JILL GREEN, SOCIAL WORKER, WAKE COUNTY HUMAN SERVICES
Defendant Jill Green, Social Worker 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 WCHS 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 WCHS social workers, their supervisors, county attorneys and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).
My Family’s first contact with Jill Green came during the first “surprise” visit to our home on October 15, 2009 and was very pleasant and uninteresting on the surface. Jill Green (Social Worker) was very cordial and polite with both my wife and myself and each of our children while she was assigned to investigate allegations of abuse from a disgruntled family member (my estranged sister Kelli-Ann Reale). She asked only appropriate questions and was very satisfied with our responses and her observations throughout the home. She even issued the required Safety Assessment circling “No” for ALL indicators with regard to observations or indications of abuse or neglect. Since CPS has filed their Neglect Petition in June it has been reported throughout their various court documents that the social worker (Jill Green) who issued this report in the home had concerns of the children seeming fearful. Why was this not noted on the Safety Report? Because it was a fabrication designed to support the present agenda of WCHS to remove the children from our home 8 months later. Fraud! In fact what she observed were very polite and respectful children who were playing in the yard when she arrived and who were, in fact, taking turns sitting in my lap (seemingly seeking security from a strange person in our home, which seemed very normal) during the interview process and other discussions. Upon completion of her visit Jill could not say enough about how impressed she was with the family home and each of our children. Also since the Neglect petition, have been accusations that my wife would not disclose anything in my presence as a reason why she did not disclose any abuse allegations during this visit. The truth is I was not even home when the Jill Green first arrived. I was approximately 45 minutes from home when I received a call from my wife explaining the situation. At first I said he could not make it home any time soon and I advised my wife to call me if the worker had any questions for me specifically. The worker insisted that she would eventually need to meet with me so I simply decided to rearrange my schedule and head home. Therefore my wife Debra had at least 45 minutes to disclose anything she would have liked; not to mention the fact that I wasn’t even interested in heading home at all. This is a clear example of more lies to support their agenda 8 months after the fact. More Fraud!
COUNT I; VIOLATIONS OF THE FOURTH AMENDMENT – Due Process
Jill Green also testified on behalf of my wife during the unlawful hearing held by Judge Christian on May 3, 2010. She committed multiple counts of perjury by stating under oath, as evidenced by the hearing transcript that; “one of the boys MRR… appeared scared and timid…He didn’t currently have any marks or bruises on him but, he had previously from a belt had a mark on him.” Well did he or didn’t he? Of course he didn’t, it was just more double talk and inflammatory, prejudicial, and uncorroborated testimony to suit their agenda at the time. None of which was supported by any report at the time of the actual visit which she herself signed on that very day. She goes on to contradict her actual visit and the report of the visit by saying; “and he looked really timid. He would look down. He was scared and kind of just inside himself.” If these so-called shocking revelations were even remotely true, why did she not take any action? In the alternative she chose to leave a safety report indicating “NO” signs of abuse or Neglect. And more to the point, why is she testifying to the exact opposite of what she really observed. AGENDA! FRAUD! PERJURY! Jill Green goes on to testify under oath that she questioned my wife about domestic violence which she acknowledges was “vehemently denied” by my wife and goes onto imply that she must have been lying and even goes on to excuse the answer by stating; “when I did interview the parents together, it was Mr. Reale who was the one that answered the questions.” She fails to make mention of the 45 minutes she had with my wife and the children prior to my arriving home. FRAUD! She also fails to mention that she violated state law, not to mention the fourth Amendment to the Constitution by entering our home without both the permission of me and my wife. Remember, I was not home upon her arrival but she was in my home when I arrived 45 minutes later. This is against the law and clearly violates the United States Constitution! Period!
On a follow-up visit by Jill’s Supervisor Richard Hayner it was much of the same. Richard was welcomed into our family’s home with his training social worker (name not provided). Ultimately a “letter of findings” was sent to us via US Mail dated October 29, 2010 reporting no findings of abuse in the home. This was signed by both Jill Green and Richard Hayner (supervisor).
During her testimony in the May hearing and for her contribution to the neglect petition in June, Jill Green clearly was focused on saying whatever she needed to, even rising to the level of perjury, to succeed in WCHS’ goal of removing our 7 minor children from the family home. This was fabricated, calculated, and an overall egregious effort which resulted in the removal of 7 minor children from their family home and a clear deprivation of rights on many levels.