| CBC/DCF FLORIDA |
| CBC/DCF of Central Florida SUSAN COX STEAL CHILDREN,CHILD ABUSERS,EMOTIONAL ABUSE ON PEOPLE THAT ARE DISABLED Internet |
| 17th of Sep, 2011 by wooterbug |
NOTICE OF CLAIM.
YOU ARE BEING SUED.
Stacia Ann Adams II Irizarry
Raul Irizarry,
INJURED PLAINTIFF(s)
Suing additionally,on behalf of such minor Caeden Kenneth Raul Irizarry
currently under age 18.
V.
Department Of Social Services,CBC.
DEFENDANT(s)
Seminole County Department of Social Services
The date of when injury has arise causing such lawsuit(s)and notice of claim per government worker as
others to be promptly prepare,serve against all liable defendants for cause of child/parent injury as such
injury arising has taken place on or about 1-31-2011.Violation(s)of staid nature is causing such
innocent loving once happy family falsely accuse to take the appropriate action as available to such injure
party by a state worker(s)causing such federal right injury to immediate put on such warranted notice
when such state worker(s)for such agency as others who are committing such violation under federal law.
Such child has been FORCE to separate at no fault of the loving parent now bringing suit as being
told “what to say”how to act,by such falsity involving their loving parents,who are continually fighting in
such court(s)to have their loving child now injured by the defendants,return based on such well –establish
law in Florida.The continue inequities,by such defendant(s)has cause ongoing harm per 1 child
hence such lawsuit now shall be properly filed in due course as such adult claim(s)involving the plaintiff..
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Mr.and Mrs.Raul Irizarry,who elect to at this time exercise their u.s.constitutional right to
file such notice,follow by such warranted lawsuit(s)for such staid injuries to their loving now injured family.
PURSUANT TO SUCH CLAIMS NOW BEING FILED Under U.S.C SEC.42 1983-85-88
applicable for bringing such lawsuit in due course for violations resulting in the pain and
suffering from intentional infliction of emotional distress upon the removal of one’s child(ren)
As such harm to both child and parent,for the removal of child from his loving home not even
warranted by the state to take such drastic,unconstitutional action,has now put child life
repeat harm,serious danger without any end in sight.
Plaintiff shall clearly enumerate below such nature of the claim that has now arise due to such
wrongful removal,continue removal,detention of one’s loving un-abuse child who has not
been abused until AFTER such unwarranted unconstitutional removal by all said defendant(s)
CBC on such date of JANUARY 31, 2011.
The Children are now being told/as parents they are going to be”put up for adoption if case plan is not
in time frame aloud to be completed”
YET NO ABUSE WAS SUBSTANTIATED Hence such adoption would be ILLEGAL.
NO ABUSE SUBSTANTIATED AGAINST PLAINTIFFS YET BEING TREATED LIKE A
CRIMINAL WHOSE BEEN CONVICTED OF SUCH ABUSE AND OR NEGLECT BY CBC.
THIS IS NOT THE CASE.
As by law,such pre-requisite involving one’s child remove by a state agency worker at CBC in
order to simply avoid such placement OUT OF THE HOME;CBC FAIL TO WORK WITH THE
LOVING PARENTS BY OFFERING SUCH REQUIRED,MANDATE SERVICES TO RAUL
AND HIS WIFE,THE INJURED MOTHER MRS.STACIA ANN ADAMS II IRIZARRY BUT RATHER HAS
KEPT CHILD OUT OF THE HOME,EXTENDING EACH DAY THE VIOLATION TAKING PLACE
THE CBC Defendant(s)never offer plaintiff service(s)to keep child INSIDE of the parent home
while such services,IF warranted are taking place.Rather such law(s)state/federal/involving this
once happy family have been fully circumvent to have children remain where they do NOT
belong in such foster care system where the child has been,and are continually being
abused,mistreated for some time,prompting notice of plaintiff intent to sue against defendants
to be filed,serve to each defendant as such child was not being abused by either parent,
shall be proven,in the proper forum after all notice(s)and lawsuit in federal court has been filed.
THE INJURED PLAINTIFFS HAVE BEEN DEPRIVE SUCH RIGHT TO RAISE
THE YOUNG CHILD IN THE COMFORT,PRIVACY OF THEIR LOVING HOME
IN VIOLATION OF THE FOURTEENTH AMENDMENT.DEFENDANT(s)
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mentioned has failed to duly consider the loving father and loving mother as
a good loving parent who love their children and want what is best for them.
The Due Process Clause in our United States Constitution is not in any way
ambiguous,however defendant(s)continue to ignore,not abide by such
law(s)pertaining to the child(ren)involve,and the loving parents now suing.
Such child has been removed,yet has the Legal and the Constitutional RIGHT!
To be home with their loving mother/father BOTH severely injure by such chain of
“continual events” that has allow the state to continue to violate and injured,the child
while in state foster care and injure the parent(s)RAUL AND STACIA for far too long
now prompting plaintiff lawsuit and notices to be filed at once due to non-return of child and
injury to their sweet child while in such care of the state unconstitutionally.
To make matters worse defendant(s)are feigning the law(s)do not require such child to be reunited,
upon no abuse being established,when clearly such law is clear indicative of such fact.
Upon further information and such belief, CBC Defendant(s)has made no effort
of such reasonableness to return child to the parent,under FLORIDA LAWwhen abuse is NOT
found,proven,nor substantiated,as require by law to do so.
Such Dismissal of action brought against the innocent parent has to take place.
Child is to returned to the parents,falsely accused at once.Such reasoning for lawsuit to be properly filed
due to a“State actor”violating a U.S.federal right repeatedly involving the family shall be clearly notated
throughout the plaintiff notice of intent to sue,followed by their lawsuit.
As the law is clear.Child is suppose to be home with their loving,now injured parent,STACIA ANN ADAMS II
IRIZARRY AND RAUL IRIZARRY.
However,due to biascy,discrimination,ongoing illegal practice(s)by the caseworker and or the continued
negligent in the improper handling of this case such Defendant(s)has failed to return the children to
parent causing such injury to take place for some time without any end in sight.
Plaintiff hence is now filing such lawsuit(s)due to staid injury by not returning the child back to HIS
legal primary care,when NO abuse has been found,substantiated against neither parent.
As set forth in such clear statute,law in our state of FLORIDA child has a legal right
to be returned naturally once such investigatory process has been implemented involving;
all of the parties,yet CBC has illegally been keeping child without a end in sight to return
CAEDEN now age 2,to his parents,in VIOLATION of his,and his parents U.S.Constitutional Right.
Hence lawsuit now,shall be filed,as such plaintiff and the children right to do so at once,
to prevent any further violation(s)causing staid injury to the child and loving parents,of such innocence
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as such condition(s)for which has lead to the child being remove was found to be unproven in reference
to serious abuse,sexual abuse allegation(s)physical abuse etc.yet the child has yet to be return in
violation of their right as the parents injured has now elect to bring forth such warranted lawsuit in due
course for the failure to reunite parent and child as a host of other significant injuries to be enumerate
some in such required notice,and lawsuit.
Child has, by no reason of such validity should have to remain out of the parent home and
has been for some time prompting lawsuit to be filed-as the child should have to not remain any longerfrom
his parents,namely CAEDEN age 2,suffering severe trauma while away each day from mom and dad
as unconstitutional.While child is still out of the plaintiff loving care
he has been horribly abused,mistreated,maltreated,injured,repeatedly as well as emotionally abuse
has been force by either caseworker(s)over at CBC/Foster “Care’’Parents to say things that are wrong
about his own parent,and or force to hear things that are clearly about his own parents,is causing the boy
to in furtherance become withdrawn,angry, unlike how he was when living under the care custody,control
of his loving parents fit to raise him,as they have done since birth.
RAUL IRIZARRY the child’s father listed in such notice(s) has been CLEARED of any wrongdoing,
in furtherance was not even arrested when falsely accused,but yet is branded by such state worker(s)for
some time as a”child abuser”as well as his loving wife,mother to the child Stacia Ann Adams II Irizarry
prompting such warranted lawsuit(s)and notice of claim against Defendants to be filed.
As the law(s)protecting our children as our parental rights shall not and are not in any way unclear.
However defendant(s)continue to ignore such right of parent as importantly the child whose now being
traumatize,emotionally verbally psychologically abuse and mistreated for some time,as shall be proven
when such federal lawsuit is filed soon.
FOSTER CARE IS SURELY NOT WHAT IS BEST FOR THE IRIZARRY CHILD.
THIS CHILD WAS NOT ABUSED YET CANNOT RETURN HOME?
A SERIOUS VIOLATION HAS TAKEN PLACE,NOTICE OF ONE’S INTENTION TO FILE LAWSUIT
AGAINST SUCH PUBLIC GOVERNMENT ENTITY
and other liable parties,shall now be filed,followed by the plaintiff Federal Lawsuit in U.S.District Court of
FLORIDA,for each day child is being traumatize,as parent injured while family is torn part at no fault
of the loving parents nor the child,in violation of the family constitutional right under the fourteenth
amendment.
The Plaitiff-Child have been clearly traumatize since such removal not warranted has taken place,and continue
up to this day forcing such suit to soon be filed against all liable defendant(s)named in the aforesaid and throughout
notice.
The allegation(s)made against the plaintiff has not been SUBSTANTIATED,and or found guilty in a court of law.
The child was NEVER ABUSED.Yet,are Still being illegally detain allegedly by the CBC Defendant(s)
for some time now.
Stating such claim(s)for which plaintiff for which relief may be granted,under the United States Fourteenth
Amendment,in violation additionally of the FOURTH and Ninth.Suing under U.S.C.SECTION (42)1988-1983
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claim(s)against defendant for such state actor whose allege to have violated the plaintiff(s) federal right
involving the wrongful and the continue removal of one’s children from the home,causing such staid injury
to the entire family as there has been no reasonable grounds under C.K.R.I
As, the plaintiff YOUNGEST, child CAEDEN away from the loving home of their parents.
Parents concede CAEDEN need help for MEDICAL needs by falsely accusing HIS
parents. and the parent right.Rather defendant(s)let her remain ”AS IS” without no end
insight.
However Caeden.now age 2 deserve the right to be home with his loving parents,who are being injured each day by
such removal for some time now,as the child is being equally injured as well,whose implore CBCto let him go home.
Such violation by defendant(s)continue to undermine the family unit,their right to as by such well-establish
constitution as the right to familial association- being allegedly by being humiliated,by force supervise visitation
with their own child yet;
NO CHILD ABUSE –NO SUBSTANTIATED,NOR PROVEN in a court of law has been noted by the court.
The Plaintiff Un-abused child should be home.
THAT IS THE LAW.CBC DEFENDANTS ARE IGNORING THE LAW,AND ARE CIRCUMVENTING SUCH LAW
TO ALLOW SUCH CASEWORKER TO KEEP THE BOY IN THE CARE OF THE STATE IN VIOLATION OF SUCH
RIGHT,INVOLVING PARENT AND CHILD,THE RIGHT TO SUCH FAMILIAL ASSOCIATION HENCE LAWSUIT
SHALL NOW BE FILED.
Since child is still being ilegally unlawfully detain by defendant(s)
this lawsuit shall be officially filed against all liable defendant(s)causing plaintiff injury under the fourth/fourteenth
amendment,the COLOR OF LAW as additional continuum violation(s)set forth giving such injure plaintiff(s)the right
to move forward and file their lawsuit in UNITED STATES DISTRICT FEDERAL COURT.
The injured plaintiff(s) in violation hence,of the parents 14th amendment right,as right to such privacy in
their loving home under the 9th amendment.Children are traumatize,the youngest son is imploring to be
return home.
CHILD WAS NEVER RETURN WHEN SUCH OSTENSIBLE ABUSE BY PARENT
WAS ALLEGE,AND THEN FOUND TO HAVE NOT TAKEN PLACE.THE CHILD
IS STILL WITHOUT HIS LOVING MOTHER,AND SUFFERING IN STATE
“SUPERVISE”CARE FOR SOME TIME NOW.
THIS IS A VIOLATION OF SUCH 14TH AMENDMENT involving the child being
continually unlawfully detain by CBC Defendant(s)and a staid injury to the loving
parent as the state has fail repeatedly to expedite to have child return even
allegedly after there was no abuse was even substantiated against the plaintiff.
State continue to FAIL to work with parent(s)to have the child return by mandate/state require services.
Such lawsuit now shall thus,be promptly and timely filed against ALL liable defendant(s)named in notice.
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All defendant(s)the parties officially now being named in the Notice shall be properly served within time
allotted by law followed by such lawsuit(s)that shall be accompanied by such facts,relevant to support
the injure party claim(s)under such constitutional right allowing any per state actors who are violating
U.S.Federal Right is allowed to be sued IN FEDERAL COURT,whenever there is a federal civil right
violation has accrued against the plaintiff.
Family is suing under such federal/4th amendment for improper illegal unreasonable seizure
as in addition under the State-Federal COLOR OF LAW.
as in addition suing under such fourteenth (14th)amendment for damages.
All state worker(s)named in such lawsuit now being prepared,as per notice of claim against each
defendant shall be sued in their OFFICIAL and their INDVIDUAL capacity under law.
The injured family,namely the children loving innocent parent(s)elect to exercise naturally so their
U.S.CONSTITUTIONAL RIGHT,Now that such serious injury to child,and violation has continue to
worsen,each day the child once loved,taken care of,is being abuse,being learned by the devastating
parent(s)the plaintiff now bringing suit,as the injure parents now suing for money damages associated
with such staid injury.All shall not be naturally illuminated in such notice but a clear outline shall be
exerted below as above,causing such reason of such validity to have this lawsuit filed in due course.
Summarily,
On or about January 31 2011 the parents of herein; C.K.R.I.
have been violated.
The Children have not been returned,yet parent(s)in lawsuit notice are cleared of wrongdoing to such
child,yet the child is still being made a “Ward of the state”by FLORIDA CBC.
The parents of CAEDEN. are devastated over the loss of child forcibly remove from the home,
has not been at all return as require by such well-establish law. The parents of C.K.R.I. . have been
completely bereft of their loving child as the child were placed in the ostensible”care”custody and
the control, of the Seminole County
FLORIDA CBC.OF SOCIAL SERVICES herein CBC
THESE DEFENDANTS ARE NOW BEING SUED IN DUE COURSE BY SUCH INJURED PLAINTIFF.
FALSE ALLEGATION IS THE ONLY REASON AS TO WHY UNCONSTITUTIONALLY
THE CHILDREN HAS BEEN USED,ABUSED,DEPRIVE FOR A LONG PERIOD OF TIME.
WITHOUT END IN SIGHT.
Such liable defendants,allegedly in one way or another has been abused since being remove from
their loving parents,based on the premise the parent was harming the child,however not a shred
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of evidence was found to support such abuse taking place to the child yet the child is still to
remain out of the home in clear violation of the plaintiff(s)united states constitutional right.
A FALSE ALLEGATION IS THE REASON WHY THE CHILD WAS TAKEN.
Stripped of his loving parents warmth,care,daily attentiveness from each loving parent security
their routine daily education empowerment from their Un-Abusive Loving home
under the parent supervision primary care,a violation under the 14th amendment.
Clearly being deprived for some time now,prompting such lawsuit notice to be filed served
against all defendants.
ROBBED OF PRECIOUS TIME DAILY WITH MOTHER AND HIS LOVING FATHER,
REMOVE FROM THE ONLY HOME HE KNOWS AND NOW IS HIMSELF BEING
ABUSED,WHILE UNDER STATE CARE,AS SHALL BE PROVEN IN DUE COURSE.
Child was Remove based on a non-secure removal where NO IMMINENT DANGER
had exist then were not return in violation of fourth and or fourteenth amendment as such
deprivation of one’s rights regarding their children still unwarranted.
Needlessly the state of FLORIDA worker(s)at CBC are as of today by time such notice of
claim of plaintiff intention to sue is being filed/served the state is allowing such inaction/action by
the state worker(s)to continue to take place.
Are continuing up through the time such lawsuit is now being prepared,as notices against such
liable defts.
The Defendant COX has violated the childs and the parents again recently by stating
allegedly to the family:
“THE CHILD SHALL NOT BE GOING HOME.
“THE CHILD SHALL NOT BE RETURNED BACK TO YOUR CARE”
“NO RECOMMENDATION”FOR CHILD TO BE RETURN TO THE PARENTS”
Most recent excuse is”PARENTS ARE NON COMPLIANT WITH CASE PLAN?”
PER COURT HEARING 9-6-2011
This is the outlandish and unjust reason as to why the little boy cannot return to his room that
is awaiting him and the home for which he has shared with his parents his entire life since birth.
This is the explanation by CBC caseworker COX who recently adage such statement(s)to
the already deprive parents of the younger child CAEDEN,age 2 years of age,who flagrantly has
no reason to be outside of the loving parents home where abuse was NOT substantiated,
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nor proven in a court of law.Such reason exert by COX is NOT a reason to keep a boy who
was NOT abused, by such loving parents,away from their primary care hence such violation is
taking place,and parents intention to sue is now being brought forth against ALL defendant(s).
Completely irrelevant if such law(s)ALLOW the child to go home when abuse is not
proven is not relevant”the child is acting up”in foster system under STATE Control,
care and supervision when the child is NOT suppose to even be there!
The child has such constitutional right by well-establish law in FLORIDA as nationally
to be home.
Yet CBC worker(s)named of plaintiff NOTICE OF CLAIM continue to make their own law,to
ignore state mandated/required law that allow the injure party to have her child home with
the family.THAT IS A VIOLATION,and prompting such lawsuit to be filed in due course.
Such “acting up”allegedly by child clearly is happening due to child NOT being in the loving
companionship and care and primary custody as he was since birth of his parents the now
injured plaintiff.
Child has a right to be HOME when no abuse/no serious injury/no serious risk by the parent is
taking place,as such compliance by the parent(s)has been duly noted but yet the state has
still,in violation detain child whose clearly”Acting out’’by the trauma of him being away from his
parents,by continually being violated unconstitutionally prompting parents injured to bring suit.
Caseworker COX the Defendant(s)violating the child right as per plaintiff adult states how he
is NOT going home because “he is now acting up “ while under”state supervision”in foster care
etc, so child can’t go home etc. but yet the mother and the loving father is readily able to provide
as always a loving secure home for their child.
Defendant(s)convieniently forget to mention how the child has been abused,while remaining in
such supervision,and or continually neglected,being forced to eat and things he did not like. He was'd
dress like he was homeless by the foster parents. He was also with foster parents that has a non medical foster home
the parents saw many bruises on child and smelled un clean while they visited child at a YANA center
in Seminole county Florida THE PARENTS WERE UNABLE TO VIDEO THE CHILD DUE TO
THE CENTERS RULES.
“caretaker a violation of the child as parent right as shall be further exerted in the proper
forum ,as ALL violation(s)proving such injury when lawsuit is officially filed child being placed in a foster home that has not for
children with the medical conditions that Caeden has a violation to him and
his entire family now bringing forward such lawsuit.
Worker(s)clearly have demonstrate,clear bias allegedly involving the parents,that continue to
undermine the child and the loving parents,now bringing such warrante lawsuit in federal court.
Child belong home with their parents.Child is being abused,while out of loving parents home.
YET SUCH DEFENDANT(S)AT CBC ARE NOT RETURNING THE PLAINTIFF CHILDREN.
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A VIOLATION OF THEIR FOURTH/FOURTEENTH AMENDMENT RIGHT ;
and a host of other continuum of violation(s)for which such damage to child parent shall be
sought,for non-reunification,non-return to the home of their loving child.
Such factual discovery during such lawsuit phase of the plaintiff federal suit shall divulge more
injuries,as it is clear the defendant(s)are engaging in biascy,discriminative act(s)against plaintiff
for their own gain.As such case has nothing to do with two parents who are “abusive”as no
abuse of any sort has been established,proven in a court of law,hence child deserve to be home
by LAW.
Plaintiff(s)have been lied upon,slandered,completely defame,as libel involving such injury taking
place involving this once happy loving family as the plaintiff contend the child has been injured
as a result,as the plaintiff of adult age for some time due to the child NOT being returned to his
The state allegedly involving the injure plaintiff STACIA AND RAUL IRIZARRY,have continually
been humiliated,have been violated by being completely bereft of their loving children,whose
latest residence causing them injury is FLORIDA foster care system,where they are being
subjected to such REAL ABUSE.
Child was not being abused in the loving parents home,hence this lawsuit shall now in due
course follow as additionally as enumerated below,the injured plaintiff(s)are filing such lawsuit
involving continual:
Unconstitutional acts bestowed upon Plaintiff(s) without just cause.
Based on such but not limited to :
1. Reckless disregard.
2.CAPTA Law(S) pertaining to proper procedures and protocol.
3. Illegal removal of one's child,whereas,there was NO LEGAL BASIS TO DO SO,unwarranted
4..Intentional Infliction of Emotional Distress,in regards to the non-return of Tristan,to his loving
home.
Continual violations of parental rights and civil rights for parent/child under such guaranteed
fourth and fourteenth amendment.
A LAWSUIT IN DUE COURSE SHALL FOLLOW THIS NOTICE OF TORT CLAIM
The information herein is putting ALL parties on Notice of Intent to Sue and will be properly
delivered to all Defendants.
All parties shall be served accordingly for lawsuit with valid reasoning;
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Below is prompting a warranted suit to be filed agains all liable defendant(s)listed as:
1.)DEPT.OF SOCIAL SERVICES,SEMINOLE COUNTY,FLORIDA.
2. )SUSAN COX, LIABLE DEFENDANT NAMED IN SUCH NOTICE OF PLAINTIFF
INTENTION TO SUE.
HER POSITION:
CASEWORKER CURRENT STATE EMPLOYEE,WHOSE LIABLE FOR SUCH INJURIES
TAKING PLACE INVOLVING ALL PLAINTIFF(S)and their children,BY HER FAILURE TO
RETURN PLAINTIFF CHILD WHEN NO ABUSE AND OR SERIOUS INJURIES
NO NEGLECT,NO IMMINENCY et.
Relating to the child is evident nor has ever taken place as defendant Alicia Jacksonhas
consistently blame parents for child being removed,slander the loving mother,
as the innocent father,has continually FAILED to work with mother to keep child IN the home,
by offering such “Services”therapy etc,to keep the child at their home to avoid continued
removal.CBC has Failed,as Ms.Cox DEFENDANT(S)has fail repeatedly even though
such is protocol,procdure to offer such required service(s)IN THE HOME to
PREVENT CAEDEN,THEIR CHILD REMOVAL.
3. ) GLEN CASTLE CEO OF CBC, LIABLE DEFENDANT NAMED IN SUCH NOTICE OF PLAINTIFF
INTENTION TO SUE.
HIS POSITION:
THE ATTORNEY OF CBC SEMINOLE COUNTY ACTING IN SUCH PROSECUTORIAL ROLE INVOLVING THE
INJURE PLAINTIFF,WHERE NO ABUSE AND OR SERIOUS INJURIES,
NO NEGLECT WAS EVEN FOUNDED AGAINST THE LOVING PARENTS THAT WOULD
RESULT IN THE CONTINUE REMOVAL OF SUCH SWEET CHILD.
4.) This notice will be legally putting all liable parties on required state notice; effective
immediately.
DEFENDANT(s )herein;CBC are now being put on notice within time allotted by such law for
civil right,personal injury caused by Defendants/worker(s) involved within the illegal removal
and ongoing detention of child for during which time plaintiff and child suffered such injuries.
The Defendant(s) and all others named in such pending suit to soon be filed are being sued in
their OFFICIAL CAPACITY for reasoning of such validity being brought forth against such defts.
Defendant(s) in furtherance are to be sued to their INDIVIDUALCapacity-for multitude of
violation(s) per 1 child. This lawsuit will be based upon the ongoing mistreatment of a family by
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unlawful removal and continued separation. By alleging a multitude violations of such staid
nature:
ALL DEFENDANTS CAUSING SUCH STAID INJURY ARE NOW HEREBY AS REQUIRED
Being Notified –in accordance to all applicable law that shall apply to such claim being now
immediately filed, by federal law(s) in accordance to:
U.S.C.sec.42 (1983) claims- for money damage(s) for injuries sustained per the forced and
unwarranted removal of one’s child, inasmuch continual slander,continual and constant
defaming plaintiff(s)name toward their loving child.
Biological parent(s)as said by our U.S.SUPREME Court have a
substantive due process fundamental right under the 14th Amendment to
solely make decisions regarding the care and custody of their children; in
absence of neglect or abuse the state cannot interfere with such decisions.
ALL DEFENDANTS UPON FURTHER INFORMATION ARE BELIEVED TO HAVE VIOLATED
SUCH RIGHTS.
Additionally suing for damage(s) but not limited to:
Failure to Act by defendants herein: CBC IN FLORIDA.
insofar as to keep child in the home and/or moving forward by offering of reasonable services.
Intentional and Negligent Infliction of Emotional Distress; parental alienation; fabrication.
Damages to both parent/child(ren) from suffering insurmountable pain due to abrupt and
forced separation.
Known Domicile of Plaintiff Filing such Notice of Tort Claim against defendants :
Mailing Address for all future Notice(s)for the injured plaintiff(s) is listed as:
4001 Pelee Street
Suite 200
Orlando, FL 32817
Phone: 321-441-2060
Fax: 407-681-0560
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3405 HANNA AVE N
LEHIGH ACRES FL,33971
239-333-8836
239-333-7107
When such Non-Secure order was utilize illegally and or wrongfully to remove the
child(ren)namely STACIA ANN ADAMS II IRIZARRY,unconstitutionally under the fourth
amendment.Mother was not serve ANY warrant of removal to seize her child
under a day “later”after the fact.
The loving father was not serve until SEVERAL days later in violation of such right(s)of the
father,the plaintiff RAUL IRIZARRY.
Such Notice shall NOT have all violation(s)listed , as saving for such federal suit but shall clearly
outline of such reason of validity as to why such warranted lawsuit(s)are now being filed in
violation of the plaintiff right to child-right to privacy,right to such fair DUE PROCESS relating
to the injure parents.
The child upon further information and such belief are now truly being harmed,placed at
repeated significant risk while living away from their parents unconstitutionally when the child
clearly can be home and should be home,NOT illegally detain by such defendant listed in such
notice,now being filed against all who are responsible for the undermine of one’s family under
the fourteenth amendment.State continually has shown bias and clear indifference when it
come to promptly as by LAW to return the children when NO such abuse was found against
the plaintiff.
Defendant(s)listed in notice in one way or another have allegedly harm the child by such
violation(s)of such federal right taking place under our well-establish U.S.Constitution-as the
legal right of the plaintiff has now elect to bring such lawsuit commencing with the require
notice serve upon each defendant-are now being sued within such time allowed by law;
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allowing parent to seek proper redress and to be rectified from violations and injuries.
Suing on behalf of child/children under the age of 18 when the staid violation(s) were taking
place.
Defendants are as follows:
CBC/ DCF SEMINOLE COUNTY (ALL FOSTER PARENTS)
Glen Casel
CEO
Keri Flynn
Community Relations Manager - Orange County
Shannon Harding
Utilization Management Coordinator
Michael Bryant
Chief Operating Officer
Diane Greene
Director of Quality Assurance
Nancy King
Licensing Manager
Joe Durso
Vice President of Community & Government Relations
Susan Lowe
Director of Utilization Management
Beth Batten
Network Director
Ashley Moore
Corporate Office Receptionist
Anna Brown
Foster Parent Trainer
Amanda Ross
Quality Assurance Manager
Sheryl Snell
Service Center Receptionist - Seminole County
Virginia Thompson
Support Unit Supervisor
Susan cox
Case Manager
All defendant(s)listed has NOT worked in the”best interest”of either child.
Law Guardian/GAL/Caseworker(s)/Supervisors all listed has indeed continually HARM such
child,prompting such lawsuit to be filed once prepared against all liable parties causing injury.
PLAINTIFF:
STACIA AND RAUL IRIZARRY,INJURED PARTIES BRINGING SUCH LAWSUIT.
Shall serve all DEFENDANT(s),their notice of tort-as in addition their federal lawsuit.
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AS SUCH REQUIRED NOTICE IS PROPERLY FILED/SERVED AGAINST ALL LIABLE
PARTIES VIOLATING CHILD AND PARENT RIGHT UNDER SUCH 14TH AMENDMENT.
AS ALL OTHER VIOLATIONS CAUSING SUCH INJURY TO PER CHILD,AND LOVING
FATHER,AND MOTHER,FORCIBLY SEPERATED FOR SOME TIME WITH NO END IN
SIGHT.
SUCH PARTIES,LIABLE FOR PARENT AND CHILD INJURY SHALL BE SERVE
AS ACCORDING TO LAW,TO SATISFY SUCH WARRANTED NOTICE REQUIREMENT
And shall proceed with warranted suit against all named defendant(s) as later to be officially
serve per defendant liable allegedly for causing such injury to the family now undermine by the
state action(s)and inaction,and by all other defendants being listed in such lawsuit by plaintiff.
Naturally all violations cannot be illuminated here in such notice, however:
shall be enumerated per notice of being filed and served upon each defendant involved
with such violations under the fourth and fourteenth amendment
of the United States involving Child Protection Services in violations of procedure and protocol.
As her Child being named as plaintiff additionally in suit are as follows but not limited to:
The child under age 18 at the time of such warranted notice being serve to all responsible
defendants ONE minor during the course of said violations,is CAEDEN age 2
Plaintiffs child are significantly damaged while apart from mother,as well as the loving
father and mother falsely accused, causing more psychological damage/risk to child hence plaintiff injury
lawsuit shall now follow shortly upon such proper filing/serving to all defendants requiring notice.
The Plaintiffs Lawsuit shall be filed as pursuant to U.S.C.Sec 42 1983 per each day they were
illegally detained out of the home based on false allegations as reasoning to detain.
Instrusion on a family's constitutional right to privacy while residing in their home.
Discriminative Action toward the Plaintiff in regards to her child as follows;
Falsely accused and without probable cause; intentionally suppression of evidence;
Unwarranted/and or the Illegal removal of child(ren)whereas;no abuse has even taking place.
The removal of said child as being illegal on or about JANUARY 31, 2011.Continue removal is still
taken place throughout 2011,up to this day,based on lies,perjury,subornation of perjury18
fabrication,falsehood,in sworn affidavit(s)by CBC defendant(s)to have the judge keep child out
of his parents loving home,without any regard for such law(s)being ignored-violated
by CBC DEFENDANTS.
As it is clear the child has a RIGHT to return home when NO serious injury, no ABUSE
has been found rather has been listed as being unfounded against plaintiff(s)
The Defendant(s) had a duty to at once return child to the plaintiff(s) in due course.
Mother allege CBC defendants named in notice had violated plaintiff(s) civil rights as per child
involved.
Hence this notice of tort claim shall be filed and served at once against all liable defendant(s)
for such staid damages -psychological emotional and or physical abuse that befell her and her
child(ren) while out of her immediate care.
Foregoing the lack of reasonable effort to investigate in prevention of removal.
Believing acts to be criminal and unconstitutional upon and foregoing in removal of said
child(ren) encompassing the act(s)of allege conspiracy involving CBC defendant(s) to
keep child away from the loving plaintiff home in violation of such federal right.
DEFENDANT (s)are to have allegedly withheld evidence,significant KEY information pertaining
to the father/mother innocence,in order to illegally detain the child for several months.
in “foster care”whereas;now the child is acting out,having serious issues,as additionally in
school not doing well at all due to such unwarranted unconstitutional removal by such agency.
Plaintiff allege the defendant(s)at CPS:
Witholding evidence,fabricated statements allegedly in order to attempt to prove/ substantiate
child abuse on Plaintiff in the calendar year of 2011.
Plaintiff allege:
Illegal/Criminal acts imposed to substantiate and remove child,allegedly by CBC defendant(s)
Fabricating/Falsifying Documents, being circumvent to FIT what the worker(s)at CBC
want the judge to believe without any such authentication,validity to such documentation being
presented,as to be altered to FIT what the worker at CBC want the judge to think,has happen
to the child while in the loving care of the parents.
Suing additionally for:
Defamation of Character
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Manipulation involving the plaintiff child under age of 18 at the time of suit and notice
being filed.
Plaintiff suing for money damages from rendering effects of intentional and negligent infliction of
emotional distress,civil right violation(s) of the 4th and 14th amendment right.
DEFENDANTS ACCUSE THE PARENTS,NAMELY RAUL OF ABUSING OR NEGLECTING CHILD
FOR WHICH WAS NOT EVER PROVEN,AS SUCH HORRID ALLEGATION MADE AGAINST
HIM HAS UNDERMINE HIS LIFE AS HIS WIFE STACIA,THE ENTIRE FAMILY HAS BEEN
UNDERMINE DUE TO CBC DEFENDANT(s)ACTION/INACTION. THE COURT HAS ALWAYS BEEN AWARE
MR. IRIZARRY HAS A BRAIN INJURY.
Suing additionally for:
Professional/Medical Malpractice,Gross Negligence,Negligent, False imprisonment,
Illegal Detention of one’s child,Continual Malicious Prosecution,Perjury.False Swearing.
A continuum of violation(s)that shall be discuss,further in such proper forum,when warranted,as
in the federal lawsuit(s)now being filed.
Plaintiff allege Defendants involvement in ongoing conspiracy and unethical work procedures
outside the scope of her aptitude/training and job duties; has clearly exhibited bias behavior
contributing to the ongoing alleged discrimination against plaintiff which gravely injured both
child and parent.
Plaintiff allege the defendants has allegedly been working with CBC defendant(s)to keep the
injured Plaintiff,estranged from child.
Plaintiff allege:
Reckless Disregard to the facts; Failure to properly analyze and collect key data
that would have resulted in the IMMEDIATE RETURN of the child importantly
the son CAEDEN who has been imploring the state to allow him to return home,
as reporting such abuse to his loving parents ALL IGNORED by CBC DEFENDANT(s)
whose meanwhile as of today allegedly WAS ABUSED in foster care under
“State”supposed supervision and”care”yet is not allow to return home,
in violation of his/and the parent u.s.constitutional right.
Plaintiff has implore governor for such assistance due to this unlawful detainment of the
child.
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Plaintiff allege Negligent Infliction of Emotional Distress from failure to evaluate and provide
proper counsel
Plaintiff allege such unwarranted removal was done out of falsehood by defendant(s)over at
CBC.
Plaintiff allege Plaintiff allege Intentional Infliction of Emotional Distress.
Plaintiff allege Defamation,Libel,gruesome in nature as continually branded dad as sex abuser.
Slander continually against the loving mother and innocent father.
Plaintiff allege Conspiracy and Coercion.
Plaintiff allege Child Abuse – Mental Verbal Emotional Abuse all taken place
only after being removed unconstitutionally from their loving parents residence)
Plaintiff will readily produce documents/ facts along with witnesses to substantiate claims
against Defendant(s)when proper discovery time to do so involving this lawsuit in federal court,
is taking place.
False information about Plaintiff documented as the truth, - by Defendant(s)in order to allegedly
see to it the child remain”out of the home”even when the father falsely accuse has been cleared
as well as the loving mother.
This shall clearly establish "desired goals" being tailored to fit personal agenda's and also the
desired goal to have the judge adjudicating "believe" what was taking place.
All evidence to come forth shall support such injury/fabrication(s)taking place involving
defendant(s)CBC and all other Defendants allegedly taking place and causing injury
to the plaintiff and their children in due course under the 14th amendment.
The Plaintiff suffered insurmountable amounts of trauma and psychological damage throughout
the wrongful state intervention by Child Protective Services into her home.
ALL WAS DONE ALLEGEDLY WITHOUT FLORIDA CBC NON-SECURE
WARRANT OF REMOVAL/EMERGENCY COURT ORDER..
Other multitudes of violations, but not limited to:
(a)False Imprisonment of one’s child where as there was no legal basis to do so by defendant
(b)Continued Detention of one’s child without proper due process given to the plaintiff(s)
by way of engaging in illegal misconduct with ongoing falsehoods, slander, defamation,
libel, coercion, conspiracy and fraudulent/perjured acts.
(c) Unreasonable SEIZURE of one’s unabused child under our 4th amendment.
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(d) Unwarranted removal whereas IMMINENT or extingent circumstances were not involved.
(e)Numerous violation(s)under our constitutional right pertaining to the fourteenth amendment
by clearly failing to reunite parent- by way of such obligatory duty that is OWED to the plaintiff
inasmuch, as immediate- to reunite Plaintiff with her child by offering such services working with
the Plaintiff to alleviate the reason why the child was initially removed in the first place,
Unless “Aggravating”circumstances arise that shall then relieve such state worker(s) from
reuniting parent by following TPR hearing (which did not take place where it would have been
allowed to keep such child from Plaintiff) the parents have NEVER at any time lost such right to
child legally in a court of law yet the child still is not home,as the right to raise their child has not
been TERMINATED by such required TPR hearing,
yet the child is still be told” he can’t come home”because dad and mom has harm child that
mom had did something”wrong”Being told to the injured son,injured by defendant(s)falsehood
for some time continual fallacious statements of slanderous defaming nature to their injured little
boy.
The child is traumatize.Plaintiff(s)child has clearly noted he want to come home while he was visiting
with Mr. and Mrs. Irizarry
Defendant(s)pretend this is not the case and has failed to abide by such law(s)of the court as
CBC own protocol/procedure in violation of one’s right and such violation has cause staid injury
to child as the parents now bringing such lawsuit against all said defendant(s) named in notice.
Plaintiff alleging damages resulting from child being IN A NON MEDICAL FOSTER HOME
causing such damage,emotionally,psychologically in addition forcing child to BE VERY SICK
U.S.CONSTITUTIONAL right being treated nothing short of INHUMANE by CBC Defendants
and by the foster parent(s)named in notice of plaintiff intent to file such lawsuit in due course.
Defendant(s)at CBC are all claiming the non-continuation of the child removal shall be
contrary to the child CAEDEN”Best interest”If they were to “Return him?”
But yet the parents have been clear of any and all wrongdoing.
LAW IS CLEAR.
CHILD IS TO BE RETURNED Under such well-establish statute.
CBC has clearly and are continuing to unconstitutionally circumvent our FLORIDA LAW to suit their
illegally unlawful purpose by keeping child OUT of the home of the innocent parent.
Plaintiff Violation is not in any way ambiguous and shall be proven during such lawsuit phase
after proper notification of plaintiff intent to sue is served shortly.
Reasonable ”effort”has not been made by the state to see to it as by LAW child is to be
immediately RETURNED.
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The Child has been detain now illegally/and or unconstitutionally so needlessly for more than
200 plus days without barely having regular contact with mom dad.entire family for which the
child is acclimated with.
Yet parents have been CLEARED BY STATEMENT OF POLICE OFFICERS IN ALTAMONTE SPRINGS
of injuring the child and has never cause any type of
serious nor injuries to the child but CANNOT bring their own children back home is a violation of
the fourteenth amendment,as each day pass such familial association is being violated,
involving the family,now filing such lawsuit(s)for such damages.pro-se
Civil Right Personal Injury Attorney,if brought on,shall notify all defendant(s)naturally.
Currently being filed pro-se.All defendant(s)shall receive their copy of their notice of tort claim
accordingly as required by law.
IN CONCLUSION:
Plaintiff falsely accused of child abuse.Was Cleared.NO ABUSE FOUNDED/UNPROVEN.
Child still has not been returned according to such clear statute that would have had by now
child return by now as such agency as other parties mention in the lawsuit(s)has continue to
IGNORE such protocol/procedure in reuniting the child with parent,falsely accused.
The child WAS abused in foster care as shall be proven.
Allegedly the listed DEFENDANT(s)are continuing to”add-on”new and bogus false
allegation(s)in order to have the child NOT return and are attempting to,
in such furtherance DEFAME family good name,in violation of such right(s)
as CBC listed defendant(s) are continually to deprive willfully,wanton,maliciously
and mistreat the child as the loving parents by failing to return child as stated by such
well-establish law(s)concerning our Florida/familial association is clearly being violated
here,without an end in sight prompting such notice of plaintiff intent to sue to be filed.
Plaintiff has now elect to file notice of tort claim with intent to sue defendant for such
violation.Plaintiff shall for per injury taking place all bring forth lawsuit after such notice.
Judge listed as defendant by plaintiff for such federal right allowing such judge to be named in
suit for injuries under federal laws,as such defendant-has allowed such separation of child and
innocent parent to continue that is clearly causing such undermine/continual damage to the
child as evident by such significant proof that shall be all presented,by the injured family when
such time during discovery is taking place,involving the plaintiff federal suit.
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Biascy plaintiff shall also allege,suing for damages,involving all parties,against the injured
plaintiff,as a host of other violation(s)making such lawsuit ,in need of being filed in due course.
ALL DEFENDANTS ARE RESPONSIBLE FOR SUCH STAID INJURY TO CHILD AS PER
ADULT PLAINTIFF NOW PREPARING SUCH LAWSUIT TO BE FILED AFTER ALL PROPER
NOTICES ARE SERVED.
All defendant(s)at DHS Falsely accuse loving father Mr.Raul Irizarry who is completely
innocent.The only thing Mr. Irizarry is guilty of is the love for his son Caeden.
The father was falsely accuse of hurting the son,however such was NEVER proven
against him and now has to live with such false stigma of abusing a child for which
he never harm,but has taken care of along with his loving wife,falsely accused Mrs.Stacia Ann
Adams II Irizarry
Such notice of their intent to sue now follows.
Evidence overwhelmingly so as factual shall be in support of such claim(s) inextricably shall
support this plaintiff's position and substantiate the fact,the child was apprehended illegally,
and or without such court order where IMMINENT danger would have allow such removal
WITHOUT the proper execution from a judge,as there was no imminency at all involving son
CAEDEN that would have warranted such drastic action like a removal of a child to take place.
This has completely continually been traumatizing to the son,as injury to him is unambiguous
as any chil who would be kept illegally detain from its loving parent.Such notice of plaintiff intent
to sue is now being served,to ALL defendant(s)liable for such injuries to the child and parent(s).
The Defendant(s) involved continued to Conceal Evidence and Refused to Investigateany
and all false ONGOING accusations,allegedly.In furtherance refuse to believe any TRUTH
of what the plaintiff has said and has refuse to reunite as mandated in such law(s)involving our
state and our CBC agency when it come to reuniting the child IF no SERIOUS risk to childimminent
danger is visible,taking place but yet the child is still in north carolina foster care and
wants to come home as HOME is where the child should be without the Ongoing interference
of child protection services agency,the Defendant(s)now being sued.
The Defendant(s) continued to accuse, defame and humiliate plaintiff,rather than go by such
factual the defendant(s)conspiring to keep triston,youngest child away from his loving
parents,unconstitutionally.
The Defendant(s) were continually uncooperative in working with the Plaintiff as required by
law.
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Perjury has been a big part of what has taken place in violation of their right to have child
home,as such perjury,false “Sworn –in affidavit,statement by caseworker”has been utilize in
order to keep child in the horrid FLORIDA Foster Care System,when child has NOT been abuse by
such loving parent prompting lawsuit to now be filed at once.
The Defendant(s) repeatedly humiliated- DISMISSED Plaintiff's claims when plaintiff state
they are innocent,as additional info that would have assisted them in proving such
innocence,but worker(s)at CBC kept insisting they are the”problem”no one else,
and they are not getting their child back,might be put up for adoption,in violation of the plaintiff
united states constitutional right as NO ABUSE,serious risk neglect nothing has been formally
substantiated against the plaintiff(s)but yet they are”the problem”as clearly is FALSEand
now are at risk of being put up feasibly,as being allege by plaintiff,for”adoption?”Such
violation(s)are causing grave injury to the plaintiffs family suffering from severe agony,daily
pain,suffering from such removal and continue removal of their children,without any end in
sight,prompting such suit to be filed.
The Plaintiff suffered,financial,emotional, extreme psychological effects from humiliation,
grief, anger, defamation; being stripped of identity, dignity and respect; all without investigation;
and from these outrageous acts, bestowed upon Plaintiff and Child constant torture from
incompetent, negligent workers who opted to "look the other way" in violation of the plaintiff
right(s) now bringing such warranted suit in due course.
Plaintiff allege Reckless Disregard,Involving Defendant(s)as showing clear indifference
to the child(ren)and the parents by continually ignoring what is truly BEST for the child,
by returning such child and IGNORING son CAEDEN who wants to be return to loving parents who
has NOT abused him and or put him at any serious risk as such falsehood is being told by the
defendant(s)for some time now.
Reckless Disregard involving the psychological/medical needs of said minor child,
Caeden,their son now having problems with family interaction from being in “foster care”due to such separation from
his loving parents,as the child clearly was doing just fine PRIOR to involvement unwarranted
by Child Protection Agency,caseworker(s)as all defendant(s)became involve with the child
Caeden all plaintiff(s)
Plaintiff now has brought such suit by way of putting ALL State Defendant(s) herein; on
immediate notice, who were and or continually in state family court allege to have taken
part,continue to conspire,taking part in the illegal continued conspiracy, fabrication(s)
and falsity involving this plaintiff which are clearly unconstitutional and illegal and from
that continuing to keep mother,father,child estranged.
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Plaintiff lost the right to continue to raise her child based on fabrication and ongoing lies
as this removal was clearly predicate NOT on imminent danger to child but to biascy and
discriminative illegal action.
Fallacious statements have clearly been supplied to a judge and further disseminated
the Plaintiff good name throughout several unwarranted court hearing(s) in state family court
to make it appear as if the plaintiff is hostile/uncooperative and had abused her child.
The plaintiff continue to suffer by such falsity as her spouse,for some time without no end
in sight,since such child is still out of the plaintiff primary care unconstitutionally.
Child has been injured,by such foster parent(s)now being sued,as such removal has been
psychologically damning to the children involved.CBC DEFENDANT(S)continue to IGNORE
state/federal/ignoring all law in regard to the return of one’s child when there is NO serious
injury,no abuse proven,not substantiated hence such warranted suit is now being filed.
State of FLORIDA has upon further information and such belief violated in “state” family
court,a U.S.Federal Right.As it is IRRELEVANT that”child was acting up”in foster care since
the child is suppose to way before now be returned if child was not found to be SERIOUSLY
injured/and or “abused”and or neglect,was not at all substantiated,and such law(s)are to be
fully adhere to by defendant(s)but since they are not, the child has been sadly abused are being
factually neglected in foster care and thus shall prompt the injured parents,children the family
to now bring such lawsuit against all liable DEFENDANTS.Parents move to exercise such right
by law(s)to bring such lawsuit action against these DEFENDANTS within time allotted by law.
This lawsuit,shall be filed in such jurisdiction in State or our U.S. Federal District Court
whereas; the Plaintiff shall move to seek such damage(s)on behalf of her child(ren)
and each adult plaintiff,at the time the family underwent ongoing trauma in family experiences.
Family has REPEATEDLY complied,even though NO serious injuries even took place to child
yet the boy is STILL in SEMINOLE COUNTY CBC System being brainwashed,injured,suffering immensely.
All for what is being allege shall be proven in due course upon serving of such lawsuit in due
course.Plaintiff shall properly notify all parties if attorney shall be brought in by time of federal
suit file against all defendant(s)currently acting as Pro-Se Litigant(s)bring such federal suit.
Plaintiff filing their lawsuit after each notice of their intent to sue has been properly served to
defendant(s)pursuant to U.S.C.SEC.42(1983)(1988)claims, against all parties named and
or as according to all other state federal statute allowing families to sue for money damages et.
against a public entity for such staid violations under federal law.
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AMOUNT OF DAMAGES SOUGHT FOR INJURIES ASSOCIATED WITH SUCH CLAIM
ENUMERATE IN NOTICE AND U.S.DISTRICT FEDERAL SUIT FILED,PLAINTIFF SEEK:
10 Million Dollars.
$10,000,000.00 in damages,and or what the court shall deem appropriate.
JURY TRIAL SHALL BE DEMANDED FOR SUCH AND ALL TRIABLE ISSUES
RELATING TO THIS WARRANTED FEDERAL SUIT NOW BEING FILED AGAINST
ALL DEFENDANTS,NAMED IN SUCH NOTICE.
JURY TRIAL SHALL BE DEMANDED FOR SUCH AMOUNT OF DAMAGES TO BE
AWARDED TO THE PLAINTIFF PER INJURY TO CHILD EACH DAY CHILD IS TO
REMAIN OUT OF THE CARE WITHOUT A LEGAL BASIS,AS SUCH PARENT INJURY.
HENCE CONSIDER YOURSELF OFFICIALLY SERVED.
HAVE A GOOD DAY NOW.
DATED: _____9-10-11______
Stacia Ann Adams II Irizizarry PLAINTIFF
Raul Irizarry PLAINTIFF |
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