| Chuck 2005-07-31, 10:53 pm |
| Kathleen M. Dickson
Lara E. Dickson
Diane M. Dickson
David D. Dickson, et al,
And on behalf of all Families and
Children of the State of Connecticut
In the cause of a class action:
v=2E STATE OF CONNECTICUT US DISTRICT COURT
1 Exchange Terrace
Providence, Rhode Island 02903
27 JULY 2005
AFFIDAVIT
I, Kathleen M. Dickson, representing residents of the State of
Connecticut, claim the following abuses and neglect of duty by
employees of the State of Connecticut:
Civil and human rights abuses, color of law violations, deprivation of
rights, and conspiracy to deprive of rights, and regarding the
well-known and numerous acts and examples of incompetence, perjury,
acts of defrauding the courts, state employees defrauding the police,
the police defrauding the courts, judicial misconduct, the State of
Connecticut=E2=80=99s defrauding The United States of America, the criminal
behavior of the Department of Children and Families (DCF) and related
staff, and DCF=E2=80=99s well-documented abuse and neglect of children and
families, and in default of the protections guaranteed by federal and
state laws,
DO HEARBY SWEAR that the following statements are truthful, sworn
testimony, written as any reasonable person would understand, before
God, as stated.
Statutes and Rules Violated
18 U.S.C. Section 241 Conspiracy Against Rights
18 U.S.C Section 242 Deprivation of Rights Under Color of Law
18 U.S.C. Section 245 Federally Protected Activities
Americans With Disabilities Act
Risk of Injury to Minor Children
Racketeering Influenced and Corrupt Organizatrions (RICO) violations
Plaintiff KM Dickson requests of the District of Rhode Island federal
court to be fully respectful of the abundantly common public knowledge
of the loss of the public trust due to the indictments and criminal
racketeering behavior of the former - and now criminal- Governor John
G=2E Rowland and his staff as regards the Connecticut Department of
Children and Families (DCF), and the fact that DCF in January 2004 was
criticized by the Hartford Courant as
=E2=80=9DFor a while, it seemed as if the Department of Children and Famili=
es
belonged to the scandal of the week club=E2=80=9D.
Plaintiff KM Dickson respectfully asks the court to consider and agree
that the following is true and documented, except where specified in
the document to have not been delivered previously to the State of CT
in the specified datapackage (one known case):
ROWLAND RACKETEERING
1) The families of the State of Connecticut were victimized by the
corrupt and abusive practices of the CONNECTICUT DEPARTMENT OF CHILDREN
AND FAMILIES and their former Commissioner KRISTINE RAGAGLIA, the
former Governor JOHN G. ROWLAND, his chief of staff PETER ELLEF, his
co-chief of staff LAWRENCE ALIBOZEK. These individuals were criminally
charged and/or prosecuted and/or sued, with WILLIAM TOMASSO in the past
year. The charges and civil allegations were theft of honest services
of the government and racketeering. This was described as depriving
the public of the honest services of the government, and Governor
=E2=80=A6=E2=80=9CRell said, =E2=80=98Anyone who violated the public trust =
must be
prosecuted to the fullest extent of the law.=E2=80=99=E2=80=9D [Exhibits =
A, B, C,
D]
CT OFFICE OF POLICY AND MANAGEMENT=E2=80=99S INVOLVEMENT IN THE ROWLANDGATE
SCANDAL:
2) The former Manager of the Office of Policy and Management, MARC S.
RYAN apparently left the state unscathed in the criminal and civil
actions of the above named individuals. The CONNECTICUT JUVENILE
TRAINING SCHOOL (CJTS) built by the TOMASSO Brothers is a CT State
disgrace, as was the abuse of the pediatric prisoners by the guards.
Governor Rell ordered DCF=E2=80=99s current commissioner to come up with a
plan for what to do with CJTS by July 1, 2005, to include closing it.
RYAN having been complicit in the misapplication of his duties to
soundly provide for the residents from the federal funding, under the
demands of his duties as specified above, was not punished.
ABUSE OF CHILDREN PRISONERS:
3) The children were abused in this prison. Attorney General RICHARD
BLUMENTHAL=E2=80=99s and the CHILD ADVOCATE=E2=80=99S (Jeane Milstein) Press
Release states: =E2=80=9CThe manhandling and mistreatment of children sho=
wn
in these videos demands swift, strong steps to reform and revamp this
facility.=E2=80=9D [Exhibit D].
One may conclude that children are abused in DCF=E2=80=99s =E2=80=9Ccare.=
=E2=80=9D
THE DCF =E2=80=93 ROWLANDGATE BILLS:
4) JOHN G. ROWLAND sponsored the bills HB- 5021 (1998) and HB-6999
which stated =E2=80=9CThe proposed increases in spending are attributed to
higher than expected spending requirements in federal entitlement
programs (Medicaid and Temporary Family Assistance), lower than
budgeted savings from the Early Retirement Incentive Plan, the
carryover effect of current years deficiencies and the Governor=E2=80=99s n=
ew
initiatives=E2=80=A6.=E2=80=9D
And
=E2=80=9CAn additional growth factor is the increase of termination of
parental rights petition approved by the courts, which leads to a child
being defined as =E2=80=9Cno-nexus.=E2=80=9D [Exhibit E]
One might conclude that since the Rowland is in jail for his
facilitating this abuse of funding and did not provide adequately for
the children of the State of Connecticut.
CT DCF DEFRAUDING THE UNITED STATES DEPARTMENT OF HEALTH AND HUMAN
SERVICES=E2=80=99 AGENCY FOR CHILDREN AND FAMILIES:
5) In =E2=80=9CCAREENING TOWARDS CRISIS,=E2=80=9D The Connecticut Voices f=
or
Children have determined that the State DCF =E2=80=9Cmisallocated=E2=80=9D =
the
UNITED STATES=E2=80=99 Department of Health and Human Services Agency for
Children and Families=E2=80=99 Temporary Aid to Needy Families (TANF funds),
which were intended to go to needy families, but were instead delivered
to the salaries of State DCF employees. [EXHIBIT F]
Among their findings:
=E2=80=9CConnecticut=E2=80=99s budget now invests far too little in the hom=
e and
community-based services that can prevent child abuse and neglect in
the first place=E2=80=A6
=E2=80=A6 an increasing share of funds being spent on more costly and
restrictive institutional and restrictive institutional out of home
care.
DIVERSION OF TANF BLOCK GRANT funds to fund DCF staff=E2=80=A6
DIVERSION of Title IV-B funds to fund DCF staff=E2=80=A6=E2=80=9D
This report reads like an indictment of DCF in defrauding the federal
government and the residents of CT of the DHHS=E2=80=99 Agency for Children
and Families=E2=80=99 Temporary Aid to Needy Families it received. From pa=
ge
2 of this indictment:
=E2=80=9CKEY FINDINGS
1=2E Growth in DCF=E2=80=99s Budget Has Far Exceeded Growth in DCF=E2=80=
=99s
caseload
In the last decade, the number of children served by DCF increased from
7,500 children at the end of FY 94 10 12,247 children at the end of FY
04 (a 63% increase). DCF=E2=80=99s General Fund budget grew faster- from
$227.6 million in FY 94 to 606.1 million in FY 04 (a 165% increase),
With DCF=E2=80=99s revised SFY 05 General Fund budget at $642.6 million,
there has been a 182% nominal increase since FY 94. While some of this
growth is attributed to the more complex clinical needs of children now
in care and to long overdue investments to improve the quality of care
of these children, much growth is also due to skewed spending policies
that skimp funding for services that could reduce child welfare
involvement while, at the same time, increasing spending for =E2=80=9Cback
end=E2=80=9D placements and services.=E2=80=9D
=E2=80=9CROWLAND=E2=80=99s NUMBERS=E2=80=9D
6) The former Governor JOHN G. ROWLAND made this claim on his website:
=E2=80=9CTo help protect children, Governor Rowland has hired more social
workers, moved more staff into the field to work directly with at-risk
children, and made it easier to remove at-risk children from abusive
homes. The number of children in new permanent homes has jumped 445 %
since 1996, while the number of children found to have been abused or
neglected has fallen 45 % since 1997."
Plaintiff(s) personally find this to appear to show that 10 times as
many children were taken from their parents as needed to be. If 1000%
of children were taken, then there would be zero children found to be
abused or neglected.
Additionally, in the January 5, 2004, Hartford Courant, in
=E2=80=9CCOMPLICATED MAN AT THE CENTER OF THE CORRUPTION PROBE=E2=80=94Pete=
r Ellef
was a big dreamer.=E2=80=9D
=E2=80=9CAs Gov. John G. Rowland=E2=80=99s co-chief of staff, Ellef spoke of
levitating trains, hydroponics gardening, building prisons in old stone
quarries and opening trade relations with China. His plans after state
service included developing a string of juvenile detention facilities
across the country, a chain of home improvement stores and a high-end
garden center.
To the casual observer, the alleged racket run out of Rowland=E2=80=99s
office involved increasing the termination of parental rights because
that made the =E2=80=9Cracket=E2=80=9D eligible for more federal funding,
proportionate to the increase in =E2=80=9Cno-nexus=E2=80=9D children needin=
g to be
housed in some facility (like a prison) or another. [EXHIBIT E- the
bills ]
DETENTION VS PREVENTION, the VIOLENCE IN HARTFORD:
7) =E2=80=9CVIOLENCE HIGHLIGHTS DCF=E2=80=99s ROLE.=E2=80=9D The Child Ad=
vocate Jeane
Milstein said in an article dated the 20th of June 05 in The Hartford
Courant,
=E2=80=9CThe state DCF anticipates spending $762,00 on prevention programs
targeting teens in the coming year. The amount is one-tenth of 1
percent of he agency=E2=80=99s $762 million budget, even though prevention =
is
one of the agency=E2=80=99s four principal missions; the others being child
protection, juvenile justice and meeting children=E2=80=99s behavioral heal=
th
needs.
=E2=80=9CIt=E2=80=99s amazing that DCF has no problem spending taxpayer m=
oney to
the tune of $514,000 per child, per year at the Connecticut Juvenile
Training School, but it can=E2=80=99t find the funds in its $700 million
budget on prevention programs targeting teens in the to help mentor
troubled youth in our communities.=E2=80=9D [EXHIBIT G]
Plaintiff KM Dickson had made the claim that JOHN G. ROWLAND was using
the DCF as a =E2=80=9Cfederal money farm for the Tomassos.=E2=80=9D It is =
now
unclear who, if =E2=80=9CTREA=E2=80=9D was a real entity, and if TREA is an=
acronym
for the names of the federally indicted, and that one cannot conclude
the =E2=80=9CR=E2=80=9D stands for ROWLAND, but may stand for RAGAGLIA, sin=
ce this
was a limited liability corporation, and to my knowledge, MS RAGAGLIA
is a lawyer. A lawyer might be necessary to set up a limited liability
corporation.
AN APPALLING COMBINATION OF ARROGANCE AND INEPTITUDE:
8) The CT DCF was resoundingly criticized in August 2004, by JUDGE
CARMEN LOPEZ for =E2=80=9Can appalling combination of arrogance and
ineptitude, =E2=80=9D in cases where DCF workers defraud the courts, in an
effort to gain custody. PAUL CHILL of UCONN Law school was quoted in
the Connecticut Law Review as saying, =E2=80=9C was appropriately intolera=
nt
of official malfeasance and abuses of power in the child protection
system.=E2=80=9D Chill, who has run advocacy clinics on child protection
issues for 16 years, said Lopez was the first judge to hold DCF
accountable.=E2=80=9D [EXHIBIT H]
THE SETTLING OF THE 1989, 15 YEAR OLD CIVIL RIGHTS CLASS ACTION AGAINST
DCF:
9) ChildrensRights.org - Juan F. case lawsuit. (2003). =E2=80=9CIn Octobe=
r,
the state and the lawyers for thousands of Connecticut abused and
neglected children reached an unprecedented landmark agreement after
the state and its Department of Children and Families (DCF) were
charged with contempt of court for failing to comply with the court
orders and improve services for children. [EXHIBIT I]
Subsequently, =E2=80=9CCASH INFUSION IS TO PROVIDE ALTERNATIVES TO
STATE=E2=80=99S DETENTION CELLS,=E2=80=9D (news article) June 27, 2005, =
The
Hartford Courant. [EXHIBIT J]
The 8.5 million dollar settlement =E2=80=9Cbetween attorneys representing
hundreds of children in juvenile detention in a federal class action
lawsuit and the state agencies that manage the detention centers and
children=E2=80=99s mental health programs.=E2=80=9D
=E2=80=9CThe settlement also calls for increased training and cooperation on
the part of state social workers, juvenile probation and juvenile
parole officers to make sure children with serious emotional needs have
detailed treatment plans so that they can get the proper services that
they deserve=E2=80=9D.
DCF was sued for civil rights violations, which took nearly 15 years to
resolve, and which concluded with increased training and cooperation.
Plaintiff KMDickson had made the claim directly to Assistant Attorney
General James Kelly that DCF staff were =E2=80=9Ccognitively and morally
challenged=E2=80=9D on January 27, 2003, and =E2=80=9Ccognitively and moral=
ly
impaired,=E2=80=9D January 28, 2003. Reading DCF=E2=80=99s =E2=80=9Crecor=
ds=E2=80=9D give
once the sense that the DCF staff and reality are two entirely
different universes. Plaintiff KMDickson was an analytical chemist
for Pfizer, Inc, and thus record keeping, being absolutely accurate is
imperative.
Conservatively speaking, the DCF=E2=80=99s record-keeping indicates that mi=
ld
mental retardation may be a DCF employee job requirement, as is
demonstrated by Plaintiff KM Dickson in her replies to complaints made
to the Statewide Bar Counsel and CT Commission on Human Rights, with
the evidence. For examples, science does not equal insanity, although
DCF=E2=80=99s former New Haven principal attorney, Sarah Gibson, believes it
does. A DCF =E2=80=9Cworker=E2=80=9D Lisa McArthur informed Plaintiff Dick=
son that
her dog and grandfather died of Lyme disease. Plaintiff KM Dickson gave
this =E2=80=9Cworker=E2=80=9D a great deal of scientific information about =
how
damaging Lyme disease is to the nervous system. Later, DCF=E2=80=99s
McArthur and her co workers wanted to know how serious was Lyme
disease. Plaintiff KM Dickson suggested that if McArthur and her
coworkers can=E2=80=99t read, perhaps they could visit the cemetery to see =
if
McArthur=E2=80=99s grandfather had improved.
APPLAUSE FOR THE PROPOSED END TO DCF=E2=80=99S INCOMPETENCE AND ABUSES:
10) =E2=80=9CFORUM ADDRESSES CHILDREN, FAMILIES,=E2=80=9D (news article) H=
artford
Courant June 28, 2005
=E2=80=9CThe forum focused on ways current state and federal funding needs =
to
be changed to better protect children and promote healthy families.=E2=80=
=9D
=E2=80=9CWe need a major overhaul,=E2=80=9D Sirry (the federal court monito=
r of the
DCF) said to applause from the crowd of about 100 child welfare
professionals.=E2=80=9D [EXHIBIT K]
There appears to be a broad consensus that DCF is hardly successful.
THE FAILURE OF THE MENTAL HEALTH SYSTEM:
11) The current LT. GOVERNOR KEVIN B. SULLIVAN was commissioned to
uncover the source of =E2=80=9Cthe failure of the mental health system=E2=
=80=9D and
the June 9, 2005 statement on Mr. Sullivan=E2=80=99s website says the
following:
=E2=80=9CBut make no mistake,=E2=80=9C Sullivan added, =E2=80=9Cthis is jus=
t the
beginning of what we need to do in order to build a more effective and
more efficient system of community-based mental health care that works
and is less expensive that what we are doing now. Over the next three
years, we need to keep the momentum for reform that has been lost too
many times in the past. I also remain deeply troubled that the
Governor, who had no hesitation taxing nursing home patients in part to
help maximize federal Medicaid funding for longterm care, still refuses
to end Connecticut=E2=80=99s sad distinction as the only state in the nation
not to take get back more of our federal tax dollars by taking full
financial advantage of major Medicaid funding. This would go a long way
in helping reinvest in mental health care for children and adults.=E2=80=9D
Recent examples of the CT =E2=80=9Cmental health system=E2=80=99s=E2=80=9D =
alleged
criminal behavior:
HOSPITAL PSYCHOLOGIST FIRED (Hartford Courant) published on June 23,
2005,
=E2=80=9DA veteran psychologist at a state-run psychiatric hospital for
children has been fired after investigators found he downloaded
pornography on his work computer.
Kenneth C. Thunberg, 54, of Deep River, was on paid administrative
leave from the Riverview Hospital for Children and Youth while
officials from the state Department of Children and Families, which
runs the Middletown facility, investigated.
Thunberg counseled children at Riverview for 12 years. Notified of his
dismissal last.......=E2=80=9D [EXHIBIT L]
Prominent Psychologist Faces Charges Eating Disorder Expert Inhaled
Gas, Police Say
July 12, 2005, By TOM PULEO, Courant Staff Writer
WEST HARTFORD -- A prominent psychologist who specializes in eating
disorders faces criminal charges after she inhaled propellant from
whipped cream cans and collapsed on a supermarket floor in May, police
say.
Lisa G. Berzins, 49, of 9 Talcott Glen Road in Farmington, was charged
in a warrant Friday with possession of a restricted substance,
third-degree criminal mischief and creating a public disturbance. She
was released on $500 bail for a July 21 appearance in Superior Court in
Hartford.
"These are only allegations," said Berzins' attorney, Bob Ludgin of
Hartford. "My client is innocent unless convicted. I have confidence
that there will be no convictions."
Berzins, who has a practice listed at 91 S. Main St. in West Hartford,
has lectured and written widely in the areas of eating disorders,
female development, sex roles and self-esteem, according to her
speaker's biography listed with the American Psychological Association.
Her resume includes listings as director of the eating disorders
programs at the Institute of Living in Hartford, and the former
Elmcrest Psychiatric Institute in Portland. It was unclear when she
held those positions.=E2=80=9D [EXHIBIT M]
----
Mumbo-Jumbo Syndrome.
=E2=80=9CMunchausen=E2=80=99s syndrome by proxy is a quintessential example=
of that
most suspect of scientific theories =E2=80=94 one that brooks no rational
argument, a closed circle we all must accept at face value.
For example, the only cure must begin by the sufferer accepting that he
or she is afflicted with the condition =E2=80=94 which, of course, the
alleged sufferer is loath to do. But if someone who is diagnosed as a
sufferer vociferously denies it, this serves to reinforce the
diagnosis. A denial of the condition is, perforce, a symptom of the
condition. And then there=E2=80=99s this: there is no cure but it is accept=
ed
that sufferers can sometimes continue to live among other people
without exhibiting the symptoms =E2=80=94 murdering people or making them
ill. Furthermore, there is no agreed biological or psychological cause.
So there we have it: an illness that has no cause or cure and that is
diagnosed at least partly by the alleged victim=E2=80=99s denial that he or
she is so afflicted. The more the victim denies it, the more obviously
the victim is afflicted. And it is an illness that may somehow exist
within a person without cause or cure or indeed any manifestation of
its symptoms.
In the medical establishment, in the law courts and in the press, why
were we prepared to believe this guff for more than a quarter of a
century and send people to prison as a result?=E2=80=9D -- TIMES ONLINE, UK
Parents who say their children have Lyme disease, are often accused of
Munchausen=E2=80=99s by proxy. It is not unusual for a psychiatrist to say
that the denial of the illness, is a sign of the illness. Here, the
writer questions why we accept this medical mumbo-jumbo and circular
reasoning on the basis of zero evidence, in the courts, and in the
press, and in the medical establishment. [EXHIBIT N]
FALSE ACCUSATIONS OF TERRORISM
12) Plaintiff KM Dickson complained to the USDOJ and National
Institute of Mental Health on November 11, 2003, that the DCF
apparently falsely informed the Stonington, CT Schools and the
Stonington, CT Police that Plaintiff KM Dickson was a terrorist, or
intent on murder, and the schools then had a special terrorist drill,
and ordered Plaintiff Dickson off the schools=E2=80=99 grounds. This is a
National Security risk, because this distracts police from real
terrorisms targets surveillance. AAG JESSICA GAUVIN listed this
communication in her second petition as evidence that Plaintiff KM
Dickson was insane (Nov 11, 2003 Vigilante Justice complaint).
Plaintiff KM Dickson was complaining to the USDOJ and NIMH that DCF was
insane, which is more obviously the truth. Plaintiff Dickson testified
at the FDA about how Yale=E2=80=99s dangerous LymeRIX vaccine was not a
vaccine. The vaccine came off the market a year later. DCF did not
help children in this way as regards Lyme disease or as regards the
dangerous LymeRIX vaccine. Instead DCF accused Plaintiff Dickson of
being a terrorist. The United States Department of Justice may find
this to be criminal behavior on the part of the DCF. It appears that
this all started with Donald G. Dickson=E2=80=99s false accusations that
Plaintiff KM Dickson intended to drive her children into a lake.
[EXHIBIT O NIMH and =E2=80=9CVigilante Justice?=E2=80=9D]
Plaintiff KM Dickson found outer, after Nov 21, 2003, that Donald G.
Dickson was the one who filed the false DCF accusation that Plaintiff
KM Dickson of intending to kill Plaintiff=E2=80=99s children from reading t=
he
Lyme disease newsgroup. [EXHIBIT P Chuck P Adams=E2=80=99 post]
DCF=E2=80=99s INCOMPETENCE AND THE RHODE ISLAND TICK BORNE DISEASES
MANAGEMENT PLAN
13) Plaintiff KM Dickson submitted testimony to the April 2002 Rhode
Island Tick Borne Diseases Commission regarding the fraud of Lyme
disease, with substantiating documentation, entitled =E2=80=9D The Rhode
Island Tick Borne Diseases Management Plan.=E2=80=9D Rhode Island passed
legislation protecting physicians from the Organized Crime and
Racketeering-Influenced Corruption as regards Lyme Disease, CT DCF
staff Maureen Auger asserted that since Plaintiff KM Dickson was the
author of this document [EXHIBIT Q], it was meaningless. These are
largely summaries of abstracts published in the scientific literature.
If these scientific articles are meaningless, DCF=E2=80=99s Maureen Auger
should take up her claim that this science is meaningless with the
National Library of Medicine, the publishers of these journals and the
scientists who produced these reports.
Instead of the Plaintiff KM Dickson=E2=80=99s Tick Borne Diseases Management
Plan being adopted by the State of Rhode Island, it was adopted by
commercial interests in Rhode Island. This is evidence of DCF=E2=80=99s
incompetence.
FALSE DCF ACCUSATIONS MISHANDLED
14) The psychiatrist-diagnosed (diagnosed by J. David Ruffner, MD,
Psychiatrist) =E2=80=9Csociopath,=E2=80=9D Donald G. Dickson, falsely claim=
ed to
the DCF that Plaintiff KM Dickson was going to drive her children into
a lake. Nancy E. Martin, 21 Redstone Way, Farmington, CT made numerous
false allegations to DCF, and was not arrested at the depositions,
where these allegations were discovered to be false. Nancy Martin
proceeded to lie under oath, however, and give a vague explanation of
Plaintiff KM Dickson=E2=80=99s having been talking about her grandparents, =
as
if they were alive during Plaintiff Dickson=E2=80=99s brother=E2=80=99s fun=
eral in
1977. In fact, they all were dead for 12 years by 1977, and no such
bizarre conversation happened. Nancy E. Martin, and Donald G. Dickson
further perjured themselves at Plaintiff KM Dickson=E2=80=99s DCF
=E2=80=9Ctrial.=E2=80=9D Every single statement made by the DCF=E2=80=99s=
witness at
Plaintiff Dickson=E2=80=99s =E2=80=9Ctrial=E2=80=9D was perjury, with the =
exception of
James Phillips saying Plaintiff Dickson was a victim of child abuse.
That abuser was Carolyn Martin, who, we found out at the depositions,
invented herself, that Plaintiff KM Dickson said she would =E2=80=9Cslit her
own throat,=E2=80=9D an accusation which made its way into the DCF=E2=80=99=
s first
petition, which was thrown out, and but was retained as part of a final
statement DCF made for the court, December 23, 2004. Carolyn Martin
was also not arrested by DCF for making false allegations.
The =E2=80=9Csociopath=E2=80=9D Donald G. Dickson made other false allegati=
ons to
the DCF at least twice, and once told the DCF falsely that Plaintiff KM
Dickson =E2=80=9Cbeats the children=E2=80=99s butts until they are red,=E2=
=80=9D =E2=80=9Cpokes
them in the face with sticks,=E2=80=9D and =E2=80=9Cscreams at them non-sto=
p for
two hours.=E2=80=9D Plaintiff KM Dickson is sick with the Multiple Scleros=
is
presentation of Lyme Disease. If Plaintiff KM Dickson could scream for
2 hours, she would not be disabled from Lyme Disease.
DCF=E2=80=99s DELIBRATE RISK OF INJURY TO MINORS
15) Plaintiff Dickson faxed DCF=E2=80=99s Lisa McArthur on January 6, 2003,
the extensive evidence of Donald G. Dickson=E2=80=99s abuse history,
including his arrest for domestic violence (1993), a restraining
granted order against Donald G. Dickson (1996), and a letter from the
Battered Women=E2=80=99s Shelter in New London, CT (1994), stating that
Plaintiff KM Dickson and her 2 older children had to stay there
temporarily for safety from Donald G. Dickson. [EXHIBIT EE The
alleged =E2=80=9Charassing communications and threatening=E2=80=9D] This sh=
ould
have been enough evidence that Donald G. Dickson was not a reliable
witness. Instead, DCF gave the Plaintiff KM Dickson=E2=80=99s children to
this well-known child abuser (taken in testimony by DCF of the children
themselves) and wife beater, Donald G. Dickson, which is illegal. This
is risk of injury to a minor:
=E2=80=9CAnyone who exposes a child to harm or fails to protect a child from
physical assault may be prosecuted under the risk of injury statute.=E2=80=
=9D
Hartford Courant, July26, 2005
DCF informed Plaintiff KM Dickson=E2=80=99s children that if they complained
about being placed with an abusive parent, they would be kidnapped
again and placed in separate foster homes, therefore this dangerous
placement was deliberate.
The CT statute regarding false allegations to DCF stipulates a $1500
fine and up to a year in prison, yet when Plaintiff KM Dickson tried to
discover how to prosecute false allegations, the Middletown Superior
Court, and the Milford State=E2=80=99s Attorney=E2=80=99s office did not kn=
ow whose
job it was to prosecute false allegations, because, as they told
Plaintiff Dickson, no one had ever been prosecuted for false
allegations before. Thus, DCF are incompetent to an apparently
unlimited number of their own statutes.
=E2=80=9CCONFIDENTIALITY=E2=80=9D AND =E2=80=9CIMMUNITY=E2=80=9D
16) =E2=80=9CJudge=E2=80=9D John C. Driscoll stated that the =E2=80=9Cproc=
eedings=E2=80=9D of
a DCF =E2=80=9Ctrial=E2=80=9D are confidential, however, DCF=E2=80=99s form=
er New Haven
principal attorney, Sarah Gibson sent Plaintiff KM Dickson a copy of
Connecticut Statute 17a-28, which clearly states that the =E2=80=9Cperson=
=E2=80=9D
who is a defendant, and who is guilty regardless of being proven
innocent, may give any information about their DCF =E2=80=9Ccase=E2=80=9D to
whoever they want. Plaintiff KM Dickson, as a long time human rights
activist, exposed the fraudulent and bizarre activities of CT DCF to
the entire world, so that other families may be warned and protected
against their abuse, by scanning in evidence into her website and
posting to various newsgroups, the truth about DCF=E2=80=99s behaviors and
incompetence.
The only reason these DCF proceedings are kept =E2=80=9Cconfidential,=E2=80=
=9D is
to protect from criminal liability, the perjury of the DCF, their
deliberate defrauding of the courts, and the perjury they orchestrate
with their witnesses under their =E2=80=9Cimmunity.=E2=80=9D That the aver=
age
legislator can=E2=80=99t see the reasoning behind these combined conditions,
=E2=80=9Cconfidentiality=E2=80=9D and =E2=80=9Cimmunity,=E2=80=9D especiall=
y in the face of the
rising budget and 445% increase in children taken from their parents in
contrast to a 45% reduction in child abuse, and especially when it is
well known that the mental health system is a failure, speaks to
legislators=E2=80=99 either motives or incompetence. The statute clearly
states that the defendant/perp may release records to anyone they want,
canceling out any confidentiality rulings.
The CT DCF and their inane statutes are clearly organized crime and
racketeering influenced, due to the obvious intimidation attempts to
commit and attempts to falsely arrest people who complain to the proper
authorities about the criminal behavior of the CT DCF staff.
RECENT NEWS REGARDING CT DCF=E2=80=99s CARE OF PEDIATRIC PRISONERS:
17) CT DCF is in charge of the juvenile justice system in CT. In
today=E2=80=99s (July 27, 2005) Hartford Courant, it was claimed that:
=E2=80=9CAnd some say that when 16- and 17-year-olds are added in,
Connecticut has the nation's highest incarceration rate for youths.=E2=80=
=9D
This news article comes on the heals of yet another child who killed
himself in DCF=E2=80=99s =E2=80=9Ccare,=E2=80=9D this past Sunday, July 24,=
2005. The
child hung himself in one of the DCF=E2=80=99s prisons for children. It
never ends. DCF shows no signs of willingly ending their practices of
harming children, will not do so voluntarily, and retaliate against
people who claim abuse by DCF and ask for relief and fairness.
=E2=80=9CROWLANDGATE=E2=80=9D AND NATIONAL SECURITY:
18) This extraordinary number of children removed from parents,
jailed, and mistreated by DCF may have something to do with John G.
Rowland describing himself as =E2=80=9Ca National Security Advisor=E2=80=9D=
to
President George W. Bush. The criminal enterprise run out of
Rowland=E2=80=99s office, TREA, was about a =E2=80=9Cnational string of pri=
sons and
juvenile detention centers.=E2=80=9D Some people have claimed that this Bu=
sh
administration plans to incarcerate people who protest against the
NeoCon abuses masterminded by Paul Wolfowitz:
=E2=80=9CProject for a New American Century
Wolfowitz however could not remain completely out of politics for long
and in 1997 he became one of the charter members, alongside Donald
Rumsfield, Dick Cheney, Jeb Bush, Richard Perle and others, of the
Project for a New American Century (PNAC). William Kristol and Robert
Kagan founded this neo-conservative think-tank with the stated aim of
"American global leadership" through military strength. In 1998
Wolfowitz was one of the signatories of the PNAC open letter to
President Bill Clinton that was highly critical of his continued policy
of containing Iraq. The PNAC advocated preemptive U.S. military
intervention against Iraq and other "potential aggressor states" to
"protect our vital interests in the Gulf". In 2000 the PNAC produced
its magnum opus the 90-page report on Rebuilding America's Defenses:
Strategies, Forces and Resources for a New Century that advocated the
redeployment of U.S. troops in permanent bases in strategic locations
throughout the world where they can be ready to act to protect U.S.
interests abroad. The Clinton administration however remained unmoved
and pressed on with containment.=3D=3D=3D wikipedia
Pre-emptive military aggression, when it is clearly about oil and not
national security, may result in a national security risk to Americans.
Americans might not stand for the increased terrorism, in retaliation
for a fraudulent Iraq war, directed at Americans, and Americans might
also rebel against this =E2=80=9Cadministration,=E2=80=9D or the concept of=
the
United States becoming the self-designated World Police. Such a
rebellion could be accommodated by a national string of prisons and
juvenile detention centers. America has little GNP or natural energy
supplies of our own, and in such an economically disadvantaged state it
appears that the US has little choice but to become a world police
force. Perhaps the plan is to pay ourselves by taxing other countries
for this unwanted service. Paul Wolfowitz is now the head of the World
Bank. Bush=E2=80=99s 2005 Inaugural speech contained these passages:
=E2=80=9CA few Americans have accepted the hardest duties in this cause - in
the quiet work of intelligence and diplomacy ... the idealistic work of
helping raise up free governments ... the dangerous and necessary work
of fighting our enemies. Some have shown their devotion to our country
in deaths that honored their whole lives - and we will always honor
their names and their sacrifice.
All Americans have witnessed this idealism, and some for the first
time. I ask our youngest citizens to believe the evidence of your eyes.
You have seen duty and allegiance in the determined faces of our
soldiers. You have seen that life is fragile, and evil is real, and
courage triumphs. Make the choice to serve in a cause larger than your
wants, larger than yourself - and in your days you will add not just to
the wealth of our country, but to its character.=E2=80=9D [EXHIBIT R]
DANGEROUS PERJURY- DMHAS
19) DEPARTMENT OF MENTAL HEALTH AND ADDICTION SERVICES=E2=80=99 (DMHAS)
=E2=80=9CMedical Director,=E2=80=9D Kenneth Marcus, [see EXHIBIT X for more
background info on =E2=80=9CDr.=E2=80=9D Marcus] came to Plaintiff Dickson=
=E2=80=99s DCF
=E2=80=9Ctrial,=E2=80=9D perjuring himself in court and said you treat an o=
rganic
delirium like any other psychosis, when that is clearly against the
American Psychiatric Associations (APA) Guidelines, due to the
increased brain damage caused by this mistreatment [EXHIBIT T ].
The APA guidelines clearly state, =E2=80=9CWhen delirium is comorbid with
other psychiatric disorders, the delirium should be treated first. =E2=80=
=9C
This is a guideline that should apply to all persons with neurologic
Lyme disease. Central nervous system Lyme disease should be treated
with ceftriaxone. The guideline continues:
=E2=80=9CMedications for psychiatric disorders can be both the cause of
delirium and exacerbate or contribute to delirium from other causes.=E2=80=
=9D
Lyme disease is an organic brain syndrome. [EXHIBIT U] As published
by Allen Steere in 1989, =E2=80=9CLyme disease may affect the central nervo=
us
system causing organic brain syndromes suggestive of demyelination.=E2=80=
=9D
In an world uncomplicated by the perversion of dogma regarding the
source of emotional trauma, wherein sexual repression is considered to
be the cause of child abuse emotional sequelae, instead of child abuse
being the cause of child abuse sequelae, as is the case of the
perverted world of James Phillips, MD, Clinical Professor or Psychiatry
at Yale and Forensic Psychiatrist for the State of Connecticut, a mere
reading of the scientific documentation given to James Phillips, MD,
regarding the science of Lyme as a brain disease, by Plaintiff KM
Dickson, would have alleviated the steps where the Plaintiff KM
Dickson=E2=80=99s children were traumatically removed by DCF, and Plaintiff
KM Dickson went to jail, in the end, for Carolyn Martin=E2=80=99s child
abuse. We could have moved on to guaranteeing proper medical treatment
for Plaintiff KM Dickson and her children, and a validation of this
neuropsychiatric disease, borreliosis. Freud is out of style. Freud
invented, in fact, his psychotic assertions that the world=E2=80=99s woes a=
re
due to inadequate sex instead of inadequate care or love, because the
fathers of Freud=E2=80=99s female =E2=80=9Chysteria=E2=80=9D patients, were=
in fact, the
sexual perpetrators against these female children, who later grew up to
be Freud=E2=80=99s =E2=80=9Chysterical=E2=80=9D patients. The fathers did =
not approve of
Freud=E2=80=99s discoveries. Modern Psychiatry, thanks to the bad fathers =
of
Freud=E2=80=99s day, was then founded upon the concept that the victim is t=
he
guilty, or the victim is the =E2=80=9Cbad=E2=80=9D one. Little has changed.
DMHAS=E2=80=99 Kenneth Marcus also said for the DCF =E2=80=9Ccourt,=E2=80=
=9D something to
the effect that Plaintiff KM Dickson =E2=80=9Cis so psychotic, she does not
know how psychotic she is, which is a sure sign of her psychosis.=E2=80=9D
Plaintiff had left numerous scientific journal articles in the office
of Laura Lustig, PhD, of The New Learning Center, Westport, CT, which
demonstrated the cellular brain damage and other damage caused by most
psychotropics. These were also on Plaintiff KM Dickson=E2=80=99s website,
ActionLyme.com. This is not only perjury and promoting malpractice,
but more psychiatric Mumbo Jumbo. With this reasoning, Plaintiff KM
Dickson could make the claim that =E2=80=9CDCF and DMHAS staff are so stupi=
d,
they don=E2=80=99t know how stupid they are, which is a sure sign of their
stupidity.=E2=80=9D
More seriously, it calls into question the validity of any psychiatric
expert testimony in any legal case, since this was clearly an attempt
by DCF to commit Plaintiff KM Dickson, in an attempt to falsify more
records, and preventing Plaintiff from filing malpractice lawsuits and
other complaints about the criminal behavior of the DCF, as regards
Yale=E2=80=99s dangerous Lyme vaccine, and as regards the Yale/Allen Steere-
orchestrated apparent conspiracy to create a fraudulent testing schema
for Lyme disease to pass off their bogus Lyme vaccine, LymeRIX, and to
also guarantee a monopoly on the post-FDA approval of Yale=E2=80=99s LymeRIX
vaccine.
This perjury, on the part of DMHAS=E2=80=99 Medical Director, is a severe
and dangerous color of law abuse, and should result, minimally, in
Kenneth Marcus=E2=80=99 immediate resignation. [EXHIBIT V- 3:05-CV-91
(CFD)]
Yale and DMHAS=E2=80=99s Vladimir Coric fraudulently reported to the crimin=
al
court numerous aspects of Plaintiff Dickson=E2=80=99s mental health. The
Plaintiff=E2=80=99s children=E2=80=99s Ad Litem, Priscilla Hammond (Old Lym=
e CT),
walked up to Plaintiff Dickson November 21, 2003, after the DCF
depositions, in Milford, CT, and said, =E2=80=9CThe State is watching this
case very closely.=E2=80=9D
Therefore, it is not paranoid of Plaintiff Dickson to be saying, =E2=80=9CT=
he
State is watching this case very closely.=E2=80=9D Coric also perjured
himself and stated that Plaintiff Dickson was treated with
antipsychotic medication for 5 years when she was in her twenties.
Plaintiff Dickson had stated to Coric, that she was given exactly and
only 3 bottles of tranquilizers to be used as needed, over a 5 year
period, and in truthfulness, and to indicate that there was little
medication involved in Plaintiff KM Dickson=E2=80=99s previous psychiatric
history of depression due to the child abuse by Carolyn Martin,
Plaintiff=E2=80=99s =E2=80=9Cmother.=E2=80=9D
Carolyn Martin is now responsible for destroying the lives of exactly 9
children: five of her own, and four grandchildren, due to her abundant
and bizarre lying, hatefulness, and chronic- and lifelong- extreme
physical violence to children, which included beatings with a cat of
nine tails (whip), beatings with this whip with and without clothing,
and full force kicks upon children. That Carolyn Martin is free to
harm more children is a testament to the failure of the =E2=80=9Cmental
health system,=E2=80=9D the =E2=80=9Cchild protection system,=E2=80=9D and=
the
=E2=80=9Ccriminal justice system=E2=80=9D in Connecticut. [EXHIBIT W, Caro=
lyn
Martin is known by all to be a crazy person.]
REGARDING THE DEPARTMENT OF MENTAL HEALTH AND ADDICTION SERVICES AND
THEIR RELATIONSHIP WITH THE DEPARTMENT OF CHILDREN AND FAMILIES:
20) DMHAS is incompetent to brain matters as described in a lawsuit
against the State of CT and Yale University. The State of Connecticut
cannot handle important epidemics such as autism and Lyme borreliosis
as disclosed in 3:05 =E2=80=93CV- 91 (CFD). [EXHIBIT V]
DCF hired Laura Lustig of the New Learning Center, Westport, who
declared for the court, that Plaintiff KM Dickson has Borderline
Personality Disorder and Autism, when the two disorders are mutually
exclusive. Autism is defined by a lack of a personality. Plaintiff KM
Dickson was diagnosed with High Functioning Autism and has two blood
relatives with the same cognitive strengths and deficits. This is
medical and legal incompetence. Yale university has a Center for the
Study of Autism. Yale university also rediscovered Lyme as a brain
infection, yet no Yale or DMHAS physician is competent to either
disorder that Plaintiff KM Dickson has encountered.
The CT 54-56D competency statute assumes that DMHAS is up to date on
brain matters. Clearly for the entire combined National Institutes to
declare Chronic Lyme to be a chronic infection of the nervous system,
and for Yale and DMHAS to declare otherwise, places DMHAS and Yale
staff in default of the competency required by the CT 54-56D competency
statute.
FALSE CRIMINAL CHARGES, CONSPIRACY AGAINST RIGHTS, FEDERALLY PROTECTED
ACTIVITIES
21) Plaintiff KM Dickson was falsely criminally charged with the
bizarre perjury invented by DCF prosecutor Assistant Attorney General
JESSICA GAUVIN. The Honorable Kevin P. Murphy ordered Plaintiff
Dickson to be treated for Lyme disease, as a condition of her release.
The prosecution subsequently switched courts to New Britain, CT, where
the State proceeded to orchestrate more perjury, and state that
Plaintiff Dickson does not have Lyme disease and that Lyme is not a
brain disease (DMHAS=E2=80=99s Elizabeth Byron) [EXHIBIT X Scott Murphy
datasets].
Plaintiff KM Dickson does not have =E2=80=9Ccommand hallucinations to kill
Jessica Gauvin,=E2=80=9D and Plaintiff KM Dickson is not a =E2=80=9Cdangero=
usly
intelligent=E2=80=9D =E2=80=9Cchemist=E2=80=9D =E2=80=9Clike Ted Kaszinski,=
=E2=80=9D the Unibomber.
This is the nonsense GAUVIN invented for Plaintiff KM Dickson at
Plaintiff KM Dickson=E2=80=99s DCF =E2=80=9Ctrial,=E2=80=9D and with which =
GAUVIN then
later falsely criminally charged Plaintiff Dickson.
Plaintiff KM Dickson is a human rights activist, Lyme support group
leader, and testified at the FDA about Yale=E2=80=99s dangerous LymeRIX
vaccine as a pharmaceutical chemist, demonstrating for the FDA (January
31, 2001) that LymeRIX was not qualified with a proper standard and
should not be used for children until we know what is making adults so
sick from this vaccine. These are, to Plaintiff KM Dickson=E2=80=99s
knowledge, not the Unibomber=E2=80=99s methods of activism.
The epidemic of Lyme disease, which is =E2=80=9CConnecticut=E2=80=99s disea=
se,=E2=80=9D
has made no progress in treatment, detection, or prevention in the past
19 years. The CONNECTICUT STATE DEPARTMENT OF HEALTH, the STATE
DEPARTMENT OF MENTAL HEALTH AND ADDICTION SERVICES, the STATE
DEPARTMENT OF CHILDREN AND FAMILIES have all failed their commissions
including the CT state competency statute, 54-56D, for not addressing
this epidemic and not recognizing that borreliosis is a primarily a
brain and nervous system disease.
In fact, despite being given the published scientific evidence which
clearly demonstrates that Lyme borreliosis is a brain disease, DMHAS
staff, in court, in deliberate perjury, and despite the entire combined
National Institutes=E2=80=99 declaring that Lyme is a borreliosis- a
permanent brain infection (The NIH=E2=80=99s Integrative Neural Immune
Program), and despite having full knowledge that Lyme is a brain
disease (since these rediscoveries were also made at Yale University),
stated for the court that Lyme is not a brain disease and that DMHAS
was not aware of Plaintiff Dickson=E2=80=99s diagnosis of Lyme disease.
DMHAS staff further perjured themselves and stated that Plaintiff KM
Dickson refused to meet with a neurologist. Plaintiff met with
Christopher Gottschalk, later discovered to be a Yale Neurologist, who
told Plaintiff that Lyme is not a permanent brain infection, which is
false. Gottschalk told Plaintiff KM Dickson he was from Cross County
Neurology Group and gave Plaintiff the document which is EXHIBIT Y.
FAILURE OF COMMISSIONS:
22) The commissioner of the DEPARTMENT OF SOCIAL SERVICES is obligated
to: 16) conduct, encourage and maintain research and studies relating
to social services development; (17) prepare, review and encourage
model comprehensive social service programs; (18) maintain an inventory
of data and information and act as a clearing house and referral agency
for information on state and federal programs and services; and (19)
conduct, encourage and maintain research and studies and advise
municipal officials and officials of social service agencies about
forms of intergovernmental cooperation and coordination between public
and private agencies designed to advance social service programs. (see
definitions and statutes at end of this document).
DCF was given hundreds of pages of documents related to Lyme disease
and Autism, by Plaintiff KM Dickson, from December 2002, to March
2003. Plaintiff Dickson received her DCF =E2=80=9Crecords,=E2=80=9D in Mar=
ch,
2003, more than three months after requesting them, and only with the
assistance of Congressman Rob Simmons. When Plaintiff KM Dickson read
these records, she was assured she was dealing with extremely mentally
defective individuals employed by the State of Connecticut, and began
filing complaints with various agencies of the State and Federal
government about CT DCF. DCF later removed Plaintiff=E2=80=99s children, =
in
November 2003, defrauding the DCF =E2=80=9Ccourt=E2=80=9D in their Temporar=
y Order
of Custody. These are color of law, deprivation of rights, and
violations against federally protected activities. Residents may file
complaints with the proper authorities, under these Federal Civil
Rights Statutes (USC Title 18, Secs 241, 242, 245). DCF is clearly
funded by federal agencies (DHHS, Agency for Children and Families,
etc.), and the latter statute specifically protects individuals from
color of abuses by federally funded organizations.
DCF=E2=80=99s former Commissioner Kristine Ragaglia resigned from DCF some
time in Feb or March, 2003, but was later re-employed by the
Department of Social Services some time after March 2003. Plaintiff
KM Dickson gave (emailed and hand-delivered) Ragaglia and others
employed by DCF these scientific documents which supported that Lyme is
a borreliosis- a permanent infection of the brain, that =E2=80=9CLyme
disease=E2=80=9D is not a controversy, but scientific fraud, that autism is=
a
pervasive development disorder, and the scientific evidence of the
brain damage caused by all psychotropics. This scientific evidence was
also on Plaintiff KM Dickson=E2=80=99s website, ActionLyme.com.
DCF, DSS, DPH, and DMHAS are in default of their basic commissions,
which are to know facts, serve and provide, based on the facts, the
science, and the state of the art, in care. They are not commissioned
to become a participants in the scientific fraud of Lyme disease.
FAILURE TO ACT IN THE INTERESTS OF THE STATE BY ATTORNEY GENERAL
RICHARD BLUMENTHAL:
23) AG RICHARD BLUMENTHAL was mailed an enormous amount of
information regarding the fraud of Lyme disease by Plaintiff KM
Dickson. R. Blumenthal held two public hearings on the mistreatment
of persons who have Lyme disease by insurance companies and Yale
University (1999 and 2004). Richard Blumenthal did not act to protect
the residents of the State of CT even when given evidence of the
perjury which occurred at one of his hearings, and as regards the NIH
Edward McSweegan and Yale=E2=80=99s Durland Fish=E2=80=99s conspiracy to se=
nd Karen
Forschner of the Lyme Disease Foundation in Hartford, CT, =E2=80=9Ca bogus
article=E2=80=9D to publish in their journal, The Journal of Spirochetal and
Tick Borne Diseases (JSTD). Yale university is involved in the
scientific fraud of Lyme Disease.
Richard Blumenthal=E2=80=99s staff lawyers referred Plaintiff KM Dickson to
the US Attorney Kevin O=E2=80=99Connor as the person with whom to file the
complaint of scientific fraud as regards Lyme disease (RICO) in July
2003. Kevin O=E2=80=99Connor=E2=80=99s wife worked in Rowland=E2=80=99s le=
gal office and
Mr. O=E2=80=99Connor had to recuse himself from the investigation of the
criminal former Governor Rowland and the activities which were
conducted from Rowland=E2=80=99s office which involved the DCF=E2=80=99s Kr=
istine
Ragaglia and others defrauding the federal government.
These communications to Richard Blumenthal regarding the Lyme
racketeering enterprise were instead used by AAG JESSICA GAUVIN to be
evidence of Plaintiff KM Dickson=E2=80=99s insanity. DMHAS=E2=80=99s Kenne=
th
Marcus testified at Plaintiff KM Dickson=E2=80=99s DCF =E2=80=9Ctrial,=E2=
=80=9D
=E2=80=9CDon=E2=80=99t look at the content=E2=80=A6,=E2=80=9D of these comm=
unications.
Plaintiff KM Dickson is a scientist. Content is of primary importance
in any scientific report. The content specified in these reports
regarding the scientific fraud in =E2=80=9CLyme Disease=E2=80=9D are why Pl=
aintiff
KM Dickson cannot get medical and special education care for herself
and her 3 children, who have Lyme disease. The =E2=80=9Ccontent=E2=80=9D
demonstrated the scientific fraud in Lyme disease, and how that
involved Yale=E2=80=99s dangerous Lyme vaccine.
Plaintiff KM Dickson asserts that it might be either perjury or
psychiatric mumbo jumbo to be saying that because the State of CT
failed to protect its citizens from the deliberate in the denial of
care for Lyme disease, and for Yale=E2=80=99s attempting to pass off a bogus
Lyme vaccine (for which adverse events were not reported to the FDA),
that the Plaintiff KM Dickson is insane to be reaching to the federal
level for protection.
SUMMARY OF THE STATE OF CONNECTICUTS FAILURES TO PROMOTE AND PROTECT
THE GENERAL WELFARE:
Lyme disease is an epidemic of a brain infection, and there is a rising
epidemic of autism, yet neither of these two illnesses are addressed
even lightly by any of the Departments of the State of Connecticut,
with the possible exception of the DEPARTMENT OF MENTAL RETARDATION
(DMR) as regards autism. The State hires experts who are completely
unfamiliar with autism as a =E2=80=9Cpervasive development disorder=E2=80=
=9D or
Lyme as a brain disease, despite these experts being associated with
the Yale Department of Psychiatry (VLADIMIR CORIC), which has an autism
clinic, and despite a report by the Yale Department of Pathology in
which the congenital brain damage from Lyme infection was listed as the
probable cause of death in one newborn and one stillborn infant.
[EXHIBIT X - Scott Murphy dataset, June 11, 2005]
Clearly the DMR needs to be explaining what a pervasive development
disorder is to the DCF, Yale Department of Psychiatry, and DMHAS.
It is inherently within the commissions of the DCF, DPH, and DMHAS to
have an understanding of, and address the needs of the disabled with
Lyme and/or Autism. Thus, they have failed their basic commissions.
The OPM is authorized to discover federal aid sources, however, MARC S.
RYAN appears to have dominantly sought increased the spending for the
DCF in House Bills 1999 5021 and HB 2001, 6999 and as is written into
the text, this increase in state spending was required to meet
increased federal spending requirements, and RAGAGLIA appears to have
added, =E2=80=9Cdue to the increase in termination of parental rights being
approved by the courts=E2=80=A6=E2=80=9D This is inconsistent with provid=
ing aid
to needy families, and which may be another deliberate fraud against
the United States of America, the Connecticut public, and the federal
government, and which resulted in a 445% increase in children taken
from their parents and the disgrace of the pediatric jail. [EXHIBIT Z
Letter to Rell, DMHAS=E2=80=99s perjury dataset, July 1, 2005]
DCF prosecutors willfully and knowingly falsely criminally charge
parents with the false allegations, hearsay, and the perjurous
testimony elicited and invented by the DCF prosecutors themselves and
their =E2=80=9Cwitnesses,=E2=80=9D and then deny the parents access to the =
courts
by declaring the parent insane to say they are innocent and threaten
their victims with being involuntarily committed if they maintain their
innocence. [EXHIBIT X (eg., Scott Murphy dataset re: Christopher
Gottschalk, Joseph More, Sam Donta, Lara, Diane and David D.)]
There is clearly a consistent pattern of criminally charging parents
with whatever is today=E2=80=99s flavor of inane crime if the parent/alleged
=E2=80=9Cperpetrator=E2=80=9D retaliates against the criminal behavior of t=
he State
of CT employees by filing the proper documents for relief from abuse
and neglect with the proper agencies.
DCF willingly and knowingly places children in dangerous homes, and
informs the children that if they complain of this abuse, they will be
placed in separate foster homes. DCF willingly and knowingly
fraudulently declares parents to be mentally ill to be filing
legitimate complaints about judges, DCF attorneys, and DCF staff to the
Commission on Human Rights and Statewide Bar Counsel, and Judicial
Review Boards, in order for the claim to be considered invalid. These
are Color of Law abuses, Conspiracy Against Rights, and violations of
the rights to Federally Protected Activities.
DCF threatens the liberties of parents, and makes it a condition of
release that the innocent parent admit guilt for the crimes they did
not commit, and that the parent may not =E2=80=9Ccriticize the government,=
=E2=80=9D
nor =E2=80=9Cfax any state, federal, or local agencies,=E2=80=9D which are =
clearly
and abundantly civil and human rights abuses, illegal, a violation of
the First Amendment, a violation of the Americans With Disabilities
Act, violations of Federally Protected Activities, Conspiracy to
Deprive of Rights, and Color of Law abuses, when the parent has Lyme
disease, and especially when the children also have Lyme disease and
can get no access to care. [EXHIBIT Z]
It is criminal child abuse to willfully deny children access to medical
care, when the denial of medical care results in a regression of
health, yet the State of Connecticut does this consistently as regards
all Lyme disease victims, including children.
These behaviors and actions of CT DCF staff are Title 18 Secs 241, 242,
and 245 criminal civil rights violations (Title 42, Sec 1983,
redundant).
------
THE CHIEF STATE=E2=80=9DS ATTORNEY CHRISTOPHER MORANO AND THE PUBLIC
DEFENDER=E2=80=99S OFFICE ON COMPENSATING COURT APPOINTED LAWYERS FOR
CHILDREN AND FAMILIES HARASSED BY DCF:
24) In default of proper protections provided by the State to families
involved with DCF in comparison to criminal cases, as stated publicly
by Chief State=E2=80=99s Attorney, Christopher Morano, and the Public
Defender=E2=80=99s office regarding court appointed attorneys, parents who
are victims of DCF=E2=80=99s abuses, in the interest of the welfare of
children and families, should expected to take humane and compassionate
action on behalf of other families who will be destroyed by the
Connecticut Department of Children and Families, without such public
exposure and restraint as otherwise afforded under the US Constitution,
but denied all Connecticut residents. These incidents reveal gross
incompetence, and criminal civil rights violations, not only on the
part of DCF staff, but also the police. Lawyers assigned to children
victimized DCF attack are paid a fraction of fees for court appointed
representation of criminal charges. These lawyers for children have
since passed legislation protecting themselves from malpractice
lawsuits by families who they inadequately represented. [EXHIBIT AA]
There is no legislative protection for the families against this
inherent, built-in, legal incompetence.
25) OTHER CASES OF THE STATE=E2=80=99S INCOMPETENCE, RETALIATION, ABUSE,
QUESTIONS OF INTEGRITY
25- A) Daniel Scruggs: In the case of the suicide of Daniel Scruggs,
the entire family was in need of services, and had been visited by DCF.
A simple $40 weekly contract with a cleaning service, in light of the
cognitive disabilities of Mrs. Scruggs and her son Daniel, provided
under the Temporary Aid for Needy Families, would have been a logical
remedy. Daniel Scruggs was depressed and was said to be mildly
autistic (newspaper article), yet no one, and in particular, no one at
DMHAS or Yale is competent to Autism/Asperger=E2=80=99s in adults. One can
assume Daniel Scruggs inherited his cognitive disabilities from either
his mother or his father (who was notably absent), yet the father
shared no liability for this tragedy. [EXHIBIT BB]
It appears that =E2=80=9CScruggs' arrest by Meriden police came six weeks
after Norris filed the notice of intent to sue the city of Meriden for
failing to protect Daniel from daily bullying.=E2=80=9D=E2=80=94not include=
d but
taken from Hartford Advocate, November 2003, =E2=80=9CEveryone was at
Fault=E2=80=9D news article.
Charging Mrs. Scruggs appears to be retaliation by the State, and an
effort to prevent legal discovery of DCF=E2=80=99s incompetence and liabili=
ty
in the death of this child. This appears to be another case of a
conspiracy to deprive of rights.
25- B) Baby Emily: In the case of Baby Emily, recently resolved by the
State of CT, =E2=80=9CA state investigation after Emily=E2=80=99s death f=
ound
that state child welfare workers knew of abuse within the infant=E2=80=99s
family and failed to protect children in the household.=E2=80=9D [EXHIBIT
CC]
This is a simple evidence point of DCF=E2=80=99s abundant incompetence.
25- C) Jennifer O=E2=80=99Connor: Mrs. O=E2=80=99Connor informed Plaintif=
f KM
Dickson that she had asked the DCF to come and give her parenting
skills in regards to herself and her daughter Sara. Approximately
April 2003. DCF came to visit Mrs. O=E2=80=99Connor, found =E2=80=9Cno abu=
se or
neglect,=E2=80=9D and declined the request for assistance. A few weeks
later, Mrs. O=E2=80=99Connor shot and killed her daughter, presumably as a
result of her deficit in parenting skills, which was not addressed by
DCF despite the specific request. Plaintiff KM Dickson feel this
behavior on the part of the DCF is consistent with the DCF staff not
understanding big words like =E2=80=9CNeuroborreliosis,=E2=80=9D which the =
DCF
staff calls =E2=80=9Cbizarre talking,=E2=80=9D and is consistent with the
acknowledgement that DCF staff needs =E2=80=9Cincreased training,=E2=80=9D =
in the
conclusion of the Juan F. case.
Mrs. O=E2=80=99Connor was diagnosed with a learning disability, as was her
daughter, and had had genetic screening prior to becoming pregnant,
Plaintiff KM Dickson was told by a friend of the family. Plaintiff KM
Dickson=E2=80=99s experience and knowledge of Autism and Asperger=E2=80=99s
disorder, leaves Plaintiff KM Dickson strongly aware that Mrs.
O=E2=80=99Connor was misdiagnosed as =E2=80=9Cmentally ill,=E2=80=9D when s=
he had
Asperger=E2=80=99s disorder, and may have been subject to malpractice, in
addition to the incompetence of the DCF staff. This conversation took
place in the jail; Plaintiff Dickson does not have access to Mrs.
O=E2=80=99Connor=E2=80=99s DCF records. Plaintiff Dickson=E2=80=99s unders=
tanding from
reading the news reports online, is that Mrs. O=E2=80=99Connor called the D=
CF
herself for assistance. This assistance was denied. The child is
dead, and Mrs. O=E2=80=99Connor is in jail instead of in an assisted living
arrangement or with assistance for herself and her daughter=E2=80=99s
learning disabilities [EXHIBIT DD]
The primary problem with DCF=E2=80=99s incompetence is never addressed: The
fact is, they don=E2=80=99t appear to understand common English. If someo=
ne
says, =E2=80=9CHelp Me,=E2=80=9D it doesn=E2=80=99t mean, =E2=80=9CBlow me=
off,=E2=80=9D and it
doesn=E2=80=99t mean, =E2=80=9CSubject my children to a traumatizing kidnap=
ping,
and give them to a known =E2=80=93to-DCF, chronic genitals-exposing,
physically violent to others, maniac (Donald G. Dickson),=E2=80=9D and it
doesn=E2=80=99t mean, =E2=80=9C=E2=80=9DIf I am sick, and sometimes need DC=
F=E2=80=99s
babysitting Respite Care, tell the courts I am insane, kidnap my kids
and give them to someone known to be a violent person, invent my crimes
and throw me in jail.=E2=80=9D If DCF is not a child welfare agency, they
should not advertise as such, and mislead the public. This is a waste
of tax dollars, not to mention children=E2=80=99s lives.
25- D) The =E2=80=9Charassing communications and threatening,=E2=80=9D wi=
th which
Plaintiff KM Dickson was falsely criminally charged are dated 14 April
2004, and are in correspondence with the US Attorney=E2=80=99s office (Kevin
O=E2=80=99Connor), and CIGNA, Plaintiff KM Dickson=E2=80=99s Pfizer disabil=
ity
insurance carrier, and which contain more newspaper articles of DCF=E2=80=
=99s
incompetence. [EXHIBIT EE]
-March 8, 2004 (Courant) =E2=80=9CDCF never asked, DPH never told of hospit=
al
problems=E2=80=9D Quote from Jeane Milstein (as regards DCF):
=E2=80=9CCommon sense would tell you to pick up the phone and do your
homework.=E2=80=9D
-March 7, 2004 (Courant) =E2=80=9CHospital Troubles Elude DCF=E2=80=9D Jeane
Milstein:
=E2=80=9CYou learn from your mistakes. You learn from what you do,=E2=80=
=99
Milstein said. =E2=80=98DCF needs to be a more responsible parent.=E2=80=99=
=E2=80=9D
-December 18, 2003, Courant =E2=80=9CMILSTEIN SUES DCF OVER AGENCY=E2=80=
=99S
TREATMENT OF ABUSED CHILD=E2=80=9D- Associated Press.
=E2=80=9CMilstein accused DCF of =E2=80=98callous and reckless indifference=
in
caring for the youth, and she suspects other children may be suffering
because of DCF=E2=80=99s missteps.=E2=80=9D
25- E) Christopher Kennedy: In the case of Mr. Christopher Kennedy,
it is Plaintiff=E2=80=99s KM Dickson=E2=80=99s belief and knowledge that th=
is
started out as a simple case of divorce, and ended with numerous
criminal charges against a man who had no criminal history until DCF
involvement. Mrs. Leanna Kennedy was arrested for second degree
assault for stabbing Mr. Christopher Kennedy. On Friday, June 30,
2005, Mr. Kennedy was charged with perjury and the bail was said to be
requested at $500,000 but was dropped to $50,000.00. To Plaintiff KM
Dickson=E2=80=99s understanding, Mr Kennedy was charged with perjury for
neglecting to mention that there had been issued a restraining order
against Mr. Kennedy. As Plaintiff KM Dickson informed CT Governor Jodi
Rell via mail, that if the State were charged at a rate of $50,000 per
incident of perjury in Plaintiff KM Dickson=E2=80=99s =E2=80=9Ccases,=E2=80=
=9D the State
would owe a debt in the range of $50,000,000.00. [EXHIBIT FF- 1,- 2]
Mr. Kennedy=E2=80=99s wife has been arrested for stabbing Mr. Kennedy.
Plaintiff KM Dickson is not aware of Mr. Kennedy stabbing Mrs. Kennedy,
yet Mr. Kennedy is facing jail time for false criminal charges. DCF
was =E2=80=9Cinvolved.=E2=80=9D
Although Mr. Kennedy sought redress directly with the present
Governor=E2=80=99s Chief Legal Counsel, Kevin J. Rasch, Mr. Kennedy was
instead charged with perjury.
25- F) In comparison, to the above Christopher Kennedy Perjury case,
MR. JOHN G. ROWLAND defrauded the federal court in his financial
affidavit regarding his income, yet no charges were filed. Mr.
Rowland=E2=80=99s sentence was not compounded for nearly the same negligent
=E2=80=9Cperjury=E2=80=9D with which Mr. Kennedy is charged. [EXHIBIT GG]
=E2=80=9CBut federal prosecutors were disappointed. On Thursday, the U.S.
attorney's office had urged Dorsey to put Rowland in prison for up to
37 months, saying that the office had learned that Rowland had tried to
conceal a $416,000 personal retirement account from federal officials.
By portraying his financial condition as increasingly dire, prosecutors
said, Rowland was trying to generate leniency from the court=E2=80=9D---
Hartford Courant March 19, 2005
25- G) It is noteworthy that as regards Governor Rell and her son=E2=80=99s
behaviors, from CORPORATE CRIME REPORTER
http://www.corporatecrimereporter.c...ryinterview.htm
=E2=80=9CCCR: If he is impeached or resigns, what is the provision in
Connecticut law for an emergency election?
CURRY: There isn't one. It's one of the questions I've raised with
people in the last few weeks. As in most states, the Lt. Governor takes
over. I think that's a mistake. I think we designed the offices of vice
president and Lt. Governor with an eye to the death or incapacity of
the President or Governor.
I believe that when a chief executive is marched out of office for
impeachable offenses, we should have an election to fill the remainder
of the term. The idea that a member of Rowland's posse simply follows
in Rowland's footsteps is a bad one.
CCR: Has the Lt. Governor, Jodi Rell, been implicated?
CURRY: When her son was found by state environmental officers to be
running a stolen property ring out of her basement for Skidoos, the
environmental officers who made the arrests had their careers
threatened.
They suffered until it hit the press and then the administration backed
off. She denied any involvement in the retaliation. Again,
Connecticut's extraordinary unwillingness to investigate the apparent
corruption of its own elected officials saved her from further public
embarrassment.
In any event, she has been a happy, willing partner and an insider in
the Rowland administration for nine years.=E2=80=9D
this at least gives the suggestion that the State of Connecticut is
corrupt, and to include the present Governor. [EXHIBIT HH Corporate
Crime Reporter, Curry Interview]
25- H) The Saraceno Case: Plaintiff KM Dickson suspects the integrity
of Chief State=E2=80=99s Attorney Christopher Morano due to what we learned
in the Hartford Courant=E2=80=99s Northeast Magazine, Jan 9, 2005, regarding
the Saraceno boy=E2=80=99s case:
=E2=80=9CSaraceno was convicted and imprisoned but later released after a
private investigation discovered that the prosecutor was protecting
four other young men who almost certainly did the crime. The chief
state=E2=80=99s attorney=E2=80=99s office uncomfortably joined in the defen=
se in a
motion to overturn the conviction. That should have freed the youth
from further jeopardy. Instead, in 1999, under threat of extending the
legal nightmare that had already cost his parents $100,000, Saraceno
accepted guilt for =E2=80=9Chindering prosecution by falsely confessing. =
=E2=80=9D
Under the statute of limitations, the state had allowed the five-year
window for prosecuting the known suspects to close. No one except the
wrong man did jail time for the crime. The law officer most
responsible for compelling Saraceno to declare it was his fault is
Chief State=E2=80=99s Attorney Christopher Morano=E2=80=9D.
25- I) The Office of Public Integrity: Mr. Christopher Morano, the
Chief State=E2=80=99s Attorney has an Office of Public Integrity, yet Morano
never responded to the integrity complaints lodged by Plaintiff KM
Dickson as regards the bizarre and discriminatory behavior of DCF
staff.
25- J) CHRISTOPHER MORANO=E2=80=99S BIRTHDAY PARTY, FROM THE WEBSITE: CRIME
AND FEDERALISM, by Norm Pattis:
March 29, 2005 in Federal Courts | Permalink | Comments (5) | TrackBack
But the Governor did it?
Norm Pattis
Connecticut calls itself the Land of Steady Habits. In recent years,
those habits have evolved to graft among its public officials. Why just
the other day, former Governor John G. Rowland was sentenced to federal
prison for a brief stretch. He couldn't keep distinct in his mind his
official duties and gorging himself at the public trough.
After his guilty plea and resignation from office, he kept on grabbing
cash. He raked in about $15,000 a month as a consultant to private
industry on, of all things, government. Now the Connecticut General
Assembly wants to take a look at why felons are hired as consultants.
Oink, Oink, Oink
Now comes news that a prosecutor may not have been able to avoid all
the fun. Supervisory Assistant State's Attorney David Newman of New
Haven is under the microscope, according to the Chief State's
Attorney's Office. Suspicions that all is not well in the historic Elm
Street courthouse. According to the New Haven Register, questions have
arisen about whether Mr. Newman regards himself as a legitimate
beneficiary of charitable contributions intended to resolve minor
offenses. Charity for a Day
Newman has hired criminal defense lawyer Hugh Keefe, who tried to waive
off the scandal as an "internal employment matter." Well, that's one
spin. But Keefe is known for his defense of police officers in claims
arising under 42 U.S.C. Section 1983 and for defending those accused of
crimes. He's no employment lawyer.I Want Mine, Too
This comes on the heels of a report that a former prosecutor was
arrested leaving the 50th birthday party of Chief States Attorney
Christopher Morano. The former lawman was drunk, was carrying a little
reefer, and was armed. He's now asking the court for a diversionary
program that would permit the record of his arrest to be erased after a
brief period of probation.
Wow. I guess there's no place like home for white collar crime, and, if
you know the right people it seems that just about anything is
possible.
March 29, 2005 | Permalink | Comments (2) | TrackBack
Plaintiff KM Dickson would only add the comment that the residents of
the State of CT would wonder how often these prosecutors get together
to party, and what they discuss. CT State prosecutors breaking the law
is the nature of this complaint. We victims of their crimes only wish
the vast majority of crimes committed by State prosecutors and other
state employees was limited to smoking marijuana.
25- K) FALSE ARREST, NOT INVOLVING DCF: Steven G. Erickson. In
the case of Steven G. Erickson, It is Plaintiff KM Dickson=E2=80=99s belief
and knowledge that the testimony of Steven G. Erickson was truthful, in
that Erickson believes that he wasn=E2=80=99t getting equal protection and
service being a Stafford Springs downtown Connecticut landlord.
Mr. Erickson, formerly of Stafford, CT, wrote letters to the editor
critical of police and Connecticut courts and wrote President Bush a
letter about how the economy was hurt by downtown (Stafford) property
and small business owners getting a fair shake in courts and adequate
police help and service. Mr. Erickson proposed Civilian Oversight of
Police to State Senator Tony Guglielmo and former State Representative
Mordasky. Mordasky=E2=80=99s aid, =E2=80=9CRosemarie,=E2=80=9D advised Eri=
ckson that
Erickson should sell his property and leave Connecticut before the
Connecticut State Police retaliated for the laws Erickson proposed
directing police powers, and for what Mr. Erickson had written critical
of police in newspapers, and for being a =E2=80=9CBig Mouth.=E2=80=9D
Mr. Erickson also attests that the Connecticut State Police were
bragging that Mr. Erickson would be going to prison and run out of town
after Erickson was attacked by Brian Caldwell on Erickson=E2=80=99s property
when Erickson returned home from a double shift of work. Caldwell had
told Erickson=E2=80=99s tenants Caldwell would kill Erickson when Erickson
got home, and had threatened Erickson, harassed Erickson via voicemail,
and beating on Erickson door after midnight, yelling that Caldwell,
would cut Erickson=E2=80=99s penis off if Caldwell caught Erickson outside
Erickson=E2=80=99s home.
According to Mr. Erickson, Connecticut State Troopers, Amaral and
Langlais refused to take Erickson=E2=80=99s complaint against Erickson=E2=
=80=99s
assailant who had jumped Erickson and tried to rob Erickson, nor would
they take the complaint of witness Sue Johnston, nor that of Clayton
Varno. Instead the police only arrested Erickson, refusing to view
Erickson=E2=80=99s injuries, and then later committing perjury of these fac=
ts
to get me convicted of overreacting to being beaten during a robbery
attempt using pepper spray.
Apparently, Judge Jonathan Kaplan of Rockville Connecticut Court stated
that Erickson was guilty and was going to prison before Erickson=E2=80=99s
trial began. A videotape was shown to the jury of how to find Erickson
guilty, but nothing about innocence or reasonable doubt, tainting them.
(XXX, evidence #)
It is Erickson=E2=80=99s belief that Judge Kaplan informed Erickson=E2=80=
=99s
attorney, Michael H. Agranoff (Stafford, CT), that Agranoff was not
allowed to dispute police perjury, the prosecution, nor defend
Erickson.
Erickson sent an email to the former Connecticut State Police
Commission Arthur L. Spada in late October 2002, the day before
Erickson was to be sentenced, asking Spada to remove the US Department
of Justice webpage on Community Policing off the Connecticut State
Police website, stating the policies were not being followed. Erickson
indicated that Erickson was sending a copy of the email to the US
Department of Justice.
Erickson believes the Connecticut State Police, the prosecutors,
Erickson=E2=80=99s lawyer, and Judge Jonathan Kaplan were acting in collusi=
on
to ensure Erickson=E2=80=99s conviction to prevent Erickson from suing for
Civil Rights violations and to keep Erickson from lodging complaints
and exposing corruption within the courts and Connecticut State Police.
Erickson further asserts that Judge Jonathan Kaplan appeared to
reference the email Erickson sent to Commissioner Spada at
Plaintiff=E2=80=99s sentencing, indicating to Erickson their was illegal
collusion between Judge Jonathan J. Kaplan and Connecticut State Police
Officers to ensure Erickson was convicted and given the maximum
penalties allowed.
Mr. Erickson was sent to an overcrowded prison and was singled out for
abuse by guards referencing Erickson=E2=80=99s feud with the Connecticut
State Police. Mr. Erickson was held in prison longer than his stated
release date, wasn=E2=80=99t allowed to take classes in prison as further
harassment, and was told that Erickson wasn=E2=80=99t allowed in Stafford,
Connecticut upon release by LT Desso, also a Stafford town police
officer.
Mr. Erickson asserts that he was told by his parole officer at the
Enfield Police Station, that Erickson wasn=E2=80=99t allowed to make
complaints against police officers, nor contact the media regarding
Erickson=E2=80=99s case or face more prison time. These are clearly federal
color of law, deprivation of rights, and violation of federally
protected activities, and first amendment violations.
When Mr. Erickson was turned over to adult probation in Manchester
Connecticut, Erickson was given told by Angela K. that she would
violate Erickson=E2=80=99s probation if she received any more calls regardi=
ng
Erickson and would violate Erickson=E2=80=99s probation if Erickson didn=E2=
=80=99t
leave the State of Connecticut. Mr. Erickson was given an hour to
pack and leave the State of Connecticut to avoid further persecution
and fraudulent prosecution.
25-J) Jeffrey Yeaw To Plaintiff KM Dickson=E2=80=99s belief and
knowledge, Mr. Yeaw was not provided equal protection under the law,
was deprived of his civil rights, as were his children. These children
were not reported as physically harmed or neglected by Mr. Yeaw in any
way. This family=E2=80=99s tragedy was another color of law abuse and
illegitimate traumatization to children. Mr. Yeaw was arrested, and
not his wife, when all known reports are clear and convincing, that
Mrs. Yeaw was physically violent to her husband, and initiated an
altercation. Mr. Yeaw=E2=80=99s children were taken by DCF, and Mr. Yeaw,
being of sound mind and familiar with DCF abuses, merely rescued these
children. Instead he was charged with the =E2=80=9Ccrime=E2=80=9D of abduc=
ting his
own children. [EXHIBITS II]
Plaintiff KM Dickson wishes she had the courage to rescue her own
children, but it never occurred to this Plaintiff. At that, Plaintiff
Dickson never anticipated her children being taken, since there was no
abuse or neglect going on, and everyone knew it. DCF threw out their
first petition against this Plaintiff and wrote a new one.
Now Mr. Yeaw faces years in prison, because his wife attacked him, and
he left the house in response. The present Governor, Rell, publicly
commented on this crime, when she did not know it was not a crime.
This is disheartening to CT residents, since we had faith that this
replacement Governor, Mrs. Rell, for Governor Rowland, was Number One,
a woman, and Number Two, got rid of a number of the cronies hired by
Rowland. Rell did not get rid of DMHAS=E2=80=99 or DCF=E2=80=99s commissio=
ners,
however, when we know both agencies are abundant and obvious failures.
No one should have been arrested in any of these =E2=80=9Ccases.=E2=80=9D W=
ere it
not for the incompetence and abuse by DCF and the prosecutorial madness
in the State of Connecticut, and were it not for the failure of the
mental health system, some of these cases would, from an outside
observer, appear be family arguments. Instead, they became obvious
cases of discrimination and retaliation, and then numerous and extreme
civil rights violations, including false criminal charges, prison
sentences and threats of permanent incarceration, under the apparently
Secret Connecticut =E2=80=9CWe=E2=80=99ll Commit You Permanently and Take Y=
our
House and Income if You Don=E2=80=99t Shut Up, by Inventing Your Crimes, a=
nd
then Committing You to a Psychiatric Hospital, Indefinitely, For Saying
You Are Innocent=E2=80=9D Act.
That the DCF would record family arguments as neglect of children,
implies that nearly all Connecticut children would have to be removed
from their parents.
Given DCF=E2=80=99s civil rights violations and false criminal charges, to
known and unknown numbers of parents and children, and the fact that
the DCF is well-known to be =E2=80=9Carrogant and inept,=E2=80=9D as regards
children and families, Jeffrey Yeaw was competent, correct, sane,
protective, caring and fully within his rights to rescue his children
from the abomination known as the CT Department of Children and
Families.
It is Plaintiff KM Dickson=E2=80=99s belief that the evidence submitted
supports that no children are safe in DCF=E2=80=99s =E2=80=9Ccare,=E2=80=9D=
and due to
the presence of the Rowlandgate Appointee US Attorney Kevin O=E2=80=99Conno=
r,
justice cannot be gained in the US Department of Justice District of
Connecticut.
-----------------------------------------
DAMAGES AND RELIEF REQUESTED
1) The Connecticut Department of Children and Families is to be
dissolved completely and all related DCF statutes stricken from
Connecticut General Statutes.
2) $100,000,000 in pain and restitution of costs to Plaintiff Dickson
and her children from the State of Connecticut.
3) The establishment of a research clinic and hospital for vector borne
diseases, in Connecticut, to be named the Hospital of the Immaculate
Heart, with the funds recovered in the discovery of scientific fraud
committed by Yale University, the Yale Corporation, and to include the
criminal prosecution of all Yale- and Lyme-related perjury anywhere to
be found in America.
Plaintiff Dickson will manage this organization, which will restore the
earlier meanings of =E2=80=9Ccare=E2=80=9D and =E2=80=9Cintegrity=E2=80=9D =
to the English
language.
The $100,000,000 million in damages from the State granted to the
Plaintiff shall be donated to this establishment, the Hospital of the
Immaculate Heart.
4) AAG Jessica Gauvin is to be criminally charged with making false
statements to police and Gauvin shall be asked to leave the State of CT
permanently after her criminal sentencing.
5) A forum for redress of all DCF perjury committed in the last 15
years, and the return of fraudulently taken children by CT DCF.
6) The prosecution of MARC S. RYAN and KRISTINE RAGAGLIA for conspiring
to defraud the federal government as regards child welfare, and the
incarceration of children as policy, over care.
7) Federal oversight of the CT Department of Justice, and the Chief
State=E2=80=99s Attorney=E2=80=99s Office.
8) The return of Plaintiff KM Dickson=E2=80=99s children to Plaintiff KM
Dickson=E2=80=99s care, and in sole custody.
Signed this _________ day of _____________, 2005
______________________
Kathleen M. Dickson, et al
23 Garden Street
Pawcatuck, CT 06379
________________________
Lara E. Dickson
________________________
Diane M. Dickson
_________________________
David D. Dickson
DEFINITIONS AND STATUTES
ADA Title II: State and Local Government Activities
Title II covers all activities of State and local governments
regardless of the government entity's size or receipt of Federal
funding. Title II requires that State and local governments give people
with disabilities an equal opportunity to benefit from all of their
programs, services, and activities (e.g. public education, employment,
transportation, recreation, health care, social services, courts,
voting, and town meetings).
State and local governments are required to follow specific
architectural standards in the new construction and alteration of their
buildings. They also must relocate programs or otherwise provide access
in inaccessible older buildings, and communicate effectively with
people who have hearing, vision, or speech disabilities. Public
entities are not required to take actions that would result in undue
financial and administrative burdens. They are required to make
reasonable modifications to policies, practices, and procedures where
necessary to avoid discrimination, unless they can demonstrate that
doing so would fundamentally alter the nature of the service, program,
or activity being provided.
ADA Title II: State and Local Government Activities
Title II covers all activities of State and local governments
regardless of the government entity's size or receipt of Federal
funding. Title II requires that State and local governments give people
with disabilities an equal opportunity to benefit from all of their
programs, services, and activities (e.g. public education, employment,
transportation, recreation, health care, social services, courts,
voting, and town meetings).
State and local governments are required to follow specific
architectural standards in the new construction and alteration of their
buildings. They also must relocate programs or otherwise provide access
in inaccessible older buildings, and communicate effectively with
people who have hearing, vision, or speech disabilities. Public
entities are not required to take actions that would result in undue
financial and administrative burdens. They are required to make
reasonable modifications to policies, practices, and procedures where
necessary to avoid discrimination, unless they can demonstrate that
doing so would fundamentally alter the nature of the service, program,
or activity being provided.
DEFINITIONS:
Connecticut Chapter 319 Sec. 17b-608. (Formerly Sec. 17-608). Persons
with disabilities. Definition. For the purposes of sections 17b-609 and
17b-610, "persons with disabilities" shall mean persons having
disabilities which (1) are attributable to a mental or physical
impairment or a combination of mental and physical impairments; (2) are
likely to continue indefinitely; (3) result in functional limitations
in one or more of the following areas of major life activity: Self
care, receptive and expressive language, learning, mobility,
self-direction, capacity for independent living or economic
self-sufficiency; and (4) reflect the person's need for a combination
and sequence of special, interdisciplinary or generic care, treatment
or other services which are of lifelong or extended duration and
individually planned and coordinated.
CONSPIRACY AGAINST RIGHTS
Summary:
Section 241 of Title 18 is the civil rights conspiracy statute. Section
241 makes it unlawful for two or more persons to agree together to
injure, threaten, or intimidate a person in any state, territory or
district in the free exercise or enjoyment of any right or privilege
secured to him/her by the Constitution or the laws of the Unites
States, (or because of his/her having exercised the same). Unlike most
conspiracy statutes, Section 241 does not require that one of the
conspirators commit an overt act prior to the conspiracy becoming a
crime.
The offense is punishable by a range of imprisonment up to a life term
or the death penalty, depending upon the circumstances of the crime,
and the resulting injury, if any.
TITLE 18, U.S.C., SECTION 241
If two or more persons conspire to injure, oppress, threaten, or
intimidate any person in any State, Territory, Commonwealth,
Possession, or District in the free exercise or enjoyment of any right
or privilege secured to him by the Constitution or laws of the United
States, or because of his having so exercised the same;...
They shall be fined under this title or imprisoned not more than ten
years, or both; and if death results from the acts committed in
violation of this section or if such acts include kidnapping or an
attempt to kidnap, aggravated sexual abuse or an attempt to commit
aggravated sexual abuse, or an attempt to kill, they shall be fined
under this title or imprisoned for any term of years or for life, or
both, or may be sentenced to death.
--------------------------------
DEPRIVATION OF RIGHTS UNDER COLOR OF LAW
Summary:
Section 242 of Title 18 makes it a crime for a person acting under
color of any law to willfully deprive a person of a right or privilege
protected by the Constitution or laws of the United States.
For the purpose of Section 242, acts under "color of law" include acts
not only done by federal, state, or local officials within the their
lawful authority, but also acts done beyond the bounds of that
official's lawful authority, if the acts are done while the official is
purporting to or pretending to act in the performance of his/her
official duties. Persons acting under color of law within the meaning
of this statute include police officers, prisons guards and other law
enforcement officials, as well as judges, care providers in public
health facilities, and others who are acting as public officials. It is
not necessary that the crime be motivated by animus toward the race,
color, religion, sex, handicap, familial status or national origin of
the victim.
The offense is punishable by a range of imprisonment up to a life term,
or the death penalty, depending upon the circumstances of the crime,
and the resulting injury, if any.
TITLE 18, U.S.C., SECTION 242
Whoever, under color of any law, statute, ordinance, regulation, or
custom, willfully subjects any person in any State, Territory,
Commonwealth, Possession, or District to the deprivation of any rights,
privileges, or immunities secured or protected by the Constitution or
laws of the United States, ... shall be fined under this title or
imprisoned not more than one year, or both; and if bodily injury
results from the acts committed in violation of this section or if such
acts include the use, attempted use, or threatened use of a dangerous
weapon, explosives, or fire, shall be fined under this title or
imprisoned not more than ten years, or both; and if death results from
the acts committed in violation of this section or if such acts include
kidnaping or an attempt to kidnap, aggravated sexual abuse, or an
attempt to commit aggravated sexual abuse, or an attempt to kill, shall
be fined under this title, or imprisoned for any term of years or for
life, or both, or may be sentenced to death.
FEDERALLY PROTECTED ACTIVITIES
Summary:
The portion of Section 245 of Title 18 which is primarily enforced by
the Criminal Section makes it unlawful to willfully injure, intimidate
or interfere with any person, or to attempt to do so, by force or
threat of force, because of that other person's race, color, religion
or national origin and because of his/her activity as one of the
following:
o A student at or applicant for admission to a public school or public
college
o A participant in a benefit, service, privilege, program, facility or
activity provided or administered by a state or local government
o An applicant for private or state employment; a private or state
employee; a member or applicant for membership in a labor organization
or hiring hall; or an applicant for employment through an employment
agency, labor organization or hiring hall
o A juror or prospective juror in state court
o A traveler or user of a facility of interstate commerce or common
carrier
o A patron of a public accommodation or place of exhibition or
entertainment, including hotels, motels, restaurants, lunchrooms, bars,
gas stations, theaters, concert halls, sports arenas or stadiums.
This statute also prohibits wilful interference, by force or threat of
force, with a person because he/she is or was participating in, or
aiding or encouraging other persons to participate in any of the
benefits or activities listed above without discrimination as to race,
color, religion, or national origin.
The offense is punishable by a range of imprisonment up to a life term,
or the death penalty, depending upon the circumstances of the crime,
and the resulting injury, if any.
TITLE 18, U.S.C., SECTION 245
(a)(1)Nothing in this section shall be construed as indicating an
intent on the part of Congress to prevent any State, any possession or
Commonwealth of the United States, or the District of Columbia, from
exercising jurisdiction over any offense over which it would have
jurisdiction in the absence of this section, nor shall anything in this
section be construed as depriving State and local law enforcement
authorities of responsibility for prosecuting acts that may be
violations of this section and that are violations of State and local
law. No prosecution of any offense described in this section shall be
undertaken by the United States except upon the certification in
writing of the Attorney General, the Deputy Attorney General, the
Associate Attorney General, or any Assistant Attorney General specially
designated by the Attorney General that in his judgment a prosecution
by the United States is in the public interest and necessary to secure
substantial justice, which function of certification may not be
delegated.
(2) Nothing in this subsection shall be construed to limit the
authority of Federal officers, or a Federal grand jury, to investigate
possible violations of this section.
(b)Whoever, whether or not acting under color of law, by force or
threat of force willfully injures, intimidates or interferes with, or
attempts to injure, intimidate or interfere with--
(1)any person because he is or has been, or in order to intimidate such
person or any other person or any class of persons from--
(A) voting or qualifying to vote, qualifying or campaigning as a
candidate for elective office, or qualifying or acting as a poll
watcher, or any legally authorized election official, in any primary,
special, or general election;
(B) participating in or enjoying any benefit, service, privilege,
program, facility, or activity provided or administered by the United
States;
(C) applying for or enjoying employment, or any perquisite thereof, by
any agency of the United States;
(D) serving, or attending upon any court in connection with possible
service, as a grand or petit juror in any court of the United States;
(E) participating in or enjoying the benefits of any program or
activity receiving Federal financial assistance; or
(2) any person because of his race, color, religion or national origin
and because he is or has been--
(A) enrolling in or attending any public school or public college;
(B) participating in or enjoying any benefit, service, privilege,
program, facility or activity provided or administered by any State or
subdivision thereof;
(C) applying for or enjoying employment, or any perquisite thereof, by
any private employer or any agency of any State or subdivision thereof,
or joining or using the services or advantages of any labor
organization, hiring hall, or employment agency;
(D) serving, or attending upon any court of any State in connection
with possible service, as a grand or petit juror,
(E) traveling in or using any facility of interstate commerce, or using
any vehicle, terminal, or facility of any common carrier by motor,
rail, water, or air;
(F) enjoying the goods, services, facilities, privileges, advantages,
or accommodations of any inn, hotel, motel, or other establishment
which provides lodging to transient guests, or of any restaurant,
cafeteria, lunchroom, lunch counter, soda fountain, or other facility
which serves the public and which is principally engaged in selling
food or beverages for consumption on the premises, or of any gasoline
station, or of any motion picture house, theater, concert hall, sports
arena, stadium, or any other place of exhibition or entertainment which
serves the public, or of any other establishment which serves the
public and (i) which is located within the premises of any of the
aforesaid establishments or within the premises of which is physically
located any of the aforesaid establishments, and (ii) which holds
itself out as serving patrons of such establishments; or
(3) during or incident to a riot or civil disorder, any person engaged
in a business in commerce or affecting commerce, including, but not
limited to, any person engaged in a business which sells or offers for
sale to interstate travelers a substantial portion of the articles,
commodities, or services which it sells or where a substantial portion
of the articles or commodities which it sells or offers for sale have
moved in commerce; or
(4) any person because he is or has been, or in order to intimidate
such person or any other person or any class of persons from--
(A) participating, without discrimination on account of race, color,
religion or national origin, in any of the benefits or activities
described in subparagraphs (1)(A) through (1)(E) or subparagraphs
(2)(A) through (2)(F); or
(B) affording another person or class of persons opportunity or
protection to so participate; or
(5) any citizen because he is or has been, or in order to intimidate
such citizen or any other citizen from lawfully aiding or encouraging
other persons to participate, without discrimination on account of
race, color, religion or national origin, in any of the benefits or
activities described in subparagraphs (1)(A) through (1)(E) or
subparagraphs (2)(A) through (2)(F), or participating lawfully in
speech or peaceful assembly opposing any denial of the opportunity to
so participate--
shall be fined under this title, or imprisoned not more than one year,
or both; and if bodily injury results from the acts committed in
violation of this section or if such acts include the use, attempted
use, or threatened use of a dangerous weapon, explosives, or fire shall
be fined under this title, or imprisoned not more than ten years, or
both; and if death results from the acts committed in violation of this
section or if such acts include kidnaping or an attempt to kidnap,
aggravated sexual abuse or an attempt to commit aggravated sexual
abuse, or an attempt to kill, shall be fined under this title or
imprisoned for any term of years or for life, or both, or may be
sentenced to death. As used in this section, the term "participating
lawfully in speech or peaceful assembly" shall not mean the aiding,
abetting, or inciting of other persons to riot or to commit any act of
physical violence upon any individual or against any real or personal
property in furtherance of a riot. Nothing in subparagraph (2)(F) or
(4)(A) of this subsection shall apply to the proprietor of any
establishment which provides lodging to transient guests, or to any
employee acting on behalf of such proprietor, with respect to the
enjoyment of the goods, services, facilities, privileges, advantages,
or accommodations of such establishment if such establishment is
located within a building which contains not more than five rooms for
rent or hire and which is actually occupied by the proprietor as his
residence.
(c) Nothing in this section shall be construed so as to deter any law
enforcement officer from lawfully carrying out the duties of his
office; and no law enforcement officer shall be considered to be in
violation of this section for lawfully carrying out the duties of his
office or lawfully enforcing ordinances and laws of the United States,
the District of Columbia, any of the several States, or any political
subdivision of a State. For purposes of the preceding sentence, the
term "law enforcement officer" means any officer of the United States,
the District of Columbia, a State, or political subdivision of a State,
who is empowered by law to conduct investigations of, or make arrests
because of, offenses against the United States, the District of
Columbia, a State, or a political subdivision of a State.
(d) For purposes of this section, the term "State" includes a State of
the United States, the District of Columbia, and any commonwealth,
territory, or possession of the United States.
DEFINITIONS:
Connecticut Chapter 319 Sec. 17b-608. (Formerly Sec. 17-608). Persons
with disabilities. Definition. For the purposes of sections 17b-609 and
17b-610, "persons with disabilities" shall mean persons having
disabilities which (1) are attributable to a mental or physical
impairment or a combination of mental and physical impairments; (2) are
likely to continue indefinitely; (3) result in functional limitations
in one or more of the following areas of major life activity: Self
care, receptive and expressive language, learning, mobility,
self-direction, capacity for independent living or economic
self-sufficiency; and (4) reflect the person's need for a combination
and sequence of special, interdisciplinary or generic care, treatment
or other services which are of lifelong or extended duration and
individually planned and coordinated.
CONNECTICUT STATUTES
Connecticut Chapter 368a Sec. 19a-6. (Formerly Sec. 19-4a).
Commissioner to plan and administer programs for control and treatment
of lung disease and chronic illness and for medical rehabilitation. (a)
The commissioner shall be responsible for planning state-wide programs
for the control and treatment of lung diseases; the treatment of
persons affected with other chronic illness, and the medical
rehabilitation of chronically ill, physically disabled and handicapped
persons. The commissioner shall provide and maintain facilities and
personnel for the diagnosis or detection and treatment of such diseases
or enter into contracts for the provision of diagnostic and treatment
programs for such diseases with persons or organizations capable in his
judgment of providing such services.
Chapter 50* Office of Policy and Management Sec. 4-66a. Secretary to
advise Governor and General Assembly on matters concerning local
government and matters affecting the state. Planning, management and
technical assistance for local governments. Federal financial
assistance and funds, and financial assistance and aid from private
sources. (a) The Secretary of the Office of Policy and Management shall
advise the Governor on matters concerning local government including
state laws relating to local government, the impact of federal actions
or proposed federal actions on local government, the financial needs
and resources of local government and the allocation of program and
financial responsibility between local government and the state.
(b) The secretary shall advise the Governor regarding potential
federal actions affecting state government and the citizens of the
state and shall advise the joint standing committees of the General
Assembly having cognizance of matters relating to appropriations and
relating to the subject area of each federal policy initiative,
including the allocation of resources in the federal budget, federal
public assistance policy, federal economic policy and the distribution
of federal assistance and facilities among regions and states.
(c) The secretary may provide planning and management assistance
to local governments utilizing such state and federal funds as may be
appropriated for such purpose. =E2=80=A6
Sec. 17b-3. Commissioner of Social Services: Powers and duties. (a) The
Commissioner of Social Services shall administer all law under the
jurisdiction of the Department of Social Services. The commissioner
shall have the power and duty to do the following: (1) Administer,
coordinate and direct the operation of the department; (2) adopt and
enforce regulations, in accordance with chapter 54, as are necessary to
implement the purposes of the department as established by statute; (3)
establish rules for the internal operation and administration of the
department; (4) establish and develop programs and administer services
to achieve the purposes of the department as established by statute;
(5) contract for facilities, services and programs to implement the
purposes of the department as established by statute; (6) process
applications and requests for services promptly; (7) make no duplicate
awards for items of assistance once granted, except for replacement of
lost or stolen checks on which payment has been stopped; (8) promote
economic self-sufficiency where appropriate in the department's
programs, policies, practices and staff interactions with recipients;
(9) act as advocate for the need of more comprehensive and coordinated
programs for persons served by the department; (10) plan services and
programs for persons served by the department; (11) coordinate outreach
activities by public and private agencies assisting persons served by
the department; (12) consult and cooperate with area and private
planning agencies; (13) advise and inform municipal officials and
officials of social service agencies about social service programs and
collect and disseminate information pertaining thereto, including
information about federal, state, municipal and private assistance
programs and services; (14) encourage and facilitate effective
communication and coordination among federal, state, municipal and
private agencies; (15) inquire into the utilization of state and
federal government resources which offer solutions to problems of the
delivery of social services; (16) conduct, encourage and maintain
research and studies relating to social services development; (17)
prepare, review and encourage model comprehensive social service
programs; (18) maintain an inventory of data and information and act as
a clearing house and referral agency for information on state and
federal programs and services; and (19) conduct, encourage and maintain
research and studies and advise municipal officials and officials of
social service agencies about forms of intergovernmental cooperation
and coordination between public and private agencies designed to
advance social service programs. The commissioner may require notice of
the submission of all applications by municipalities, any agency
thereof, and social service agencies, for federal and state financial
assistance to carry out social services. The commissioner shall
establish state-wide and regional advisory councils.
(b) The Commissioner of Social Services is authorized to do all
things necessary to apply for, qualify for and accept any federal funds
made available or allotted under any federal act for social service
development, or any other projects, programs or activities which may be
established by federal law, for any of the purposes or activities
related thereto, and said commissioner shall administer any such funds
allotted to the department in accordance with federal law. The
commissioner may enter into contracts with the federal government
concerning the use and repayment of such funds under any such federal
act, the prosecution of the work under any such contract and the
establishment of and disbursement from a separate account in which
federal and state funds estimated to be required for plan preparation
or other eligible activities under such federal act shall be kept. Said
account shall not be a part of the General Fund of the state or any
subdivision of the state.
Section 1983. Civil action for deprivation of rights
Every person who, under color of any statute, ordinance,
regulation, custom, or usage, of any State or Territory or the District
of Columbia, subjects, or causes to be subjected, any citizen of the
United States or other person within the jurisdiction thereof to the
deprivation of any rights, privileges, or immunities secured by the
Constitution and laws, shall be liable to the party injured in an
action at law, suit in equity, or other proper proceeding for redress,
except that in any action brought against a judicial officer for an act
or omission taken in such officer's judicial capacity, injunctive
relief shall not be granted unless a declaratory decree was violated
or declaratory relief was unavailable. For the purposes of this
section, any Act of Congress applicable exclusively to the District of
Columbia shall be considered to be a statute of the District of
Columbia.
=EF=82=B7 United States Code TITLE 42 - THE PUBLIC HEALTH AND WELFARE
CHAPTER 21 - CIVIL RIGHTS,
SUBCHAPTER V - FEDERALLY ASSISTED PROGRAMS
Section 2000d-4a. ''Program or activity'' and ''program'' defined
For the purposes of this subchapter, the term ''program or
activity'' and the term ''program'' mean all of the operations of =E2=80=93
(1)(A) a department, agency, special purpose district, or other
instrumentality of a State or of a local government; or
(B) the entity of such State or local government that
distributes such assistance and each such department or agency (and
each other State or local government entity) to which the assistance is
extended, in the case of assistance to a State or local government;
(2)(A) a college, university, or other postsecondary
institution, or a public system of higher education; or
(B) a local educational agency (as defined in section 7801 of
title 20), system of vocational education, or other school system;
(3)(A) an entire corporation, partnership, or other private
organization, or an entire sole proprietorship -
(i) if assistance is extended to such corporation,
partnership, private organization, or sole proprietorship as a
whole; or
(ii) which is principally engaged in the business of providing
education, health care, housing, social services, or parks and
recreation; or
(B) the entire plant or other comparable, geographically
separate facility to which Federal financial assistance is extended, in
the case of any other corporation, partnership, private organization,
or sole proprietorship; or
(4) any other entity which is established by two or more of the
entities described in paragraph (1), (2), or (3);
any part of which is extended Federal financial assistance.
CERIFICATION
This certifies that this complaint was sent to
CT Attorney General Richard Blumenthal
55 Elm Street
Hartford, CT 06106
---------------------------------------
Kathleen M. Dickson, et al,
23 Garden Street
Pawcatuck, CT 06379
And in the cause of a class action on behalf of other victims of the
State of Connecticut=E2=80=99s employees=E2=80=99 crimes.
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