first amended complaint dillon v laflamme

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PATRICIA J. BARRY SBN 59116634 S. Spring St., Ste 823Los Angeles, Ca 90014Tele. (213) 995-0734Fax (213) [email protected] for Plaintiff RUBY DILLON on behalf of herself and her minor daughter A.D. as her guardian ad litem

UNITED STATES DISTRICT COURT

FOR CENTRAL DISTRICT OF CALIFORNIARUBY DILLON on behalf of herselfand her minor daughter A.M. as herguardian ad litem,

Plaintiff, v.

HAROLD LA FLAMME, ROBERTMUNOZ (in his individual capacity),MAHATHAP SRIKUREJA, STATEOF CALIFORNIA, COUNTY OFORANGE, ORANGE SUPERIORCOURT, ROSANNE FROEBERG (inher individual capacity), TONYRACKAUCKAS, (in his individualcapacity), BONNIE BREEZE (in herindividual capacity), MAUREENNAGANUMA (in her individualcapacity), C. J. WILKINSON (in hisindividual capacity), KRISTENEITNER (in her individual capacity),BIRUTE BRUZAS-RANES (in herindividual capacity), ROBERTMUNOZ, (in his individual capacity),

CASE NO. SA 15-CV-0339 DFM

FIRST AMENDED COMPLAINTFOR DAMAGES, ATTORNEYFEES AND COSTS, ANDINJUNCTIVE RELIEF

1. 42 U.S.C. Sec.1983: First Amendment - Free SpeechRetaliation and Denial ofMeaningful Access to Court;Fourth Amendment - IllegalSeizure of Child and false arrestand imprisonment; FourteenthAmendment - Denial of EqualProtection and of Due Process(Denial of Family Rights and ofRight to Bodily and EmotionalIntegrity)

2. 42 U.S.C. Sec.1985(2):Conspiracy to Deny EqualProtection and to Violate First Amendment - Free SpeechRetaliation and Denial ofMeaningful Access to Court;Fourth Amendment - IllegalSeizure of Child; FourteenthAmendment - Denial of DueProcess (Denial of FamilyRights and of Right to Bodilyand Emotional Integrity)

Case 8:15-cv-00339-JLS-JCG Document 15 Filed 03/26/15 Page 1 of 90 Page ID #:88

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JILL LUX (in her individual capacity)D'ALICIA MARRON-TAYLOR (inher individual capacity), DAVIDGLIDDEN (in his individual capacity),JENNIFER PALMQUIST (in herindividual capacity), DENISEJOHNSON (in her individualcapacity), JESSICA CHLEBOWSKI(in her individual capacity),THOMASMALABAN (in his individual capacity),HOWARD CHANG (in his individualcapacity) , JOHN CATE, ALANSTOKKE, MATTHEW DE ARMEY,GRACE COLEMAN, SHERYLEDGAR, EVA SRIKUREJAPRAVIT SRIKUREJA, ELIZABETHRAMIREZ LOCKMER, CAROLSTEWART, PATRICIA NASH, P.A.NASH & ASSOCIATESDOES 1 - 10,

Defendants.

3. 42 U.S.C. Sec.1985(3):Conspiracy to Deny EqualProtection Conspiracy to DenyEqual Protection and to ViolateFirst Amendment - Free SpeechRetaliation and Denial ofMeaningful Access to Court;Fourth Amendment - IllegalSeizure of Child; FourteenthAmendment - Denial of DueProcess (Denial of FamilyRights and of Right to Bodilyand Emotional Integrity)

4. 42 U.S.C. Sec.1986: Action forNeglect to Prevent Wrongs

5. Violence Against WomenReauthorization Act, 42 U.S.Code Sec.12395(b): Genderdiscrimination by Recipients andDisbursers of Federal Funds

6. Monell Violation

7. Negligence per se

8. Breach of Fiduciary Duty

9. Legal Malpractice

10. False Imprisonment

11. Child abuse

JURY DEMAND

PLAINTIFF RUBY DILLON (Dillon) on behalf of herself and her minor

daughter A.D. as her guardian ad litem alleges for her First Amended Complaint:

INTRODUCTION

In a series of searing questions, the three judges [former Chief JudgeKozinski, Judge Wardlaw, Judge Fletcher] expressed frustration andanger that California state judges were not cracking down onprosecutorial misconduct....Wardlaw, a Clinton appointee, complainedthat California's courts were "condoning" prosecutorial misconduct byupholding verdicts, a rare public criticism of her fellow judges. Shesuggested that state judges, who must be approved by voters, fearinciting the public's wrath....Fletcher...observed that the state's attorney general had fought "tooth


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and nail" more than a decade ago to prevent a court from seeing atranscript that revealed the false evidence.

U.S. Judges See 'Epidemic' of Prosecutorial Misconduct in State, MauraDolan, Los Angeles Times, January 31, 2015, 7:20 PM, emphasis added.

1. The Ninth Circuit scolding of state court judges may have influenced

Judge Thomas Goethels, DEFENDANT ORANGE SUPERIOR COURT

(Court), to take a courageous step on March 12, 2015, against DEFENDANT

TONY RACKAUCKAS (Rackauckas) Orange County District Attorney and his

Office by disqualifying the Office and appointing the Attorney General to

prosecute the death penalty phase of a murder case. The defendant, Scott Dekraai,

(Dekraai) had already pled guilty to the gun massacre of Michelle Fournier

Dekraai (Fournier), his ex wife and the mother of their eight year old son, and

seven other individuals at Fourniers work place in Seal Beach. The massacre

occurred in October 2011.

2. The Ninth Circuit panel (Judges Kozinski, Fletcher, and Wardlaw),

was also upset with State Attorney General Kamala Harris for defending against

the habeas petition of Defendant Baca in the face of the prosecutors own perjury.

Harris backed down, agreeing that Bacas conviction could be reversed and a new

trial granted.

3. Despite what occurred in the Baca case, Harris remains tethered to a

corrupt system which does not work for any of us, and repeatedly causes egregious

harm to women and children as occurred in this case and in the Dekraai case. And

the lesson of the Dekraai case is that when one does not listen to the domestic

violence victim, as was Michelle Fournier Dekraai, Dekraais ex wife,

(Fournier) one risks a massacre as did occur in the Dekraai case.

4. Harris is wasting taxpayer dollars on an appeal defending Rackauckas

and not the public interest. She is unmoved by the suffering of the family

members and friends of the murder victims of Dekraai who want the case to

proceed. That Harris is so calloused about the survivors of the victims should be


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noted. The mass killings were motivated by Dekraais misogyny directed against

Fournier.

5. Fournier had repeatedly warned the Court about Dekraais domestic

violence, his instability, and his raging personality. Yet, no one at the courthouse

seemed to take the female victim seriously. Somehow no one in charge the

judges and the police forced Dekraai to surrender his weapons as automatically

ordered when a Domestic Violence Prevention Act (DVPA) restraining order is

made which, it seems, was entered in the case before Dekraai murdered eight

people using guns.

6. DEFENDANT JOHN CATE (Cate) handpicked by DEFENDANT

HAROLD LAFLAMME (La Flamme) to be his successor as A.D.s minors

counsel in Dillons custody litigation represented Fournier.

7. At Http://usatoday30.usatoday.com/news/nation/story/2011-10-12/

calif-salon-shooting/50745746/1, Cate was quoted as telling the Orange County

Register that when Dekraai appeared for the Review hearing "Obviously, I saw

no indication that he was violent, the attorney said, emphasis added.

8. Yet, Fournier, his client alleged in pleadings that Dekraai

...had been physically abusive to her during their marriage, and that in2008 he beat his stepfather, pleaded guilty to assault and battery andunderwent a year of anger management....

Michelle Dekraai also alleged that her ex-husband called 911 at leastonce "advised that he was going to kill himself or someone else." Shewrote that he "is a diagnosed bipolar individual who has problemswith his own medication and his reaction to same, and he certainlyshouldn't be allowed to have unilateral and unfettered control of anyand all medical and psychological aspects of our son's life."

9. The murders occurred on October 12, 2011 and Michelle supposedly

had obtained a temporary restraining order on Tuesday, October 11, 2011, the day

of the hearing which was just one day before Dekraai murdered her and seven

other individuals according to one news report using guns.

http://www.cbsnews.com/news/ex-wife-of-accused-calif-salon-shooter-said-he-was-abusive-in-court-filings/


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10. If all the above is true, Cate, the judges, and the police took no steps

to insure that Dekraai surrendered his weapons to the police. A DVPA restraining

order is only as good as its enforcement.

11. It is also bitterly ironic that the misogynistic murderer successfully

recused Rackauckas while so far Rackauckas and his office have not been held

accountable for what they did to Dillon and most of all, to her daughter, A.D.

12. It is also no coincidence that Fournier litigated her case in the same

court, DEFENDANT ORANGE SUPERIOR COURT (Court) as did Dillon.

Fournier ended up murdered and Dillons daughter, A.D., now ten years old, has

literally been disappeared by Court judge Glenn Salter as far as we know to

Napa where she is imprisoned in the home of a hostile sister-in-law of A.D.s

father, DEFENDANT MAHATHAP SRIKUREJA (Srikureja). This is the man

A.D. said was sexually abusing her.

13. Dekraai gets a jury trial. Dillon and A.D. do not. Instead, Dillon and

A.D. and mothers and children throughout the state have their destinies

determined by the likes of La Flamme, a minors counsel. He also misappropriates

federal and other public funds, earmarked for the protection children, to protect

batterers and pedophiles rather than the children he is representing.

14. On LaFlammes State Bar profile, LaFlamme does not list whether he

received a bachelors degree and what he majored in. He graduated from Western

University State College of Law. We do not know if he meets the educational

requirements for a minors counsel set out in Rule 5.242, CA Rules of Court.

15. In 2009, Barry served a bar complaint against LaFlamme on the

California Supreme Court Chief Justice and President of the State Bar alleging

that LaFlamme had covered up sexual abuse of a father in another case and

betrayed his young client who was alleging that her father was sexually abusing

her. Both individuals returned the complaint to Barry. Their inaction enabled

LaFlamme to continue to harm other mothers and children including Dillon and


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A.D.

16. Social workers and County Departments of Family and Social

Services (DCFS) also known as Child Protective Services, (CPS) are out of

control. For example, Los Angeles DCFS is being investigated for child

trafficking. Social workers terminate the rights of parents, sell their children to

individuals, and pocket the money for themselves. According to one recent

article, a DCFS Administrator, Ron Louden, may have been involved in the child

trafficking ring. Los Angeles Department of Children and Family Services under

state investigation, dweisman | March 7, 2015 | Updated: March 7, 2015 @ 3:35

am

17. The State Bar is also implicated in the statewide invidious

discrimination against female protective parents and their children in family and

juvenile courts. In September 2014, this writer filed a request with the California

Supreme Court to remove former San Bernardino Judge Craig Kamansky as a

MCLE provider, teaching, of all topics, ethics to attorneys. Barry did so, because

of Kamanskys notorious reputation as a pedophile. Kamansky settled a case

brought by Jason Bumpus in this Court for $300,000.00 who alleged that while

sitting as a juvenile court judge, Kamansky had made Bumpus his ward and then

raped and sodomized him.

18. This writer understands that Kamansky was willing to risk a jury trial

until he learned that two sisters, the Harris sisters, were prepared to testify he

sexually abused them also.

19. Kamansky also received a public reproval from the California

Commission on Judicial Performance for taping over a video which Bumpus

alleged had child porn on it.

20. In October 2014, California Supreme Court Chief Justice

Cantil-Sakauye did not just deny Barrys request, she struck it. The Chief Justice

has sent a message loud and clear to the mothers and children Barry represents and


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to Barry, that childrens lives do not matter, especially those children who are

sexually abused like A.D., like Bumpus, and like the Harris sisters. The justice

prefers to support Kamansky, the alleged pedophile. Bumpus ended up taking his

own life. His life definitely did not matter to the state legal establishment. The

only court where he received any justice was this Court.

21. In September 2011, the State Bar Review Court, Judges Remke,

Purcell, and Epstein, ruled that Attorney Gary Grants plea of guilty to possession

of child porn was NOT moral turpitude. He was suspended for three years, with

actual suspension for two years. The judges, two women and one man, appeared

to buy into his bogus defense of being a sex/love addict. See pp.6-7 of the ruling.

Sex and love were not the issue, even addiction to either or both. A crime against

children was.

22. In February 2014, the California Supreme Court surprisingly reversed

the Review Court and disbarred him, while retaining Kamansky who is alleged not

only to possess child porn like Grant, but actually sexually abused at least three, if

not more, children using his judicial authority to obtain custody of the children

for the sole purpose of sexually abusing them.

23. Thus, female (for the most part) protective parents and their

children suffering from sexual abuse do not stand a chance. It in this so-called

justice system in which Dillon and A.D. found themselves when Srikureja began

his campaign to wrest custody from Dillon so that he was free to molest A.D. at

his pleasure.

24. Although the Court awarded Dillon sole custody of A.D. when she

was nine months old, after Srikureja filed a motion for modification of custody in

2010, Dillon agreed to joint custody. A.D. then began to disclose that Srikureja

was sexually abusing her. A.D. reported on multiple occasions that she was being

sexually abused by Srikureja. A.D. exhibited physical symptoms of sexual abuse,

and two medical professionalsthe childs psychologist and her treating


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physician firmly believed that the abuse was real. And yet the court awarded

sole custody of A.D. to Srikureja.

25. This is consistent with the nation wide, state wide, county wide

pattern and practice of awarding custody to the alleged abuser and punishing the

protective parent, almost exclusively, the mother, by denying her access to the

child she is trying to protect and turning the child over to the abuser.

26. Srikureja, Srikurejas attorneys, in particular, La Flamme, notorious

for his betrayal of his vulnerable clients and support of abusive fathers, Srikurejas

close friend with a MFT license, his two sisters, nannies, a police officer, members

of the D.A.s office, social workers, and visitation monitors participated in a

conspiracy to hide and suppress all the evidence of A.D.s abuse, to insure that

Dillon and A.D. would not have access to each other, and Srikureja would have

custody of A.D. despite the fact she repeatedly disclosed that Srikureja was

sexually abusing her.

27. The conspiracy reached high places, and included DEFENDANT AL

STOKKE (Stokke), Srikurejas attorney and members of the District Attorneys

Office who took over the investigation of the sexual abuse charges.

28. Rackauckas and Stokke, who not only contributes but also raises

campaign funds for Rackauckas, have informally agreed that Stokkes clients will

generally not be prosecuted or they will enter into a collusive sweetheart plea

agreement for Stokkes clients. Srikureja also may well have donated campaign

funds to Rackauckas.

29. Srikureja abandoned A.D. in June 2013. He fled to Canada on June

29, 2013 one day after Tustin Police Dept informed the D.A. it was

recommending prosecution of Srikureja on six felony counts of sex abuse of A.D.

He is not a citizen of Canada but rather of Thailand. The United States will not

allow him to re-enter the country.

30. The jurists, Commissioner Wilson (Comm. Wilson), Judge James


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L. Waltz (J. Waltz) and Judge Glenn R. Salter (J. Salter) , assigned to the

family law department of Court were willing participants in this conspiracy.

31. The judgment of J. Waltz entered in July 2013 giving Srikureja full

custody and ruling that Dillon had coached A.D. to allege charges of sexual abuse

against Srikureja began unraveling in J. Salters courtroom. The custodial parent

was nowhere around and not enforcing his right of custody. There was enormous

negative publicity in newspapers, on T.V., on the internet, and the radio against J.

Salter, the court, the D.A., and LaFlamme. A review of the Robing Room ratings

of J. Salter are among the worst any judge has received, given what this writer has

reviewed, about 48 ratings, only 3 of which are positive, and the rest, extremely

negative and mostly about what he was doing to Dillon and A.D.

32. Judge Salter began to attack and threatened all those who supported

A.D., including Dean Tong, a former potential expert witness for Srikureja,

Merritt McKeon, who at one time served as Dillons appellate attorney, Allan

Gleisinger, who is Dillons husband, Ron Funk who took on the case in J. Salters

courtroom in 2014 and also filed writ petitions and briefs in the Court of Appeals,

and Thea Reinhart, who was A.D.s court-appointed therapist whose opinion was

that A.D. was credible, Dillon should have exclusive custody, and Srikureja had

most likely molested A.D. and should be placed in supervised visitation.

33. On May 7, 2014, J. Salter ordered his courtroom bailiff

DEFENDANT HOWARD CHANG (Chang) to falsely arrest and falsely

imprison Dillon on an eight year old failure- to- appear for traffic-related offenses

of which Dillon was unaware. For the first time since he had taken over the case,

and after Dillon had made numerous appearances, he claimed he did not know

who Dillon was and ordered her arrested.

34. In August 2014, J. Salter ordered A.D. to Napa County where on

information and belief A.D. is forced to live with a virtual stranger,

DEFENDANT EVA SRIKUREJA , (Eva), the wife of Srikurejas brother. She


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of course is not a blood relation of A.D. On information and belief, she is abusive

to A.D. because she, along with Srikurejas sister Pravit, refuse to accept that

Srikureja sexually abused A.D. and are punishing her for saying he did.

35. After five years of custody litigation in Orange Superior Court, no

one in California has an order of custody and no one knows where A.D. is. She

may well be out of state or out of the country since she is not registered in any

school in Napa. J. Salter has disappeared A.D.

36. Another way that female protective parents, like Dillon, and their

abused children, like A.D. lose out is the court itself in which the die is cast. In

this case, Police officers wanted to file, or perhaps had filed, a juvenile court

petition. Defendant social workers, working hand in glove and at the behest of

LaFlamme, possibly Rackauckas office, put the kibosh on the petition - twice.

37. In Family Court, when a mother alleges abuse by the father of the

children, the mother goes on trial, not the father. The case becomes about the

mother reporting what her children are telling her, and not about what the father is

doing to the children.

38. In the macabre ritual which child abuse cases have become in family

court, the mother is labeled with the scarlet A (alienator). The accused father

and his supporters need only label the mother an alienator, and immediately the

burden shifts to the mother to prove the negative, that she is not. The father

generally can avoid rebutting the forensic evidence accumulating against him

simply by attacking the mother.

39. Further, as Srikureja and LaFlamme did, aided and abetted by a

commissioner and two judges, they simply quashed the testimony of the childs

medical expert and her therapist by hijacking A.D.s privilege in a patriarchal

twist of the law turning her privilege against her in favor of the man abusing her.

40. If the defendant social workers had not been a part of the gender-

based conspiracy to deprive Dillon and her daughter of due process and equal


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protection, had a will to protect A.D., and had joined forces with the police to file

a petition in juvenile court, the outcome for A.D. and her mother would have been

the very opposite.

41. Defendants forced Dillon and A.D. into the family law forum

knowing that civil rules of evidence apply and the focus was on Dillon, and not on

A.D.; whereas, dependency court has two hearsay exceptions which would have

allowed A.D.s out-of-court statements about sexual abuse into evidence.

42. Thus, the out-of-court statements of A.D. about sexual abuse most

likely would have been admitted because they were disclosed to police officers,

social workers, and health care practitioners. And the exit order back to family

court would have been a permanent restraining order against Srikureja, supervised

visitation, and sole legal and physical custody of A.D. to Dillon.

43. What basic rights should every child be guaranteed by a civilizedsociety? Do children have the right to be mothered and fathered inloving and non-violent ways? Are childrens needs being met by thepatriarchal family during marriage or by the patriarchal state afterdivorce? ....

As a nation we say we care about childrens safety and welfare. Yet,as a society we tend to view custody as a contest between awinner and a loser, not as a series of questions about theconditions under which women mother, and men father, and childrengrow up and about who determines these conditions.

Our focus must shift from resolving custody by force, and in anti-mother ways, to a more civilized resolution of our child-carearrangements. ....

Public hearings on custody are urgently needed, Such hearings couldinform the public that all mothers are custodially vulnerable becausethey are women; that all fathers, including incestuous [as in thiscase] , violent, absent, [as in this case], passive, or helper Fathers,can win custody, not because mothers are unfitor because fathersare truly equal parents but because fathers are men, and that allcustodial mothers and children are impoverished against their will,both by individual fathers and by the legislators. Mothers on Trial,Phyllis Chesler, Preface, pp.xv-xvi.

JURISDICTION AND VENUE

44. The Court has jurisdiction over this action pursuant to 28 U. S.C.

Sec.1331 (federal question), 42 U.S.C. Sec. 2000d-7(a)(1) & (2) , and under 28


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U.S.C. Sec.1367(a) (supplemental jurisdiction based on the same core of facts on

which the federal claims are based). Venue lies in this district since the claims

arose and most of the defendants are located in the Central District of California.

PARTIES

45. Dillon is the Mother of A.D. and currently is living in Canada. She

is a Canadian citizen. She resided in DEFENDANT COUNTY OF ORANGE

during almost all the time the acts alleged in this complaint occurred.

46. A.D. is the minor daughter of Dillon and Srikureja. She is ten years

old and her birthdate is October 17, 2004. She is a victim of child sexual abuse by

Srikureja.

47. La Flamme is an attorney licensed to practice in the courts of

California. He engaged in a conspiracy to hide and suppress the evidence of

Srikurejas sexual abuse of A.D., to deprive Dillon of custody of A.D., A.D. of

access to her Mother , and to insure custody of A.D. to Srikureja. He violated his

fiduciary duty to A.D. and committed legal malpractice against her. He is

responsible for the acts of which Dillon complains. He is a recipient of federal

funds and was receiving them at the time he was minors counsel for A.D.

48. DEFENDANT ROBERT MUNOZ (Munoz) is a former social

worker employee of DEFENDANT COUNTY OF ORANGE Social Services

Agency, Division of Children and Family Services (DCFS). He conspired to

hide and suppress the evidence of sexual abuse of A.D. by Srikureja, to deprive

A.D. of access to her Mother, to deprive Dillon of custody of A.D., and to insure

that Srikureja would be awarded custody of A.D.

49. Munoz engaged in felony perjury by falsifying his credentials on the

stand and by rendering opinions related to the custody of A.D. which were false

and had no factual or legal foundation, resulting in the Court awarding custody to

Srikureja. County terminated Munoz from employment, on information and

belief, because of his felony perjury in A.D.s custody case. He is sued in his


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individual capacity.

50. Srikureja is the father of A.D., currently residing in Canada. He is a

citizen of Thailand. He left the U.S. on June 29, 2013 and has abandoned A. D.

He sexually, physically, and emotionally abused A.D. thus directly violating her

right to bodily and emotional integrity. He also defamed Dillon.

51. California is a state and a recipient of federal funds. It is liable to

Dillon and A.D. for the gender discrimination and retaliation committed by the

other defendants resulting in deprivation of fundamental family rights and denial

of equal protection and due process. It is liable for aiding and abetting Srikurejas

violation of R.M.s right to bodily and emotional integrity by failing to insure that

public funds did not get into the hands of individuals like the defendant social

workers and LaFlamme who protect pedophiles and harm children. California is

liable for the public funds it paid to La Flamme, to the County, and to the Court.

52. Court is a public entity created by state statute and the California

Constitution. It is a part of the state government. It is a recipient of federal funds.

It is liable to Dillon and A.D. for the gender discrimination and retaliation

committed by the other defendants resulting in deprivation of Dillons and A.D.s

fundamental family rights and denial of their right to equal protection and due

process. It is liable to A.D. for aiding and abetting Srikurejas violation of

A.D.s right to bodily and emotional integrity by failing to insure that the funds

did not get into the hands of individuals like LaFlamme or were used to pay for the

salaries of judges like J. Waltz and J. Salter. Court is liable for the public

funds it paid to La Flamme.

53. DEFENDANT COUNTY OF ORANGE (County) is a public entity

existing by reason of the constitution and laws of the State of California. Its

policies, customs, practices, and procedures caused the constitutional violations of

which Dillon and A.D. complain.

54. County is also a recipient of federal funds. As such, it is also liable to


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Dillon and A.D. for the gender discrimination and retaliation committed by the

other defendants resulting in deprivation of fundamental family rights and denial

of equal protection and due process. It is liable to A.D. for aiding and abetting

violation of A.D.s right to bodily and emotional integrity by failing to insure that

the funds did not get into the hands of individuals like the defendant social

workers and LaFlamme who support pedophiles and harm children. The County is

liable for the public funds it paid to La Flamme.

55. DEFENDANT ROSANNE FROEBERG (Froeberg) is a deputy

district attorney employed in the Orange County District Attorneys Office. She

conspired with the other defendants to hide and suppress the evidence of sexual

abuse Srikureja inflicted on A.D., to deprive A.D. of access to her Mother , to

deprive Dillon of custody of A.D., and to insure that Srikureja would be awarded

custody of A.D. She took over the investigation of sexual abuse of A.D.,

suppressed evidence of A.D.s sexual abuse, denied Dillon access to the Countys

records of investigation, and falsely reported that no abuse had occurred. She

attempted unethical ex parte contact with J. Salter. She is sued in her individual

capacity.

56. Rackauckas is the Orange County District Attorney. DEFENDANT

ALAN STOKKE and Rackauckas have had a long term personal quid pro quo

relationship whereby Stokke donates to Rackauckas campaigns and urges others

to make political donations to him in exchange for which Rackauckas will not

prosecute Stokkes clients or go very lightly on them.

57. On information and belief, Rackauckas personally insured or

indirectly or directly conveyed to Froeberg that she was to close her

investigation of Srikureja finding no evidence of sexual abuse. Stokke was in

contact with Rackauckas office to insure that Srikureja and other individuals

recommended for prosecution by the County Sheriff Department and Tustin

Police Dept would not be prosecuted , namely, Defendants Edgar, Cate, Nash,


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P.A. Nash & Associates , Munoz, and Coleman. He is sued in his individual

capacity.

58. DEFENDANT BONNIE BREEZE is a police officer employed by

Tustin Police Dept. She suppressed evidence of A.D.s sexual abuse and testified

to matters for which she had no expertise in order to insure that Srikureja would be

awarded custody, Dillon would have custody of A.D. taken from her, and A.D.

would not have access to Dillon . She is sued in her individual capacity.

59. DEFENDANT MAUREEN NAGANUMA (Naganuma) is a social

worker employed by County DCFS. She participated in a conspiracy to suppress

evidence of A.D.s sexual abuse and to falsify reports. She is sued in her


60. DEFENDANT C. J. WILKINSON (Wilkinson) is a social worker

employed by County DCFS. He participated in a conspiracy to suppress evidence

of A.D.s sexual abuse and to falsify reports. he is sued in his individual capacity.

61. DEFENDANT KRISTEN EITNER (Eitner) is a social worker

employed by County DCFS. She participated in a conspiracy to suppress evidence

of A.D.s sexual abuse and to falsify reports. She is sued in her individual

capacity.

62. DEFENDANT BIRUTE BRUZAS-RANES (Bruzas-Ranes) is a

social worker employed by County DCFS. She participated in a conspiracy to

suppress evidence of A.D.s sexual abuse and to falsify reports. She is sued in her


63. DEFENDANT JILL LUX (Lux) is a social worker employed by

County DCFS. She participated in a conspiracy to suppress evidence of A.D.s

sexual abuse and to falsify reports. She is sued in her individual capacity.

64. DEFENDANT D'ALICIA MARRON-TAYLOR (Marron-Taylor) is

a social worker employed by County DCFS. She participated in a conspiracy to

suppress evidence of A.D.s sexual abuse and to falsify reports. She is sued in her


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65. DEFENDANT DAVID GLIDDEN is a social worker employed by

County DCFS. he participated in a conspiracy to suppress evidence of A.D.s

sexual abuse and to falsify reports. He is sued in his individual capacity.

66. DEFENDANT JENNIFER PALMQUIST is a social worker



capacity.

67. DEFENDANT DENISE JOHNSON is a social worker employed by

County DCFS. She participated in a conspiracy to suppress evidence of A.D.s

sexual abuse and to falsify reports. She is sued in her individual capacity.

68. DEFENDANT JESSICA CHLEBOWSKI is a social worker



capacity.

69. THOMAS MALABAN (Malaban) is a social worker employed by

County DCFS. He participated in a conspiracy to suppress evidence of A.D.s

sexual abuse and to falsify reports. He also failed to refer A.D. for a forensic

sexual abuse exam. He is sued in his individual capacity.

70. Chang is a deputy sheriff employed by the County. He is assigned as

a bailiff to J. Salters courtroom at Lamoreaux Center in Orange, California. He

falsely arrested and had Dillon imprisoned on May 7, 2014. He is sued in his


71. Cate is an attorney licensed to practice in California. Cate replaced

LaFlamme as minors counsel. He participated in the conspiracy to hide and

suppress evidence of A.D.s sexual abuse, to insure custody to Srikureja, to deny

his client A.D. access to her Mother. He joined with other supporters of Srikureja

to send A.D. to Napa where she has been held prisoner by DEFENDANT EVA


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SRIKUREJA whom she barely knows. Eva is the estranged wife of

SRIKUREJAs brother who lost his medical license in several states. Cate

breached his fiduciary duty to A.D. and committed legal malpractice against her.

Orange County Sheriff Department recommended to the D.A. Cate be prosecuted.

Rackauckas declined based on his pay-to-play agreement with Stokke.

72. DEFENDANT ALAN STOKKE (Stokke) is an attorney licensed to

practice in California. Srikureja retained him as his criminal attorney to insure that

Rackauckas would not prosecute him for criminal child sexual abuse. Stokkes

unethical relationship with Rackauckas is well documented and the subject of

Orange County Grand Jury Reports. He was part of the conspiracy to hide and

suppress evidence of A.D.s sexual abuse, to insure custody to Srikureja, to deny

his client A.D. access to her Mother .

73. DEFENDANT MATTHEW DE ARMEY (De Armey) is an

attorney licensed to practice in California. Srikureja retained him as his family law

attorney. De Armey pushed the Court to appoint LaFlamme as minors counsel.

De Armey knew that LaFlamme would protect Srikureja and sacrificed the health,

safety, and welfare of his own client, A.D. Stokke, De Armey, and La Flamme

worked hand in glove to suppress all evidence of Srikurejas sexual abuse, defeat

Dillon and A.D. and insure that Srikureja would have custody of A.D.

74. DEFENDANT GRACE COLEMAN (Coleman) is a close friend of

Srikureja and had lived with him for three years. She is a marriage and family

therapist. Coleman violated a court order by conducting therapy with A.D. in

which she attempted to make A.D. recant that she was sexually abused by

Srikureja, wrote falsified reports which she provided to De Armey who in turn

provided her falsified, unethical, and unauthorized reports of therapy to

Froeberg who used them, in part, to say that A.D. was not sexually abused.

Because of Stokkes and Rackauckas unethical relationship, Rackauckas declined

to prosecute Coleman for interference with a witness although she was


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recommended for prosecution by Tustin Police Department.

75. DEFENDANT EVA SRIKUREJA (Eva) is the estranged wife of

Srikurejas brother. She has had little contact with A.D. and yet she agreed to

have A.D. live with her in Napa. A.D. wants to be with her Mother . Eva has

kept A.D. from her Mother for over six months. Dillon has no idea what

condition her daughter is in, even whether she is attending school, whether she has

suffered any illness, or whether she is safe. Eva does not have an order of custody

of A.D. Orange Superior Court found her to be an unsuitable guardian for A.D.

and dismissed her guardianship petition. On information and belief she is abusing

and neglecting A.D. unless she has shipped her off somewhere else because she

dislikes her for reporting that Srikureja sexually abused her.

76. DEFENDANT PRAVIT SRIKUREJA (Pravit) took custody of

A.D. without a court order and literally held her prisoner after her brother

Srikureja fled the country in fear he would be criminally prosecuted for sexually

abusing A.D. On information and belief she abused and neglected A.D. because

she dislikes her for reporting that Srikureja sexually abused her. She participated

in the conspiracy to deny custody to Dillon, deny A.D. access to her Mother , and

insure her absentee brother would retain custody.

77. DEFENDANT ELIZABETH RAMIREZ LOCKMER (Lockmer)

served as a so-called nanny for A.D. She abused and neglected A.D. and filed

falsified declarations with the Court.

78. DEFENDANT CAROL STEWART (Stewart) was employed by

DEFENDANT P.A. NASH & ASSOCIATES and in that capacity served as

visitation monitor for the visits between Dillon and A.D. Stewart falsified

information in her reports and defamed Dillon. She participated in the conspiracy

to suppress evidence of Srikurejas sexual abuse of A.D., deny custody to Dillon,

deny A.D. access to her Mother , and insure Srikureja would retain custody. The

police department recommended that she be prosecuted criminally. Rackauckas


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insured she would not be prosecuted just as he insured that Srikureja, Attorney

Edgar, Attorney Cate, Munoz, and Coleman would not be prosecuted.

79. DEFENDANT PATRICIA NASH is the owner of DEFENDANT

P.A. NASH & ASSOCIATES. LaFlamme handpicked her and her company to

serve as visitation monitor for the visits between Dillon and A.D. Stewart falsified

information in her reports and defamed Dillon. She participated in the conspiracy

to deny custody to Dillon, deny A.D. access to her Mother , and insure Srikureja

would retain custody. The police department recommended that she be prosecuted

criminally. Rackauckas insured she would not be prosecuted just as he insured

that Srikureja, Attorney Edgar, Attorney Cate, Munoz, and Coleman would not be

prosecuted.

80. DEFENDANT P.A. NASH & ASSOCIATES is the company owned

by Nash. As such it is responsible for the acts of Nash and Stewart based on

respondeat superior.

81. Defendants DOE 1 through DOE 10, inclusive, are sued herein under

fictitious names. Their true names and capacities are unknown to Dillon. When

their true names and capacities are ascertained, Dillon will amend this complaint

by inserting their true names and capacities herein. Dillon is informed and believes

and thereupon alleges that each of the fictitiously-named defendants is responsible

in some manner for the occurrences herein alleged, and that Dillons damages as

herein alleged were proximately caused by those defendants.

82. Dillon is informed and believes and thereupon alleges that at all times

herein mentioned each of the defendants was the agent of each of the remaining

defendants, and in doing the things herein alleged, was acting within the scope of

his/her agency with one another.

STATEMENT OF FACTS

83. In April 2005, Dillon left Srikureja when A.D. was 6 months old. In

July 2005, the Court awarded Dillon sole physical custody and Srikureja,


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visitation.

84. Before he filed a motion to modify custody which was in November

2010, Srikureja began sending bizarre texts to Dillon asking rhetorically what was

wrong with A.D. having sex and in what ended up to be prescient statements,

given his subsequent sexual abuse of A.D., that she would be having sex by the

time she turned seven.

7. Shortly after Srikureja filed his motion, Dillon and Srikureja signed a

stipulation providing for shared physical custody after Dillon was misled into

believing there had to be joint custody before a judge would order a custody

evaluation which she wanted. Shortly thereafter, A.D. reported incidents Dillon

found troubling, such as Srikureja sleeping naked in the same bed as A.D. with his

penis up against A.D.

85. By 2011, A.D. started to show physical symptoms of abuse. On

February 25, 2011, A.D. informed Dillon that she had been bleeding from her

rectum, and Dillon observed blood on the toilet A.D. had been using. Dillon

immediately took A.D. to the emergency room, where doctors diagnosed A.D.

with three anal fissures. The treating doctor informed Dillon that he had never

seen three fissures so large in his seventeen years of practice, and that the fissures

may have been caused by non-accidental trauma.

86. The incident and the doctors diagnosis were reported to CPS that

same day. Malaban, the CPS investigator, ultimately deemed the possibility of

abuse unfounded because, according to CPS personnel, six-year-old A.D. did

not disclose sexual abuse when interviewed. Malaban failed to refer A.D. for a

forensic medical exam citing "the child most likely had perinatal fissures that bled

from constipation and an ongoing custody battle" although an ongoing custody

battle cannot cause fissures in a childs rectum. Malaban was unqualified to

conclude that it was constipation, and squelched a referral for a forensic sex abuse

examination of A.D. Malaban also failed to interview collateral contacts.


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87. On March 1, 2011, the trial court appointed Dr. David Sheffner to

serve as the court-appointed child custody evaluator. Dr. Sheffner, a

specialist in forensic psychiatry, conducted numerous consultations with

Srikureja, Dillon, and A.D. over the ensuing five months.

88. The Court also ordered both Dillon and Srikureja not to take A.D. to

therapists without an order.

89. Srikureja defied the order and enlisted Coleman who has a California

MFT license and is Srikurejas close friend with whom he lived for three years to

engage in harmful, unethical, and fraudulent therapy with A.D. Coleman had 30

sessions with A.D. Dillon obtained six of Colemans "To Whom it May Concern"

letters which began in June 2011 and ended in May 2013.

90. Colemans "To Whom it May Concern" letters were forwarded to

Stokke who provided them to Froeburg who on information and belief utilized the

letters in her investigation to conclude there was no or insufficient evidence to

prosecute Srikureja for sexual abuse of A.D. The dates of Colemans Letters

which Dillon was able to obtain are June 30, 2011, December 3, 2012, December

16, 2012, January 27, 2013, April 14, 2013, and May 30, 2013.

91. Coleman claimed she was [A.D.]s therapist but had Srikureja

participate in the sessions, meaning that she knowingly forced the alleged victim

to talk about the abuse in the presence of the alleged abuser.

92. On June 11, 2011, Coleman wrote:

-- I am writing this as an advocate for [[A.D.]]. [But the onlyadvocates the Court appointed for [A.D.] were LaFlammeand Cate who ended up as advocates for Srikureja. The onlycourt- appointed therapist was Dr. Reinhart.]

I do not know [[A.D.]]'s mother.

I know her father, whom I have seen frequently with [A.D.],[an underwhelming description of her relationship withSrikureja and based on overwhelming deceit she had livedwith Srikureja for three years, whether it was sexual is notknown. She was a friend trying to get a friend out of troubleand willing to risk her license in doing so. ]


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93. The letter goes on, waxing eloquent for Srikureja, turning the letter

into a paen to him and his fatherly abilities.

94. On December 3, 2012, Coleman wrote that she and [A.D.] do not

discuss ... the legalities that are powerful forces that tend to eliminate or modify

her God-given right to spontaneity, confidence, and joy. Whatever that sentence

may mean, there is no question it is Coleman and Srikureja who smothered

[A.D.]s God-given right to spontaneity, confidence, and joy when they forced

[A.D.] to sit with them to discuss her sexual abuse allegations against Srikureja.

95. Further, at this point, thanks to LaFlammes false allegation of

coaching, Judge Waltz had already placed Dillon in supervised visitation in July

2012, so that as of December 2012, A.D. had been in the exclusive clutches of

Coleman and Srikureja for five months.

96. By December 16, 2012, Coleman, the unauthorized and contumacious

therapist was now defaming Reinhart, the authorized and legitimate court

appointed therapist, in her letter of same date claiming that [A.D.] had told her that

Reinhart told [A.D.] to keep her visit at [A.D.]s school a secret from Srikureja.

Reinhart was the therapist for A.D., not Coleman. Undermining Reinhart became

important since Reinhart had now reached the conclusion that A.D. was a victim

of sexual abuse.

97. Coleman had good reason to rachet up the controversy. As of

December 2012, Tustin Police Dept had removed A.D. from her fathers custody

twice, on August 23, 2012, filing an affidavit of good cause that she was in danger

in her fathers custody and then in November 2012. On both occasions, the police

department had also filed juvenile court petitions, both of which were quashed by

social worker defendants acting in concert with LaFlamme, DeArmey, and

possibly, Stokke, if not Rackauckas himself or a deputy acting at his direction.

98. There is no question that hundreds of thousands of dollars exchanged

hands from Srikureja to Stokke and DeArmey, Stokke continued to raise campaign


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funds for Rackauckas, and LaFlamme misappropriated federal and other public

funds to protect Srikureja. LaFlamme and Srikureja probablycontributed to

Rackauckas campaign coffers.

99. Srikureja, DeArmey, LaFlamme, and probably Stokkes only defense

to the growing body of evidence that Srikureja was sexually abusing A.D. was

that Dillon was coaching A.D. Their bias was obvious, particularly their financial

interest. Srikureja was paying these lawyers huge amounts of money and expected

results. They needed A.D. to say she was coached. Coleman came through for

them through her criminal interference with a witness, her deception and her

willingness to breach her code of ethics.

100. In her January 27, 2013, letter Coleman began, lightly, to state that

she now has learned that from A.D. that she was coached to lie about Srikureja.

101. Dr. Sheffner and Dr. Reinhart, the courts own experts, saw no

evidence of coaching. Sheffner made mandated reports on behalf of A.D. He

also testified that Dillon should have primary custody. Dr. Reinhart believed the

child and urged that Srikureja be placed in supervised visitation just as Dr.

Kanofsky, a gynecologist who examined A.D., had done. Both Reinhart and

Kanofsky made mandated reports and wrote to the Court about their concerns for

the safety of A.D. Twice Tustin Police Department had removed A,D. from

Srikureja because the officers concluded she was in danger in Srikurejas custody.

Tustin police officers found A.D. credible.

102. Coleman had to take action in the face of what the official experts and

the police department were saying. In her next letter dated April 14, 2013, almost

two years to the date that Coleman began her pernicious therapy, she ratcheted up

what she claimed A.D. was telling her: now the disclosures were because

Mommy made me do it.

103. Then, on May 30, 2013, Coleman made coaches out of anyone who

heard A.D. disclose that Srikureja was sexually abusing her - her mother, Dillons


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husband Allen, Dillons friends Tanya Garrett and Sara Hill and A.D. was

forced to lie, be evasive and dishonest with Sheffner, Reinhart, and the police.

Coleman did not directly attack the official court appointees or the police; she just

made them dupes of the hapless little girl who was coached by so many people

the villains in the piece per Coleman.

104. Tustin Police Dept was having none of Colemans machinations.

Instead, a month later, Tustin P.D. recommended criminal prosecution of

Srikureja. They also investigated Coleman for dissuasion of a witness and

referred her to the D.A. for criminal prosecution. So far, Coleman has suffered no

consequences for her criminal and unethical actions against a vulnerable child

because of Rackauckas pay to play scheme.

105. On August 2, 2011, Dr. Sheffner released an 84-page report detailing

his recommendations. He recommended that Dillon be granted primary custody

during the school year, while Srikureja would have primary custody during the

summer. Dr. Sheffner concluded that [ Dillon ] was far more reasonable

/appropriate, . . . more flexible, manifested parental concerns, and her

verbalizations were more child-oriented, whereas [ Srikureja s] verbalizations

were more having to do with [ Dillon ]. Dr. Sheffner was especially concerned

with [ Srikureja s] quite prominent and chronic hostility toward [ Dillon ], and

his obstructionist attitude toward [A.D.] and [ Dillon s] relationship..

106. Dr. Sheffner briefly commented on the reports of abuse (which were

limited at that point) and Srikureja s counter-allegation that Dillon had coached

A.D. to make those reports. Dr. Sheffner could not conclude either molestation or

coaching had occurred, but noted that he had not received the [CPS] reports.

107. On January 2, 2012, CPS received a new report that A.D. may be the

victim of abuse. The next day, CPS conducted a CAST interview with A.D.,

during which A.D. stated that Srikureja had inappropriately kissed and touched

her, including on her genitals. CPS ultimately found these reports inconclusive.


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CPS cited the on-going custody battle as a basis for questioning A.D.s claims,

stating that it is unclear whether or not the sexual abuse has occurred due to the

on-going custody battle. which does not make sense, because a custody battle

cannot cause sexual abuse to occur. It occurred because Srikureja was molesting

A.D.. The custody dispute arose because A.D.s mother sought to protect A.D.

which Srikureja did not like.

108. On January 26, 2012, CPS received another report of potential abuse,

this one from Dr. Myron Kanofsky, a gynecologist who had examined A.D. Dr.

Kanofsky not only referred his concerns to CPS, but provided a declaration to the

trial court stating that he was so concerned for [A.D.s] wellbeing that the court

should immediately suspend Srikureja s visitation rights. Dr. Kanofsky

explained that after examining and speaking with then-seven-year-old A.D., her

reports of abuse were credible, and the doctor believed they were true. Pursuant

to Dr. Kanofskys referral, CPS conducted a second CAST interview on January

30, 2012. A.D. again reported inappropriate touching by Srikureja.

109. On February 27, 2012, Naganuma consulted with Senior Social

Services Supervisor Bruzas-Ranes regarding the CAST interview "as it appeared

that the sexual abuse allegations could not be substantiated due to the child's

inconsistent statements and the possibility the child was coached". Bruzas-Ranes

concurred the child could be released to the father. CPS did not address the fact

that Dr. Kanofsky believed the allegations to be true.

110. In January 2012, Dillon requested that the court suspend Srikureja s

custody given the abuse allegations. Srikureja responded by requesting sole

custody pending trial, alleging that the abuse allegations were the result of

Dillons coaching. Commissioner Wilsonthen presiding over the caseheld

a hearing on February 24, 2012.

111. The two witnesses at the hearing were Robert Munoz, CPSs liaison

to the family court, and Detective Bonnie Breeze. Munoz was not involved in the


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investigations but somehow got away with summarizing the CPS reports to date.

Breeze, who had investigated some of the abuse reports, admitted she had no

direct evidence of coaching. She agreed with a statement of Srikureja s counsel,

however, that A.D.s inability to answer certain questions was consistent with

coaching. Breeze had no factual basis for making this opinion nor was she

qualified to render such an opinion.

112. Dillon called Dr. Kanofsky to testify, and Srikureja asserted the

doctor-patient privilege on A.D.s behalf. The court sustained the objection,

rejecting Dillon s claim that Srikureja had a conflict of interest in asserting the

objection. The court erred in allowing Srikureja the alleged perpetrator of the

abuseto assert the privilege to prevent Dr. Kanofsky from testifying. Conflict of

interest aside, California Family Code 3083 allows either custodial parent to

waive the childs privilege. In effect, the court allowed a privilege of the little girl

to be highjacked by her abuser and used for his benefit.

113. Besides excluding Dr. Kanofsky from testifying, Comm. Wilson

ignored letters from Dr. Sheffner in January and March 2012 informing her that

A. D. had consistently disclosed physical, sexual, and emotional abuse. She

asked rhetorically from the bench, What am I going to do with these letters?

This was the Courts expert and a mandated reporter. Yet, she did not compel the

Courts own expert to appear and testify on the issue of sexual abuse when he

could offer relevant evidence on the topic.

114. It did not come as any surprise that Comm. Wilson found there was

insufficient evidence to substantiate that A.D. was abused. The commissioner

then took a very dramatic step, a step which violated A.D.s right to ongoing and

frequent contact with her mother, and deliberately retained A.D. in a zone of

danger and expanded it. Comm. Wilson did not just decline to suspend

Srikurejas visitation, it granted him sole physical custody pending trial. The court

gave no reasons for this action other than finding the evidence of the abuse


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allegations insufficient, having herself seen to it that she would not hear from two

mandated reporters on the issue, Dr. Kanofsky and Dr. Sheffner. The

commissioner did not address Srikurejas claim that Dillon coached A.D. but still

changed custody to the father. The commissioner did order therapy for A.D.

115. When he learned that Dillons custody was reduced at the February

24, 2012 hearing Dr. Sheffner wrote the court recommending custody be switched

back to Dillon. In his letter dated March 9, 2012, to the court, Dr. Sheffner

quoted A.D.:

[A.D.] related 1)essentially the same statements regarding her father'sinappropriate behavior as she had related to me before; and 2)shedenied being coached ... and stated that the only adult who told hernot to tell the truth had been her father.... [A.D.] displayed a verystrong express desire, accompanied by distrust, to be reunited in hermother's primary custody (this distress being to the point where,as we discuss matters, she stated she wanted to speak to thejudge)." emphasis added.

116. To no avail. The letter was ignored and so was A.D. By this time it

was becoming apparent that unless the expert or witness was on board with Team

Srikureja, he or she would be ignored, glossed over, or humored even if court

appointed. Marginalization of court appointed professionals even judges --

when they stand up for the child proves the deeply institutionalized and

entrenched patriarchal axioms applied to child custody cases throughout the

state courts.

117. On March 16, 2012, the court granted Srikureja s request to appoint

Minors counsel for A.D. DeArmey insisted that LaFlamme be appointed. The

Court agreed and appointed LaFlamme as A.D.s attorney. LaFlammes

appointment spelled the deathknell to A.D.s constitutional, human, and civil

rights as an abused child.

118. The conspiracy was sealed with the appointment of LaFlamme.

Neither LaFlamme nor DeArmey disclosed that DeArmey had represented

LaFlamme as his personal attorney in a private matter eight months prior. The


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triumvirate of DeArmey, LaFlamme, and Stokke with Stokkes inside pipeline to

Rackauckas with huge amounts of money exchanging hands, including from the

public fisc to LaFlamme, guaranteed that the fix was in. A.D. did not have a

chance.

119. On June 4, 2012, Dr Sheffner wrote a letter to Judge Waltz, who had

replaced Commissioner Wilson following the February 2012 hearing, stating:

I am extremely concerned as to this child's welfare and my view isshe has experienced emotional deterioration since I first consultedwith a cheerful and vivacious girl I saw the spring... I fear for thischild and appealing to her attorney and the court to take immediateaction to be sure [that she gets the] professional help she sodesperately needs.

120. On June 11, 2012, J. Waltz called an emergency hearing for all

parties. J. Waltz stated, Mr. LaFlamme, upon getting this letter from the 730

evaluator I immediately called this hearing, what did you do? LaFlamme replied,

I sent my investigator to the childs school and she ( A. D.) said she doesnt want

to live anymore.

121. On June 15, 2012, LaFlamme did select Dr. Thea Reinhart,

(Reinhart) a specialist in child sex abuse cases, as A.D.s therapist, of which

Dillon was unaware until later. But rather than provide therapy, LaFlamme wanted

Reinhart to indoctrinate her patient. It was his finding that A. D. was never

abused (how he knew this is not known) and Reinhart must treat A. D. to accept

this finding. LaFlamme expected brainwashing and gaslighting of the child, not

therapy. As therapy ensued Reinhart realized that A. D. was abused contrary to

LaFlammes insistence that none had occurred

122. On June, 21, 2012, Dillon filed a motion seeking modification of

custody. Dillon also requested that Dr. Sheffner be supplied CPS reports and

police records so that he could evaluate the allegations of physical, emotional and

sexual abuse. LaFlamme failed to provide Dr. Sheffner the childs CAST

interviews and police reports, although they were in LaFlammes possession. Dr.


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Sheffner had to have those records in order to comply with Fam.C. Sec.3118(a)

which states in part that

The order appointing a child custody evaluator or investigatorpursuant to this section shall provide that the evaluator or investigatorhave access to all juvenile court records pertaining to the child who isthe subject of the evaluation, investigation, or assessment.

123. LaFlamme was doing everything to sabotage the custody evaluation

because it was clear that Dr. Sheffner was standing on adherence to the law and

protocol, and meeting his ethical obligations. He too had to be marginalized, if

not knocked out completely.

124. In July 2012, DeArmey requested that Dillons visitation be

monitored at all times just so LaFlamme could control A.D. and her disclosures. It

also allowed LaFlamme to hire a visitation monitor company which would do his

bidding. Dr. Kanofskys testimony having been barred, Dr. Sheffners letters and

recommendations and A.D.s repeated disclosures ignored, LaFlamme

assertedwithout support or explanationthat he believed there [was] every

possibility that [ Dillon ] was coaching the child.

125. J. Waltz granted DeArmeys request and ordered that Dillons

visitation be monitored solely on LaFlammes false and unsubstantiated allegation

of coaching, one of the two favorite mantras, besides alienator used by

abusive fathers, their attorneys, minors counsel, custody evaluators (Dr. Sheffner

an unusual exception), social workers, and judges throughout California against

female protective parents.

126. To summarize:

* Dillon was the primary caretaker and sole custodian of A.D. from her

birth in 2004 to age 6, when in November 2010 Srikureja sought

custody and Dillon was misled into stipulating to 50/50 physical

custody. After her father had A.D. fifty percent of the time, A.D.

began to allege sex abuse by her father.


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* In February 2011 ER physician finds 3 fissues in A.D.s anus

after A.D reported a bloody rectum and her mother saw blood on

the toilet seat after A.D. had used the toilet. CPS finds allegation

unfounded.

* In March 2011 Dr. Sheffner, a psychiatrist, is appointed as custody

evaluator.

* In August 2011, Dr. Sheffner recommends that Dillon have primary

custody. He is not certain about sex abuse allegations.

* In January 2012, A.D. reports abuse and CPS thinks it might be

because of custody battle.

* In January 2012, Dr. Kanofsky examines A.D., concludes she is

victim of sexual abuse and Srikureja should be placed in

supervised visitation.

* In January 2012, Comm. Wilson will not allow Dr. Kanofsky to

testify. But the commissioner wants to hear from Munoz, a social

worker, and Breeze, a Tustin police officer, both unqualified to

determine whether there was physical evidence consistent with sexual

abuse. On the basis of excluding the only medical testimony

available for that hearing and listening to the two unqualified

government employees, the commissioner gives sole physical

custody to the accused, the father.

* In March 2012, DeArmey conspires with LaFlamme to get him

appointed as minors counsel and J. Waltz goes along with it.

* In July 2012, LaFlamme insists that Dillon is coaching A.D. and

that she be placed in supervised visitation. J. Waltz gladly goes

along with his unsupported allegation and places Dillon in supervised

visitation.

127. Thus, a mom who had sole custody of a child from her birth to age 6


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lost custody and was placed in supervised visitation within a year and a half after

the father filed a motion for custody only because medical doctors reported that

her daughter was being sexually abused. The likelihood of A.D. suffering grave

emotional harm due to maternal deprivation was obvious.

128. As alleged supra, LaFlamme had to have complete control of A.D.

and Dillon, besides manipulating the outcome in court with the judges as willing

participants. DeArmey having obtained the order of supervised visitation, La

Flamme personally selected Nash & Associates to monitor the visits between

Dillon and A.D. on or about July 20, 2012.

129. Despite this measure to eliminate Dillons alleged coaching, A.D.s

reports of abuse continued. On August 23, 2012, Dillon took A.D. to swim with

Dillons friend Tanya Garrett, and Garretts daughter. Stewart, LaFlammes

handpicked monitor, was present as well.

130. Outside of Dillon s presence, A.D. asked Garrett if she could tell

Garrett a secret, because her therapist said [she] needed to talk to a friend about

what is happening to [her]. A.D. then told Garrett, [w]hen I . . . see my dad I get

scared because he touches me on the inside and it hurts me. Garrett told A.D. to

repeat this statement to both Dillon and the monitor, and Dillon immediately

brought A.D. to the police station. CPS opened another investigation.

131. Stewart called Nash who said to end the visit immediately and return

A.D. to her father in violation of her mandated reporting duties under the Penal

Code. Neither Stewart nor Nash made a mandated report. Dillon contacted

Newport Beach Police and an officer advised Dillon not to allow A.D. to be taken

to Srikureja and to bring her to Tustin Police Dept. immediately. Stewart

accompanied Dillon and A.D. to the Tustin Police Dept.

132. At the Police Department, Officer Mitchell interviewed Stewart,

Dillon, A.D., and Dillons driver, Michael Cooper. Stewart claimed that A.D. told

her in the lobby of the police department that A.D. has a secret phone to call her


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mother, and her mother coached her to make the allegation. CPS jumped on the

secret phone coaching by Dillon to use against A.D. It was a silly allegation,

bordering on the absurd since by this time, A.D., was now in the complete control

of Srikureja, Coleman, and Lockmer, the nanny, who were all watching A.D. like a

hawk. Coleman was grilling her on a regular basis. LaFlamme was orchestrating

the debacle.

133. Tustin Police Officer Singleton called in the referral to the child

Abuse Registery. Eitner was the emergency response social worker. Officer

Singleton stated to Eitner that Srikureja had been touching A.D. with his hands

and fingers inside her private body parts and that she had seen the father's penis.

A.D. stated she had to sleep in her father's bed at which time he touched her

inappropriately and that she was forced to make videotapes. Officer Singleton

also said that it would be reported the father takes close-up photographs of her

body parts. Singleton also stated that Lockmer the nanny did not feed her enough

food. The officer stated A.D. is quite obviously intelligent and articulate and he

found her to be credible in her account and report of abuse by her father.

134. Eitner interviewed AD at police station at approx 11:30 pm after A.D.

had been sitting in the lobby of the Tustin Police Dept for almost eight hours.

Eitner described A.D. in her report as appearing to be awake and alert" knowing

full well she had to be awaken to conduct this interview.

135. During the interview AD reported physical and sexual abuse but

Eitner contacted the on-call supervisor Palmquist for consultation. Eitner told

Palmquist she had concerns about the child's credibility and the mother's

evasiveness, and the fact that the mother lost custody even though the loss of

custody was due to falsified testimony of Munoz and Breeze and the commissioner

barring Kanofsky from testifying.

136. Eitner cited concerns that the court did not follow Dr Sheffner's

recommendation that A.D. be placed back with her mother. Eitner also cited a


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concern about the child not being returned to her mother, but then refused to

conduct an investigation, or at least speak to Dr Sheffner. Inexplicably, Eitner

stated that she did not feel comfortable taking A.D. into protective custody and

Palmquist concurred. Certainly, Eitner and Palmquist would have incurred the

wrath of an angry LaFlamme or possibly even Rackauckas if they had done so.

137. At this point Lt Tarpley stepped in and voiced his concerns that A.D.

had disclosed sexual abuse by her father to the social worker, his officer, and his

detective and vested his authority to take AD into protective custody without the

concurrence of the social workers(called a parachute).

138. On August 23, 2012, Tustin Police Department took A. D. into

protective custody. Officers filed a probable cause affidavit stating the reasons

why A. D. was in danger in Srikurejas custody. LaFlamme did not speak to the

detectives nor did he visit A. D. while she was at Orangewood, the Orange

County juvenile facility.

139. Despite A.D.s disclosures and the police departments conclusion

she was being abused by Srikureja Naganuma shockingly unfounded allegations

of sexual abuse. "The child has made statements alleging sexual abuse by her

father however the child has been found to be less than credible throughout the

investigation" This was a question begging, bootstrapping conclusion because

besides Srikureja, DeArmey, Stokke, and LaFlamme, the only other individuals

finding the child less than credible were the social workers following

LaFlammes lead and their custom and practice of unfounding allegations of

sexual abuse in child custody cases (where most child sexual abuse cases originate

since most children who suffer sexual abuse know their perpetrators). The

practice endures even in the face of the childs repeated disclosures with the

mother in supervised visitation and unable to coach.

140. DeArmey did his part in poisoning the well at CPS if it could be said

it needed poisoning. Naganuma's investigative report states in part:


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... on August 24, 2012 intake Senior social worker MaureenNaganuma received a telephone call from attorney Milo DeArmey...He stated there of already been 2 cast interviews on this child.. Hestated that a social worker believed that the mother coached the childinto making the allegations... He stated that the child has been takento six or seven different police departments making allegations.. Hestated that the child has an attorney with Harold LaFlamme's officeand Shirley is the investigator.

141. The only true statement DeArmey made to Naganuma was that

LaFlamme was A.D.s attorney (of sorts) and Shirley was LaFlammes

investigator. The truth is that A.D. had only been taken to one police department

which was Tustin. No social worker to date had ever stated that the mother

coached the child although bordering on it.

142. On August 24, 2012, Naganuma received a call from Sanchez.

Sanchez stated that the child has already had two CAST interviews. She stated

that the mother was found to have lied and to have coached the child. At that

point DeArmey, LaFlamme, and Sanchez had no evidence that Dillon had

coached A.D. or had lied.

143. On August 24, 2012, Naganuma contacted DeArmey. DeArmey

defamed Dillon stating that she had visits at FACES, a visitation monitoring

agency, but was kicked out which was false. He said the appointed monitor Hector

Delgadillo quit because Dillon was not complying with the exchanges. Delgadillo

tries to extort mothers forced into supervised visitation for money. He does not

follow the law by taking notes during the visits and making contemporaneous

reports, thereby allowing him to falsify reports depending on what the

unmonitored parent, the social worker, or someone like LaFlamme wants him to

report.

144. Delgadillo had extorted Dillon for $540 to monitor a ten minute

exchange whereby A.D. walked from one car to the other. He quit only when

Dillon demanded a receipt documenting this outrageous payment to him.

145. DeArmey also falsely informed Naganuma that a doctor's notes stated


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the child was stressed from being coached. He indicated that Srikurejas criminal

defense attorney is Al Stokke and that Stokke instructed Srikureja, not to talk to

anyone. However, Srikureja was in a civil proceeding. If he chose to take the

Fifth it could be used against him as evidence of his guilt. Yet, Srikureja was

accorded all of his rights as if he were in criminal court being prosecuted;

whereas, Dillon and A.D. were stripped of every possible constitutional and

statutory right guaranteed in the family code and in federal law.

146. On August 27,2012 Naganuma received an email from DeArmey in

which he writes "the purpose of this letter is to provide you with facts and identify

documentation to assist you with your investigation into the allegations made by

[A.D.] on August 23, 2012. Naganuma apparently was impressed by the

information in DeArmeys unsolicited letter because she repeatedly

unfounded A.D.s repeated disclosures of sexual abuse. The letter was filled

with factual inconsistencies, lies, and libel of Dillon.

147. Naganuma also did not have a problem with DeArmeys credibility

despite the fact that he was the attorney for the man A.D. was accusing of sexually

abusing her. Naganuma took no action to protect A.D. despite the mounting

evidence of Srikurejas sexual abuse of A.D.

148. On August 31, 2012, Eitner interviewed Carol Stewart the monitor.

Stewart confirmed the child disclosed allegations of sexual abuse by her father

during a monitored visit with her mother on August 23, 2012. She stated A.D. was

not alone with her mother anytime during the day at this visit or during the three

previous visits she monitored. She stated she was not aware of any coaching

occurring between the mother and the child on this day or previous days. Stewart

stated A.D. said, "when he touches me in my private parts, he puts his fingers in

me". Stewart said she believed that what A.D. was saying at that time was true.

149. Stewart also admitted that she called her employer Nash who told her

to end the visit and return A.D. to her nanny Lockmer. This in violation of the


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Penal Code which requires that mandated reporters make a call to CPS Hotline.

150. After interviewing all the parties, Tustin Police Dept placed A.D. in

protective custody at Orangewood Juvenile Detention. On August 24, 2012,

Eitner conducted another CAST interview and unfounded the allegation despite

having the police report indicating that A.D. was credible. One of the reasons for

unfounding the allegation of A.D. was the secret phone allegation of Stewart.

151. On or about August 25, 2012, Dillon provided Eitner text messages

Srikureja sent Dillon in 2009 or 2010 in which he stated that there was nothing

wrong with A.D. having sex. She will probably be having sex by the time she was

seven years old. Srikureja also accused Dillon of having sex orgies at her house.

Dillon both faxed and emailed them to Eitner. Eitner denied receiving the text

messages besides unfounding A.D.s report of sexual abuse.

152. On August 27, 2012, CPS conducted another CAST interview with

A.D. A. D. told the interviewer that Srikureja had previously put his fingers

inside her rectum, and that Srikureja had been touching her for as long as she can

remember. CPS grabbed at straws to deem A.D.s claims inconclusive such as

whether Srikureja provided A.D. sufficient food or toys. In accordance with its

long-time pattern and practice, of never finding sex abuse when it originates in a

first amended complaint dillon v laflamme

Documents