A.O., a child of 12 on 16 September, and 10 other children, with 3 ‘new’ children by James Renwick Manship, a legal “next friend”, and other adult citizen next friends Individually and on behalf of all others similarly situated, Next Friend Manship files Pro Se, and as Disabled Veteran, In Forma Pauperis Plaintiffs,v.

ARLINGTON COUNTYSHERRI BROTHERS, in her official capacity as Arlington County Virginia Supervisor, Child Protective Services DivisionMARITA Y. WILSON, in her official capacity as Arlington County Virginia Social Worker, Child Protective Services DivisionTAMMEE GAYMON, in her official capacity as Arlington County Virginia Social Worker, Child Protective Services DivisionVALERIE CUFFEE, in her official capacity as Arlington County Virginia Social Worker, Child Protective Services DivisionSUZANNE EISNER, in her official capacity as Arlington County Virginia Director, Department of Human ServicesJASON McCANDLESS, in his official capacity as Arlington County Virginia Assistant County AttorneyKAREN MARIE GRANE, in her official capacity as Arlington County Virginia JDR Court Appointed Guardian Ad LitemESTHER WIGGINS, in her official capacity as Arlington County Virginia JDR Court JudgeGEORGE VAROUTSOS, in his official capacity as Arlington County Virginia JDR Court Judge Defendants.

1. Just after 6 in the evening yesterday, Pearl Harbor Day, 7 December 2011, a 12 year old girl, “A.O.”

lead child plaintiff, filing by way of her Next Friends James Renwick Manship, and Delores Heffernan,

also her grandmother and guardian by virtue of Montgomery County Maryland Court Order of 2005,

was assaulted by an Arlington County Court employee. Next Friends James Manship, and Salim

Bennett were mere feet away and in perfect position to witness the assault. Inserted below is an email account

by Next Friend Manship, lead Plaintiff, and an outrageous response by Defendant Jason McCandless, an

Assistant Arlington County attorney. Plaintiffs demand or beg for Federal Court Restraining Order !!!

EMERGENCY MOTION DUE TO BLOODY ASSAULT ON A.O. by ARLINGTON COURT EMPLOYEE p. 1

IN THE UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRGINIA Alexandria Division

EMERGENCY MOTION DUE TO BLOODY ASSAULT ON 12 YEAR OLD “A.O.”

BY ARLINGTON EMPLOYEE WITNESSED BY NEXT FRIENDS and PLAINTIFFS

MANSHIP and BENNETT ON 7 DECEMBER 2011

Case No:1: 11CV1003JCC/JFA

EMERGENCY MOTION DUE TO BLOODY ASSAULT ON A.O. by ARLINGTON COURT EMPLOYEE p. 2

Yesterday, 7 December, in Arlington Juvenile and Domestic Relations Court on the fourth floor of the Arlington Courthouse, I was in the hallway outside of the Judicial Chambers and looking at the door of Courtroom 4B where for the entire day a Parental Rights Termination Hearing against Patricia Tacket, mother of Ashlie Mae O'Brien was heard, substitute Judge William Boice of Henrico County presiding.

Before the hearing began about 10 a. m., Mr. Godwin, Guardian Ad Litem for Ashlie's father, Sean Schwartz, who has for years known me, Mr. Manship, said "I told McCandless that this child should be returned to her family." At the time of court recess when the incident below occurred, Mr. Godwin and Mr. McCandless had both gone to the Men's Room.

A bit after 6 p.m. during the recess called by Judge Boice when judge Wiggins in the judicial chambers office asked to speak with substitute Judge Boice.

I, James Renwick Manship, Sr., was standing near the door to the Judicial Chambers next to the opening to the waiting area for court witnesses, speaking with Mr. Salim Bennett and Mr. Darnell (Donnie) Ford, stepfather of Ashlie O'Brien.

Ashlie's 20 year old sister Samantha exited the courtroom, and the two sisters hugged each other for a time. Then Ashlie asked what was going on in the courtroom.

Samantha said to her sister words to the effect of, "Do you realize that you may not be able to see your mother or any of us anymore after this hearing? They are trying to take away Mommy's parental rights."

Ashlie asked, "When will I be able to testify? I have been here all day waiting to testify."

Samantha said, "Your lawyer (Guardian Ad Litem Karen Grane) said she did not want you to testify, and so you won't be able to."

Ashlie was outraged, and went around her sister Samantha to go into the Courtroom 4B that was not in session during the recess, or break, called by Judge Boice to meet with Judge Wiggins who had asked to speak with him.

Samantha said, "Don't go in there, they will not let you testify..."

! Date: !December 8, 2011 10:57:11 AM EST! From: !StatesManship <statesmanship@me.com>! Subject: !Chaplain Manship recollections of attack of 12 year old girl Ashlie by

Arlington deputy! To: !James Renwick Manship Sr. <James@STATESMANSHIP.US>, bhollingsworth

<bhollingsworth@washingtonexaminer.com>, ken@cuccinelli.com, Robert.F.McDonnell@governor.virginia.gov

! Cc: !dheffernan Heffernan <dobrienh@gmail.com>, Pam O'Connor <psoconnor@fcps.edu>, scvclerk@courts.state.va.us, Eric.Futrell@vsp.virginia.gov

EMERGENCY MOTION DUE TO BLOODY ASSAULT ON A.O. by ARLINGTON COURT EMPLOYEE p. 3

The door was about three quarters open, so I could see Ashlie standing in the back of the courtroom when she said, "I want to testify. Why can't I testify?"

An Arlington Deputy rushed at Ashlie and began to push Ashlie from the Courtroom. Ashlie tried to wiggle away from his grip, and then the Deputy seized her by the shoulders as he pushed Ashlie from the Courtroom, and then the Deputy swung Ashlie, smashing Ashlie into the corner between the entrance to Courtroom 4B and the double glass doors to the Judicial Chambers, knocking a phone off the wall in the process. (Later the phone was picked up, taken into the Judicial Chambers, and still later one of the Deputies put the phone back on the wall, to restore the image of normality.)

Ashlie began to scream. The Arlington Deputy reached with his hand for his extendable nightstick, and placed in under the throat of 12 year old Ashlie, apparently to silent the screams of Ashlie. I saw blood on the face of Ashlie.

Samantha saw all this too, and took a step or two to grab the Deputy to successfully pull him away from his assault on Ashlie. The Deputy began to strike Samantha, and Samantha reached back as though to strike him back, when I stepped forward and did a "bear hug" around both of Samantha's arms and pulled her away from the Arlington Deputy who had assaulted Ashlie first, and then began to assault Samantha when she tried to protect her younger sister.

Some Arlington Deputy came over and grabbed Samantha from me in the safe position several steps away from the attacking Deputy, and threw Samantha to the floor, and began dragging her into the short hallway that leads to the back of the Courtroom, and there turned her over with her face to the floor, jerked her arms behind her back and pulled hand-cuffs from his belt to hand-cuff Samantha.

Seeing that abuse of her sister Samantha, Ashlie sort of half bent over and began to SCREAM a little girl frightened scream at the top of her lungs.

NOW EVERYONE was aware of the problem and people and deputies began to rush into the hall outside the Judicial Chambers. An Arlington Deputy seized Ashlie, hand-cuffed her and wrestled Ashlie away while she was screaming at the top of her lungs across the entire lobby area down the hall by the Men's Room, into an office that is part of Court Services, out of sight of me, or any witnesses who were not Arlington employees.

Other Deputies came and ordered me, Donny and Salim into the waiting area, against our will, and did the same with other Citizens, so in reality all of us were in an imprisonment, when I tried to look out of the waiting area into the hallway to see what was going on, I was threatened by a Deputy.

Eventually, a Deputy came and stood in front of the Judicial Chambers doors and said, "It's over. You all must go now." and ordered us to leave the waiting area.

EMERGENCY MOTION DUE TO BLOODY ASSAULT ON A.O. by ARLINGTON COURT EMPLOYEE p. 4

Earlier the lights in the building had gone out (while I was on the witness stand), and so the elevators were ruled out of service, so we were told to go down the stairs near the hallway to the men's bathroom to the 3rd floor and take the escalators from there. We did as ordered by the Arlington Deputies.

Once outside in the rain, Ashlie's mother Patti Tackett and step-father Donny Ford saw an Arlington Ambulance parked facing the wrong way along the curb on Courthouse Road in front of the Arlington Courthouse. We all went over to see if Ashlie was in the ambulance, but could not see in.

After several minutes in the rain, and trying to find a Video Camera newsman George McDermott (not in time) two EMS technicians came to the ambulance. We asked about the condition of Ashlie after the attack by the Arlington Deputy, but neither Arlington EMS technician said even one word.

Samantha had been released by the Arlington Deputies, but complained that in the attack by the Arlington Deputy her hip had been hurt. Not trusting "anything Arlington" rather than go to Arlington Hospital Center, Samantha went with her step-father Donny Ford and mother Patricia Tackett to Georgetown University Hospital. Grandmother and Maryland Court Order Guardian Delores O'Brien Heffernan and I, Attorney in Fact for Mrs. Heffernan, drove in my truck to the Georgetown hospital, and News Reporter George McDermott went in his vehicle to Georgetown Hospital.

I have this morning spoken with an Arlington Sheriff Department employee Nancy Powell, to relate my recollections of the attack incident AND to REQUEST a copy of the Court Videos from Camera 40 of the elevator lobby and the Camera on the east wall of the waiting room that would have a view of the entrance door to Courtroom 4 B.

I advised Mrs. Powell that back in 2007, I had been forced to name Sheriff Beth Arthur in a Federal lawsuit because her staff would not release court videos where I was threatened by a man working in conjunction with a lawyer. When that prompted her to release the court videos, I filed a motion to remove Beth Arthur as a defendant because she eventually did her duty to a Citizen.

Time: 10:53 AM, 8 December in the Year of Our Lord Jesus 2011

James Renwick Manship, Sr.Chaplain, Advocate, Mediator, Counselor, Attorney-in-factAmos 5:15 Project - "Hate evil and love the good. Remodel your Courts into True halls of Justice"God and Country FoundationBox 76, Mount Vernon, Virginia 22121703-NRA-1776

3. Grandmother and Guardian of A.O. also a Next Friend and Co-Plaintiff in this case, Mrs. Heffernan

forwarded the following email exchange between her and Defendant Jason McCandless to Chaplain

Manship, Next Friend of the assaulted youth A.O. that shows the total lack of integrity and

responsibility of Arlington County, and the attempt to blame the incident on A.O.’s older sister, who just

told A.O. the truth that her Court Appointed Guardian Ad Litem Karen Grane had concealed from her.

EMERGENCY MOTION DUE TO BLOODY ASSAULT ON A.O. by ARLINGTON COURT EMPLOYEE p. 5

---------- Forwarded message ----------From: dheffernan <dobrienh@gmail.com>Date: Thu, Dec 8, 2011 at 2:08 PMSubject: Fwd: Please Advise On the Status of Ashlie andTo: James Renwick Manship <statesmanship@me.com>Cc: "Roy Morris Esq." <roy_morris@alum.mit.edu>

---------- Forwarded message ----------From: Jason McCandless <jmccandless@arlingtonva.us>Date: Thu, Dec 8, 2011 at 1:58 PMSubject: RE: Please Advise On the Status of Ashlie andTo: dheffernan <dobrienh@gmail.com>Cc: Godwin <flgodwin_law@verizon.net>, "Patricia Tackett (patacket@gmail.com)" <patacket@gmail.com>, Karen Grane <KGrane@cbclawoffice.com>, Sherri Brothers <Sbrothers@arlingtonva.us>

Ms. O'Brien:

I am told that Ashlie is safe. Your statement that medics were not permitted to examine Ashlie is incorrect.

It is unfortunate -- but not surprising -- that you blame the courtroom deputies for what happened. In his "recollections," Mr. Manship, suggests that Ms. Mahoney actually was the one who incited Ashlie's "outrage":

Samantha said to her sister words to the effect of, "Do you realize that you may not be able to see your mother or any of us anymore after this hearing?

They are trying to take away Mommy's parental rights."

4. As is all too typical, lawyer McCandless twists the truth (and should be severely sanctioned by

the Court). Transcripts can prove GAL Grane DID NOT speak in favor of A.O. testifying, and

dissembled in a way that the substitute judge, William Boice of Henrico County said that he did not

want to the poor little girl to be put in that position, without hearing directly the desires of A.O.

EMERGENCY MOTION DUE TO BLOODY ASSAULT ON A.O. by ARLINGTON COURT EMPLOYEE p. 6

Ashlie asked, "When will I be able to testify? I have been here all day waiting to testify."

Samantha said, "Your lawyer (Guardian Ad Litem Karen Grane) said she did not want you to testify, and so you won't be able to."

Ashlie was outraged, and went around her sister Samantha to go into the Courtroom 4B that was not in session during the recess, or break, called by Judge Boice to meet with Judge Wiggins who had asked to speak with him.

You will recall that Ms. Grane's position was that Ashlie should be permitted to testify. The judge, not Ms. Grane, ultimately determined that it was not in Ashlie's best interest. Therefore, if what Mr. Manship says is true, Ms. Mahoney actually lied to Ashlie about what had transpired in the courtroom. And for what purpose? How was upsetting Ashlie going to help you, Ms. Tackett, or Ms. Mahoney? It ultimately harmed Ashlie.

Ashlie's medical records are subject to a protective order issued by Judge Varoutsos; accordingly, you will not receive a copy.

Jason McCandless

Assistant County Attorney

Counsel for DHS / Child & Family Services Division

2100 Clarendon Boulevard #403

Arlington, VA 22201

Phone: (703) 228-3045

Fax: (703) 228-7106

Cell: (571) 329-4817

5. In the meantime, now A.O. has been physically attacked and bloodied in that attack by an

Arlington County employee, while her so-called attorney Guardian Ad Litem Karen Grane, sat on

her duff a few feet away and did not rise to assist until Grandmother Heffernan challenged Grane to

“get up and help your client”. Witnesses saw Grane finally get up, but really do nothing to help A.O.

6. Way back on 15 August 2011, “A.O.” wrote to juvenile Judge Varoutsos saying, “I don’t want

Karen Grane as my lawyer. She let the police det. Scott question me for hours with no drinks, no

food. I was crying the whole time. The only person who helped me was Mr. Scott the social

worker. Now he is gone because he helped me. Karen Grane did not stop the Police Det. Mrs.

Scott from her questions and abuse of me. Karen Grane does not protect me like a lawyer

should. She should have stopped the police of their abuse of me. I want a lawyer who tells the

court the TRUTH, and speaks for Me, and who speaks up for me. This court should know the

truth --”

7. The 12 year old girl A.O. desperately needs an honest lawyer (one who is not padding her

expense vouchers in this case as has Karen Grane), who is zealous to protect the interests of A.O,

NOT protect the interests of the Arlington JDR Court or its judges who give her lucrative jobs.

8. Plaintiffs beg for Emergency Restraining Order of a Federal appointed receiver, and assignment

of A.O. OUTSIDE the control of Arlington CPS or their appointed Foster Parents.

DATED: 30 November anno domini 2011

Respectfully submitted by:

__________________________

James Renwick Manship, Sr. Next Friend, Lead Plaintiff, Pro Se, and In Forma PauperisAmos 5:15 Project: “Hate evil and love the good. Remodel your Courts into True Halls of Justice.”God and Country Foundation, Box 76, Mount Vernon, Virginia 22121-0076, Phone: 703-672-1776 Facsimile: 703-638-1146

EMERGENCY MOTION DUE TO BLOODY ASSAULT ON A.O. by ARLINGTON COURT EMPLOYEE p. 7

EMERGENCY MOTION DUE TO BLOODY ASSAULT ON A.O. by ARLINGTON COURT EMPLOYEE p. 8

CERTIFICATE OF SERVICE

I hereby certify that on the 30th day of November 2011, I will file the foregoing with the

Clerk of the Court, asking the Clerk to use the CM/ECF system to notify the Arlington County

government attorney to notify other employee defendants, and certify I will send electronically to

the various adult co-plaintiffs. In addition, I hereby certify that I will mail the document by U. S.

mail to the following non-compliant with the Federal Rules of Civil Procedure attorney:

Ara L. Tramblian, Deputy County AttorneyArlington County Attorney’s Office2100 Clarendon Boulevard, Suite 403Arlington, Virginia 22201703-228-3100 (voice)703-228-7106 (fax)

also to assistant Attorney General, attorney for the Commonwealth of Virginia employees:

Farnaz FarkishAssistant Attorney General900 East Main StreetRichmond, Virginia 23219

and also to Arlington juvenile judge appointed Guardian Ad Litem attorney Karen Grane, who

properly should NOT be the beneficiary of representation by the Assistant Attorney General:

Karen Marie Grane2007 North 15th Street, Suite 1Arlington, Virginia 22201

NOTE: For Grane’s basement office shared with other “favored” Arlington JDR

Court appointed Guardian Ad Litem attorneys Mina Ketchie and Isabel Kaldenbach,

__________________________________

James Renwick Manship, Sr., Next Friend, Pro Se, In Forma Pauperis

Amos 5:15 Project, God and Country Foundation, Box 76, Mount Vernon, Virginia 22121

703-NRA-1776

EMERGENCY MOTION DUE TO BLOODY ASSAULT ON A.O. by ARLINGTON COURT EMPLOYEE p. 9