Wednesday, August 22, 2012

BOSTON JUVENILE COURT: OGECHI EKE/PHILLIP OFUME V. DCF






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NATIONAL AND INTERNATIONAL RELEASE ORDERED  IMMEDIATELY
OGECHI EKE  V. DCF DOCKET NO.  CP10B0179          
                        COMMONWEALTH OF MASSACHUSETTS
                      Suffolk, ss                     
                                                                         Boston Juvenile Court
                                      Civil Docket No.    CP10B0179
_____________________________________________________________
                  OGECHI EKE
               Applicant/Defendant (Pro se)
                              and
PHILLIP OFUME (LIMPT, INC. -                                                                                                                                EDUCATION AND WORK FORCE PROJECT)
                   Intervenor - Applicant/Advocate  - Defendant
                                    v.
MASSACHUSETTS DEPARTMENT OF CHILDREN AND FAMILIES(DCF)
                   Respondent/Plaintiff
________________________________________________________________________________
APPLICANTS, OGECHI EKE AND PHILLIP OFUME'S  VERIFIED JOINT EMERGENCY MOTION AND MEMORANDUM FOR SUMMARY JUDGMENT AS TO URGENT RETURN OF CUSTODY TO PARENT, OGECHI EKE  PURSUANT TO   Fed. R. Civ. P. 56
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OGECHI EKE  V. DCF DOCKET NO.  CP10B0179          
and Local Rule 56 of the Mass. R. Civ. P.; .G.L. c. 18  sec.  2 (A)(D); 1st , 4th , 5th  and 14th  Amendments to the Constitution  and Bill of Rights of the United States; Mass. Sup. Court Rule 9A(b)(5); Mas Juv. Ct. Standing Order 2-07; CHINS, G.L. c. 119 §§39E-H); Emergency custody hearing (G.L. c. 119, §24; Convention on the Rights of the Child - Parts I & II (General Assembly resolution 44/25 of 20 November 1989; Equal Protection Clause of the Fourteenth Amendment to the United States Constitution,Title IX of the Education Amendments of 1972, 20 U.S.C. §§ 1681–1688 (―Title IX),and the Massachusetts  Human Rights Act, United States Constitution, Title IV of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000c2000c-9 (Title IV) and NO CHILD LEFT BEHIND ACT (2001); Ofumes v. DCF - Hampden County Juvenile District Court, Holyoke Session, Docket No. CP 11H0011; etc.
________________________________________________________________________________
Subject:   Care,  Protection, return of custody to parent, summary judgment  of the Subject child (name reserved pursuant to U.S. Constitution and Bill of Rights and United Nations Convention on the Rights and Protection of the Child). Ms. Ogechi Eke (hereinafter, “Mother“) the mother of the subject child and Applicant-Intervenor move  seeking Order of this Honourable Court to grant their Motion for Summary Judgment because of the following reasons:
 A.           STATEMENT OF MOTION/BRIEF ANALYSIS
Pursuant to the above mentioned local, federal and international laws and for the reasons set forth in the attached Memorandum, Applicants, Ogechi Eke and Phillip Ofume hereby move this Court for the entry of summary judgment.
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OGECHI EKE  V. DCF DOCKET NO.  CP10B0179          
As set forth more fully in the accompanying Memorandum of Law, argument, exhibits and fact at the close of the DCF's extensive unnecessary, 100% rumor and hear say  and public fund exhausting research and investigation; gold digging inexperience and partisan  psychiatric examiner/evaluator and caseworkers, etc without supervising the anti-education, care and protection activities of the foster caregiver that claim that education is not important in the life of the child and that child should be used as bull to work and make money.
This careless conduct  led to simultaneous destruction of highly talented/smart/gited/A/A+/ B+ student (subject child) who was raised, home schooled and taught by parent, Ms. Ogechi Eke but at present DCF, foster caregiver and  other staff and secret agents or informants of the Department of Children and Families (DCF) have destroyed Ms. Eke's child because they are not interested in education, care and protection of the subject child's education, maintenance, security, healthcare, etc to the threatening level that the subject child who was TALENTED/SMART /GIFTED/A/A+/B+ student and recommended for advanced grade promotion from K  with two scholarly jumps to grades 2 or 3 becuase of the subject child mother's scholarly teaching and learning curricula  (EXHIBITS A & B below). Horribly, the subject child is now  dropped below pre-K  where she was at the age of 3 and placed in the present class of K instead of grade 3 which the scholarly plan constructed under EXHIBIT A & B would place her at the present age of 7.11 years. The recent picture (EXHIBIT C) shows that she is in K class instead of grade 2 or 3. Very painfully,  in this class she is a big girl and other students are small kids. There is a wide academic gap between her past work when she was with Ms. Eke and now with   furious money making foster caregivers or nigerian pastor and his wife who use subject child to work several hours per day seven days  a week in their child care center and gospel church to make money to build empire in Nigeria and forgot about the educational achievement of the subject child.
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OGECHI EKE  V. DCF DOCKET NO.  CP10B0179          
In this matter,  purpose of Summary Judgment is met because  there is no genuine dispute as to any material fact.  Accordingly, summary judgment in defendants' favor is appropriate on Respondent/Plaintiff's claims for damages, because there is no material dispute -- indeed, there is no evidence at all -- that defendants violated Plaintiff's "clearly established" constitutional rights.
 At present, single Mother of the subject child Ms. Ogechi Eke has beautiful apartment, full time jobs and she works with the Commonwealth of Massachusetts Department of Human services and she is  one of the Media/TV Assistant directors of the largest Gospel Churches in Canton, MA (Fountain of Grace Church). Because of EXHIBITS A, B, etc below experts have recommended her to be parents and moms instructor and role model particularly on how to raise their children and make them become TALENTED/SMART /A/A+/B+ frpm age to age through grade school and into tertiary institution. Now under the help of international and national experts, professional, institutions of learning and others Ms. Eke is now making efforts ro incorporate  a Profit Corporation which will hire over time several hundreds of staff to write, publish and print pre-k through tertiary institution high standard  educational curricula, text  books and other step by step education and training resources. Additionally, she is doing further education and saving money to continue and complete her Pharmacy course program in academic year 2013/2014 and place her child (subject child) in one of the best private or suburban schools in the United States.  Within 72 hours pursuant to Emergency custody hearing (G.L. c. 119, §24) Applicants request this Court to select unbiased Court inspector to review the progress mentioned above as final review to return full and permanent custody of the subject child to Ms. Ogechi Eke.
WHEREFORE, the Applicants/Defendants/Intervenor, Ogechi Eke and Phillip Ofume (LIMPT, INC. - EDUCATION AND WORKFORCE PROJECT), request this Honourable Court to grant their Motion for Summary Judgment because subject child is in eminent danger educationally, socially, economically and psychologically.   In support of this Motion, Applicants/Defendants/Intervenor  submit their Verified Memorandum of of Law, argument, exhibits and other material references/evidences which are  hereto adequately incorporated and
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submitted and served upon Plaintiff or her Attorney.
 B.                        MEMORANDUM
                     THREE-PRONG QUESTION IN ISSUE/ANALYSIS    
1.               Whether the action or conduct of this Court, former Attorney of Ms. Eke and DCF is not racially and politically motivated because the subject child is detained and been ex-communicated and being destroyed educationally, socially, .
                       
2.            Under the Constitution and Bill of Rights of the United States and the United Nations Conventions on the rights of the Child, Women and Parents, reliant on seizure and foster placement of no fault subject child and pains suffered by no fault  mother, whether this Court erred when they allowed ONLY rummor, hearsay, gossip, nigerian oil/gas political persecution directed against the Biafrans or Igbos of Nigeria under which DCF's leaders earn extra means of livelihood, confussion encountered by inexperience Psychiatric Evaluator on cultural differences between Nigeria and America, etc to determine and influence the position of this Court.
2.             Whether this Court erred when it failed, refused and neglected to consider that Ms. Ogechi Eke is academically, professionally, health wise, etc sound and excelled above several of the mothers and parents in the United States and world in general and also considering efforts which Ms. Eke made in  EXHIBITS A & B and/or the past and present effort to make the subject child TALENTED/GIFTED/SMART/A/A+/B+ student and at the tender age of 5 she was able to publicly and in-doorly and before or in front  The Honourable Presiding Justice Lewis read and explain grade 8 book called Mrs. Piggle-Wiggle Chapter books -Reading level: Ages 8 & up. 128 pages by Betty Mac Donald.
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OGECHI EKE  V. DCF DOCKET NO.  CP10B0179          
                                                BACKGROUND
Purpose of presenting direct,  accurate and personal statement of fact and evidence,  victims' personal statement and evidence are cited verbatim as follows:
                            Ms.  Ogechi Eke (Mother of Subject Child)
3.   "... I am university graduate and have strings of academic and professional qualifications and additionally, in 2004, I was a 4th year pharmacy school at Mcphs and same time  I was pregnant and worked at a community pharmacy. In  Sept. 30th 2004, I was delivered of a beautiful baby called Jillian George. Days later, I was admitted (Pre-eclampsia) to the BWH in Boston from school, the same place I had my baby, I had a poor delivery without pre-natal care and treatment equitably desired by all mothers notwithstanding political affiliation, race, and color because DCF infiltrated the rank and file of the staff and blackmailed me and called me a bad person as path to seize my beautiful child. Then I was vulnerable, with no or limited support  and I could not question things that were wrong. Unlike now when several experts inside and outside law body, civil rights leaders and organizations, United Nations, immediate and extended families, christian brothers and sisters, etc are behind me and support me to fight these criminals (DCF and its secret agents) that have tortured me physically and psychologically to extent of injecting dangerous medications into me which made me to sleep over 24 hours and when I woke up and found that my new born baby has been abducted and  removed by DCF/DSS without my permission and given to heartless stangers called foster caregiver when I was sound and healthy and highly educated to care and protect my baby...
4.     On the incident mentioned in paragraph 1 above what I am able to figure out before DCF drugged and put me on long medicated sleep is that one friend Marie-Jonelle Durvne was carrying when I was under uncared or unattended post-natal severe acute pains and I as may recall, shortly after, a group of persons identified as DCF staff swarm into my room, they asked Marie-Jonelle to leave, they took away my baby without any explanation to me, they tied me up to a bed and used a hard restraint on me. I asked the reason for taking away my baby and why they were doing what they were doing to me. My question attracted more brutality, I was
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OGECHI EKE  V. DCF DOCKET NO.  CP10B0179          
injected and that was all I knew.
3.      I woke up the next day and asked for my baby- no one answered a word. A “Good Samaritan” I would call this person, now told me that I have been declared insane and that they have been warned to keep off me and be careful the way they went to my room or answered any questions. The hospital staff has also stopped calls to get through to my room. I asked the “Good Samaritan” the reason for labeling me so, and she said she is telling me these things because she did not see me as a danger nor do I look insane to her. I thanked her. I was too sick and too weak. The Pre-eclampsia was still there. I do not have a history of blood pressure either in my family, but my BP went off the roof because of the harassment, bullies and other forms of psychological tortures melted on me by the DCF and its errand runners. I was finally discharged from the BWH hospital and I was told to go in search of my newborn child.   I was very sore, I was bleeding heavily and I had to go in search of my child, my only child. I was still in Pharmacy school; my school did not make allowance for me to make up missed assignment and the DCF has taken the school captive of any rational focus as to teaching and learning directions and the school did nothing to help me under my maternity or post natal conditions.
4.      I was assigned a lawyer, by name Amy Geary and she was doing my case without serving me the papers she filed in Court and she allowed DCF to continue to seize and hold  my child; I had a social worker by name Natalie. I had the support of Mrs. Juliet Achebe.  Till this day, I did not know why the DCF (then DSS) took my child. The state lawyer had told me that I was accused of negligence. I told her that I was on hospital admission ill from Pre-eclampsia and postpartum pains (surgical stitches). The DSS case was later closed (and quickly too).
5.   Jillian and I continued our lives. In 2006, events at my school made me to report the racial antagonization which  I was going through and which brought to the Civil Rights Commission. My school Mcphs was making the learning environment very hostile and toxic for me. My report which I laws latter forced to withdraw made a target;  I was now a target of retaliation in
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breach Mass. Law 151B §4(4) and §4(4A). §4(4). I took some time off based my Dr.’s
recommendation.
6.    . Sometime in 2006, and there was this social worker who identified herself as Carol Powers. When Carol Powers came to my home, she called me to a negotiation table right in my home, she has been sent and that she knew about the case with Mcphs but she added and said, “ it did not matter.” Ms. Powers said to me right there in my home, “If you agreed to plead insanity, you will be fine and this case would be closed.” In response, I shared with her one of the life lessons my father taught me, and the lesson is this, “if you are not guilty of a thing, never, never admit to that thing, regardless the weight of persecution which suffer, never say yes, when the answer is a no.” Carol Power, then said, “since you have refused the easy way out, (plead insanity) I will ruin your life with my pen.” And with those words, Ms. Powers left my apartment. I called her to find out the outcome of her visit, I met a wall; I asked to speak to her boss, I met a wall and after that I have constantly met walls after walls, lies, after lies, deception after deception, with the DCF officials.
7.          When DCF (DSS at that that time) came to me, they said I was accused of yelling at my child because of milk. I told them that we don’t do milk at that stage. That Jillian was not bottled feeding. The allegation was later changed to that I said I will blind Jillian’s eyes with pepper and apply pepper to her vagina. I almost passed out when I heard this wicked allegation because in my family inside and outside Nigeria, we talk and teach a child what is right and wrong and this continuous talking makes  better change because spanking  tries to radicalise children and hardens them.  I  asked  the present foster caregivers of my child
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what brought deep cut on the wrist of my child and I was surprised that the foster caregivers bullied and harassed and asked me, “who gave you the authority to question our child” and they requested me to leave their home or they will call police on me. I told the DSS and they did not send any feed back to me.
8.          Now, Jillian was attending pre-school at Parker Hill ABCD Headstart, it was steps away from Mcphs, my school. Usually, I drop her off and walk to school. She was doing good, initially there were no complaint, out of the blues, very unkind allegations were being written against my child, a child that was not even 3 years of age; the school wanted her to be acting like a 12 year old. For no reason, the DCF arranged that Jillian be transferred to Jamaicaplain ABCD, whose Director was Joyce Tanner( Joyce Tanner’s close relative was David Tanner of Mcphs) I objected strongly because, there was no reason to move Jillian from Parker Hill ABCD Headstart; my school, Mcphs was at Longwood and Parker ABCD was a stone throw away.


9   She was now at Jamaicaplain ABCD. JP Headstart constantly and consistently endangered Jillian. Jillian’s standard of education was seriously affected because the foster caregivers refuse to take my after school teaching and learning resources and each time I visit my child and talk about education, the caregivers would harassment and force me to leave their home or they will call for police on me.
10.     In 2011, we had lost 11 family members in 2years. By this time, I was homeschooling Jillian. I bought a ticket and our luggage was tagged to Nigeria-our final destination and the DCF’s mounted spies were in full force around Jillian and
                               
I and they followed us here and there. When we got to Canada, we were prevented from boarding Lufthansa airline. We were left stranded at the airport (a foreign country) me and my six year old Jillian had nowhere to go and no one was there to explain to us. The next day, a group of people came to us and whispered that they had been asked to bring us back to Boston. I wanted to know who, (Ms. Geary was well informed that we were traveling, and she okayed it) I insisted that we were going to home to attend a funeral of our family members. We were accused of being illegal immigrants to Canada and said we must be deported now. I was asked, “How did you expect to feed this child when you get to Nigeria?”what??? Was all I could say? We were returned back to Boston and my bank card was charged for returning us back to Boston. As soon as we were returned, to Boston, Amy Geary quickly contacted me and said that DCF is asking for an immediate hearing. It was then; Jillian was taken away from me and placed in the custody of the Rev. & Mrs. Azubuine. After wards, I was told I could travel if I wanted.
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11.    In 2011, we had lost 11 family members in 2years. By this time, I was homeschooling Jillian. I bought a ticket and our luggage was tagged to Nigeria-our final destination. When we got to Canada, we were prevented from boarding Lufthansa airline. We were left stranded at the airport (a foreign country) me and my six year old Jillian had nowhere to go and no one was there to explain to us. The next day, a group of people came to us and whispered that they had been asked them to bring us back to Boston. I wanted to know who, (Ms. Geary was well informed that we were traveling, and she okayed it) I insisted that we were going to home to attend a funeral of our family members. We were accused of being illegal immigrants to Canada and said we must be deported now. I was asked, “How did you expect to feed this child when you get to Nigeria?”what??? Was all I could say? We were returned back to Boston and my bank card was charged for returning us back to Boston. As soon as we were returned, to Boston, Amy Geary quickly contacted me and said that DCF is asking for an immediate hearing. It was then; Jillian was taken away from me and placed in the custody of the Rev. & Mrs. Azubuine. After wards, I was told I could travel if I wanted.
12.     On December 20th2011, the Azubuine’s invited me to attend a performance at Jillian’s school (Winter Hill Community). The Azubuine’s told me it was at 8am and I went to Jillian’s school hoping to meet them there. I learned from her teacher that the event was by 10am and that I could wait in the hall. Now, I have never gone to Jillian’s school before now. I went because I was invited. I took pictures and left. A week later I went to visit my child, the Azubuine’s spiting me, and they told me that Jillian’s school had filed a trespassing report at the police station. I contacted my state lawyer, who initially told me that the police was not contacted for any reason, when I insisted, she told me that yes, that the police was contacted but that no police report was filed; she later changed her story; this is the norm, with Ms. Geary, she changes her story, she misinforms me, misleads me and works against me her clients (I have several e-mails to prove this)
11.       On December 20th2011, the Azubuine’s invited me to attend a performance at Jillian’s school (Winter Hill Community). The Azubuine’s told me it was at 8am and I went to Jillian’s school hoping to meet them there. I learned from her teacher that the event was by 10am and that I could wait in the hall. Now, I have never gone to Jillian’s school before now. I went because I was invited. I took pictures and left. A week later I went to visit my child, the Azubuine’s spiting me, and they told me that Jillian’s school had filed a trespassing report at the police station. I contacted my state lawyer, who initially told me that the police was not contacted for any reason, when I insisted, she told me that yes, that the
police was contacted but that no police report was filed; she later changed her story; this is the norm, with Ms. Geary, she changes her story, she misinforms me, misleads me and works against me her clients (I have several e-mails to prove this).
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OGECHI EKE  V. DCF DOCKET NO.  CP10B0179          
               JURISDICTIONAL STANDPOINT
12.    This Court has overwhelming jurisdictions,( personal and subject matter ) to hear and grant Applicants' Motion.  Summary Judgment maybe filed  if any party in the case found that,  there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law. Since 2004 there is no pending dispute in this case from the disclosure provided by the former Counsel for the defendant, Ms. Ogechi Eke and Ms. Eke has been put in the dark without disclosure of the document filed in her defense and also document filed by the Plaintiff, DCF.
13.      Actions of the Counsel for  Ms. Eke and  the Court violate 5th  and 14th  Amendments to the Constitution  and Bill of Rights of the United States and the failure of the counsel in staying visitation, investigation and research on the subject child to the extent of allowing DCF and the foster care providers, violate US and United Nations Convention and Bill of Rights and Universal Declaration on the Rights of the child, parent and family; Equal Protection Clause of the Fourteenth Amendment to the United States Constitution, Title IX of the Education Amendments of 1972, 20 U.S.C. §§ 1681–1688 (―Title IX),and the Massachusetts  Human Rights Act, United States Constitution, Title IV of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000c2000c-9 (Title IV) and NO CHILD LEFT BEHIND ACT (2001); Ofumes v. DCF - Hampden County Juvenile District Court, Holyoke Session, Docket No. CP 11H0011; etc. For example during one of the few visitations Ms. Eke was allowed make, she found a deep cut on the wrist of  her child and both caregivers would not allow the subject child’s mother a minute privacy and as they positioned them directly in a circle of the subject child, foster caregivers and Ms. Eke, Ms. Eke asked her daughter what happened to your wrist and swiftly the caregivers bullied her and shut up and requested her to leave their home or they will call police on her. She rushed out because they trying to fights her and frame up allegation against her. Ms. Eke reported the injury to DCF and nothing was done as to sending further information to the
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Applicant, Ms. Eke. The injury has deformed subject child’s hand.  Ms. Eke request this Court cause a direct discovery examination on the hand or wrist of her daughter and reason her level of education has drastically dropped.
14.  Further readings on rights of the child, parent, family, etc.
Fed. R. Civ. P. 56 and Local Rule 56 of the Mass. R. Civ. P.; .G.L. c. 18  sec.  2 (A)(D); 1st , 4th , 5th  and 14th  Amendments to the Constitution  and Bill of Rights of the United States; Mass. Sup. Court Rule 9A(b)(5); Mas Juv. Ct. Standing Order 2-07; CHINS, G.L. c. 119 §§39E-H); Emergency custody hearing (G.L. c. 119, §24; Convention on the Rights of the Child - Parts I & II (General Assembly resolution 44/25 of 20 November 1989; Equal Protection Clause of the Fourteenth Amendment to the United States Constitution, Title IX of the Education Amendments of 1972, 20 U.S.C. §§ 1681–1688 (―Title IX),and the Massachusetts  Human Rights Act, United States Constitution, Title IV of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000c2000c-9 (Title IV) and NO CHILD LEFT BEHIND ACT (2001); Ofumes v. DCF - Hampden County Juvenile District Court, Holyoke Session, Docket No. CP 11H0011; United Nations Universal Declaration of Human Rights (Dec. 10, 1948); etc.
                                ARGUMENT
Applicants respectfully request leave of this Court to assign numbers to each paragraphs of their argument because of past experience in their cases when several paragraphs were missing.
15.     In applying the Rules of this Court and other local rules and Federal rules, in return custody proceedings, question maybe asked whether the destination of the proposed return is in the best interest of the subject child. In this case two questions have been resolved thus, that in the home of the wealth seeking  foster caregivers,  the subject child is in severe acute danger educationally, socially, economically, psychologically, etc. The destination where she will be returned is
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similar to "heaven" and is her nuclear parent's or mother's home where she was enjoying her life and excelling and sound educationally, socially, economically, psychologically, with freedom of association and speech, etc.
16.   Additionally, at present, single Mother of the subject child Ms. Ogechi Eke has beautiful apartment, several hundreds of educational toys , books and other learning resources, several clothes and shoes to wear and reconnect her previous wealthy life style under her mom’s effort; Ms. Eke has full time jobs and she works with the Commonwealth of Massachusetts Department of Human services and under extra income she is  one of the Media/TV Assistant directors of the largest Gospel Churches in Canton, MA (Fountain of Grace Church). Because of EXHIBITS A, B, etc below experts have recommended her to be parents and moms instructor and role model particularly on how to raise their children and make them become TALENTED/SMART/A/A+/B+ from age to age through grade school and into tertiary institution. Now under the help of international and national experts, professional, institutions of learning, countries and others Ms. Eke is now making efforts to incorporate  a Profit Corporation which will hire over time several hundreds of staff to write, publish and print pre-k through tertiary institution high standard  educational curricula, text  books and other step by step education and training resources. Also Ms. Eke is doing further education and saving money to continue and complete her Pharmacy course program in academic year 2013/2014 and place her child (subject child) in one of the best private or suburban schools in the United States. 
17.     Within 72 hours pursuant to Emergency custody hearing (G.L. c. 119, §24) Applicants/defendants/intervenor request this Court to select unbiased Court inspector to review the progress mentioned above as final review to return full and permanent custody of the subject child to Ms. Ogechi Eke.
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18.     The present condition of the subject child is heading to severe form of destruction bitterly Ms. Eke's child has lost almost all the strong academic background which she had prior to the forcible removal to this maximum prison called foster home, where the DCF consented to for the foster caregivers to spank her and to use Ms. Eke’s  child assisting in the foster caregiver's child daycare facility. This child labor has deprived the subject child access to right to do her homework and engage in remedial or catch-up lessons. As part learning component, of EXHIBITS A & B, during the summer holidays, Ms. Eke enrolls her child (subject child) in one of the best summer school.  
19.  Case of ); Ofumes v. DCF - Hampden County Juvenile District Court, Holyoke Session, Docket No. CP 11H0011 is one of the most cited cases in the United States because it shows how DCF place TALENTED/GIFTED/SMART/A+/A/B+ students in foster care where they are used like bull to destroy their educational achievement. Five children were removed from this family on January 31, 2011 and placed them  in scattered foster families where children between the ages of five years and 12 years were used to dig snow and one school days they make to go to school and be late for over two hours.  The pastor who took the five year and twelve-year children designed a damaging and criminal plan in the foster home. Each day apart from making the 12-year child to go late for over two hours , each day soon as she comes from school, the pastor and his wife make sure she did not do her school assignment and they will remove her to the Spanish Church where she does not hear and understanding  Spanish used in the church to conduct services.
20.       Ms. Eke's EXHIBITS A & B which are an in-home accelerated teaching and learning program is the best option for the United States to raise standards of education Pre-K - Tertiary Institution and if possible world in general (see Finland). Few visitations allowed by the school, fired attorney, caregiver and DCF because of the secret kept around subject child, parent, Ms. Eke tested her child to know the level she is but less than two minutes of the simple academic question/answer and
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writing the caregivers rushed into the testing and disrupted the testing and forced Ms. Eke to leave the foster caregivers' home and warned Ms. Eke not to visit their  home and that failure they will accuse her of  trespassing into the foster care home and also warned her  not to visit subject child's school.  The few testing which lasted less than two minutes comparatively shows that the subject child has lost her education in foster stay and if urgent removal to parent is not made, she will drop out  from school and forced her to enter the DCF and intended caregiver  planned trap for TALENTED/SMART/A/A+/B+ non-whites victims which is boy/girl friend circle which will lead to teen pregnancy to enable the caregivers start to dig addition gold through foster babies or children's state welfare or benefits. Criminally, caregivers under DCF program try to target victims' education to destroy it.
 21.       DCF'S  politically designed and defective care and protection system, they (foster caregiver and DCF) are interested in large public  monies  shared  between the  caregiver and DCF under pretense of providing for the subject child but these monies allow them to buy secret beautiful  castles oversea. When Ms. Eke visited her school when she was doing a performance and Ms. Eke has to take some of her beautiful clothes. When she arrived there she found that the clothes the subject child  wore was old and stained and improper for such outreach appearance and Ms. Eke has to go change her unfitting clothes with the ones she brought.
22.   Academically, the Subject child earned this downfall because the teaching and learning curricula which mother of the subject child put in place was suppressed and in place she is forced to do child labor or domestic work and providing care which adults are supposed to provide in the foster caregiver's home daycare business; etc.
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OGECHI EKE  V. DCF DOCKET NO.  CP10B0179          
23.           Reason that several experts have found that the case of the subject child  is case of child human and constitutional rights case and subject child now forcibly placed in danger of money making child merchants (DCF and foster caregiver) or nigerian pastor, Emergency Order in nature  of Immediate Return of Custody to Subject Child Mother, Ogechi Eke be issued because the subject child identified by cause docket number above be immediately and urgently adjudicated in need of care and protection and committed to the custody of her Mother, Ogechi Eke and/or any other appropriate order to be made pursuant to Fed. R. Civ. P. 56 and Local Rule 56 of the Mass. R. Civ. P.; .G.L. c. 18  sec.  2 (A)(D); 1st , 4th , 5th  and 14th  Amendments to the Constitution  and Bill of Rights of the United States; Mass. Sup. Court Rule 9A(b)(5); Mas Juv. Ct. Standing Order 2-07; CHINS, G.L. c. 119 §§39E-H); Emergency custody hearing (G.L. c. 119, §24; Convention on the Rights of the Child - Parts I & II (General Assembly resolution 44/25 of 20 November 1989; Equal Protection Clause of the Fourteenth Amendment to the United States Constitution,Title IX of the Education Amendments of 1972, 20 U.S.C. §§ 1681–1688 (―Title IX),and the Massachusetts  Human Rights Act, United States Constitution, Title IV of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000c2000c-9 (Title IV) and NO CHILD LEFT BEHIND ACT (2001); Ofumes v. DCF - Hampden County Juvenile District Court, Holyoke Session, Docket No. CP 11H0011; etc.
24.            In LIMPT, INC. (EDUCATION AND WORKFORCE PROJECT), within researchers and investigators' works in computing number of the predominantly  non-white victims appearing before the Juvenile Courts across the United States they found that the US Congress, politicians, civil liberties organization are aware that DCF is secretly created to destroy non-whites and under these activities TALENTED/SMART/GIFTED /A/A+/B+  students and parents are DCF's focus and they fight hard to distroy them because they will earn education to take their jobs (Ofumes v. DCF –
                                                16
OGECHI EKE  V. DCF DOCKET NO.  CP10B0179          
Hampden County Juvenile District Court, Holyoke Session, Docket No. CP 11H0011) and Ofume et al v. Holyoke Police Department et al - Plymouth County Superior Court, Docket No. 1260.
25.     From experts (Limpt, Inc., Dr. Phillip Chukwuma Ofume, Dr. Kifindi Bunkheti, etc) research and investigation point of view on Nigerian and African nuclear and extended families system culture, they found that the reaction of Ms. Ogechi Eke in 2004 through out each political plot organized and implemented by the DCF and its irate child merchants to seize her gold (subject child) is normal reaction of all responsible, caring and loving Nigerian and African mothers or parents.  Commonwealth of Massachusetts and its agencies (DCF et als) selected weak and inexperience Psychiatric Evaluator and caseworkers that know nothing about oversea culture and civilization. The reaction of Ms. Eke is exemplary of good, excellent, caring and loving mothers and parents. Relatively, the silly behaviors of Americans if reviewed by oversea or Nigerian Psychiatric evaluators may be rated as mental health behaviors.
 26.     Birthday, March 15, 1969 through presents Ms. Ogechi Eke has never had any mental and related health problems and at all material time she has been TALENTED/ SMART /GIFTED /A/A+/B+ university graduates. In the United States she has completed over four (4) years of Pharmacy course and she disengaged from the Pharmacy course program because of the harassment, bullying and physical/ psychological tortures directed against her by the DCF and its secret/overt informants. The action of the DCF is a vicious retaliation by the DCF and its agents following Ms. Eke's petitions to the government of the Commonwealth of Massachusetts and its agencies (Human Rights Commission et als) to complain against her persecution, harassment, bullying and physical/ psychological tortures. Day of the birth of the subject child on September 30, 2004 DCF mounted its agents or informants in the hospital where the subject child was born with the intention to create trouble as path to seize her child. This experience several Nigerians and other non-white has had in the United States.
27.   Sectors to sectors, place to place, Ms. Eke continues to answer questions on what she did to make her child TALENTED/ SMART /GIFTED /A/A+/B+ student at the age of 4. Age-4
                                                                        17
subject child was reading tertiary level books tom the extent that she read **Mrs. Piggle-Wiggle Chapter books*** Reading level: Ages 8 & up. 128 pages by Betty Mac Donald** Jillian Read this Book at age 5!!!!! – read same before Judge Lewis. Ms. Eke said "... see EXHIBITS A & B and in answering public question on what she did make her child excel to this high level, she said, “what I do day to day to put my daughter top of her class are to give her  healthy food, allow rest and sleep after school, sound teaching with quality curriculum, teach by practical example, private study and creativity, continuous and comprehensive assignments and evaluation,  play and interaction with other kids, etc."
=================================================================================
EXHIBITS A & B :  Jillian’s Books for Home School (Core curriculum Only) Learning Coach is Mom (Ogechi Eke)
EXHIBIT  B. 1, 2, 3, Through  115  by Ms. Ogechi Eke (Mother of Subject Child)
.
#
Book Title
Author
1
K12 Math+:  Activity Book grade 1 semesters 1& 2
K12
2
K12 Math+:  Lesson Guide grade 1 semesters 1 & 2
K12
3
K12 Math+:  Activity Book grade 2 semesters 1 & 2
K12
4
K12 Math+:  Lesson Guide grade 2 semesters 1 & 2
K12
5
Language Arts 1:  Student Pages Semesters 1 & 2
K12
6
Language Arts 2:  Student Pages Semesters 1 & 2
Language Arts Books (Literature or literal Study)
POMPEII Buried Alive
Edith Kunhardt
Wagon Wheels
Barbara Brenner
The Long Way to a Newland
Joan Sandin
Clara and the Bookwagon
Nancy Smiler Levinson
Chang' s Paper Pony
Eleanor Coerr
Sam the Minuteman
Nathaniel Benchley
George the Drummer Boy
Nathaniel Benchley
The Bears On Hemlock Mountains
Alice Dalgliesh
Now I am Six
Scholastic
Surprises (Poems by)
Lee Bennett Hopkins
No Fighting. No Biting
Maurice Sendak
The Long Way WestWard
Joan Sandin
Little Bear
Else Holmelund Minarik
The First Thanksgiving
Linda Hayward
A Picture of Harold’s Room
Crockett Johnson
Danny the Dinosaur
Syd Hoff
The Tales of Amanda Pig
Jean Van Leeuwen
Buddy. The First Seeing Dog
Eva moore
Te Josefina Story Quilt
Eleanor Coerr
Tye May and the Magic Brush
Molly Garrett
Frog and Toad are Friends
Arnold Lobel
Bedtime for Frances
Russell Hoban
Sam Bangs & Moonshine
Evaline Ness
Harry and the Lady Next Door
Gene Zion
Crow Boy
Taro Yashima
Robin Hood (chapter book)
Annie Ingle
Winnie-the-Pooh
A.A Milne
Knights of the Round Table
Gwen Gross
Peter Pan
J.M. Barrie
Ready…Set…Read!
Joanna Cole
Other Books: Mrs. Piggly Wiggly, Too many to list; Jillian is a voracious Reader; Her she has a Reading Log (Over 150 books before she was snatched away.
Language Arts Supplements
Listen, My Children (Poems for First Graders) A Core Knowledge K12
Listen, My Children (Poems for Second Graders) A Core Knowledge K12
The Legend of Blue Bonnet - Tomie DePaola
The Hundredth Name -------Shulamith Levey Oppenheim
Sundiata ---------------------- David Wisniewski
K12
7
Phonics 1 Student Pages Semester 1 & 2
K12
8
Phonics 1 semester 1 & 2 Teacher Guide
K12
9
Phonics 2 Student Pages Semester 1 & 2
K12
10
Phonics 2 semester 1 & 2 Teacher Guide
Phonics Works Video
K12
11
Primary Analogies Critical & Creative Thinking Book 1
Gae Brunner
12
Primary Analogies Critical & Creative Thinking Book 2
Jan Z. Olsen
13
Junior Great Books Volume 1: Grade 1
          The Black Hen’s Egg
          The Mouse & the Wizard
        Imaginations
Pegasus Series
14
Junior Great Books Volume 2: Grade 1
          Rumpelsiltskin
          Eeyore Has a Birthday and Two Great Presents
        “When I Grow Up”
K12
15
Junior Great Books Volume 3: Grade 1
          The King of the Frogs
          Snow-White and the Seven Dwarfs
        “Mysterious Animals”
K12
16
Junior Great Books Volume 1: Grade 2
          Chestnut Pudding
          The Pied Piper
        Fanciful Animals
K12
17
Junior Great Books Volume 2: Grade 2
          The Mermaid Who Lost Her Comb
          Hansel & Gretel
        Special Places
K12
18
Junior Great Books Volume 3: Grade 2
          Mother of the Waters
          Zlateh the Goat
        Secret Messages
19
Classics for Young Readers Volume 1
K12
20
Classics for Young Readers Volume 2
K12
21
Early Reading Comprehension in Varied Subject Matter Book A
Jane Ervin
22
Handwriting Without Tears 1st grade;
Jan Z. Olsen
23
Handwriting Without Tears 2nd Grade;
Jan Z. Olsen
24
Sylvester and the Magic Pebble
William Steig
25
Hooked on Phonics! 1st Grade
HOP Editors
26
Hooked on Phonics 2nd Grade
HOP Editors
27
Hooked on Phonics Master Reader
HOP Editors
28
Writing Homework
Scholastic Ref
29
Sciences 1 Student Pages  (Semesters 1 & 2)
K12
30
Sciences 2 Student Pages  (Semesters 1 & 2)
Science Supplements
*A Weed is a Flower  ------------------------ Aliki
*Weather (poems for All Seasons)  -------- Lee Bennett Hopkins
*Bright and Bold (Animals Alphabet Book⇾ Celebration Press
*What is the World Made of? Stage 1 & 2
   ( All About Solids, Liquids, and Gases)-- Kathleen W. Zoehfeld
*Let’s Go Rock Collecting stage 2 ------ Roma Gans
*What Happens to a Hamburger? Stage2------- Paul Showers
What Makes a Magnet? Stage 2-------------Franklyn M Branley
Why Frogs Are Wet ------------Judy Hawes
Down Comes The Rain  -------------Franklyn M Branley
Flash, Crash, Rumble, and Roll -------------Franklyn M Branley
K12
31
History 1 Student Pages (Semesters 1 & 2)
K12
32
History 2 Student Pages (Semesters 1 & 2)
History Supplements
The Trojan Horse (How the Greeks Won the War) - Emily Little
Mummies ------------------------------------------Joyce Milton
Fossils  stage 1& 2: ( Tell of Long Ago) -------- Aliki
Knights In Shining Armor -----------------------Gail Gibbons
K12
33
Arts 1 Student Pages (Semesters 1 & 2)
K12
34
Arts 2 Student Pages (Semesters 1 & 2)
Arts Supplement
How Artists See Play .-----------  Collen Carroll
How Artists See Animals by------------ Collen Carroll
Come Look with me: Exploring Landscape Art with Children- Gladys Blizzard
Come Look with me: World of Play--- Gladys Blizzard
K12
35
Beginning 2 Music Student Pages Volume 2  (Semesters 1 & 2)
K12
36
Let’s Sing Songbook Volume 2
K12
37
Music software
K12
38
Music Supplement
          Music: Let’s Listen Volume 2
          Music: Let’s Sing Volume 2
          Music: Let’s Learn Music Volume 1 Video
          Music: Let’s Learn Music Volume 2 Video
          Music: Let’s Rhythm
          Tambourine
          Drums
          Keyboard/piano
        Instructional DVD
K12
K12
_________________________________________________________________________________
EXHIBIT   A .1, 2, 3, Through 232 strands
Jillian’s Reading Log by Ms. Ogechi Eke (Mother of Subject Child)
Week of 9/27/2009 to 10/4/2009
HOP books 24books in all- from Kindergarten Edition
HOP Books
14 Books from Cat Tick –Tock Gets a Pal
HOP Books
10 Books from Dad and Sam Kim Kangaroo
HOP Books
Week of Oct13. 2009
Mon: Hop on Pop
Tues: The Cat in the Hat
Dr. Seuss
Wed: Minnie and Moo Wanted Dead or Alive
Denys Cazet
Thur: Green Eggs and Ham
Dr Seuss
Fri: Fred and Ted Like to Fly
Peter Eastman
Sat: My Car Trip
Sindy Mckay
Sun: Three Little Bears (4books in one pack)
David Martin
My comment for the Week of Oct. 11. 2009
Wed. Book was hard: try reading it again.
 Jillian answered 90% of the questions
My goal for Jillian: fluency in reading; answer 100% of the questions; sustain Jillian’s reading interest.
Week of Oct18. 2009
Mon: Goldilocks and the Three Bears
Jerry Smath
Tues: The Three Little Pigs
Jerry Smath
Wed: Are You still Mad
Ellen Weiss
Thur: One Smart Goose
Caroline Jayne Church
Fri: Little Bears Friend
Maurce Sendak
Sat: Mumps Story
Gabby is Hungry
Beverly Randell
Michele Dufesne
Sun: Frog and Toad Adventure
Days with Frog and Toad
Arnold Lobel
Arnold Lobel
Week of Oct 25. 2009
Mon: Fox in Socks
Dr. Seuss
Tues: Bath time for Biscuits
Alyssa Satin Capucilli
Wed: Biscuits and the Baby
Alyssa Satin Capucilli
Thur: A Snout for Chocolate
Denys Cazet
Fri: The Case of the Cat’s Meow
Crosby Bonsall
Sat: My Car Trip
Sindy Mckay
Sun: Detective Dog and the Lost Rabbit Book
         Slam Dunk (In the Dark)
David Martin
Hop Book 17
Week of Nov.1 2009
Mon: How the Grinch Stole Christmas
Dr. Seuss
Tues: Bath Time for Biscuits
Denys Cazet
Wed: Chicka Chicka Boom Boom
Bill Martin
Thur: A Snout for Chocolate
Denys Cazet
Fri: Fly Guy Fly
Ted Arnold
Sun: Yertle the Turtle
Dr. Seuss
Week of Oct8. 2009
Mon: Are You My Mother
P.D. Eastman
Tues: The Tooth Book
Dr. Seuss
Wed: Mouse Soup
Arnold Lobel
Thur: What do You Hear When Cows Sing &  Other Silly Riddles
Marco & Giulio Maestro
Fri: Sammy the Seal
Syd Hoff
Sat: Big Egg
Molly Coxe
Sun: Inauguration Day
Too Much Toothing
Lauren Brown
Sanford Hoffman
Week of Nov.15. 2009
Mon: American History for Children(DVD)
The History Channel (2005)
Tues: African American Life
The History Channel (2005)
Wed: American Independence
The History Channel (2005)
Thur: Native American Life
The History Channel (2005)
Fri: Martin Luther King Jr.
Sat: The Presidents
The History Channel (2005)
Sun: The United States Constituting
The History Channel
Week of Nov.22. 2009
Mon: Early to Bed, Early to Rise)
Benjamin Franklin
Tues: Let’s Explore the Rainforest Level 2 (ages 6-7years)
Wed: Baby’s Story time (15 Best story levels)
Arco Guthrie
Thur: Little Rats Sets Sail
Monika Bang-Campbell
Fri: Three Stores You Can Read to Your Teddy Bear
Sara Swan Miller
Sat: Andy Shane and the Very Bossy Dolores Star buckle
Jennifer Richard Jacobson
Sun: Dr. Seuss ABC
Dr. Seuss
Week of Nov.29. 2009
Mon: Arthurs Reading Trick
Marc Brown
Tues: Hare and Rabbit: Friends Forever
Julia Noonan
Wed: Equal Rights for All
American History
Thur: United Flag
The History Channel
Fri: National Observances
The History Channel
Sat: Early Settlers
The History Channel
Sun: Us Songs and Hymns
The History Channel
Week of Dec.1 2009
Mon: Arthurs Reading Trick
Marc Brown
Tues: Hare and Rabbit: Friends Forever
Julia Noonan
Wed: Equal Rights for All
American History
Thur: United Flag
The History Channel
Fri: National Observances
The History Channel
Sat: Early Settlers
The History Channel
Sun: Us Songs and Hymns
The History Channel
Week of Dec.1 2009
Mon: Pooh Makes Growing-Up Fun
Disney Books
Tues: Feelings and Emotions
Wed: The 100th Day of School
Angela Shelf Medearis
Thur: Mighty Spider
Jean Day Zallinger
Fri: Wake Me Up in Spring
James Preller
Sat: I am Water (Scholastic Reader (Level 1)
Jean Marzollo
Sun: I am a Seed (Hello Reader)
Jean Marzollo
Week of Dec.6 2009
Mon: Stories of Dogs
Russell Punter
Tues: One Saturday Afternoon
Barbara Baker
Wed: The Man on A Unicycle & Other Stories
Elizabeth Bram
Thur: Ice is Whee
Carol Greene
Fri: The Birthday Tree
Paul Fleischman
Sat: Big World Small World
Jeanine Titherington
Sun: Little Rat Sets Sail
Monika Bang-Campbell
Week of Dec.13 2009
Mon: Monkeys and the Universe (Chapter Book)
Kate Banks
Tues: The Carrots Seed
Ruth Krauss
Wed: The Little Red Hen (Nursery Classics)
Tony Palazzo
Thur: What’s So Great About Nice
Jacquelyn Reinach
Fri: Don’t Eat Too Much Turkey
Miriam Cohen
Sat: Ready Readers: Giant Collection 10-in-1-Collection
Preschool-Grade1
Sun: Buster and Phoebe. Thje Greast Bone Game
Liz Bechtole
Week of Dec.20 2009
Mon: The Perfect Christmas Picture
Fran Manushken
Tues: Treasured Tales (Snowhite)  
A Parragan Publishing
Wed: Chicken Soup With Rice 
Maurice Sendak
Thur: Green Eggs and Ham
Dr. Seuss
Fri: Are You a Spider
Judy Anen & Judy Humphries
Sat: Disney’s Story Book Collection( Beauty and the Beast)
 Disney Storyland Treasury
Sun: Disney’s Story Book Collection( Sleeping Beauty)  Beast)
Disney Storyland Treasury
Week of Dec.27 2009
Mon: There’s A Bird on Your Head
Mo Willems
Tues: The High-Rise Private Eyes: The Case of the Troublesome Turtle  
Cynthia Rylant
Wed: Today I Will Fly 
Mo Willems
Thur: A Kiss For Little Bear
Maurice Sendak
Fri: Arthur’s Hiccups
Marc brown
Sat: Disney’s Story Book Collection( Lion King)
Disney Storyland Treasury
Sun: Nate The Great and The Big sniff ( Chapter Book)
Marjorie et al
Week of Jan.3 2010
Mon: The Teacher From the Black Lagoon
Mike Thaler
Tues: On the Thinks You Can Think  
          I Can Read With My Eyes Closed
Dr. Seuss
Dr. Seuss
Wed: Minnie And Moo Go To Paris 
Denys Cazet
Thur: How Do Dinosaurs Go To School
Jane Yolers
Fri: Gorillas Gentle Giants of the Forest
Joyce Milton
Sat: Disney’s Story Book Collection( Pinocchio )
Disney Storyland Treasury
Sun: Go, Dog, Go! 
P.D Eastman
Week of Jan.10.2010: Chapter Book galore!!!!
Mon: Junie B. Jones Is Not a Crook
Barbara Parks
Tues: Amelia Bedelia And The Surprise Party   
Peggie Parish
Wed: Oliver and Amanda And The Big Snow  
Jean Van Leewen
Thur: Crocodile! Crocodile
Margaret Mahy
Fri: Winnie the Pooh And Some Bees
Stephen Krensky
Sat: Amelia Bedelia 4 Mayor
Herman Parish
Sun: Amanda Pig and Her Big Brother Oliver
Jean Leewen
Week of Jan.17.2010: Chapter Book galore!!!!
Sat: Disney’s Story Book Collection( Noah’s Ark )
Disney Storyland Treasury
Sat: Disney’s Story Book Collection( The Ugly Duckling )
Disney Storyland Treasury
Sat: Disney’s Story Book Collection( Alice In Wonderland )
Disney Storyland Treasury
Sat: Disney’s Story Book Collection( Cinderella )
Disney Storyland Treasury
Sat: Disney’s Story Book Collection( Peter Pan )
Disney Storyland Treasury
Sat: Disney’s Story Book Collection( Sleeping Beauty )
Disney Storyland Treasury
Sat: Disney’s Story Book Collection(Beauty and the Beast )
Disney Storyland Treasury
It was Not all books, We sang, yes, we danced, Christ was with us
Jillian by heart  knew these & more
Pop Goes the weasel
 Classic Nursery Rhythms
Jack and Jill
Classic Nursery Rhythms
If you’re Happy and You Know It
Classic Nursery Rhythms
Five Little Monkeys
Classic Nursery Rhythms
Pat-a-Cake
Classic Nursery Rhythms
Three Blind Mice
Baa, Baa, Black Sheep
Hot Cross Burns
Oh Dear What Can The Matter Be
Little Miss Muffet
Little Jack Horner
Twinkle, Twinkle Little Star
Polly Put that kettle On
30 Days hath September
I’m a Little Teapot
The Cow Who Jumped Over The moon
Humpty Dumpty
Old McDonald Had Farm
Hey Diddle, diddle
To Market, To Market
Pease Porridge Hot
Jack Sprat
Sing A Song of Six Pence
Do Your Eyes Hang Low
Jack Be Nimble, Jack be Quick
Hickory, dickory dock
Classic Nursery Rhythms
We Read Bible Stories Too, We Read the Holy Bible!!!!
The Holy Bible, the infallible Word of God
Veggies Tales Bible StoryBook
King Solomon
King David
Queen Esther
Samuel
Samson
Noah and The Ark
The Creation
The 10 Commandments
VeggieTales
The List is inexhaustible, once Jillian learned to read, she ran with books to school, to church, at the subway, she could not stop!
Blizzard of the Blue Moon
Mary Pope Osborne
December Secrets
Paatrica Reilly Giff
The Boxcar Children Books 1-4
Gertrude Chandler Warner
**Mrs. Piggle-Wiggle Chapter books*** Reading level: Ages 8 & up. 128 pages by Betty Mac Donald
** Jillian Read this Book at age 5!!!!! – read before Judge Lewis
Betty MacDonald

                                                    CONCLUSION/RELIEF
The present horrible conditions of the subject child afore stated determine what she will become in the future and that DCF is not in dispute with anything in this case and no steps have been taking since over one year of the rumor base cause of removal and as such the subject child must be returned to Ms. Ogechi Eke to enable her return the hope of this Child to where intended before she was forcibly removed.
Therefore sake of the foregoing, Applicants’ Motion must be granted and subject child be returned to Ms. Eke and other order Court deems fit.
                             VERIFICATION
 Respectfully verified, signed and submitted under the pains and penalties of perjury this 14th  day of August 2012,
___________________________________
           OGECHI EKE  (Defendant)
___________________________________
          Phillip C. Ofume, Ph.D.
             Intervenor/Advocate
To:
Boston Juvenile Court
Clerk’s Office
24 New Chardon Street
Boston, MA 02114
                                                        CERTIFICATE OF SERVICE
I, OGECHI EKE  certify that a true copy of the APPLICANTS, OGECHI EKE AND PHILLIP OFUME'S  VERIFIED JOINT EMERGENCY MOTION AND MEMORANDUM FOR SUMMARY JUDGMENT AS TO URGENT RETURN OF CUSTODY TO PARENT, OGECHI was served up on the Attorney General of Mass and other parties by  U.S. Postal Service first class mail or Hand Delivery on  August 14, 2012.   
                                                                            
Massachusetts Department of Housing and Community Development                                                                                                                                                                         c/o The Honourable Secretary of Justice and Attorney-General of                                                                                                                                                                    the commonwealth of Massachusetts     Attention, Attorney of Record Gwen A. Werner                                                                                                                                            Department of Justice (Litigation)                                                                                                                                                                                                                          One Ashburton Place                                                                                                                                                                                                                                                                    Boston, MA 02108 -1518                                                                                                                                                                                                                       Phone: (617) 727-2200
Attorney Amy McManus Geary, Esq
P.O. Box 248
North. Quincy MA 02171
Kathleen J. Moore
 ____________________
   OGECHI EKE  
Date:   August 14, 2012
                                  
cc.    President Barack Obama, Vice-President Joseph Biden, H.E. United Nations High Commissioner for Human Rights, Counsels for DCF, Child and Foster Parents, The Hon. Secretary and Attorney-General of the United States, Eric H. Holder, Jr., Hon. Secretary of State, Senator Hilary Clinton, H.E. Secretary General of the United Nations, Bakim Moon, Executive Director, UNICEF, Chair, Amnesty International (Intl. Secretariat, London, UK), Executive Director, Human Rights Watch (USA), President, AAAA (Washington, DC, USA), LIMPT, INC. (EDUCATION & WORKFORCE PROJECT,  c/o Dr. Phillip Chukwuma Ofume – National Coordinator), etc.

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