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Law Educator, Esq.
Law Educator, Esq., Attorney
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Experience:  JA Mentor -Attorney Labor/employment, corporate, sports law, admiralty/maritime and civil rights law
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FOR ONLY PAUL. Good evening. Update(s) for ya! Hope your

This answer was rated:

Good evening.
Update(s) for ya!
Hope your well.
The attorney "bob"shockingly reach "tina!"
he was saying to her,how he is"very sorry"it did not work out,for the two of them on this suit,but"if she ever need him to just"talk"about the case or any"info!"to just reach him? wtf!

is he odd or what. He try to expound,"your realizing i never did say in writing at any time i "am your lawyer"and or how"we are working on this Amend-Complaint against cps with each other right?"Tina was not obtuse,she caught on to him,who knows may have record her,scared of LEGAL MAL,but she said, your email(s)are proof enough sir,and paul trust me I read them! all weeend,so he is either senile,and or just fretting over whether or not she really did save them,and luckily for her she did!
Sad,she assume he finally rationalize what he oughta do,but he did not sir.Not at all.


She just said to him,thx for having the nerve to reach me when i m,on my own again,trying to put finishing touches on it.(i think he was trying to see if she was able to file timely)for some strange reason.however,i just verify with her,she say she did not file.(But she is early tue.morning)she was not able to get this all in,even if he did most,it was just really depressing to her,and i told her stay afloat,focus on the great job
he has already done,before backing out of the suit,like a wimp.and she did have a few queries,and i told her as always i will reach out to the legal experts,at just answers.

so i have a query or two paul:

1.She is frighten the most on the part whereas; she"want to encompass"what has taken place,from day on paul.almost 8 long years ago...She feel"the wrongful removal"should be added,from the first Nature of the Action part,then to add about how she was cleared
(not of the 1 light spanking to child)but the most"serious allegations"that kept her away
from the children for years on end.(should she take it back from the beginning)and by doing so,this might if i am right paul(and BOB)mention this to me,prior,that it might look as if she is attempting to under ROOKER FELDMAN(will be toss out feasibly)because your not able to we all know who work in law,or study in this field,your not able to seek damages,such as,in an attempt to "try your old case"in fed.ct. please expound on this in clear writing/answer for her thank you.


what your reading from paul thur.or so was clearly from "new claim(s) from around 07 or so whereas; child first report listed under state care"withheld"newly discover by mom in 2010,along with "prior judge"call this case in2010 and 2011,human nightmare for child and "human tragedy for mom,and child"and "should have not happen"he even mention there is definitely some"negligence here"but again ,this transcript she don't have,but heard it and her former atty.has it.(he said all this during LAST HEARING,when child with mom went to court,when child turn 18.during january 2011.

Judge notice(as)bob outline about,multiple bouts of rape,sex abuse,fondle,physical abuse
running away(to escape foster father abuse)but then end up more harm,and dyfs knew
but lie under oath over 35 hearings,and always say"we visit child"she was fine with dad
so "no need to give mother back child"knowingly all along poor kid was being tortured
and even"at one point"lost in the system,CPS , lost child,but yet feign she is safe at home with"Dad."

so again,i think it will be easily proven from 2007,no?and maybe she can then add in a part/paragraph naturally in the"background"section;Not the nature of action etc. what do you think!

i await your relevant feedback,and she did tell court by phone it will be in later by five
or morning,she is 1 day late but she promise for tue.with process server by 9a.m.

Thank you for your new question and update.

I concur that Bob appears to be trying to cover his tracks now, but it is too late because of the emails. She needs to hang up on him if he calls her again in the future.

1) She needs to stay away from the old issue that was already litigated, you and I have discussed that part. Make her stay on course and argue only this new issue, because if she raises the old issue even a little, the other side is going to use that to argue she is trying to do an end run and re-litigate the old issues.

2) She needs to focus on the new issues and the lies in the reports and concealing the harm that was happening to her child at the hands of the foster parent with the knowledge of the CPS agents who hid what was happening.

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Customer: replied 4 years ago.

paul here just real fast download, media fire, review fast!(this is his good draft)imo as your agreeing he was really doing a great job,


so, here it is again!


remember the 1st amend-complaint judge/only dismiss without prejudice,your even agreeing a month ago,was "very generous"of him,when he had to feasibly

see "something there"'but was not clear enough" ya know.


Laughingtitle="Laughing"/>i recall your agreeing to that!and again she file "THEN"pro-se,so i see why she feel in fear some,but she is DEFINITELY utilizing 99% here,and just review this and then i want you,to be able to really comment,on if she should mention about how this happen in beginning,and that etc. because i know all about;

ROOKER V.FELDMAN,learn this in 1st year of attempting to procure paralegal degree

B.A. many years ago and working at law firms

so ok i await your response,and remember:


1. (the spanking yes was affirm,she admit to light spanking)but was not overturned. (however)this was clearly NOT the reason the child was not return.


2. the"thirty three!(add-ons,and lies,and horrific,"as cited by THREE appeals in 04,(when case began)and throughout 09,order dyfs to fully investigate,all 33 "serious allegations"that WOULD be a reason yes,to bar a mother or father from the kid,but again this was not properly at any time"investigated"until 2010,int january 2011,


and executive order,then finally said,


"We OVERTURN all 33 allegations"as appeal order them to do this though,etc. investigate,or substantiate 04,07,09.understand?

Hence, was telling her how,your able to make sense of all this for her.




i think she should mention the appeal ordered this SINCE yes day one.

was"never done"and had it been investigated,adherence by caseworker

when three appeals said,"do it..."and yet fail to adhere,if cps did the child would have;

1. been reunited with mom,in the home;and or a regular visitation and parenting time weekly schedule"until reasonable effort(As required)by cps was applied,to return child in due time.


2.would have not been naturally put into a "rape"situation;repeat sex abuse and torture in 10 group homes!(and hospitalize paul.)



i await your response.



She is i think scared,because as your seeing atty.was wording it right

but she do not know how,and i am trying to help her with great answers

again as much as feasible,thank you.


oh! and lastly:


as your reviewing the attorney lawsuit,he institute for her,(well started to)




I am fairly certain,"After"i've review her past complaint,by her pro-se and

the DYFS D.A.G.(*deputy atty.gen.)the lawyer opposition mention this paul;

about how


a third district as "other districts"preclude such suit of"this kind"because

your only able to file against a caseworker(s)etc. and or its agency itself

managerial etc;supervisory etc; IF "a wrong has been i.e. conviction was

later overturned,and or the state "Admit its wrongdoing"then your able to proceed,and he cite few case law(s) so if i am correct,a executive order

from the "same office"out of nj,whereas,attorney general cite,all of the


"un-investigated" 04-07 allegations,"After"1 spanking affirmation is now

OVERTURNED;listed as unfounded,against the mother.We now close your case january 2011.


isn't this supportive of her claim from (the beginning)of her case,if she decide to go this route,or at least"it should allow suit"on THIS claim to move forward,(this,meaning the mom claim on the fact,IF when she was cleared paul,officially,2010-2011,then there was"no reason"at all the child should have

NOT been reunited,with mother in home,of the mom understand?


Instead,cps left her homeless,at times(verify by dr. report and was lost int he system,supporting"homelessness"and as a result,(u know the rest)


awaiting your response thank you.

download "bob"draft,again thx.(link is above)




I think the complaint is fine as it is, Bob did a good job with it and it does not really need any more playing with it as a notice pleading is sufficient.

As far as her addressing all of the other issues, not in the complaint, she can address them later in the case, including the 33 counts that were overturned. Putting that information in the complaint just allows them to argue the res judicata issue. If she wants to argue that she never committed anything worth having the child kept from her, that is for a later time as the trial progresses. But for now, just make her focus on the issues regarding the abuse the child suffered at the hands of CPS concealing it and the emotional distress she suffered because she kept trying to get CPS to do something and all CPS did was cover it up.

Customer: replied 4 years ago.

i think i edit/add later check again!

way up top thx i am my self reading it over.

or click below thx!


I found it.
Customer: replied 4 years ago.

ok got it!


and yes,

i know just a "few"clean-up wording is warranted,premise on the last five! (he sent her five last emails)prior to ditching her,wrongfully.and was saying how,"oh "WE" need to both work on a few area(s)meaning the fact that he did "say in a email"(if your agreeing paul)its going in,because he was about to encompass the fact,"whereas;it talk about in i think your seeing count five cause of action etc.and whereas he was going to edit,the part,adaging that

"Not all facts,were naturally known at such time,UNTIL 2010,and jan.2011 and this is when"mom still in court fighting to bring child home,to"avoid"any more rapes,abuse to her child etc,learning state knew all along,and "she did not know this in 08 the first wrongful removal claim,naturally.he was going to add,"33"allegations see exhibit ______

proving state did eventually"clear her"of the allegations,that were the sole reason,(not 1 spanking)but the 33 allegations,were eventually overturned

paul,he was surely going to encompass this would you do that

or no?


I think it is significant,at the least,sir,to demonstrate to the fed,ct.that

"ok" mom is cleared,(of the allegations never investigated as cited in the first few pages,about"how there were always allegations of serious nature never even investigated,yet,"were used"as truth,barring mom from her own child,for years..."when state finally did clear her"the damage was already done,(rapes,sexua abuse in foster care etc.)bob email sounding

as if he was goin to"go there"and encompass the doc at"the least"it should be marked in the general sufficient complaint,paul you think?

because it show,as "bob"say in emails insofar,as


a.)at least it show mom was indeed,cleared for "the allegations"33, in total,that were used as a basis to keep child out of mother home,but

as soon, as she was cleared,"child could have at least during this point been returned."The appeal section excerpt adaging three times,ordering cps to "investigate"premise on if not investigated,it will continue to affect mom"parental constitutional right", this appeal in 04,07 do say this paul


so again,she should not attach this,or she should?just want your feedback


and lastly:


final note:


Judge(the fed.ct.magistrate himself)mention how,he was letting mom

cure its deficiencies,i.e. he cites,in quote"parent is alleging has exhibit"

a proof(s)from the office of atty.general "clearing her name"from the add'l

33 allegations,that at such time,she was"cleared"of such wrongdoing,by

state office,during 2010-but "state"still failed to reunite mom at this time.


State,knew child was being abused,lost in the"system"mom says,but yet

state,even though parent was"available,working"nice house,and cleared

at least by 2010,state office,fail to work with her,to have child home.


so again judge mention this right before he say,"without prejudice"that

let her get to at least,this point sir,so just want your feedback,on this thx.

I personally think,as i can see bob was in emails,"he was at the least"goin to attach just as a simple,yet somewhat strong factual exhibit

whereas;state clear parent,at least in 2010,but yet failed to even allow the child to go home,KNOWING she was suffering immensely,raped in a foster home,and sex abuse in multiple foster /group homes






Yes, of course I would encompass the fact the charges were overturned, that goes to the fact that they had no grounds to continue keeping the child from her. It also shows that she was not a danger to the child as CPS tried to allege.
Law Educator, Esq. and 3 other Legal Specialists are ready to help you
Customer: replied 4 years ago.

your awesome thx again paul.

i am just helping her,she is feeling"Better"reading your answers. i am also goin to share just the "edit 1st part;section with her late night"so just check it out,i think that is fine,just review the 1st part.I just think she want it in as the parent being"cleared"and again i did read the decision,whereas; judge did

comment on this,prior to allowing her to include such"allege proof"of such

in her new complaint,so it can only help,the dyfs will fail in a argument for

res judi,on this since again"there was no way paul a parent would know years ago,if he or she was cleared,of additional allegations etc. if it was not "decided"by attorney gen. until YEARS later.


Thank you for your response.

The issue on res judicata is not what she could have known at the time, it is she filed suit too soon on the issue or she did not gather all of her evidence together at the time (combined with their concealing reports and fabricating evidence), but this needs to be brought out in the discovery phase and into the trial phase of the case not now because it will just give the other party more to argue for dismissal.

She is mentioning how the child was taken away on charges that were later found to be unfounded and vacated, that is enough to allow her to raise this later on in the case process. She and you need to be patient and what happens with many pro se litigants is they include way too much in their complaint or not enough, in this case if she raises up old issues she would be including too much and giving the opposition something to grab onto to try to get a dismissal.
Customer: replied 4 years ago.

your the best thank you paul. i just read this tonight.and sending now again "to tina" she is so much more happier,suing cps self file,without a lawyer and i am going to help her,see,remain empower enough to know she has as your agreeing a claim there,as i know personally,she do as well,so glad your answers,are always thorough,and help me (even if i know as your aware much of it)but what i am not sure i not only double but triple-check with you and just answers legal experts,so thank you again,i ACCEPT.


bye now.





Thank you very much.