Defendant Susan Vick, Attorney Advocate Guardian ad Litem (aka Public Pretender) Attorney for my 7 minor children June 23, 2010 thru April 19, 2011
Defendant Susan Vick, Attorney Advocate being hereby named in both her individual and official capacities, is an individual and a resident of this jurisdictional district, is an attorney advocate for The Wake County Guardian ad Litem Program and is appointed by the Wake County District Court Judge in Wake County, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; c/o The Wake County Guardian ad Litem Program, PO Box 1107, Raleigh, NC 27602. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that while in her official capacity as a Guardian ad Litem Attorney Advocate for Wake County her execution of The Wake County Guardian ad Litem Program’s “customs” and/or “policies” were the moving force behind his unconstitutional acts. In addition, as a court appointed attorney (public defender) she did act under the authority or color of state law when she acted in concert with local officials, including but not limited to, WCHS social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980). Attorney immunity for intentional harm to one’s client (Plaintiff 7 minor children) was never so protected at common law, Tower v. Glover (1984).
|Name||Ms. Susan F. Vick|
|Address||2217 Oxford Road|
|Fax||Not on file|
COUNT I; VIOLATION OF THE FOURTEENTH AMENDMENT – Both the Due Process Clause and the Equal Protection Clause
Susan Vick is the Guardian ad Litem ,Attorney advocate appointed by Judge Monica Bousman to represent the so-called “best interest” (a loosley parroted term often overused in our court proceedings to hide behind the truth) of my 7 minor children in case number 10JA xxx-xxx. To this day she has failed to even come close to representing the “best interest” of my 7 minor children. She seems to be more concerned with her own selfish motivations of claiming “victory” at various stages of this process with complete disregard for the rights of my 7 minor children and indeed the rights of anyone else in this case. She has conspired with other collaterals to coerce both me and my wife on topics of Legal separation and Divorce, even posing question asking me in one Non-Secure Custody hearing demanding that I explain “the meaning of my wedding ring”. She has contributed her own lies to the proceedings, even supporting false allegations of sending threatening emails and false reports that I somehow threatened a so-called therapist who I never met. She has “insisted” that I “must” take responsibility for allegedly abusing my entire family both mentally and physically with absolutely no corroborating evidence, as none exists. She further conspired with others in a hearing held on December 16, 2010 demanding that the court Order that I “start over” in her desperate attempt to coerce me into admitting something that never took place. Susan Vick demands in her motion before the court; “Since the date of the adjudication and disposition, Ronald Reale has denied the veracity of the stipulations he entered and disputes that he was ever physically aggressive to his wife or children. This is a concern to the Court given his psychological evaluation directly conditions progress on the father’s willingness to take responsibility for his past actions and his reliability for being truthful.” Actually, the court specifically stated that it did not want me to “put your hand up and simply say ok, I did it, tell me what I need to do,” and she knows very well that there were no admissions of abuse in the stipulation as none existed nor was there any sort of allocution to those allegations. Most of these new demands and renewed efforts to keep my children from me arose out of Wake County Human Services’ dislike of the emails being sent to them by me demanding that they honor the court order as to visitation. These emails were, in effect, turning up the heat on WCHS and its agents yet they deferred to Susan Vick to work on their behalf to generate her motion for review rather than a more customary approach of filing their own motion. None of the emails in question were directed to Susan Vick. Further evidence will be presented in the pending Federal Action to this end. Attorney immunity for intentional harm to one’s client (the plaintiff’s 7 minor children) was never so protected at common law, Tower v. Glover (1984).
COUNT II; VIOLATION OF THE FOURTEENTH AMENDMENT – Both the Due Process Clause and the Equal Protection Clause
Susan Vick presented a motion captioned “Motion for Review as to Respondent father’s Repudiation of his Stipulations and to Prohibit any Non-Therapeutically Sanctioned and Administered Visitation with the children” which was just one of a series of attempts by the GAL Attorney Advocate, Susan Vick to misrepresent the Stipulation and the Order on Adjudication and Disposition and conspiring to say or to do whatever need be to prevent visitation between me and my 7 minor children, to prevent me from regaining custody, both absolutely contrary to the best interest of my children (her clients).
To start with Susan Vick’s motion states “The respondent father stipulates to very specific instances of abuse and injury.” This is false as allegations of abuse or neglect have never been stipulated to at any point in these proceedings. In fact, the last sentence of paragraph 6 of the Order on Adjudication and Disposition states; “Since no disclosures were made, the allegations were not substantiated, and WCHS determined at this time that the family was not in need of services.” Where is the stipulation to ANY abuse? Again, Susan Vick refers to paragraph 18 of the Order on Adjudication and Disposition stating; “the children have been emotionally impacted by the injurious environment in which they lived with the father and mother.” my wife and I stipulated to the fact that this statement was made on several occasions throughout this process, specifically in the DVPO which was entered unlawfully and is in effect, a void order and has since been set aside as such, but neither of us offered any allocution as to support or agreement on the topic. Where are the specifics, the details, anything that could corroborate or move these allegations in the direction of becoming even remotely true? They do not exist because the allegations are far from the truth, rendering them impossible to prove because the abuse never existed.
COUNT III; VIOLATION OF THE FOURTEENTH AMENDMENT – Both the Due Process Clause and the Equal Protection Clause
Here is an example of how Susan Vick attempted to request that the court require that a “treatment team” be recognized and be a pre-requisite for visitation to take place between me and my 7 minor children. This request was reckless and in keeping with her conspiring with others to keep the children from me, clearly not in the “best interest” of her client (my 7 minor children). The conspiracy in that along with the county attorney and the social workers she continues to attempt to mold the order permitting visitation to reach a final outcome contrary to the interest of each of my 7 minor children. She referenced the following statement in the Order on Adjudication and Disposition date September 3, 2010; “Attending visitation with his children as scheduled once the DVPO expires or is modified and visitations are approved by the treatment team, in which case he shall be authorized to have weekly visits for at least 1 hour each visit, supervised by WCHS at the agency or in the community.” At the time this order was entered no such treatment team was in existence for any of my 7 minor children. Per the Court Summary – 3 Month Review submitted by Julie Riggins and Nikki Lyons dated October 20, 2010 the following was revealed; “WCHS’ CHDP, on 7/20/2010, completed physicals, developmental assessments, and mental health assessments on all 7 children.” BRR (age 3) and JRR (age 4) were not recommended for therapy whatsoever. The rest of my minor children had not begun any sort of therapy. The DVPO entered on May 3, 2010 has been set aside and an amended order has been entered as of October 29, 2010 clearing the way for visits to commence immediately. WCHS has ignored all requests via email and in person from me to schedule or facilitate any supervised visits. Susan Vick was well aware that there was no such treatment team. She was simply conspiring with the others’ to prevent visits and in doing so she was clearly effecting the deprivation of rights of my entire family.
COUNT IV; VIOLATION OF THE FOURTEENTH AMENDMENT – Due Process Clause
Susan Vick comes out of “left field” and describes an accusation that was never adjudicated nor was it to be found anywhere in the stipulation. I guess because it was an accusation that adds TEETH to their agenda; they felt they could not “pass it up”. The GAL attempts to insert the requirement that I “acknowledge his role in allowing his children to be left without proper supervision and education.” RIDICULOUS! Here is a great example of how the psychological evaluation is flawed and clearly biased. This is an accusation that comes straight from CPS documents (provided in advance to the evaluator) which was also never accompanied by any evidentiary facts nor was it included in any Court Order or ever stipulated to in this case. This allegation has been vehemently denied from the beginning, and will be to the end and in fact, can quite easily be negated.