THE FEDERAL CASE

Click to view a copy of the Civil Rights Complaint filed in the Eastern District of North Carolina on November 28, 2011 and amended on September 17, 2012

Reale Family Civil Rights Complaint (Amended 9/17/2012); Title 42, Section 1983 U.S.C.

Click to view a copy of the Request for a Temporary Restraining Order & Appointment of Law Guardian filed in the Eastern District of North Carolina on September 17, 2012, in conjunction with the Civil Rights Complaint.

Reale Family Request for TRO & Appointment of Law Guardian

CIVIL COMPLAINT

NOW COME the above named Plaintiffs and for their causes of action against the above named Defendants, respectfully state to the court the following, and files this complaint.

Plaintiffs seek relief in the form of an order requiring the immediate return of the Plaintiffs’ seven minor children to the full legal and physical custody of the Plaintiff parents and other relief by way of back and front lost income, back and front medical and mental health expenses, actual, compensatory and punitive damages, and all legal fees and costs.

STATEMENT OF JURISDICTION

Jurisdiction is proper in this court for violations of civil rights pursuant to 42 U.S.C. § 1983. This is a civil action arising under the Constitution of the United States of America, and North Carolina common and statutory law, and is brought pursuant thereto and to 42 U.S.C. § 1983. Jurisdiction is proper under 28 U.S.C. §§ 1331 and 1343. Venue is proper in the Eastern District of North Carolina under 28 U.S.C. § 1391(b) as Defendants reside in North Carolina and live and/or work in the Eastern District of North Carolina. This is the jurisdictional district in which the Plaintiffs reside and/or previously resided, including during the times the Plaintiffs’ causes of action arose, and/or the jurisdictional district in which the injuries suffered by Plaintiffs were sustained, and in which all the events giving rise to the Plaintiffs’ claims occurred.

PARTIES

PLAINTIFFS

Plaintiffs are residents of Morrisville, North Carolina in the County of Wake. Current mailing address is 11010 Lake Grove Blvd, Suite 100-211, Morrisville, NC 27560.

Plaintiff, Ronald Reale, is an individual and resident of the State of North Carolina, the husband of Plaintiff Debra Reale, and the natural and legal father, legal custodian of, and next friend to the minor children Plaintiffs, S.R.R., M.R.R., H.M.R., S.M.R., J.R.R., and B.R.R.. Ronald Reale is also the stepfather of Plaintiff T.R.B..
Plaintiff, Debra Reale, is an individual and resident of the State of North Carolina, the wife of Plaintiff Ronald Reale, and the natural and legal mother, legal custodian of, and next friend to the minor children Plaintiffs, T.R.B., S.R.R., M.R.R., H.M.R., S.M.R., J.R.R., and B.R.R..
Plaintiff, T.R.B. (through next friends Ronald and Debra Reale), is an individual, a minor child, and resident of the State of North Carolina.
Plaintiff, S.R.R. (through next friends Ronald and Debra Reale), is an individual, a minor child, and resident of the State of North Carolina.
Plaintiff, M.R.R. (through next friends Ronald and Debra Reale), is an individual, a minor child, and resident of the State of North Carolina.
Plaintiff, H.M.R. (through next friends Ronald and Debra Reale), is an individual, a minor child, and resident of the State of North Carolina.
Plaintiff, S.M.R. (through next friends Ronald and Debra Reale), is an individual, a minor child, and resident of the State of North Carolina.
Plaintiff, J.R.R. (through next friends Ronald and Debra Reale), is an individual, a minor child, and resident of the State of North Carolina.
Plaintiff, B.R.R. (through next friends Ronald and Debra Reale), is an individual, a minor child, and resident of the State of North Carolina.

DEFENDANTS

Defendant State of North Carolina, operating as a State Government, North Carolina was at all times material, pertinent and relevant hereto. Current mailing address is; c/o Attorney General Roy Cooper, III, Old Education Building, 114 W. Edenton Street, Raleigh, NC 27602. The Defendant was in fact at all times, operating and acting under the authority or color of state law at the time these claims occurred in that its “customs” and/or “policies” were the moving force behind the unconstitutional acts of its agents against the Plaintiffs in effecting the deprivation of rights.

Defendant Beverly Perdue, North Carolina State Governor, and being hereby named in both her individual and official capacities, is an individual and a resident of this jurisdictional district, is a state employee and was at all times material, pertinent and relevant hereto, employed by The State of North Carolina. Current mailing address is; c/o Attorney General Roy Cooper, III, Old Education Building, 114 W. Edenton Street, Raleigh, NC 27602 or 20301 Mail Service Center, Raleigh, NC 27699-0301. 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 the Governor of North Carolina her execution of North Carolina’s “customs” and/or “policies” were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, acting personally and individually she did act under the authority or color of state law when she acted in concert with other local officials including but not limited to Defendants North Carolina Department of Health and Human Services, Albert Delia, Wake County Human Services, North Carolina Administrative Office of the Courts, and the Wake County Guardian ad litem Program, among others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant North Carolina Department of Health and Human Services, a state agency doing business in The State of North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; c/o Emery Edwards Milliken, 2001 Mail Service Center, Raleigh, NC 27699-2001. The Defendant was in fact at all times, operating and acting under the authority or color of state law at the time these claims occurred in that its “customs” and/or “policies” were the moving force behind the unconstitutional acts of its agents against the Plaintiffs in effecting the deprivation of rights.

Defendant Albert Delia, Acting Secretary North Carolina Department of Health and Human Services, and being hereby named in both his individual and official capacities, is an individual and a resident of this jurisdictional district, is a state employee and was at all times material, pertinent and relevant hereto, employed by The State of North Carolina. Current mailing address is; c/o Emery Edwards Milliken, 2001 Mail Service Center, Raleigh, NC 27699-2001. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that while in his official capacity as the Acting Secretary North Carolina Department of Health and Human Services his execution of North Carolina’s “customs” and/or “policies” were the moving force behind his unconstitutional acts, and that personally, his individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, acting personally and individually he did act under the authority or color of state law when he acted in concert with other local officials including but not limited to Defendants the North Carolina Department of Health and Human Services, Wake County Human Services, the North Carolina Administrative Office of the Courts, and the Wake County Guardian ad litem Program, among others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Wake County Human Services (WCHS), is located in, licensed and doing business in Wake County, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; 220 Swinburne Street, Raleigh, NC 27610. The Defendant was in fact at all times, operating and acting under the authority or color of state law at the time these claims occurred in that its “customs” and/or “policies” were the moving force behind the unconstitutional acts of its agents including but not limited to Defendants Ramon Rojano (Director Wake County Human Services), Dr. Warren Ludwig (Wake County Human Services Child Welfare Division Director), Lisa Cauley (Wake County Human Services Assistant Division Director), Virginia King (Wake County Human Services Program Manager), Saundra Judd (social worker), Jill Green (social worker), Richard Hayner (social worker supervisor), Julie Riggins (social worker), Nikki Lyons (social worker supervisor), John Gustavson (social worker supervisor), and Nancy Brake (social worker) against the Plaintiffs in effecting the deprivation of rights.

Defendant Ramon Rojano, Director Wake County Human Services and being hereby named in both his individual and official capacities, is an individual and a resident of this jurisdictional district, is a county employee and was at all times material, pertinent and relevant hereto, employed by Wake County Human Services in Wake County, North Carolina. Current mailing address is; c/o Wake County Human Services, 220 Swinburne Street, Raleigh, NC 27610. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that while in his official capacity as the Director of Wake County Human Services his execution of Wake County Human Services’ “customs” and/or “policies” were the moving force behind his unconstitutional acts, and that personally, his individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, acting personally and individually he did act under the authority or color of state law when he acted in concert with other local officials, including but not limited to, other Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Dr. Warren Ludwig, Wake County Human Services Child Welfare Division Director and being hereby named in both his individual and official capacities, is an individual and a resident of this jurisdictional district, is a county employee and was at all times material, pertinent and relevant hereto, employed by Wake County Human Services in Wake County, North Carolina. Current mailing address is; c/o Wake County Human Services, 220 Swinburne Street, Raleigh, NC 27610. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that while in his official capacity as the Child Welfare Division Director for Wake County Human Services his execution of Wake County Human Services’ “customs” and/or “policies” were the moving force behind his unconstitutional acts, and that personally, his individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, acting personally and individually he did act under the authority or color of state law when he acted in concert with other local officials, including but not limited to, other Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Lisa Cauley, Wake County Human Services Assistant Division Director and being hereby named in both her individual and official capacities, is an individual and a resident of this jurisdictional district, is a county employee and was at all times material, pertinent and relevant hereto, employed by Wake County Human Services in Wake County, North Carolina. Current mailing address is; c/o Wake County Human Services, 220 Swinburne Street, Raleigh, NC 27610. 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 the Assistant Division Director for Wake County Human Services her execution of Wake County Human Services’ “customs” and/or “policies” were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, acting personally and individually she did act under the authority or color of state law when she acted in concert with other local officials, including but not limited to, other Wake County human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Virginia King, Wake County Human Services Program Manager and being hereby named in both her individual and official capacities, is an individual and a resident of this jurisdictional district, is a county employee and was at all times material, pertinent and relevant hereto, employed by Wake County Human Services in Wake County, North Carolina. Current mailing address is; c/o Wake County Human Services, 220 Swinburne Street, Raleigh, NC 27610. 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 Program Manager for Wake County Human Services her execution of Wake County Human Services’ “customs” and/or “policies” were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, acting personally and individually she did act under the authority or color of state law when she acted in concert with other local officials, including but not limited to, other Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant John Gustavson, Wake County Human Services Social Worker Supervisor and being hereby named in both his individual and official capacities, is an individual and a resident of this jurisdictional district, is a county employee and was at all times material, pertinent and relevant hereto, employed by Wake County Human Services in Wake County, North Carolina. Current mailing address is; c/o Wake County Human Services, 220 Swinburne Street, Raleigh, NC 27610. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that while in his official capacity as a social worker supervisor for Wake County Human Services his execution of Wake County Human Services’ “customs” and/or “policies” were the moving force behind his unconstitutional acts, and that personally, his individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, acting personally and individually he did act under the authority or color of state law when he acted in concert with other local officials, including but not limited to, other Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Nikki Lyons, Wake County Human Services Social Worker Supervisor and being hereby named in both her individual and official capacities, is an individual and a resident of this jurisdictional district, is a county employee and was at all times material, pertinent and relevant hereto, employed by Wake County Human Services in Wake County, North Carolina. Current mailing address is; c/o Wake County Human Services, 220 Swinburne Street, Raleigh, NC 27610. 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 social worker supervisor for Wake County Human Services her execution of, Wake County Human Services’ “customs” and/or “policies” were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, acting personally and individually she did act under the authority or color of state law when she acted in concert with other local officials, including but not limited to, other Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Richard Hayner, Wake County Human Services Social Worker Supervisor and being hereby named in both his individual and official capacities, is an individual and a resident of this jurisdictional district, is a county employee and was at all times material, pertinent and relevant hereto, employed by Wake County Human Services in Wake County, North Carolina. Current mailing address is; c/o Wake County Human Services, 220 Swinburne Street, Raleigh, NC 27610. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that while in his official capacity as a social worker supervisor for Wake County Human Services his execution of Wake County Human Services’ “customs” and/or “policies” were the moving force behind his unconstitutional acts, and that personally, his individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, acting personally and individually he did act under the authority or color of state law when he acted in concert with other local officials, including but not limited to, other Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Nancy Brake, Wake County Human Services Social Worker and being hereby named in both her individual and official capacities, is an individual and a resident of this jurisdictional district, is a county employee and was at all times material, pertinent and relevant hereto, employed by Wake County Human Services in Wake County, North Carolina. Current mailing address is; c/o Wake County Human Services, 220 Swinburne Street, Raleigh, NC 27610. 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 social worker and class instructor for Wake County Human Services her execution of, Wake County Human Services’ “customs” and/or “policies” were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, acting personally and individually she did act under the authority or color of state law when she acted in concert with other local officials, including but not limited to, other Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Julie Riggins, Wake County Human Services Social Worker and being hereby named in both her individual and official capacities, is an individual and a resident of this jurisdictional district, is a county employee and was at all times material, pertinent and relevant hereto, employed by Wake County Human Services in Wake County, North Carolina. Current mailing address is; c/o Wake County Human Services, 220 Swinburne Street, Raleigh, NC 27610. 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 social worker for Wake County Human Services her execution of Wake County Human Services’ “customs” and/or “policies” were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, acting personally and individually she did act under the authority or color of state law when she acted in concert with other local officials, including but not limited to, other Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Saundra Judd, Wake County Human Services Social Worker and being hereby named in both her individual and official capacities, is an individual and a resident of this jurisdictional district, is a county employee and was at all times material, pertinent and relevant hereto, employed by Wake County Human Services in Wake County, North Carolina. Current mailing address is; c/o Wake County Human Services, 220 Swinburne Street, Raleigh, NC 27610. 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 social worker for Wake County Human Services her execution of Wake County Human Services’ “customs” and/or “policies” were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, acting personally and individually she did act under the authority or color of state law when she acted in concert with other local officials, including but not limited to, other Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Jill Green, Wake County Human Services Social Worker and being hereby named in both her individual and official capacities, is an individual and a resident of this jurisdictional district, is a county employee and was at all times material, pertinent and relevant hereto, employed by Wake County Human Services in Wake County, North Carolina. Current mailing address is; c/o Wake County Human Services, 220 Swinburne Street, Raleigh, NC 27610. 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 social worker for Wake County Human Services her execution of Wake County Human Services’ “customs” and/or “policies” were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, acting personally and individually she did act under the authority or color of state law when she acted in concert with other local officials, including but not limited to, other Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Ginger Gialanella, Wake County Human Services Clinician, MS Licensed Marriage and Family Therapist and being hereby named in both her individual and official capacities, is an individual and a resident of this jurisdictional district, is a county employee and was at all times material, pertinent and relevant hereto, employed by Wake County Human Services in Wake County, North Carolina. Current mailing address is; c/o Wake County Human Services, 10 Sunnybrook Road, Raleigh, NC 27610. 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 Clinician, MS Licensed Marriage and Family Therapist for Wake County Human Services her execution of Wake County Human Services’ “customs” and/or “policies” were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, acting personally and individually she did act under the authority or color of state law when she acted in concert with other local officials, including but not limited to, other Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Jamie Sessoms, Wake County Human Services Clinician, Licensed Clinical Social Worker and being hereby named in both her individual and official capacities, is an individual and a resident of this jurisdictional district, is a county employee and was at all times material, pertinent and relevant hereto, employed by Wake County Human Services in Wake County, North Carolina. Current mailing address is; c/o Wake County Human Services, 10 Sunnybrook Road, Raleigh, NC 27610. 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 Clinician, Licensed Clinical Social Worker for Wake County Human Services her execution of Wake County Human Services’ “customs” and/or “policies” were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, acting personally and individually she did act under the authority or color of state law when she acted in concert with other local officials, including but not limited to, other Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Laurie Scholl, Wake County Human Services Clinician, Licensed Clinical Social Worker and being hereby named in both her individual and official capacities, is an individual and a resident of this jurisdictional district, is a county employee and was at all times material, pertinent and relevant hereto, employed by Wake County Human Services in Wake County, North Carolina. Current mailing address is; c/o Wake County Human Services, 10 Sunnybrook Road, Raleigh, NC 27610. 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 Clinician, Licensed Clinical Social Worker for Wake County Human Services her execution of Wake County Human Services’ “customs” and/or “policies” were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, acting personally and individually she did act under the authority or color of state law when she acted in concert with other local officials, including but not limited to, other Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Onslow County Department of social Services (OCDSS), is located in, licensed and doing business in Onslow County, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; 1915 Onslow Drive Ext, Jacksonville, NC 28540. The Defendant was in fact at all times, operating and acting under the authority or color of state law at the time these claims occurred in that its “customs” and/or “policies” were the moving force behind the unconstitutional acts of its agents against the Plaintiffs in effecting the deprivation of rights.

Defendant Onslow County Child Support Enforcement, is located in, licensed and doing business in Onslow County, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; 3886 Henderson Drive Ext, Jacksonville, NC 28546. The Defendant was in fact at all times, operating and acting under the authority or color of state law at the time these claims occurred in that its “customs” and/or “policies” were the moving force behind the unconstitutional acts of its agents against the Plaintiffs in effecting the deprivation of rights.

Defendant Policy Studies, Inc., is located in, licensed and doing business in Onslow County, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; 1515 Wynkoop Street, STE 400, Denver, CO 80202. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that while in its official capacity as the contracted child support collections agent for Onslow County Department of Social Services its execution of Onslow County Department of Social Services’ “customs” and/or “policies” were the moving force behind the unconstitutional acts of its agents against the Plaintiffs in effecting the deprivation of rights.

Defendant the North Carolina Administrative office of the Courts, a state agency doing business in The State of North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; PO Box 2448, Raleigh, NC 27602-2448. The Defendant was in fact at all times, operating and acting under the authority or color of state law at the time these claims occurred in that its “customs” and/or “policies” were the moving force behind the unconstitutional acts of its agents against the Plaintiffs in effecting the deprivation of rights.

Defendant North Carolina Judicial Standards Commission, a state agency doing business in The State of North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; PO Box 1122, Raleigh, NC 27602. The Defendant was in fact at all times, operating and acting under the authority or color of state law at the time these claims occurred in that its “customs” and/or “policies” were the moving force behind the unconstitutional acts of its agents against the Plaintiffs in effecting the deprivation of rights.

Defendant Robert Rader, Wake County Chief District Court Judge and being hereby named in both his individual and official capacities, is an individual and a resident of this jurisdictional district, is the Chief District Court Judge in the Tenth Judicial District, Wake County in the State of North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; PO Box 351, 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 his official capacity as the Chief District Court Judge his implementation and execution of, The Tenth Judicial District Family Court Rules for Domestic Court’s “customs” and/or “policies” and his execution of the “customs” and/or “policies” of the North Carolina Administrative office of the Courts were the moving force behind his unconstitutional acts, and that personally, his individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). His judicial immunity is defeated when, “though judicial in nature,” his acts are “taken in complete absence of jurisdiction,” Mireles v. Waco (1991). In addition, he did act under the authority or color of state law when he acted in concert with local officials, including but not limited to, other Defendant Judges named herein, and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Eric Chasse, Wake County District Court Judge and being hereby named in both his individual and official capacities, is an individual and a resident of this jurisdictional district, is a District Court Judge in the Tenth Judicial District, Wake County in the State of North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; PO Box 351, 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 his official capacity as the District Court Judge in case number 10JA172-178 his execution of, The Tenth Judicial District Family Court Rules for Domestic Court’s “customs” and/or “policies” and his execution of the “customs” and/or “policies” of the North Carolina Administrative office of the Courts were the moving force behind his unconstitutional acts, and that personally, his individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). His judicial immunity is defeated when, “though judicial in nature,” his acts are “taken in complete absence of jurisdiction,” Mireles v. Waco (1991). In addition, he did act under the authority or color of state law when he acted in concert with local officials, including but not limited to, Wake County Human Services social workers, their supervisors and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Jane Gray, Wake County District Court Judge and being hereby named in both her individual and official capacities, is an individual and a resident of this jurisdictional district, is a District Court Judge in the Tenth Judicial District, Wake County in the State of North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; PO Box 351, 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 the District Court Judge in case numbers 10JA 172-178 her execution of, The Tenth Judicial District Family Court Rules for Domestic Court’s “customs” and/or “policies” and her execution of the “customs” and/or “policies” of the North Carolina Administrative office of the Courts were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). Her judicial immunity is defeated when, “though judicial in nature,” her acts are “taken in complete absence of jurisdiction,” Mireles v. Waco (1991). In addition, she did act under the authority or color of state law when she acted in concert with local officials, including but not limited to, Wake County Human Services social workers, their supervisors and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Lori Christian, Wake County District Court Judge and being hereby named in both her individual and official capacities, is an individual and a resident of this jurisdictional district, is a District Court Judge in the Tenth Judicial District, Wake County in the State of North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; PO Box 351, 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 the District Court Judge in case numbers 10CVD7386, 10CVD7539 and 10CVD5477 her execution of, The Tenth Judicial District Family Court Rules for Domestic Court’s “customs” and/or “policies” and her execution of the “customs” and/or “policies” of the North Carolina Administrative office of the Courts were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). Her judicial immunity is defeated when, “though judicial in nature,” her acts are “taken in complete absence of jurisdiction,” Mireles v. Waco (1991). Judge Christian’s acts also raise the questions as to criminal acts under 18 U.S.C.A § 242, for willful deprivation of constitutional rights. In addition, she did act under the authority or color of state law when she acted in concert with local officials, including but not limited to, Wake County Human Services social workers, their supervisors and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Kris Bailey, Wake County District Court Judge and being hereby named in both his individual and official capacities, is an individual and a resident of this jurisdictional district, is a District Court Judge in the Tenth Judicial District, Wake County in the State of North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; PO Box 351, 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 his official capacity as the District Court Judge in case number 10CVD7539 his execution of, The Tenth Judicial District Family Court Rules for Domestic Court’s “customs” and/or “policies” and his execution of the “customs” and/or “policies” of the North Carolina Administrative office of the Courts were the moving force behind his unconstitutional acts, and that personally, his individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). His judicial immunity is defeated when, “though judicial in nature,” his acts are “taken in complete absence of jurisdiction,” Mireles v. Waco (1991). In addition, he did act under the authority or color of state law when he acted in concert with local officials, including but not limited to, Wake County Human Services social workers, their supervisors and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Monica Bousman, Wake County District Court Judge and being hereby named in both her individual and official capacities, is an individual and a resident of this jurisdictional district, is a District Court Judge in the Tenth Judicial District, Wake County in the State of North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; PO Box 351, 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 the District Court Judge in case number 10JA 172-178 and 10CVD7386 her execution of, The Tenth Judicial District Family Court Rules for Domestic Court’s “customs” and/or “policies” and her execution of the “customs” and/or “policies” of the North Carolina Administrative office of the Courts were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). Her judicial immunity is defeated when, “though judicial in nature,” her acts were “taken in complete absence of jurisdiction,” Mireles v. Waco (1991). In addition, she did act under the authority or color of state law when she acted in concert with local officials, including but not limited to, Wake County Human Services social workers, their supervisors, county attorneys, court appointed attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Wendy Kirwan, Family Court Case Coordinator and being hereby named in both her individual and official capacities, is an individual and a resident of this jurisdictional district, is a Family Court Case Coordinator in the Tenth Judicial District and was at all times material, pertinent and relevant hereto. Current mailing address is; PO Box 351, 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 Family Court Case Coordinator her execution of The Tenth Judicial District Family Court Rules for Domestic Court’s “customs” and/or “policies” and her execution of the “customs” and/or “policies” of the North Carolina Administrative office of the Courts were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, she did act under the authority or color of state law when she acted in concert with local officials, including but not limited to, Defendant Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Steve Combs, Private Attorney and being hereby named in both his individual and official capacities is an individual and a resident of this jurisdictional district, was initially a court appointed attorney appointed by the Wake County District Court Judge, later hired privately by Plaintiff Ronald Reale in case number 10JA 172-178 and 10CVD7386 in Wake County, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; 1003 High House Road, Suite 106, Cary, NC 27513. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that while in his official capacity as a court appointed attorney (public defender) his execution of, The Tenth Judicial District Family Court Rules for Domestic Court’s “customs” and/or “policies” and his execution of the “customs” and/or “policies” of the North Carolina Administrative office of the Courts were the moving force behind his unconstitutional acts and he was in fact, acting under the authority or color of state law at the time these claims occurred. He did act personally and individually under the authority or color of state law when he acted in concert with local officials, including but not limited to, Defendant Wake County Guardian ad Litem administrators, Wake County Human Services 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 (Ronald Reale) was never so protected at common law, Tower v. Glover (1984).

Defendant Rick Croutharmel, Private Attorney and being hereby named in both his individual and official capacities is an individual and a resident of this jurisdictional district, is a court appointed attorney for Plaintiff Debra Reale and was appointed by the Wake County District Court Judge in case number 10JA 172-178 and 10CVD7386 in Wake County, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; 303-200 Blake Street, Suite 211, Raleigh, NC 27601. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that while in his official capacity as a court appointed attorney (public defender) his execution of, The Tenth Judicial District Family Court Rules for Domestic Court’s “customs” and/or “policies” and his execution of the “customs” and/or “policies” of the North Carolina Administrative office of the Courts were the moving force behind his unconstitutional acts and he was in fact, acting under the authority or color of state law at the time these claims occurred. He did act personally and individually under the authority or color of state law when he acted in concert with local officials, including but not limited to, Defendant Wake County Guardian ad Litem administrators, Wake County Human Services 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 (Debra Reale) was never so protected at common law, Tower v. Glover (1984).

Defendant Albert Singer, Assistant County Attorney and being herby named in both his individual and official capacities is an individual and a resident of this jurisdictional district is a county attorney for Wake County, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; c/o The Wake County District Attorney’s Office, PO Box 550, 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 his official capacity as the County Attorney for Wake County his execution of, The Tenth Judicial District Family Court Rules for Domestic Court’s “customs” and/or “policies” and his execution of the “customs” and/or “policies” of the North Carolina Administrative office of the Courts were the moving force behind his unconstitutional acts and was in fact, acting under the authority or color of state law at the time these claims occurred in that he often acted “out of court” personally and individually in an investigatory capacity. The Supreme Court reasoned that “out of court” activities of the prosecutor did not implicate judicial functions as immediately as the decision to prosecute (or the presentation of a case in court) bolstering its conclusion that historically, absolute immunity did not accompany such administrative or investigative functions of the prosecutor. Burns v. Reed (1991) and Kalina v. Fletcher (1997). In addition, he did act under the authority or color of state law when he acted in concert with local officials, including but not limited to, Defendant Wake County Guardian ad Litem administrators, Wake County Human Services social workers, their supervisors, and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Melinda Cope, Assistant County Attorney and being herby named in both her individual and official capacities is an individual and a resident of this jurisdictional district is a county attorney for Wake County, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; c/o The Wake County District Attorney’s Office, PO Box 550, 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 the County Attorney for Wake County her execution of, The Tenth Judicial District Family Court Rules for Domestic Court’s “customs” and/or “policies” and her execution of the “customs” and/or “policies” of the North Carolina Administrative office of the Courts were the moving force behind her unconstitutional acts and was in fact, acting under the authority or color of state law at the time these claims occurred. In addition, she did act under the authority or color of state law when she acted in concert with local officials, including but not limited to, Defendant Wake County Human Services social workers, their supervisors, and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant The Wake County Guardian ad Litem Program, is located in, licensed and doing business in Wake County, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; 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 its “customs” and/or “policies” and its execution of the “customs” and/or “policies” of the North Carolina Administrative office of the Courts were the moving force behind its unconstitutional acts against the Plaintiffs in effecting the deprivation of rights.

Defendant Naeimeh Livingston, Wake County Guardian ad Litem District Administrator and being hereby named in both her individual and official capacities, is an individual and a resident of this jurisdictional district, is the Wake County Guardian ad Litem District Administrator, 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 the Wake County Guardian ad Litem District Administrator her execution of The Wake County Guardian ad Litem Program’s “customs” and/or “policies” and her execution of the “customs” and/or “policies” of the North Carolina Administrative office of the Courts were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, she did act under the authority or color of state law when she acted in concert with local officials, including but not limited to, Defendant Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Margaret Hertzler, Wake County Guardian ad Litem Program Supervisor and being hereby named in both her individual and official capacities, is an individual and a resident of this jurisdictional district, is the Wake County Guardian ad Litem Program Supervisor, 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 the Wake County Guardian ad Litem Program Supervisor her execution of The Wake County Guardian ad Litem Program’s “customs” and/or “policies” and her execution of the “customs” and/or “policies” of the North Carolina Administrative office of the Courts were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, she did act under the authority or color of state law when she acted in concert with local officials, including but not limited to, Defendant Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Bacchus Carver, Wake County Guardian ad Litem and being hereby named in both his individual and official capacities, is an individual and a resident of this jurisdictional district, is a Guardian ad Litem community volunteer, appointed by a 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 his official capacity as a Guardian ad Litem for Wake County his execution of The Wake County Guardian ad Litem Program’s “customs” and/or “policies” and his execution of the “customs” and/or “policies” of the North Carolina Administrative office of the Courts were the moving force behind his unconstitutional acts, and that personally, his individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, he did act under the authority or color of state law when he acted in concert with local officials, including but not limited to, Defendant Wake County Guardian ad Litem administrators, Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Susan Vick, Attorney Advocate for the Wake County Guardian Ad Litem and 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” and her execution of the “customs” and/or “policies” of the North Carolina Administrative office of the Courts were the moving force behind her 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, Defendant Wake County Guardian ad Litem administrators, Wake County Human Services 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).

Defendant Mellonee Kennedy, Attorney Advocate for the Guardian Ad Litem and 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” and her execution of the “customs” and/or “policies” of the North Carolina Administrative office of the Courts were the moving force behind her 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, Defendant Wake County Guardian ad Litem administrators, Wake County Human Services 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).

Defendant Reginald O’Rourke, Attorney Advocate for the Wake County Guardian Ad Litem and being hereby named in both his 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 his 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” and his execution of the “customs” and/or “policies” of the North Carolina Administrative office of the Courts were the moving force behind his unconstitutional acts. In addition, as a court appointed attorney (public defender) he did act under the authority or color of state law when he acted in concert with local officials, including but not limited to, the Defendant Wake County Guardian ad Litem administrators, Wake County Human Services 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).

Defendant Nevada Department of Health and Human Services, a state agency doing business in The State of Nevada and was at all times material, pertinent and relevant hereto. Current mailing address is; 4126 Technology Way, Room 400, Carson City, NV 89706. The Defendant was in fact at all times, operating and acting under the authority or color of state law at the time these claims occurred in that its “customs” and/or “policies” were the moving force behind the unconstitutional acts of its agents, and in conspiring with other Defendants, including but not limited to Nevada DCFS, Child Haven and Wake County Human Services and its agents, against the Plaintiffs in effecting the deprivation of rights.

Defendant Nevada Department of Children and Family Services, a state agency doing business in The State of Nevada and was at all times material, pertinent and relevant hereto. Current mailing address is; 4126 Technology Way, 3^rd Floor, Carson City, NV 89706. The Defendant was in fact at all times, operating and acting under the authority or color of state law at the time these claims occurred in that its “customs” and/or “policies” were the moving force behind the unconstitutional acts of its agents, and in conspiring with other Defendants, including but not limited to Child Haven and Wake County Human Services and its agents, against the Plaintiffs in effecting the deprivation of rights.

Defendant Las Vegas Metro Police Department, is a law enforcement agency located in the State of Nevada and was at all times material, pertinent and relevant hereto. Current mailing address is; 3141 Sunrise Avenue, Las Vegas, NV 89101. The Defendant was in fact, acting under the authority or color of law at the time these claims occurred in that its “customs” and/or “policies” were the moving force behind the unconstitutional acts of its officers, and in conspiring with other Defendants, including but not limited to Child Haven and Wake County Human Services and its agents, against the Plaintiffs in effecting the deprivation of rights.

Defendant Child Haven, is located in, licensed and doing business in Clark County, Nevada and was at all times material, pertinent and relevant hereto. Current mailing address is; 701 North Pecos Road, Las Vegas, NV 89101. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that its “customs” and/or “policies” were the moving force behind the unconstitutional acts of its agents, and in conspiring with other Defendants, including but not limited to Las Vegas Metro Police Department and Wake County Human Services and its agents, against the Plaintiffs in effecting the deprivation of rights.

Defendant Wrenn House, is located in, licensed and doing business in Wake County, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; 706 Hillsborough Street, Suite 200, Raleigh, NC 27603. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that its “customs” and/or “policies” were the moving force behind the unconstitutional acts of its agents and in conspiring with other Defendants, including but not limited to, Wake County Human Services and its agents, against the Plaintiffs in effecting the deprivation of rights.

Defendant Wake House, is located in, licensed and doing business in Wake County, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; 2024 Noble Road, Raleigh, NC 27608. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that its “customs” and/or “policies” were the moving force behind the unconstitutional acts of its agents, and in conspiring with other Defendants, including but not limited to Wake County Human Services and its agents, against the Plaintiffs in effecting the deprivation of rights.

Defendant Kelli-Ann Reale, Private Actor and being hereby named personally, is an individual, is the complainant in two separate, fabricated Wake County Human Services Child Protective Services complaints in October, 2009 and January, 2010 and resides in Pittsburgh, Pennsylvania, and was at all times material, pertinent and relevant hereto. Current mailing address is; 308 Ashland Ave, Pittsburgh, PA 15228. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that as a Wake County Human Services Child Protective Services Complainant she did act personally and individually under the authority or color of state law when she acted in concert with local officials, including but not limited to, Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Timothy Griego, Private Actor and being hereby named personally, is an individual, is the natural father of minor Plaintiff T.R.B. and resides in Apple Valley, California and was at all times material, pertinent and relevant hereto. Current mailing address is; 16421 Apple Valley Rd., #3, Apple Valley, CA 92307. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that he did act personally and individually acted in concert with local officials, including but not limited to, Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Natasha Wilde-Brant, Foster Caregiver being hereby named personally, is an individual, was a foster caregiver for the seven minor children (herein Plaintiffs) in case number 10JA 172-178 in Wake County, North Carolina and currently resides in Onslow County, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; 12780 North B Street, El Mirage, AZ 85335. Last known mailing address is; c/o Wake County Human Services, 220 Swinburne Street, Raleigh, NC 27610. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that as a the current Foster Caregiver she did act personally and individually under the authority or color of state law when she acted in concert with local officials, including but not limited to, Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Gerard Anderberg, Foster Caregiver and being hereby named personally, is an individual, is the current foster caregiver for T.R.B. (herein plaintiff) in case number 10JA 172-178 in Wake County, North Carolina and currently resides in San Diego County, California and was at all times material, pertinent and relevant hereto. Current mailing address is; 1720 Redwing Street, San Marcos, CA 92078. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that as the current Foster Caregiver he did act personally and individually under the authority or color of state law when he acted in concert with local officials, including but not limited to, Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Rhonda Anderberg, Foster Caregiver and being hereby named personally, is an individual, is the current foster caregiver for T.R.B. (herein plaintiff) in case number 10JA 172-178 in Wake County, North Carolina and currently resides in San Diego County, California and was at all times material, pertinent and relevant hereto. Current mailing address is; 1720 Redwing Street, San Marcos, CA 92078. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that as the current Foster Caregiver she did act personally and individually under the authority or color of state law when she acted in concert with local officials, including but not limited to, Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Christopher Anderberg, Private Actor and being hereby named personally, is an individual, was a foster caregiver for the seven minor children (herein Plaintiffs) in case number 10JA 172-178 in Wake County, North Carolina and currently resides in San Diego County, California and was at all times material, pertinent and relevant hereto. Current mailing address is; 1720 Redwing Street, San Marcos, CA 92078. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that as a Foster Caregiver he did act personally and individually under the authority or color of state law when he acted in concert with local officials, including but not limited to, Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Robin Domingez, Foster Caregiver and being hereby named personally is an individual, was a foster caregiver for the seven minor children (herein Plaintiffs) in case number 10JA 172-178 and mother of Natasha Wilde sharing the same residence in Jacksonville, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; 12780 North B Street, El Mirage, AZ 85335. Last known mailing address is; 1633 Secret Garden Place, Salt Lake City, UT 84104. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that as a Foster Caregiver she did act personally and individually under the authority or color of state law when she acted in concert with local officials, including but not limited to, Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Alex Wisnoski, Foster Caregiver and being hereby named personally, is an individual, is the current foster caregiver for S.R.R. and J.R.R (herein plaintiffs) in case number 10JA 172-178 in Wake County, North Carolina and currently resides in Wake County, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; 120 Cullen Place, Garner, NC 27529. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that as the current Foster Caregiver he did act personally and individually under the authority or color of state law when he acted in concert with local officials, including but not limited to, Defendant Wake County Guardian ad Litem administrators, Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Saundra Wisnoski, Foster Caregiver and being hereby named personally, is an individual, is the current foster caregiver for S.R.R. and J.R.R (herein plaintiffs) in case number 10JA 172-178 in Wake County, North Carolina and currently resides in Wake County, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; 120 Cullen Place, Garner, NC 27529. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that as the current Foster Caregiver she did act personally and individually under the authority or color of state law when she acted in concert with local officials, including but not limited to, Defendant Wake County Guardian ad Litem administrators, Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant David Stonehouse, Foster Caregiver and being hereby named personally, is an individual, is the current foster caregiver for M.R.R. and B.R.R (herein plaintiffs) in case number 10JA 172-178 in Wake County, North Carolina and currently resides in Wake County, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; 4923 Oak Park Road, Raleigh, NC 27612. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that as the current Foster Caregiver he did act personally and individually under the authority or color of state law when he acted in concert with local officials, including but not limited to, Defendant Wake County Guardian ad Litem administrators, Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Amanda Stonehouse, Foster Caregiver and being hereby named personally, is an individual, is the current foster caregiver for M.R.R. and B.R.R (herein plaintiffs) in case number 10JA 172-178 in Wake County, North Carolina and currently resides in Wake County, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; 4923 Oak Park Road, Raleigh, NC 27612. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that as the current Foster Caregiver he did act personally and individually under the authority or color of state law when he acted in concert with local officials, including but not limited to, Defendant Wake County Guardian ad Litem administrators, Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Main Street Clinical Associates PA is a private agency, licensed and doing business in Durham and Wake County, North Carolina, a private practice group of licensed psychologists, clinical social workers, and board certified psychiatrists who provide comprehensive mental health services and was at all times material, pertinent and relevant hereto. Current mailing address is; 115 North Duke Street, Suite 1-B, Durham, NC 27701. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that its “customs” and/or “policies” were the moving force behind the unconstitutional acts of its agent Dr. Karin Yoch (Licensed Psychologist contracted by Wake County Human Services) against the Plaintiffs in effecting the deprivation of rights.

Defendant Karin Yoch, PhD, Licensed Psychologist and being hereby named in both her individual and official capacities, is an individual, is a contracted employee of Wake County Human Services, and is listed on staff at Main Street Clinical Associates PA in Durham, North Carolina also providing services in Wake County, North Carolina and at all times material, pertinent and relevant hereto. Current mailing address is; c/o Main Street Clinical Associates PA, 115 North Duke Street, Suite 1-B, Durham, NC 27701. 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 contracted licensed psychologist for Wake County human Services her execution of Wake County Human Services’ and Main Street Clinical Associates PA’s “customs” and/or “policies” were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, she did act under the authority or color of state law when she acted in concert with local officials, including but not limited to, Wake County Human Services social workers, their supervisors, county attorneys and others causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Carolina Psychological Health Services is a private agency licensed and doing business in Onslow County, North Carolina, is a private practice group of licensed clinical psychologists, psychiatrists, social workers and other master level clinicians who provide comprehensive mental health services and was at all times material, pertinent and relevant hereto. Current mailing address is; 1703 Country Club Road, Suite 204, Jacksonville, North Carolina 28546. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that its “customs” and/or “policies” were the moving force behind the unconstitutional acts of its agent Joyce Williams and others, against the Plaintiffs in effecting the deprivation of rights.

Defendant Joyce Williams, Licensed Professional Counselor and being hereby named in both her individual and official capacities, is an individual, is a contracted employee of Wake County Human Services, and is listed on staff at Carolina Psychological Health Services in Jacksonville, North Carolina also providing services to other Defendants in Wake County, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; c/o Carolina Psychological Health Services, 1703 Country Club Road, Suite 204, Jacksonville, North Carolina 28546. 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 contracted Licensed Professional Counselor for Wake County Human Services her execution of Wake County Human Services’ and Carolina Psychological Health Services’ “customs” and/or “policies” were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, she did act under the authority or color of state law when she acted in concert with local officials, including but not limited to, Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Discovery Counseling and Wellness PLLC is a private agency licensed and doing business in Wake County, North Carolina, is a private practice group of Licensed Professional Counselors and was at all times material, pertinent and relevant hereto. Current mailing address is; 110 Raleigh Street, Fuquay Varina, NC 27526. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that its “customs” and/or “policies” were the moving force behind the unconstitutional acts of its agent Michaele Worrix and others, against the Plaintiffs in effecting the deprivation of rights.

Defendant Michaele Worrix, Licensed Professional Counselor and being hereby named in both her individual and official capacities, is an individual, is a contracted employee of Wake County Human Services, and is listed on staff at Discovery Counseling and Wellness in Fuquay Varina, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; 110 Raleigh Street, Fuquay Varina, NC 27526. 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 contracted Licensed Professional Counselor for Wake County Human Services her execution of Wake County Human Services’ and Discovery Counseling and Wellness’ “customs” and/or “policies” were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, she did act under the authority or color of state law when she acted in concert with local officials, including but not limited to, Defendants Wake County Guardian ad Litem administrators, Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Institute for Family Centered Services is a private agency licensed and doing business in Wake County, North Carolina, is a private practice group of Licensed Professional Counselors and was at all times material, pertinent and relevant hereto. Current mailing address is; 3210 Skipwith Road, Suite B, Henrico, VA 23294. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that its “customs” and/or “policies” were the moving force behind the unconstitutional acts of its agents Brianne Smith, Philip Smith, Jennifer Bretz, and others, against the Plaintiffs in effecting the deprivation of rights.

Defendant Brianne Smith, Executive Director at Institute for Family Centered Services and being hereby named in both her individual and official capacities, is an individual, is a contracted employee of Wake County Human Services, and is listed on staff at Institute for Family Centered Services in Apex, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; 504 Wrennstone Court, Apex, NC 27539. 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 contracted agent for Wake County Human Services her execution of Wake County Human Services’ and the Institute for Family Centered Services’ “customs” and/or “policies” were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, she did act under the authority or color of state law when she acted in concert with local officials, including but not limited to, Defendants Wake County Guardian ad Litem administrators, Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Philip Smith, Contracted Agent at Institute for Family Centered Services and being hereby named in both his individual and official capacities, is an individual, is a contracted employee of Wake County Human Services, and is listed on staff at Institute for Family Centered Services in Apex, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; c/o Brianne Smith, 504 Wrennstone Court, Apex, NC 27539. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that while in his official capacity as a Contracted Agent for Wake County Human Services his execution of Wake County Human Services’ and the Institute for Family Centered Services’ “customs” and/or “policies” were the moving force behind his unconstitutional acts, and that personally, his individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, he did act under the authority or color of state law when he acted in concert with local officials, including but not limited to, Defendants Wake County Guardian ad Litem administrators, Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Jennifer Bretz, Contracted Agent at Institute for Family Centered Services and being hereby named in both her individual and official capacities, is an individual, is a contracted employee of Wake County Human Services, and is listed on staff at Institute for Family Centered Services in Apex, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; c/o Brianne Smith, 504 Wrennstone Court, Apex, NC 27539. 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 Contracted Agent for Wake County Human Services her execution of Wake County Human Services’ and the Institute for Family Centered Services’ “customs” and/or “policies” were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, she did act under the authority or color of state law when she acted in concert with local officials, including but not limited to, Defendants Wake County Guardian ad Litem administrators, Wake County Human Services social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Commissioner John Vineyard, Riverside County California Commissioner and being hereby named in both his individual and official capacities, is a County Commissioner in Riverside County, in the State of California and was at all times material, pertinent and relevant hereto. Current mailing address is; c/o Riverside Historic Courthouse, 4050 Main Street, Riverside, CA 92501. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that while in his official capacity as the Riverside County Commissioner in case number SWD020638 his execution of, The Riverside County California “customs” and/or “policies” were the moving force behind his unconstitutional acts, and that personally, his individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). His judicial immunity is defeated when, “though judicial in nature,” his acts are “taken in complete absence of jurisdiction,” Mireles v. Waco (1991).

Defendant Riverside County Department of Public Social Services, is located in, licensed and doing business in Riverside County, California and was at all times material, pertinent and relevant hereto. Current mailing address is; Riverside County Clerk of the Board, County Administrative Center, 4080 Lemon Street, First Floor, Riverside, CA 92501. The Defendant was in fact at all times, operating and acting under the authority or color of state law at the time these claims occurred in that its “customs” and/or “policies” were the moving force behind the unconstitutional acts of its agents including but not limited to Defendants Courtney Barzandeh (social worker) and Bruce Rudberg (social worker), against the Plaintiffs in effecting the deprivation of rights.

Defendant Courtney Barzandeh, Social Worker and being hereby named in both her individual and official capacities, is an individual and is a Riverside County, California employee and was at all times material, pertinent and relevant hereto, employed by Riverside County Department of Public Social Services in Riverside, California. Current mailing address is; Riverside County Clerk of the Board, County Administrative Center, 4080 Lemon Street, First Floor, Riverside, CA 92501. 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 social worker for Riverside County Department of Public Social Services her execution of Riverside County Department of Public Social Services’ “customs” and/or “policies” were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, acting personally and individually she did act under the authority or color of state law when she acted in concert with other local officials, including but not limited to, other Riverside County Department of Public Social Services social workers, their supervisors, Wake County Human Services’ social workers and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

Defendant Bruce Rudberg, Social Worker Supervisor and being hereby named in both his individual and official capacities, is an individual and is a Riverside County, California employee and was at all times material, pertinent and relevant hereto, employed by Riverside County Department of Public Social Services in Riverside, California. Current mailing address is; Riverside County Clerk of the Board, County Administrative Center, 4080 Lemon Street, First Floor, Riverside, CA 92501. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that while in his official capacity as a social worker for Riverside County Department of Public Social Services his execution of Riverside County Department of Public Social Services’ “customs” and/or “policies” were the moving force behind his unconstitutional acts, and that personally, his individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, acting personally and individually he did act under the authority or color of state law when he acted in concert with other local officials, including but not limited to, other Riverside County Department of Public Social Services social workers, their supervisors, Wake County Human Services’ social workers and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).

The Defendants and each of them acted individually and jointly under color of state law to deprive and in conspiring to deprive the Plaintiffs of their civil rights. Because the Defendants acted knowingly, recklessly and in disregard of well-established law, agency guidelines and regulations, with no objectively reasonable basis for their actions, they do not have qualified immunity from damages under the standards set forth by the United States Supreme Court, the United States Fourth Circuit Court of Appeals, and by this Court. Judicial immunity is defeated with respect to the FOUR Defendant District Court Judges when, “though judicial in nature,” their acts were “taken in complete absence of jurisdiction,” Mireles v. Waco (1991). Attorney immunity with respect to the Defendant court appointed attorneys is defeated since attorney immunity for intentional harm to one’s client (Plaintiffs – ALL) was never so protected at common law, Tower v. Glover (1984).

CLICK THE FOLLOWING LINK FOR THE ENTIRE BODY OF THE

“CIVIL ACTION”

Reale Family Civil Rights Complaint (Amended 9/17/2012); Title 42, Section 1983 U.S.C.

CONCLUSION

WHEREFORE, based on all of the foregoing, Plaintiffs respectfully request the Court enter judgment in favor of Plaintiffs request for relief in the form of an order requiring the immediate return of the Plaintiffs’ seven minor children to the full legal and physical custody of the Plaintiff parents, and against Defendants, jointly and severally in an amount that will fully and fairly compensate Plaintiffs for all injuries suffered as a result of Defendants’ illegal actions as set forth more fully herein, including actual, compensatory, coincidental, incidental, treble and punitive damages; all in an amount that while not currently ascertainable to an exact degree will be determined at trial of this matter, and upon information and belief will exceed twenty million dollars; along with interest thereon at the highest rate allowable by law and all legal fees and costs incurred in bringing this action as well as all other relief the Court deems just and equitable in the circumstances.

JURY DEMAND

COME NOW the Plaintiffs in the above-captioned cause of action and hereby demand trial by jury in each of the foregoing causes so triable.

Respectfully submitted this ____ day of September, 2012

RONALD REALE and DEBRA REALE individuals and as next friends of T.R.B., S.R.R., M.R.R., H.M.R., S.M.R., J.R.R., B.R.R., minor children.

13 Responses to THE FEDERAL CASE

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Sarah says:

December 3, 2011 at 8:22 pm

Congradulations Mr. & Mrs. Reale on beating a corrupt system
I have been reading your story and was disgusted at how the system hurt your family it is sad to say but even still to this day the system is corrupt in every state and most in cases where the parents have not neglected their children or abused them they are still taken in to custody by the state and either forced into foster care or placed in adoption. I no or one man who fought for his child and completed all taskes given to him and decided him self to do more. He also became a certified foster care worker and is also able to be an adoptive parent but the system in ct still said he the father is high risk of getting into trouble with the law. That was 4 years ago they closed the case and placed his son then of 5 yrs of age up for adoption This father yes did have a couple of arrest in his life time and even one judge directed then to not bring up his arrest record again because he did his time. So by the end of the case that judge was not in office for the case and another judge presided And he lost his child in the state of ct
It is so over look in the system that yes these workers are just out to make money how do they have the right to say they no best or that they love our children more. They don’t and guide lines Need to be set or this system will keep on commiting murder yes murder by way of killing some people’s will to live by leaving parents broken for sometimes no accusations at all just because they want to. So to see your family win it may give hope to those parents who are still fighting for their kids today. Thank you for sharing your story

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Let's Get Honest says:

February 21, 2012 at 11:54 am

Mr. Reale —
A person who runs a large message forum board in Pennsylvania to expose court (and other) corruption forwarded me your email. MANY parts of it I can identify with, although my case is different. I hear your outrage, but am interested to read the federal complaint — which is coming up blank (as are several other links). Can you email me, or respond here, with an “html” which I could post in to read.

I do not want to post identifying traits here, but because of my having studied this field for years (I lost kids overnight, improperly, and without remedy also) and in several states — particularly our nicely corrupt California (San Diego & Riverside County are home to many corrupt cases) — perhaps there is something I could point you to.

In reading your website, I am going to skip over the inflammatory material, consider hearsay anything which looks like hearsay (i.e., no supporting documents posted), however credible it sounds, and see if I can point to any leverage that may help you and wife. Also helpful to know that it’s not common and (assuming DV was false allegations, which I’m picking up on), the “crimes” you have committed include exercising your right to homeschool (which provides competition for that monopoly), and having 7 wonderful kids that the state didn’t have its hands on.

My case involved real, and nearly lethal domestic violence, and the setup for such cases includes the pingpong — one is let out with a restraining order, but then bounced back in through family court. Family courts are business franchises, only funded with tax dollars.

They are NOT run by the VAWA industry, but by a parallel and equally large “reunification”-theory, i.e., fatherhood and marriage promotion. Whenever someone mentions VAWA with anger, I know they are failing to mention the equally large Healthy Marriage/Responsible Fatherhood industry, which diverts money from TANF block grants to states (i.e., welfare/child support) to programming. See federal database at http://TAGGS.hhs.gov These have created the kangaroo courts you protest — they talk about out-come based results to perpetuate the grants, etc. (See my blog, esp. posts from January 2011).

If you think you have it rough — and you do — please study the “Godboldo” case from Wayne County Michigan, which I learned about yesterday, where a single, African-American mother with a disabled child stood off CPS with SWAT Team home invasion, apparently with TANKS too! They got (and drugged) her teenaged daughter; she’d turned down Risperdal, which was her “crime.” Charged with felony, daughter put in an institution, facilitated by a family court judge and under invalid orders. She finally got her daughter back, only recently and got felony charges dropped, with community support and reporting. The prosecutor — not having real crime to prosecute in the area? is appealing. In this process, her separated husband was also grilled on the stand, and stood by her; it’s all in the record.

Some details here:
Scranton (PA) Political Times/Grand Jury Investigating (local GAL)? -posts linking to Wayne County, MI case. Excellent reporting by Voice of Detroit connected the dots to clinical trials of drugs enabled by local “community mental health” or “child family center” type outfits.

Our court case was prolonged over 10 years, and I experienced many of the same violations of rules of court, laws (my case had an UNprosecuted felony child-stealing act), and contempt of court issues, judges giving testimony, judges cross-examining when it was my privilege to do so, unnecessary extra court-appointed personnel in case, crooked court-appointed mediators and such. Much of this is enabled by the 1996 switch from “AFDC” to block grants to states for welfare — and the loopholes for crooks and extortioners (working through courts and gov’t agencies) this enables.

Please don’t characterize all DV issues as false allegations, or minimize them. This is a serious issue, which I know firsthand, and religious families no better than agnostic in that matter. It’s about control and domination.

I also believe you’d enjoy the site JAIL4judges.org and it’d show you why judicial complaint commissions are a whitewash as intended.

I hope things work out. If you are willing to send or post the html for the civil complaint, and if I have anything to offer that may provide some leverage, I will post. However, it’d be most helpful to post a bulleted outline (versus narrative) of case actions, if expecting others to help (particularly for free). We are all overwhelmed with this, and the easier it is to read, the better (not that my blog illustrates this).

Also, if you are an executive director of “Exposing the Record” and collecting donations, are you registered as a corp. or nonprofit in NC? Recommended…. and from what I understand, that’s the law. Check out the registrations of any organizations among the 32 defendants in the lawsuit, if have not yet. (See my blog).

It’s hard while you are fighting your own case to see the bigger picture, but this is where remedies are likely to show up. I couldn’t see it til I’d lost everything, including all contact with children AND my work life.

You have a narrative of being handcuffed and led out of the courtroom straight to the ATM to give money to the court. It’s not clear whether this was for “bail” or “child support” or what — however it’d be better to scan in that transcript than relate yourself. To all outsiders, it’s hearsay. If your wife is completely on the same page, has she put up a blog also, or been ordered not to? That would also lend credibility, which might affect support from strangers and others. Calling her sister “mentally deranged” doesn’t, whether or not it’s true.

Looking forward to a response.

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- My Kids Dad says:
  
  February 21, 2012 at 12:10 pm
  
  Sorry about the links. I will update the link to the Federal Action (it has changed since I originally posted). Let me know what other specific docs are BLANK and I will address those too. Ron
  
  Reply
Pamela McClarnon says:

September 18, 2012 at 1:38 pm

Do you still live here in NC. And if so please get in touch with me.
Thank you ! Pamela

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Rebecca Dye says:

October 5, 2012 at 4:33 pm

Ron,

Will be also filing a civil rights constitutional deprivation suit, since the courts through their so called elected servants have acted under color of law and without any jurisdiction to state that DSS does not allow my son to have any contact with anyone or to call since he walked away and is competent being held by aggravated felony kidnapping. Time to get the show on the air. IT’S SHOW TIME.

If anyone knows of an attorney who would, as pro bono, and an honest attorney with backbone to fight corruption, as their is no litigation to be heard and I have the certified files needed to send to them, file a writ of prohibition, a writ of supersedeas and a temporary supersedeas order to stay the falsified criminal action and three years probation in excess of the law, please let me know at my email, catwomandye@gmail.com or call me at 704-433-0601.

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takeresponsibility says:

February 15, 2013 at 1:56 pm

What happened to your law suit. You were late on your response and tried to lie about it. It is being thrown out, it needs to be. Are you really trying to make people believe that all of these people got together against you and your family, from the governor on down. You should really admit your fault in all of this and stop blaming everyone else. You did it and you know it. You are not an expert on any of these matters. You are not even close to being an expert in this field. I hear that sam club has a sale on aluminium foil. You need to buy by the truckload.

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- My Kids Dad says:
  
  February 23, 2013 at 8:44 am
  
  Which Lawsuit are you referring to. We have one pending with 9 Plaintiffs (My wife and I, along with our 7 children as Plaintiffs) against 73 Defendants, another similar suit against 36 so-called professionals (therapists, social workers, their insurance carriers, Etc.) for mal-practice and other related charges seeking damages and the forfeiture of their license to practice in their field (will be completed, filed and served very soon), and a Qui Tam (whistle-blower) action against the State of North Carolina and other County Governments and agencies for FRAUD (receiving Federal Funds fraudulently from the Federal Government – Title IV Funds), also to be completed, filed and served very soon?
  
  Are you a friend of the Judge? You make it seem as if you have an inside track on these matters. I’ll have my investigators look into it. I’m sure you’re just spouting off more rhetoric but I’m happy to find out. Because the last I checked, the Federal District Court Judge (James Dever III, in this case) must make the final decision on all matters pertaining to our Federal Action pertaining to Section 1983 for Deprivation of rights.
  
  To clarify, the initial filing of the Federal Action for Deprivation of Rights does not allege that “all these people got together against … our family,” but rather alleges that each of the individuals at some point and time, CONSPIRED with Wake County Human Services, aka CPS (and others), to deprive our family of our rights under the Constitution. That’s as simple as it gets. Yes, this includes the Governor of the State as she has certain direct responsibilities (appointing Judges, State Budge allocation for the funds in question, and many other duties), and because she was notified of the alleged acts of deprivation and did NOTHING (did not even look into it). Our Federal Action does not allege that I am an expert in any field as you seem to declare in opposition more than once in your comments.
  
  Your comment declares “you did it and you know it.” I did what? First of all the Fraudulent Abuse, Neglect, and Dependency case in Wake County (which is what brings rise to our Federal Action) was filed against both my wife and I. Second, the adjudication was for NEGLECT, albeit UNSUBSTANTIATED. there was NEVER any SUBSTANTIATED or even ALLEGED ABUSE!!! So, based on your comments in totality I assume that is your assertion (that I abused my children). Well, try again. You see this is another area where you so ignorantly expose yourself and your TRUE agenda. Since I know who you are, and since I know you already know the facts of this case, I also know your agenda with these comments is to “react” EMOTIONALLY to our family’s own pursuit of justice. In a nut shell, you do not like the website, you do not like my own personal comments, you do not like the fact that I ran for office last term (and that I will run again), that I have set out to bring this entire system to it’s knees (OK, a bit of rhetoric of my own), and most of all THAT OUR FAMILY WILL NOT JUST LIE DOWN AND TAKE IT, AND THAT WE WON’T JUST TUCK OUR TAILS BETWEEN OUR LEGS AND RUN…
  
  I know this goes without saying, but you are PATHETIC! FYI, since I know you have my number (it has not changed) I will be happy to discuss with you anytime by phone if you like. Or you can keep coming to this site like the imbecile you are. Think about what you are doing for a second… Who do you think comes to this site? The answer is, people like me who are under attack by the same corrupt system. You are just feeding (more accurately, proving my points) the rage in most of the folks who visit this site and other sites like this one. OK with me. In fact, I should say thank you!
  
  Happy trails in North Carolina, Oregon, or wherever you may find yourself this week…
  
  Reply
- Jason Shupe says:
  
  May 6, 2013 at 10:55 am
  
  Maybe you should look at your own heading. “takeresponsibility” That’s what you need to do. I have had only a little interaction with this fellow devil dog and from what we have talked about he has gone through alot of what i have gone through. I too was falsly accused found to be innocent but the state of North Caroline DSS had no problems as 3 judges put it in a court order ” kidnapped” my 2 children. is that simple enough for you? KIDNAPPED!!!! put them in foster care for over 2 years and even when a judge would say return the kids they would and the iceing on the cake is they came after me and my wife for child support. so before you rant and rave you liberal moron go vote for your dictator again ok. There are changes comming so that families get the rights to be a family and legal process is upheald. The stories you read on here are true and accurate. you want proof come at me bro i dare you. I have had social workers put in jail, i have had social workers DEPORTED yes deported. I support ron and his family 1,000,000,000% and am on the same track as them. I would say i could just make a phone call and have your kids taken away from you for years but i wont come down to your hippie peace loving trash way of life. RON FOR PRESIDENT!!!!!!! Semper Fi
  
  Reply
Kevin Kinney says:

February 24, 2013 at 12:02 pm

To all that read this,

This corruption in our courts and agencies that act in the “best interest of our children”, have a agenda to destroy families. Families are the wealth of our nation and if your keeping up on current events, these courts and agencies are destroying themselves. Tax dollars drive this corrupt system and it is broke!
If the counties and the states want to rely on our federal government for funding, good luck. Our federal government is destroyed financially and is afraid to tell its own citizens that we already went over the “fiscal cliff”. We will see this very soon.
In my county, Contra Costa, 6 judges were laid off in December along with some 30 staff positions, 3 courts were closed all due to budgetary reasons. The game is over people, and the system is caving in on itself!
I am glad there are people like Ron and Debra to help nudge these corrupt judges, social workers and the whole support team of injustice over the cliff. Most people wouldn’t have the ability and perseverance to expose the truth of this evil which exists in our communities. I respect you!
This system will end itself I assure you in time!
Good luck and never give up!

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- Let's Get Honest says:
  
  February 24, 2013 at 6:27 pm
  
  I looked some of this up. As you know there has been a lot of outcry over the court closures overall.
  
  This San Diego article shows they didn’t scrub the car allowance of over $574/month for judges (San Diego) and $250 (Contra Costa).
  Judges Keep Car Perks: Despite enormous cutbacks, Superior Court maintains over $1 million in vehicle allowances
  In the switch (1997? coinciding with welfare reform) from having states not counties pay the judges, some counties (Los Angeles is another one) ended up continuing to pay their judges perks, which makes a difference, evidently when going up against the county in any action a Judge is going to rule on… Conflict of interest much?):
  
  The California budget crisis has trickled down to the local justice level, with the San Diego County court looking to make up a $33-million shortfall in what had been a $190-million budget. The court was ordered to drain its rainy-day reserves—roughly $22 million—leaving $11 million left to slice in the coming fiscal year, with even bigger cuts predicted in the next cycles.
  
  The talk is all CUTS. That’s about cash flow; what they don’t talk about what’s sitting off-budget in all the other funds the public is not supposed to think about, so they can be horsewhipped into service cuts and tax increases…
  
  As fall arrives, the court has begun shutting down outlying courtrooms, shortening hours, laying off some employees and furloughing others. // But the Superior Court did not cut one line item: nearly $1 million per year in transportation allowances set aside for judges and executive managers. // San Diego judges each receive $572 per month ($6,864 annually) in car stipends, while the presiding judge, assistant presiding judge and supervising judges each collect $674 per month ($8,088 annually). // Between the 126 current judges, that’s $903,427 per year in vehicle allowances. Nine administrators collected a combined $59,472 per year, bringing the figure to $962,899. Another $8,281 was reimbursed for out-of-county travel. // The 24-year-old practice is particular to San Diego County as a carryover from when the county government paid for the courts and the benefit was tied to the Board of Supervisors’ compensation package. Now, the state funds the court, and there’s no mandate from Sacramento to provide these vehicle allowances.
  
  Also note about who determines such budgets:
  
  Superior Court judge salaries— $178,789 per year—are protected by the state Constitution, and the number of judges is set by the state Legislature. They can’t be laid off, furloughed or have their salaries cut. The judges also control the budgeting process at the county level.
  
  The budget-reduction plan for the next two years, according to a Superior Court spokesperson, was developed by an ad hoc budget committee, which was then approved by the court’s executive committee. Both committees are made up of judges.
  
  Closing down courtrooms means more centralization, which means whoever’s presiding judge (etc.) has more power. Then again, why’d they build so many courtrooms to start with? Watch where the real estate goes, and at what price. Same deal I’m sure in North Carolina. I’m telling ya’, Mr. Neale, want some clout, start looking up these things in re: your case. they don’t like exposure. I’ve been exposing such things (or similar) for four years in California…. The public needs to get on the stick about this. That car allowance could’ve fed a few children.
  
  Reply
Let's Get Honest says:

February 24, 2013 at 1:50 pm

Kevin — we are in the same county. Let’s talk. (are you a real estate agent, I saw one listed)….

I see I posted about a year ago (above), however, also twice yesterday and today.

Listing of 2008 Contra Costa County Employees is huge. This County would have more sales and income tax from me in the past several years if they had done something when my children were stolen, and a little more concerned about enforcing child support (father in another county, so that’s hardly cutting down on the local income).

There’s an incentive to simply divert money from private hands into programming, in my opinion. The system isn’t broke — just individuals. There’s plenty of government income around, however, they keep most of the wealth off the “budget” section.

What Carl Herman here is pointing out as to Calif. in general is true of all government entities — they all have CAFRs which conceal where the wealth is. This wealth came from prior public investment to accumulate the assets, which then are invested to produce returns — which say in government control for the most part.

http://www.washingtonsblog.com/2013/01/state-school-budget-cuts-100-funding-if-cafr-billions-trillions-disclosed.html.

There’s massive coverup of this, and of course I’m offended. I’ve been forced three times back onto welfare/begging from the constant pressure put on the public to think we are collectively broke. We may be as individuals — but our states, counties, and school districts are not, neither is “The United States of America.” The bankrupcty is of understanding economics. We can change that by starting our own learning curve.

If the only source of income is jobs (or child support), then those who have other soruces of income (assets that put off enough to live on, or who know how to invest, buy & sell businesses and property etc.) collectively, will run the place. Right now, that type of private equity (including from “philanthropy,” i.e., privately controlled but astoundingly wealth foundations) is actually driving government, which is going to listen to them, not us. Please read my lips: Even if we boycotted paying taxes (which i’m not recommending), there’d still be enough to keep operations going and these operations obviously still include trafficking our kids, and the prison system, etc.
_ _ _ _
I do hope to hear from you, post a comment on my blog or something, I’m local; would you like to talk about any of this? I didn’t know Contra Costa was layinug off judges and closing courtrooms, but then again, I’ve not had a good experience in either court, or with law enforcement, in this county since I moved here a decade ago. Primarily it’s been an experience of consistent, and dramatic losses which couldn’t have otherwise occurred — without the courts, and without unenforceable court orders.

Reply
Fran Lucas says:

May 12, 2013 at 8:43 pm

Can u email a copy of your whistleblower case? And other court papers filed
In your lawsuit? Thank you.
I too live in NC, Charlotte. Any meetings going on concerning
These crimes against humanity and our families?

Reply

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