U.S. URBAN/MIXED URBAN SCHOOL = MAXIMUM PRISON

                 IN THE UNITED STATES DISTRICT COURT
                FOR THE DISTRICT OF MASSACHUSETTS

   CIVIL ACTION DOCKET NO. _____________________

___________________________________________________


LIMPT, INC.  (EDUCATION AND WORKFORCE PROJECT),                                                                                      on behalf Ms. Isabelle Ofume presently of Brockton                                                                                                 High School, MA

                                                      Plaintiff

                                        v.

Holyoke High School and Classical High School  and                                                                                         Brockton High School and   Gene Constantino and and                                                                                                  Diane Bauer and Susan Szachowicz (Principal of Brockton                                                                       High School) and  Bose, Animesh                                                                                                                                ( Mathematics Department)                                                                                                                                                             and Brassil, Thomas  ( Physical Education Department)                                                                                                                                                     and Donahoe, Helen  (Science Department) and Kelly,                                                                                                                                        Doryn  ( English Department) and O’Connor, Gary                                                                                                                              (  Guidance Departmen) and Sullivan James and Grove                                                                                                                                                (Physics) and Joan Williamson (Guidance Counselor -                                                                                                       Brockton High School) and Karen Honourable                                                                                                                                                      Secretary of Education and Superintendent                                                                                                                 of Brockton Public Schools  and Honourable                                                                                                Commissioner of Elementary and Secondary                                                                                                      Education and U.S. Honourable Secretary of                                                                                                          Education and A'Hearn Karen (AP European History) and                                                                                                            (Female Front Desk administrative staff - Brockton, MA)                                                                                      and Michele Conners (Social Studies Department Chair)                                                                                                            and Mrs Deirdre Smith (English Teacher - Brockton High                                                                                                                  School) and Mrs Deirdre Smith  (English - Brockton High                                                                                                                                  School) and  Heenan Suzanne  ( Biology - Brockton High                                                                                                 School) and Ms Heenan Suzanne (Biology - Brockton High School).

                                               Defendants

_______________________________________________________________________

EMERGENCY COMPLAINT AND REQUEST FOR PERMANENT                                                    INJUNCTIVE  AND IN PAR TEMPORARY INJUNCTIVE AND                                                                       DECLARATORY RELIEF       ________________________________________________________________________

A.                PARTIES IN THE COMPLAINT

a.                 PLAINTIFF

  1.    Plaintiff, LIMPT, INC (Education and Workforce Project) is corporate body and office located in Brockton, MA within the jurisdiction of this Honourable Court. This  Action is brought to this Court on behalf Ms. Isabelle Ofume, former student at Holyoke High School and Classical High School  and  at present she is grade 12 student at Brockton High School.

b.                DEFENDANTS

2.    Holyoke High School is in the city of Holyoke and district/county of Hampden of Massachusetts  is an urban public school with the rank of high school  and admits students from grade 9 through grade 12.

3.  Brockton High School  is  in the city of Brockton and district/county of Plymouth of Massachusetts  is an urban public school with the rank of high school  and admits students from grade 9 through grade 12.

4.   Lynn Classical High School  in the city of Lynn and district/county of Essex of Massachusetts  is an urban public school with the rank of high school  and admits students from grade 9 through grade 12.

5.     Mr.  Gene Constantino is the Principal of Lynn Classical High School and resident of Massachusetts within the jurisdiction of this Court.

6.  Diane Bauer,  is the Principal of Holyoke High School and resident of Massachusetts within the jurisdiction of this Court.

7.  Defendant, Bose, Animesh   is mathematics teacher in the Department of Mathematics at Holyoke High School of the City of Holyoke of Masachusetts.                                                                                                                                                          

8.  Defendant, Brassil, Thomas  is a teachers in  Physical Education Department  at Holyoke High School of the City of Holyoke of Masachusetts.                                                                                                                                                          

9.      Defendant, Donahoe, Helen  is teacher in   Science Department  at Holyoke High School of the City of Holyoke of Masachusetts.    

 10.    Defendant, Kelly, Doryn   is  teacher in English Department  at Holyoke High School of the City of Holyoke of Masachusetts.    

 11.   Defendant, O’Connor, Gary  is Guidance Counselor in  Guidance Department at Holyoke High School of the City of Holyoke of Masachusetts.    

 12.    Defendants, Sullivan James and Grove  are teachers teach Physics in Physics Department  at Holyoke High School of the City of Holyoke of Masachusetts.    
13.    Defendant, A'Hearn Karen  is AP European History teacher at Brockton High School

14.      Defendant, A Female Front Desk administrative staff - Brockton High School  MA

15.     Defendant, Michele Conners  is Social Studies Department Chair at Brockton High School

16.     Defendant, Mrs Deirdre Smith   is Social Studies Department Chair at Brockton High School

17.       Defendant, Heenan Suzanne  is Biology  Teacher at  Brockton High School


18.     Defendant,  Joan Williamson  is Isabelle Ofume's Guidance Counselor at  Brockton High School.


19.   Defendant,  Honourable Secretary of Education is the head and secretary of the Massachusetts Department of Education and incharge of all educational sectors pre-k through tertiary institution.

20.  Defendant, Honourable Commissioner of Elementary and Secondary Education is the commissioner of Elementary and Secondary Education in the Commonwealth of Massachusetts.

 21.  Defendant,  Honourable Secretary of Education is the head and secretary of the U.S. Department of Education and incharge of all Federal educational sectors pre-k through tertiary institution.

B.             PRINCIPAL QUESTION IN ISSUE

22.    Whether any local and federal education Acts allow teachers to use tardness which is unconnected with the test and examination done and passed to put students' scores which are A/B+ to F

23.   Whether The Migrant Student Information Exchange (MSIX) per the mandate of the  Congress, in Section 1308 (b) of the Elementary and Secondary Education Act, as amended by the No Child Left Behind Act of 2001 (NCLB)  require students to repeat the grade which they have comnpleted and passed; test/examination which they have done and past in the states where they are migrating from.

24.    Whether under normal court system, process and proceedings, victim will not prevail as result of the action under contest in this case.


C.            PERMANENT INJUNCTION

25.   Potentially and outstanding scholarly, Isabelle Ofume is talented/smart/gifted/A/A+/B+/ honor/ high honor students and shortlist and physical evidence of her academic and professional qualifications and awards are hereto attached and marked EXHIBITS A, A.1 to A.27 and MUST BE ALLOWED TO GRADUATE IN JUNE 2012 and other Order of this Court to request the defendants to return and properly restate all her scores which were scored F unlawfully and branded them as what she will get because she was tardy three times whereas Isabelle was not tardy three times and that using purported three tardiness to alter student's earned scores and assign F is unlawful and against US and Massachusetts school record assignment and school record/credit accrual laws and other work marked and scored and issued failing grade under political animosity  because of her parents' political bid for the President of Nigeria past and 2015 must be remarked , re-scored under comparative (peer to peer or student to student) marking and scoring compared with other students' works and fully reversed in full with complete score issued and also  reasonable damages in favor of Isabelle Ofume because Georgetown University and New York University have collaborated with the lies told by these moneyed persecutors or defendants or schools  to deny Isabelle admission without reviewing Isabelle's case including interviewing Plaintiff, Isabelle and parents.

26.    Far back at Riverbend High School, Fredericksburg, Virginia one of the best high schools in the United States, Isabelle did and passed grade 10 SOL which is similar to Massachusetts MCAS and standard wise SOL is higher than the Massachusetts grade 10 MCAS but Brockton High School which is one of the allies of the federal law opposition such as State of Arizona and other opposition states  particularly in opposition to Section 1308 (b)(2)(A) and continues to receive federal funds and stands on its feet and wrote to Isabelle and her parents to maintain that Isabelle if she fails to redo the Grade 10 SOL or MCAS that she will not graduate in June 2012 and she will not receive her High School Diploma.  Isabelle under the roof or premises of Brockton High School, Lynn Classical High School and Holyoke High School Isabelle Ofume has been threatened to forfeit her graduation in June 2012, suffered physical and psychology tortures, teasing,  Social exclusion or ex-comunication, daily threats which could trigger disengagement or drop out from school, massive  Intimidation, racial ad other harassment, Public humiliation including public disclosure of imposed and untrue failing and call trash her senior ID because she not worthy of wearing it, etc. Ancient and modern times, “bullying” means systematically and chronically inflicting physical hurt or psychological distress on one or many students, admiistrators and teachers may be involved and in Isabelle's  case many students, teachers and administrator were involved on daily basis. The Honourable Secretaries of Education (Massachusetts and United States) and Honourable Commissioners of Education, Superintendents and Principals supported all these hostilities under color and race privileges without intervention. Without parents or LIMPT, INC. Isabelle would have disengaged from school and be made street lady as this education sector has done to several non-whites across the United States.


 D.               JURISDICTIONAL BASIS
 27.    The Migrant Student Information Exchange (MSIX) per the mandate of the  Congress, in Section 1308 (b) of the Elementary and Secondary Education Act, as amended by the No Child Left Behind Act of 2001 (NCLB) prevent intended state of migration to avoid duplication and creating redundancy of allowing the migrant student to redo the tests, courses and examinations which the student has done and completed in his/her previous state and school. Further, Congress directed the Secretary, in Section 1308 (b)(2)(A) of the statute, to ensure the linkage of migrant student record systems.


28.         The purpose of MSIX is to ensure greater continuity of educational services for migrant children by providing a mechanism for all States to exchange educational related information on migrant children who move from State to State due to their migratory lifestyle or conditions. It is anticipated that the existence and use of MSIX will help to improve the timeliness of school enrollments, improve the appropriateness of grade and course placements, and reduce incidences of unnecessary immunizations of migrant children. Further, MSIX will facilitate the accrual of course credits for migrant children in secondary school by providing accurate academic information on each student’s course history and academic progress.
                                                                                                                                                 
29.  Paragraphs 1- 30 above are fully incorporated and attached herewith. Complainant, LIMPT, INC. (EDUCATION AND WORKFORCE PROJECT) is a corporate body with its corporate office registered in the Commonwealth State of Massachusetts and working on how to raise standard of US Education Pre-K to Tertiary Institution across the United States of America with strong emphasis on teaching, learning, reduction of violence, increase retention and reduce school dropout and administrative problems in the Urban and Mixed Urban Schools; monitoring peer/peer, teacher/administration abusive conducts and relationships; reduction and elimination of harassment, bullying and other activities inside and outside the close door of the classroom in other to reduce disengagement or drop out  from school and raise retention via efforts of school teachers and administrators; computation of the role of teachers, administrators, parents and reason that parents have less than 1% role to play in the education of the child and that 99% of the role parents play in teaching, learning and retention is worthless.  LIMPT,INC takes control of the child and granted parents overwhelming relief to make parents be more productive at workplace and at home to jump national economies and their longevity via healthy and stress-free lifestyle;  etc.


30.    This case is brought to this Honourable Court on behalf Student, Isabelle Ifeoma Ofume who is senior and grade 12 current or former students of the Districts of Massachusetts, Virginia and Halifax Municipality of Nova Scotia of Canada. Isabelle migrated from some of the best suburban schools in Canada (Bedford South School, Bedford, NS) and United States (Braintree Middle School, Braintree, MA and Riverbend High School, Fredericksburg, VA) politically and persecutorily because of the parents' bid for the President of Nigeria past and 2015 and parents' campaign for civil liberties and Isabelle's smartness/giftedness/talent and strong academic standing as honor, high honor, student ambassador and nominated as guest writer for several news and information organiations and her summarized Resume/Bio speak for themselves as follows:


EDUCATION

Brockton High School (2011-present)
High Honor Roll & Honor Roll (2006 - 2011) | Advanced Studies: English, Biology, US History

WORK EXPERIENCE

School Morning News Assistant (2007)
Stalley’s Promotional Team “MILQ MEN” (2010-2011)
Member of the Cool Kid Project (2010-2011)
Fiasco Friday II International Music Movement (2010-2011)
Promotions Intern at theloveinus (2011-2012)
PBS’s Tavis Smiley Show - Guest Blogger for “Made Visible” (April 2012)
Remaking America: From Poverty to Prosperity Official Blogger (1/12/2012)
Made Visible: Women, Children, and Poverty (3/18/2012)
Blogger for Greedmont Park | Pop Culture Magazine - (2010-Present)
The Middle East: Restaurant & Nightclub - Street Team (March 2012-Present)
Moderator/Contributor at GorillaLeak (April 2012- Present)

SKILLS

Excel, Powerpoint,  Access, Microsoft Word and Publisher for governmental and non-governmental agencies and organizations, also good in Movie Maker & editing, basic HTML, Photoshop, MAC & PC.

Social Media Expert - Wordpress, Blogger, Tumblr, Twitter, Facebook, HootSuite, and more.

COMMUNITY INVOLVEMENT

Volunteer at the Lynn Museum - Sales, Accounting, Handling of Money (21 May 2011)
Assistant Construction worker for Refugees, Homeless people, etc. (Dec-Jan.2010)
Social Media Marketer & Writer for Fountain of Grace Church (FOG) - (Feb. 2012-Present)

 ACHIEVEMENT & AWARD

People to People Student Ambassador (2006-2012)
Miss Boston 2006 - 2009 Nominee
Who's Who Award (2007-2008)
WWDMAGIC & Teen Vogue Correspondent - Official Blogger (2011)
Nominee for National Youth Leaders Conference (2011)

CONFERENCE ATTENDED

Marcus Troy Experience on Imeet – (2011)
Remaking America: From Poverty to Prosperity Conference Call (1/9/2012)
Made Visible: Women, Children, Poverty Conference Call - (3/13/2012)

31.      From these outstanding schools in Canada and United States, politically because of parents' bid for the President of Nigeria past and 2015, Isabelle, parents and siblings were sanctions and prevented from getting permit to work and receive all other services to the limited extent that effective April 2012 one child was granted unemployment assistance of $284.00 now made bi-weekly. Under this sanction Isabelle and her parents and siblings were forcibly moved several times between August 2010 through January 31, 2011 to jurisdiction with very poor urban schools (Holyoke High School, Lynn Classical High School and Brockton High School, MA). In these poor and low standard urban schools where administrators and teachers were cheaply influenced by parents political opponents and with this political influence and privilege, Isabelle was under marked and scored and several of her tests, examinations, assignments and other works were censored and not released and issued to Plaintiff or parents. Plaintiff's after teacting has been stocked because teachers (over 97% whites) in these schools keep students' (predominantly non-whites) completed/uncompleted works (test, examination, homework and other works) for several months without marking and scoring them. Student agents are mobilized and kept as servants and assured of high and passing scores and unselected students who are mostly talented/smart/gifted/A/A+/B+ are dumped to make them  loss their chance to transit to tertiary institutions.  To further destroy these excellent students including Isabelle dangerous groups are formed in nature of assigning two sturborn and weak students to one excellent student to do a team or group project. The two sturborn and weak students have nothing to contribute nothing  towards the research and investigation of the project. The teacher instructs them to do interactive or exchange scoring activities and frustrate the excellent student in the team and to enable the teacher issue failing grade to the excellent student because the score is team score in daylight but in secret place, the teacher gives high marks to his/her student agents. Plaintiff seeks Order of this Court to nominate jury of experts to remark and rescore all tests, examination and assignments. Plaintiff has issued several notices on the teachers and administrators of these public schools to keep copies of all tests, examination and assignment scored and uinscored.


 32.    This complaint is seeking emergency  injunctive and declaratory relief to stop Brockton High School from blocking Isabelle Ofume's graduation in June 2012 because she did not repeat grade 10 test which she has done and passed in the Commonwealth state of Virginia; order to compel Holyoke High School to allow Isabelle to Complete all the uncompleted school works, tests and examinations or waived all the uncompleted school works, tests and examinations  in computation of her final score because on January 31, 2012 these works, test and examination were disrupted by the politically energized Department of  Children and families (DCF) when Holyoke Police Department was paid by Isabelle's parents (Dr. & Mrs. Ofume)  political opponents to arrest, detain, charge and prosecute Dr. Ofume and seize, place in foster care  all his children in Holyoke and evict parents and render them homeless to impede their (parents) campaign for the President of Nigeria April 20, 2011; order of this Court to appoint experts to remark and rescore all Isabelle's courses such as Mathematics  - Algebra and Pre-Calculus,,  Physical Education, Sciences, English - literature, composition, Biology, History - America and European, Physics, Physiology and Human Anatomy) which were marked, issued without teaching and remediation program for migrant students, under scored, scored under hate clout and political animosity. Defendants, above mentioned teachers and administrators  conspired to mark and falsify score to reduce her GPA as plot to block her admission to study medicines at Georgetown University, Howard University, New York University, etc; nominal, compensatory, and punitive damages, and other costs which this Court deems fit.


 E.   COMPLAINT  AND APPORTMENT OF INFRACTION

33.   Defendant, Gene Constantino: is the Principal of Lynn Classical High School and resident of Massachusetts within the jurisdiction of this Court. Without written consent of Isabelle Ofume’s parents the  Defendant Gene Constantino or Principal of Lynn Classical High School entered into further conspiracy with the  Holyoke High School, to the destructive extent that  Honor Algebra II, AP British Literature, Honors Chemistry, AP US History -  uncompleted or  unfinished exams, tests, assignments and  incomplete grades and  scored 0 or F  because of the removal of Isabelle Ofume  and siblings  by the Department of Children and Families (DCF) and follow-up incident which is now the subject of the matter, Ofume et al v. Department of Children and Families (DCF), Holyoke Police Department et al, (Brockton Superior Court) DCF and Holyoke Police Department interrupted the test, exams and completion of the courses. At Lynn Classical High School, the Defendant or Principal (Gene Constantino) secretly demanded for the results (0 or F) at the Holyoke High School and at Lynn Classical High School Isabelle scored A & B+ and heartlessly the principal (Gene Constantino) matched A & B+ with  0 & F fraudulently to get low scores and failing grade (EXHIBIT C). See http://universal-fashion-art-music.blogspot.com/2011/11/brockton-sup-court-department-ofume-v.html  Under this conspiracy, without the consent of parents and allowing the investigation by the Department of Education and FBI to complete their investigation, at close door, Classical High School relied on these incomplete tests, exams and courses to match the high scores which she earned at Classical High School and brought the scores to low scores.  See http://universal-fashion-art-music.blogspot.com/2011/11/brockton-sup-court-department-ofume-v.html; http://phillyimc.org/en/ event/brockton-ma-superior-court-ofume-v-holyoke-police-department-et-al-question-democratic-policin . Parents and Plaintiff petitioned Lynn Public School and Massachusetts Department of Education (Hon. Secretary ) and Hon. Commissionner of Elementary and Secondary Schools to make complaint on the action of Mr Constantino and parents and Plaintiff sent several reminders to the  Massachusetts Department of Education (Hon. Secretary ) and Hon. Commissionner of Elementary and Secondary Schools without action taken in the circumstance and the Defendant, Mr. Constantino adopted the Honor Algebra II, AP British Literature, Honors Chemistry, AP US History -  uncompleted or  unfinished exams, tests, assignments and  incomplete grades and  scores and when he matched the 0 or F with the A and B+ grades at Lynn Classical High School, in which 98% became 49% which became F. On the day of the course placement process with the Guidance Counselor and in attendance are Ms. Isabelle Ofume and Dr. Phillip Chukwuma Ofume and this process progressed,  Defendant Gene Constantino broke the process by harshly removing the Guidance Counselor to secret meeting as Dr. Ofume and Ms. Isabelle Ofume remain seated in the Guidance Counselor's Office.  Defendant Gene Constantino and the Guidance Counselor came back to the office of the Guidance Counselor and Defendant Gene Constantino ranged and said, "I am not accepting the so called admission offered to you (Isabelle) and I am going to contact Holyoke High School to know what happened there, sign this release for me." Dr. Ofume and Ms. Isabelle Ofume declined to sign the release and Dr. Ofume told him that the entire report card of about three months of attendance at Holyoke High School is under appeal to the Hon. Secretary of Education and the Superintendent of Holyoke Public School. Iratically, Defendant Gene Constantino rushed into another topic which is MCAS and he irately said, "you must do grade 10 MCAS before you can graduate in my school." Dr. Ofume said, "for your information, Isabelle has done equivalent of MCAS called SOL in Virginia and she can not repeat the same test in Massachusetts." After some months, some staff at Classical High School told Plaintiff, Isabelle Ofume and her parent that the Defendant Gene Constantino has matched unknown grade with her good grade at Classical High School and that Isabelle has poor result because of the action of the Defendant Gene Constantino. Plaintiff and staff interviewed Defendant Gene Constantino and he confirmed that he got Isabelle's transcripts from Holyoke High School without signed and other consent from Isabelle's parents. In 2010 Isabelle Ofume was minor and she is not qualified to sign consent and her parents did not sign any consent or release to Defendant Gene Constantino.  Defendant Gene Constantino did not give any reason why he should add up the Holyoke High School  uncompleted or  unfinished exams, tests, assignments and  incomplete grades with the excellent results which Isabelle earned at Lynn Classical High School.

34.       Defendant, Diane Bauer  is the Principal of Holyoke High School, the Plaintiff petitioned and wrote to her to inform her that the action of the DCF and Holyoke Police Department on January 31, 2011 has led Isabelle’s failure to complete several tests, exams, assignments and turn in several home works which part of the score structure and that courses such as  Honor Algebra II, AP British Literature, Honors Chemistry, AP US History, etc that information from her school shows that these  uncompleted or  unfinished exams, tests, assignments and  incomplete grades  were scored 0 or F and that the Plaintiff on behalf Isabelle has sent appeals to her office. EXHIBIT D & E. In February 2011, Isabelle and her parents and siblings relocated to Lynn, MA and she was admitted at Lynn Classical High School to continue Grade 11. After the admission made and supervised by the Superintendent of Lynn Public School, Dr. Catherine Latham,  the present Principal Lynn Classical High School who Isabelle’s Parent Dr. Phillip Chukwuma Ofume clearly identified in 2006 with his political opponents and Government of Nigeria, was infuriated when Dr. Latham admitted Isabelle. Defendant Gene Constantino told Dr. Ofume that without Isabelle's parents signed and other consent that the Defendant, Diane Bauer  issued Isabelle's transcripts containing uncompleted or  unfinished exams, tests, assignments and  incomplete grades to him. Plaintiff contacted the   Defendant, Diane Bauer and she confirmed that she issued the transcript to the Defendant, Mr. Constantino because he told her that Isabelle's parents issued oral consent to him.


 35.   Defendant, Susan Szachowicz is the Principal of Brockton High School. Prior to  relocating to the City of Brockton, Isabelle's parents opposition has infiltrated Brockton and lobbied the Public Schools. The administration of the Brockton Public Schools was aware and to unblock this organization, the Deputy Superintendent and Director of Operation (Mr. Michael P. Thomas) accompanied Dr. Ofume  and Ms. Isabelle Ofume through the admission channels and processes but the resistance conduct of the director of the Azure House, guidance/counselor (Joan Williamson) and office clerks show that the entire system has been build for confrontation because they were not respecting the instructions of the Director of Operation because they were taking contra instructions from the Principal. The Principal requested them to stay sending Isabelle's parents  release to one of the best High Schools in the United States (Riverbend High School, Fredericksburg, VA) where Isabelle did grade 10 full year and with straight  A/B+ but in search of lead to get low scores, the principal commanded them to contact Holyoke High School and Classical High School were Isabelle's record has been messed up because of imposed and politicized scores in which A/B+ were matched with uncompleted or  unfinished exams, tests, assignments and  incomplete grades  were scored 0 or F to get failing score to block Isabelle from pursue the intended medical career.                              

36. Defendant, Bose, Animesh is Isabelle's  Mathematics teacher at Holyoke High School  and  the action of the DCF and Holyoke Police Department on January 31, 2011 has led to Isabelle’s failure to complete several tests, exams, assignments and home works which part of the score structure and that courses such as  Honor Algebra II, AP British Literature, Honors Chemistry, AP US History, etc that information from her school shows that these  uncompleted or  unfinished exams, tests, assignments and  incomplete grades  were scored 0 or F.
                                                                                                                                                       

37.    Defendant,  Brassil, Thomas  is Isabelle's   Physical Education teacher at Holyoke High School. Reason that there was eminent threat by the White Supremacist Organization to use its members in Isabelle's Class to use physical education activities in the gymnastic to assassinate Isabelle as it attempted to assassinate Isabelle's sibling, Keynes Ofume  at Lynn Classical High School in 2009. Parents and Plaintiff petitioned  Isabelle's teacher, the Superintendent of the Holyoke High School to waive Isabelle's participation in Gym.  Bcause of this threat which w   as issued on parent by this group several time by telephone, Isabelle did not do Physical Education. Under this political brawl and anger, the Physical Education teacher scored Isabelle F on the course she did not do because she is not fit to do the course. Plaintiff request this Court for an Order on the teacher of the Physical High School and Brockton High School to expunge Physical Education from her report card.

38.   The Defendant, Donahoe, Helen  is Isabelle's Science teacher at Holyoke High School  and  the action of the DCF and Holyoke Police Department on January 31, 2011 has led to Isabelle’s failure to complete several tests, exams, assignments and home works which part of the score structure and that courses such as  Honor Algebra II, AP British Literature, Honors Chemistry, AP US History, etc that information from her school shows that these  uncompleted or  unfinished exams, tests, assignments and  incomplete grades  were scored 0 or F.

39.    Defendant, Kelly, Doryn  is Isabelle's  English  teacher at Holyoke High School  and  the action of the DCF and Holyoke Police Department on January 31, 2011 has led to Isabelle’s failure to complete several tests, exams, assignments and  home works which part of the score structure and that courses such as  Honor Algebra II, AP British Literature, Honors Chemistry, AP US History, etc that information from her school shows that these  uncompleted or  unfinished exams, tests, assignments and  incomplete grades  were scored 0 or F.

40.   The Defendant, O’Connor, Gary is Isabelle's Guidance Counselor severally forced Isabelle to do Gym and detained her and libel against her by telephoning several people and agencies such as the Department of Children and Families, Holyoke Police Department (HPD), Holyoke District Homeless Coordinators, Superintendent of Holyoke Public Schools, Director of Family Homeless Shelter, etc to the extent that the Gym teacher said that the Defendant,  O’Connor, Gary forced him to issue F to Isabelle on Physical Education a course Isabelle did not do.  Plaintiff seeks Order of this Court to request Mr. O’Connor, Gary and Holyoke High School to expunge this score and defendant to resign immediately and reasonable damages be paid to Isabelle.

41.   Defendants, Sullivan James and Grove are Isabelle's Physics teachers  at Holyoke High School  and  the action of the DCF and Holyoke Police Department on January 31, 2011 has led to Isabelle’s failure to complete several tests, exams, assignments and  home works which part of the score structure and that courses such as  Honor Algebra II, AP British Literature, Honors Chemistry, AP US History, etc that information from her school shows that these  uncompleted or  unfinished exams, tests, assignments and  incomplete grades  were scored 0 or F.

 42. Defendants  A'Hearn Karen (AP European History) and Michele Conners (Social Studies Department Chair) are teacher and head  Isabelle's AP European History. When Isabelle was admitted at Brockton High School this Class has done about three weeks and the teacher or Defendant refused to set migrant catch or remediation program to enable Isabelle adjust and transit into the past and on-going teaching and learning. In place of this program which federal and state monies are used, the Defendant gave Isabelle several assignments/tests on the topics which the class did when Isabelle has not been admitted to the school and  without teaching her the topics. From the first day the teacher/defendant used bullying and harassment method to request Isabelle to read more and more new books on the work the class did when Isabelle has not been admitted and continued to strain Isabelle physically and psychologically by issuing almost daily assignments to overload the past assignments. Isabelle submitted all the past works and assignments which is 50% and the on-going work is 50% but the Defendant refused to score them   50% of the overall score and failure to allow her submit her summer work is a plot to put her grade at F or failing grade.  During investigation, Defendant, Michele Conners agreed that she order the A'Hearn Karen to deny Isabelle right to submit her work and head of the department of social sciences did not give reason for her denial. Order of this Court sought immediately to request the defendants to score and add up Isabelle score and defendants to resign and pay reasonable damages to Isabelle.

43   Defendant, Mrs Deirdre Smith  is Isabelle's English teacher. When Isabelle entered this class the first day she encountered unspeakable political animosity and she felt the impulse of hate and she intended to disengage from the school because the hate in this class was similar to the hate she expereinced in the other classes at Brockton High School, and Holyoke High School. Defendant, Deirdre Smith built agression and anger within fellow classmates and energized the  entire class to isolate her and she has been alone because the teachers and administrators told her classmates and person she may say hello to on daily basis that she's a bad person and that if they associates with her they will fail all their courses. Defendant, Deirdre Smith showed the anger by forcing Isabelle to read several summer books, assignments, tests and examinations without teaching her and additionally she must read several  books and do all assignments, tests and examinations which accompany the on-going class works. Heartlessly, at Lynn Classical High School Isabelle has read summer books and did all the assignments, tests and examinations all of which have been marked and scored but defendant, Mrs. Deirdre Smith ignored Congress directive issued to the Hon. Secretary of Education, in Section 1308 (b)(2)(A) of the statute, to ensure the linkage of migrant student record systems. Isabelle work over all days and slept less than four hours per day including week end and holidays punitively to complete the summer works and on-going class works (assignments, tests and examinations) but Defendants refused to mark and score them because the politicians paid the school to issue F in all Isabelle's works in other to block her plan to study medicine and earn High School Diploma. Under normal circumstance or without political hate and animosity, majority of Isabelle's works are A/A+/B+.but all the defendants (teachers) entered straight F and this particular teacher entered tardiness in place present to get three personal or in-school unlawful rule which says that three (3) tardiness will will convert all the passing scores (A/A+B+) of any student will be scored F.


44.      Defendant, Mrs. Stewart   is Isabelle's  Pre-calculus  teacher and Isabelle has never done Calculus before. Work already done before Isabelle was admitted were imposed on her without teaching or remediation or catch program. Defendant told Isabelle to leave the work that she will organize tutorial but she never organized the tutorial to present time. Restating that the Defendant, Mrs. Stewarts did not organize or put in place remediation program to enable Isabelle catch up with the work which the class did prior to Isabelle's admission. Without this part, she boldly issued F and posted it on the school report card. Defendant teaching and response to students's questions,  Plaintiff suspect that the defendant did not  study and have knowledge of Calculus. After teaching, majority of the students in the class will not understand the topic taught and all the questions will not be answered and she rant without the skill to solve the calculus question task, some students will go to the teaching board to try solve the task which the teacher can not solve.  Under this poor teaching, the majority of the students in the class have failing grade and some preferred students are awarded score  to defuse protest. The teaching and testing are questionable because after teaching she will not answer and resolve the questions which students asked and the Defendant will not test the students soon to match the students with the practice and comprehension but she will wait several  weeks to impose test when student who were maltaught and may have forgotten what taught with questions unanswered from time to time.

45.     Defendant,  Ms Heenan Suzanne  is Isabelle's Biology teacher. During the interview students, Plaintiff found that the Defendant has overwhelming difficulties to teach biology and in place of teaching she organizes the student team or work group plan thus, targeting smart students who are non-whites. Same vein, she form team by selecting smart student and unit him/her with two weak students. Several of the defendants stated above do the same thing.  Unable to teach and test and  graded assignments are made up of untaught  topics. Formed team of two weak students and one smart student is destructive and talented and smart students are prone to earn low grade because the two weak students attached to the smart students present failing contribution to the group assignment and drag the smart student's score to the mud. The project was left for the smart student or Isabelle  to do and the score is low score because the weak students are trained to formulate complaint that the smart student did not give them the opportunity to contribute. At this point, the worst occurred because the work plan is reversed to the extent that the defendants (teachers) request them to share the work and turn each work to other  team mate to score and crtic and  pass the scored team work round and round until the work is totally mess up. The process becomes  the type where weak students correct and score the work of smart student in other to intimidate the smart student.

46.  Defendant, Ms.  Logan Denise is the Physiology and Human Anatomy  teacher of Isabelle. Several scored assignments, tests and examination which Isabelle completed and submitted to the Defendant were not included in the score evaluation and assessment grade book and were not issued and given to Isabelle to return to parents or Plaintiff. In January 2012 Physiology and Human Anatomy  class started and since January 2012 Isabelle has done/completed several assignments, tests and examinations and after the works have been scored the defendant tactically refused to put them in the grade book. This a holding plan to deny that Isabelle ever did and submitted the work.

 47.    Defendant,  Honourable Secretary of Education is the head and secretary of the Massachusetts Department of Education and incharge of all educational sectors pre-k through tertiary institution. All the incidents stated above were received by hand delivery to the office of the Honourable Secretary of Education and no action was taken by the Honourable Secretary. Notice of the on-going action was also sent to the Secretary without action take to address the action of these public schools.

48.   Defendant, Honourable Commissioner of Elementary and Secondary Education is the commissioner of Elementary and Secondary Education in the Commonwealth of Massachusetts. The incidents stated above were received by hand delivery to the office of the Honourable Commissioner of   Elementary and Secondary Education and no action was taken by the Honourable Commissioner. Notice of the on-going action was also sent to the Commissioner without action take to address the action of these teacherss, principals administrators and superintenents.

49.  Defendant,  Honourable Secretary of Education is the head and secretary of the U.S. Department of Education and incharge of all Federal educational sectors pre-k through tertiary institution.   All the incidents stated above were received by hand delivery to the office of the Honourable Secretary of Education and no action was taken by the Honourable Secretary. Notice of the on-going action was also sent to the Secretary without action take to address the action of these public schools.  Directly, several incidents were posted on the Honourable Secretary's  social media (Facebook).

50.    Defendants,  Joan Williamson (Guidance Counselor - Brockton High School) and one  Female Front Desk administrative staff of the Brockton High School, have cruelly engage Isabelle in durable   BULLY, HARASSMENT, INSULT,  VIOLATION OF ISABELLE'S PRIVACY ACT, RELEASE OF ISABELLE'S PERSONAL OR CLASSIFIED INFORMATION(scores when students and vistors are many, told Isabelle publicly that she has straight F in courses -Fs which   were issued because of the falsification of tardiness, ,DISTORTION OF OFFICIAL RECORDS, PHYSICAL AND PSYCHOLOGICAL TORTURES, ETC. ON THE ISSUE "WITHOUT DOING YOUR GRADE 10  MCAS YOU WILL NOT GRADUATE AND WE ARE GOING  TO GIVE YOU CERTIFICATE OF ATTENDANCE IN PLACE OF  HIGH SCHOOL DIPLOMA" PETITIONERS WITH SEVERAL EXPERTS IN EDUCATION, POLICIES AND PRACTICES; HAVE READ MSIX AND NO CHILD LEFT BEHINACT (2001) AND QUESTIONED THE HONOURABLE SECRETARIES OF FEDERAL AND STATE DEPARTMENTS OF EDUCATION ON ACCRUAL PART OF THESE ACTS THAT THERE IS RATIONALE FOR A MIGRANT  STUDENT WHO HAS DONE/PASSED  EQUIVALENT OFGRADE 10 MCAS CALLED SOL IN BETTER AND ONE OF THE BEST HIGH SCHOOLS IN THE UNITED STATES NOW THE STUDENT IS IN GRADE 12 WHY SHOULD THE SUPERINTENDENT OF BROCKTON PUBLIC SCHOOLS MR. MATTHEW H. MALONE WASTE PUBLIC SCHOOL'S RESOURCES TO ENGAGE IN STAFFMEETINGS AND WRITE AND MAIL EXPENSIVE CERTIFIED MAILTO ISABELLE AND ENERGIZED AND REQUEST THE STAFF TO EXPAND SUCH HARASSMENT AND BULLYING ACTIVITIES AGAINST THISSTUDENT WHO RESPECTED MR. MALONE, HIGHLY RACIST GUIDANCE COUNSELOR WHOCALLS ISABELLE TIME TO TIME IN THE MIDDLE OF AN ON-GOING LECTURES PURPOSELY TO RESTATE, ""WITHOUT DOING YOUR GRADE10  MCAS YOU WILL NOT GRADUATE AND WE ARE GOING  TO GIVE YOU CERTIFICATE OF ATTENDANCE IN PLACE OF  HIGH SCHOOL DIPLOMA."  THIS A STUDENTWHO HAS BEEN ATTENDING SCHOOL UNDER THE CIVIC, MORAL AND ETHICAL SUPPORT OF THE CHURCH OF JESUS CHRIST OF LATTER-DAY SAINTS AND LIMPT,INC.(EDUCATION & WORKFORCE PROJECT).WITHOUT THIS BACKGROUND CONSIDERATION OF THE NONCHALANCE OF THEBROCKTON POLICE DEPARTMENT, HON. SECRETARIES OF THE FED/STATE DEPARTMENTS OF  EDUCATION, AND FBI TO INVESTIGATE THESE ACTS OF INFRINGEMENT, SUCH STUDENT WOULD ATTEMPT VIOLENT PATH TO SEEK REDRESS AGAINST THESE STATE POLITICIZED ABUSERS.

52.    Defendant, Ms.  Joan Williamson  is Isabelle's Guidance Counselor at  Brockton High School. Across the United States in Urban and Mixed Urban Schools Guidance Counselors are threat to retention and assiduity and major brain behind the mass disengagement of non-whites from school and closures of these public schools thus, action which is crown on white education insurgency to remove so many non-whites from school to prevent them from acquiring education to take white jobs across the United States. The activism in the US, states and district courts empower this white supremacy and handicapped human rights works like LIMPT,INC, IMUN, INC., etc. Defendant has censored enrichment information to Isabelle, disgraced Isabelle public and privately to force her to drop out of school. Talented, gifted, smart , A. A+ and B+ student like Isabelle are more targeted because these whites fear that they will earn education pre-K through tertiary level to compete for job and other services. Defendant and another administrative staff ( defendant) mentioned above have insulted Isabelle publicly to trigger school disengagement. Via school monitoring camera and course syllabus schedules, Defendant,  Joan Williamson (Guidance Counselor - Brockton High School) has targeted when Isabelle was doing important work in the classroom and removed her to harass, bully and question her saying "I WILL SEIZE YOUR SENIOR ID IF YOU CONTINUE TO BE TARDY AND GET F...YOU WILL NOT GRADUATE IF YOU SHOULD CONTINUE TO REFUSE TO DO GRADE 10 MCAS..." Complaints have been made to the defendants, Hon. secretaries and commissioners of  and superintendents of these punlic schools, police departments of these districts, written to the President and Vice-President of the United States, governor, congress of the United States, etc without action taken in all the circumstances.


 F.         ARGUMENT UPON WHICH COMPLAINT MADE AND RELIEF SOUGHT
Plaintiff requests leave of this Court to assign numbers to this argument because in other courts, parts or paragraphs of its argument or brief have been missing or deleted ad altered to change meaning and content to reduce the weight of its case.


53 .       This Court has jurisdiction over the subject matter and personal matter herein pursuant to 28 U.S.C. §§ 1331, 1343, 1345, and 2201-2202, as well as 42 U.S.C. §§ 2000c–2000c-9,20 U.S.C. §§ 1681–1688, and 29 U.S.C. § 1367(a).Venue in the District of Massachusetts  is proper pursuant to 28 U.S.C.II. 1391(b) and that some of the infractions are Harassment and Bullying and hate because of political belief which also include the use of derogatory language, intimidation, release of victim's personal school and other information to the public with consent from victim's parents, physical and psychological tortures and threats of Mounted Brockton/Holyoke/Lynn Police Departments; or the use of derogatory language which is done by publicly disclosing her personal and family information;  forcibly removing Isabelle from the classroom during core course lectures to make her get low grades and put her to public shame to force her to drop out of school and what are stated and restated time to time are "I/we will seize your senior ID if you continue to get F which is personally issued under illegal personal determination based on three tardiness which are forged to get straight F to block Isabelle application to Georgetown University, New York University, Howard University, etc to study Medicine...;  you must do your grade 10 MCAS and without doing it you will not graduate and get your high school diploma and we will confer on you only certificate of attendance; etc". Letter of the Superintendent (Mr. Matthew H. Malone) of Brockton Public Schools restating this harassment is incorporated and will be marked  EXHIBIT B.



54.    Ms. Isabelle Ifeoma Ofume was terribly mistreated, bullied, harassed, disgracefully disclosed and exposed  her personal Brockton High School scores, family's personal information and school report cards were exposed to students, mass public; Isabelle has been ex-communicated and in the entire school she is alone and class room team or group work is designed to increase harassment and bullying activities by the defendants and to get low scores; Isabelle is severely underscored at Holyoke High School and Classical High School and Brockton High School to block her chance to pursue medical career and university admission at New York University, Georgetown University, Howard University, etc all which are generated and activated because of parents' (Dr. Phillip Chukwuma Ofume and Mrs. Maureen Ngozi Ofume) bid for the President of Nigeria past and 2015 and because Isabelle campaigns for standard of education in urban and mixed urban schools in the USA. The action of the defendants violates First and Fourteenth Amendments to the U.S.Constitution and Bill of Rights; Title IV of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000c–2000c-9 (Title IV), and; Title IX of the Education Amendments of 1972, 20 U.S.C. §§ 1681–1688 (Title IX); Equal Protection Clause,Title IV, Title IX; UNITED STATES OF AMERICA et als  v. ANOKA-HENNEPIN SCHOOL DISTRICT NO. 11, et als NO. 11-cv-01999-JNE-SER & NO. 11-cv-02282-JNE-SER or any other state or federal law and denies all liability for any alleged statutory or regulatory violation, by the District or any of its employees, agents, or School such as three times tardness which is used to draw down all her scores to F and in this case several complaints sent to the Superintendeents of Lynn/Holyoke/Brockton public schools, Hon. Secretaries of state and US departments of education were unattended particularly under white privileges. Day to day, Plaintiff which is the representative of Isabelle and her siblings in these public schools has monitored the attendance of  Isabelle and her siblings and other students within its system and Isabelle was not tardy three times as claimed by Brockton Public School or Brockton High School. Under this animosity, several times when Isabelle was in school the staffs have posted tardness voice message on Plaintiff and parents' telephone and Plaintiff questioned all the posting and the staff incharge has apologized and promised to remove the posting. For example, Isabelle's English and other teachers have used this fake recording to issue F on Isabelle's work and during Plaintiff's complaint to the defendants and FBI, on particular tardy date claimed by the English teacher and other teachers, Plaintiff found that Isabelle was in her class and other classes and latter-time the English and other teachers admitted that Isabelle was in their classes but the English and other teachers offered no apology and refused to change the F score.




 55.        Ms. Isabelle Ifeoma Ofume, is U.S. domestic Migrant Student, Isabelle and parents and siblings are United Nations Convention Refugees, statelessperson,  Asylee in the US and also Isabelle is International Migrant Student and with academic records in Canada (Bedford South School, Bedford, Nova Scotia Canada B4A 4B6); United States (Riverbend High School, Fredericksburg, Virginia, Lynn Classical High School, Lynn MA, Lynn Classical Academy, English High School, and Burncoat High School, Worcester, MA, now at Brockton High School and in grade 12); reason that Holyoke High School, Lynn Classical High School and Brockton High School are part of the United States and receive federal fund, Isabelle record must be matched pursuant to The Migrant Student Information Exchange (MSIX) per the mandate of the  Congress, in Section 1308 (b) of the Elementary and Secondary Education Act, as amended by the No Child Left Behind Act of 2001 (NCLB) to enable  intended state of migration to avoid duplication and creating redundancy of allowing the migrant student to repeat the tests, courses and examinations which the student has done and completed in his/her previous state and school where he/she migrated. Further, Congress directed the Secretary, in Section 1308 (b)(2)(A) of the statute, to ensure the linkage of migrant student record systems.



56. The clause of equal protection is dumped by the principal defendants (Hon. Secretaries of US and Mass Department of Education and Hon. Commissioners of Education and Superintendents).September 28, 2011 - present time the conduct of the United States and the world which is in search of peace to replace war/conflict found nothing because of vague ego of the dream of power.  All the 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‖),finally settled on expanding the harasssment and bullying activities and the Title IV and Title IX action-positions raised by the United States and the equal protection and federal and state law assertion raised by the Plaintiff and after reviewing the nonchalance of which makes Isabelle to shed tears almost everyday back from school because of several unfair, unjust, unreasonable, and other conducts which are inconsistent with federal law, and the Students' peace of mind.




57.    Plaintiff requests this Court for an Order on all the public school districts sued to use the mechanism provided in accordance with the requirements of Title IV and Title IX, their implementing regulations, and OCR Guidance, to stop and prevent further harassment in its education programs and activities to make sure other students do not suffer the physical and psychological tortures which Isabelle and other students suffered in these school districts.



58.  Isabelle Ofume,  under the roof or premises of Brockton High School, Lynn Classical High School and Holyoke High School she has been continually threatened to forfeit her graduation in June 2012, suffered physical and psychology tortures, teasing,  Social exclusion or ex-comunication, daily threats which could trigger disengagement or drop out from school, massive  Intimidation, racial ad other harassment, Public humiliation icluding public disclosure of imposed and untrue failing and call trash her senior ID because she not worthy of wearing it, etc. Ancient and modern times, “bullying” means systematically and chronically inflicting physical hurt or psychological distress on one or many students, admiistrators and teachers may be involved and in Isabelle's  case many students, teachers and admiistrator were involved on daily basis.


59. SHORTLIST OF WEBLINKS on what Isabelle Ofume suffered and outrage of lawlessness in the educational sectors of the Defendants:

59.a.


http://universal-fashion-art-music.blogspot.com/search?q=holyoke+high+school%2C+brockton+high+school%2C+lynn+classical+high+school

59.b.  


http://universal-fashion-art-music.blogspot.com/2011/11/brockton-high-school-holyoke-high.html

59.c.


http://www.google.com/#pq=limpt%2C+inc+v.&hl=en%20&sugexp=kjrmc&cp=28&gs_id=3i&xhr=t&q=LIMPT%2C+%20INC.+V.+UNITED+STATES&pf=p&sclient=psy-ab&source=hp&pbx=1&oq=LIMPT,+INC.+V.%20+UNITED+STATES&aq=f&aqi=&aql=&gs_sm=&gs_upl=%20&fp=1&biw=1366&bih=667&bav=on.2,or.r_gc.r_pw.,cf.osb&cad=b

59.d.


http://groups.google.com/group/soc.org.nonprofit/browse_thread/thread/8047794a7245ef6d?pli=1

59.e.

http://groups.google.com/group/soc.org.nonprofit/browse_thread/thread/8047794a7245ef6d?pli=1

59.f.


Ofume's Mandate 2015:

 http://www.phillyimc.org/en/event/dr-phillip-chukwuma-ofume-president-nigeria-2011-complete-political-manifesto.

59.g.
Phillip Ofume's foreign or non-nigeria  opposition  at:

http://universal-fashion-art-music.blogspot.com/2011/07/america-uk-and-some-western-nations.html; Presidential Candidate of Nigeria 2015

  G.        PARTIAL TEMPORARY  INJUNCTION

60.   During research and investigation on pattern of marking and assigning scores, Plaintiff found that the defendants give scores based on color, race, and political preference. Further temporary injunction Plaintiff request this court for teemporary order to stop Brockton High School graduation scheduled to take place in June 2012 pending determination of this emergency complaint because to stop Isabelle from graduating because she did not repeat the test which she has done and passed in Virginia in 2010 would severely violate  Congress' directive issued to the Hon. Secretary of Education, in Section 1308 (b)(2)(A) of the statute, to ensure the linkage of migrant student record systems.



 61.                                   RELIEF

 61.a. THEREFORE, for the foregoing reason, Plaintiff request this Court for emergency Order on Brockton High School to respect the law of the federal government of America  and allow Ms. Isabelle Ifeoma Ofume graduate in June 2012.



61.b.  Order of this Court to set up jury of expert to review all the works of Isabelle's class at Brockton High School and use the works/scores of other students to compare Isabelle's works in order to  reverse all the works scored F because of falsified three tardiness created by the defendants to make Isabelle loss the chance of getting admission to study medicine.



61.c. Order to appoint highly inclusive educational experts to review the educational fraud carried out by the Defendants. Educational experts to guide Defendant, Gene Constantino to separate and remove all  uncompleted or  unfinished exams, tests, assignments and  incomplete grades and  scores and when he matched the 0 or F.



61.d.  Because of the extensive and harsh harassment, bullying, public disclosures of scores, mockery, intimidation, and disclosure of parents/family's private information, fatal libel, and related  cruelty, on behalf of Isabelle, Plaintiff seek  nominal, compensatory, and punitive damages, and other costs which this Court deems fit but considered within the sum amount of five million US dollars ($5million) because Isabelle under the roof or premises of Brockton High School, Lynn Classical High School and Holyoke High School Isabelle Ofume threatened to forfeit her graduation in June 2012, suffered physical and psychology tortures, teasing,  Social exclusion or ex-comunication, daily threats which could trigger disengagement or drop out from school, massive  Intimidation, racial ad other harassment, Public humiliation icluding public disclosure of imposed and untrue failing and call trash her senior ID because she not worthy of wearing it, etc. Ancient and modern times, “bullying” means systematically and chronically inflicting physical hurt or psychological distress on one or many students, admiistrators and teachers may be involved and in Isabelle's  case many students, teachers and admiistrator were involved on daily basis.

 Respectfully submitted,
HRRG, IHRRC, LIMPT, INC/IMUN,INC. & ASSOCIATES                                                        (EDUCATION & WORKFORCE PROJECT -  USA CHAPTER)

Signed
___________________
Phillip C. Ofume, Ph.D.
National Coordinator/Representative/Advocate for LIMPT, INC.


    VERIFICATION OF COMPLAINT/MOTION

I, Ms. Isabelle Ofume hereby respectfully verify the above mentioned Complaint and attached Motion that they are correct to the best of my knowledge and signed and authorize submission under the pains and penalties of perjury this 23rd   day of May 2012.

Signed
____________________
       Isabelle Ofume

Contact and Service Information of the Defendants:



Diane Bauer, Principal; Bose, Animesh                                                                                                         (Mathematics Department)                                                                                                                                  and Brassil, Thomas  ( Physical Education Department) and Donahoe, Helen  (Science Department) and Kelly, Doryn  ( English Department) and O’Connor, Gary (  Guidance Departmen) and Sullivan James and Grove (Physics)
c/o Holyoke High School
500 Beech Street, Holyoke , MA 01040
Phone: (413) 534-2020