* Monkeys and the Universe (Chapter Book)		Kate Banks
	*Tues:* The Carrots Seed		Ruth Krauss
	*Wed:* The Little Red Hen (Nursery Classics)		Tony Palazzo
	*Thur:* What’s So Great About Nice		Jacquelyn Reinach
	*Fri:* Don’t Eat Too Much Turkey		Miriam Cohen
	*Sat:* Ready Readers: Giant Collection 10-in-1-Collection		Preschool-Grade1
	*Sun:* Buster and Phoebe. Thje Greast Bone Game		Liz Bechtole

	Week of Dec.20 2009
	*Mon:* The Perfect Christmas Picture		Fran Manushken
	*Tues:* Treasured Tales (Snowhite)		A Parragan Publishing
	*Wed:* Chicken Soup With Rice		Maurice Sendak
	*Thur:* Green Eggs and Ham		Dr. Seuss
	*Fri:* Are You a Spider		Judy Anen & Judy Humphries
	*Sat:* Disney’s Story Book Collection( Beauty and the Beast)		Disney Storyland Treasury
	*Sun:* Disney’s Story Book Collection( Sleeping Beauty) Beast)		Disney Storyland Treasury

	Week of Dec.27 2009
	*Mon:* There’s A Bird on Your Head		Mo Willems
	*Tues:* The High-Rise Private Eyes: The Case of the Troublesome Turtle		Cynthia Rylant
	*Wed:* Today I Will Fly		Mo Willems
	*Thur:* A Kiss For Little Bear		Maurice Sendak
	*Fri:* Arthur’s Hiccups		Marc brown
	*Sat:* Disney’s Story Book Collection( Lion King)		Disney Storyland Treasury
	*Sun:* Nate The Great and The Big sniff ( Chapter Book)		Marjorie et al

	Week of Jan.3 2010
	*Mon:* The Teacher From the Black Lagoon		Mike Thaler
	*Tues:* On the Thinks You Can Think I Can Read With My Eyes Closed		Dr. Seuss Dr. Seuss
	*Wed:* Minnie And Moo Go To Paris		Denys Cazet
	*Thur:* How Do Dinosaurs Go To School		Jane Yolers
	*Fri:* Gorillas Gentle Giants of the Forest		Joyce Milton
	*Sat:* Disney’s Story Book Collection( Pinocchio )		Disney Storyland Treasury
	*Sun:* Go, Dog, Go!		P.D Eastman

	Week of Jan.10.2010: Chapter Book galore!!!!
	*Mon:* Junie B. Jones Is Not a Crook		Barbara Parks
	*Tues:* Amelia Bedelia And The Surprise Party		Peggie Parish
	*Wed:* Oliver and Amanda And The Big Snow		Jean Van Leewen
	*Thur:* Crocodile! Crocodile		Margaret Mahy
	*Fri:* Winnie the Pooh And Some Bees		Stephen Krensky
	*Sat:* Amelia Bedelia 4 Mayor		Herman Parish
	*Sun:* Amanda Pig and Her Big Brother Oliver		Jean Leewen

	Week of Jan.17.2010: Chapter Book galore!!!!
	*Sat:* Disney’s Story Book Collection( Noah’s Ark )		Disney Storyland Treasury
	*Sat:* Disney’s Story Book Collection( The Ugly Duckling )		Disney Storyland Treasury
	*Sat:* Disney’s Story Book Collection( Alice In Wonderland )		Disney Storyland Treasury
	*Sat:* Disney’s Story Book Collection( Cinderella )		Disney Storyland Treasury
	*Sat:* Disney’s Story Book Collection( Peter Pan )		Disney Storyland Treasury
	*Sat:* Disney’s Story Book Collection( Sleeping Beauty )		Disney Storyland Treasury
	*Sat:* Disney’s Story Book Collection(Beauty and the Beast )		Disney Storyland Treasury

	*It was Not all books, We sang, yes, we danced, Christ was with us*		*Jillian by heart knew these & more*
	Pop Goes the weasel		Classic Nursery Rhythms
	Jack and Jill		Classic Nursery Rhythms
	If you’re Happy and You Know It		Classic Nursery Rhythms
	Five Little Monkeys		Classic Nursery Rhythms
	Pat-a-Cake		Classic Nursery Rhythms
	Three Blind Mice
	Baa, Baa, Black Sheep
	Hot Cross Burns
	Oh Dear What Can The Matter Be
	Little Miss Muffet
	Little Jack Horner
	Twinkle, Twinkle Little Star
	Polly Put that kettle On
	30 Days hath September
	I’m a Little Teapot
	The Cow Who Jumped Over The moon
	Humpty Dumpty
	Old McDonald Had Farm
	Hey Diddle, diddle
	To Market, To Market
	Pease Porridge Hot
	Jack Sprat
	Sing A Song of Six Pence
	Do Your Eyes Hang Low
	Jack Be Nimble, Jack be Quick
	Hickory, dickory dock		Classic Nursery Rhythms
	We Read Bible Stories Too, We Read the Holy Bible!!!!		The Holy Bible, the infallible Word of God
	*Veggies Tales Bible StoryBook* King Solomon King David Queen Esther Samuel Samson Noah and The Ark The Creation The 10 Commandments		VeggieTales

	The List is inexhaustible, once Jillian learned to read, she ran with books to school, to church, at the subway, she could not stop!
	Blizzard of the Blue Moon		Mary Pope Osborne
	December Secrets		Paatrica Reilly Giff
	The Boxcar Children Books 1-4		Gertrude Chandler Warner

	Mrs. Piggle-Wiggle Chapter books* Reading level: Ages 8 & up. 128 pages by Betty Mac Donald ** Jillian Read this Book at age 5!!!!! – read before Judge Lewis		Betty MacDonald

36. In the present condition of the subject child because of the on-going intensive child labor imposed on the appellant’s child by the foster parents because of lack of protection by external guidance such DCF and children protection advocates to review the greedy and selfish behavior of the foster parents. Because of lack of the teaching curriculum mentioned above in paragraph 24 and marked EXHIBIT P above and termination of the ongoing child labor badly affected the academic status of the subject child. Ms. Eke’s child has lost all the academic excellence and merit awards which she earned when she was with her biological mother, Ms. Eke, 2004 to April 2011.

37. Indirectly Appellant saw the school progress report of her child. Information further reveals that the only awards her child earned so far in school is demotion to K, best school janitor and cleaner award and related academic failures including F. The school, DCF, MCPHS, and the court below work as team mate and they may alter the progress report which Ms. Eke has seen.

38. Because of this deprivation in education and other needs, Appellant requested Judge Lewis to issue Order on the foster parents and DCF to allow Appellant to teach her daughter after school and week end but Judge Lewis denied her Motion because Judge Lewis is aware of

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the abuses and refuse to return custody of the child to the appellant because the child will give explosive confession that will destroy Judge Lewis’ career and put the foster parents in prison and put DCF in trouble. This case led to the law made in Russia on January 1, 2013 banning US child Adoption in Russia and also adopting Russian children. See http://www.cnn.com/2012/12/28/world/europe/russia-us-adoptions

39. Appellant’s sworn Petition for Review pending in this court shows that she constructed EXHIBIT P (the teaching and learning curricula), which made her child a talented/gifted/smart/ academic award winning child and she read grade 5 & 8 books at the age of 4-5 years and she read one of these books in the presence of The Hon. Justice Lewis and Judge Lewis was surprised , “…because judge Lewis is one of the most heartless racists we have seen in over 220 countries… the types that enjoy the destruction of the people they call ‘OTHERS’ the talent and smartness of this child must be ruined...because she will emerge to take our jobs…”(Intervenors). Under defence of what of whiteman/woman said below prevails in US court system because the Motion seeking Order of this Court to allow appellant to visit and teach her child to make her catch-up her previous academic excellence are in the best interest of the child, biological parents and public but rejected by Judge Lewis and the clerk advised appellant to file the motion with Judge Lewis and Appellant did not appeal the advise to The Mass Supreme Judicial Court and she filed the Motion with Judge Lewis and without reading appellant’s Motion, Judge Lewis used one word “DENIED” to increase the heartburn of the grieving blackwoman, Ms. Eke/Appellant and the Intervenors. Under the control of Judge Lewis only the tapes were released without the transcripts.

40. Under this accelerated teaching and learning strategies, Appellant decided to put her into external and superior learning orbit and Ms. Eke paid $5000.00 to put her in one of the best Summer School and the authorities there were very surprised and she was awarded Merit Awards in Mathematics, Writing and Reading.

41. At present, the academic progress stated above is gone because the foster parents have no interests in education, they have monetized

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Appellant’s child and converted her child (8-year old) to work bull, wife and child laborer in which she is paid peanut of about $1.00 or $2.00 per day for doing adult care job in their internal care center for several hours daily.

42. After school instead of allowing her to do her home work, the foster parents drill her to work from after school time through 10.00pm until she is tired and sleeps to the next morning tired to prepare for school and because of the hard labor at home, information reveals that she sleeps in the classroom.

43. Before the on-going forcible and no fault removal, the subject child was recommended by the Department of Education as one of the children that have excelled academically and would be matched up for advanced class placement, from grade 1 to 2 or 3. Contrary to previous academic advancement her child cannot read and write based on her age and educational level. She has been demoted academically and she is very shy to remain in small kids or K class. Action of the foster parents is in violation of the subject child’s educational protection right under No Child Left Behind Act (2001).

44. Several months ago when Appellant met her daughter, she was crying and ran to her mother and less than two minutes when she made this gruesome confession that this 60-year Reverend father sleeps with her, the irate foster mother rushed my daughter out of me and made her cry more and more.

45. After this visit and the subject child’s confession of the secret thing going on in her place of foster placement, the foster parents banned Ms. Eke from talking to her child, visiting her, telephoning her, etc because the foster mother heard her said, “ I will tell you more”.

46. Restating that before the subject child was swiftly and harshly removed from Ms. Eke’s hand on the last day of her visit, which is

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over one year and during this forcible removal the subject child told her biological mother that she will telephoned her to disclose more of what she has been suffering.

47. Now her academic performance and level are far behind her age and with this after school in-house program, she will be able to catch up and recap her former excellence and level.

48. In April 2011 the child was seized because of the secret activities between her attorney and DCF and Ms. Eke was not allowed to read and see documents (agreements, court briefs, affidavits, etc) filed in court and submitted to parties and others by Attorney Amy Geary. Under attorney supremacy over client, Ms. Eke was intimidated to sign some of these documents which she did not read. Appellant was not informed when her ONLY child was secretly sold to a Nigerian Reverend Father and an Indigenous African American foster mother who is the wife of the reverend father who are supported by the Court below to abuse and destroy her child. These judicial misconducts were filed with the Massachusetts Commission on Judicial Conduct against Judge Paul Lewis on FIRST PART and complaint was filed against Attorney Amy Geary with the Board of Bar. Under the privileges enjoyed by the whites in the United States, Judge Lewis (white) and Attorney Geary (white) were not reprimanded.

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

E. JURISDICTIONAL STANDPOINT

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50. This Court has overwhelming jurisdictions,( personal and subject matter ) to hear and grant Applicants' Petition or Appeal.

51. Actions of the Counsel (Ms. Amy Geary) for the Appellant, Ms. Eke and the Court violate 5th and 14th Amendments to the Constitution and Bill of Rights of the United States and the failure of the counsel in staying visitation, investigation and research on the subject child to the extent of allowing DCF and the foster care providers, violate US and United Nations Convention and Bill of Rights and Universal Declaration on the Rights of the child, parent and family; etc.

52. Equal Protection Clause of the Fourteenth Amendment to the United States Constitution, Title IX of the Education Amendments of 1972, 20 U.S.C. §§ 1681–1688 (―Title IX‖),and the Massachusetts Human Rights Act, United States Constitution, Title IV of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000c–2000c-9 (―Title IV‖) and NO CHILD LEFT BEHIND ACT (2001); Ofumes v. DCF - Hampden County Juvenile District Court, Holyoke Session, Docket No. CP 11H0011; etc.

53. For example during one of the few visitations Ms. Eke was allowed make over one year ago, she found a deep cut on the wrist of her child and both caregivers would not allow the subject child’s mother a minute privacy and as they positioned them directly in a circle of the subject child, foster caregivers and Ms. Eke, Ms. Eke asked her daughter what happened to your wrist and swiftly the caregivers bullied her and shut up and requested her to leave their home or they will call police on her. She rushed out because they were trying to fights her and frame up allegation against her. Ms. Eke reported the injury to the Court, DCF and nothing was done as to sending further information to the Applicant, Ms. Eke on the outcome of her complaint. The injury has deformed subject child’s hand. Ms. Eke request this Court to cause a direct discovery examination on the hand or wrist of her daughter and reason her level of education has drastically dropped. All application and complaints which she filed with the Court and directed to single Judge Paul Lewis were overruled.

54. Further readings on the rights of all children, parents, families, etc.

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

F. ARGUMENT

55. Appellant requests leave of this Court to assign numbers to all the paragraphs and sub-paragraphs of this Argument to secure the content of her brief.

56. In the United States of America, The Supreme Court, charged the interests of the child and parents and put them above everything and they are not negotiable contrary to the well being of the Child. Child labor, 60-year Reverend to enjoy sleeping with 8-year old daughter of Ms. Eke is disgusting, unhealthy, criminal and a major damage and violation of the rights of the child to disvirgin a 8-year child is full path to the destruction of the subject child; child labor is destruction of the education and entire life of the subject child under NO CHILD LEFT BEHIND ACT (2001), etc all of which are not in the best interest of the child and her biological parent and American public and international community in general.

57. Ms. Eke said “I further state that I am requesting this Court for interim order of disclosure and production of my child’s academic record and report cards , April 2011.” Very surprising, Judge Lewis overrule this solemn request which no judge/magistrate can overrule under the Convention and Declaration of the United Nations and the Constitution of the United States.

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58. Reliable information reveals that DCF and fosters parents are brainwashing and building a lot of future castles on air to bar and deceive the subject child to stay further confession on the abuses the subject child has suffered. This information further revealed that before the beginning of this brainwashing and to win the conscience of my child that they (DCF and fosters parents) told my child that I died on motor accident and that because of these lies; they have stopped my visiting rights almost one year.

59. DCF and court below have no claim that desire denial to return care and protection of the subject child to Ms. Ogechi Eke where, Courts and Judges below failed to take any position on whether between September 2004 and April 2011 there were any child abuse allegations brought against Ms. Eke. If there is no child abuse case or allegation against her what case has been established against Ms. Eke to warrant removal of her only child and place such a smart/gifted/brilliant/ talented child in abusive foster care. Socially, to boost the academic strength of the subject child to get to this stardom, Ms. Eke adopted educational enhancement work and play (in-Limpt,Inc.)and engaged the subject child in several enrichment programs such Jillian social life; Blue Hill Boys and Girls Club Swimming class at the Roxbury YMCA; School at the Children’s Dept. of Jubilee church, Boston Vacation Bible School at Jubilee Church; Ann Christian’s Learning Center (ACLC) Summer Academy; Fountain of Grace Sunday school; Museum of Fine Arts, Children’s Museum; West Roxbury skating arena; Book Clubs and Jazz; Franklin Part Zoo; Shopping at Kingston Mall; Dance to the Rhythm; Record your own song; etc.

60. DCF and court below have no claim that desire denial to return care and protection of the subject child, if DCF, Courts and Judges below failed to take any position on para 26 above next strand of question in issue is whether travelling to Nigeria to attend family burial is a crime which could lead to seizure of the subject child.

61. DCF, courts, and judges below have no claim that desire denial to return care and protection of the subject child to Ms. Eke, if Courts and Judges below failed to take any position on para 13 above next and final question is whether there is any travel ban or restriction on Ms. Eke and the subject child in the ENTIRE Decisions of Judge Lewis dated March 2, 2011 and other decisions of Judge Lewis and other Judges since 2004 and before April 2011. Particularly between March 2,

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2011 and April 2011 when Ms. Eke and the subject child were returned from Canada to Boston were there any child abuse allegations against Ms. Eke to trigger seizure of the subject child? There was no child abuse case or allegations.

62. On September 30, 2004 Ms. Eke gave birth to the Subject Child with pains and the nurses and physicians abandoned her and the nurses called DCF and the agency came and seized and removed the subject child. The DCF, hospital, College of Pharmacy and visiting psychiatric doctor connived to recommend mental health evaluation. This unverified, tested and related lack of expert research and investigation created a nickname for Ms. Eke and shamefully restated and cited by the long retained (2004 through October 9, 2012) Hon. Justice Paul D. Lewis. The newborn subject child was returned to Ms. Eke.

63. On March 2, 2011 Judge Paul Lewis ordered that Custody of the Subject Child would continue to remain with Ms. Eke (the child’s mother) EXHIBIT C.

64. Is there any touch with just rule and judicial orderliness how Care and Custody changed under the personal power of the DCF, Judge Lewis and court below because Ms. Eke and the subject child planned to travel to Nigeria to attend the burials of their relatives. In EXHIBIT C Judge Lewis did not order or impose travel restriction on Ms. Eke and the subject Child.

65. Who on earth will not detect conflict of interest and sabotage that on the day of the departure, DCF, Ms. Eke’s attorney and other conspirators listed above followed them from the Boston Airport to Canada and in Canada Ms. Eke and the Subject Child were blocked from travelling to Nigeria and they were return to Boston and in the following days Ms. Eke and subject child were brought to court before Judge Lewis and without reason the subject child was seized and placed

OGECHI EKE V. DCH DOCKET NOS. CA 2013-P-0791,SUCV 2012-4516 – A & CP10B0179

under the custody of foster parents that make the subject child to suffer severe acute danger educationally, socially, economically, psychologically, etc. Applicants respectfully request leave of this Court to assign numbers to each paragraphs of their argument because of past experience in their cases when several paragraphs were missing.

66. In applying the Rules of this Court and other local rules and Federal rules, in return custody proceedings, question maybe asked whether the destination of the proposed return and placement in the present abusive condition is in the best interest of the subject child.

67. In this case two questions have been resolved thus, that in the home of the wealth seeking foster caregivers, the subject child is in severe acute danger educationally, socially, economically, psychologically, etc. The destination where she will be returned is similar to "heaven" and is her nuclear parent's or mother's home where she was enjoying her life and excelling and sound educationally, socially, economically, psychologically, with freedom of association and speech, etc.

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

OGECHI EKE V. DCH DOCKET NOS. CA 2013-P-0791,SUCV 2012-4516 – A & CP10B0179

(subject child) in one of the best private or suburban schools in the United States.

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

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

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

72. Ms. Eke's EXHIBITS A & B which are an in-home accelerated teaching and learning program is the best option for the United States to raise standards of education Pre-K - Tertiary Institution and if possible world in general (see Finland). Few visitations allowed by

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the school, fired attorney, caregiver and DCF because of the secret kept around subject child, parent, Ms. Eke tested her child to know the level she is but less than two minutes of the simple academic question/answer and writing the caregivers rushed into the testing and disrupted the testing and forced Ms. Eke to leave the foster caregivers' home and warned Ms. Eke not to visit their home and that failure they will accuse her of trespassing into the foster care home and also warned her not to visit subject child's school. The few testing which lasted less than two minutes comparatively shows that the subject child has lost her education in foster stay and if urgent removal to parent is not made, she will drop out from school and forced her to enter the DCF and intended caregiver planned trap for TALENTED/SMART/A/A+/B+ non-whites victims which is boy/girl friend circle which will lead to teen pregnancy to enable the caregivers start to dig addition gold through foster babies or children's state welfare or benefits. Criminally, caregivers under DCF program try to target victims' education to destroy it.

73. DCF'S politically designed and defective care and protection system, they (foster caregiver and DCF) are interested in large public foster child benefit monies this age through 18 years shared between the caregiver and DCF under pretense of providing for the subject child but these monies allow them to buy secret beautiful castles here and oversea. When Ms. Eke visited her child’s school when she was doing a performance and Ms. Eke has to take some of her beautiful clothes. When she arrived there she found that the clothes the subject child wore was old and stained and improper for such outreach appearance and Ms. Eke has to go change her unfitting clothes with the ones she brought.

74. Academically, the Subject child earned this downfall because the teaching and learning curricula (EXHIBITS A & B) which mother of the subject child put in place was suppressed and in place she is forced to do child labor or domestic work and providing care which adults are supposed to provide in the foster caregiver's home daycare business; etc.

75. Reason that several experts have found that the case of the subject child is case of child human and constitutional rights case and subject child now forcibly placed in danger of money making child merchants (DCF and foster caregiver) or nigerian pastor,

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Emergency Order in nature of Immediate Return of Custody to Subject Child Mother, Ogechi Eke be issued because the subject child identified by cause docket number above be immediately and urgently adjudicated in need of care and protection and committed to the custody of her Mother, Ogechi Eke and/or any other appropriate order to be made pursuant to Fed. R. Civ. P. 56 and Local Rule 56 of the Mass. R. Civ. P.; .G.L. c. 18 sec. 2 (A)(D); 1st , 4th , 5th and 14th Amendments to the Constitution and Bill of Rights of the United States; Mass. Sup. Court Rule 9A(b)(5); Mas Juv. Ct. Standing Order 2-07; CHINS, G.L. c. 119 §§39E-H); Emergency custody hearing (G.L. c. 119, §24; Convention on the Rights of the Child - Parts I & II (General Assembly resolution 44/25 of 20 November 1989; Equal Protection Clause of the Fourteenth Amendment to the United States Constitution,Title IX of the Education Amendments of 1972, 20 U.S.C. §§ 1681–1688 (―Title IX‖),and the Massachusetts Human Rights Act, United States Constitution, Title IV of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000c–2000c-9 (―Title IV‖) and NO CHILD LEFT BEHIND ACT (2001); Ofumes v. DCF - Hampden County Juvenile District Court, Holyoke Session, Docket No. CP 11H0011; etc.

76. In LIMPT, INC. (EDUCATION AND WORKFORCE PROJECT), within researchers and investigators' works in computing number of the predominantly non-white victims appearing before the Juvenile Courts across the United States they found that the US Congress, politicians, civil liberties organization are aware that DCF is secretly created to destroy non-whites and under these activities TALENTED/SMART/GIFTED /A/A+/B+ students and parents are DCF's focus and they fight hard to distroy them because they will earn education to take their jobs (Ofumes v. DCF – Hampden County Juvenile District Court, Holyoke Session, Docket No. CP 11H0011) and Ofume et al v. Holyoke Police Department et al - Plymouth County Superior Court, Docket No. 1260.

77. From experts (Limpt, Inc., Dr. Phillip Chukwuma Ofume, Dr. Kifindi Bunkheti, etc) research and investigation point of view on Nigerian and African nuclear and extended families system culture, they found that the reaction of Ms. Ogechi Eke in 2004 through out each political plot organized and implemented by the DCF and its irate child merchants to seize her gold (subject child) is normal reaction of all responsible, caring and loving Nigerian and African mothers or parents. Commonwealth of Massachusetts and its agencies (DCF et als) selected weak and inexperience Psychiatric Evaluator and caseworkers that know nothing about oversea culture and civilization. The reaction of Ms. Eke is exemplary of good, excellent, caring and loving mothers and parents. Relatively, the silly behaviors of Americans if reviewed

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by oversea or Nigerian Psychiatric evaluators may be rated as mental health behaviors.

78. Birthday, March 15, 1969 through presents Ms. Ogechi Eke has never had any mental and related health problems and at all material time she has been TALENTED/ SMART /GIFTED /A/A+/B+ university graduates. In the United States she has completed over four (4) years of Pharmacy course and she disengaged from the Pharmacy course program because of the harassment, bullying and physical/ psychological tortures directed against her by the DCF and its secret/overt informants. The action of the DCF is a vicious retaliation by the DCF and its agents following Ms. Eke's petitions to the government of the Commonwealth of Massachusetts and its agencies (Human Rights Commission et als) to complain against her persecution, harassment, bullying and physical/ psychological tortures. Day of the birth of the subject child on September 30, 2004 DCF mounted its agents or informants in the hospital where the subject child was born with the intention to create trouble as path to seize her child. This experience several Nigerians and other non-white has had in the United States.

79. Sectors to sectors, place to place, Ms. Eke continues to answer questions on what she did to make her child TALENTED/ SMART /GIFTED /A/A+/B+ student at the age of 4. Age-4-17

subject child was reading tertiary level books tom the extent that she read **Mrs. Piggle-Wiggle Chapter books*** Reading level: Ages 8 & up. 128 pages by Betty Mac Donald** Jillian Read this Book at age 5!!!!! – read same before Judge Lewis. Ms. Eke said "... see EXHIBITS A & B and in answering public question on what she did make her child excel to this high level, she said, “what I do day to day to put my daughter top of her class are to give her healthy food, allow rest and sleep after school, sound teaching with quality curriculum, teach by practical example, private study and creativity, continuous and comprehensive assignments and evaluation, play and interaction with other kids, etc."

80. The major problem the subject child has now is absence of nuclear or biological mother and Ms. Eke lamented and said, “When I was allowed to visit Jillian, Jillian would cry out her eyes each time I had to leave, the foster parents would scold Jillian and next time, the foster parents would not allow me to visit. DCF and children secret physicians took Jillian to therapy which is anti-biological mother brainwashing center…DCF and foster parents lied that I am allowed to visit Jillian, it is important to state that I visited Jillian only 2 times last year and this year only once. The 3 times was interrupted with drama from the foster parents when Jillian said ‘I want to go with mommy…’. In the appendix see Motion for visitation and teaching permission which Judge Lewis denied in his handwriting with one word “DENIED.” The major secret in all these schemes is that Judge Lewis and other Judges, DCF, foster parents, etc are protecting their reputation and good standing of the Court because they fear that Jillian will confess more and more abuses which onlookers suspect may include but unlimited to sexual abuses, child labor, etc.

G. CONCLUSION/RELIEF

81. There is eminent proof that DCF,Judge Lewis and other judges below that are copying and reaffirming what other judges affirmed because of color and race and political alliance and affiliation

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failed to assert claim which desires relief vis-à-vis paragraphs 27,

59, 60, and 61 above therefore full care and protection of the subject child be returned to the biological mother, Ms. Ogechi Eke because of the interest of the child and Ms. Eke particularly to avoid early or teen pregnancy which will jeopardize the entire life and educational and other careers of the subject child pursuant to NO CHILD LEFT BEHIND ACT (2001).

82. And/or also I custody is not returned, the present horrible conditions of the subject child (afore stated) determine what she will become in the future and that DCF is not in dispute with anything in this case and no steps have been taking since over one year of the rumor of the abuse and recent confession of the subject child before Ms. Eke and if not that the foster parents quickly snatched the child from the hands of Ms. Eke more dreadful confessions would have been made by the child. To protect the sitting harmful judicial system, the courts and judges below, DCF and fosters parents are suspected to have raised large amount of money to block further contact between the biological parent and intervenors.

83. Base on US Child Protection Human Rights laws and United nations International Convention on the Rights of the Child, the subject child must be returned to Ms. Ogechi Eke to enable her return the hope of this Child to where intended before she was forcibly removed without fault.

84. Therefore sake of the foregoing, Applicants’ Appeal must be granted and subject child be returned to Ms. Eke and other order Court deems fit.

H. VERIFICATION

85. Respectfully verified, signed and submitted the foregoing Appellant’s Brief under the pains and penalties of perjury this day of July 2013,

______________________

OGECHI EKE V. DCH DOCKET NOS. CA 2013-P-0791,SUCV 2012-4516 – A & CP10B0179

OGECHI EKE (Defendant)

143 Columbia Road, #11

Dorchester, MA 02121

INTERVENORS & SUPPORTERS:

___________________

Phillip C. Ofume, Ph.D. International Coordinator (Strategic Policy/Practice of Politics of Unification and Unifification Politics), U.S. Coordinator ( LIMPT, INC. (HUMAN RIGHTS, LAW REFORM & LITIGATION PROJECT - INTL. CHAPTER)

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 .

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);

OGECHI EKE V. DCH DOCKET NOS. CA 2013-P-0791,SUCV 2012-4516 – A & CP10B0179

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

LIMPT, INC. (EDUCATION AND WORKFORCE PROJECT ET ALS);

MOVEMENT FOR EMANCIPATION OF THE NIGER DELTA (MEND);

INTERNATIONAL MOVEMENT FOR NEW FEDERAL UNION OF NIGERIA (IMUN, INC.);

LIMPT, INC. & IMUN, INC. PROJECT (EDU., HUMAN RIGHTS, INSURANCE CORP., LAW REFORM & LITIGATION PROJECT - INTL. CHAPTER);

INTL. COALITION FOR PRO SE/UNSIGNED LAWYERS & GLOBAL CLASS ACTION PROJECT;

INTL. ENDOWMENT FOR DEMOCRACY;

FOSTER/ADOPTIVE/ ORPHANAGE & CIVIL LIBERTIES OF THE NUCLEAR AND EXTENDED FAMILIES;

DR. PHILLIP C. OFUME & ASSOCIATES

CERTIFICATE OF SERVICE

I, Ms. Ogechi Eke defendant in this complaint hereby certify that I have served the foregoing, Appellant’s Brief upon all parties and their agents, representatives and attorneys, by hand delivery or first class U. S. Postal Service at:

_____________________

Ms. Ogechi Eke -

Date: July , 2013

cc. President Barack Obama, Vice-President Joseph Biden, H.E. United Nations High Commissioner for Human Rights, Counsels for DCF, Child and Foster Parents, The Hon. Secretary and Attorney-General of the United States, Eric H. Holder, Jr., Hon. Secretary of State, Senator Hilary Clinton, H.E. Secretary General of the United Nations, Bakim Moon, Executive Director, UNICEF, Chair, Amnesty International (Intl. Secretariat, London, UK), Executive Director, Human Rights

OGECHI EKE V. DCH DOCKET NOS. CA 2013-P-0791,SUCV 2012-4516 – A & CP10B0179

Watch (USA), President, AAAA (Washington, DC, USA), LIMPT, INC. (EDUCATION & WORKFORCE PROJECT, c/o Dr. Phillip Chukwuma Ofume – National Coordinator), etc.

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