AMERICA: HELL IN U.S. URBAN/MIXED URBAN SCHOOLS OR NON-WHITES SCHOOLS

        COMMONWEALTH OF MASSACHUSETTS
        Suffolk, ss.      

      SUPERIOR COURT DEPARTMENT
                                                                                                                                                                                                      OF THE TRIAL COURT

                                CIVIL ACTION DOCKET NO. ________________________________


_______________________________________________________



Phillip Ofume,  on behalf his four (4) minor children in K and                                                                                                                             grades 2, 5 and 8 at Plouffe Academy and  Arnone Elementary                                                                                School, Brockton, MA -under protection of the rights of minor children,       names reserved and will be personally referred to as  Child G, C, B and L)
                                      Plaintiff  (Pro se  and Forma Pauperis)


                                        v.


 Plouffe Academy, Arnone Elementary School and Brockton Police Department and Principals and Ms.  Michelle Nessralla (Principal of Plouffe Academy) and Mr. Kenneth Kevelson (Algebra Teacher) and Honourable Secretary of Education and Superintendent of Brockton Public Schools and Kary Denitzio (Homeroom Teacher), Guidance Counselor (Mr. McDonald), Guidance Counselor (Mrs. Lobo) and Honourable Commissioner of Elementary and Secondary Education and Eric McGuire (Teacher of Grade 5) and Ms. Colleen Proudler (Principal of Arnone Elementary School)  and Ms. Peri Jacoubs (Assistant Principal of Arnone Elementary School) and Lynn Breed Middle School and Acting Principal Ms.  Julie Louf (Breed Middle School, Lynn, MA) and Female breakfast/launch staff (Arnone Elementary School, Brockton, MA) and Ms. Werner and Ms." Depina" (teachers of Student G)          

                                                         

                                      Defendants
__________________________________________________

                                   COMPLAINT

A.                                   PARTIIES
  1.   In full name Plaintiff, Dr. Phillip Chukwuma Ofume is resident of the Commonwealth of Massachusetts within the jurisdiction of this Honourable Court. This  Action is brought to this Court on behalf four (4) minor children in K and grades 2, 5 and 8    at Plouffe Academy and  Arnone Elementary School,  Brockton, MA - names reserved and will be personally referred to as  Child G, C, B and L) and residents of Brockton of Massachusetts within the jurisdiction of this Court.

2.    Defendant ,  Plouffe Academy  in the city of Brockton and district/county of Plymouth of Massachusetts  is an urban public school with the rank of middle school  and admits students from grade 6 through grade 8.

3.  Defendant , Arnone Elementary School is located   in the city of Brockton and district/county of Plymouth of Massachusetts  is an urban public school with the rank of elementary school  and admits students from K through grade 5.

4.   Kenneth Kevelson  is the Algebra teacher at Plouffe Academy, Brockton, Massachusetts

5.   Defendant, Guidance Counselor (McDonald) is a  staff at Plouffe Academy, Brockton, MA.

6.     Defendant, Michelle Nessralla is the Principal of Plouffe Academy, Brockton, MA.

7.   Defendant, K. Denitzio is the hommroon teacher at Plouffe Academy, Brockton, MA.

8.      Defendants,  Colleen Proudler  is the Principal of Arnone Elementary School, Brockton, MA and Ms. Werner is a teacher of Student G. at Arnone Elementary School, Brockton, MA.

9.    Defendabnt Peri Jacoubs is the Assistant Principal of Arnone Elementary School,  Brockton, MA.

10.     Superintendent of Brockton Public Schools, is the head of the Brockton, MA  Public Schools system within the jurisdiction of this Court.

11.     Defendant ,  Lynn Breed Middle School  in the city of Lynn and district/county of Essex of Massachusetts  is an urban public school with the rank of middle school  and admits students  grade 6 through grade 8.

12.   Defendant, the Acting Principal Julie Louf (now)  is the Acting Principal of  Lynn Breed Middle School  in the city of Lynn and district/county of Essex of Massachusetts  is an urban public school with the rank of middle school  and admits students  grade 6 through grade 8.

13.   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.

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

15.   Defendant, Eric McGuire is Grade 5 teacher at Arnone Elementary School, Brockton. MA with the jurisdiction of this Court.


16.  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.



17.   Defendant, Brockton Police Department (BPD) is the police department in charge of the City of Brockton, MA.



18.  Defendant, Female breakfast/launch staff (Arnone Elementary School, Brockton, MA) is one of the launch and breakfast at Arnone Elementary School and she serves breakfast and lauch meals on the  students.

B.                     JURISDICTION OF COMPLAINT


19.   The Defendants and Plaintiff and victims reside in the Commonwealth of Massachusetts and as apportioned below per multiple infractions this Court has personal and subject matter jurisdiction over the Complaints.

20.    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.


21.  That  these four (4) minor children, G, C, B, and L are  in K and grades 2, 5 and 8 at Plouffe Academy and  Arnone Elementary School,  Brockton, MA. Under the rights of minors, the  names of these children are  reserved  but  purpose of this case will be personally referred to as  Child G, C, B and L) and residents of Brockton of Massachusetts within the jurisdiction of this Court. The Defendants as apportioned below per multiple infractions,  have caused various weight of  harms and mistreatments  such as bullying, harassment, have been  round-up with other Blacks and  branded theft and paraded before the mass public of Arnone Elementary School and Lynn Breed Middle School because of their color, race and other unwarranted decoration; multiple size of social exclusion;  different  threats; intimidation ; under-marking and scoring; removal from the classroom during test/examination; removal of classroom during teaching of core courses such as English, Sciences, Mathematics; shameful teasing;  converted student C money and protected by mounted Brockton Police Department; bullying ; social and school exclusion; threat of failure and failed without merit by Student L; funding young boys/girls to lure, deceive and get female talented/smart/gifted/ honor/high honor/A/A+/B+ students pregnanted  to derail their educational career (confession by student agents on case of student L); detention, students B and L; intimidation by defendants and student agents on cases of students B, L, G, and C; stalking students L, and B ; physical violence, case of student G;  stereotype; branding students B & L  thieves and paraded inside and outside school pr emises by defendants and student agents; excessive streaming similar to maximum prison cases of students L and B;  racial harassment students B and L;  public humiliation, students B and L; destruction of property, student B; etc. . Defendants allowed  in-house (school premises) detention and stalking, allowing physical violence without surpervision, racial harassment, multiple public humiliation and related human degrading activities were carried out against students, victim B, L, C, and G.,



22.     The conducts of the defendants including stay of intervention are barred under  Title XLVIII K-20 EDUCATION CODE Chapter 1006 SUPPORT FOR LEARNING (View Entire) Chapter 1006.147,  s. 815.03 and  s. 784.048(1)(d).   Bullying and harassment are prohibited (cited as the “Jeffrey Johnston Stand Up for All Students Act.”  Bullying or harassment of any student of a public K-12 educational institution is prohibited during  any education program or activity conducted by a public  school K-12 educational institution. The Superintendents of these Public Schools tie themselves with the prifix of doctor and armed with this rank they are  aware of their own action and the action of the staffs under their organizational structure but if they are lay, Plaintiffs may clarify their action purposes of this lawsuit that, “bullying means systematically and chronically inflicting physical hurt or psychological distress on one or more students and may incorporate infraction listed above."






B.          ON BEHALF VICTIMS, STUDENTS,  THE PLAINTIFF                                                                                                     ALLEGES AND AFFIRM THE FOLLOWING:

 On behalf Students G, C, B, and L,  Parent, Plaintiff,  Dr. Phillip Chukwuma Ofume an outstanding international Human Rights and excelled in Pro se Law Practice Court to Court from the small courts through the Supreme Court of the United States and Canada and after exhausted the domestic mechancism and apart from defeating the Government of Canada,  he moved higher and higher to the United Nation and there after he made unmade history when 1999 - 2003 he was able to get three United Nations Special Rapporteurs and three United Nations Reports and he prevailed. In the Juvenile Court he made unbeatable mark in the matter, Phillip Ofume/ Maureen Ofume v. Department of Children and Families (DCF) when within five days he used Interlocutory Motion to destroy the custody and care cases of the DCF and secured the full custody and  care of five children removed by the DCF.


With this incredible experience he  brought this Action against Massachusetts Department of Education and its heads  and U.S. Department of Education and its heads and Plouffe Academy and Arnone Elementary School and administrators in these schools and Brockton Public School and its Superintendent alleging claims of violation of the constitutional rights of the child, students G, B,B, and L, detention,  harassment, discrimination, etc on the basis of academic and professional orientation in the District of Massachusetts and United States under 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‖),and the Massachusetts  Human Rights Act, etc and  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) and , thus filed a Complaint-in-Intervention in this action and move this Honourable Court to grant his Complaint and relief sought.


C.              CAUSE OF ACTION

         
                                      COUNT #1



21.      Clearly alleged that Defendants  have caused various weight of  harms and severally caused them severe acute forms of mistreatments  such as bullying; harassment; that on April 2, 2012 and May 24, 2011 Colleen Proudler,  Eric McGuire , Julie Louf,  Peri Jacoubs  and other defendants have profiled and round up students B and L with other Blacks  in classes made of whites, blacks, hispanics, etc and  branded them theft and paraded them before the mass public of Arnone Elementary School and Lynn Breed Middle School because of their color, race and other unwarranted decoration as plot to force them to disengage from school; complaints filed with federal and state HUMAN RIGHTS COMMISSIONS and THE ATTORNEY GENERAL OF MASSACHUSETTS remain stocked without action taken to investigate and act upon the complaint in any capacity.



                          COUNT # 2



22.        A  Female breakfast/launch staff (Arnone Elementary School, Brockton, MA) and Colleen Proudler have conspired to use launch meal to poison student, C and   Eric McGuire  and Colleen Proudler have conspired to use ICE CREAM to poison student B and student G was poisioned by another launch staff and the names of these launch/breakfast staffs were procted by defendants,Colleen Proudler, Peri Jacoubs, Arnone Elementary School and its administrators and all requests to disclose their names were unheeded by  Colleen Proudler, Peri Jacoubs, Arnone Elementary School and its administrators. Under white privilege and other political decoration these three poison cases were designed to kill students, G,C, and B. Severally, Brockton Police Chief and Department were contacted and formal complaint filed without action taken to arrest, investigate and press charge against  the defendants because they are whites and the police chief and majority of the operatives of the BPD  are whites and students C, G, and B are blacks and generally over 99% of the defendants are whites and because of the negligence of the police to effect arrest and  investigation on  the incidents, several physicians in these incidents and complaints were administering random medical care and variously put in professional darkness and students, B, C and G continue to suffer pains and several tardiness as result of several emergency runs to the hospital and fruitless physician treatment to cure an unknown poisons. All medical reports and activities will be incorporated and become available in support of these Complaint.



                                  COUNT # 3


23.    Against student, L and B there have been multiple size of social exclusion;  different  threats of failure, detention, school exclusion and marginality; intimidation in part supported by mounted police; under-marking and scoring; failure of teachers and administration attention and care suffered by students G, B, and L . Students L and B were several removed from the classrooms and particularly student L was time to time removed from the classroom during test/examination; removed from the  classroom during teaching of core courses such as English, Sciences, Mathematics,etc by  K. Denitzio, Guidance Counselor (Mr. McDonald), Guidance Counselor (Mrs. Lobo), Michelle Nessralla, etc.

                                            COUNT # 4

 24.     Student B suffered frequent shameful teasing by  Eric McGuire and her several student agents before the classroom sessions and bred the students to expand the activities to the neighborhood which compelled him to cry from time to time and refused to go to school the following days. Several complaints of peer-peer  bullying and harassment were made to the Chief of Brockton Police and Department without action taken to stop these threaten action in these schools.

                                       COUNT # 5

25.   Parent, Dr. Phillip C. Ofume  of student C put the sum of five dollars ($5.00) in an envelope and sealed the envelope and wrote the full  names of student C on the front or recipient side  of the envelope and  gave the envelope to a female staff at  Arnone Elementary School. The staff cconverted student C money  and Brockton Police Department entered inbetween the activity of the conversion and protected the staff.

                          COUNT # 6


26.      Student B and L suffered  aggrevated  bullying ; social and school exclusion; threat of failure and failed without merit created by defendants, Kenneth Kevelson , Michelle Nessralla, Eric McGuire, Colleen Proudler,  Eric McGuire , Julie Louf,  Peri Jacoubs  and other defendants .  These defendants have funded and empowered other students to bully and harass student B, L, G, and C who are talented/smart/gifted/ honor/high honor/A/A+/B+ students to derail their  educational career (confession by student agents on cases of students L, B, C, and G. Also theese defendants have used in house (school) detention, bullying and harassment on students, G, C, B and L.

                           COUNT # 7



27.    Highhanded  intimidation by defendants, Kenneth Kevelson , Michelle Nessralla, Eric McGuire, Colleen Proudler,  Eric McGuire , Julie Louf,  Peri Jacoubs  and other defendants and student agents against students B, L, G, and C; stalking, stereotyping and streaming  students L, and B ; Defendant, the Grade 5  teacher Eric McGuire has  profiled  smartness including student B and created classroom seating group and student B is the smart/talented/gifted /A/A+/B+ students'  student in her classroom and her student agents have created minor and fatal allegations against these students particularly student B  including the incident designed by these student agents  on 4/2/2012 and several other days which forced student B to disengage from school and parents and their representatives (LIMPT, INC - EDUCATION AND WORKFORCE PROJECT) assisted student B by counseling and words of courgage which empowered and re-energized student B to return to school again. To enable the bad students create more and more allegations,  Defendants,  Eric McGuire, Colleen Proudler and Peri Jacoubs removed student B  and others from the smart/talented/gifted/A/A+/B+ students' seating position to  the seating position of the bad, noisy and weak students' seating  position. These bad students are rewarded by the defendants particularly in all the classes of students B, C, and G. Defendants train these bad students on how to establish initial fake  friendly relationship to enable them create allegations against their victims including student B.  In the class of Defendant, LIMPT, INC found that defendant, Eric McGuire these bad students carry  out her instructions to enable them get free scores and play games on the computer whereas student B has been severally barred from using computer including barring him from using computer to do class assignment and academic research.  These students created several allegations against student B and make him be placed in long detention and  cry and refuse to go to school on the following days.

                      COUNT #8        

                           

28.          Physical violence at Arnone Elementary School, Brockton, MA, case against student G which was organized under peer-peer bullying and harassment, designed and put in place  by the teachers and  administrators',  Colleen Proudler and teachers  with maximum negligence of care and protection by the class teacher which is action capable of forcing child, G to disengage from school.  Student G was pushed on sharp object and she had serious injuries inside and outside her mouth and on her face. Student G  bled and swallowed the blood for several hours through closing time when her parents came to pick her up after school. The teacher, Defendants, Ms. Werner and  Colleen Proudler did not telephone or e-mail parents and their representatives (LIMPT, INC - EDUCATION & WORKFORCE PROJECT); another round of case of student G  under peer-peer bullying and harassment designed by the teachers , administrators and negligence of care and protection by the classroom  teacher which is action capable of forcing child to disengage from school, student G was pushed to sharp object she had serious injuries which rift  through her jeans and boot to inflict cut on her body, Defendants, Ms. Werner and  Colleen Proudler did not telephone or e-mail parents and their representatives (LIMPT, INC - EDUCATION & WORKFORCE PROJECT);

                                                   
            COUNT # 9


29.    Students,  G, C, B and L, Plaintiff filed, articled, published  and served up on Defendants ; several Complaints on the victim students' highhanded streaming to trigger drop out from school;  bullying ; social and school exclusion; threat of failure; funding young boys/girls to lure, deceive and get female talented/smart/gifted/ honor/high honor/A/A+/B+ students pregnanted  to derail their educational career; detention; intimidation; stalking; physical violence;  stereotype; branding students B & L  thieves; excessive streaming similar to maximum prison;  racial harassment;  public humiliation; destruction of property; etc. were reported to the Chief of the Brockton Police Department without action take to address the complaints and each time simple questions were asked by the Plaintiff  or the Ofume parents, the  principal and assistant principal, police was invited to remove Plaintiff or the Ofume parents out of the school premises. Students'  freedom of expression is suppressed  and the presence of police officers empowers the teachers and administrators which are over 98% whites in predominantly urban or non-whites school in which the students pupulation is over 90% non-white students.   In greater part, they are several talented/smart/gifted/ honor/high honor/A/A+/B+ students because  of the  self-help programs put in place by parents' and their representatives' Educational  Enrichment Programs (PEE) which are  organized informally after school, interactive  home school, weekend and breaks/holidays. Because across the United States an intersive research and investigation conducted on EDUCATION AND WORKFORCE show that pre-K-12 there are suburban schools (predominantly white schools and best schools) and in the other hand there are urban and mixed urban schools which are predominantly non-white schools and extreme majority of these schools are designed to be poor, low standard schools, and majority of the teachers and administrators are whites and deliberately  with several  programs (bullying, social exclusion, threat, intimidation, stalking, physical violence, stereotype, branding non-whites theft, excessive streaming similar to maximum prison,  racial harassment, public humiliation, destruction of property, etc. ) to force disengagement or drop from school because the whites think that if non-whites pass through pre-k-12 they will pass into tertiary institution and/or  are given education including better or standard education they (non-whites) will emerge to take their jobs, multiple better means of livelihood, take over the Presidency,  Congress and other lawmaking offices of the United States, etc. Arnone Elementary School, Plouffe Academy and Breed Middle School are urban school and mixed  schools and across these schools  several talented/smart/gifted/ honor/high honor/A/A+/B+ students are targeted in both test, examination, assignments, marking and scoring with irritating open classroom,  school and public  bullying, social exclusion, threat, intimidation, stalking, physical violence, stereotype, branding non-whites theft, excessive streaming similar to maximum prison,  racial harassment, public humiliation, destruction of property, stereotype, mockery, etc  to psychologically dimish their academic  assiduity and retention.  See http://universal-fashion-art-music.blogspot.com/search?q=holyoke+high+school%2C+brockton+high+school%2C+lynn+classical+high+school; http://universal-fashion-art-music.blogspot.com/2012/03/plouffe-academy-brockton-ma-urban.html



                                                                                                                                 
                                                COUNT #10



30.     Students, G, C, B & L who are   talented/smart/gifted/ honor/high honor/A/A+/B+ students have been variously and daily targeted to force them to drop out from school. The failure of the  Chief of the Brockton Police Department to act in accordance with Title XLVIII K-20 EDUCATION CODE Chapter 1006 SUPPORT FOR LEARNING (View Entire) Chapter 1006.147,  s. 815.03 and  s. 784.048(1)(d), the teachers and administrators are energized to do and undo with extensive impunity, thus on April 2, 2012 (Arnone Elementary School, Brockton, MA) and May 24, 2011  (Breed Middle School, Lynn, MA) students B and L and other non-white students were profiled and called thieves of money, cell phone, etc. of white teacher and student and the news was broadcasted across the school and community in general and students B and L cried and refused to go back to school. After investigation, these schools found that students L and B did not steal the money, cell phone, etc but these schools failed to reverse the news in these schools and communities in general. Parents and Plaintiff engaged these children in intensive guidance counseling before they agreed to return to school but the teachers and administrators at these schools continued  their bullying ; social and school exclusion; threat of failure;  detention; intimidation; stalking; physical violence;  stereotype; branding students B & L  thieves; excessive streaming similar to maximum prison;  racial harassment;  public humiliation; destruction of property; etc. against students , G, C, B & L. Other students who have no parents and Plaintiff to support their children experienced drop out and that is reason why drop out of students in US schools is higher internationally.


                COUNT # 11



31.   Severally, cited in the US urban and mixed urban schools,  talented/smart/gifted/ honor/high honor/A/A+/B+ students are placed in the sciences, algebra, calculus and other maths, english languages classes with weak and poor teachers to get failing scores/grade. Defendant,  Mr. Kenneth Kevelson  is the Algebra teacher at Plouffe Academy, Brockton, Massachusetts.  At Plouffe Academy, one (Kenneth Kevelson) of the two maths teachers  is unfit to teach algebra, The teacher mentioned above is not fit to teach Algebra and best students including student L who have been an outstanding talented/smart/gifted/ honor/high honor/A/A+/B+ student in Maths are forced to be in the class of this weak teacher. Initially and continuously, Plaintiff or L student's parents have requested Plouffe Academy, Commissioner of Education, Hon. Secretary of the Department of Education, Superintendent of Brockton Public Schools, Mr. Matthew Malone, Principal of Plouffe Academy, Ms. Michelle Nessralla, etc to transfer L student to another Algebra Classes where there are good teachers without action taken in all the circumstances. The good teachers have reviewed the teaching, marking and scores of the L student's Algebra teacher and found  several signs of academic instructional weaknesses including improper  and defective teaching , marking and scoring and lacking the professional and academic knowhows to solve majority of Algebra tasks and in0-class questions of the majority of the students . The horrible consequences of the action of the defendants to refuse to take the expert advise of the Plaintiff are huge because all or about extreme majority of the students including L student failed Algebra and they must repeat the Class of Algebra in grade nine(9). Parents and students are unable to protests because parents and students are typical urban lower and poor class community and fear of mounted police. Within Massachusetts, Plaintiff has cited a highly qualified Maths teacher (Black) who graduated from Harvard University and cerified Maths teachers but because she is a Black, Plaintiff reference was not considered by the defendants.  On May 28, 2012 Plaintiff was told that there is an on-going plan by the defendant and Plaintiff's  opponents to find job for this maths teacher and her husband far state (state reserved) of the United States to waive her evidence in this case.



                            COUNT # 12


32.      RACISM, POLITICAL  ANGER AND POISONED SCHOOL FOOD  TO KILL STUDENTS G, C AND B  AT ARNONE ELEMENTARY SCHOOL:  Parents of students, L, G, C and B bid for the President of Nigeria past and 2015 and their political opponents that are in control of the majority of the services in the united States including education, healthcare, social services have used services as tool to endanger and harm parents and students, L, G, C, and B. Opponents and this court have used sanctioned on housing and food stamps and cash benefits to lure parents and their students to food poison spots such as school breakfast and launch.  Soon as students L, G, C, and B were admitted at Arnone School food and other securities were discussed with the school authority but no effort was made to avert this danger. During school launch, on student C table as he was eating a meal in a plate,  suddenly one of the female  food staff rushed  to his table and removed the food he was already eating without permission and reason of her action student  was compelled to eat other food which same school food staff served him because if student C should refused or stop to eat and finish his meal he will be put in detention and punished in other ways. Student C said that thereafter in the classroom and throughout the school period and back home and to present time, he continued  to have stomach problem and unable to attend school the following day and continuously, time to time to present.  Student C was taken to the hospital in an emergency ambulance. Time to time students B and G have been suffering same endless stomach problem.



                   COUNT #13



 33.             On the food poisoning mentioned above severally,  Parents or Plaintiff filed complaint with the Brockton Police Department and no action was taken to arrest and question the food staffs,  to enable the assigned physicians at Brockton Emergency and Neighborhood hospitals know the procedure to follow to kill the poison. September 2011 - present, Student, C has been to emergency hospital several times without clear knowledge of the type of treatment the physicians are making to stop the longstanding pains students C, G and B  have been suffering. Particularly, several times when student, C was rushed to the emergency hospital under acute severe forms of pains, the physicians were tempted to rush into surgery blindly to cut open student, C stomach. They (physicians) have adopted general poison cure and treatment medications without killing the poison and student, C continues to loss weight and slowly dying.

   
                 COUNT # 14


34.      Defendant, Ms. Eric McGuire is Grade 5 teacher at Arnone Elementary School, Brockton. On teacher's attention on student B work and performance, marking and scoring, etc this teacher has exhibited open hate and discrimination  on student, B. Several weeks and over one month assignments, and have been neglected, abandoned and returned unmarked and unscored. Three remarkable students (names reserved under protection of minors) who are teacher's agents have bullied, harassed,  libelled and lied against student, B to force him to drop out of school. The actions (bullying ; social and school exclusion; threat of failure;  detention; intimidation; stalking; physical violence;  stereotype; branding student B  thief; excessive streaming similar to maximum prison; adverse counseling; racial harassment;  public humiliation; destruction of property; etc). These student, agents create allegations against student, B to please the teacher who in turn allow them to remain on class computer for several hours playing games and earn high score on work they did not do.  Student, B would not be allowed access to right to use computer for class assignment and the agent students are granted unlimited time to use computer to play all sort of games. B student and parents  fall under U.S. district, county, state and federal poverty level and it's the obligation of the teacher/school to grant him access to computer to do school work or assignment and stop students and teacher that are vandalizing his school supplies and blocking from access to right to school computers.


             COUNT #15


ORGANIZED PLOT BY TEACHERS AND ADMINISTRATORS (OVER 98% WHITES) IN URBAN/MIXED URBAN SCHOOLS TO GET LOW SCORE IN CORE MATRICULATION COURSES TO BLOCK PASSAGE PRE-K THROUGH TERTIARY LEVELS - MATHS, ENGLISH & SCIENCES

35.a.              Some of Plaintiff's students including students L, C, G, & B receive extra after teaching and because Arnone Elementary  School and Plouffe Academy refused to issue text books in several course syllabuses and disclose its teaching curricula and students' scored  works, our after school teaching which is now  the solution in urban and mixed urban schools is stocked because of this  lack of disclosure to create interactive teaching and learning between formal school and informal school or after school sessions. Under Plaintiff's research and investigation, these teachers and administrators who does not want to give education to non-whites, have created several obstacle to destroy Plaintiff programs such as issuing test, assignment, and examination without teaching and defectively teaching the majority of the core courses; stay of marking and scoring completed work; under-scoring completed work; bullying ; social and school exclusion; threat of failure;  detention; intimidation; stalking; physical violence;  poisoning targeted students' food; removing students' school supplies; stereotype; branding students L &  B  thief; excessive streaming similar to maximum prison; adverse counseling; censorship of enrichment and other information; racial harassment;  public humiliation; creating allegations during core course and other course teaching and testing and removing student L, B, G. & C. to keep these students in the offices of the guidance counsellor, vice-principal and nurse to get low score in time of testing;  destruction of other property including school supplies; etc.  Plaintiff's student, victim  L, G, C, & B have been suffering these cruelties and the defendants are directly and indirectly put on adequate notice but no action has been taken suspected because the defendants are whites and victims are non-whites under white privileges in the United States.

23.b.   In any an on-going semester, under Plaintiff's after school program  student, victim L, in the class of the weak Algebra teacher, Mr. Kenneth Kevelson Plaintiff  student, victim L used after school program to upgrade their algebra skill and she scored high grade and after she had 90% as the best in her classs anger ensued,  within the teacher and administrators . Particularly, the high grade angered the principal and the guidance counselor at Plouffe Academy and to make sure student's L  grade is lowered, and with the knowledge that  March 17, 2012  is completion examination day  of  the final assessment and evaluation of grade 8, thus on March 16, 2012 the principal and counselor designed a plot and to implement this plot they (principal and guidance counselor)  adopted a student in-school and matched as emergency friend of student Victim L and trained this student to act as witness against student, L.

23.c.     In the scenario, on March 16, 2012  to make the plot secretive, the principal dismissed her office assistant staffs and very unusual she was alone in the office to carry out this racist and political assignment to earn perfect plot void of stitches. In line of duty, the principal placed the female student witness armed with cell or mobile phone  in holding detention and as  student, L  had entered  after "school home room to do her assignment", the school office was ran by the principal and when Plaintiff and parents visited the school they found that the principal was alone in the office. Prior to this investigative walk-in, Plaintiff and parents  telephoned student, L to review her security and the principal received the phone and told Plaintiff and parents  that student, L  was not in school whereas she was in after school program or home room to do her home work.

23.d.     For about two hours, parents and plaintiff  telephoned the school several times and the principal received all the calls and denied that student, L was in school and in after school program or home room.  When it was time to dismiss after school students, parents and plaintiff told the principal that they intend to call 911 or police, she released her witness and the principal cited student on the direction she was walking out to exit the school building and the purportedly detained witness was placed in company of student L  to establish direct contact with student L to plant allegation and justify her yet unidentified plot on March 16, 2012.

23.e.   Fear that parents and plaintiff may have contacted the police to join search for student L, the principal expanded the incident to student L's Guidance Counselor  to enable the counselor remove student L from the Algebra examination or test on March 17, 2012 and she used the counselor to telephone parents and plaintiff  and the counselor lied as form of advance notice the counselor lied that student, L was in company of the student witness who was purposely detained for this organized low score seeking adventure.

23.f.   Exactly as pre-planned by the principal of Plouffe Academy and the Guidance Counselor, Kary Denitzio (Homeroom Teacher), Guidance Counselor (Mr. McDonald), on March 17, 2012 for over four hours from test/examination to test/examination, student, L was removed from the test classes to face intimidation and interrogation and repeatedly on small question, "why did you accompany student (name reserved)  on March 16, 2012" and each time of removal, student, L continue to cry in defence she told the principal and counselor that the detained girl ran into her and told her that she was in detention but the counselor continued his secret mission and when each test remains about five minutes to finish, the counselor and the principal will release student L and soon as Algebra and other tests start, the counselor or principal will walk into the classroom or order the teachers to remove student, L from an on-going test for further intimidation and interrogation before the principal or counselor.  At Plouffe Academy, student L class is created by the defendants by selecting talented/gifted/smart students and majority of these students are non-whites and secretly minority that is whites enjoys external extra lectures.

23.g.   Same thing happens at Brockton High School to the 18-year sibling of the students L, B, G. and C who is also talented/smart/gifted/A/B+ Student.  How? In all the core courses and tests in sciences, english and maths to create low scores she suffered what student L  suffered. Several times their sibling Grade 12 was removed from an on-going courses and tests. This action disrupted the chance of this student to get admission at New York University, Georgetown University, etc particularly that several of her scores were not added or were under-scored.  Guidance Counselor mentioned above at Plouffe Academy removed student L for the planned interrogation designed to harvest low score. In both schools tests which these smart students  were scored failing grade and graded COMPLETE whereas  she did few minutes before she was removed from the tests.  Plaintiff recommendation requested defendants to allow her complete major time allowed for the test but they failed to accept the recommendation and entered INCOMPLETE and FAILING GRADE. Under safe learning condition student, L  must be given the opportunity to redo the full package of all the tests/examinations.


                COUNT # 16


24.       FORCING MINOR OR MIDDLE SCHOOL STUDENTS TO SIGN SEVERAL DOCUMENTS

Students and their parents of the children or students, victims  L, G. B and C  in these schools, principals, guidance counselors (Mrs. Lobo) and teachers create actionable report cards and other news letters and force the students to sign without parent supervision. The parents are forced to sign and failure to sign, their children or students will be detained in the school until they will be forced to sign.   Severally, students, B, G, C, and L are taken to secret interrogation rooms to force them to consent to created activities without signed and other release from parents or their representatives.


             COUNT # 17



25.    Mr.  Kenneth Kevelson IMPEDED THE  RIGHTS OF NON-WHITE INCLUDING  STUDENT TO ACCESS AND USE TOILET OR WASHROOM -  Maths teacher,  Mr.  Kenneth Kevelson  has failed to heed our advice posted below because of the support extended to him by the school management authorities and on Jan 5, 2012 the principal enforced his racist physical/psychological tortures on non-white students which is capable of disrupting  learning and comprehension as path to get low grade which is the purpose of majority of urban and mixed urban schools across the United States. Some female students urinated on their clothes and some were shy to stand up and move around. This complaint was sent to the Federal and state Human Rights Commissions and several months no action has been taken to address this issue.

D.                         RELIEF

THEREFORE  reliant on the foregoing particularly, the extensive and harsh harassment, bulllying, mockery, intimidation, and fatal libel, and related  cruelty, on behalf of the Students G, C, B, and L Plaintiff seek  nominal, compensatory, and punitive damages, and other costs which this Court deems fit but considered within the sum amount of Twenty five million US dollars ($25million) because these children/students under the roof or premises of these schools and their heads threatened to drop out of school, 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 and other harassment, Public humiliation including public disclosure of imposed and untrue failing of Algebra and uncompleted tests because of the action of the defendants. 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 students G, C, B, and L's  case many students, teachers and admiistrator were involved on daily basis.


 E.      VERIFICATION OF COMPLAINT AFTER CONSENTING WITH STUDENTS G, C, B AND L


Respectfully verified, Signed and submitted under the pains and penalties of perjury and that Plaintiff explained this Complaint to these students during several meetings with students L, B, C and G this 19th   day of June 2012,



____________________________
Dr. Phillip Chukwuma Ofume & Co.
 P.O. Box 2416 Lynn, MA 01903
E-mail: limptintinc@gmail.com

To:

Suffolk County Superior Court for Civil Business
Suffolk County Courthouse, 12th Floor
Three Pemberton Square
Boston, MA 02108



Contact and Service Information of Defendants:

 Ms. Colleen Proudler (Principal of Arnone Elementary School)  and Ms. Peri Jacoubs (Assistant Principal of Arnone Elementary School) and Female breakfast/launch staff (Arnone Elementary School, Brockton, MA) and Ms. Werner and Ms." Depina" (teachers of Student G)                                                                      Defendants

c/o
ARNONE ELEMENTARY SCHOOL
http://www.brocktonpublicschools.com/page.cfm?p=308
135 Belmont Street
Brockton, MA 02301
Hours: 9:00 a.m.- 3:15 p.m.
(508) 894-4440

Michelle Nessralla, Principal and other defendants
c/o
PLOUFFE ACADEMY
250 Crescent Street
Brockton MA 02302
Hours: 8:05 a.m.- 2:35 p.m.
(508) 894-4301



 Ms.  Julie Louf (Acting Principal, Breed Middle School, Lynn, MA)
c/o
  Breed Middle School
90 Ocallaghan Way
Lynn, MA 01905
Essex County
PHONE: (781) 477-7330
FAX: (781) 581-6985

U.S. Secretary of Education Hon. Arne Duncan
U.S. Department of Education
Lyndon Baines Johnson (LBJ)
Department of Education Building
400 Maryland Ave, SW
Washington, DC 20202

Massachusetts Secretary of Education, Hon. Paul Reville
Department of Education
Executive Office of Education                                                                                                                                One Ashburton Place, Room 1403
Boston, MA  02108