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In the United States District Court

for the Middle District of Georgia


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..,,,:,,,
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il$l,rKsrei*.AjLbrlf
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ee
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!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.
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A

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