BREAKING NEWS
MASS SECRETARY OF JUSTICE & ATTORNEY-GENERAL, JUDGES PAUL LEWIS AND ELIZABETH FAHEY, AND MASS DCF IGNORE ABUSES OF A BLACK 8-YEAR FEMALE SUBJECT CHILD BY AN ANGLICAN CHURCH REV. FOSTER PARENTS (April 2011 - PRESENT)
Paris, France Dec. 23, 2012 & Brussels, Belgium Dec. 20, 2012
http://universal-fashion-art-music.blogspot.com/search?q=ogechi+eke+v.+dcf
______________________________________________________
COMMONWEALTH OF MASSACHUSETTS
Suffolk,
ss SUPERIOR
COURT DEPARTMENT
CIVIL
ACTION DOCKET NO.
DOCKET
NO. OF COURT BELOW: CP10B0179
------------------------------------------------------------------------------------------------
OGECHI EKE
Petitioner/Defendant (Pro se)
and
PHILLIP
OFUME (LIMPT, INC. –
EDUCATION AND WORK FORCE PROJECT)
Intervenors /Child Civil Rights
Advocate
v.
MASSACHUSETTS
DEPARTMENT OF CHILDREN AND FAMILIES (DCF)
Respondent/Plaintiff
________________________________________________________________________
COMPLAINT
&
MOTION FOR SHORT
ORDER OF NOTICE
Ms. Ogechi Eke & Associates
43
Columbia Avenue Suite 11
Dorchester, MA 0212i
Tel.
617-436-358_______________________________________________________________________________
TABLE OF CONTENT
COMMONWEALTH OF MASSACHUSETTS
Suffolk, ss SUPERIOR COURT DEPARTMENT
SUFFOLK COUNTY SUPERIOR COURT DOCKET NO. 12-4516
BOSTON JUVENILE COURT Docket No. CP10B0179
------------------------------------------------------------------------------------------------------------
OGECHI EKE
Petitioner/Defendant (Pro se)
and
PHILLIP OFUME (LIMPT, INC. –
EDUCATION AND WORK FORCE PROJECT)
Intervenors /Child Civil Rights Advocate
v.
MASSACHUSETTS DEPARTMENT OF CHILDREN AND FAMILIES (DCF)
Respondent/Plaintiff
_____________________________________________________________________________
TABLE OF CONTENT
TAB ITEM PAGE
Motion for Short Order ……………………………………………………………………….1
Complaint and Request for Permanent Injunctive Relief
Including Equitable Relief……………………………………………………………………2-11
Exhibits:
A. Motion for Summary Judgment…………………………………………………..11 - 35
B. Subject Child’s Academic Awards…………………………………………………36 - 38
C. Judgment of Hon. Justice Paul Lewis (03/02/2011…………………..........39.
E. Academic Excellence of the Subject Child……………………………………….40
F. Investigation on Child Abuse………………………………………………………….41-43
G. Subject Child’s above age/grade impact in Language Arts……………44
L. Mental Health Report - Provider: Angela Bell, Ph.D………………………45-47
M. Petitioner’s Complaint against Judge Paul Lewis – Commission on
Judicial Conduct ………………………………………………………………………………………48-50
N. Case Procedural History 2004 – 2012…………………………………………………….51-53
O. Petitioner disagrees of Counsel’s secret proceedings with
the Respondent and Judge Lewis to place subject child
in abusive strangers’ permanent guardianship ………………………………………………54
P. Motion for Reconsideration before Jury of Judges of the
order of Judge Lewis on Oct. 9, 2012 leaving custody with
the strangers that are abusing subject child……………………………………………………55-61
______________________________________________________________________________
COMMONWEALTH OF MASSACHUSETTS
Suffolk, ss
SUFFOLK COUNTY SUPERIOR COURT DOCKET NO. 12-4516
BOSTON JUVENILE COURT Docket No. CP10B0179
------------------------------
PHILLIP OFUME (LIMPT, INC. -
EDUCATION AND WORK FORCE PROJECT)
Intervenors /Child Civil Rights Advocate
______________________________
MASSACHUSETTS DEPARTMENT OF CHILDREN AND FAMILIES (DCF)
PETITIONER, OGECHI EKE AND INTERVENORS, PHILLIP OFUME & LIMPT, INC.’S MOTION FOR SHORT ORDER OF NOTICE
______________________________
HERE COMES the Plaintiff and Intervenor aforementioned, jointly move this honourable Court for a short order of Notice in the above matter for purpose of filing a Motion for Preliminary Injunction and/or also seeking equitable relief (M.C.P.R. 1), subject such as Care, Protection, Return of Custody to Petitioner or nuclear parent (Ms. Ogechi Eke) of the Subject child name reserved as J. George forcibly removed on before April 13, 2011 and placed in harmful, abusive, child labor cartel, and destructive custody detailed in the enclosed PETITION FOR REVIEW AND REQUEST FOR PERMANENT INJUNCTIVE OR EQUITABLE RELIEF.
Respectfully submitted,
_________________________
OGECHI EKE (Defendant)
------------------------------
Phillip C. Ofume, Ph.D.
Intervenor/Advocate/Defendant
CERTIF
I, Ms. Ogechi Eke certify that a true copy of the PETITIONER, OGECHI EKE AND INTERVENORS,PHILLIP OFUME & LIMPT, INC.’S MOTION FOR SHORT ORDER OF NOTICE was served up on all parties by U.S. Postal Service first class mail or Hand Delivery on December 7, 2012.
Massachusetts Department of Housing and Community Development
Attorney Kathleen J. Moore
P. O. Box 558
Milton, MA 02186
Attorney Melaine Capwell
Department of Children and Families (DCF)
50B Park Street
Dorchester, MA 02122
_________________
OGECHI EKE
____________________________________________________________________________
COMMONWEALTH OF MASSACHUSETTS
Suffolk, ss
SUFFOLK COUNTY SUPERIOR COURT DOCKET NO. 12-4516
BOSTON JUVENILE COURT Docket No. CP10B0179
------------------------------
PHILLIP OFUME (LIMPT, INC. -
EDUCATION AND WORK FORCE PROJECT)
Intervenors /Child Civil Rights Advocate
MASSACHUSETTS DEPARTMENT OF CHILDREN AND FAMILIES (DCF)
______________________________
A. COMPLAINT (NATURE OF PETITION FOR REVIEW) AND REQUEST FOR PERMANENT INJUNCTIVE RELIEF INCLUDING EQUITABLE RELIEF (M.C.P.R. 1)
1. In support of the fact of this Petition for Review, Petitioner attaches the following material evidence,EXHIBIT A, (MOTION FOR SUMMARY JUDGMENT filed with the Court below); EXHIBIT B (MOTION TO SUBMIT WITNESS AND EXHIBIT filed with the Court below); EXHIBIT C (JUDGMENT OF JUDGE PAUL D. LEWIS dated on March 2, 2011) and Equitable Relief (M.C.P.R. 1), on EXHIBIT C or Order dated March 2, 2011; EXHIBITS E, F, G, H, I, GREAT MOTHER/PARENT IN TESTIMONIES BY SUBJECT CHILD, SUBJECT CHILD'S SCHOOL, ETC.; EXHIBIT D - SERVICE PLAN, COMPLETION AND EXPERT REPORT - LOCATION OF CARE: Roxbury Comprehensive Community Health Center - Mental Health Department. Name of Provider: Angela Bell, Ph.D. LMHC. ; EXHIBIT L(HUNDREDS OF ASSORTED CLOTHES OF THE SUBJECT CHILD PURCHASED BY MS. EKE) AND EXHIBIT M (ASSORTED SHOES AND FREE WEARS PURCHASED BY THE MS. EKE); ETC
2. Ms. Eke is an excellent graduate of the Nigerian University of Agriculture and fifth Year Student of the Massachusetts College of Pharmacy. At present, single Mother of the subject child Ms. Ogechi Eke has personal 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).
3. On before 2004 Ms. Ogechi Eke, mother of the subject Child, J. George was a Pharmacy Student at the Massachusetts College of Pharmacy and because of her Nigerian ethnic place of origin some opponents inside and outside the college unleashed highhanded persecution and controlled the academic body in nature of coalition including unfounded allegation of insanity against Ms. Eke and alert sent to the Department of Social Services or Department of Children and Families. When the persecution reached life-threatening level Ms. Eke petitioned the college and the academic staff to the Civil Rights Commission and The Governor of Massachusetts. Receipt of the papers of the investigation angered the Massachusetts College of pharmacy and the Department of Social Services or Department of Children and Families. Action taken under 1st and 5th Amendments to the Constitution and Bill of Rights of the United States was construed as MENTAL HEALTH issue and swiftly Ms. Eke was expelled from the Massachusetts College of Pharmacy without assessment and evaluation of the allegation by mental health physician or expert. Irately the trump up allegation of mental health was widely circulated to block Ms Eke and set future path for further persecution including seizure of her child and her access to alternative education, employment, etc.
4. To dismiss the falsified mental health allegation of the Massachusetts College of Pharmacy, Ms. Attended mental health evaluation. SERVICE PLAN, COMPLETION AND EXPERT REPORT - LOCATION OF CARE: Roxbury Comprehensive Community Health Center - Mental Health Department. Name of Provider: Angela Bell, Ph.D. LMHC. Department of Children and Families (DCF), and other collaborating predominantly white department refused to accept Dr. Bell's Expert assessment and evaluation conducted on Ms. Ogechi Eke because the provider, Dr. Bell is a Black. For rejecting expert mental health evaluation and assessment because of race, color, political affiliation, religion and related intolerance is what several courts and Judges in the United States will oppose.
5. The action of Judge Lewis and DCF angered Roxbury Comprehensive Community Health Center and Mental Health Department and the Director of the Center, Ms. Coonie B. Cohen (white). In further opposition, Ms. Coonie B. Cohen signed the assessment/evaluation report of Dr. Bell (Black) on November 26, 2012. EXHIBIT D.
5. Because of EXHBIT D which has complete requirement of an official expert work under conventional mental health assessment and evaluation acceptable by court and other adjudicating authority, the presiding Judge sanctioned Motion for reconsideration which remain pending to this day when Petitioner and her Intervenors proceeded this honourable to file this Complaint.
6. In this case, the Court, Judges and DCF staff are divided. One part of the DCF staff said, “white attorneys and DCF staff are rejecting the report because as usual the provider is not a white and they want the child of a black woman Ms. Eke at all cost.” On September 4, 2012 the Haitian Court Investigator controlled by Judge Lewis (White) received copies of the mental health report of Dr. Bell and she (Haitian Court Inspector) promised to give the Report to Judge Lewis and on September 4, 2012 and under the conspiracy between DCF and this Court the purported Court Investigator censored 100% of the progress made by Ms. Eke including completion of the majority of the SERVICE PLAN including the falsified mental health treatment recommended by a racist mental health doctor on September 30, 2004 and another falsified report by Daniel Audet.
7. On September 30, 2004 Ms. Eke gave birth to the Subject Child with pains and the nurses and physicians abandoned her and the nurses called DCF and the agency came and seized and removed the subject child. The DCF, hospital, College of Pharmacy and visiting psychiatric doctor connived to recommend mental health evaluation. This unverified, tested and related lack of expert research and investigation created a nickname for Ms. Eke and shamefully restated and cited by the long retained Hon. Justice Paul D. Lewis. The newborn subject child was returned to Ms. Eke.
8. On March 2, 2011 Judge Paul Lewis ordered that Custody of the Subject Child would continue to remain with Ms. Eke (the child’s mother) EXHIBIT C.
9. Paragraph 5 above was changed by the personal power of the DCF because Ms. Eke and the subject child planned to travel to Nigeria to attend the burials of their relatives. In EXHIBIT C Judge Lewis did not order or impose travel restriction on Ms. Eke and the subject Child.
10. On the day of the departure, DCF and other conspirators listed above followed them from the Boston Airport to Canada and in Canada Ms. Eke and the Subject Child were blocked from travelling to Nigeria and they were return to Boston and in the following days Ms. Eke and subject child were brought to court before Judge Lewis and without reason the subject child was seized and placed under the custody of foster parents that make the subject child to suffer severe acute danger educationally, socially, economically, psychologically, etc.
11. Paragraph 28 and EXHIBITS A & B of EXHIBIT A above EXHIBITS J. George’s Books and other educational enrichment materials for Home School (Core curriculum Only) Learning Coach is Mom (Ogechi Eke) and at the early age of 3-5 years the subject child read grades 5-8 books while under the care of Ms. Eke the subject child read these high grade books in the presence of Judge Lewis and also the Department of Education evaluated her educational excellence and promised to jump her promotion to grade 2 or 3. Now the subject child’s education is doomed and the school where she is placed demoted her to about grade 1 because all the educational enrichment resources, daily after accelerated teaching created by Ms. Eke is gone. In one of the top ranking Summer Schools in Mass (fee $5000.00) she earned merit award in English, Mathematics, Writing, etc.
12. The subject child is abused and subjected to severe form of child labor and the foster parents pay her about $2.00 to make her abandon her education because the subject child show example strained of right to see and touch money by the foster parents and when the subject child now 8 years was paid $2.00/day for working several hours .
13. On October 9, 2012 Ms. Eke moved for immediate and unconditional return of her child but the Judge was interrupted by the DCF with the mental health rumor created by the Massachusetts College of Pharmacy but without paper and other evidence.
B. PERMANENT INJUNCTIVE RELIEF
13. The allegations of paragraphs 1 (one) through thirteen (13) above are incorporated by reference.
14. Other foster kids seized by the DCF and given to guardians or adopted are used as money making tools without focus on their education and the large sum of money paid by the DCF to these foster parents are used to build personal empire and soon as these kids are 18 years the payment ends and in major part the adult kids are excluded and made destitute. Some of the female kids are impregnated to enable them make unofficial kids whom the foster parents put into moneymaking machine (child benefits and other social assistance).
15. Subject Child is highly intimidated and shut up on disclosure of any information on what she has been suffering since she was taken into foster care. Several times when Ms. Eke visited the foster parents to see her only daughter and soon as the subject child hugs her bio-mother, the foster parents drags her out and separate her from receiving questions and answering them.
16. The only child of Ms. Eke is mistreated and used to run in-house profit make business and she is paid $2.00 per day the subject child confessed and said,
“Mommy I am paid for taking care of smaller kids in my foster parent daycare …can I give you some money” Mom ask, tell me how do you do this work? Subject child said, “each time I come back from school, I start working and I work to time to sleep”
17. This and several other anonymous and disclosable information and activities which the intervenors and Ms. Eke got led to prior October 9, 2012 when the Ms. Eke and the Intervenors demanded subpoena on the subject child and other several witnesses and no subpoenas were issued and the subject child was not brought to the hearing.
16. Without urgent action taken by this honorable court, the subject child will suffer more and more abusive danger educationally, socially, economically, psychologically, etc and finally drop out of school.
17. Therefore on the foregoing, the Petitioner is fully entitled to an Order that the Defendant return custody of the subject to Ms. Eke. (Child’s biological mother)
WHEREFORE, the Plaintiff asks that this Honorable Court enter a Judgment against Defendant ordering Defendant to return custody of the subject child to Ms. Eke because the subject child is being destroyed on daily basis because education which is GATEWAY TO EVERYTHING is neglected and replaced with child indentured labor.
C. VERIFICATION OF PETITION
We, Phillip C. Ofume and Ms. Ogechi Eke hereby respectfully verify and submit the above-mentioned documents and that they are correct to the best of my knowledge and signed and authorize submission under the pains and penalties of perjury this 6th day of December 2012.
Massachusetts Department of Housing and Community Development
Department of Justice (Litigation) One Ashburton Place
Boston, MA 02108 -1518
Phone: (617) 727-2200
Attorney Kathleen J. Moore
P. O. Box 558
Milton, MA 02186
Attorney Melaine Capwell
Department of Children and Families (DCF)
50B Park Street
Dorchester, MA 02122
_________________
OGECHI EKE
Contact information and other particulars of the Respondent:
Massachusetts Department of Transitional Assistance (DTA) Attorney Gwen Werner
c/o The Honourable Secretary of Justice and Attorney-General of
the commonwealth of Massachusetts
Department of Justice (Litigation)
One Ashburton Place
Boston, MA 02108 -1518
Phone: (617) 727-2200
Massachusetts Department of Transitional Assistance (DTA) Attorney Gwen Werner
c/o The Honourable Secretary of Justice and Attorney-General of
the commonwealth of Massachusetts
Department of Justice (Litigation)
One Ashburton Place
Boston, MA 02108 -1518
Phone: (617) 727-2200
SUPPORTED BY:
LIMPT, INC. & IMUN, INC. PROJECT (EDU., HUMAN RIGHTS, INSURANCE CORP., LAW REFORM & LITIGATION PROJECT - INTL. CHAPTER); INTL. COALITION FOR PRO SE/UNSIGNED LAWYERS & GLOBAL CLASS ACTION PROJECT; INTL. ENDOWMENT FOR DEMOCRACY, FOSTER/ADOPTIVE/ ORPHANAGE & CIVIL LIBERTIES
Phillip C. Ofume, Ph.D.
Godson Etiebet, Ph.D.
Cynthia H. Taylor, Ph.D.
Alh. (Dr.) Farruk Mohammad - Strategic Policy Researcher
Tan Ochollu, D.Lit. - Expansion Project Developer
Reid MacDonald, Ph.D. - Strategic Program Developer
Jerome Tesfai, D. Min/Div - Domestic Intervention Strategist
Francois Bourgeois & Pierre Bushel - International Human Rights
AFRICAN CANADIAN HUMAN RIGHTS ASSOCIATION (ACHRA);
NETLINK INTERNATIONAL COMMUNICATION SYSTEM (NLICS);
INTERNATIONAL CAMPAIGN FOR NIGERIAN PEOPLE’S LIBERATION AND
DEMOCRACY(ICN-PLD);
OIL AND CHEMICAL WATCH INTERNATIONAL (OCWI);
AFRICAN CANADIAN IMMIGRANT SETTLEMENT ASSOCIATION (ACISA);
INTERNATIONAL NETWORK FOR PEACE AND DEVELOPMENT IN AFRIK (NIPAD).
LIMPT, INC. (EDUCATION AND WORKFORCE PROJECT ET ALS)
MOVEMENT FOR EMANCIPATION OF THE NIGER DELTA (MEND)
INTERNATIONAL MOVEMENT FOR NEW FEDERAL UNION OF NIGERIA (IMUN, INC.)
Contact Information:
LIMPT, INC. & IMUN, INC. PROJECT (EDU., HUMAN RIGHTS, INSURANCE CORP., LAW REFORM & LITIGATION PROJECT - INTL. CHAPTER); INTL. COALITION FOR PRO SE/UNSIGNED LAWYERS & GLOBAL CLASS ACTION PROJECT; INTL. ENDOWMENT FOR DEMOCRACY, FOSTER/ADOPTIVE/ ORPHANAGE & CIVIL LIBERTIES
41 Gallivan Blvd
Dorchester, MA 02124 OR
Lynn, MA 01903
Tel. 857-266-2253/781-479-9027
E-mail: limptintinc@gmail.com or
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