DMCA Copyright Owned and Counterclaimed by Roxanne Grinage manager HireLyrics Administrative
Services U.S. Citizens Public Docket Database, Pennsylvania and U.S. Department of Treasury registered standard access litigation
referral having verified due diligence reported herein. All internet radio domain and video hosts are notified of Roxanne
Grinage's COUNTERCLAIM WILLINGNESS TO ACCEPT SERVICE IN UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA
AT BUSINESS ADDRESS, P.O. BOX 22225, PHILADELPHIA PA, 19136 Tel 267-444-0594 Fax 215-405-2939.
ROXANNE GRINAGE, LEGAL
ASSISTANT MARKETING CAREERS PROJECT MANAGER, HIRELYRICS ADMINISTRATIVE SERVICES, U.S. CITIZENS CONTROLLED PUBLIC DOCKET
DATABASE. WWW.HIRELYRICS.ORG ARE REGISTERED BUSINESS ENTITIES HAVE ACCOUNTABILITY TO PENNSYLVANIA SECRETARY OF STATE AND
U.S. DEPARTMENT OF TREASURY. WE REPORT ONLY VERIFIED FACTS AND EVIDENCE NON-FICTION CRIMES AND POST FOR REFERRAL TO
LAW ENFORCEMENT, FUNDING DECISION MAKERS, U.S. SENATE, U.S. COURT ADMINISTRATION, AND U.S. ATTORNEYS AND OFFICE OF CRIME
VICTIM WITNESS PROTECTION PROGRAMS.
09/16/12: PLEASE TAKE NOTICE THAT ALL ROXANNE GRINAGE IS WILLING TO ACCEPT SERVICE
OF DMCA OR OTHER CLAIMS REGARDING CONTENT POSTED ON THIS WEBSITE/DOMAIN. WWW.HIRELYRICS.ORG IS USED EXCLUSIVELY TO
POST VERIFIED CLAIMS INTAKE ASSESSMENTS, AND REFERRING DATA REPORTED AS DUE DILIGENCE TO FEDERAL AND STATE PROSECUTORS,
U.S. DEPARTMENT OF JUSTICE, U.S. SENATE AND STATES FUNDING DECISION MAKERS IDENTIFYING WHICH INDIVIDUALS ARE RESPONSIBLE
FOR ABUSE THEIR OFFICIAL POSITIONS TO INFLICT PERJURY PERSONAL INJURIES DISABILTY AND WRONGFUL DEATH AND EMBEZZLE FEDERAL
AND TAX PAYER FUNDING INTENDED FOR THE PRESERVATION OF AMERCICAN FAMILIES. ROXANNE GRINAGE IS WILLING TO ACCEPT SERVICE
OF ANY CLAIM IN THE U.S. DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA. MY FULL CONTACT INFORMATION IS BELOW
AND ABOVE.
Roxanne Grinage, Legal Assistant Marketing Careers Project Manager Federal Rules of Evidence compliant Expert Witness Report Services
HireLyrics Administrative Services
U.S. Citizens Public Docket Database
PO Box 22225
Philadelphia Pa 19136
Tel 267-444-0594 Fax 215-405-2939 Skype:
roxanne.grinage
www.HireLyrics.org
www.Facebook.com/Roxanne.Grinage
www.Twitter.com/HireLyrics
www.YouTube.com/HireLyrics
www.YouTube.com/WhatIsThereLeftToDo
www.YouTube.com/RoxanneGrinage
www.BlogTalkRadio.com/Born-To-Serve
www.ireport.cnn.com/people/HireLyrics
Roxanne
Grinage applies 26 years experience and exemplary competitive work ethic to the professional services she renders for Attorneys,
Law Firms (Intellectual Property, Commercial Litigation, Civil Rights), Human Resources Executives, Marketing and Research
Executives, Investment Bankers (Mergers & Acquisitions), and Political Campaigns EQUALLY professionally and competitively
rendered for pro se litigants (usually federal crime victims created by official corruption fraud and civil rights violations),
seeking lawful but assertive solutions for compliant Federal Court Complaints, Dept of Justice Claim for Damages caused by
employees of a federally funded agency; class action litigation referral and citizens' layperson referral to States Attorney
Generals and Special Prosecutors with verified claims intake assessment data showing a public safety emergency need for law
enforcement intervention, investigations and audits when personal injuries theft and irreparable harms are caused as a result
of a State Court Judge's deliberate legal malpractice (Court Ordered Child Abuse or Unlawful Imprisonment) in accommodation
of Racketeering Influenced Corrupt Organizations (RICO) schemes: Perjury, Kidnap for Profit, Human Trafficking, Falsification
of Identification Documents and Witness Intimidation.
2,060 Federal Crime Victims Verified By HireLyrics Business Model Created By Official Corruption
HireLyrics Jobs Creation 2012
Law Enforcement are Working Class People Too!
HireLyrics
Owners Say Bernstein Cox Windsor Defamation Wont Stop All States CPS Reform Jobs YouTube.com/HireLyrics
November 16, 2012
HireLyrics Owners Say Bernstein Cox Windsor Defamation Wont Stop All States CPS Reform Jobs
www.Youtube.com/HireLyrics
HireLyrics
Owners Say Bernstein Cox Windsor Defamation Wont Stop All States CPS Reform Jobs YouTube.com/HireLyrics
November 16, 2012
HireLyrics Owners Say Bernstein Cox Windsor Defamation Wont Stop All States CPS Reform Jobs
www.Youtube.com/HireLyrics
Legal Malpractice Crime Victims Speak as Voter Constituency The Legal Assistant's Role in Evidence Production Litigation
and Law Enforcement Referral & 06/03/12 Grinage Family Asks Philadelphia District Attorney and Pennsylvania Attorney General
to End Saundra O. Sullivan and Erick L. Brown's 2 1/2 years Crime Spree.
HireLyrics™
Scope of Services OPTION 1: PRO SE DOCUMENT PRODUCTION
These standard services are a preview of Jobs Creation 2012 HireLyrics is in the process of applying for grant funding
for so that financially devastated American Federal Crime Victims verified by standard access to claims intake assessment
and litigation referral may receive Pro Se Document Production and Claims Forms Preparation free or at substantially subsidized
cost while community enrichment jobs are created.
HireLyrics Claims Intake Assessment
Performed by a Legal Administrative Assistant:
Evidence Gathering Depositions and Expert Witness Testimony
HireLyrics Litigation Referral:
Merits
of Claim Contingent Liabilities Assessed; verified evidence indicated Calls for Class Action, Special Prosecutor or Defense,
PrivateInvestigator, Forensics, Credentialed Expert Witnesses or other Legal Industry Support Service
including transcriptionists researchers paralegals, technology, law or business school students.
Legal Administrative Assistant Verification Report:Docket Analysis; Identify Conflict of Interest;
Measure Individual Accountability Components:Work Ethic, Compliance, Negligence, Records Mismanagement,
Employee Misconduct, Malpractice; Embezzlement or Fraudulent Billing; discern whether bogus warrants, whistleblower retaliation,
false arrest, nepotism or judicial tyranny.
Package
and submit due diligence as trial prep evidence modules which responsibly record respectfully report degrees of individual
accountability for Official Corruption Fraud Civil Rights crimes perpetrated under color of law against American working
class student impoverished families and business owners.
HireLyrics Trial Prep Evidence
Binder:
Legal Administrative Assistant Summarized Marked Exhibits Index provided to HireLyrics
Client on Data Disc or Flash Drive and, if authorized by Federal Crime Victim Pro Se Claimant, active links posted to
HireLyrics Administrative Services managed case study page prototype demonstration of U.S. Citizens Public Docket Database
on the internet at www.HireLyrics.org.
U.S.D.C. Pro Se Forms Compliant Federal Civil Lawsuit Complaint
HireLyrics Legal Administrative
Assistant Drafts Affidavit of Facts compiled from evidence provided by Federal Crime Victim Claimant; prepares U.S. District
Court official package of pro se Federal Lawsuit Complaint form, and if asked by HireLyrics Client, gathers the information
necessary and completes U.S.D.C. pro se forms package compliant Petition Informa Pauperis (Poverty Affidavit; Indigent Litigant)
asking U.S. District Court for permission to waive Filing Fee.The Pro Se Claimant (HireLyrics Client)
must sign and file with the Court by Certified Mail or Hand Delivery on their own behalf.HireLyrics
Legal Administrative Assistants are not attorneys are not enrolled to practice before the IRS and do not represent any
person in any court or claims process.
If verified evidence indicates:
HireLyrics Certified Service Distribution Fraud Report Whistleblower Transmittal Law
Enforcement Investigation and Audit Request
Presidential Executive Officers, U.S. Department of Justice, Appropriate U.S. Senate
Committees, U.S. Courts Administration; State Lawmakers, Child Abuse Registry, Child Support Enforcement, Licensing and
Disciplinary Review Boards, Internal Revenue Service Office of Professional Responsibility (IRS OPR); U.S. government Accountability
Office (GAO) and others as verified evidence indicates and lawful reporting opportunities become available.
If verified evidence indicates:
Appropriate Referrals to U.S.
Department of Justice Programs (OJP Victims of Crime):Domestic Violence Elderly Abuse and Mistreatment
Identity Theft or Theft by Deception Schemes.
In an effort to send a clear message that HireLyrics
will not allow the quality of life enhancing results of a standard access mechanism to be hindered by misuse, HireLyrics
will promptly report all facts and evidence discerned during claims intake assessment; due diligence, trial prep, research
and discovery including those challenges and crimes for which there is help or criminal justice intervention by way of
appropriate referral.
Example:If a Federal Crime Victim’s
claims of official corruption are verified and the claimant is observed to need help with addiction, vocational rehab,
arrest recidivism intervention or penal action is necessary to intervene in a discovered domestic violence or elder abuse,
identity theft or scams of defenseless Americans; HireLyrics will move swiftly decisively lawfully and without notice to
cause appropriate reports referrals and notices to appropriate law enforcement and funded neighborhood innovation programs.
If verified evidence indicates:
HireLyrics Certified Service Notice to Federal State
County Employers.
HireLyrics Certified Service Notice to Federal State County Employers of evidence
verified Employee(s) or Professional Practitioner Misconduct, Bribery, Coercion, Intimidation, Extortion, Nepotism, Cover
Up Censorship Rerouting Destruction of Evidence, court filings, Falsification of Records Fraud Embezzlement Kidnap For Profit.
If verified evidence indicates:
U.S. Department of Justice Form 95 Claim For Damages or Wrongful Death Caused by a
Federal Agency.
If verified evidence indicates:
U.S. Department of
Justice Office of Inspector General (OIG) Fraud Waste Abuse Misconduct Report.
If
verified evidence indicates:
Certified
Service Form COL Violation Warning Denial of Rights Under Color of Law Violation Warning—18 U.S.C. §242; 18
U.S.C. §245; 42 U.S.C. §1983.
“I certify that
the forgoing information stated here is true and correct.Legal Notice and Warning - Federal law provides
that it is a crime to violate the Rights of a citizen under the color-of-law. You can be arrested for this crime and you
can also be held personally liable for civil damages.”
Certified
Service Distribution of Form COL Violation Warning Denial of Rights Under Color of Law Violation Warning—18 U.S.C.
§242; 18 U.S.C. §245; 42 U.S.C. §1983 is always publicly posted to HireLyrics Administrative Services managed
case study pages within prototype demonstration of U.S. Citizens (controlled) Public Docket Database.
If verified evidence indicates:
Dept of Justice Executive Office For Immigration Review Alien’s Change of Address
Form Board of Immigration Appeals
If verified evidence indicates:
Dept of Justice
Executive Office For Immigration Review Immigration Practitioner Complaint
If verified evidence indicates:
Dept of Justice Executive Office For Immigration Review Application for Cancellation of Removal and Adjustment of
Status for Certain Nonpermanent Residents
Revision Authorized Roxanne Grinage:01/08/2012,
Tel 267-444-0594 Fax 215-405-2939 roxannegrinage@yahoo.com
Call in number to speak
with the host(646) 200-4377
HireLyrics Primary Purpose - Guard The Integrity Of Data
Posted To U.S. Citizens (controlled) Public Docket Database. Administrative Solutions Tool Series: Docket Never
Lies…Child Slaughter U.S. Economy Fraud Court and Education Reform Public Safety Emergency Is Measured In Docket
Monitoring. Full length 36min letter to President and First Lady Obama titled State Agency Malpractice Crime
Victim Voters Beseech President Obama Intervene Slow Child Slaughter at CNNireport, http://ireport.cnn.com/docs/DOC-495712.
1. Lorraine Grinage recounts 06/08/10 Erick Brown Saundra Sullivan Public Mob Assault Abduction of her children Ezekiel
and Arriyel Brown, enabled by 47 Counts of Official Corruption Fraud Civil Rights felonies inflicted by Philadelphia lawyers
Fern Brown Caplan, Timothy E. Possenti covered up by Anne Marie Ambrose Judge Robert J Matthews Marvin L Williams.
2. Angela Barff-Eib recounts Humboldt County California CPS lawyer adoption contractor and sheriffs' employees collusion
with child sexual predator Aaron Eib facilitate Schrock and Schrock illegal adoption transport to Cabott AR by Dustin and
Peggy Joy Baker, trauma injured Hahnnah and Savannah Eib. 3. Mary Nettie August Carol Nixon facts and witness testimony
recorded by HireLyrics expose Robert M. McKenna and Karen M. Dinan have abused Washington Attorney General's office to cover
up Kelso CPS saddism torture of Autumn Joy August, Haitian Kids extreme child abuse case coming up soon, acts of Retaliation
motions for abusive foster parents to take child out of state and Motions to criminalize protector parents to enable billing
and sale of wanted children by way of lying in official court documents. Mary Beth Bunch her daughter Lindsay Merritt's
4 children and grandchildren in Cowlitz County WA have presented for claims intake to HireLyrics Administrative Services.
Disclaimers provided throughout live broadcast.
HireLyrics is Born To Serve on Blog
Talk Radio where we try to meet every Sunday 11:00 AM EST to share administrative solutions for market entering challenges
for previously un-measured un-accommodated Worldwide Population of Disadvantaged Creators. This week we will document all
tracker activity just before websites controlled by Roxanne Grinage dba HireLyrics Administrative Services and U.S. Citizens
Controlled Public Docket Database and Lorraine Grinage dba Grinage Family Rescue Ezekiel Arriyel Brown from the irreparable
harms caused by State Court Conflict of Interest Malpractice with City of Philadelphia DHS all related dockets Roxanne Grinage
v Fern Brown Caplan, et al U.S.D.C. PaED 209-cv-04119-MSG see 07/06/10 filing Figure 1 - were taken down. We will responsibly
record respctfully report within the context of administrative solutions for fair access to litigation entry administrative
challenges for American Families committed to owning responsibility for our electoral process acting lawfully to slow bring
to screaching halt nationwide Child Slaughter U.S. Economy Court and Education Reform State of Emergency caused by systematic
abuse of immunity language in 1983 Civil Rights Act. Also we'll talk about the court ordered mental health evaluations science
fraud as a tactic deployed by dishonest DHS and Contractor Orchard Children's Services Inc. Employees
in Washtenaw County, Michigan Juvenile Trial Court against Chantella Tucker and Child Abuse Central Registry Fraud as it was deployed to block
Michigan Grandmother Debbie Tucker Williams from standing to her granchildren federal lawsuit reports to State Attorney General
Science Fraud pending. Proofs of Cowlitz County Judge Warme and Court appointed lawyer Jo Vernon play the out of office rescheduling
date game while 2 year old Autumn Joy August is hospitalized at undisclosed location due to kidnap for profit injuries sustained
starting 09/06/2010.
Judge
Kevin M Dougherty Malpractice Caused Feltonville Crash Tragedy Janice Brown Family’s Illegal Adoption http://www.youtube.com/watch?v=XhZkIPG_rb4Janice Brown 3rd Street Angels Grandmother Lead Plaintiffs $1B Class Action Philadelphia
DHS Illegal Adoption Zyeem Hill, Kyshone Smith, Envy Smith Mother and Father Federal Crime Victims Deneesha Hill Robert Smith
Learn on January 15, 2011 Judge Kevin M. Dougherty Knew the killer of Janice Brown and Maurice West's family members in 2009
Feltonville Crash.
Federal Crime Victim Voters
Outraged DHS Kidnap Injuries Civil Rights Hero Brave Little Jasmine Kitchen.
Philly Judge Kevin M Dougherty Drops
Proof of Child Support Fraud In Lap Federal Crime Victim Voters
Toll Free (888) 589-1110. As 50 families shop whistleblower law and audit firms
specializing in retaliation to litigate measure damages inflicted by PHILADELPHIA FAMILY COURT CONFLICT OF INTEREST MALPRACTICE
WITH DHS AGENCY MISCONDUCT, Tom Corbett's pick for Pa attorney general Kenya Mann Faulkner and non-responsive Eastern District
USDOA Zane David Memeger; Tracker download all U.S. Citizens Public Incident Reports of Judge Robert J Matthews participation
in 47 felony crimes show heavy hitter law firms Schnader Harrison Segal & Lewis, Ballad Spahr, Mattioni and Mattioni and
others specializing in White Collar Defense Litigation are maneuvering White Collar Defenses for the Official Corruption Fraud
Civil Rights Defendants named in all related dockets U.S.D.C. PaED 209cv04119MSG 209cv05448BMS 210cv00179MSG.Lead Plaintiffs
call the names of lawyers judges and every DHS employee responsible for inflicting injury by way of Malpractice Kidnap For
Profit schemes. Position descriptions of City of Philadelphia Civil Rights Legal Department Craig T Straw City Solicitors
read: One negligent conflict of interest example after the next showing how Phila CCP Family Division with DHS Agency has
usurped the Pa Constitutional Rights of Families who live and work here. First demand in Jury Trial Complaint is immediate
return of injured children to families restored to how they were before encountering the veracious billing agenda of Malpractice
Conflict of Interest of Judge Kevin M Dougherty Anne Marie Ambrose Roberta Trombetta Esq Judge Robert J Matthews Judge Alice
Beck Dubow Fern Brown Caplan, Esq, Timothy E Possenti, Esq, Marvin L. Williams Esq CPA PACSES and others. Free Sign Up form
at HireLyrics.org No professional including police officers and city agency employees are exempt from the Child Support Enforcement
Fraud and Child Abuse Registry Fraud systematically inflicted by Official Corruption Fraud Civil rights Defendants named in
this $1B Class Action.
(888) 589-1110 Toll free give verifiable Family Court DHS Conflict of Interest
Malpractice CPS Corruption testimony; Campaign 2012 Galvanize Voter Clout Federal Crime Victims; Constitutional Citizens Grand
Juries Safe Haven DHS Court Ordered Abused Runaways.This podcast is sent to Senator Chuck Grassley Iowa;
President Barack Obama Domestic Violence Senior Advisor Valerie Jarrett, John Walsh America’s Most Wanted, Oprah Show
Producers, Michelle Rhee Education Reformist USDOJ Eric Holder plead investigations audits intervention to protect public
safety in corruption poisoned Eastern District of Pennsylvania.Please donate www.HireLyrics.org
Mayor Michael Nutter works with DHS to distract media
exposure systematic nature of Family Courtroom Killing Floors by featuring a scapegoat DHS atrocity once every 6 months or
so coined Federal Crime Victim Voters, “DHS Nutter News Network”.
Remember names
of Americans DHS Slaughters every day and names of New Civil Rights Movement Families Fight Back Say No More DHS Demonic Horror
Stories heroes; patriotic law abiding Americans (excerpt played Liberty and Tyranny Modern America by Mark Levin) committed
to acting lawfully as Plaintiffs in massive civil rights child custody personal injury lawsuits, citizens grand juries safe
haven for DHS Runaways; owning responsibility to participate in electoral process Campaign 2012 Galvanize Voter Clout Federal
Crime Victims.
Grinage Family Rescue Ezekiel Zadkiel Brown, Deborah Young Chronic Court Denied Protection from Abuse
Kidnap For Profit victim founded grassroots community organization Justice For Families and Children, Tilia Ayala with Denise
Smith, the first DHS Kidnapped For Profit Victim with the Courage to make posterboard signs with her children’s pictures
and protest outside DHS office alone until Denise Smith had the courage to join her standing side by side in all kinds of
weather launched the original DHS Give Us Back Our Children support group, 4 year old Marc Anthony Clayton sold on the block
because his grandparents Barbara and Kirt Clayton said they didn’t need any DHS “services” they wanted their
grandchild. Willie Brownson Ezekiel Zadkiel Brown Arriyel Roxanne Brown v Judge Robert J Matthews Anne Marie Ambrose $6.2M
Theft Vested Interest Career Theft U.S.D.C. PaED 209-cv-05448-BMS reads the 47 felony crimes committed by Judge Robert J.
Matthews to cover up the felonies committed by his official corruption fraud civil rights colleagues Fern Brown Caplan, Esquire
and Timothy E. Possenti, Esquire in Philadelphia Family Court all related dockets 209cv04119-MSG last filing 07/06/2010.
Three generations of Janice Brown’s and Maurice West’s family.
Mildenberg lawyers represent interests of adversarial party DHS after
Federal Judge Jan E. Dubois’ 08/2710 Memorandum Jurisdictional Challenges determined DHS illegally transported Veronica
Spencer’s Children.Bryan Jones reports DHS was able to overstep a Federal Judge again and kidnap
Brave Little Jasmine Kitchen again 1/14/11.
Jasmine Kitchen ran into 20 degree
weather 12/20/10 wearing only flip flops and wind breaker to escape choking beating by DHS contractor employee at 48th and Fairmount DHS controlled facility.Brave Little Twelve 12 year old Jasmine Kitchen courageously
carried the truth and evidence to galvanized Federal Crime Victim Community of how DHS facility managers actually pay child
molesters to come in and rape the children coined by her step father Bryan Jones as “DHS is running Pervert Paradise
here on Earth.”
No profession or walk of life is exempt from the
veracious Conflict of Interest Malpractice Relationship Philadelphia Family Court Judges Kevin M Dougherty Margaret T Murphy
Alice Beck Dubow Judge Robert J Matthews share with Anne Marie Ambrose Roberta Trombetta Esquire more than 200 multi-million
dollar billing foster evaluator pharmaceutical adoption contractors.
Docket Never Lies! Child Slaughter
U.S. Economy Fraud Court and Education Reform Emergency is Measured in Docket Monitoring. See Pa Superior Court Docket Reports
to see individually accountable official corruption fraud civil rights defendants to be named in upcoming 50 Philadelphia
Families $1 Billion Class Action.Dependency DHS Fast Tracked Closed Pa Sup EDA 551 Zyeem Hill Pa Sup 552
EDA Envy Smith Fast Track Involuntary Termination Parental Rights Pa Sup EDA 1331 Zyeem Hill DHS Pa Sup EDA 1333 Envy Smith.
Janice Brown and Maurice West learn and report in this show how Judge Kevin M. Dougherty’s Conflict
of Interest Malpractice committed with City of Philadelphia billing contractors (an academy) actually caused the 2009 Feltonville
Crash tragedy that killed Janice Brown’s daughter two grandbabies and a neighbor’s used by Kevin M. Dougherty
to claim Janice Brown needed grief counseling.The minor that police were chasing whose car crashed in
2009 Feltonville Crash, had appeared before Judge Kevin M. Dougherty with 7 felonies and was not detained but sent to an Academy
sharing financial incentives with City of Philadelphia.
Judge Kevin M. Dougherty
later told Janice Brown in open court “THEY ARE MY KIDS NOW.”Three Generations of Janice Brown’s
family; hundreds of Federal Crime Victims created when Judge Kevin M. Dougherty Anne Marie Ambrose and Michael Nutter indulged
conflict of interest relationships with DHS multimillion dollar billing contractors to commit malpractice breaking Rules of
Civil Procedure, Pennsylvania and U.S. Constitutional laws, Official Corruption Fraud Civil Rights felonies inflicted sold
Janice Brown’s and Maurice West’s Grandchildren, Deneesha Hill and Robert Smith’s children Zyheem Hill and
Envy Smith as billable fodder injuring them and causing irreparable personal injury and economy loss in the process of Kidnap
for Profit:Theft of HeritageVested Interest Trauma Injuries Inflicted Forced Commerce
Theft of Religious Freedom Economic Treason; Defraud Adoption Tax Credit and President Barack Obama’s Domestic Violence
Awareness DOJ Released Best Practices issued to Family Court judges in re Domestic Violence epidemic in America why no child
is safe at home.See YouTube video Judge Kevin M Dougherty Malpractice Caused Feltonville Crash Tragedy
Janice Brown Family’s Illegal Adoption http://www.youtube.com/watch?v=XhZkIPG_rb4
Election 2012 Federal Crime Victims Plead Public Safety Intervention Shop Class Action Law Firms
Date
/ Length:
12/19/2010 11:00 AM - 2 hrs 29 min
Length:
2 hrs 29 min
Description:
New
HireLyrics Administrative Solutions Tool designed as free one page flyer aggressively marketed on internet and into community
grassroots citizens galavnize the vote Class Action campaigns distributed where working class student and impoverished families
victim pool EDUCATE THROUGH CONVERSATION not STREET PROTEST WE ARE FEDERAL CRIME VICTIMS WITH VOTER CONSTITUENCY CLOUT AND
SIMILARLY SITUATED CLASS ACTION CLAIMS. HireLyrics.org Title of Sign Up Form: DHS FAMILY COURT CHILD SUPPORT SLAUGHTERED
FAMILIES SIGN UP PLAINTIFFS LIST SHOP and RETAIN as GROUP WHISTLEBLOWER CLASS ACTION LAW FIRMS AUDIT FIRMS PAY FORENSICS
EXPERT WITNESSES. 2. Plaintiffs in All Related Dockets USDC PaED 209cv04119-MSG Roxanne Grinage Brounson Lorraine Grinage
Ezekiel Zadkiel Brown Arriyel Roxanne Brown v Fern Brown Caplan Esq Timothy E. Possenti Judge Robert Matthews Anne Ambrose
Erick Brown Saundra Sullivan Diane Kearney Lenwood Kearney are going to sue City of Philadelphia Family Court DHS PACSES
and Pennsylvania Unified Judicial System For One Billion Dollars. Sign Up to Join Class Action Lawsuit Pending. 3. Class
Actions Growing Victim Testimony: Cowlitz County WA CPS DHS Judge James Warme Jean Waller Karen Dinan Esq CASA workers Kidnap
Injuries inflicted Autumn Joy August 9/06/10; Debbie Williams Chantella Tucker Detroit Michigan DHS Orchard Services Vickie
Pallatino Susan Buttons Marianne Taylor; John Gosselin illegal seizure of license inheritance home parent alienation injuries;
Adrienne Tynes State Court Judge Virgil Smith Protects Doctor Child Rapist rape 6 children kill two children animals MI;
Bryan Jones Philadelphia PHA with DHS kidnap for profit schemes; Deborah Young how to navigate appeals Family Pa Superior
Court Informa Pauperis. Tili Ayala cofounder with Denise Smith 2005 DHS Give Us Back Our Children and Justice For Families
will Call In as she travels to Philly fight illegal adoption. John Gottlieb NJ Child Support Slaughtered victim expected
to call in. HireLyrics.org
Plead Eric Holder Intervention: PaED Judge Helps Class Action Lawyers Strong
Arm DHS Slaughtered
Date / Length:
12/9/2010
11:00 AM - 2 hrs
Length:
2 hrs
Description:
12/09/10 Emergency Plea Eric Holder Intervention: PaED Judge Helps Class Action Lawyers
Strong Arm DHS Slaughtered Clients. HireLyrics is Born To Serve on Blog Talk radio. Special Guest Bryan Jones reports 12/08/10
extreme acts of gangland style strong arm organized crime retaliation tactics being participated in by U.S.D.C. PaED Federal
Judges a class action law firm with corruption poisoned City of Philadelphia Mayor Michael Nutter’s administration (Campaign
2012 Slogan: “Philadelphia DHS Slaughtered Federal Crime Victim Voters Vow No 2nd Term Michael Nutter Judge Kevin M.
Dougherty Anne Marie Ambrose Must Go!” Emergency submission to Certified Service Federal Crime Victim Disclosure Distribution
List docket analysis internet accessible links to testimony audio files go to entities authorized or positioned through media
or community development to intervene and help slow Child Slaughter U.S. Economy Fraud Court Reform State of Emergency. See
www.HireLyrics.org case studies submitted as an Administrative tool developed to accommodate financially devastated working
class student and impoverished victims of CPS DHS Court corruption victims achieve access to litigation referral via legal
administrative assistant services contingently document report case merits contingent liabilities to qualified legal industry
professionals for an untapped population of claimants hoping to attract legal representation to litigate Damages Compensation
Criminal Accountability issues while notifying Highest Levels of Law enforcement Lawmakers Court Reform Education Reform CPS
Reformists of resulting Economy Education Health and Career Impacts of State Court Denials Protection From Abuse, children
kidnapped for profit of billing state Agency contractor providers Human Trafficked injured through abuse and separation trauma
injuries theft of heritage vested interest careers religious freedoms role in causing Domestic Violence No Child Safe at Home
epidemic in our country. Roxanne Grinage
This Election Day....CROSS PARTY LINES!!! Vote only for those candidates who acknowledge Federal Crime Witness Victim Voters
Exist as working class student and impoverished American Families.
WE ARE ORGANIZING CITIZENS CAMPAIGNS TO BRING MESSAGE
TO COMMUNITY PER UNIVERSITY AREAS, SHOPPING AREAS, EACH WORK SHIFT, COORDINATING VARIOUS COMMUNITY MENTOR GROUPS, ENTREPRENEURIAL,
BUSINESS OWNERS, EDUCATORS, WORKING CLASS, STUDENT AND IMPOVERISHED (DPW OFFICES) IN GROUPS OF 3 TO 5 ALL AROUND THE CITY
UNTIL ELECTION DAY.
OUR MESSAGE IS SIMPLE.CROSS PARTY LINES!!!
VOTE ONLY FOR THOSE CANDIDATES WHO ACKNOWLEDGE THE EXISTENCE OF CORRUPTION IN GOVERNMENT VICTIM FAMILIES HOLDING EVIDENCE
OF FELONY CRIMES INFLICTED BY STATE AGENCY DHS EMPLOYEES AND CONTRACTORS MISCONDUCT WITH STATE COURT MALPRACTICE WITH NEPOTISM
CORRUPTION IN ELECTED OFFICIALS’ OFFICES.FEDERAL CRIME VICTIM VOTERS CROSS PARTY LINES!!!! IF YOUR
WORKING CLASS STUDENT OR IMPOVERISHED AMERICAN FAMILY HAS BEEN A VICTIM OF CORRUPTION....THIS ELECTION DAY CROSS PARTY LINES!!!!
VOTE FOR THE CANDIDATE WHO ACKNOWLEDGES THAT A HUGE GROUP OF VOTER CONSTITUENCY IS CREATED BY OFFICIAL CORRUPTION FRAUD CIVIL
RIGHTS FELONIES INFLICTED BY OFFICIALS IN A POSITION TO DO SO AND OUR COURTS ARE IN A STATE OF EMERGENCY UNABLE TO PROVIDE
REDRESS OF GRIEVANCES.
Donation buttons for support contributions are at http://www.HireLyrics.org Contact Roxanne Grinage to meet and pick up LOANS of BULL HORN
MEGAPHONES or DONATIONS OF PRINTING PAPER INK POSTER OR CORKBOARD OFFICE SUPPLIES GIFT CERTIFICATES, CAR RENTAL OR PREPAID
CELL PHONE DEALS OR PLEDGES TO USE YOUR PRIVATE VEHICLE TO TAKE PEOPLE TO POLLS DURING ELECTION DAY. WE
COULD ALSO USE THE SUPPORT OF LOCAL RESTAURANTS FOR PROVIDING REFRESHMENTS TO CITIZENS CAMPAIGN TEAMS EVERY DAY BEGINNING
OCTOBER 9, 2010 THROUGH NOVEMBER 2, 2010. Roxanne Grinage, In Philadelphia Pa (229) 395-0039, PO Box 22225,
Philadelphia Pa 19136.RoxanneGrinage@Yahoo.com.
FEDERAL CRIME VICTIM VOTERS CROSS PARTY LINES!!!! IF YOUR WORKING CLASS STUDENT OR IMPOVERISHED AMERICAN FAMILY HAS BEEN A
VICTIM OF CORRUPTION....THIS ELECTION DAY CROSS PARTY LINES!!!! VOTE FOR THE CANDIDATE WHO ACKNOWLEDGES THAT A HUGE GROUP
OF VOTER CONSTITUENCY IS CREATED BY OFFICIAL CORRUPTION FRAUD CIVIL RIGHTS FELONIES INFLICTED BY OFFICIALS IN A POSITION TO
DO SO AND OUR COURTS ARE IN A STATE OF EMERGENCY UNABLE TO PROVIDE REDRESS OF GRIEVANCES. Donations support Federal Crime
Victims of State Agency DHS with Family Court Malpractice pay for our own private investigations that gather evidence to (1)
show to Presidential, USDOJ State Lawmakers and prosecutors with the authority to intervene and audit (2) rescue court ordered
abused injured children suffering in plain sight of community witnesses (3) organize and galvanize as a voter LOBBYING constituency
with endorsement and impeachment clout.
Philadelphia Crime Victims Demand DA Seth Williams Arrest Fugitives Erick Brown Saundra Sullivan Pennsylvania Candidates Hit Snag
Did Not Plan For Large Body Federal Crime Victim Voters
Work Ethic Integrity and Morality are Measurable for Impacting U S Economic Recovery
Take
these steps to get Roxanne Grinage's help legal administrative assistant help documenting and reporting your cps dhs with
family court corruption victimization. Regrettably I am unable to help without a donation to honor my private
investigation expenses that we pray will rescue my June 8, 2010 public mob assault abducted abused and verified injured since
December 13, 2009, Ezekiel Zadkiel Brown Age 4 and Arriyel Roxanne Brown Age 2. Strongest prayers for the rescue of
children of all ages.
1. Donate what you can afford using the donation button. You don't need a pay
pal account, just a credit or debit card. 2. Send an email to RoxanneGrinage@Yahoo.com saying you authorize Roxanne Grinage to publish report and
distribute your verified evidence to anyone who we pray is ethical and has the authorities to help slow a Child Slaughter
U.S. Economy Fraud Court Reform Emergency, including aggressive internet publishing. You must put your full real name,
mailing address with zip code and every phone number you can get a message at. You must put the full names of your children
or grandchildren nieces nephews, their ages and as much as you can remember or have paperwork that shows full names of a social
worker or placement agency or lawyer or child advocate that made false statements about you or gave you misleading or conflicting
information or ignored your evidence in the best interest of your family. You should also indicate whether you think
your children were injured or abused while in someone else's so-called "placement." 3. Call Roxanne Grinage
at 229-395-0039 and be prepared to stay on the phone as long as it takes to plan a reporting strategy (Fraud Report Whistleblower
Transmittal Intervention and Audit Request) that could include your calling into HireLyrics is Born To Serve and Blog
Talk Radio show and giving your testimony in your own voice to become an aggressively downloaded and distributed audio
evidence file. http://blogtalkradio.com/born-to-serve
Contact Roxanne Grinage
Click Pic See 38 Philadelphia Families Whistleblow DHS Family Court Corruption Malpractice Fraud.
Invitation
to Participate in History Making 10/03/2010 HireLyrics Is Born To Serve on Blog Talk Radio Show Topic Agenda.
Disclaimer
Disclaimer. Blog Talk Radio does not agree with support or have any prior knowledge of the content or statements made
in this show. Roxanne Grinage individually and dba as HireLyrics Administrative Services and U.S. Citizens Public Docket
Database take full responsibility for the accuracy, truthfulness and verified fact checking of all content shared in this
broadcast. Enjoy the show! Switchboard opens in 20 minutes.
All callers lines will be opened at the same time so all callers
can hear and speak to each other for the purpose of creating a synergetic discussion forum for learning.
HireLyrics discussion forums abide by the highest standards of personal and professional conduct. We have learned through
responsible evidence gathering due diligence and experience that the nature of corruption in government victimizations particularly
DHS Demonic Horror Story assaults are to disorient confuse divide and conquer. All participants in any HireLyrics mediated
forum show respect and tolerance for differing or passionately expressed opinions and experiences shared. Any caller
who practices any uncivil or disrespectful conducts including verbal violence, name-calling or threats will be immediately
cut off the switchboard or banned from the chat room without comment.
Welcome all to the HireLyrics is Born To Serve on Blog Talk Radio
show where we try to meet Sundays at 11:00 am EST to share administrative solutions for market entering challenges for the
previously unseen, unmeasured, un-accommodated Worldwide Population of Disadvantaged Creators. HireLyrics first launched
our Introduction and Test Show here on Blog Talk Radio March 31, 2008. Welcome, I am your host, Roxanne Grinage, and
founder of a ten year demonstrated Standard Access Mechanism, HireLyrics.org, which raises quality of life by providing those
administrative services that enable fair and holistic entry into competitive processes to cause exposure and earnings opportunities
for the previously unseen unmeasured un-accommodated Worldwide Population of Disadvantaged Creators.
What are we Creating? Americans
are creators of families holding untapped or unfairly diverted U.S. Economy enriching careers contributions into industries
of Education, Engineering Architecture and Bio-engineering, Technology and Information Technology, Medicine and Healing Arts,
Science and Research, Entrepreneurial and Self Employment endeavors, Entertainment Arts Culture and Design, Citizens Journalism,
Transportation, Space Travel, Military and Defense, Small Business Careers and Community Development; Employee Assistance
and Twelve Step Recovery, Life Experience and Mentorship; Litigation Referral, etc.
What is the Disadvantage?
A disadvantaged creator is a person, a partnership or group, a family or community, a generation or region or other identifiable
demographic whose wittingly or unwittingly produced tangible or intangible work and by products are distributed and sold into
processes for consumption by any person place or thing without Fair Recognition Fair Compensation rendered to the creator
of the product contribution.
I did the usual Blog Talk Radio disclaimers at the beginning of the show. But I want
to get back to what we used to do when we first joined Blog Talk Radio March 31, 2008, as a talk radio show host; and that
is to acknowledge Blog Talk Radio as one of the free or low cost internet technologies that we can use to participate in quality
of life enhancing forums for sharing ideas and experiences on just about any subject. One of HireLyrics
Standard Access Practice Model Schematics Slogans is "Sharing Learning Results in Community Courage and Increased Quality
of Life...HireLyrics Shares Our Learning." Thank you Blog Talk Radio for making the collaboration powers of Satellite
Radio Technology available free to those of us who believe we have information to share as a talk radio show host and to those
of us who benefit by hearing the ideas and discussions shared by others.
The call in number for listening live or commenting during a live
broadcast of HireLyrics is Born To Serve on Blog Talk Radio Show is area code (646) 200-4377. That's (646) 200-4377.
The chat room is open during the live broadcast. But you don't have to catch the show live. Blog Talk Radio enables
free listening and free downloads of any Blog Talk Radio show anytime. It's free to be a Blog Talk radio show host and
it's free to be a listener. Listen and download free anytime.
See HireLyrics Administrative Services Docket Monitoring Court
Reform Case Studies Work and Administrative Solutions Tools Developed for Working Class Student and Impoverished Americans
to use to help ourselves pro se which are working to slow nationwide Child Slaughter U.S. Economy Fraud Court Reform State
of Emergency at www.HireLyrics.org. See our video journalism Roxanne Grinage managed YouTube Channels HireLyrics, WhatIsThereLeftToDo,
USCPSCourtReform and RoxanneGrinage YouTube Channel. CNN ireporter Facebook and Yahoo profiles are Roxanne Grinage.
Follow on Twitter/HireLyrics Contact Roxanne Grinage by email at DignityForTheHumanSpirit@HireLyrics.org or RoxanneGrinage@Yahoo.com
and telephone Roxanne Grinage on her cell phone 229-395-0039 in Philadelphia Pa. All calls are recorded. You must
leave your full real name and telephone number and Roxanne Grinage reminds you she is recording her returned telephone call
at the beginning of live conversations. Reporters are advised to get Roxanne's signature on appropriate releases before
quoting or referencing purported interviews. All accurately quoted content and statements published at www.HireLyrics.org
or BlogTalkRadio.com/Born-To-Serve are gratefully appreciated. Everything I do is for the rescue of my 06/08/2010 Public
Mob Assault Abducted Abused and Verified Injured since 12/13/2009, grandbabies, Ezekiel Zadkiel Wright Leach Brown, Age 4
and Arriyel Roxanne Brown, Age 2 born to my daughter Lorraine Carlette Grinage and all CPS corruption in government destroyed
children similarly situated. Strongest Prayers for the rescue of children of all ages destroyed by corruption in government.
Much Love and Respect. Enjoy the show. Chat room is monitored. Switchboard is Open. Callers you are
on the air HireLyrics is Born to Serve on Blog Talk Radio Show.
Today's Show Topic - President and First Lady Obama Pennsylvania
Tom Corbett Dan Onorato Shown Federal Crime Victim Voter.
Assistance of University Think Tank Technology and Student Community
helping Roxanne Grinage build and demonstrate prototype of administrative solutions tool U.S. Citizens controlled Public Docket
Database has revealed a massive special interest voter constituency with lobbyist powers that if harnessed can focus endorsement
or removal clout in the best interest of Working Class Student Impoverished Family Victims of Official Corruption Fraud Civil
Rights; an effective lobbyist group for raising quality of life for the American Family by competitive participation in the
electoral process to vote in elected officials and judges and pull 'em out per voter constituency special interests which
for CPS Corruption in Government Victims is A New Civil Rights Movement Is Underway In These United States...Families Fight
Back Say No More DHS Demonic Horror Stories. Evidence reported by 42 families responsibly pleads intervention and audits of
Philadelphia Michael Nutter and District Attorney R Seth Williams complacent participation in perpetrating Pennsylvania Eastern
District's epidemic child abuse registry fraud self employment and entrepreneurial businesses decimation by way of cover up
and nepotism corruption to benefit the financial agendas of Anne Maria Ambrose DHS' hundreds of multi-million dollar foster
evaluator and adoption contractors. Voter Constituency of Federal Crime Victims created by CPS funded State Agency DHS employee
misconduct with State Court Malpractice Plead with President and First Lady Obama Gubernatorial Candidates Dan Onorato and
Tom Corbett Lawmakers who proposed 7/26/10 Bipartisan Pennsylvania Public Integrity Commission to recognize large special
interests of voter constituency of Federal Crime Victims of Official Corruption Fraud Civil Rights felonies inflicted by the
malpractice and deliberate mis-appropriation of Federal and Recovery Act funding sources by State agency State Court Judges
with taxpayer paid lawyer and CPA malpractice.
A nationwide large body of federal crime witness victims of corruption in
government are measured as a specialized interest group voter constituency comprised of Working Class Student and Impoverished
American Families.
Free and low cost internet technologies offer opportunities for the formerly isolated victim pool fed on in vampire
like fashion by official corruption fraud civil rights assailants to leverage individual accountability for systematic abuse
of immunity language in 1983 Civil Rights act which perpetuates a responsibly documented respectfully reported to Mr. Eric
Holder, President and First Lady Obama, Pennsylvania Gubernatorial Candidates and lawmakers, nationwide Child Slaughter U.S.
Economy Fraud Court Reform State of Emergency.
Courtrooms have become Killing Floors where U.S. or states' constitutions
are all but shredded. Federal children's protective services (CPS) funding intended for family preservation services
is systematically embezzled through acts of misconduct and malpractice by and between states' Departments of Human Services,
taxpayer paid municipal lawyers, private wealthy bar association lawyers with greedy wealthy state court judges who no longer
have to appeal to voter approval but literally buy their judicial seats, a function of old money wealth and "organized
crime" families functioning unquestioned and unaccountable to the working class student impoverished consumers of their
supposed professional services.
DHS Demonic Horror Stories slaughters can be slowed and the tables turned such that the
American Family Victim Pool fed on in vampire like fashion by Official Corruption Fraud Civil Rights assailants bearing titles
of social worker, child advocate, evaluator, state judge, commissioner, agency, taxpayer paid lawyer, CPA, child support enforcement,
custody and divorce lawyer, DHS foster adoption contractor, etc.; can go on the offensive, gather due diligence and report
evidence to ethical authorities like President Barack Obama and United States Department of Justice Mr. Eric Holder
and if passed, 7/26/2010 Bipartisan proposed Pennsylvania Public Integrity commission who we pray will recognize and declare
a State of Emergency based in the systematic abuse of a congressional act and be morally compelled to ride in like the calvary
and enforce U.S. Federal Laws, States' constitutions and enforce the public safety promised in municipal charters.
Working
Class Student and Impoverished victims, formerly easy targets of corruption in government assailants have become a constituency
of voters able to demand accountability from candidates and elected official, able to endorse ethical candidates and remove
from office corrupt judges and elected officials.
Grows from our last week's show 09/24/2010 Open Letter read...Dear Respected
President of the United States Barack Obama; Dear Pennsylvania Gubernatorial Candidate Dan Onorato; Dear Pennsylvania Gubernatorial
Candidate Tom Corbett; Dear Philadelphia Mayor Michael Nutter; Dear Philadelphia District Attorney R Seth Williams:
cc:
Mr. Eric Holder, United States Department of Justice
There exists a voting constituency of working class student and
impoverished families having specialized interests as crime victims created by official corruption fraud civil rights felonies
inflicted. We have used free and low cost services of the internet to develop standard access to administrative solutions
tools which gather evidence depositions and witness testimony; count victims, measure economy fraud and career theft costs;
measure intent culpability or competency of official corruption assailants to responsibly verify document and whistleblow
a nationwide Child Slaughter U.S. Economy Fraud Court Reform State of Emergency. Today, September 24, 2010, across the
street from Philadelphia Family Courthouse, 1801 Vine Street, Philadelphia Pennsylvania we stand beneath the Angels Fountain
having faith in Psalm 91 "for He shall give his angels a command concerning you to lift you up lest you cast your foot
against any stone" representing 322 families nationwide and 42 Pennsylvania families who beseech our elected officials
and those lobbying the interests of candidates to please recognize our quality of life impacting special interests as a voter
constituency characterized by State Court Family Division with State Agency DHS with budget crisis compromised Municipality
corruption. President Barack Obama....you are respectfully addressed because you have the authority to declare a state
of emergency and suspend systematic abuse of immunity language in Congressional acts pending your Executive Officers'
investigation of U.S. Citizens' evidence gathered proving same. Certain U.S. District Court judges appointed for life
unaccountable to working class student and impoverished victims of a nationwide Child Slaughter U.S. Economy Fraud Court
Reform State of Emergency are systemically abusing the immunity language in the 1983 Civil Rights Act to forsake Judicial
Oaths they took to treat the rich and the poor fairly and judicial Canons Codes of Conduct particularly 2B Outside Relationships,
to shirk jurisdictional responsibilities for fairly adjudicating States' Constitutions and U.S. Constitutional Federal Questions
providing "tag team" court reform state of emergency "colleague protection" for Official Corruption Fraud
Civil Rights serial criminals bearing titles of State Judge Malpractice, State Agency Employees Malpractice; wealthy well-connected
bar association lawyers Malpractice; taxpayer paid supreme court and municipality lawyers' and certified public accountants
Malpractice. See July 6, 2010 reported to Mr. Eric Holder U.S.D.C. PaED Filing in all related dockets an official
corruption fraud civil rights complaint which catapulted my family irretrievably into A New Civil Rights Movement...Families
Fight Back...say NO MORE DHS DEMONIC HORROR STORIES. Our working class student and impoverished families constituency have
learned that DOCKET NEVER LIES! CHILD SLAUGHTER U.S. ECONOMY FRAUD IS MEASURED IN DOCKET MONITORING.
Dear
Respected President of the United States Barack Obama; Pennsylvania Gubernatorial Candidates Dan Onorato; Tom Corbett; Philadelphia
Mayor Michael Nutter; Philadelphia District Attorney R Seth Williams; cc: Mr. Eric Holder, United States Department of Justice.
There exists a voting constituency of working class student and impoverished families having specialized interests as crime
victims created by official corruption fraud civil rights felonies inflicted. We have used free and low cost services of the
internet to develop standard access to administrative solutions tools which gather evidence depositions and witness testimony;
count victims, measure economy fraud and career theft costs; measure intent culpability or competency of official corruption
assailants to responsibly verify document and whistleblow a nationwide Child Slaughter U.S. Economy Fraud Court Reform State
of Emergency. Today, September 24, 2010, across the street from Philadelphia Family Courthouse, 1801 Vine Street, Philadelphia
Pennsylvania we stand beneath the Angels Fountain having faith in Psalm 91 “for He shall give his angels a command concerning
you to lift you up lest you cast your foot against any stone” representing 322 families nationwide and 42 Pennsylvania
families who beseech our elected officials and those lobbying the interests of candidates to please recognize our quality
of life impacting special interests as a voter constituency characterized by State Court Family Division with State Agency
DHS with budget crisis compromised Municipality corruption. Contact Roxanne Grinage www.HireLyrics.org email RoxanneGrinage@Yahoo.com
Cell Telephone: (229)395-0039 in Philadelphia, PA. Call in Number for participating live HireLyrics is Born To Serve on Blog
Talk Radio is 646-200-4377. Listen Download Free Anytime! BlogTalkRadio.com/Born-To-Serve. See Video Journalism at YouTube
Channels HireLyrics WhatIsThereLeftToDo RoxanneGrinage and USCPSCourtReform
42
Pennsylvania Families move closer to achieving USDOJ Presidential IRS GAO Federal Intervention in the form of Federal Indictments
of Corrupt Judges in illicit financal partnership with state agency DHS reported to verified and documented by Roxanne Grinage
HireLyrics Administrative Services administrative solutions tools, prototype demonstration of a U.S. Citizens Controlled Public
Docket Database which is working to slow a systematic abuse of immunity language in the 1983 Civil Rights Act, Child Slaughter
U.S. Economy Fraud Court Reform State of Emergency. 09/21/2010 40th DHS Slaughtered Philadelphia working class student impoverished
victim family is 4th verified Judge Alice Beck Dubow corrupt financially incented child advocates with DHS Conractors Methodist
Families and Children, Children's Choice Inc and dishonest DHS social workers - relationships formed in Courtroom H; children's
careers anf families' economies destroyed by wealthy DHS Factory like facilitators, abusing Judicial Canons codes of conduct
and all judicial oaths, forsaking any pretense of guarding Pennsylvania State or U.S. Constitutional rights to due process
in favor of fast tracking sale of traumitized injured children to State Agency contractors who are in violation of Recovery
Act and Federal CPS funding laws. Ahnna Scott (sister/aunt age 23) Ada Banks (maternal grandmother)will publicly post facts
of DHS stolen 18 months Larry Ingram Jr. and 5 months Shamir for the profit of DHS contractors Jewish Families Services Methodist
Families and Children, Children's Choice, Inc. all multimillion dollar billable contractor giants fueled by the stolen vested
interest and careers contributions of working class student and impoverished American families. See how standard access to
public incident posting using free and low cost services of the internet enable a specialized crime victim pool of voters
created by State Agency DHS malpractice with Philadelphia Family Court Domestic Relations judges measure modus operandi, "wolf
pack" and "tag team" individual accountability of financially motivated child advocate Katherine Scribner and the corrupt
relationships bred in Alice Beck Dubow's Courtroom H with DHS social worker misconduct of Marsha Trotter and Cheryl Stewart
to give maternal custodial aunt Anna Scott conflicting advice and when Anna Scott sought to satisfy misrepresented requirements,
used excuse of "mother on drugs" to rip the child away for billing into pre-adoptive DHS contractor. Common denials
of due process felonies of slander, libel and Internal Revenue Office of Professional Accountability are present.
How Poor Families Get Qualified Ethical Litigation Protect State and US Constitutional Rights
World Watches Poor Families Use Pro Se Admin Tools Whistleblow Intervention Audit Fraud Reports
Federal Indictments Loom Poor Families Use Free Internet Whistleblow Corruption Evidence HireLyrics
How Poor CPS DHS Lawyer Elected Official Corruption Victims Can Report Evidence
Federal Indictments Loom Poor Families Use Free Internet Whistleblow Corruption Evidence HireLyrics
Anybody Notice CPS Court Reform Activists Jailed For Contempt Drop Dead Six Months Later?
Judge Robert Matthews Cover Up of Fern Brown Caplan's Crimes Spark New Civil Rights Movement
How Poor CPS DHS Lawyer Elected Official Corruption Victims Can Report Evidence
CIVIL CASE DOCKETED. Notice filed by Appellant Roxanne Grinage in District
Court No. 2-09-cv-04119. (DW)
06/10/2010
RECORD available on District Court
CM/ECF. (DW)
06/11/2010
LEGAL DIVISION LETTER SENT advising that the case has been listed for possible
dismissal due to jurisdictional defect. (CLJ)
06/29/2010
FOLLOW UP LETTER to Michael Daley, Esq. for Lisette Shirdan-Harris and Timothy
E. Possenti requesting the following document(s): Appearance Form on or before 07/13/2010. (DW)
07/01/2010
ECF FILER: ENTRY OF APPEARANCE from Michael Daley, Esquire on behalf of Appellee(s)
The Honorable Lisette Shirdan-Harris. (MD)
SEALDC, SPECIAL
United States District
Court Eastern District of Pennsylvania (Philadelphia) CIVIL DOCKET FOR CASE #: 2:08-cv-04100-JD
A, a minor, Et. Al.
v. NUTTER Et. Al. Assigned to: HONORABLE JAN E. DUBOIS Cause: 42:1983 Civil Rights Act
Date Filed: 08/25/2008 Jury Demand: Defendant Nature of Suit: 440 Civil Rights: Other Jurisdiction: Federal Question
Plaintiff
VICTOR H. TERMINATED: 01/21/2009
represented by
DAVID S. MILDENBERG MILDENBERG
& STALBAUM PC 123 S. BROAD ST., SUITE 1610 PHILADELPHIA, PA 19109 215-545-4870 Email: dsm@milandstal.com
TERMINATED: 08/18/2009
Plaintiff
VICTORIA H. TERMINATED: 01/21/2009
represented by
DAVID S. MILDENBERG (See
above for address) TERMINATED: 08/18/2009
Plaintiff
MALIKA H. TERMINATED: 01/21/2009
represented by
DAVID S. MILDENBERG (See
above for address) TERMINATED: 08/18/2009
Plaintiff
ALFEA D. TERMINATED: 01/21/2009
represented by
DAVID S. MILDENBERG (See
above for address) TERMINATED: 08/18/2009
Plaintiff
JASMIN K. TERMINATED: 01/21/2009
represented by
DAVID S. MILDENBERG (See
above for address) TERMINATED: 08/18/2009
Plaintiff
MELVIN W., JR. TERMINATED: 01/21/2009
represented by
DAVID S. MILDENBERG (See
above for address) TERMINATED: 08/18/2009
Plaintiff
LANCE H. MINOR CHILDREN, BY AND THROUGH THEIR NATURAL MOTHER AND NEXT FRIEND VERONICA L. SPENCER TERMINATED: 01/21/2009
represented by
DAVID S.
MILDENBERG (See above for address) TERMINATED: 08/18/2009
Plaintiff
LADESHA F. A MINOR CHILD, BY AND THROUGH HER NATURAL PARENTS AND NEXT FRIENDS VERONICA L. SPENCER AND BRYAN JONES, ON THEIR OWN
BEHALF AND ON BEHALF OF ANY AND ALL SIMILARLY SITUATED PERSONS TERMINATED: 01/21/2009
represented by
DAVID S.
MILDENBERG (See above for address) TERMINATED: 08/18/2009
Plaintiff
VICTORIA L. SPENCER TERMINATED: 01/21/2009
represented by
DAVID S. MILDENBERG (See
above for address) TERMINATED: 08/18/2009
Plaintiff
BRYAN JONES ON THEIR OWN BEHALF AS NATURAL PARENTS AND ON BEHALF OF ANY AND ALL SIMILARLY SITUATED PERSONS TERMINATED:
01/21/2009
represented by
DAVID S.
MILDENBERG (See above for address) TERMINATED: 08/18/2009
Plaintiff
A, a minor by and through their natural mother and next friend, Parent 1, on their own behalf and on behalf of any and all similarly
situated persons
represented by
BRIAN R. MILDENBERG MILDENBERG &
STALBAUM PC 123 S. BROAD ST. SUITE 1610 PHILADELPHIA, PA 19109 215-545-4870 Email: brm@milandstal.com
LEAD ATTORNEY ATTORNEY TO BE NOTICED
DAVID S. MILDENBERG (See
above for address) ATTORNEY TO BE NOTICED
Plaintiff
B, a minor by and through their natural mother and next friend, Parent 1, on their own behalf and on behalf of any and all similarly
situated persons
represented by
BRIAN R. MILDENBERG (See above for address)
LEAD ATTORNEY ATTORNEY TO BE NOTICED
DAVID S. MILDENBERG (See
above for address) ATTORNEY TO BE NOTICED
Plaintiff
C, a minor by and through their natural mother and next friend, Parent 1, on their own behalf and on behalf of any and all similarly
situated persons
represented by
BRIAN R. MILDENBERG (See above for address)
LEAD ATTORNEY ATTORNEY TO BE NOTICED
DAVID S. MILDENBERG (See
above for address) ATTORNEY TO BE NOTICED
Plaintiff
D, a minor by and through their natural mother and next friend, Parent 1, on their own behalf and on behalf of any and all similarly
situated persons
represented by
BRIAN R. MILDENBERG (See above for address)
LEAD ATTORNEY ATTORNEY TO BE NOTICED
DAVID S. MILDENBERG (See
above for address) ATTORNEY TO BE NOTICED
Plaintiff
E, a minor by and through their natural mother and next friend, Parent 1, on their own behalf and on behalf of any and all similarly
situated persons
represented by
BRIAN R. MILDENBERG (See above for address)
LEAD ATTORNEY ATTORNEY TO BE NOTICED
DAVID S. MILDENBERG (See
above for address) ATTORNEY TO BE NOTICED
Plaintiff
F, a minor by and through their natural mother and next friend, Parent 1, on their own behalf and on behalf of any and all similarly
situated persons TERMINATED: 08/18/2009
represented by
BRIAN R. MILDENBERG (See
above for address) TERMINATED: 08/18/2009 LEAD ATTORNEY
DAVID S. MILDENBERG
(See above for address) TERMINATED: 08/18/2009
Plaintiff
Parent 1 on her own behalf, and on behalf of any and all similarly situated persons
represented by
BRIAN R.
MILDENBERG (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
DAVID S. MILDENBERG (See above for address) ATTORNEY TO BE NOTICED
Plaintiff
G, a minor by and through their natural mother and next friend, Parent 2, on their own behalf and on behalf of any and all similarly
situated persons TERMINATED: 08/18/2009
represented by
BRIAN R. MILDENBERG (See
above for address) TERMINATED: 08/18/2009 LEAD ATTORNEY
DAVID S. MILDENBERG
(See above for address) TERMINATED: 08/18/2009
Plaintiff
H, a minor by and through their natural mother and next friend, Parent 2, on their own behalf and on behalf of any and all similarly
situated persons TERMINATED: 08/18/2009
represented by
BRIAN R. MILDENBERG (See
above for address) TERMINATED: 08/18/2009 LEAD ATTORNEY
DAVID S. MILDENBERG
(See above for address) TERMINATED: 08/18/2009
Plaintiff
Parent 2 on her own behalf, and on behalf of any and all similarly situated persons TERMINATED: 08/18/2009
represented by
BRIAN R.
MILDENBERG (See above for address) TERMINATED: 08/18/2009 LEAD ATTORNEY
DAVID S. MILDENBERG (See above for address) TERMINATED: 08/18/2009
Plaintiff
I, a minor by and through his/her natural mother and next friend, Parent 3, on his/her own behalf and on behalf of any and all
similarly situated persons TERMINATED: 08/18/2009
represented by
BRIAN R. MILDENBERG (See
above for address) TERMINATED: 08/18/2009 LEAD ATTORNEY
DAVID S. MILDENBERG
(See above for address) TERMINATED: 08/18/2009
Plaintiff
Parent 3 on her own behalf, and on behalf of any and all similarly situated persons TERMINATED: 08/18/2009
represented by
BRIAN R.
MILDENBERG (See above for address) TERMINATED: 08/18/2009 LEAD ATTORNEY
DAVID S. MILDENBERG (See above for address) TERMINATED: 08/18/2009
Plaintiff
J, a minor by and through their natural mother and next friend, Parent 4, on their own behalf and on behalf of any and all similarly
situated persons TERMINATED: 08/18/2009
represented by
BRIAN R. MILDENBERG (See
above for address) TERMINATED: 08/18/2009 LEAD ATTORNEY
DAVID S. MILDENBERG
(See above for address) TERMINATED: 08/18/2009
Plaintiff
Parent 4 on her own behalf, and on behalf of any and all similarly situated persons TERMINATED: 08/18/2009
represented by
BRIAN R.
MILDENBERG (See above for address) TERMINATED: 08/18/2009 LEAD ATTORNEY
DAVID S. MILDENBERG (See above for address) TERMINATED: 08/18/2009
Plaintiff
K, a minor by and through their natural mother and next friend, Parent 5, on their own behalf and on behalf of any and all similarly
situated persons TERMINATED: 08/18/2009
represented by
BRIAN R. MILDENBERG (See
above for address) TERMINATED: 08/18/2009 LEAD ATTORNEY
DAVID S. MILDENBERG
(See above for address) TERMINATED: 08/18/2009
Plaintiff
Parent 5 on her own behalf, and on behalf of any and all similarly situated persons TERMINATED: 08/18/2009
represented by
BRIAN R.
MILDENBERG (See above for address) TERMINATED: 08/18/2009 LEAD ATTORNEY
DAVID S. MILDENBERG (See above for address) TERMINATED: 08/18/2009
Plaintiff
L, a minor by and through their natural mother and next friend, Parent 6, on their own behalf and on behalf of any and all similarly
situated persons TERMINATED: 08/18/2009
represented by
BRIAN R. MILDENBERG (See
above for address) TERMINATED: 08/18/2009 LEAD ATTORNEY
DAVID S. MILDENBERG
(See above for address) TERMINATED: 08/18/2009
Plaintiff
Parent 6 on her own behalf, and on behalf of any and all similarly situated persons TERMINATED: 08/18/2009
represented by
BRIAN R.
MILDENBERG (See above for address) TERMINATED: 08/18/2009 LEAD ATTORNEY
DAVID S. MILDENBERG (See above for address) TERMINATED: 08/18/2009
Plaintiff
M, a minor by and through his/her natural parents and next friends, Parent 7 and Parent 8, on his/her own behalf and on behalf
of any and all similarly situated persons TERMINATED: 08/18/2009
represented by
BRIAN R.
MILDENBERG (See above for address) TERMINATED: 08/18/2009 LEAD ATTORNEY
DAVID S. MILDENBERG (See above for address) TERMINATED: 08/18/2009
Plaintiff
Parent 7 on his own behalf, and on behalf of any and all similarly situated persons TERMINATED: 08/18/2009
represented by
BRIAN R.
MILDENBERG (See above for address) TERMINATED: 08/18/2009 LEAD ATTORNEY
DAVID S. MILDENBERG (See above for address) TERMINATED: 08/18/2009
Plaintiff
Parent 8 on her own behalf, and on behalf of any and all similarly situated persons TERMINATED: 08/18/2009
represented by
BRIAN R.
MILDENBERG (See above for address) TERMINATED: 08/18/2009 LEAD ATTORNEY
DAVID S. MILDENBERG (See above for address) TERMINATED: 08/18/2009
Plaintiff
N, a minor
represented by
BRIAN R. MILDENBERG (See
above for address) ATTORNEY TO BE NOTICED
Plaintiff
Parent 9 on her own behalf, and on behalf of any and all similarly situated persons
represented by
BRIAN R.
MILDENBERG (See above for address) ATTORNEY TO BE NOTICED
V.
Defendant
MICHAEL NUTTER IN HIS OFFICIAL CAPACITY AS MAYOR OF THE CITY OF PHILADELPHIA
represented by
RICHARD G. TUTTLE ARCHER
& GREINER P.C. ONE LIBERTY PL 32ND FL 1650 MARKET ST PHILADELPHIA, PA 19103-7393 215-963-3300
Email: rtuttle@archerlaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
STELLA
M. TSAI ARCHER & GREINER, P.C. ONE LIBERTY PL 32ND FL 1650 MARKET ST. PHILADELPHIA, PA
19103-7393 215-279-9348 Email: stsai@archerlaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
MATTHEW K. HUBBARD CITY OF PHILA. LAW DEPT OFFICE OF THE CITY SOLICITOR, CIVIL RIGHTS
UNIT 1515 ARCH STREET., 14TH FLOOR PHILADELPHIA, PA 19103 215-683-5439 Email: matthew.hubbard@phila.gov
ATTORNEY TO BE NOTICED
Defendant
ANNE MARIE AMBROSE IN HER OFFICIAL CAPACITY AS COMMISSIONER OF THE DEPARTMENT OF HUMAN SERVICES ("DHS") OF THE CITY OF PHILADELPHIA
represented by
RICHARD G.
TUTTLE (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
STELLA M. TSAI (See above for address) LEAD ATTORNEY ATTORNEY TO BE
NOTICED
MATTHEW K. HUBBARD (See above for address) ATTORNEY TO BE NOTICED
Defendant
EDWARD G. RENDELL IN HIS OFFICIAL CAPACITY AS GOVERNOR OF THE COMMONWEALTH OF PENNSYLVANIA
represented by
DORIS M.
LEISCH OFFICE OF GENERAL COUNSEL DEPT OF PUBLIC WELFARE 1700 STATE OFFICE BLDG 1400 SPRING GARDEN ST. PHILADELPHIA, PA 19130 215-560-2192 Fax: 215-560-5554 Email: DLeisch@state.pa.us
LEAD ATTORNEY ATTORNEY TO BE NOTICED
RICHARD G. TUTTLE (See
above for address) TERMINATED: 10/17/2008 LEAD ATTORNEY
SHERRI GLANTZ PATCHEN
DEPT.OF PUBLIC WELFARE 1700 STATE OFFICE BUILDING 1400 SPRING GARDEN STREET PHILADELPHIA,
PA 19130-4088 215-560-2192 Fax: 215-560-5554 Email: shpatchen@state.pa.us ATTORNEY TO BE NOTICED
Defendant
THE CITY OF PHILADELPHIA TERMINATED: 03/06/2009
represented by
RICHARD G. TUTTLE (See
above for address) TERMINATED: 03/06/2009 LEAD ATTORNEY
MATTHEW K. HUBBARD
CITY OF PHILA. LAW DEPT DIVISIONAL DEPUTY OFFICE OF THE CITY SOLICITOR, CIVIL RIGHTS UNIT 1515
ARCH STREET., 14TH FLOOR PHILADELPHIA, PA 19103 215-683-5439 Email: matthew.hubbard@phila.gov TERMINATED:
03/06/2009
STELLA M. TSAI (See above for address) TERMINATED: 03/06/2009
Defendant
THE DEPARTMENT OF HUMAN SERVICES
("DHS") OF THE CITY OF PHILADELPHIA TERMINATED: 03/06/2009
represented by
RICHARD G.
TUTTLE (See above for address) TERMINATED: 03/06/2009 LEAD ATTORNEY
Defendant
THE DEPARTMENT OF PUBLIC WELFARE
("DPW") OF THE COMMONWEALTH OF PENNSYLVANIA TERMINATED: 03/06/2009
represented by
DORIS M.
LEISCH (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
RICHARD G. TUTTLE (See above for address) TERMINATED: 10/17/2008 LEAD
ATTORNEY
Defendant
THE COMMONWEALTH OF PENNSYLVANIA TERMINATED:
03/06/2009
represented by
DORIS M.
LEISCH (See above for address) TERMINATED: 03/06/2009 LEAD ATTORNEY
RICHARD G. TUTTLE (See above for address) TERMINATED: 10/17/2008 LEAD
ATTORNEY
Defendant
JOHN/JANE DOES #1-100
Defendant
HARRIET DICHTER SECRETARY OF THE DEPARTMENT OF PUBLIC WELFARE OF THE COMMONWEALTH OF PA
represented by
DORIS M.
LEISCH (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
RICHARD G. TUTTLE (See above for address) TERMINATED: 10/17/2008 LEAD
ATTORNEY
SHERRI GLANTZ PATCHEN (See above for address) ATTORNEY TO BE NOTICED
COMPLAINT against all defendants ( Filing fee $ 350 receipt number 951028.), filed
by MELVIN W., JR, LANCE H., LADESHA F., VICTORIA L. SPENCER, BRYAN JONES, VICTOR H., VICTORIA H., MALIKA H., ALFEA D., JASMIN
K.(tj, ) (Additional attachment(s) added on 8/25/2008: # 1 Ex. A, # 2 Ex. B, # 3 Ex. C1, # 4 Ex. C2, # 5 Ex. C3) (tj, ). (Entered: 08/25/2008)
08/25/2008
Summons Issued; 8 Mailed to counsel
8/25/08 as to MICHAEL NUTTER, ANNE MARIE AMBROSE, ESTELLE B. RICHMAN, EDWARD G. RENDELL, THE CITY OF PHILADELPHIA, THE DEPARTMENT
OF HUMAN SERVICES ("DHS") OF THE CITY OF PHILADELPHIA, THE DEPARTMENT OF PUBLIC WELFARE ("DPW") OF THE
COMMONWEALTH OF PENNSYLVANIA, THE COMMONWEALTH OF PENNSYLVANIA. (tj, ) (Entered: 08/25/2008)
08/25/2008
DEMAND for Trial by Jury by MELVIN
W., JR, LANCE H., LADESHA F., VICTORIA L. SPENCER, BRYAN JONES, VICTOR H., VICTORIA H., MALIKA H., ALFEA D., JASMIN K. (tj,
) (Entered: 08/25/2008)
STIPULATION EXTENDING TIME FOR DEFENDANTS' RESPONSE TO COMPLAINT
by MICHAEL NUTTER. (TUTTLE, RICHARD) (FILED IN ERROR BY ATTORNEY; COPY FORWARDED TO CLERK/JUDGE FOR APPROVAL) Modified on
9/18/2008 (nd). (Entered: 09/17/2008)
STIPULATION AND ORDER THAT THE TIME WITHIN WHICH DEFENDANTS MAY ANSWER PLAINTIFF'S
COMPLAINT IS EXTENDED UNTIL 10/17/08. SIGNED BY HONORABLE JAN E. DUBOIS ON 9/19/08. 9/22/08 ENTERED AND COPIES E-MAILED AND
FAXED BY CHAMBERS.(fdc) (Entered: 09/22/2008)
NOTICE of Withdrawal of Appearance by RICHARD G. TUTTLE on behalf of THE
DEPARTMENT OF PUBLIC WELFARE ("DPW") OF THE COMMONWEALTH OF PENNSYLVANIA(TUTTLE, RICHARD) (Entered: 10/17/2008)
MOTION to Dismiss filed by THE CITY OF PHILADELPHIA.Memorandum, Affidavit, Certificate
of Service. (Attachments: # 1 Memorandum of Law, # 2 Affidavit Burgess-Bolden, # 3 Text of Proposed Order Dismissal Order)(TUTTLE, RICHARD) (Entered:
10/17/2008)
NOTICE of Appearance by DORIS M. LEISCH on behalf of ESTELLE B. RICHMAN,
EDWARD G. RENDELL, THE DEPARTMENT OF PUBLIC WELFARE ("DPW") OF THE COMMONWEALTH OF PENNSYLVANIA, THE COMMONWEALTH
OF PENNSYLVANIA with Certificate of Service(LEISCH, DORIS) (Entered: 10/19/2008)
STIPULATION re 9 MOTION to Dismiss JOINT STIPULATION EXTENDING TIME FOR PLAINTIFFS
TO RESPOND TO THE CITY DEFENDANTS MOTION TO DISMISS by MELVIN W., JR, LANCE H., LADESHA F., VICTORIA L. SPENCER, BRYAN
JONES, VICTOR H., VICTORIA H., MALIKA H., ALFEA D., JASMIN K.. (MILDENBERG, DAVID) (FILED IN ERROR BY ATTORNEY; COPY FORWARDED
TO JUDGE FOR APPROVAL) Modified on 10/31/2008 (nd, ). (Entered: 10/30/2008)
STIPULATION AND ORDER THAT PLAINTIFFS' RESPONSE DATE TO THE CITY OF PHILADELPHIA'S
MOTION TO DISMISS IS HEREBY EXTENDED TO 12/17/08. SIGNED BY HONORABLE JAN E. DUBOIS ON 10/30/08. 11/3/08 ENTERED AND COPIES
E-MAILED AND FAXED BY CHAMBERS.(fdc) (Entered: 11/03/2008)
Praecipe to File First Amended Complaint (pursuant to Court Order) together
with Certificate of Service, by VICTORIA L. SPENCER. (Attachments: # 1 First Amended Complaint, together with Certificate of Service, # 2 Exhibit A-REDACTED-to First Amended Complaint)(MILDENBERG, DAVID)
(Entered: 12/17/2008)
FIRST AMENDED COMPLAINT for Declaratory and Injunctive Relief against MICHAEL
NUTTER, ANNE MARIE AMBROSE, ESTELLE B. RICHMAN, EDWARD G. RENDELL, THE CITY OF PHILADELPHIA, THE DEPARTMENT OF HUMAN SERVICES
("DHS") OF THE CITY OF PHILADELPHIA, THE DEPARTMENT OF PUBLIC WELFARE ("DPW") OF THE COMMONWEALTH OF PENNSYLVANIA,
THE COMMONWEALTH OF PENNSYLVANIA, JOHN/JANE DOES #1-100, filed by A, a minor, B, a minor, C, a minor, D, a minor, E, a minor,
F, a minor, Parent 1, G, a minor, H, a minor, Parent 2, I, a minor, Parent 3, J, a minor, Parent 4, K, a minor, Parent 5,
L, a minor, Parent 6, M, a minor, Parent 7, Parent 8, Certificate of Service.(fdc, ) (Entered: 01/21/2009)
NOTICE of Appearance by STELLA M. TSAI on behalf of THE CITY OF PHILADELPHIA,
MICHAEL A. NUTTER, THE DEPARTMENT OF HUMAN SERVICES ("DHS") OF THE CITY OF PHILADELPHIA and DHS COMMISSIONER ANNE
MARIE AMBROSE with Certificate of Service(TSAI, STELLA) Modified on 6/10/2009 (fh) (Entered: 01/16/2009)
STIPULATION JOINT STIPULATION REGARDING DEADLINES FOR AMENDED PLEADINGS
AND CONFIDENTIALITY by G, a minor, H, a minor, Parent 2, I, a minor, Parent 3, J, a minor, Parent 4, K, a minor, Parent
5, L, a minor, Parent 6, M, a minor, Parent 7, Parent 8, A, a minor, B, a minor, C, a minor, D, a minor, E, a minor, F, a
minor, Parent 1. (MILDENBERG, DAVID) (FILED IN ERROR BY ATTORNEY; COPY FORWARDED TO JUDGE FOR APPROVAL) Modified on 2/12/2009
(nd). (Entered: 02/11/2009)
STIPULATION AND ORDER THAT PLAINTIFFS SHALL FILE A SECOND AMENDED COMPLAINT
("SAC") WITHIN TWENTY (20) DAYS FROM THE ENTRY OF AN ORDER APPROVING THIS STIPULATION; THE CITY DEFENDANTS AND THE
COMMONWEALTH DEFENDANTS SHALL ANSWER OR OTHERWISE PLEAD OR RESPOND TO THE SAC WITHIN THIRTY (30) DAYS OF THE FILING OF THE
SAC, ETC. SIGNED BY HONORABLE JAN E. DUBOIS ON 2/11/09. 2/12/09 ENTERED AND COPIES E-MAILED AND FAXED BY CHAMBERS.(fdc) (Entered:
02/12/2009)
ORDER THAT A STATUS CONFERENCE IS SET FOR 2/26/09 AT 9:00 AM BEFORE HONORABLE
JAN E. DUBOIS. SIGNED BY HONORABLE JAN E. DUBOIS ON 2/17/09. 2/19/09 ENTERED AND COPIES MAILED, E-MAILED AND FAXED BY CHAMBERS,
MAILED UNREPS.(fdc) (Entered: 02/19/2009)
NOTICE of Appearance by BRIAN R. MILDENBERG on behalf of G, a minor, H, a
minor, Parent 2, I, a minor, Parent 3, J, a minor, Parent 4, K, a minor, Parent 5, L, a minor, Parent 6, M, a minor, Parent
7, Parent 8, A, a minor, B, a minor, C, a minor, D, a minor, E, a minor, F, a minor, Parent 1 with Certificate of Service(MILDENBERG,
BRIAN) (Entered: 02/26/2009)
02/26/2009
20
Minute Entry for proceedings held before HONORABLE JAN E. DUBOIS: In Chambers
Conference held on 2/23/09. (fdc, ) (Entered: 02/26/2009)
02/27/2009
Mail Returned as Undeliverable. Mail sent to Multi-Ethnic Behavior Health
(fdc, ) (Entered: 02/27/2009)
ORDER THAT PLAINTIFFS SHALL FILE AND SERVE A SECOND AMENDED COMPLAINT ON
OR BEFORE 3/2/09, IT IS FURTHER ORDERED THAT A TELEPHONE STATUS CONFERENCE IS SET FOR 6/22/09 AT 4:00 PM BEFORE HONORABLE
JAN E. DUBOIS. SIGNED BY HONORABLE JAN E. DUBOIS ON 2/26/09. 3/3/09 ENTERED AND COPIES MAILED, E-MAILED AND FAXED BY CHAMBERS,
MAILED TO UNREPS.(fdc) (Entered: 03/03/2009)
ORDER THAT THE CITY DEFENDANTS' MOTION TO DISMISS IS DENIED AS MOOT WITHOUT
PREJUDICE TO DEFENDANTS' RIGHT TO FILE MOTIONS(S) TO DISMISS THE SECOND AMENDED COMPLAINT. SIGNED BY HONORABLE JAN E. DUBOIS
ON 2/26/09. 3/3/09 ENTERED AND COPIES MAILED, E-MAILED AND FAXED BY CHAMBERS.(fdc) (Entered: 03/03/2009)
STIPULATION re 16 Stipulation, 17 Stipulation and Order, 21 Order,, Set Scheduling Order Deadlines,, Set Hearings, STIPULATION
TO AMEND COURT'S ORDER OF FEBRUARY 26, 2009 TO CONFORM TO PRIOR APPROVED STIPULATION BETWEEN THE PARTIES by G, a minor,
H, a minor, Parent 2, I, a minor, Parent 3, J, a minor, Parent 4, K, a minor, Parent 5, L, a minor, Parent 6, M, a minor,
Parent 7, Parent 8, JOHN/JANE DOES #1-100, A, a minor, B, a minor, C, a minor, D, a minor, E, a minor, F, a minor, Parent
1. (MILDENBERG, DAVID) (FILED IN ERROR BY ATTORNEY; COPY FORWARDED TO JUDGE FOR APPROVAL) Modified on 3/4/2009 (nd, ). (Entered:
03/03/2009)
Praecipe to file second amended complaint pursuant to court order by G, a minor,
H, a minor, Parent 2, I, a minor, Parent 3, J, a minor, Parent 4, K, a minor, Parent 5, L, a minor, Parent 6, M, a minor,
Parent 7, Parent 8, A, a minor, B, a minor, C, a minor, D, a minor, E, a minor, F, a minor, Parent 1. (Attachments: # 1 Second Amended Complaint) (MILDENBERG, DAVID) Modified on 3/5/2009
(nd). (Entered: 03/04/2009)
SECOND AMENDED COMPLAINT against MICHAEL NUTTER, ANNE MARIE AMBROSE, ESTELLE B.
RICHMAN, EDWARD G. RENDELL, filed by G, a minor, H, a minor, Parent 2, I, a minor, Parent 3, J, a minor, Parent 4, K, a minor,
Parent 5, L, a minor, Parent 6, M, a minor, Parent 7, Parent 8, A, a minor, B, a minor, C, a minor, D, a minor, E, a minor,
F, a minor, Parent 1, jury demand.(fdc, ) (Additional attachment(s) added on 3/6/2009: # 1 exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit C, # 5 Exhibit E, # 6 Exhibit F) (rs, ). (Entered: 03/06/2009)
STIPULATION AND ORDER. ORDER THAT PLAINTIFFS' DEADLINE FOR FILING A SECOND
AMENDED COMPLAINT SHALL BE 3/4/09. SIGNED BY HONORABLE JAN E. DUBOIS ON 3/4/09. 3/5/09 ENTERED AND COPIES E-MAILED AND FAXED
BY CHAMBERS.(fdc) (Entered: 03/05/2009)
NOTICE of Appearance by SHERRI GLANTZ PATCHEN on behalf of ESTELLE B. RICHMAN,
EDWARD G. RENDELL with Certificate of Service(PATCHEN, SHERRI) (Entered: 04/01/2009)
STIPULATION AND ORDER THAT THE TIME WITHIN WHICH ALL DEFENDANTS MUST FILE
A RESPONSE TO THE SECOND AMENDED COMPLAINT, CURRENTLY DUE ON 4/3/09, IS HEREBY ENLARGED TO 4/24/09. SIGNED BY HONORABLE JAN
E. DUBOIS ON 4/2/09. 4/3/09 ENTERED AND COPIES MAILED, E-MAILED AND FAXED BY CHAMBERS.(fdc) (Entered: 04/03/2009)
STIPULATION AND ORDER THAT THE TIME WITHIN WHICH THE COMMONWEALTH DEFENDANTS
MUST FILE A RESPONSE TO THE SECOND AMENDED COMPLAINT, CURRENTLY DUE ON 4/24/09, IS HEREBY ENLARGED TO 5/1/09. SIGNED BY HONORABLE
JAN E. DUBOIS ON 4/24/09. 4/24/09 ENTERED AND COPIES MAILED, E-MAILED.(fdc) (Entered: 04/24/2009)
MOTION to Dismiss Plaintiffs' Second Amended Complaint filed by MICHAEL
NUTTER.Memorandum, Certificate of Service. (Attachments: # 1 Memorandum, # 2 Text of Proposed Order)(TUTTLE, RICHARD) (Entered: 04/24/2009)
ORDER THAT PLAINTIFFS' TIME FOR RESPONDING TO THE MOTION TO DISMISS PLAINTIFFS'
SECOND AMENDED COMPLAINT IS EXTENDED FOR A PERIOD OF THIRTY (30) DAYS TO 5/25/09. SIGNED BY HONORABLE JAN E. DUBOIS ON 4/29/09.
4/30/09 ENTERED AND COPIES MAILED, E-MAILED.(fdc) (Entered: 04/30/2009)
STIPULATION re 31 Order,, Set Motion and R&R Deadlines/Hearings, 30 MOTION to Dismiss Plaintiffs' Second Amended ComplaintJOINT
STIPULATION EXTENDING TIME FOR PLAINTIFFS TO RESPOND TO THE CITY DEFENDANTS MOTION TO DISMISS by G, a minor, H, a minor,
Parent 2, I, a minor, Parent 3, J, a minor, Parent 4, K, a minor, Parent 5, L, a minor, Parent 6, M, a minor, Parent 7, Parent
8, A, a minor, B, a minor, C, a minor, D, a minor, E, a minor, F, a minor, Parent 1. (MILDENBERG, DAVID) (FILED IN ERROR BY
ATTORNEY; COPY FORWARDED TO JUDGE FOR APPROVAL) Modified on 5/27/2009 (nd, ). (Entered: 05/26/2009)
STIPULATION AND ORDER THAT PLAINTIFFS AND THE CITY DEFENDANTS REACHED AN
AGREEMENT TO EXTEND PLAINTIFFS' RESPONSE TO MOTION TO DISMISS BY TWENTY (20) DAYS, TO ON OR ABOUT 6/15/09. SIGNED BY HONORABLE
JAN E. DUBOIS ON 5/27/09. 5/28/09 ENTERED AND COPIES MAILED, E-MAILED.(fdc) (Entered: 05/28/2009)
NOTICE of Appearance by MATTHEW K. HUBBARD on behalf of MICHAEL NUTTER, ANNE
MARIE AMBROSE with Certificate of Service(HUBBARD, MATTHEW) (Entered: 06/09/2009)
STIPULATION AND ORDER THAT THE TIME FOR PLAINTIFFS TO RESPOND TO THE COMMONWEALTH
DEFENDANTS' MOTIONS FOR DISMISS IS EXTENDED UNTIL 6/15/09. SIGNED BY HONORABLE JAN E. DUBOIS ON 6/9/09. 6/9/09 ENTERED AND
COPIES MAILED, E-MAILED.(fdc) (Entered: 06/09/2009)
MOTION for Extension of Time to File Response/Reply as to 32 MOTION to Dismiss, 34 Order,, Set Motion and R&R Deadlines/Hearings, 36 Order, Set Motion and R&R Deadlines/Hearings, 30 MOTION to Dismiss Plaintiffs' Second Amended Complainttogether
with Proposed Order, Memorandum of Law, and Certificate of Service filed by G, a minor, H, a minor, Parent 2, I, a minor,
Parent 3, J, a minor, Parent 4, K, a minor, Parent 5, L, a minor, Parent 6, M, a minor, Parent 7, Parent 8, A, a minor, B,
a minor, C, a minor, D, a minor, E, a minor, F, a minor, Parent 1.memorandum, certificate of service.(MILDENBERG, BRIAN) (Entered:
06/15/2009)
ORDER THAT PLAINTIFFS' MOTION TO ENLARGE TIME FOR PLAINTIFFS TO RESPOND TO
DEFENDANTS' MOTIONS TO DISMISS IS GRANTED. IT IS FURTHER ORDERED THAT THE TIME IN WHICH PLAINTIFFS' RESPONSE TO THE SAID MOTIONS
OF DEFENDANTS IS HEREBY ENLARGED FOR A PERIOD OF SEVEN (7) DAYS, UNTIL ON OR BEFORE 6/22/09. SIGNED BY HONORABLE JAN E. DUBOIS
ON 6/16/09. 6/16/09 ENTERED AND COPIES MAILED, E-MAILED.(fdc) (Entered: 06/16/2009)
06/23/2009
39
Minute Entry for proceedings held
before HONORABLE JAN E. DUBOIS: Telephone Conference held on 6/22/09 (fdc, ) (Entered: 06/23/2009)
ORDER THAT ALL RESPONSES TO PROPOSED PLAINTIFF ABRAHAM GAFNI'S MOTION TO
SUBSTITUTE HIMSELF AS A PARTY PLAINTIFF ARE DUE BY 6/24/09, MOTIONS ARE DUE BY 7/16/09, A CHAMBERS CONFERENCE IS SET FOR 8/6/09
AT 4:45 PM IN COURTROOM BEFORE HONORABLE JAN E. DUBOIS, A TELEPHONE CONFERENCE IS SET FOR 6/25/09 AT 2:00 PM BEFORE HONORABLE
JAN E. DUBOIS. SIGNED BY HONORABLE JAN E. DUBOIS ON 6/22/09. 6/24/09 ENTERED AND COPIES MAILED, E-MAILED, MAILED UNREPS.(fdc)
(Entered: 06/24/2009)
RESPONSE in Opposition re 32 MOTION to Dismiss, 30 MOTION to Dismiss Plaintiffs' Second Amended ComplaintPlaintiffs'
Response in Opposition to Defendants' Motions to Dismiss, together with Memorandum of Law, Proposed Order and Certificate
of Service filed by A, a minor, B, a minor, C, a minor, D, a minor, E, a minor, Parent 1. (MILDENBERG, BRIAN) (Entered:
06/24/2009)
Praecipe to Attach Exhibit A to Plantiffs' Memorandum of Law in Opposition
to Defendants' Motions to Dismiss EXHIBIT A is attached hereto in PDF by A, a minor, B, a minor, C, a minor, D, a
minor, E, a minor, Parent 1. (MILDENBERG, BRIAN) Modified on 6/25/2009 (nd, ). (Entered: 06/25/2009)
Reply Memorandum to Motion re 30 MOTION to Dismiss Plaintiffs' Second Amended Complaint filed by MICHAEL NUTTER, Certificate of Service. (TUTTLE,
RICHARD) Modified on 7/8/2009 (nd, ). (Entered: 07/07/2009)
Reply Memorandum of Lawe in Support of 32 MOTION to Dismiss Second Amended Complaint filed by ESTELLE
B. RICHMAN, EDWARD G. RENDELL, Certificate of Service. (LEISCH, DORIS) Modified on 7/13/2009 (fh) (Entered: 07/10/2009)
STIPULATION AND ORDER THAT THE TIME WITHIN WHICH ALL DEFENDANTS MUST FILE
A REPLY MEMORANDUM OF LAW IN SUPPORT OF THEIR MOTIONS TO DISMISS, CURRENTLY DUE ON 7/7/2009, IS HEREBY ENLARGED TO 7/10/2009.
SIGNED BY HONORABLE JAN E. DUBOIS ON 7/21/2009. 7/21/2009 ENTERED AND COPIES MAILED, E-MAILED.(tomg, ) (Entered: 07/21/2009)
ORDER THAT THE PLAINTIFFS' LETTER/REQUEST FOR A ONE DAY EXTENSION OF TIME
FROM 6/23/2009 TO 6/24/2009, TO RESPOND TO DEFENDANTS MOTIONS TO DISMISS IS GRANTED NUNC PRO TUNC.. SIGNED BY HONORABLE JAN
E. DUBOIS ON 7/20/2009. 7/21/2009 ENTERED AND COPIES MAILED, E-MAILED.(tomg, ) (Entered: 07/21/2009)
Letter from BRIAN R. MILDENBERG, ESQUIRE TO THE HONORABLE JAN E. DUBOIS DATED
6/23/2009 IN RE: THE FILING OF PLAINTIFF'S RESPONSE TO DEFENDANTS' MOTION TO DISMISS. (tomg, ) (Entered: 07/21/2009)
TRANSCRIPT of Telephone Conference held on 6/22/09, before Judge DuBois.
Court Reporter/Transcriber Laws Transcription Service. Transcript may be viewed at the court public terminal or purchased
through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be
obtained through PACER.. Redaction Request due 8/24/2009. Redacted Transcript Deadline set for 9/3/2009. Release of Transcript
Restriction set for 11/2/2009. (fdc, ) (Entered: 08/03/2009)
Notice of Filing of Official Transcript with Certificate of Service re 49 Transcript - PDF, 8/3/09 Entered and Copies Emailed and Mailed. (fdc)
(Entered: 08/03/2009)
ORDER THAT ON OR BEFORE 8/10/09, PLAINTIFFS SHALL FILE A MOTION FOR LEAVE
TO FILE A THIRD AMENDED COMPLAINT. SIGNED BY HONORABLE JAN E. DUBOIS ON 8/3/09. 8/4/09 ENTERED AND COPIES MAILED, E-MAILED.(fdc)
(Entered: 08/04/2009)
Praecipe to File Third Amended Complaint, Exhibits, and Blacklined Version of Complaint,
Pursuant to Leave of Court, together with Certificate of Service by A, a minor, B, a minor, C, a minor, D, a minor, E, a minor.
(Attachments: # 1 Third Amended Complaint, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M, # 15 Blackline version of TAC compared against SAC)(MILDENBERG, BRIAN)
(Entered: 08/13/2009)
THIRD AMENDED COMPLAINT against MICHAEL NUTTER, ANNE MARIE AMBROSE, ESTELLE B.
RICHMAN, EDWARD G. RENDELL, JOHN/JANE DOES #1-100, filed by N, a minor, Parent 9, A, a minor, B, a minor, C, a minor, D, a
minor, E, a minor, Parent 1, jury demand, certificate of service. (Attachments: # 1 ex.a, # 2 ex.b, # 3 ex.c, # 4 ex.d, # 5 ex.e, # 6 ex.f, # 7 ex.g, # 8 ex.h, # 9 ex.i, # 10 ex.j, # 11 ex.k, # 12 ex.l, # 13 ex.m)(fdc, ) (Entered: 08/18/2009)
ORDER THAT DEFENDANTS' MOTIONS TO DISMISS PLAINTIFFS' SECOND AMENDED COMPLAINT
ARE DENIED AS MOOT; AND THAT DEFTS MAYOR MICHAEL NUTTER, AND COMMISSIONER ANNE MARIE AMBROSE, AND THE COMMONWEALTH DEFENDANTS,
SHALL RESPOND TO THE THIRD AMENDED COMLAINT BY 9/17/2009. SIGNED BY HONORABLE JAN E. DUBOIS ON 8/24/2009. 8/25/2009 ENTERED
AND COPIES E-MAILED.(md) (Entered: 08/25/2009)
MOTION to Dismiss Third Amended Complaint filed by MICHAEL NUTTER.Certificate
of Service. (Attachments: # 1 Memorandum of Law, # 2 Proposed Order)(TUTTLE, RICHARD) (Entered: 09/17/2009)
MOTION to Dismiss Third Amended Complaint filed by ESTELLE B. RICHMAN,
EDWARD G. RENDELL.Proposed Order, Memorandum of Law, Certificate of Service.(PATCHEN, SHERRI) (Entered: 09/24/2009)
STIPULATION AND ORDER THAT THE TIME WITHIN WHICH ALL DEFENDANTS MUST FILE
A RESPONSE TO THE THIRD AMENDED COMPLAINT, CURRENTLY DUE ON 9/17/09, IS HEREBY ENLARGED TO 9/24/09. SIGNED BY HONORABLE JAN
E. DUBOIS ON 9/25/09. 9/28/09 ENTERED AND COPIES MAILED, E-MAILED.(fdc) (Entered: 09/28/2009)
ORDER THAT DEFENDANTS' MOTION TO FILE EXHIBITS UNDER SEAL IS GRANTED. SIGNED
BY HONORABLE JAN E. DUBOIS ON 9/28/09. 9/28/09 ENTERED AND COPIES MAILED, E-MAILED.(fdc) (Entered: 09/28/2009)
09/28/2009
60
Defendants' Exhibits A-E,H,N and P
to their Motion to Dismiss Plaintiffs' Third Amended Complaint. (FILED UNDER SEAL). (fdc) (Entered: 09/28/2009)
STIPULATION AND ORDER THAT PLAINTIFFS' RESPONSE DATE TO DEFENDANTS' MOTIONS
TO DISMISS IS HEREBY EXTENDED FOURTEEN (14) DAYS, TO 11/2/09. SIGNED BY HONORABLE JAN E. DUBOIS ON 10/20/09. 10/21/09 ENTERED
AND COPIES MAILED, E-MAILED.(fdc) (Entered: 10/21/2009)
RESPONSE in Opposition re 57 MOTION to Dismiss Third Amended Complaint, 56 MOTION to Dismiss Third Amended ComplaintPLAINTIFFS
RESPONSE IN OPPOSITION TO THE MOTIONS TO DISMISS PLAINTIFFS THIRD AMENDED COMPLAINT OF THE CITY AND COMMONWEALTH DEFENDANTS,
together with Proposed Orders and Certificate of Service, filed by A, a minor, C, a minor, E, a minor, Parent 1. (MILDENBERG,
BRIAN) (Entered: 11/16/2009)
MOTION for Leave to File Reply Memorandum filed by MICHAEL NUTTER.Certificate
of Service. (Attachments: # 1 Reply Memorandum, # 2 Text of Proposed Order)(TUTTLE, RICHARD) (Entered: 11/24/2009)
ORDER THAT THE CITY DEFENDANTS' MOTION FOR LEAVE TO FILE A REPLY MEMORANDUM
IS GRANTED. SIGNED BY HONORABLE JAN E. DUBOIS ON 11/24/09.11/27/09 ENTERED AND COPIES MAILED, E-MAILED.(fdc) (Entered: 11/27/2009)
ORDER THAT THE CITY DEFENDANTS' SECOND MOTION TO FILE EXHIBITS UNDER SEAL
IS GRANTED. SIGNED BY HONORABLE JAN E. DUBOIS ON 12/14/09.12/14/09 ENTERED AND COPIES MAILED, E-MAILED.(fdc) (Entered: 12/14/2009)
12/14/2009
68
EXHIBITS A & B to Reply Memorandum
in Support of City Defendants' Motion to Dismiss Plaintiffs' Third Amended Complaint (FILED UNDER SEAL). (fdc) (Entered: 12/14/2009)
MEMORANDUM AND ORDER THAT THE CITY DEFENDANTS' MOTION TO DISMISS IS DENIED,
AND THE COMMONWEALTH DEFENDANTS' MOTION TO DISMISS IS DENIED IN PART AND GRANTED IN PART. IT IS FURTHER ORDERED THAT THE CLAIMS
OF MINOR PLAINTIFFS, B,D,N, BY AND THROUGH THEIR NATURAL MOTHER, AND PARENT 9, ON HER OWN BEHALF AND ON BEHALF OF ANY AND
ALL SIMILARLY SITUATED PERSONS, ARE DISMISSED WITH PREJUDICE. IT IS FURTHER ORDERED THAT HARRIET DICHTER, THE CURRENT SECRETARY
OF THE DEPARTMENT OF PUBLIC WELFARE OF THE COMMONWEALTH OF PA, IS SUBSTITUTED AS DEFENDANT FOR ESTELLE RICHMAN. SIGNED BY
HONORABLE JAN E. DUBOIS ON 8/27/10. 8/27/10 ENTERED AND COPIES MAILED, E-MAILED, FAXED BY CHAMBERS.(fdc) (Entered: 08/27/2010)
APPEAL, STANDARD
United States District Court Eastern District of Pennsylvania (Philadelphia) CIVIL DOCKET FOR CASE #: 2:09-cv-04119-MSG
GRINAGE v. FERN BROWN CAPLAN, ESQUIRE et al Assigned to: HONORABLE MITCHELL S. GOLDBERG
Date Filed: 09/10/2009 Jury Demand: None Nature of Suit: 440 Civil Rights: Other Jurisdiction: Federal Question
Plaintiff
ROXANNE GRINAGE
represented by
ROXANNE GRINAGE PO BOX 22225 PHILADELPHIA, PA 19136 Email: DIGNITYFORTHEHUMANSPIRIT@HIRELYRICS.ORG PRO SE
V.
Defendant
FERN BROWN CAPLAN, ESQUIRE
Defendant
TIMOTHY E. POSSENTI ESQUIRE, PC
represented by
TIMOTHY E. POSSENTI 30 WEST STATE STREET
MEDIA, PA 19063 610-627-5560 Email: tepesquire@aol.com ATTORNEY TO BE NOTICED
Defendant
LISETTE SHIRDAN-HARRIS ESQUIRE
represented by
MICHAEL DALEY SUPREME COURT OF PA ADMINISTRATIVE OFFICE OF PA COURTS 1515 MARKET ST., STE 1414 PHILADELPHIA, PA 19102 215-560-6300 Email:
legaldepartment@pacourts.us LEAD ATTORNEY ATTORNEY TO BE NOTICED
Defendant
SERGEANT MUSE AND/OR USER OF MOBILE TELEPHONE 215-906-3955
Defendant
USER OF FAX NO. 215-686-3555
Defendant
JOHN D. GREEN SHERIFF, SHERIFF'S DEPT-DOMESTIC RELATIONS
ORDER THAT PLAINTIFF IS GRANTED LEAVE TO PROCEED IN FORMA PAUPERIS. THE COMPLAINT
IS TO BE FILED AND SUMMONS ARE TO BE ISSUED. THE UNITED STATES MARSHAL FOR THE EASTERN DISTRICT OF PENNSYLVANIA SHALL SERVE
THE SUMMONS AND COMPLAINT UPON THE DEFENDANTS AT NO COST TO THE PLAINTIFF. SIGNED BY HONORABLE MITCHELL S. GOLDBERG ON 9/15/09.
9/16/09 ENTERED AND COPIES MAILED TO PRO SE.(ah) (Entered: 09/16/2009)
COMPLAINT against FERN BROWN CAPLAN, ESQUIRE, TIMOTHY E. POSSENTI, LISETTE
SHIRDAN-HARRIS, SERGEANT MUSE, USER OF FAX NO. 215-686-3555, JOHN D. GREEN (IFP GRANTED), filed by ROXANNE GRINAGE. (EXHIBITS
FILED IN HARD COPY).(ah) (Entered: 09/16/2009)
09/15/2009
Summons Issued as to FERN BROWN CAPLAN, ESQUIRE, TIMOTHY E. POSSENTI, LISETTE
SHIRDAN-HARRIS, SERGEANT MUSE, USER OF FAX NO. 215-686-3555, JOHN D. GREEN. 6 Forwarded To: U.S. Marshal Service on 9/16/09.
(ah) (Entered: 09/16/2009)
ORDER THAT PLAINTIFF'S "EMERGENCY REQUEST FOR RESTRAINING ORDER"
AND "EMERGENCY REQUEST FOR INJUNCTIVE RELIEF" ARE DENIED WITHOUT PREJUDICE. PLAINTIFF MAY RESUBMIT HER REQUESTS
IN COMPLIANCE WITH FED. R. CIV. P. 65. SIGNED BY HONORABLE MITCHELL S. GOLDBERG ON 9/14/09. 9/15/09 ENTERED AND COPIES MAILED
TO PRO SE.(ah) (Entered: 09/16/2009)
AMENDED COMPLAINT against FERN BROWN CAPLAN, ESQUIRE, TIMOTHY E. POSSENTI,
LISETTE SHIRDAN-HARRIS, SERGEANT MUSE, USER OF FAX NO. 215-686-3555, JOHN D. GREEN, filed by ROXANNE GRINAGE. (EXHIBITS FILED
IN HARD COPY).(ah) (Entered: 10/16/2009)
10/16/2009
Summons Issued as to FERN BROWN CAPLAN, ESQUIRE, TIMOTHY E. POSSENTI, LISETTE
SHIRDAN-HARRIS, SERGEANT MUSE, USER OF FAX NO. 215-686-3555, JOHN D. GREEN. 6 Forwarded To: U.S. Marshal Service on 10/16/09.
(ah) (Entered: 10/16/2009)
EMERGENCY SECOND AMENDED COMPLAINT against FERN BROWN CAPLAN, ESQUIRE, TIMOTHY
E. POSSENTI, LISETTE SHIRDAN-HARRIS, SERGEANT MUSE, USER OF FAX NO. 215-686-3555, JOHN D. GREEN, filed by ROXANNE GRINAGE.(Striken
from Record for Failure to Comply)(sg, ) (Entered: 10/28/2009)
ORDER THAT PLAINTIFFS EMERGENCY REQUEST FOR RESTRAINING ORDER IS DENIED WITHOUT
PREJUDICE. PLAINTIFF MAY RESUBMIT HER REQUEST IN COMPLIANCE WITH FED.R.CIV.P.65.. SIGNED BY HONORABLE MITCHELL S. GOLDBERG
ON 10/26/2009. 10/28/2009 ENTERED AND COPIES MAILED TO PRO SE.(sg, ) (Entered: 10/28/2009)
ORDER THAT THE CLERK OF COURT IS DIRECTED TO STRIKE PLAINTIFFS, "EMERGENCY
SECOND AMENDED COMPLAINT," FROM THE RECORD FOR FAILURE TO COMPLY WITH F.R.C.P. 15(a). SIGNED BY HONORABLE MITCHELL S.
GOLDBERG ON 10/29/2009. 10/30/2009 ENTERED AND COPIES MAILED to Pro Se.(sg, ) (Entered: 10/30/2009)
MOTION to Dismiss Plaintiff's Amended Complaint filed by LISETTE SHIRDAN-HARRIS.Certificate
of Service and Memorandum of Law. (Attachments: # 1 Text of Proposed Order, # 2 Exhibit A)(DALEY, MICHAEL) (Entered: 11/02/2009)
11/05/2009
LETTER TO R. GRINAGE RETURNED TO SENDER,
INSUFFICIENT ADDRESS. UNABLE TO FORWARD. (sg, ) (Entered: 11/05/2009)
RESPONSE to Motion re 10 MOTION to Dismiss Plaintiff's Amended Complaint filed by
ROXANNE GRINAGE. CERTIFICATE OF SERVICE. (sg, ) (Entered: 11/10/2009)
ORDER THAT PLAINTIFFS MOTION FOR DEFAULT JUDGMENT IS DENIED. PLAINTIFFS MOTION
FOR DEFAULT JUDGMENT IS PREMATURE AS PLAINTIFF HAS YET TO SERVE FIVE (5) OF THE SIX (6) DEFENDANTS IN THE ABOVE-CAPTIONED
ACTION AND A MOTION TO DIMISS BY THE SIXTH DEFENDANT IS CURRENTLY PENDING BEFORE THE COURT. SIGNED BY HONORABLE MITCHELL S.
GOLDBERG ON 2/4/2010.2/5/2010 ENTERED AND COPIES MAILED TO PRO SE AND E-MAILED.(sg, ) (Entered: 02/05/2010)
MOTION AFFIDAVIT OF ROXANNE GRINAGE THIS COURT SHOULD RECUSE ITSELF PURSUANT
TO 28 U.S.C. 144 BECAUSE ITEMIZED USDC PAED DOCKET MANIPULATION CONFIRMS PREJUDICE IN FAVOR OF OFFICIAL CORRUPTION FRAUD CIVIL
RIGHTS DEFENDANT TIMOTHY E. POSSENTI, ESQUIRE PC AND FERN BROWN CAPLAN, ESQUIRE; AND USDOJ ATTORNEY GENERAL SHOULD APPOINT
A SPECIAL PROSECUTOR FROM ANOTHER UNITED STATE DISTRICT; AND FOR OVERDUE JUDGMENT OF PLAINTIFFS FORCED COMMERCE COSTS SINCE
07/20/2009; AND FOR LEAVE TO PROCEED TO JURY TRIAL DISCERNMENT OF PLAINTIFF SIX TIMES NUNC PRO TUNC.CERTIFICATE OF SERVICE,
EXHIBITS.(sg, ) (Entered: 02/16/2010)
ORDER THAT PLAINTIFF SHALL FORWARD HER CORRECT MAILING ADDRESS TO THE U.S.
MARSHAL'S OFFICE FOR THE EASTERN DISTRICT OF PENNSYLVANIA WITHIN IN SEVEN (7) DAYS OF THE DATE OF THIS ORDER OR THE ABOVE-CAPTIONED
ACTION WILL BE DISMISSED FOR LACK OF PROSECUTION. SIGNED BY HONORABLE MITCHELL S. GOLDBERG ON 2/18/2010. 2/19/2010 ENTERED
AND COPIES MAILED TO PRO SE AND E-MAILED.(sg, ) (Entered: 02/19/2010)
PLAINTIFF'S COMPLIANCE WITH ORDER OF FEBUARY 18, 2010 AND RESPECTFUL REITERATION
THAT IT IS THIS COURT'S FLAGRANT AND UNCORRECTED CLERICAL ERRORS WHICH PREVENTED SERVICE OF SUMMONS UPON DEFENDANTS AND NO
"LACK OF PROSECUTION." (sg, ) (Entered: 02/22/2010)
ORDER THAT PLAINTIFF'S MOTION IS DENIED AS FRIVOLOUS BECAUSE IT LACKS BOTH
FACTUAL AND LEGAL MERIT. SIGNED BY HONORABLE MITCHELL S. GOLDBERG ON 3/16/2010.3/16/2010 ENTERED AND COPIES MAILED TO PRO
SE AND E-MAILED.(sg, ) (Entered: 03/16/2010)
MEMORANDUM AND/OR OPINION THAT FOR THE FOREGOING REASONS, THIS COURT LAST
JURISDICTION OVER PLAINTIFF'S CLAIMS AND JUDGE SHIRDAN-HARRIS HAS JUDICIAL IMMUNITY. ACCORDINGLY, THIS COURT NEED NOT OTHERWISE
ADDRESS THE MERITS OF PLAINTIFF'S CLAIMS. AN ORDER FOLLOWS. SIGNED BY HONORABLE MITCHELL S. GOLDBERG ON 3/17/2010. 3/18/2010
ENTERED AND COPIES MAILED TO PRO SE AND E-MAILED.(sg, ) (Entered: 03/18/2010)
ORDER THAT DEFENDANT JUDGE SHIRDAN-HARRIS'S MOTION TO DISMISS IS GRANTED
AND PLAINTIFF'S ACTION AGAINST DEFENDANT JUDGE SHIRDAN-HARRIS IS DISMISSED. SIGNED BY HONORABLE MITCHELL S. GOLDBERG ON 3/17/2010.
3/18/2010 ENTERED AND COPIES MAILED TO PRO SE AND E-MAILED.(sg, ) (Entered: 03/18/2010)
Summons Returned Unexecuted by ROXANNE GRINAGE as to FERN BROWN CAPLAN, ESQUIRE,
SERGEANT MUSE, USER OF FAX NO. 215-686-3555. The City will not accept service due to defective caption. Return Unexecuted.
(sg, ) (Entered: 04/02/2010)
SUMMONS Returned Executed by ROXANNE GRINAGE re: US MARSHAL served Summons
and Complaint upon TIMOTHY E. POSSENTI, LISETTE SHIRDAN-HARRIS by PERSONAL SERVICE. TIMOTHY E. POSSENTI served on 3/30/2010,
answer due 4/20/2010; LISETTE SHIRDAN-HARRIS served on 3/29/2010, answer due 4/19/2010. (sg, ) (Entered: 04/02/2010)
MOTION OF TIMOTHY E. POSSENTI TO DISMISS PLAINTIFF'S AMENDED COMPLAINT. MEMORANDUM
OF LAW, EXHIBITS, CERTIFICATE OF SERVICE, PROPOSED ORDER.(sg, ) (Entered: 04/20/2010)
WAIVER OF SERVICE Returned Executed by ROXANNE GRINAGE. FERN BROWN CAPLAN,
ESQUIRE waiver sent on 4/23/2010, answer due 6/22/2010. (sg, ) (Entered: 04/28/2010)
ORDER THAT DEFENDANT TIMOTHY E. POSSENTI'S MOTION TO DISMISS PLAINTIFF'S
AMENDED COMPLAINT IS GRANTED AND PLAINTIFF'S ACTION AGAINST DEFENDANT TIMOTHY E. POSSENTI IS DIMISSED. SIGNED BY HONORABLE
MITCHELL S. GOLDBERG ON 5/11/2010. 5/11/2010 ENTERED AND COPIES MAILED TO PRO SE AND E-MAILED.(sg, )MAILED TO UNREPS. Modified
on 5/12/2010 (sg, ). (Entered: 05/11/2010)
Date Filed: 09/10/2009 Jury Demand: None Nature
of Suit: 440 Civil Rights: Other Jurisdiction: Federal Question
Plaintiff
ROXANNE GRINAGE
represented by
ROXANNE GRINAGE PO BOX 22225 PHILADELPHIA, PA 19136 Email: DIGNITYFORTHEHUMANSPIRIT@HIRELYRICS.ORG PRO SE
V.
Defendant
FERN BROWN CAPLAN, ESQUIRE
Defendant
TIMOTHY E. POSSENTI ESQUIRE, PC
represented by
TIMOTHY E. POSSENTI 30 WEST STATE STREET
MEDIA, PA 19063 610-627-5560 Email: tepesquire@aol.com ATTORNEY TO BE NOTICED
Defendant
LISETTE SHIRDAN-HARRIS ESQUIRE
represented by
MICHAEL DALEY SUPREME COURT OF PA ADMINISTRATIVE OFFICE OF PA COURTS 1515 MARKET ST., STE 1414 PHILADELPHIA, PA 19102 215-560-6300 Email:
legaldepartment@pacourts.us LEAD ATTORNEY ATTORNEY TO BE NOTICED
Defendant
SERGEANT MUSE AND/OR USER OF MOBILE TELEPHONE 215-906-3955
Defendant
USER OF FAX NO. 215-686-3555
Defendant
JOHN D. GREEN SHERIFF, SHERIFF'S DEPT-DOMESTIC RELATIONS
ORDER THAT PLAINTIFF IS GRANTED LEAVE TO PROCEED IN FORMA PAUPERIS. THE COMPLAINT
IS TO BE FILED AND SUMMONS ARE TO BE ISSUED. THE UNITED STATES MARSHAL FOR THE EASTERN DISTRICT OF PENNSYLVANIA SHALL SERVE
THE SUMMONS AND COMPLAINT UPON THE DEFENDANTS AT NO COST TO THE PLAINTIFF. SIGNED BY HONORABLE MITCHELL S. GOLDBERG ON 9/15/09.
9/16/09 ENTERED AND COPIES MAILED TO PRO SE.(ah) (Entered: 09/16/2009)
COMPLAINT against FERN BROWN CAPLAN, ESQUIRE, TIMOTHY E. POSSENTI, LISETTE
SHIRDAN-HARRIS, SERGEANT MUSE, USER OF FAX NO. 215-686-3555, JOHN D. GREEN (IFP GRANTED), filed by ROXANNE GRINAGE. (EXHIBITS
FILED IN HARD COPY).(ah) (Entered: 09/16/2009)
09/15/2009
Summons Issued as to FERN BROWN CAPLAN, ESQUIRE, TIMOTHY E. POSSENTI, LISETTE
SHIRDAN-HARRIS, SERGEANT MUSE, USER OF FAX NO. 215-686-3555, JOHN D. GREEN. 6 Forwarded To: U.S. Marshal Service on 9/16/09.
(ah) (Entered: 09/16/2009)
ORDER THAT PLAINTIFF'S "EMERGENCY REQUEST FOR RESTRAINING ORDER"
AND "EMERGENCY REQUEST FOR INJUNCTIVE RELIEF" ARE DENIED WITHOUT PREJUDICE. PLAINTIFF MAY RESUBMIT HER REQUESTS
IN COMPLIANCE WITH FED. R. CIV. P. 65. SIGNED BY HONORABLE MITCHELL S. GOLDBERG ON 9/14/09. 9/15/09 ENTERED AND COPIES MAILED
TO PRO SE.(ah) (Entered: 09/16/2009)
AMENDED COMPLAINT against FERN BROWN CAPLAN, ESQUIRE, TIMOTHY E. POSSENTI,
LISETTE SHIRDAN-HARRIS, SERGEANT MUSE, USER OF FAX NO. 215-686-3555, JOHN D. GREEN, filed by ROXANNE GRINAGE. (EXHIBITS FILED
IN HARD COPY).(ah) (Entered: 10/16/2009)
10/16/2009
Summons Issued as to FERN BROWN CAPLAN, ESQUIRE, TIMOTHY E. POSSENTI, LISETTE
SHIRDAN-HARRIS, SERGEANT MUSE, USER OF FAX NO. 215-686-3555, JOHN D. GREEN. 6 Forwarded To: U.S. Marshal Service on 10/16/09.
(ah) (Entered: 10/16/2009)
EMERGENCY SECOND AMENDED COMPLAINT against FERN BROWN CAPLAN, ESQUIRE, TIMOTHY
E. POSSENTI, LISETTE SHIRDAN-HARRIS, SERGEANT MUSE, USER OF FAX NO. 215-686-3555, JOHN D. GREEN, filed by ROXANNE GRINAGE.(Striken
from Record for Failure to Comply)(sg, ) (Entered: 10/28/2009)
ORDER THAT PLAINTIFFS EMERGENCY REQUEST FOR RESTRAINING ORDER IS DENIED WITHOUT
PREJUDICE. PLAINTIFF MAY RESUBMIT HER REQUEST IN COMPLIANCE WITH FED.R.CIV.P.65.. SIGNED BY HONORABLE MITCHELL S. GOLDBERG
ON 10/26/2009. 10/28/2009 ENTERED AND COPIES MAILED TO PRO SE.(sg, ) (Entered: 10/28/2009)
ORDER THAT THE CLERK OF COURT IS DIRECTED TO STRIKE PLAINTIFFS, "EMERGENCY
SECOND AMENDED COMPLAINT," FROM THE RECORD FOR FAILURE TO COMPLY WITH F.R.C.P. 15(a). SIGNED BY HONORABLE MITCHELL S.
GOLDBERG ON 10/29/2009. 10/30/2009 ENTERED AND COPIES MAILED to Pro Se.(sg, ) (Entered: 10/30/2009)
MOTION to Dismiss Plaintiff's Amended Complaint filed by LISETTE SHIRDAN-HARRIS.Certificate
of Service and Memorandum of Law. (Attachments: # 1 Text of Proposed Order, # 2 Exhibit A)(DALEY, MICHAEL) (Entered: 11/02/2009)
11/05/2009
LETTER TO R. GRINAGE RETURNED TO SENDER,
INSUFFICIENT ADDRESS. UNABLE TO FORWARD. (sg, ) (Entered: 11/05/2009)
RESPONSE to Motion re 10 MOTION to Dismiss Plaintiff's Amended Complaint filed by
ROXANNE GRINAGE. CERTIFICATE OF SERVICE. (sg, ) (Entered: 11/10/2009)
ORDER THAT PLAINTIFFS MOTION FOR DEFAULT JUDGMENT IS DENIED. PLAINTIFFS MOTION
FOR DEFAULT JUDGMENT IS PREMATURE AS PLAINTIFF HAS YET TO SERVE FIVE (5) OF THE SIX (6) DEFENDANTS IN THE ABOVE-CAPTIONED
ACTION AND A MOTION TO DIMISS BY THE SIXTH DEFENDANT IS CURRENTLY PENDING BEFORE THE COURT. SIGNED BY HONORABLE MITCHELL S.
GOLDBERG ON 2/4/2010.2/5/2010 ENTERED AND COPIES MAILED TO PRO SE AND E-MAILED.(sg, ) (Entered: 02/05/2010)
MOTION AFFIDAVIT OF ROXANNE GRINAGE THIS COURT SHOULD RECUSE ITSELF PURSUANT
TO 28 U.S.C. 144 BECAUSE ITEMIZED USDC PAED DOCKET MANIPULATION CONFIRMS PREJUDICE IN FAVOR OF OFFICIAL CORRUPTION FRAUD CIVIL
RIGHTS DEFENDANT TIMOTHY E. POSSENTI, ESQUIRE PC AND FERN BROWN CAPLAN, ESQUIRE; AND USDOJ ATTORNEY GENERAL SHOULD APPOINT
A SPECIAL PROSECUTOR FROM ANOTHER UNITED STATE DISTRICT; AND FOR OVERDUE JUDGMENT OF PLAINTIFFS FORCED COMMERCE COSTS SINCE
07/20/2009; AND FOR LEAVE TO PROCEED TO JURY TRIAL DISCERNMENT OF PLAINTIFF SIX TIMES NUNC PRO TUNC.CERTIFICATE OF SERVICE,
EXHIBITS.(sg, ) (Entered: 02/16/2010)
ORDER THAT PLAINTIFF SHALL FORWARD HER CORRECT MAILING ADDRESS TO THE U.S.
MARSHAL'S OFFICE FOR THE EASTERN DISTRICT OF PENNSYLVANIA WITHIN IN SEVEN (7) DAYS OF THE DATE OF THIS ORDER OR THE ABOVE-CAPTIONED
ACTION WILL BE DISMISSED FOR LACK OF PROSECUTION. SIGNED BY HONORABLE MITCHELL S. GOLDBERG ON 2/18/2010. 2/19/2010 ENTERED
AND COPIES MAILED TO PRO SE AND E-MAILED.(sg, ) (Entered: 02/19/2010)
PLAINTIFF'S COMPLIANCE WITH ORDER OF FEBUARY 18, 2010 AND RESPECTFUL REITERATION
THAT IT IS THIS COURT'S FLAGRANT AND UNCORRECTED CLERICAL ERRORS WHICH PREVENTED SERVICE OF SUMMONS UPON DEFENDANTS AND NO
"LACK OF PROSECUTION." (sg, ) (Entered: 02/22/2010)
ORDER THAT PLAINTIFF'S MOTION IS DENIED AS FRIVOLOUS BECAUSE IT LACKS BOTH
FACTUAL AND LEGAL MERIT. SIGNED BY HONORABLE MITCHELL S. GOLDBERG ON 3/16/2010.3/16/2010 ENTERED AND COPIES MAILED TO PRO
SE AND E-MAILED.(sg, ) (Entered: 03/16/2010)
MEMORANDUM AND/OR OPINION THAT FOR THE FOREGOING REASONS, THIS COURT LAST
JURISDICTION OVER PLAINTIFF'S CLAIMS AND JUDGE SHIRDAN-HARRIS HAS JUDICIAL IMMUNITY. ACCORDINGLY, THIS COURT NEED NOT OTHERWISE
ADDRESS THE MERITS OF PLAINTIFF'S CLAIMS. AN ORDER FOLLOWS. SIGNED BY HONORABLE MITCHELL S. GOLDBERG ON 3/17/2010. 3/18/2010
ENTERED AND COPIES MAILED TO PRO SE AND E-MAILED.(sg, ) (Entered: 03/18/2010)
ORDER THAT DEFENDANT JUDGE SHIRDAN-HARRIS'S MOTION TO DISMISS IS GRANTED
AND PLAINTIFF'S ACTION AGAINST DEFENDANT JUDGE SHIRDAN-HARRIS IS DISMISSED. SIGNED BY HONORABLE MITCHELL S. GOLDBERG ON 3/17/2010.
3/18/2010 ENTERED AND COPIES MAILED TO PRO SE AND E-MAILED.(sg, ) (Entered: 03/18/2010)
Summons Returned Unexecuted by ROXANNE GRINAGE as to FERN BROWN CAPLAN, ESQUIRE,
SERGEANT MUSE, USER OF FAX NO. 215-686-3555. The City will not accept service due to defective caption. Return Unexecuted.
(sg, ) (Entered: 04/02/2010)
SUMMONS Returned Executed by ROXANNE GRINAGE re: US MARSHAL served Summons
and Complaint upon TIMOTHY E. POSSENTI, LISETTE SHIRDAN-HARRIS by PERSONAL SERVICE. TIMOTHY E. POSSENTI served on 3/30/2010,
answer due 4/20/2010; LISETTE SHIRDAN-HARRIS served on 3/29/2010, answer due 4/19/2010. (sg, ) (Entered: 04/02/2010)
MOTION OF TIMOTHY E. POSSENTI TO DISMISS PLAINTIFF'S AMENDED COMPLAINT. MEMORANDUM
OF LAW, EXHIBITS, CERTIFICATE OF SERVICE, PROPOSED ORDER.(sg, ) (Entered: 04/20/2010)
WAIVER OF SERVICE Returned Executed by ROXANNE GRINAGE. FERN BROWN CAPLAN,
ESQUIRE waiver sent on 4/23/2010, answer due 6/22/2010. (sg, ) (Entered: 04/28/2010)
ORDER THAT DEFENDANT TIMOTHY E. POSSENTI'S MOTION TO DISMISS PLAINTIFF'S
AMENDED COMPLAINT IS GRANTED AND PLAINTIFF'S ACTION AGAINST DEFENDANT TIMOTHY E. POSSENTI IS DIMISSED. SIGNED BY HONORABLE
MITCHELL S. GOLDBERG ON 5/11/2010. 5/11/2010 ENTERED AND COPIES MAILED TO PRO SE AND E-MAILED.(sg, )MAILED TO UNREPS. Modified
on 5/12/2010 (sg, ). (Entered: 05/11/2010)
Date Filed: 09/10/2009 Jury Demand: None Nature
of Suit: 440 Civil Rights: Other Jurisdiction: Federal Question
Plaintiff
ROXANNE GRINAGE
represented by
ROXANNE GRINAGE [Correct Address]HIRELYRICS ADMINISTRATIVE SERVICESPO
BOX 22225PHILADELPHIA,
PA 19136 Email: DIGNITYFORTHEHUMANSPIRIT@HIRELYRICS.ORG PRO SE
V.
MAILING ADDRESS STILL NOT CORRECTED ON 06-08-2010
Defendant
OLD ADDRESS8239 FRANKFORD AVENUE, APT. 110 PHILADELPHIA, PA 19136
FERN BROWN
CAPLAN, ESQUIRE
Defendant
TIMOTHY E. POSSENTI ESQUIRE, PC
represented by
TIMOTHY E. POSSENTI 30 WEST STATE STREET
MEDIA, PA 19063 610-627-5560 Email: tepesquire@aol.com ATTORNEY TO BE NOTICED
Defendant
LISETTE SHIRDAN-HARRIS ESQUIRE
represented by
MICHAEL DALEY SUPREME COURT OF PA ADMINISTRATIVE OFFICE OF PA COURTS 1515 MARKET ST., STE 1414 PHILADELPHIA, PA 19102 215-560-6300 Email:
legaldepartment@pacourts.us LEAD ATTORNEY ATTORNEY TO BE NOTICED
Defendant
SERGEANT MUSE AND/OR USER OF MOBILE TELEPHONE 215-906-3955
Defendant
USER OF FAX NO. 215-686-3555
Defendant
JOHN D. GREEN SHERIFF, SHERIFF'S DEPT-DOMESTIC RELATIONS
ORDER THAT PLAINTIFF IS GRANTED LEAVE TO PROCEED IN FORMA PAUPERIS. THE COMPLAINT
IS TO BE FILED AND SUMMONS ARE TO BE ISSUED. THE UNITED STATES MARSHAL FOR THE EASTERN DISTRICT OF PENNSYLVANIA SHALL SERVE
THE SUMMONS AND COMPLAINT UPON THE DEFENDANTS AT NO COST TO THE PLAINTIFF. SIGNED BY HONORABLE MITCHELL S. GOLDBERG ON 9/15/09.
9/16/09 ENTERED AND COPIES MAILED TO PRO SE.(ah) (Entered: 09/16/2009)
COMPLAINT against FERN BROWN CAPLAN, ESQUIRE, TIMOTHY E. POSSENTI, LISETTE
SHIRDAN-HARRIS, SERGEANT MUSE, USER OF FAX NO. 215-686-3555, JOHN D. GREEN (IFP GRANTED), filed by ROXANNE GRINAGE. (EXHIBITS
FILED IN HARD COPY).(ah) (Entered: 09/16/2009)
09/15/2009
Summons Issued as to FERN BROWN CAPLAN, ESQUIRE, TIMOTHY E. POSSENTI, LISETTE
SHIRDAN-HARRIS, SERGEANT MUSE, USER OF FAX NO. 215-686-3555, JOHN D. GREEN. 6 Forwarded To: U.S. Marshal Service on 9/16/09.
(ah) (Entered: 09/16/2009)
ORDER THAT PLAINTIFF'S "EMERGENCY REQUEST FOR RESTRAINING ORDER"
AND "EMERGENCY REQUEST FOR INJUNCTIVE RELIEF" ARE DENIED WITHOUT PREJUDICE. PLAINTIFF MAY RESUBMIT HER REQUESTS
IN COMPLIANCE WITH FED. R. CIV. P. 65. SIGNED BY HONORABLE MITCHELL S. GOLDBERG ON 9/14/09. 9/15/09 ENTERED AND COPIES MAILED
TO PRO SE.(ah) (Entered: 09/16/2009)
AMENDED COMPLAINT against FERN BROWN CAPLAN, ESQUIRE, TIMOTHY E. POSSENTI,
LISETTE SHIRDAN-HARRIS, SERGEANT MUSE, USER OF FAX NO. 215-686-3555, JOHN D. GREEN, filed by ROXANNE GRINAGE. (EXHIBITS FILED
IN HARD COPY).(ah) (Entered: 10/16/2009)
10/16/2009
Summons Issued as to FERN BROWN CAPLAN, ESQUIRE, TIMOTHY E. POSSENTI, LISETTE
SHIRDAN-HARRIS, SERGEANT MUSE, USER OF FAX NO. 215-686-3555, JOHN D. GREEN. 6 Forwarded To: U.S. Marshal Service on 10/16/09.
(ah) (Entered: 10/16/2009)
EMERGENCY SECOND AMENDED COMPLAINT against FERN BROWN CAPLAN, ESQUIRE, TIMOTHY
E. POSSENTI, LISETTE SHIRDAN-HARRIS, SERGEANT MUSE, USER OF FAX NO. 215-686-3555, JOHN D. GREEN, filed by ROXANNE GRINAGE.(Striken
from Record for Failure to Comply)(sg, ) (Entered: 10/28/2009)
ORDER THAT PLAINTIFFS EMERGENCY REQUEST FOR RESTRAINING ORDER IS DENIED WITHOUT
PREJUDICE. PLAINTIFF MAY RESUBMIT HER REQUEST IN COMPLIANCE WITH FED.R.CIV.P.65.. SIGNED BY HONORABLE MITCHELL S. GOLDBERG
ON 10/26/2009. 10/28/2009 ENTERED AND COPIES MAILED TO PRO SE.(sg, ) (Entered: 10/28/2009)
ORDER THAT THE CLERK OF COURT IS DIRECTED TO STRIKE PLAINTIFFS, "EMERGENCY
SECOND AMENDED COMPLAINT," FROM THE RECORD FOR FAILURE TO COMPLY WITH F.R.C.P. 15(a). SIGNED BY HONORABLE MITCHELL S.
GOLDBERG ON 10/29/2009. 10/30/2009 ENTERED AND COPIES MAILED to Pro Se.(sg, ) (Entered: 10/30/2009)
MOTION to Dismiss Plaintiff's Amended Complaint filed by LISETTE SHIRDAN-HARRIS.Certificate
of Service and Memorandum of Law. (Attachments: # 1 Text of Proposed Order, # 2 Exhibit A)(DALEY, MICHAEL) (Entered: 11/02/2009)
11/05/2009
LETTER TO R. GRINAGE RETURNED TO SENDER,
INSUFFICIENT ADDRESS. UNABLE TO FORWARD. (sg, ) (Entered: 11/05/2009)
RESPONSE to Motion re 10 MOTION to Dismiss Plaintiff's Amended Complaint filed by
ROXANNE GRINAGE. CERTIFICATE OF SERVICE. (sg, ) (Entered: 11/10/2009)
ORDER THAT PLAINTIFFS MOTION FOR DEFAULT JUDGMENT IS DENIED. PLAINTIFFS MOTION
FOR DEFAULT JUDGMENT IS PREMATURE AS PLAINTIFF HAS YET TO SERVE FIVE (5) OF THE SIX (6) DEFENDANTS IN THE ABOVE-CAPTIONED
ACTION AND A MOTION TO DIMISS BY THE SIXTH DEFENDANT IS CURRENTLY PENDING BEFORE THE COURT. SIGNED BY HONORABLE MITCHELL S.
GOLDBERG ON 2/4/2010.2/5/2010 ENTERED AND COPIES MAILED TO PRO SE AND E-MAILED.(sg, ) (Entered: 02/05/2010)
MOTION AFFIDAVIT OF ROXANNE GRINAGE THIS COURT SHOULD RECUSE ITSELF PURSUANT
TO 28 U.S.C. 144 BECAUSE ITEMIZED USDC PAED DOCKET MANIPULATION CONFIRMS PREJUDICE IN FAVOR OF OFFICIAL CORRUPTION FRAUD CIVIL
RIGHTS DEFENDANT TIMOTHY E. POSSENTI, ESQUIRE PC AND FERN BROWN CAPLAN, ESQUIRE; AND USDOJ ATTORNEY GENERAL SHOULD APPOINT
A SPECIAL PROSECUTOR FROM ANOTHER UNITED STATE DISTRICT; AND FOR OVERDUE JUDGMENT OF PLAINTIFFS FORCED COMMERCE COSTS SINCE
07/20/2009; AND FOR LEAVE TO PROCEED TO JURY TRIAL DISCERNMENT OF PLAINTIFF SIX TIMES NUNC PRO TUNC.CERTIFICATE OF SERVICE,
EXHIBITS.(sg, ) (Entered: 02/16/2010)
ORDER THAT PLAINTIFF SHALL FORWARD HER CORRECT MAILING ADDRESS TO THE U.S.
MARSHAL'S OFFICE FOR THE EASTERN DISTRICT OF PENNSYLVANIA WITHIN IN SEVEN (7) DAYS OF THE DATE OF THIS ORDER OR THE ABOVE-CAPTIONED
ACTION WILL BE DISMISSED FOR LACK OF PROSECUTION. SIGNED BY HONORABLE MITCHELL S. GOLDBERG ON 2/18/2010. 2/19/2010 ENTERED
AND COPIES MAILED TO PRO SE AND E-MAILED.(sg, ) (Entered: 02/19/2010)
PLAINTIFF'S COMPLIANCE WITH ORDER OF FEBUARY 18, 2010 AND RESPECTFUL REITERATION
THAT IT IS THIS COURT'S FLAGRANT AND UNCORRECTED CLERICAL ERRORS WHICH PREVENTED SERVICE OF SUMMONS UPON DEFENDANTS AND NO
"LACK OF PROSECUTION." (sg, ) (Entered: 02/22/2010)
ORDER THAT PLAINTIFF'S MOTION IS DENIED AS FRIVOLOUS BECAUSE IT LACKS BOTH
FACTUAL AND LEGAL MERIT. SIGNED BY HONORABLE MITCHELL S. GOLDBERG ON 3/16/2010.3/16/2010 ENTERED AND COPIES MAILED TO PRO
SE AND E-MAILED.(sg, ) (Entered: 03/16/2010)
MEMORANDUM AND/OR OPINION THAT FOR THE FOREGOING REASONS, THIS COURT LAST
JURISDICTION OVER PLAINTIFF'S CLAIMS AND JUDGE SHIRDAN-HARRIS HAS JUDICIAL IMMUNITY. ACCORDINGLY, THIS COURT NEED NOT OTHERWISE
ADDRESS THE MERITS OF PLAINTIFF'S CLAIMS. AN ORDER FOLLOWS. SIGNED BY HONORABLE MITCHELL S. GOLDBERG ON 3/17/2010. 3/18/2010
ENTERED AND COPIES MAILED TO PRO SE AND E-MAILED.(sg, ) (Entered: 03/18/2010)
ORDER THAT DEFENDANT JUDGE SHIRDAN-HARRIS'S MOTION TO DISMISS IS GRANTED
AND PLAINTIFF'S ACTION AGAINST DEFENDANT JUDGE SHIRDAN-HARRIS IS DISMISSED. SIGNED BY HONORABLE MITCHELL S. GOLDBERG ON 3/17/2010.
3/18/2010 ENTERED AND COPIES MAILED TO PRO SE AND E-MAILED.(sg, ) (Entered: 03/18/2010)
Summons Returned Unexecuted by ROXANNE GRINAGE as to FERN BROWN CAPLAN, ESQUIRE,
SERGEANT MUSE, USER OF FAX NO. 215-686-3555. The City will not accept service due to defective caption. Return Unexecuted.
(sg, ) (Entered: 04/02/2010)
SUMMONS Returned Executed by ROXANNE GRINAGE re: US MARSHAL served Summons
and Complaint upon TIMOTHY E. POSSENTI, LISETTE SHIRDAN-HARRIS by PERSONAL SERVICE. TIMOTHY E. POSSENTI served on 3/30/2010,
answer due 4/20/2010; LISETTE SHIRDAN-HARRIS served on 3/29/2010, answer due 4/19/2010. (sg, ) (Entered: 04/02/2010)
MOTION OF TIMOTHY E. POSSENTI TO DISMISS PLAINTIFF'S AMENDED COMPLAINT. MEMORANDUM
OF LAW, EXHIBITS, CERTIFICATE OF SERVICE, PROPOSED ORDER.(sg, ) (Entered: 04/20/2010)
WAIVER OF SERVICE Returned Executed by ROXANNE GRINAGE. FERN BROWN CAPLAN,
ESQUIRE waiver sent on 4/23/2010, answer due 6/22/2010. (sg, ) (Entered: 04/28/2010)
ORDER THAT DEFENDANT TIMOTHY E. POSSENTI'S MOTION TO DISMISS PLAINTIFF'S
AMENDED COMPLAINT IS GRANTED AND PLAINTIFF'S ACTION AGAINST DEFENDANT TIMOTHY E. POSSENTI IS DIMISSED. SIGNED BY HONORABLE
MITCHELL S. GOLDBERG ON 5/11/2010. 5/11/2010 ENTERED AND COPIES MAILED TO PRO SE AND E-MAILED.(sg, )MAILED TO UNREPS. Modified
on 5/12/2010 (sg, ). (Entered: 05/11/2010)
Clerk's Notice to USCA re 26 Notice of Appeal : (sg, ) (Entered: 06/08/2010)
SPECIAL
United States District Court Eastern District
of Pennsylvania (Philadelphia) CIVIL DOCKET FOR CASE #: 2:09-cv-05727-TJS
CLAYTON v. CHIDRENS CHOICE et al Assigned
to: HONORABLE TIMOTHY J. SAVAGE Cause: 42:1983 Civil Rights Act
Date Filed: 12/01/2009 Jury Demand: Plaintiff Nature of Suit: 440 Civil Rights: Other Jurisdiction: Federal Question
Plaintiff
KIRT W. CLAYTON
represented by
KIRT W. CLAYTON 2731 W. PORTER STREET PHILADELPHIA, PA 19145 PRO SE
Plaintiff
BARBARA E. CLAYTON
represented by
BARBARA E. CLAYTON 2731 W. PORTER STREET PHILADELPHIA, PA 19145 PRO SE
Plaintiff
MARC ANTHONY CLAYTON
represented by
MARC ANTHONY CLAYTON 2731 W. PORTER STREET PHILADELPHIA, PA 19145 PRO SE
V.
Defendant
CHIDRENS CHOICE
represented by
JOSEPH L. TURCHI SALMON
RICCHEZZA SINGER & TURCHI LLP 1700 MARKET STREET SUITE 3110 PHILADELPHIA, PA 19107 Email: jturchi@srstlaw.com
LEAD ATTORNEY ATTORNEY TO BE NOTICED
Defendant
DR. BILL EBERWEIN
represented by
JOSEPH L. TURCHI (See
above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Defendant
HONORABLE KEVIN DOUGHERTY
represented by
MICHAEL DALEY SUPREME
COURT OF PA ADMINISTRATIVE OFFICE OF PA COURTS 1515 MARKET ST., STE 1414 PHILADELPHIA, PA 19102 215-560-6300
Email: legaldepartment@pacourts.us LEAD ATTORNEY ATTORNEY TO BE NOTICED
Defendant
HONORABLE PAULA PATRICK
represented by
MICHAEL DALEY (See
above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Defendant
HONORABLE MARGARET MURPHY
represented by
MICHAEL DALEY (See
above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Defendant
ANN MARIE AMBROSE
represented by
GENELLE FRANKLIN CITY
OF PHILADELPHIA LAW DEPT 1515 ARCH ST., 14TH FL PHILADELPHIA, PA 19102 215-683-5448 Email: genelle.franklin@phila.gov
LEAD ATTORNEY ATTORNEY TO BE NOTICED
Defendant
FRANCIS BEATRICE
represented by
GENELLE FRANKLIN (See
above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Defendant
MARIAN YONGU
represented by
GENELLE FRANKLIN (See
above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Defendant
CHARLES FURMAN
represented by
GENELLE FRANKLIN (See
above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Defendant
DELL MERIWETHER
represented by
GENELLE FRANKLIN (See
above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
V.
Respondent
HONORABLE CHARLES CUNNINGHAM FAMILY DIVISION
represented by
MICHAEL DALEY (See above for address)
LEAD ATTORNEY ATTORNEY TO BE NOTICED
ORDER THAT THE MOTION FOR LEAVE TO PROCEED IN FORMA PAUPERIS IS DENIED; ETC..
SIGNED BY HONORABLE TIMOTHY J. SAVAGE ON 12/3/09.12/3/09 ENTERED AND COPIES MAILED TO PRO SE.(jl, ) (Entered: 12/03/2009)
COMPLAINT against CHARLES FURMAN, DELL MERIWETHER, CHIDRENS CHOICE, BILL
EBERWEIN, KEVIN DOUGHERTY, PAULA PATRICK, MARGARET MURPHY, ANN MARIE AMBROSE, FRANCIS BEATRICE, MARIAN YONGU ( Filing fee
$ 350 receipt number PPEO15066.), filed by BARBARA E. CLAYTON, MARC ANTHONY CLAYTON, KIRT W. CLAYTON.(jl, ) (Entered: 12/30/2009)
12/30/2009
Summons Issued as to CHARLES FURMAN,
DELL MERIWETHER, CHIDRENS CHOICE, BILL EBERWEIN, KEVIN DOUGHERTY, PAULA PATRICK, MARGARET MURPHY, ANN MARIE AMBROSE, FRANCIS
BEATRICE, MARIAN YONGU. Forwarded To: KIRT CLAYTON on 12/30/09 (jl, ) (Entered: 12/30/2009)
NOTICE of Appearance by MICHAEL DALEY on behalf of KEVIN DOUGHERTY, MARGARET
MURPHY, PAULA PATRICK with Certificate of Service(DALEY, MICHAEL) (Entered: 04/26/2010)
MOTION to Dismiss Plaintiff's Complaint filed by KEVIN DOUGHERTY, MARGARET
MURPHY, PAULA PATRICK.Memorandum of Law and Certificate of Service. (Attachments: # 1 Text of Proposed Order)(DALEY, MICHAEL) (Entered: 04/29/2010)
WAIVER OF SERVICE Returned Executed by MARC ANTHONY CLAYTON, BARBARA E. CLAYTON,
KIRT W. CLAYTON. ANN MARIE AMBROSE waiver sent on 4/26/2010, answer due 6/25/2010; FRANCIS BEATRICE waiver sent on 4/26/2010,
answer due 6/25/2010; CHARLES FURMAN waiver sent on 4/26/2010, answer due 6/25/2010; DELL MERIWETHER waiver sent on 4/26/2010,
answer due 6/25/2010; MARIAN YONGU waiver sent on 4/26/2010, answer due 6/25/2010. (jl, ) (Entered: 04/30/2010)
MOTION to Dismiss Pursuant to Fed.R.Civ. P.12(b) filed by CHIDRENS CHOICE,
BILL EBERWEIN.Memorandum, Certificate of Service. (Attachments: # 1 Exhibit A)(TURCHI, JOSEPH) (Entered: 05/06/2010)
MOTION to Dismiss Plaintiff's Complaint filed by CHARLES CUNNINGHAM.Certificate
of Service and Memorandum of Law. (Attachments: # 1 Text of Proposed Order)(DALEY, MICHAEL) (Entered: 05/07/2010)
MOTION to Dismiss filed by ANN MARIE AMBROSE, FRANCIS BEATRICE, CHARLES FURMAN,
DELL MERIWETHER, MARIAN YONGU.Memoranudm of Law, Certificate of Service.(FRANKLIN, GENELLE) (Entered: 06/25/2010)
ORDER THAT ORAL ARGUMENT ON THE MOTIONS TO DISMISS THE COMPLAINTS WILL BE
HEARD ON 8/10/10 AT 9:30 A.M.; ETC.. SIGNED BY HONORABLE TIMOTHY J. SAVAGE ON 7/22/10. 7/22/10 ENTERED AND COPIES MAILED TO
PRO SE, E-MAILED.(jl, ) (Entered: 07/22/2010)
RESPONSE to Motion re 9 MOTION to Dismiss Pursuant to Fed.R.Civ. P.12(b) filed by
CHIDRENS CHOICE, BILL EBERWEIN. (TURCHI, JOSEPH) (Entered: 08/05/2010)
Memorandum of Law in Response to the Court's Order of July 22, 2010 re 7 MOTION to Dismiss Plaintiff's Complaint, 11 MOTION to Dismiss Plaintiff's Complaint filed by CHARLES
CUNNINGHAM, KEVIN DOUGHERTY, MARGARET MURPHY, PAULA PATRICK. (DALEY, MICHAEL) (Entered: 08/06/2010)
Memorandum Pursuant to the Court's Order of July 22, 2010 re 12 MOTION to Dismiss filed by ANN MARIE AMBROSE, FRANCIS BEATRICE, CHARLES
FURMAN, DELL MERIWETHER, MARIAN YONGU. (FRANKLIN, GENELLE) (Entered: 08/06/2010)
This case
was also dismissed citing jurisdictional reasons and full updated docket report coming soon.
CLOSED, STANDARD
United States District
Court Eastern District of Pennsylvania (Philadelphia) CIVIL DOCKET FOR CASE #: 2:09-cv-05015-MSG
YOUNG v. DUBOW et
al Assigned to: HONORABLE MITCHELL S. GOLDBERG Cause: 42:1983 Civil Rights Act
Date Filed: 11/02/2009 Date Terminated: 08/05/2010 Jury Demand: Plaintiff Nature of Suit: 440 Civil Rights: Other Jurisdiction:
Federal Question
Plaintiff
DEBORAH M. YOUNG NATURAL GUARDIAN OF
CAMERON DETWILER AND BRIANA DETWILER MINORS, IN OUR OWN RIGHT
represented by
DEBORAH M. YOUNG 3303 GUILFORD STREET PHILA.,, PA 19136 PRO SE
V.
Defendant
ALICE BECK DUBOW JUDGE, IN HER INDIVIDUAL CAPACITY FOR CAUSING PROLONGED CHILD ABUSE BY FAILING TO ENFORCE HER VERY OWN "STANDING
ORDER FOR COURTROOM H" RULES
represented by
MICHAEL DALEY SUPREME
COURT OF PA ADMINISTRATIVE OFFICE OF PA COURTS 1515 MARKET ST., STE 1414 PHILADELPHIA, PA 19102 215-560-6300
Email: legaldepartment@pacourts.us LEAD ATTORNEY ATTORNEY TO BE NOTICED
Defendant
ANGELE MARIE PARKER CEO
represented by
CURTIS P.
CHEYNEY , III SWARTZ CAMPBELL & DETWEILER TWO LIBERTY PLACE 28TH FL 50 S. 16TH ST. PHILADELPHIA, PA 19102 215-299-4304 Fax: 215-299-4301 Email: ccheyney@swartzcampbell.com ATTORNEY
TO BE NOTICED
Defendant
CHEREL FERRELL SOCIAL WORKER EMPLOYEE
METHODIST SERVICES FOR FAMILIES AND CHILDREN("METHODIST KINSHIP") IN THEIR INDIVIDUAL, AND FEDERAL GRANT FUNDED
CAPACITIES AS BENEFICIARIES OF KIDNAP FOR PROFIT AND PROLONGED CHILD ABUSE
Defendant
ANNE MARIE AMBROSE COMMISSIONER DHS
represented by
JEFFREY S. SIMONS CITY OF PHILADELPHIA
LAW DEPARTMENT 1515 ARCH STREET PHILADELPHIA, PA 19102 215-683-5443 Email: jeffrey.simons@phila.gov
ATTORNEY TO BE NOTICED
Defendant
KAREN R. REYNOLDS SOCIAL WORKER
represented by
JEFFREY S. SIMONS (See above for address)
ATTORNEY TO BE NOTICED
Defendant
CARLA N. GARDNER COMMISSIONER'S RESPONSE PHILADELPHIA DEPARTMENT OF HUMAN SERVICES ("DHS") IN THEIR INDIVIDUAL CAPACITIES AS
CONSPIRATORS AND COMPLICIT ACCESSORIES TO KIDNAP FOR PROFIT AND PROLONGED CHILD ABUSE
represented by
JEFFREY S.
SIMONS (See above for address) ATTORNEY TO BE NOTICED
Defendant
MARY ANN TAYLOR IN HER INDIVIDUAL CAPACITY AS MENTAL AND PHYSICAL CHILD ABUSER, AND ACCOMPLICE BENEFICIARY OF KIDNAP FOR PROFIT AND
PROLONGED CHILD ABUSE
represented by
THOMAS J. BOGAR STAMPONE LAW 500 COTTMON
AVE STE 200 CHELTENHAM, PA 19012 215-663-0400 Email: tbogar@stamponelaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
ORDER THAT THE MOTION TO PROCEED IN FORMA PAUPERIS IS GRANTED. SIGNED BY
HONORABLE MITCHELL S. GOLDBERG ON 11/6/09.11/10/09 ENTERED AND COPIES MAILED. (MAILED TO PRO SE)(stb, ) Modified on 11/10/2009
(stb, ). (Entered: 11/10/2009)
COMPLAINT against ALICE BECK DUBOW, ANGELE MARIE PARKER, CHEREL FERRELL, ANNE MARIE
AMBROSE, KAREN R. REYNOLDS, CARLA N. GARDNER, MARY ANN TAYLOR, filed by DEBORAH M. YOUNG.(stb, ) (Additional attachment(s)
added on 11/18/2009: # 1 doc) (stb, ). (Entered: 11/18/2009)
11/09/2009
7 original Summons Issued as to ALICE
BECK DUBOW, ANGELE MARIE PARKER, CHEREL FERRELL, ANNE MARIE AMBROSE, KAREN R. REYNOLDS, CARLA N. GARDNER, MARY ANN TAYLOR.
Forwarded To: U.S. MARSHAL SERVICE on 11/18/09 (stb, ) (Entered: 11/18/2009)
MOTION to Dismiss Plaintiff's Complaint filed by ALICE BECK DUBOW.Memorandum
of Law & Certificate of Service. (Attachments: # 1 Text of Proposed Order, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C)(DALEY, MICHAEL) (Entered: 12/17/2009)
AMENDED COMPLAINT against ALICE BECK DUBOW, ANGELE MARIE PARKER, CHEREL FERRELL,
ANNE MARIE AMBROSE, KAREN R. REYNOLDS, CARLA N. GARDNER, MARY ANN TAYLOR; jury demand, Certificate of Service, filed by PRO
SE PLFF DEBORAH M. YOUNG. (kw, ) (Entered: 01/06/2010)
01/04/2010
DEMAND for Trial by Jury by DEBORAH M. YOUNG. (kw, ) (Entered: 01/06/2010)
MOTION to Dismiss Plaintiff's Amended Complaint filed by ALICE BECK DUBOW.Certificate
of Service and Memorandum of Law. (Attachments: # 1 Text of Proposed Order, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C)(DALEY, MICHAEL) (Entered: 01/11/2010)
MOTION FOR THIS COURT TO CORRECT ADMINISTRATIVE ERRORS WHICH FALSLEY REFLECT
PLFFS' 42 PAGES 1/4/10 TIMELY ANSWERS WITH EXHIBITS AS AN "AMENDED COMPLAINT & FOR THIS COURT TO RENDER OVERDUE JUDGMENT
DENYING WITH PREJUDICE AS TO ANY FURTHER FILINGS, ETC., CERTIFICATE OF SERVICE, FILED BY PRO SE PLFF DEBORAH M. YOUNG.(kw,
) (Entered: 01/21/2010)
Joinder of MOTION TO DISMISS PLAINTIFF'S AMENDED COMPLAINT BY DEFENDANT
JUDGE ALICE BECK DUBOW filed by ANNE MARIE AMBROSE, CARLA N. GARDNER, KAREN R. REYNOLDS, Certificate of Service.(SIMONS,
JEFFREY) Modified on 3/29/2010 (nd). (Entered: 03/26/2010)
SUMMONS Returned Executed by U.S. Marshal, re: Served Summons and Complaint
upon DEFT MARY ANN TAYLOR on 3/15/2010, answer due 4/5/2010. (kw, ) (Entered: 04/05/2010)
SUMMONS Returned Executed by U.S. Marshal, re: Served Summons and Complaint
upon DEFT ANGELE MARIE PARKER on 3/9/2010, answer due 3/30/2010. (kw, ) (Entered: 04/05/2010)
SUMMONS Returned Executed by U.S. Marshal, re: Served Summons and Complaint
upon ANNE MARIE AMBROSE, ALICE BECK DUBOW, CARLA N. GARDNER, KAREN R. REYNOLDS on 3/2/2010, answer due 3/23/2010. (kw, ) (Entered:
04/05/2010)
ANSWERS TO JUDGE ALICE BECK DUBOW AND DHS MOTIONS TO DISMISS AND MOTION TO
COMPEL ANSWERS OF MARY ANN TAYLOR AND MOTION FOR LEAVE TO PROCEED TO JURY TRIAL 236 NUMBERED PROOF EXHIBITS INTERVENTION,
ETC., CERTIFICATE OF SERVICE. (EXHIBITS ATTACHED, FILED IN HARDCOPY FORMAT), FILED BY PRO SE PLFF DEBORAH M. YOUNG.(kw, )
(Entered: 04/26/2010)
Joinder of the Motion to Dismiss Plaintiff's Amended Complaint by Defendant
Alice Beck Dubow filed by MARY ANN TAYLOR, Certificate of Service. (BOGAR, THOMAS) Modified on 4/28/2010 (nd). (Entered:
04/27/2010)
Certificate of Service RE: Joinder of the Motion to Dismiss Plaintiff's
Amended Complaint by defendant Dubow, Certificate of Service thereof filed by MARY ANN TAYLOR, Certificate of Service.(BOGAR,
THOMAS) Modified on 4/28/2010 (nd). (Entered: 04/27/2010)
Joinder of motion to dismiss plff's amended complaint by DEFT JUDGE ALICE
BECK DUBOW, Certificate of Service, filed by DEFT MARY ANN TAYLOR. (kw, ) (Entered: 04/30/2010)
First MOTION to Dismiss pursuant to F.R.C.P. 12(b)(6) filed by ANGELE
MARIE PARKER.Memorandum. (Attachments: # 1 Memorandum of Law, # 2 Verification, # 3 Certificate of Service, # 4 Text of Proposed Order)(CHEYNEY, CURTIS) (Entered: 05/07/2010)
ORDER THAT PLFF SHALL HAVE 14 DAYS TO SHOW CAUSE WHY DEFT CHEREL FERRELL
SHOULD NOT BE DISMISSED FOR LACK OF PROSECUTION. SIGNED BY HONORABLE MITCHELL S. GOLDBERG ON 6/1/10. 6/2/10 ENTERED AND COPIES
E-MAILED AND MAILED TO PRO SE PLFF.(kw, ) (Entered: 06/02/2010)
MEMORANDUM AND/OR OPINION. SIGNED BY HONORABLE MITCHELL S. GOLDBERG ON 8/2/10.
8/5/10 ENTERED AND COPIES E-MAILED AND MAILED TO PRO SE PLFF.(kw, ) (Entered: 08/05/2010)
ORDER THAT DEFTS' MOTIONS TO DISMISS ARE GRANTED. ALL OF PLFF'S CLAIMS ARE
DISMISSED. SIGNED BY HONORABLE MITCHELL S. GOLDBERG ON 8/2/10. 8/5/10 ENTERED AND COPIES E-MAILED AND MAILED TO PRO SE PLFF.(kw,
) (kw, ) (Entered: 08/05/2010)
Top
of FormBottom of Form
General Docket Third Circuit Court of Appeals
Court of Appeals
Docket #: 10-3460
Docketed: 08/20/2010
Nature of Suit: 3440 Other Civil Rights
Deborah
Young v. Alice Dubow, et al
Appeal From: U.S. District
Court for the District of Eastern Pennsylvania
DEBORAH M. YOUNG, NATURAL GUARDIAN OF C.D. AND B.D., MINORS, IN OUR OWN RIGHT Plaintiff - Appellant
Deborah
M. Young [NTC Pro Se] 3303 Guilford Street Philadelphia, PA 19136
v.
ALICE B. DUBOW, JUDGE, IN HER
INDIVIDUAL CAPACITY FOR CAUSING PROLONGED CHILD ABUSE BY FAILING TO ENFORCE HER VERY OWN "STANDING ORDER FOR COURTROOM
H" RULES Defendant - Appellee
Michael
Daley, Esq. Direct: 215-560-6300 Email: michael.daley@pacourts.us Fax: 215-560-5486 [COR NTC State
Government] Supreme Court of Pennsylvania Administrative Office of PA Courts 1515 Market Street Suite
1414 Philadelphia, PA 19102-0000
ANGELE MARIE PARKER, CEO Defendant - Appellee
Curtis
P. Cheyney, III, Esq. Direct: 215-299-4304 Email: ccheyney@swartzcampbell.com Fax: 215-299-4301 [COR
NTC Retained] Swartz Campbell 50 South 16th Street Two Liberty Place, 28th Floor Philadelphia, PA
19102-0000
CHEREL FERRELL, SOCIAL WORKER EMPLOYEE METHODIST SERVICES FOR FAMILIES AND
CHILDREN ("METHODIST KINSHIP") IN THEIR INDIVIDUAL, AND FEDERAL GRANT FUNDED CAPACITIES AS BENEFICIARIES OF KIDNAP
FOR PROFIT AND PROLONGED CHILD ABUSE Defendant - Appellee
ANNE MARIE AMBROSE, COMMISSIONER
DHS Defendant - Appellee
Jeffrey
S. Simons, Esq. Direct: 215-683-5434 Email: jeffrey.simons@phila.gov [NTC city/county gov] City of
Philadelphia Law Department 1515 Arch Street One Parkway Philadelphia, PA 19102-0000
KAREN
S. REYNOLDS, SOCIAL WORKER Defendant - Appellee
Jeffrey
S. Simons, Esq. Direct: 215-683-5434 [NTC city/county gov] (see above)
CARLA
N. GARDNER, COMMISSIONER'S RESPONSE PHILADEPHIA DEPARTMENT OF HUMAN SERVICES ("DHS") IN THEIR INDIVIDUAL CAPACITIES
AND COMPLICIT ACCESSORIES TO KIDNAP FOR PROFIT AND PROLONGED CHILD ABUSE Defendant - Appellee
Jeffrey
S. Simons, Esq. Direct: 215-683-5434 [NTC city/county gov] (see above)
MARY
ANN TAYLOR, IN HER INDIVIDUAL CAPACITY AS MENTAL AND PHYSICAL CHILD ABUSER, AND ACCOMPLICE BENEFICIARY OF KIDNAP FOR PROFIT
AND PROLONGED CHILD ABUSE Defendant - Appellee
Thomas
J. Bogar, Esq. Direct: 215-663-0400 Email: tbogar@stamponelaw.com [Retained] Stampone Law Ste
200 500 Cottman Avenue Cheltemhan, PA 19012
Joseph P. Stampone, Esq. Direct: 215-663-0400 Email: jstampone@stamponelaw.com Fax: 215-663-9112 [COR NTC Retained] Stampone Law 500 Cottman Avenue
Cheltemhan, PA 19012
DEBORAH M. YOUNG, NATURAL GUARDIAN OF C.D. AND B.D., MINORS, IN OUR OWN RIGHT,
Appellant
v.
ALICE BECK DUBOW, JUDGE, IN HER INDIVIDUAL CAPACITY FOR CAUSING PROLONGED CHILD ABUSE BY
FAILING TO ENFORCE HER VERY OWN "STANDING ORDER FOR COURTROOM H" RULES; ANGELE MARIE PARKER, CEO; CHEREL FERRELL,
SOCIAL WORKER EMPLOYEE METHODIST SERVICES FOR FAMILIES AND CHILDREN ("METHODIST KINSHIP") IN THEIR INDIVIDUAL, AND
FEDERAL GRANT FUNDED CAPACITIES AS BENEFICIARIES OF KIDNAP FOR PROFIT AND PROLONGED CHILD ABUSE; ANNE MARIE AMBROSE, COMMISSIONER
DHS; KAREN S. REYNOLDS, SOCIAL WORKER; CARLA N. GARDNER, COMMISSIONER'S RESPONSE PHILADEPHIA DEPARTMENT OF HUMAN SERVICES
("DHS") IN THEIR INDIVIDUAL CAPACITIES AND COMPLICIT ACCESSORIES TO KIDNAP FOR PROFIT AND PROLONGED CHILD ABUSE;
MARY ANN TAYLOR, IN HER INDIVIDUAL CAPACITY AS MENTAL AND PHYSICAL CHILD ABUSER, AND ACCOMPLICE BENEFICIARY OF KIDNAP FOR
PROFIT AND PROLONGED CHILD ABUSE
Top of FormBottom of Form08/20/2010
9 pg, 402.97 KB
CIVIL CASE DOCKETED. Notice
filed by Appellant Ms. Deborah M. Young in District Court No. 2-09-cv-05015. (JK)
08/20/2010
RECORD available on District Court
CM/ECF. (JK)
08/20/2010
1 pg, 22.75 KB
ORDER (Clerk) any future
filings should be in compliance with L.A.R. 113.12 and the Judicial Conference Policy on Privacy, filed. (JK)
08/20/2010
2 pg, 11.08 KB
ECF FILER: ENTRY OF APPEARANCE
from Michael Daley, Esquire on behalf of Appellee(s) Honorable Alice Beck Dubow. (MD)
08/24/2010
2 pg, 75.99 KB
ECF FILER: ENTRY OF APPEARANCE
from Curtis P. Cheyney, III, Esquire on behalf of Appellee(s) Angele Marie Parker. (CPC)
08/25/2010
2 pg, 88.87 KB
ECF FILER: ENTRY OF APPEARANCE
from Joseph P. Stampone, Esquire on behalf of Appellee(s) Mary Ann Taylor. (JPS)
08/25/2010
3 pg, 95.29 KB
LEGAL DIVISION LETTER SENT
advising that the case will be submitted to a panel of this Court for possible summary action. (JW)
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General Docket Third Circuit Court of Appeals
Court of Appeals
Docket #: 10-3460
Docketed: 08/20/2010
Nature of Suit: 3440 Other Civil Rights
Deborah
Young v. Alice Dubow, et al
Appeal From: U.S. District
Court for the District of Eastern Pennsylvania
MOTION for Leave to Proceed in forma pauperis filed by LORRAINE GRINAGE..(ks, )
(Additional attachment(s) added on 1/15/2010: # 1 Pg. 5) (ks, ). (Entered: 01/15/2010)
ORDER THAT PLAINTIFFS MOTION FOR LEAVE TO PROCEED IN FORMA PAUPERIS IS GRANTED.
THE COMPLAINT IS TO BE FILED AND SUMMONS ARE TO BE ISSUED. THE UNITED STATES MARSHAL FOR THE EASTERN DISTRICT OF PENNSYLVANIA
SHALL SERVE THE SUMMONS AND COMPLAINT UPON THE DEFENDANTS AT NO COST TO THE PLAINITFF. S
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