From the Desk of: BellasLawStudents,National Project, Innocent

for the innocent against CPS inequities,clearly undermine/todays Good American Families.

FIGHT FOR YOUR RIGHT,TODAY BEFORE YOU LOSE SUCH RIGHT TO PUT ON TIMELYFILE NOTICE, OF YOUR INTENT TO SUE CHILD PROTECTION SERVICES TODAY. 1-888-501-4882 Ext.2.

DISTRICT OF PENNSYLVANIA UNITED STATES DISTRICT COURT.

DOCKET NO. CP-45-DP-0000116-2010 FID45-FN-000082-2010

CIVIL ACTION COMPLAINT .Lawsuit shall be filed under, pursuant to the UNITED STATES CONSTITUTION, U.S.C. 42SECT.1983, for civil right related damage, to the plaintiff, and their children suffering per day in Pennsylvania CYS Care. Such violation, and injury shall be enumerated below, and serve such notices, upon per liable defendant, violating the children right, and the mother civil and constitutional right, by U.S.POSTAL CERTIFIED SIGNATURE MAIL, to effectuate such service, on behalf of the plaintiff. And or by Process Server, to insure such validity of the CYS defendants, has procure such lawsuit being filed against the agency, and its workers assign to such family case for which injury continue per day child is out of the loving home of such

plaintiffs, Lauren Ennis

and Darren Ennis.

Lauren Ennis and Darren Ennis, Injured Plaintiffs

V.

Children Youth Services herein; C.Y.S.

Such lawsuit is being filed in conjunction with: Pursuant to U.S.C. 42 Section (1983) claim for civil rightviolations, state/ federal as such jurisdiction has such right, to properly adjudicate in such matters where injury, caused by such STATE ACTS OR herein; employed by CYS as a government public employee, whose cause such federal civil right injury to child(ren)and ones parent, family, by the:

Unlawful Removal Under the fourth amendment of such wellestablished, amendment, encompass with the fourteenth of ones child without a legal basis to do so, when such are not at such staid risk, that would require such child to remain in state foster care while such parent has already participated in such services being provided, by state, in violation of ones U.S. Constitutional Right, and civil rights under the well established fourteenth amendment, while CYS REFUSING TO REUNITE CHILDREN WITH PARENT IN SUCH MANNER FOR WHICH CHILD WOULD BE SAFE,WELL TAKEN

CARE OF BY LAUREN ENNIS, LOVING MOTHER BEING VIOLATED BY SUCH AGENCY, EXERTING RIGHTFULLY SO SUCH WARRANTED LAWSUIT AGAINST ALL LIABLE PARTIES FOR SUCH INJURY.

SUCH DEFENDANTS HEREIN; CPS DEFENDANTS has not at any time made a reasonable effort, as required by PENNSYLVANIA LAW, to return their children, as such violation has continually and verifiablyascribed to, the children whose being force to remain with strangers, and since being removed at least 1 has suffered besides Psychological Extreme Traumatization but has suffer from a staid injury for which the state later tried to/cover it up/as shall be proven in due course.

Lawsuit For Money Damages in U.S. DISTRICT FED. CT. injuries include, but not limited to:

The continued misrepresentation of such facts in front of judge assigned to plaintiffs state family civil case pending, Simply to make It appear plaintiffs are a danger to their children. Defendants over at Children Youth Services herein; CYS continually per EACH Court Hearing have made the plaintiffs appear as if they are horrible parents, incapable of raising their own children into adulthood, yet they are a loving mother and father, for which has been fighting for the right to have such children HOME, as such CYS agency has consistently, Systematically methodically conspired per hearing to have them remain nonrelevant persons in the life of their children in violation of their childrens constitutional and civil right, as well as Lauren and Darrens fourteenth amendment right. Defendants in the aforesaid, and throughout such notice of intent to sue for money damages, and other significant relief, against the county, and its agency herein; CYS such defendants have continually lied falsified, evidence and or distortion of the truth involving the children do not want to go home to their own mom and/ or dad, and or see mother, in such violation of their rights and the childrens rights.

Plaintiffs have been suffering immensely as the children per day they remain forcibly apart, by the action inaction by CYS. Case law support fully, in cases involving OUR children for which are NOT being abused, as case law fully shall establish and support, in such a case nationally as here in Stroudsburg Pennsylvania per caseworker involvement with such a family that: REASONABLE Effort by such caseworker over at CYS; when it come to keeping ones family in tact, and under one roof. But in this case, the plaintiffs have suffered insurmountably as their children now forced apart courtesy of an agency who is clearly violating the parent(s) and childrens constitutional right by the:

Failure to Act involving reunification over almost a year now has not taken place, inviolation of the family right.

Failure To Even Consider, Lauren Ennis, hard working mother is NO THREAT to her children for which she loves and has taken care of, without serious injuries, and or abuse.

Failure to tell the TRUTH under OATH, and or in sworn in affidavit, altering records, falsifying, and or distorting the truth in a court of law, each hearing, tomake it appear the plaintiffs have not been compliant with services for which they shall prove without a shadow of a doubt such is false, being adage by the

Pennsylvania Children Youth Services, herein; the DEFENDANTS over at CYS. Failure to abide by the U.S. Constitution. DEFENDANTS REMAIN IN VIOLATION OF:

Of Article I Section 1: involving such Inherent Rights, of Mankind, as such children, are born EQUALLY, as man, and such equally free/independent, and have inherent, and indefeasible, RIGHTS. Rights, among for which are those to enjoy, and defend one's LIFE, LIBERTY, and of such acquiring, possessions and protecting such property, family, reputation, and of pursuing their own happiness.... DEFENDANTS at CYS, are in clear violation of such well established laws in Pennsylvania Relevant PA. Legal Provisions, and the STATE CONSTITUTION.

Federal Rights of the children, Lauren Ennis and Darren Ennis, continually are being violated by the named defendants, now being put on such required notice of their intention to sue.

Suing for the: Failure to abide by the Pennsylvania STATE constitutional/law(s)pertaining to the Familial Bond, with such child NATURAL primary caretakers, the parents and for biasly projecting such loving mother and father as UNFIT caretakers as shall be proven in such court of law, through plaintiff lawsuit, in the Federal Ct. IN VIOLATION OF 23 PA.C.S 6375,even the most inherent, general Child Protection Services, CYS policy, procedural, encompass with such act(s)involving and violations pertaining to willful misconduct, negligent to child who was INJURED in their purported" care" and supervision, but yet the state workers are ad aging, how "the children" are better off without their own loving parents? The plaintiff shall prove such inequities, taking place in state family court, by these listed defendants, Over at CYS, has caused them to be emotionally distressed, by such intentional infliction, and her child has suffer, by DEFENDANTS. Actions/Inactions for some time now, without ANY ending in nearsight, in violation of their constitutional right, as loving mother Lauren Ennis and loving father Darren Ennis, now bringing forth such warranted lawsuit.

DEFENDANTS DIRECTLY INVOLVED WITH SUCH VIOLATIONS UNDER THE 4TH AND 14TH AMENDMENT ARE AS FOLLOWS BUT NOT LIMITED TO:

1.Ms. Suzanne McCool, Responsible for such wrongful and unlawful seizure, under the fourth amendment of said children belonging to the loving mother the primary plaintiff now suing in Federal Court. 2.Ms. Theresa Merli - DEFENDANT- CASEWORKER ASSIGNED TO THE CASE OVER AT CYS, Failed to reunite mother and child for almost a year now, in violation of such fourteenth amendment right while under the COLOR OF LAW. 3.Jane Weidensaul - Defendant. 4.Children and Youth Services-Director _____________________________. 5. Children and Youth Services-Commissioner ____________________________.

6. Children and Youth Services-Office Mgr. _______________________________. All defendants shall be served accordingly, and within time allotted by law for bringing such warranted lawsuit for money damages, and other significant relief, each day child is to remain out of the home of such loving non-threatening, good loving mother herein; Mrs. Lauren Ennis injured plaintiff(s).

Such caseworkers knew and or shouldve reasonably known each day they are working on the Ennis family case such inaction taken, and the actions for which are exert by the aforesaid worker, assign to case, and the entire CYS dept should have known their actions are:

1Unlawful. 2Unconstitutional pertaining to such enumeration of suit. 3Unwarranted, involving the continue detention of child. 4Civil Right Violations of the minor(s) belonging to plaintiff. 5Plaintiffs Lauren Ennis and Darren Ennis civil rights, pertaining to their children have been completely ignored, hence such lawsuit now shall be file, In a timely manner per suffering of such staid injury being endure by such mother and father and their children for which are referred to as in such notice of plaintiffs intent to sue, and Federal U.S. District Ct. Suit we shall refer to the children as their initial due being minors, currently at such time lawsuit is filed in 2011. Plaintiffs and children of plaintiff shall file such lawsuit for: THE FAILURE TO PRESERVE SUCH FAMILY UNITY IN SUCH THE CHILDREN WERE UNLAWFULLY REMOVED/KEPT IN STATE FOSTER CARE, AND PLAINTIFFS WERE NOT GIVEN BACK THE RIGHT TO FIRST,ATTEMPT TO HAVE THEIR CHILDREN REMAIN IN THE HOME FOR WHICH THEY ARE RAISING THEIR CHILDREN IN VIOLATION OF THEIR UNITED STATES 14th amendment right.

Continued Detention of ones child when such parents have already established, they are clearly FIT as her family to raise such child. Wrongful Detention that has lead to the undermine of such children, whose been languishing in Pennsylvania Foster Care System, for some time, without an end in sight when such loving sweet children can be home with their loving mother and father, herein; Shall be referred to during such litigation suit pending as injured plaintiffs suing, E.N.DEFENDANTS DIRECTLY INVOLVE WITH SUCH FOURTH AMENDMENT/FOURTEENTH AMENDMENT VIOLATION, WHILE EMPLOYED BY CYS, AT THE TIME, AND UNDER THE COLOR OF LAW are :

SUZANNE MCCOOL, Responsible for such wrongful initial removal of such children, not warranted by such agency. THERESA MERLI CASEWORKER, DEFENDANT, AT CYS. JANET WEIDENSAUL DEFENDANT, AT CPS. Mailing Address for such defendant to be serve accordingly: 1 Quaker Plaza. Stroudsburg,Pennsylvania

Mother exerting such lawsuit, each day plaintiff(s) children are not returned:

Additional Defendants, Directly Liable for such injury to child:

Ms. Sherry Bradshaw. DEFENDANT. Caseworker CYS. Dawn Walker. DEFENDANT. Supervisor. CYS. Kate Kroll. Caseworker CYS.

SUCH DEFENDANT(S) ARE TO BE SUED IN THEIR OFFICIAL INDIVIDUAL and are being sued in their PERSONAL CapacityBy the children, and the injured adult plaintiffs, all are suing, within time allotted by law to exert such warranted lawsuit in Pennsylvania Federal United States District Court, in due course.

BRADSHAW FROM DAY ONE, HAS FAILED TO WORK TO SUSTAIN SUCH BOND, BETWEEN PARENT(S) AND CHILD UNDER ONE ROOF, IN VIOLATION OF THE CHILD CONSTITUTIONAL RIGHT AND THE PARENTS, NOW EXERTING SUCH LAWSUIT.

Sherry Bradshaw, Dawn Walker, and Kate Kroll defendants being sued, have slandered and clearly defamed plaintiff(s) loving good character to their children to the judge, UNDER OATH, under penalty of perjury, and or has furnish such report, written by Bradshaw, Walker and/ or Kroll as other JOHN DOES; Over at CYS in Stroudsburg, PA in clear violation of the parental rights, violated by CYS illegal and or unlawful, unconstitutional acts, for which such suit is now being served accordingly to EACH DEFENDANT, to be commence, of such lawsuit for money damages, in a timely manner.

ADDITIONAL DEFENDANTS:

MONROE COUNTY CHILDREN AND YOUTH SERVICESHEREIN; CYS.Ms. Adelaine Grace DEFENDANT DIRECTOR OF MONROE COUNTY CYS. Ms. Stacy Gill DEFENDANT OFFICE MANAGER OF MONROE COUNTY CYS.

MAILING ADDRESS: TO BE SERVED ACCORDINGLY:

730 PHILLIP STREET. STROUDSBURG, PA 18360

ADDITIONAL DEFENDANT(S) LISTED IN SUCH WARRANTED SUIT FOR DAMAGES:MONROE COUNTY COURT OF COMMON PLEAS 43RD JUDICIAL DISTRICT, LOCATED IN: STROUDSBURG, PENNSYLVANIA INCLUDED BY NOT AT ALL LIMITED TO SUCH DEFENDANTS, WHO ARE,AND OR WERE, AT SUCH TIME OF SUCH LAWSUIT FILE REFUSE TO RETURN CHILD BACK TO HER FIT,LOVING PARENT(S), HEREIN; LAUREN ENNIS

Summarily: On or about NOVEMBER 2010,CHILDREN WERE REMOVED FROM SUCH HOME OF LAURENENNIS AND DARREN ENNIS, LATER TO BE UNCONSTITUTIONALLY PLACED UNDER THE CARE, CUSTODY, CONTROL, SUPERVISION OF SUCH AGENCY, KNOWN AS MONROE COUNTY CHILDREN AND YOUTH SERVICES

Herein; CYS DEFENDANTS.THE CHILDREN WERE NOT GIVEN THE OPPORTUNITY TO REMAIN IN THE HOME WITH SUCH LOVING PARENTS, NOW BRINGING SUIT. CHILDREN HAVE SUFFERED, CONTINUALLY BEING INJURED EACH DAY THE CHILDREN ARE NOT ALLOWED, TO BE RETURNED HOME IN VIOLATION OF SUCH CHILDS FOURTEENTH AMENDMENT AND FOURTH AMENDMENT, FOR WHICH CHILDREN MOTHER, LAUREN ENNIS, AND FATHER DARREN ENNIS HAS ELECTED, IS NOW EXERCISING SUCH RIGHT

SUIT, WITHIN A TIMELY FASHION, AGAINST ALL LIABLE FOR CAUSING SUCH STAID INJURY TO THEIR CHILDREN.TO BRING

Not, at anytime has caseworkers followed mandate PRIOR to such elongated, through multiple hearings, and prior, has the assigned and or the initial caseworker, being sued made a mandate, legal, REASONABLE EFFORT to see to it the child is back with her mother, all of the children, to avoid such out of the home placement, for such a long time, going on a year now without ANY circumvent, but to say mother and father are a danger yet such plaintiff(s) shall prove the children were ONLY INJURED in the care ostensible supervision of the state caseworkers and agency.

Not at any time have DEFENDANTS CYS worked with mother to keep children in the home by making, such reasonable effort to properly assist in a timely manner, Mrs. Lauren Ennis and Darren Ennis, to help RID such reasoning that led to the children removal, in the first place, in violation of their civil and constitutional rights, through the prevention of removal services could have, and should have by such law and state CYS Mandate, should have been applied to such case, by the conscious and concerted, genuine effort by defendant CYS caseworker responsible for such case open against, LAUREN ENNIS and DARREN ENNIS.

Amount of Damages Sought:

$5,000.000.00 Five Million Dollars.

A multitude of state/federal, related inequities, taking place in state family court, for sometime, almost 1 full calendar year at time of such warranted NOTICE OF CLAIM of their intention to sue has been officially served, and their lawsuit; the loving mother, plaintiff and father bringing forth such lawsuit today Their once happy beloved, sweet well taken care of children, are being neglected, harmed, mistreated, in foster care, and not allowed to return home for which they would have been safe and cared for and loved by Lauren Ennis and/ or Darren Ennis. Children were not removed due to any type of as required by CYS: IMMINENCY on the part of LAUREN ENNIS, the mother, and DARREN ENNIS, father as child was NOT removed based on proven factual account of serious injuries nor any other type of imminent dangeraggravated circumstance but by such clear bias, and the constant irrational reasoning by such liable defendants being sued in the U.S. DISTRICT COURT in due course. Such prerequisites, for which are to encompass services per outline in case plan, giving to the injured plaintiffs, have been implemented, yet biasly, and clearly discriminative,

the DEFENDANTS over at CYS REFUSE to give back their children, as days go by, familial association, is violated per child involved, and the mother and father have been forthright, steadfast in their quest to have children return home, as such rights nevertheless continue to be violated,

hence this lawsuit shall now commence.STATE EMPLOYEES, WORKERS FOR CYS UTILIZE SUCH FAMILY COURT TIME AND THEIR RESOURCE, MONIES, TO SEE TO IT THEIR CHILDREN ARE NOT GIVEN BACK TO THEM, BY THE EXERTION OF FABRICATION AND OR THE ALTERATION OF RECORDS, TO MAKE IT APPEAR THEY ARE UNFIT PARENTS, HAVE CLEARLY DEFAMED PLAINTIFFS NAME AS PER COURT HEARING TAKING PLACE UP THROUGH THIS DAY IN STATE FAMILY COURT, IN VIOLATION OF PLAINTIFFS CONSTITUTIONAL RIGHT, FOR WHICH NOW ARE BEING SUED ACCORDINGLY. Children have, for each passing day, lived without loving mother and/ or father, by state workers over at CYS has FAILED to properly and timely return the children back to their loving parents primary care, has been, traumatized, inflicted by none other than Child Protection Services agency known as CYS.

Defendants continue to say it is of the parents fault their children are not home with them. But yet the evidence shall demonstrate, such loving parents have not harm their children and or have not at any time, put their children at such serious risk, for which the child will need to remain in state foster care, in violation of the parents, and the childrens constitutional right.

Plaintiff shall sue for additionally:Daily Causing plaintiff(s) intentional emotional distress; over the whereabouts, of their children and by not having the children yet home with them for which the children shall be loved, cared for, and safe. Suing for: The Unconstitutional Seizure of ones child under fourth amendment, related to CYS removal. Unjustifiable illegal unlawful unwarranted CONTINUED needless, removal causing such injury to the plaintiffs, and their children, the unjustifiable illegal unwarranted removal herein; the CYS DEFENDANTS. Such warranted, Notice of Claim is being served upon ALL defendants as Lawsuit shall be filed shortly, for the additional violation(s) enumerate below, including but not at all limited to: Conspiracy to deprive intentionally one of the right to parents children without ONGOING and or continual wrongful removal by CYS DEFENDANTS. Unethical Unprofessional Misconduct by all worker(s)named in suit, as others shall feasibly surface, the longer, children are NOT RETURNED.

Going outside the scope of CYS daily routine required statutory obligation by presenting false allegation(s) continual to the judge with manufacture evidence, to be provided to the court, to adjudicate over to see to it the children remain out of the care of their loving mother and loving father, and or to end up terminating their civil constitutional right to their own children, in violation of such right under the fourteenth amendment. Not looking out for the BEST interest of such children forced separate from mother and father or the children would have NOT been removed, and or would have return to loving parent(s) home by now, as we are into 2011 and yet NO unbiased treatment toward mother and father has been shown but yet continual deprivation under fourteenth amendment, violations, under COLOR OF LAW has been exhibited, and shall be proven when such lawsuit is filed in due course. Biascy Discrimination against such loving parent, in violation of the family exerting such lawsuit, civil and constitutional right. False Statements, by such defendant(s) in order to sabotage ones loving family.

Continue Deprivation of ones U.S. Constitutional right, PER child and adult.

Improper/Wrongful removal/continue removal under 4t amendment. Continual Deprivation of ones right under 14 amendment of the United States Constitution, and Pennsylvania State/Federal U.S. laws, for which apply to such warranted suit, now being filed.hth

Such accumulative violation(s) resulting in the staid injury of the children are, to encompass injury related to what has been enumerate in aforesaid, and below in such warranted Notice Of Plaintiffs Injured, Intention to sue, in violation, of the childrens fourth/fourteenth amendment right injury under the COLOR OF LAW, are to include the children remaining in foster care are listed as follows:

The children victims are also part of this notice of tort claim are: BRIANNA ENNIS D.O.B. DECEMBER 8, 2000 , age 9 at time

of the injured plaintiffs child(ren) removal. ABIGALE ENNIS D.O.B. MAY 26, 2003 , age 7 at time

of the injured plaintiffs child(ren) removal. DARREN ENNIS JR. D.O.B. APRIL 11, 2007 of the injured plaintiffs child(ren) removal. LENNA ENNIS D.O.B. JUNE 9, 2008 , age 2 at time , age 3 at time

of the injured plaintiffs child(ren) removal. SANDRA ENNIS D.O.B. JUNE 9, 2008 , age at time of

Such unwarranted/continual deprivation of ones right to familial association, and their parents.

Additional Violation(s)for such money damages, are to encompass, but not at all limited to beyond further information and such belief, defendants herein; DEFENDANTS at CYS shall be sued for:

Additionally suing for damage(s) but not limited to: Failure to Act by defendants, insofar as to keep child in the home and/or moving forward by offering of reasonable services, for which would have legally allowed by law such child to remain IN the loving secured, happy, caring home of the mother Mrs. Lauren Ennis and father Mr. Darren Ennis. Intentional and Negligent Infliction Of Emotional Distress; Parental Alienation. Fabrication. Damages to both parent/ child(ren) from suffering insurmountable pain due to the unlawful unconstitutional, abrupt and forced separation, by none other than defendants listed in herein;

Such reunification process has clearly not been visible, as requirewhen a child is being remove from such home and such caseworker, knew such mother and father is fully capable of raising their children but yet has FAILED to properly return children, in a timely manner to the parents, in violation of their constitutional rights.All defendants shall be served accordingly upon such proof that service is effectuated, such parties, shall respond to plaintiffs, and or such U.S. District Federal Lawsuit shall hence then follow, within time allowed to file in the Pennsylvania District Federal Court, against all liable parties, now being put on such required notice, of the injured plaintiffs children and the adult plaintiffs intention to sue for all that is fully detailed in such warranted notice, of ones intent to sue, based on such valid reasoning in the aforementioned, hence consider yourself served.

You have a great day now.

SIGNED: ___________________________, INJURED PLAINTIFF MOTHER DATED: ____________________________.

SIGNED: ___________________________, INJURED PLAINTIFF FATHER DATED: ____________________________.

Suing on behalf of the minors, currently residing in different foster homes, since their unwarranted and lengthy removal in violation of ones fourteenth and fourth amendment right by the UNITED STATES CONSTITUTION, Injured by such defendants. Who are refusing to release child back to its rightful parent hence causing such staid violation to the children and the parents to continually take place, hence such suit is now being filed against all liable defendants at CYS, responsible.

ALL IMPLEMENTED, IS THE FIRST PART OF YOUR LAWSUIT. Balance owed : 1,900 give or take, hence prepare to pay.

Now:

NOTICE OF YOUR INTENT TO SUE IS NOW IMPLEMENTED. CALL AS ALWAYS, TO LEAVE A MSG.AT MAIN NUMBER; IF NO ANSWER, LEAVE MSG.ON YOUR CONSENSUS AGAIN ON YOUR WORK BEING PERFORMED/DRAFT/PROSE LAWSUIT AND NOTICES, THANK YOU! AND GOD SPEED TO YOU MS. ENNIS, THROUGH THIS TRYING TIME.HANG IN THERE, AND THINK POSITIVE.

BALANCE OWED: 7hrs. unpaid(from last week of 9/1 ) but the 1,230 or so was receive, thank you, Has been credited naturally to such extensive work. New Balance as fully discussed as boss so nicely said you are able to pay towards on this Friday(NO LATER than noon) by WESTERN UNION ONLY .and or if your mailing a money order again it HAS TO BE MAILED in time to be reach on FRIDAY the 16th no later,thank you..) Again if your sending w.union that is fine, to be receive on Friday, or money order HAS to be sent then Thursday to be receive on Friday morning at building number 1050. Street Julia Street as such total this past week hours and since the 1st adding on to the work being perform and for your PROSE STATE custody CYS Case to properly assist you with such now are BOTH, as we have said we can do in between our own law school/and college/and business at Bellas Law National Advocate Ctr. we are up to 27 more hours By Friday be sure for all of the above, your needing done with state cys cases, and the up and coming full lawsuit (after the notice is served) we begin immediate and or 2 weeks or so, but make sure your making by Friday at least $ 1700 or so lil more,lil less, NOT under 1700 the boss said, understandably, so I can continue and be sure to right now TODAY Tue!

JUST CALL US leave msg. after your reviewing you and your children prose well written, artfully drafted prose actionable claim notice of tort injury claim draft, as we are officially DONE! In time for court as promise for wed.

Bye now.

www.SueCPS.org www.BELLASLAW.com ext. 2 heather marie, direct extension is 2. Good day now. As the right, to such child is paramount. Shall NO Longer;

Be ignored. Such right when violated in the American U.S. Court System shall hence, CEASE and be taken back when ones family is taking such required action to have such lawsuit filed in: THE UNITED STATES DISTRICT FED. CT.

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