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