This document rebutts attorney Lisa Coogle Rambo's attempt to not be held liable for her crimes against the Cross family in Macon County Georgia. Lisa C. Rambo had one of the Cross's son's kidnapped in order to embezzle public funds. This document is part of a title 42 section 1983 civil claim.
Título original
Rebuttal to defendant Lisa Rambo's motion to dismiss
This document rebutts attorney Lisa Coogle Rambo's attempt to not be held liable for her crimes against the Cross family in Macon County Georgia. Lisa C. Rambo had one of the Cross's son's kidnapped in order to embezzle public funds. This document is part of a title 42 section 1983 civil claim.
This document rebutts attorney Lisa Coogle Rambo's attempt to not be held liable for her crimes against the Cross family in Macon County Georgia. Lisa C. Rambo had one of the Cross's son's kidnapped in order to embezzle public funds. This document is part of a title 42 section 1983 civil claim.
Macon Division Dr. Sharon Cross, et alia ) ) plaintiffs in propria persona ) ) Civil action file number: v. ) ) :!"#cv#$$$$%#C&' ) (isa 'ambo, et alia ) ) )ur* +rial Demanded defendants ) ) ___________________________________________________________________________________ Plaintiffs' rebuttal to defendant Lisa Rambo's motion to dismiss ___________________________________________________________________________________ ,laintiffs hereb* rebut defendant and ,ublic +rustee (isa 'ambo-s motion to dismiss this civil action against her. ,laintiffs .all five of them) have an interest in the ,ublic +rust and have the fundamental right to remed* breaches thereof b* the named +rustee as /ell as to redress in order to ma0e plaintiffs .all five of them) once again /hole. & +rustee liabilit* for breach of the +rust is personal .no immunit* for defendant 'ambo) in character /ith all the conse1uences and incidents of personal liabilit* and is enforceable against her estate. Defendant 'ambo claims to be a )udge therefore is also a +rustee b* /a* of provisions at &rticle 2I of the Constitution. Defendant 'ambo /as a +rustee in the capacit* of a )udge .according to defendant 'ambo and her attorne*) at all times during the instant matter. ,laintiffs- statement of facts at paragraphs 3!, 34, and 35 /ithin the complaint /ere not rebutted b* defendant 'ambo or her attorne* thus stand as undisputed fact before this Court. +here is no evidence before this court to support the assertion that defendant 'ambo did not breach the duties of a +rustee for the ,ublic +rust to the confirmed in6ur* of plaintiffs. ,age ! of !% 7o evidence has been presented to this Court to indicate that defendant 'ambo did not order that plaintiffs- son 8.C. be sei9ed: absent a la/ful /arrant, /ithout probable cause, /ithout e:igent or emergenc* circumstances, absent imminent danger to 8.C., /ithout parental consent . 7o evidence has been presented to this Court to indicate that defendant 'ambo did not order plaintiffs- medical records to be sei9ed and searched: absent a /arrant, /ithout probable cause, /ithout e:igent circumstances, absent imminent danger to 8.C., /ithout parental consent . Defendant 'ambo-s motion to dismiss relies e:clusivel* upon the defense of 6udicial immunit* buttressed b* the false assertion that in bringing and prosecuting this suit the plaintiffs, in their proper persons and as beneficiaries of the ,ublic trust, are someho/ in violation of the (a/ of the (and. ,laintiffs read the assertions that the* are someho/ in violation of the (a/ as a deliberate and malicious attempt to intimidate and stop plaintiffs from proceeding for/ard /ith this meritorious case as it is their obligation and inalienable right to do given the gross violations suffered b* the plaintiffs as a result of defendant 'ambo-s breach of +rust. ;+here can be no sanction or penalt* imposed upon one because of his e:ercise of Constitutional rights.; Sherar v. Cullen, 481 F 2d 946 (1973) No Immunity for a Trustee which has breached the Trust to manifest injury of beneficiary & +rustee liabilit* for breach of the +rust is personal .no immunit* for defendant and +rustee (isa 'ambo) in character /ith all the conse1uences and incidents of personal liabilit* and is enforceable against her estate. The Juvenile Court is not authoried by or!anic Law +here is no evidence in this Court indicating that the legally created )uvenile Court is authori9ed b* the (a/ e:pressed at the Georgia Constitution. 7o evidence has been presented to support the assertion that the Georgia legislature is authori9ed to legislate a 6udicial office into e:istence. ,age 4 of !% 7o evidence e:ists to support the assertion that the Georgia 6udiciar* is la/full* authori9ed to install .appoint) a )udge /ithin a legislativel* born <ffice of the )udiciar* .)uvenile Court). 7o evidence has been presented to support the assertion that the )uvenile Court is not a unification of legislative and 6udicial po/ers. 7o evidence e:ists to support the assertion that the unification of t/o branches of Constitutional government is authori9ed b* the Constitution. ;+he Constitution is superior to an* ordinar* act of the legislature=; Marbury v. Madisn, ! "S 137, 176 ("S Su#re$e C%.) +here is no evidence before this Court that >e the ,eople .settlors) and beneficiaries of the ,ublic +rust have authori9ed the +rustees of one branch of government to create another branch of government. +here is no evidence supporting the assertion that defendants 'ambo, ?idson, @urt are not utili9ing and enforcing private ;polic*; to substantial in6ur* of plaintiffs. ,laintiffs have seen of this before: ;@e has combined /ith others to sub6ect us to a 6urisdiction foreign to our constitution, and unac0no/ledged b* our la/s= giving his assent to their &cts of pretended (egislation=; &e'lara%in ( )nde#enden'e *uly 4, 1776. +here is no evidence to support the assertion that hearsa* is not at all times allo/ed as evidence /ithin the )uvenile Court. +here is no evidence to suggest that standards s*mboli9ing the 6urisdiction of an organic Court such as the 8ederal and State flags in addition to the Great Seal of Georgia e:ist or have ever e:isted in the )uvenile Court. <n March 4Ath 4$!5 Defendants 'ambo and &lbritton /ere emailed and noticed the (a/ at ?:hibit & .actual notice of the (a/s being violated b* +rustees). ,laintiffs commanded defendant 'ambo and &lbritton to reveal plaintiffs- accuser at /hich time defendant &lbritton informed plaintiffs that such information /as ;confidential;. ,age 5 of !% +here has been no evidence presented to this Court that an* (a/full* authori9ed Court can den* the accused the abilit* to confront his accuser. ;It is the dut* of the courts to be /atchful for the constitutional rights of the citi9en, against an* stealth* encroachments thereon.; +yd v. ".S., 116 "S 616, 63!, (188!)29. ;+he 6udicial branch has onl* one dut* # to la* the &rticle of the Constitution /hich is involved beside the statute /hich is challenged and to decide /hether the latter s1uares /ith the former...the onl* po/er it .the Court) has...is the po/er of 6udgment.; ".S. v. +u%ler, 297"S(1936) +here is no evidence /ithin this Court to support the assertion that the )uvenile Court is not an administrative entit* administering statutes appearing completel* at odds /ith the Constitution. +here is no evidence in this Court to support the assertion that defendant 'ambo is not an administrator of statutes. +here is no evidence that defendant 'ambo-s )uvenile Court is not primaril* a place of business profiting her, the attorne*s hired to defend against her ;court orders;, and the prosecuting attorne*s representing D8CS. +here is no evidence before this Court in support of the assertion that defendant 'ambo is not involved in barratr*. +here is no evidence before the Court that 8.C. /as not sei9ed for the purpose of coercing his famil* to parta0e in ;services; provided b* and profitable to the ;D?,&'+M?7+;, )U2?7I(? C<U'+; or ;D8CS; and related agencies and offshoots. +here is no evidence before the Court that defendant ?idson and defendant 'ambo did not conspire to sei9e 8.C. for the federal and state funds that /ould be ac1uired to compensate the government, D8CS, and C&S& for ;services; /hich the plaintiffs /ould be coerced into receiving. +here is no evidence indicating ,laintiffs /ere not coerced into attending a ;probable cause; hearing /ell after the plaintiffs had been deprived of their due process rights. +here is no evidence in this Court to establish that probable cause or an e:igenc* to sei9e 8.C. ,age " of !% e:isted #rir to sei9ing 8.C. and prior to the ;probable cause hearing;. +here is no evidence before this Court that defendant 'ambo has not violated her fiduciar* duties as a +rustee to the beneficiar* plaintiffs in the instant matter. +here is no evidence before this Court that defendant 'ambo has not e:ceeded her la/ful authorit*. +here is no evidence before this Court that defendant 'ambo has not abused her official po/ers to manifest in6ur* to the plaintiffs. +here is no evidence before this Court that defendant 'ambo has not deprived plaintiffs of at least "th, th, and %th &mendment rights inter alia. +here is no evidence before this Court that defendant 'ambo has not enabled a false /itness to provide hearsa* and baseless assertion /hich /ould be inadmissible .e:cept for e:ceedingl* rare circumstance) in a Court provisioned b* the Constitution. +here is no evidence before this Court that defendant 'ambo did not fail to protect plaintiffs from malicious and bad faith medical ;reporters;. +here is no evidence before this Court that defendant 'ambo is not primaril* responsible for 8.C.-s ph*sical /rist in6ur*. +here is no evidence before this Court that defendant 'ambo and defendant @urt have not coerced .under pains of plaintiffs- son being again unreasonabl* sei9ed) plaintiffs to sign documents, to cooperate /ith a D?,&'+M?7+ entit*, and to attend ;immuni9ation; class. +here is no evidence before this Court that defendant 'ambo has not terrori9ed the plaintiffs and their e:tended famil* /hile economicall* benefiting from her treacher* and ma*hem at the e:pense of the public purse. ,laintiffs direct the Court to defendant 'ambo-s affidavit /ithin document "%. Defendant 'ambo freel* admits that she collaborated /ith defendant ?idson to effect the unreasonable sei9ure of ,age of !% 8.C. +he sei9ure is evidenced as unreasonable for the follo/ing: !. Defendant 'ambo indicates that the communication bet/een her and defendant ?idson had to do /ith, ;an e$ergen% si%ua%in ( alleged de#riva%in ( a $inr 'hild;. ?mergent is not evidence of ;e:igenc*; +he ;alleged deprivation of a minor child; does not evidence 6ustification for a reasonable sei9ure. 4. ;#aren%s....,ere re(using % all, %heir 'hild % be i$$uni-ed (r %e%anus, ,hi'h a''rding % %he %rea%ing #hysi'ian and hs#i%al s%a(( ,as ne'essary #rir % $edi'al %rea%$en% ( %he 'hild.; +here is no evidence before this Court to support the assertion that refusal to ;immuni9e for tetanus; presents probable, logical, or reasonable cause or special e:igenc* to sei9e an*one at an*time. 8or the record, plaintiffs never once refused to ;allo/ their child to be immuni9ed for tetanus;. ,laintiffs refused to provide consent and /ere unable to provide informed consent for the administration of a single tetanus ;vaccine; to 8.C. +here is no evidence before this Court that tetanus ;immuni9ation; /as essential #rir to medical treatment .surger*). ,laintiffs are not a/are of an*one ever being forced to receive a tetanus vaccine against their /ill. ,laintiffs point out that 8.C. received surger* and at least % hours later /as force vaccinated e:periencing no ill effects as a result of not being vaccinated prior to surger*. Defendant 'ambo-s affidavit does not evidence that she received a second or third opinion on this point /hich plaintiffs perceive as being rec0less and neglectful. Defendant 'ambo does not indicate if it /as revealed to her that there /as a high probabilit* or an* probabilit* that 8.C. had been e:posed to tetanus bacteria. +here is no evidence before the Court to corroborate that 4B of ;children; suffering from tetanus infections die. ;)% ,as e$#hasi-ed % $e %ha% %he 'hild.s ,ell/being re0uired %he %e%anus va''ina%in and %ha% %he need ,as vi%ally i$#r%an%, i( n% 'ri%i'al.1 2age 6 ( 16 +here is no evidence before this Court that Defendant 'ambo did not order this sei9ure based upon uncorroborated, unconfirmed, and unsupported testimon* from anon*mous sources. ;In conte:t of a sei9ure of a child b* the State during an abuse investigation...a court order is the e1uivalent of a /arrant.; 3ennenbau$ v. 4illia$s, 193 F.3d !81, 652 (2nd Cir. 1999. F.6. v. ),a dis%ri'% Cur% (r 2l7 Cunr%, )d. +he <'D?' 8<' S@?(+?' C&'? .e:hibit & in complaint) does not contain an* of the relevant language contained in defendant 'ambo-s affidavit. Defendant 'ambo-s actual sei9ing order and her more recentl* produced affidavit are materiall* and substantiall* different in content. Said sei9ing order-s .?:hibit &) content is /ithout all manner of e:igenc* /hile defendant 'ambo-s affidavit /ritten /ell over a *ear later contains language suggestive of e:igenc*. +he ;sei9ing; order ma0es no mention of an* elevated ris0 or imminent danger to the life or /elfare of 8.C..onl* that his life is ;possibl*; in danger as all of our lives are possibl* in danger at all times) as does defendant 'ambo-s affidavit. +here is no evidence before this Court to support the assertion that a tetanus vaccine, regarding this instant matter, /as either vitall* important or critical to the /ell#being of 8.C. Defendant ?idson and 'ambo 0ne/ or should have 0no/n this or have sought further medical opinion given the possibilit* that 8.C. /as possibl* to become the ver* first t/o *ear old bo* in histor* to have been sei9ed from his parents in order to administer a tetanus vaccine. +here is no evidence before the Court supporting the assertion that defendant 'ambo could establish probable cause or special e:igenc* to sei9e 8.C. given the information she /as /or0ing from as it e:ists upon her affidavit. ?vidence e:ists supporting the assertion that defendant 'ambo had plent* of time to receive s/orn or affirmed testimon* from medical staff ma0ing said staff liable for the reliabilit* and truthfulness .or lac0 thereof) of their statements. ,age C of !% Defendant 'ambo freel* admitted on December !4th 4$!4, ;%his ,en% n (r hurs 3hursday a(%ernn and 3hursday nigh%. ) dn.% 7n, h, $any 'alls ) g% abu% %his.; It /as not enough to have had information .as per 'ambo-s affidavit) that 8.C. /as in some form of alleged serious danger. ;+he 8ourth &mendment itself spells out the evidence re1uired for a /arrant or entr* order. 7o /arrant shall issue but on probable cause. +he United States Supreme Court has held that courts ma* not use a different standard other than probable cause for the issuance of such orders.; 8ri((in v. 4is'nsin, 483 ".S. 868 (1987). Defendant 'ambo asserted in her affidavit that she had 8.C. sei9ed based upon ;human concern; /hich reads to plaintiffs as meaning ;personal feelings;. ,ersonal feelings are distinctl* different than the much more e:acting and rigorous ;probable cause;. Defendant 'ambo also asserts to have relied upon the facts given to her, /hich have been evidenced as to be grossl* inade1uate insofar as to establish probable cause . <n page !3 of document "% defendant 'ambo states, ;) ,as in(r$ed %ha% %he #aren%s ( %he %, year ld 'hild ,ere re(using % all, %heir 'hild % be i$$uni-ed (r %e%anus, ,hi'h a''rding % %he %rea%ing #hysi'ian and hs#i%al s%a(( ,as ne'essary #rir % $edi'al %rea%$en% ( %he 'hild.; Defendant 'ambo-s s/orn statement is inconsistent /ith the ;<'D?' 8<' S@?(+?' C&'?;. Said order ma0es no reference to the assertion that tetanus ;immuni9ation; or even that ;immuni9ation; /as necessar* prior to or after medical treatment. 8urthermore, the tetanus to:oid allegedl* confers immunit* some t/o /ee0s after administration if at all. +here e:ists a five#*ear stud* of tetanus in the Ca*o Santiago rhesus mon0e* colon* evidencing that tetanus is not an immuni9able disease. +here are several cases of ade1uatel* and up to date tetanus vaccinated human patients contracting and d*ing from tetanus. In an* event, advances in i$$edia%e burn /ound care management practices and technolog* .silver impregnated cloth, s0in grafts) is oftentimes cited as a ma6or contributing factor to tetanus infection reduction. >ound care management /hich defendant Cartie is evidenced as dela*ing ,age 3 of !% indefinitel*. <n page !A and 4$ of defendant 'ambo-s affidavit is mentioned the five coerced demands made of plaintiffs b* defendant 'ambo and defendant @urt /hich are also noted in plaintiffs- complaint at the so#called ;C4 @<U' <'D?' 8<' S@?(+?' C&'?; document. @o/ever, and in distinction to plaintiffs- complaint, defendant 'ambo-s affidavit is lac0ing the second to last paragraph of said order that is of profound significance. +hat being, ;9ny devia%in ,ill resul% in %he 'hild being %a7en in% e$ergen'y 'us%dy and %he nn/'$#lying #aren% ,ill be sub:e'% % 'ivil 'n%e$#%.; &s has been previousl* e:plained, plaintiffs son had been neglected and in6ured /hile in the care of defendants &lbritton and Darr giving plaintiffs the reasonable e:pectation that if 8.C. /as again removed b* D8CS then he could again be harmed or even 0illed. 7o evidence has been provided to this Court that defendants 'ambo and @urt /ould not have effected the sei9ure of 8.C. if plaintiffs refused to sign government documents, refused to attend immuni9ation class, or refused to cooperate /ith D8CS. +here is no evidence /ithin this Court to support the assertion that defendant 'ambo spo0e to an* hospital medical staff involved directl* in the ;care; of 8.C. Defendant 'ambo admits that she spo0e to someone, /ho spo0e to someone, /ho spo0e to someone. Defendant 'ambo has s/orn that she authori9ed a protective order .?:hibit D in the complaint) based on her finding that t/o *ear old 8.C. /as deprived pursuant to <.C.G.&. statute !#!!#4 .3) ;Deprived child; means a child /ho: .&) Is /ithout proper parental care or control, subsistence, education as re1uired b* la/, or other care or control necessar* for the child-s ph*sical, mental, or emotional health or morals= ; (isa 'ambo has not evidenced .*et has asserted) to this Court that deprivation as it is defined b* this code section /as e:perienced b* 8.C. 8or the record of this Court, /hile in the Doctors @ospital plaintiffs /ere told that 8.C.-s surger* /as put on hold for different reasons: one /as due to the ;vaccine issue; /hile another /as that other surger* patients /ere ahead of 8.C. 7ever once /ere plaintiffs told that the tetanus vaccine /as ,age A of !% critical or necessar* #rir to surger*. +here is no evidence in this Court that surger* for 8.C. /as not dela*ed as a result of defendant Cartie .or an* other medical) punishing plaintiffs for not follo/ing his medical recommendations. +he plaintiffs /ill point out that /hile defendant Cartie and defendant 'ambo bandied about a 4B chance of death in the event of a tetanus infection, neither part* bothered to ascertain the incident rate of tetanus. >hat good is a mortalit* rate /ithout an incident rate##the chances of d*ing from a blac0 mamba bite are AAB, but the chances of receiving a blac0 mamba bite in this countr* are nearl* none:istent. Shall /e all stoc0 blac0 mamba anti#venomE In the case of tetanus, the actual mortalit* rate is alleged to be closer to !!B .per CDC) rather than the 4B utili9ed b* defendants 'ambo and Cartie. <f more importance is the morbidit* .incident rate) /hich is reported to be appro:imatel* ! in !$,$$$,$$$. Defendant 'ambo asserts she ordered sei9ed 8.C. out of ;human concern for a t/o *ear old child .8.C.);. +he error in such a statement, especiall* b* a state actor, is the idea that an*one could have more concern for a child than the parents of said child. Daring mental defect, no person, agenc*, or department, could have greater concern for the /ell#being of a son or daughter than a parent. &buses do occur, but even the Supreme Court recogni9es, ;3he s%a%is% n%in %ha% gvern$en%al #,er shuld su#ersede #aren%al au%hri%y in all 'ases be'ause s$e #aren%s abuse and negle'% 'hildren is re#ugnan% % 9$eri'an %radi%in; ,arham v. ).'., ""4 U.S. 3", %$5. 8urthermore, the ;concern; did not e:tend ver* far as she proceeded to deprive said t/o *ear old of the comfort of his parents during his initial recover* after a traumatic event. Defendant 'ambo-s ;human concern; also deprived 8.C. of the comfort of his mother-s mil0, as /ell as the love and care of his other siblings and e:tended famil*. &fter being accidentall* burned, having surger* for s0in grafts, subse1uentl* force vaccinated .again, not before but after the surger*), 8.C. /as then further traumati9ed b* being ta0en from his famil* ./hom he had never gone more than an hour /ithout), placed in the care of strangers, and caused ,age !$ of !% further ph*sical in6ur* .to his /rist) /hile in the care of defendants &lbritton and Darr. +his does not evidence ;human concern.; Defendant 'ambo did not evidence concerns for 8.C. or the plaintiffs- rights /hen she ordered him unreasonabl* sei9ed, nor did she have concerns for their rights /hen she ordered 8.C.-s medical records to be unreasonabl* and unnecessaril* sei9ed and searched. ,laintiffs as0 this Court to consider that defendant ?idson /as appointed b* the attorne* general. +he attorne* general no/ represents defendants and social /or0ers Darr and &lbritton /ithin this civil action. +his Court should 0no/ that the Governor of Georgia, 7athan Deal, /as at one time a 6uvenile 6udge and has been made /ell a/are of plaintiffs- deprivation of rights b* the plaintiffs themselves. In Georgia and in the e:perience of these plaintiffs, attorne*s /ithin our government appear to have little problem /ith the unreasonable sei9ing of %her people-s sons and daughters. +his is /hat state actor ;immunit*; from prosecution delivers to our societ*: anarch*, t*rann*, rampant abuse, unaccountabilit*, and e:ponentiall* increasing miser* for families as their inalienable rights are needlessl* deprived b* unaccountable state actors . Plaintiffs are not attorneys In regards to document "% and at page 4, plaintiffs hereb* rebut the statement, ;Plaintiff "ann #layden Cross and Plaintiff #haron $arvey Cross% both non&lawyers% are re'resentin! their three children in this court action(; &s e:ecutors of the estate .of /hich plaintiffs- sons are part), plaintiffs Dann and Sharon Cross have ever* right to act according the best interests of their estate....and there is nothing in the supreme (a/ of the (and or an* positive la/ implementing it /hich bars plaintiffs from doing so, 8'C, 'ules not/ithstanding. If defendant 'ambo asserts to the contrar*, let her cite the specific &rticle, Section, and Clause of the supreme (a/ of the (and or an* positive la/ implementing the same /hich supports such claim of authorit*. &dditionall*, since /hen and b* /hat legitimate authorit* has the ,ublic +rust been set aside b* or subordinated to mere corporation ;public polic*; as is e:pressed in various federal and state codes such as the cop*righted <.C.G.&.E ,age !! of !% ,laintiffs freel* admit that their sons 8.C., D.C., and '.C. are not remunerating plaintiffs Dann and Sharon Cross. +herefore, plaintiffs Dann and Sharon Cross are not ;practicing; la/ for hire. 8urthermore= a license .b* definition) is permission to do something .or not do something) that is other/ise illegal to do .or not do). Since /hen and b* /hat authorit* is the e:ercise of plaintiffs- .parental) 'ights made an ;illegal; activit*E Defendant 'ambo brings to fore <.C.G.&. F !#!A#!. /hich states, ;It shall be unla/ful for an* person other than a dul* licensed attorne* at la/: +o practice or appear as an attorne* at la/ for an* person other than himself in an* court of this state or before an* 6udicial bod*;. +herefore plaintiffs hereb* command the immediate production of the business license to practice la/ for hire and for profit of defendant (isa 'ambo-s legal representative >illiam 7eSmith III /ith Georgia D&' 7o. 5CA4. ,laintiffs must receive proof that attorne* 7eSmith is a dul* licensed attorne* at la/ /ithin !$ da*s of the date of this document-s submission to the Court. 8ailure to provide plaintiffs proof that Mr. 7eSmith is a dul* licensed attorne* at la/ /ithin !$ da*s /ill be understood to be undeniable proof that Mr. 7eSmith is not a licensed attorne* at la/ .*et pretends to be). Said license should bear upon its face the Great Seal of the State Georgia ./hich is or should be in the custod* of the Secretar* of State), to practice la/ for hire. De advised that a D&' .membership) card is certainl* not a ;license; and the Supreme Court hasn-t the authorit* to be issuing for hire .business) licenses in the name of the State as that /ould be a direct conflict of interest in relation to the 6udicial performance of the ,ublic +rust. 8urthermore= defendant (isa 'ambo-s legal counsel cannot claim to be ;an officer of the court; for t/o reasons: !) he is not a bonded emplo*ee of the state and on its pa*roll, and 4) he cannot be an ;officer; of a supposed neu%ral forum and, at the same time, represent and advocate the interests of one side or the other of a dispute /ithout compromising the neutralit* of the ;court.; +he fact that the attorne*s and the 6udge of this Court are all members of the same fraternal organi9ation that administers and controls the ;courts; ,age !4 of !% is *et another and currentl* inescapable conflict of interest. &lso consider that the plaintiffs are suing at least three D&' attorne*s that have /ell demonstrated their participation and inclination to deprive plaintiffs- of their inalienable rights thus ma0ing the hiring of a D&' attorne* *et another conflict of interest. ;(ac0 of counsel of choice can be conceivabl* even /orse than no counsel at all, or of having to accept counsel beholden to one-s adversar*.; +urge%% v. 3e;as, 389 "S 159 8urthermore, plaintiffs hereb* command defendant 'ambo and the currentl* unverified ;licensed to practice la/ for hire and profit attorne*; 7eSmith to substantiate his claims that plaintiffs have committed an* crime /hatsoever at an* time and that plaintiffs, as beneficiaries of the ,ublic +rust, are not properl* before this Court. "efendant Rambo and )r( Ne#mith has thre e days *from the date of this document's submission+ to une,uivocally 'rove to this Court and to these 'laintiffs their alle!ations of criminal conduct on the 'art of the 'laintiffs and that they*'laintiffs+ are not 'ro'erly before this Court( &bsent proof of plaintiffs- ;criminal acts; and proof that plaintiffs are not properl* before the Court /ithin three da*s it /ill be accepted that Mr. 7eSmith and defendant 'ambo have rescinded those libelous accusations regarding plaintiffs. In the event that defendant 'ambo, attorne* 7eSmith, district attorne* ,le9 @ardin, or an* state actor elects to deprive plaintiffs- rights then here be the fee schedule, terms, and conditions for such acts of deprivation: & fine of G5,$$$,$$$ per inalienable right deprived. &dditionall*, G!,$$$ /ill be fined for each minute an* member of the Cross famil* is deprived of their inalienable rights. ,a*ment of said fines must be made in Constitution (a/ful mone* to plaintiffs /ithin 5 months of the occurrence of said rights deprivations. ,age !5 of !% -ther contributin! factors to the de'rivation of 'laintiffs' ri!hts for this Court's consideration +he entire South/estern )udicial Circuit is over/helmed /ith conflicts of interest. Man* of the individuals are present in various organi9ations, agencies, and offices that ree0 of nepotismHcron*#ism at the least. +he S<>?G& C&S& .South/estern Georgia Court &ppointed Special &dvocate) agenc* claims .at least verball* via its /or0ersHvolunteers) to be an independent non#court affiliated non#profit group that is ;to provide a voice for children in court.;. +he idea is that the 6udge, re1uired to be a neutral and unbiased presiding officer, /ill be hearing the t/o sides of cases /ithout the benefit of the vie/point of the child. & C&S& volunteer is to provide a third vie/#point that is unencumbered b* the ;politics; or ;predisposed; notions of the various agenciesHdepartments that might be involved in a case. +he realit* is that C&S& is ver* political. ;Desire to please; is a real occurrence in ever*da* life. +he li0elihood that volunteers ma* feel the need to side /ith /homever the 6udge appears to be favoring is ever present. In the South/estern )udicial Circuit, defendant (isa 'ambo goes so far in her court as to provide D8CS prosecuting attorne*s /ith /hat their ne:t move should be, so obviousl* she tends to side /ith D8CS .specificall* in the plaintiffs- C4 hour hearing, defendant 'ambo told defendant @urt /hat she ;assumed; /as his motion). >hen individuals volunteer /ith C&S& and are dul* appointed as advocates, the* are often attempting to ;net/or0; and develop their ;credentials;. In going against a ;6udge; or an* other individual in the court /ho has ;pull; or ;clout;, the volunteer is obviousl* potentiall* damaging their position for later recommendations. In this particular case, the C&S& volunteer /as /ell a/are that the D8CS supervisor, defendant Iaran &lbritton, /ho sat at the table during the initial ;C4 hour hearing; /as also a board member of C&S&. 8urthermore, the most overriding concern of C&S& is for the child-s right to ;appropriate placement and permanent home. ; Such a statement begs the 1uestion##do children have the ;right; to be unmolested b* state actors in ,age !" of !% their o/n famil*. C&S& is affiliated /ith the (ighthouse Child &dvocac* program that features defendant 'ambo as a supporter. 8unding of the (ighthouse Child &dvocac* program allegedl* comes from court probation fees .more barratr*). +he ne/ coordinator of the &dvocac* program is none other than, the ne/l* retired D8CS supervisor, defendant Iaran &lbritton. Defendant &lbritton /as the D8CS supervisor /ho, along /ith defendant Darr, too0 ph*sical possession of 8.C. at the Doctors @ospital in &ugusta, Georgia. Doth &lbritton and Darr are responsible for 8.C.-s /rist in6ur*. ?:#6uvenile 6udge and attorne* Governor 7athan Deal has appointed defendant 'ambo to the Georgia Commission on Child Support. In turn, defendant 'ambo recommended to Mr. Deal the appointment of S<>?G& C&S& e:ecutive director Drad 'a* to the Child &dvocate &dvisor* Doard .of /hich defendant 'ambo is also a member). District attorne* ,le9 @ardin is on the board of S<>?G& C&S&. Dased on information and belief ,le9 @ardin-s spouse is the sister of the S<>?G& C&S& that fa:ed the C&S& document .e:hibit D in the complaint) to ,ediatric &ssociates to effect the unreasonable sei9ure of medical records. +here is more but this /ill suffice in demonstrating that plaintiffs /ere snatched b* a group of business people /ith significant potential for conflicts of interest. ,laintiffs believe this group of people to be !$$B business, and 0ids are their 6ustification for more funding. Could it be that there is substantial pressure .revenues must al/a*s go up) to unreasonabl* ac1uire 0ids b* the 6uvenile courtE Could this possibl* contribute to the unla/ful sei9ing of 8.C.E &ccording to defendant 'ambo on December !$th, 4$!4, ;).ve been %he :uvenile 'ur% :udge 12 years and ) never had ne ( %hese 'ases.; ,laintiffs assert the reason is because most people reali9e that refusing a tetanus vaccine is not reasonable grounds to sei9e, in this case, an alread* traumati9ed little bo* from his parents /ho /ere obviousl* attempting to secure urgent medical attention for him. ,laintiffs hereb* command defendant (isa Coogle 'ambo to immediatel* produce her legitimate authorit* for her actions against these plaintiffs. ,age ! of !% ,laintiffs further command defendant and alleged ,ublic +rustee (isa 'ambo to immediatel* account for her breach of dut* to the plaintiffs .beneficiaries). 8or the foregoing reasons and all the others revealed in the plaintiffsJ complaint, defendant 'ambo-s motion to dismiss should be denied. ,age !% of !% ei$,:,tfu ,rririn; Slayelen Cruss T:rr1,.i*nrclii,ft$$4 Ci;g..,,,:,,, ,,'rl.:.::::,,,...t " il$l,rKsrei*.AjLbrlf i, ee Sr S l..ffi,A[,i$i* .,' 1 ,,,,. i :lii , . i 1 . . . i : : : : . . : , : : l : l l l ) : ' : . : . - : : . . . . 1 . : : ::a) :::a::: : ! !ilN tj,lj r tiil Tho orgnnie law of thr Unitbil,s'tster CIf Amffl*e; r,'*. ,A*fust x*{i*e *f,.th*,*rg*xrle trnrry ns express*d r.vifhin ths f'oundeti*nsl docunrents ot' thc ltepublic uf Georgia, America f;riq*r:uf1! I. I-ifer liher-ty,:rnrl properry" No yttrsttn .shttll be cleprived aJ 1ifb, liherty, or property except h.v dt*z ,Tn')4u1.$ {ry !dv,. t"nr*grnph {Itr. Freedom of consciene c. E*ch Fers{)/t hus the natural and inalienuhle right Io v'orship Gttd. *r;{ ,xrr;*rr,$ing }* /Srr ddcr*/es c/t&r*per;*xls orsn co$srieri*e.' und n* kunxrz rmtltority tl.tould, in any,c:a,st, rl.**i'r,'r:ll or iflr#i'r&re'willl sr,s.ft rlgllf *y'*o*s tieft(,e. {'irragr*plt Vl. Libel. ln dl <:ivi! ()r {rifitinu! acti,yts .fiir lihe!, the trutlt trttq, he given in eviclence; and, il it .thttlt *3;y**cr 1$ #,ls drf*r ld$rc:l lfuat the mil#er cftr.qgcc{*s lihekws rs #'ae, t'ke puriy shalt be distharged, i"*nagnuph X[{I. $earches, seizures" and warrants. I'he rigltt oltthe lteople Io be secure in their perstm,s. ,tr;irlr{ri. Jrrfl(2i',5', tnd elJtcts aguittst wtreartsiluhle ,yetrche.s mtd ,seirure,s sltul! rutt be violated; rutd no wurreill .lrrt# i:.c.rrid exc:e1tt tqtort ytrohal'tle t'mre .supporttd h.y'outh or ulfirmation pm'tit:tilarly describing the place or , ri:( {,.1 i{j hl .tetrtlwrl antl {he persans <tr ihings lo ht:sei:ed. l'*ragnxg:h XVl. Self-incrinrinntisn , No Jtcrsort .sha!! hc cotrtltclled to give testimony tending in ttny manrter kt r' ", , i / . . ; , i i ' i ", , , rt i n*t i ng, i3;,1,t'rtgr*ph XKI . nu*mrrl{i*n uf rights n*t de ninl ot'uthers. 'I'he ertunrcrcttion of'righrs herein cotrtainerj tn .:;3.xl,lttf"llrls{,.l'lrusldrrllolrshallttothct'.tstls|ru*tt,tr.re./cl4lIrlthapttlJieutyinhtrent 4 i- ; i::t r r r t eili t t)j e d. "ilfilis i1*r*u:ntent is Sctual $otice that thcse and otlren law* crealed l$ protect (parent), (parent), thsir ehildren, ftnd {,l**t.ly hft*m h$en btr:k*r'l by nunt*rous nnd speoi{ic parties under the prrt*nse of governrtiont, Suid laws have ho**l k*qiwingltri.willlngly, ilnd intcnti$nally vinlateciet:tecting $ubstnntive, psychological. physiniogicnJ" ruul I l ri fi $ l rdnn to the aforemel i ti *ned. {)$i i $rstg}ri ;l th&|tj "l c,' i nrtnuni gnti *neduc.*.l ,i txl ,,i rri sbegnrrnl av{i rl l yi l ecrecdby|.,i saRamhoantl Jams lur,, li)*c,*nth*r Sth..?013. (p*rsnt)'s tlq n$t $tend srid "eiluEali$n'lofthgjr ow,n fiFe will. (parent) and S(parent) *li*rnd *ai$ $d$catioir,basctl upon the fcrllowing written threar to do actnal harnr undemoath,said decree:,: ,,i,dll},r1*.l;l*,fjt.*vu!ltyesultinlheifld{iNtt,snn)heingtukenitttaenIefNgntycastotly,andthe tr;J|' ctll ,ulll he suhjecl to civi! L:on!{!n?pt. " ' - ' i {r:,;:ce:i tl l l ti crrc tJtal such al tuses ol ' porvcr i u' e nor aurhori zecl by l he l aw 6f the l and and that so-cal l e<J' ,oi i l ci al i*:muuiry" r.vlll nnt bc a valir{ tiefensr* fr:r any partv found to have broken the law in this instant mattL'r, ,{$$. &;li$es'r$&rierl ln he rsin are iie}}tr:qversial ergo aqtir}ngb&Lin a lawiirl coirrr quthorized to hear and lrlj-Lll! isiu$ :ugh-t:tanff s. rA;L;/ A