Motion for declaratory relief and compliance

[Marina]

.

http://waysandmeans.house.gov/hearings. ... ew&id=6197

Statement of Roma O. Amor, Tucson, Arizona

IN THE SUPREME COURT OF THE STATE OF ARIZONA

Roma O. Amor, petitioner appearing as herself

ARIZONA DEPARTMENT OF ECONOMIC SECURITY (ADES) & ITS DIVISION OF CHILDREN YOUTH AND FAMILIES (DCYF) - CHILD PROTECTION SERVICES (CPS), Parties in Interest

MOTION FOR DECLARATORY RELIEF AND COMPLIANCE

Now comes Roma O. Amor seeking Declaratory Relief for Positive Enforcement to address the issues of the greater public interest of the Constitutional, federal statutory, and Federally-Protected Rights of families and their children who reside in the State of Arizona. Petitioner seeks relief against unconstitutional policies of ADES and CPS that violate Federal Child Welfare Funding Law (Federal Contracts). CPS has adopted an increasingly unbridled pattern of disregard for the law and its methods of intrusion into the private and family affairs resulting in unnecessary child fatalities and abuse while in ADES custody or under investigation by CPS Agents.

1. Jurisdiction is conferred by AZ Rule of Civil Proc. 57, AZ Rule of the Supreme Court 28(G), Arizona Constitution Article 6 Section 5

2. Venue is found in this court for State of Arizona policies and actions under color of state law of its CPS agency, its Office of the Attorney General, and the Juvenile Courts of its subdivisions.

3. Questions Raised:

a) Whether current child welfare laws of The State of Arizona are unlawful, illegal, and unconstitutional under Federal Statutory Child Welfare Funding Law (Federal Contract Law) and the First, Fourth, Fifth, Eighth, Thirteenth, and Fourteenth Amendments to the United States Constitution.

Arizona child welfare laws violate Federal Contract Law under the United States Constitution Article I Sec. 8 cl. 1 Spending Clause which gives the U.S. Congress power to place conditions on federal funding grants. Spending Clause legislation is a contract; in return for federal funds, the recipients (State of Arizona) agree to comply with federally imposed conditions.

See: Davis v. Monroe County Bd. of Ed. 526 U. S. 629, 640 (1999), Pennhurst State School and Hospital v. Halderman 451 U. S. 1, 17 (1981); see also Davis, supra, at 640; Gebser v. Lago Vista Independent School Dist. 524 U. S. 274, 286 (1998); Guardians Assn. v. Civil Serv. Community of New York City 463 U. S. 582, 599 (1983) (opinion of White, J.); id., at 632-633 (Marshall, J., dissenting); Lau v. Nichols 414 U. S. 563, 568-569 (1974).

4. Supporting Statements and Standards of Law Incorporated Herein:

a) ARS 41-1962 “Federal law shall control.”

b) Detention/Removal Hearings, Federal Statutory Law, examples

- CFR Sec 1356.21(d) Documentation of Judicial Determinations (2) Neither affidavits nor nunc pro tunc orders will be accepted as verification documentation in support of reasonable efforts and contrary to the welfare judicial determinations. (3) Court orders that reference State law to substantiate judicial determinations are NOT acceptable, even if State law provides that a removal must be based on a judicial determination that remaining in the home would be contrary to the child’s welfare or that removal can only be ordered after reasonable efforts have been made.

If finding is not explicitly documented, Title IV-E funding is severed under federal law. 45 CFR 1356.21(c)

- 42 USC 672(a)(1) Court must make the finding that “continuance in the home of the parent or legal guardian would be contrary to the child’s welfare.” and “removal from the home was the result of a explicit judicial determination and that reasonable efforts have been made”.

This finding must be made at the time of the first court ruling authorizing removal of the child from the home or lose all Title IV-E federal funding. 45 CFR 1356.21(c)

- 42 USC 672(a)(2) Court must make finding that “placement and care are the responsibility of the State agency or any other public agency with whom the responsible state agency has an agreement.”

No federal funding until findings are made 45 CFR 1356.71(d)(1)(iii)

- 42 USC 671(a)(15), 42 USC 672(a)(1), and 45 CFR 1356.21(b)(1) Court must make the finding that “reasonable efforts have been made to prevent or eliminate need for removal.” Mandates Prevention to Prevent Removal

If explicit finding are not documented Title IV-E funding will be withdrawn. 45 CFR 1356.21(b)(1)(ii)

- PL 96-272 Judicial determinations are required to be explicit and so stated in the court order. The Senate Report on the bill that became Public Law 96-272 characterized the required judicial determinations as “important safeguard(s) against inappropriate agency action and made clear that such requirements were not to become “a mere pro forma exercise in paper shuffling to obtain Federal Funding.” (S. Rept. No. 336, 96th Congress, 2d Session. 16, 1980) “We concluded, based on our review of States’ documentation of judicial determinations over the past years that, in many instances, these important safeguards had become precisely what congress was concerned that they not become.”

c) State statutes and regulations cannot be construed to displace the protections of the United States Constitution, even when the state acts to protect the welfare of children. Cf. Lorillard Tobacco Co v. Reilly 533 U.S. 525, 540-41, 121 S.Ct. 2404, 2414 (2001)

d) “State courts can decide definitively only questions of state law that are not subject to overriding federal law.” Leiter Minerals Inc. v. United States 352 US 220 (CERT No 26, 1957)

e) “Public policy is better served by imposing a duty in such circumstances to help prevent future harm.” Gibson v. Kasey (AZ Supreme Court, No CV-06-0100-PR, 2006; AZ Ct App Div 1 No 1 CA-CV 05-0119) (En banc)

f) ARS 25-408(H)(I) Judicial acts and the court must adhere to previous agreed custody agreements

g) ARS 25-403 and 25-403.03 domestic violence and family law

h) Child abuse proceedings involve the government acting in an adversarial role toward the custodial parent, an entirely different circumstance and procedure than divorce proceedings where there is no governmental accusation of fault. “Persons faced with possible forced dissolution of their custodial rights have a more critical need for procedural protections than do those in ongoing family affairs.” Santosky 455 U.S. at 753

In Brittain v. Hansen, the 9th Cir. Court discussed the greater custodial liberty interest and procedural differences of child abuse and custody cases, and concluded that “by failing to recognize the lesser liberty interest in visitation Id. at 992 the court applied the erroneous legal standard “best interests of the child,” quoting Reno v. Flores, 507 U.S. 292, 303-04 (1993) and held the “best interest of the child” legal standard applies to custody law not child abuse proceedings”

“Custodial parents have a greater liberty interest than those with visitation rights.” Brittain v Hansen, 451 F.3d 982, 991, 992 (9th Cir. 2006), quoting Weller v Dep’t of Social Svcs, 901 f2d 387, 394 (4th Cir. 1990), Zakrzewski v Fox, 87 F.3d 1011, 1013-14 (8th Cir. 1996), Wise v. Bravo, 666 F.2d 1328, 1332-33 (10th Cir. 1981); “A non-custodial parent lacks prudential standing to bring Establishment Clause challenge based on his relationship with his child.” Brittain, quoting Elk Grove Unified School Dist v. Newdow, 542 US 1, 13-18 (2004); “Liberty interests of parents with only visitation rights does not give rise to a constitutional violation” Brittain, (9th Cir.) quoting Wise (10th Cir. 1981)

i) “Substantive Due Process rights are those which involve greater liberties, as those guaranteed by the First Amendment”. Glucksburg 512 U.S. at 721-22

Anthony v. City of New York 339 F.3d 129, 139 (2nd Cir 2003) “(1) whether any policy makers of the municipality knew that it’s employees will confront or encounter a given situation,; (2) that the situation either presents the employees with a difficult choices of this sort and that training or supervision will make less difficult or that there is a history of the employees mishandling the situation; and (3) that the wrong choice by employees will frequently cause the deprivation of a Person’s Constitutional rights.” See also: King v Atiyeh, Monell v New York City Dept of Social Services

Planned Parenthood of Southeastern Pa. v. Casey, 505 US 833, 901 (1992), quoting Miller v. Johnson, 515 US _ (1995) "Legislative purpose to accomplish a constitutionally forbidden result may be found when that purpose was the predominant factor motivating the legislature's decision.", Shaw v. Hunt 517 US _ (1996), Joseph P. Mazurek, AG of Montana v. James H. Armstrong et al (Cert. 9th Cir Ct App, No 96-1104, 1997)

5. ARS 8-821 standard of proof for temporary custody is unconstitutional under the USSC “Matthews Test” addressed by the AZ Supreme Court in Kent K. and Sherry K. ARS 8-821 provides for taking into temporary custody under the “reasonable grounds” standard, similarly vague to suspicion or probable cause. A parent’s interests at this stage are paramount; the interest of the government is to reunite the child with the custodial parent. This error of lowered standard of proof, “reasonable grounds,” at the early stage of proceedings stacks the deck against custodial parents’ greater interest in their child and familial association. Matthews v. Eldridge and Kent K and Sherry K set the minimum standard at “preponderance of evidence”. The goals at this stage are prevention and reunification not termination which does not enter the equation until 12 – 18 months later. Until the first 18 months pass, a real reunification effort with the custodial parent is mandated by federal statutory law (contract law). By giving the adverse party the greater interest and lowering the standard of proof thus increasing the risk of error, a parent’s case will be lost at the first stage of proceedings, a deprivation of substantive due process to protect the greater interests of the parent. There must be a concrete offer of due process afforded to the parent with the greater liberty interest in adversarial proceedings, not the current level of rubber-stamping and paper-shuffling to meet federal funding guidelines. These are families. Santosky 455 U.S. at 753 (holding child abuse proceedings involve the government acting in an adversarial role toward the custodial parent, and such “persons faced with possible forced dissolution of their custodial rights have a more critical need for procedural protections.”)

In Re KG, SG, and TG (9th Cir. 2004), reaffirming the decision of the U.S.S.C., “This court has noted that the permanent termination of parental rights has been described as the family law equivalent of the death penalty. Consequently, parents must be afforded every procedural and substantive protection the law allows.”

6. ARS 8-824(F) is unconstitutional; the Standard of Proof is limited to “probable cause to believe that continued temporary custody is clearly necessary.” In applying this standard of proof, the court will make an erroneous determination of unfitness without offer of proof (common in juvenile court) and substantive and procedural due process of law which will lead to loss of the parent’s right to familial association, and in affect, terminated rights to custody. Kent K and Sherry K, quoting Santosky (holding erroneous determination of unfitness at this stage could lead to permanently extinguishing the relationship between a fit parent and her child).

7. The State of Arizona encouraged and instituted into state law a vague and easily misconstrued policy of mental illness as reason for removal of a child as well as for termination of parental rights. ARS 8-533(B)(3) and ARS 8-846(1)(b) “A State shall not be immune under the Eleventh Amendment to the Constitution of the United States for violation of a federally protected right…remedies (both at law and in equity) are available.” Title 42 Chap. 126 Sec 12202 and Title 42 Chap. 21 Subchapter V 2000d-7, and Title 28 CFR, PART 35 Nondiscrimination on Basis of Disability, State and Local Government Services

Title II of the ADA, "No qualified individual with a disability shall, by reason of such disability, be excluded from participation in or be denied the benefits of the services or programs of a public entity [reasonable efforts to prevent removal and reunification programs of CPS], or be subjected to discrimination by any such entity." 42 USC 12132 A "public entity" is defined as "(A) any State or local government; or (B) any department, agency, special purpose district, or other instrumentality of a State or States or local government." 42 USC 12131

“Where a statute authorizes conduct that is ‘patently violative of fundamental constitutional principles,’ reliance on the statute does not immunize the official's conduct”. Grossman 33 F3d at 1209 See also: Meyers v. Contra Costa County Dept. Soc Svcs 812 F2d 1154, 1157, 1158 (9th Cir. 1987) and Miller v Gammie (No 01-1549, DC No CV-99-00275-HDM PHA, 9th CirCtApp. 2003)

8. Another usage of the wrong standard of law that needing addressed, is the “best interests of the child” standard in adversarial child abuse cases which invoke greater liberties and constitutional protections for familial association. “Best interests of the child” standard is erroneous in child abuse proceedings. Only when proceedings reach the permanency stage, specifically the disposition stage, does the balance of interests shift away from the custodial parent. Matthews

9. Much of A.R.S. Title 8 is unconstitutional and in violation of overriding federal law; for brevity petitioner provided examples. Vague policies, statutes, laws, or the encouragement thereof that violate Federal Child Welfare Funding Laws, constitutionally and federally-protected rights must be examined. Families have the right to be free from unbridled State intrusion into their private family life without afforded substantive and procedural due process of law. When a case of state custody is necessary, children and others in the custody of the state must be afforded the duty of care owed by the state and its agencies under the Fourteenth Amendment.

10. Federal laws of foster care and adoption, legislated by Congress with good intention, are routinely violated by the state. Rather than adhere to statutory preventative measures to provide assistance to keep families together, they many times remove children from their parents when less extreme measures should have been taken violating federal statutory law and the First, Fourth, and Fourteenth Amendments of the United States Constitution. Arizona ADES-DCYF-CPS often places children with abusive noncustodial parents or in abusive foster/shelter care. (State Created Danger)

11. State law and policies announced by Governor Napolitano encourage unlawful practices of use of these federal funds resulting in need for more monies as the number of children removed from their parents rise. Funds should be used to provide families assistance with food, shelter, furnishings, education, location to domestic violence shelters, state training of its agencies in recognizing common consequences of domestic violence on victims and their children, and other preventative measures to stabilize the family and prevent removal.

12. The most critical issue in The State is the additional large expenditures of monies to hire additional caseworkers, reportedly to handle the overflow of children, but the reality is that additional caseworkers coupled with current “take the child and run” policies encourage improper practices, erroneous and non-explicit findings of abuse, and has the beginnings of an enterprise whose practice is to break up the family. Hiring additional caseworkers creates more crisis and more child fatalities; more children are removed rather than focus on current cases; the state is not the parent and not able to provide the proper standard of care as is its duty, nor can it provide nurturing. If more monies need be spent, it should be appropriated to training current caseworkers in integrity and ethics characteristic to the social services Code of Ethics. Higher standards of care and duty to assist those in need are standards to which social workers should be held. It is time that the State of Arizona brings those ethics back into its ADES– DCYF Child Protection Services agency, perhaps with more experienced workers with families of their own who understand the value of the family.

13. AZDES CPS removes children on suspicion (substantive due process violations). Many children are then abused in state custody (six to ten times higher in state custody per NCCAA). Reasonable efforts must be made to preserve the First Amendment protection of familial association in Arizona. It is obvious that this petitioner, the Mays family, the Hill family, the Payne family and other families undisclosed to the public, the Governor’s office, the State of Arizona and its CPS agency, the Pima County Juvenile Court in the State of Arizona, the City of Tucson Police Department, and The People are aware that there are serious Constitutional policy/procedural deficiencies regarding the safety, care, and protection of children and their families in the State of Arizona under current CPS policies and procedures.

14. The announced policy statement by Governor Napolitano coupled with the seemingly endless supply of federal monies encourages wrongful state intrusion into the lives of families in Arizona and violates constitutional and federally-protected rights and federal law.

15. Pattern and Practice of State Created Danger

* Payne children, deceased 2007 (CPS - Domestic Violence)

* Emily Mays, deceased August 2005, (CPS)

* Dwight Hill, deceased November 2005, (CPS)

* D.R.A., Abused, October – November 2005 (CPS)

* Others unnamed to protect the families.

The State-Created Danger Doctrine See Penilla v. City of Huntington Park, 115 F.3d 707, 710 (9th Cir. 1997) “If affirmative conduct on the part of a state actor places a plaintiff in danger, and the officer acts in deliberate indifference to that plaintiff’s safety, a claim arises under §1983.”. Second, the official’s act did more than simply expose the plaintiff to a danger that already existed. See L.W. v. Grubbs, 974 F.2d 119, 121 (9th Cir. 1992); see also Dwares v. City of New York, 985 F.2d 94, 99 (2d Cir. 1993); Freeman v. Ferguson, 911 F.2d 52, 55 (8th Cir. 1990). Finally, the official acted with deliberate indifference to known or obvious dangers. See L.W. v. Grubbs, 92 F.3d 894, 900 (9th Cir. 1996) “The plaintiff must show that the state official participated in creating a dangerous condition, and acted with deliberate indifference to the known or obvious danger in subjecting the plaintiff to it.”

18 U.S.C 4 Misprision of Felony – parents report abuse of their innocent children in CPS custody and judicial, state, county, and other actors, with deliberate indifference to the constitutional rights of families and their children to a duty of care in state proceedings and custody (Fourteenth Amendment), do not act to interfere or stop the abuse, and even retaliate on the reporting parent by termination of rights, terminating visitation, or relinquishing custody of the child to prevent further reports of abuse at the hands of state agency policies and procedures upon these children. This is appalling and an outrage.

16. Petitioner’s case parallels the Mays and Hill cases in the period of time of injuries, the nature of the injuries, and deliberate indifference of the court, CPS, state-appointed attorneys, GALs, and assistant attorney generals acting as counsel for ADES to step up to the plate to provide the owed duty of care to protect children in state custody from further harm (death in the Mays, Payne, and Hill, other cases). The Payne case, this petitioners, and others demonstrate the deliberate indifference of CPS and juvenile courts toward domestic violence victims and their children and the need for change of the improper standard of “best interests of the child” in child abuse cases to protect the greater liberty interests of the custodial parent. It also demonstrates the complete unlawful disregard for “previous custody agreements”. ARS 25-408(H)(I)

17. This petitioner and other parents have contacted (2003-2007) Arizona Office of The Governor, Arizona House and Senate Members, and other public officials (State, City, AZBAR, AZ and Pima County Courts, and the like) who have the ability to make changes to inadequate or dangerous policy both before and after herein stated violations. They are all aware there is a problem with their own policies regarding the constitutional right of familial association and the Doctrine of State Created Danger and the duty of care afforded by the Fourteenth Amendment involving child protection and related policies.

Instead of positive changes to policies or even investigation into violations, policies were changed to further deny the Constitutional Right to due process and to strengthen policies that violate Constitutional rights in adversarial CPS cases.

18. Bill SB1430, initiated by Senator Johnson would have strengthened due process protections for First Amendment rights for CPS TPR cases, Arizona State Senate Committee on Family Services Minutes, dated February 13, 2006. Petitioner spoke at this Senate committee hearing. In June 2006 it was voted down due to Napolitano’s threat of veto. Napolitano has at the same time publicly stated that caseworkers are to “err on the side of the child”, affecting increased removals and TPR and creating policy at CPS that violates due process to families under the First and Fourteenth Amendments. "It seems like a lot of trouble for something that's going to get vetoed." Rep. Pete Hershberger, R-Tucson, said before the bill died on the House floor.

Napolitano’s threatened veto and changes to policy removed jury trials for CPS TPR cases is in violation of the 1st, 6th, 7th, and 14th Amendments guaranteeing the right to trial by jury and the right of confrontation in any criminal or government adversarial trial where the value in controversy exceeds 20 dollars (a child’s life and the right of familial association is invaluable).

The excuse was that “most jury trials resulted in TPR anyway”. This statement illustrates by admission the lack of procedural and substantive due process in Arizona juvenile courts, demonstrating the need for reform policies that implement the Constitutional Due Process of Law protections of the First, Fourth, Fifth, and Fourteenth Amendments of the United States Constitution, Arizona Constitution, Federal and Statutory law. See: Cf. Lorillard Tobacco Co v. Reilly 533 U.S. 525, 540-41, 121 S.Ct. 2404, 2414 (2001)

AZ State Representative Laura Knaperek, as well as child advocacy expert Richard Wexler, spoke out strongly condemning Governor Napolitano’s policy saying it will deeply hurt Arizona’s families, and it has.

19. The Governor’s policy implementation (threat of veto, lowered standards of proof, and removal of jury trials) is a deliberate and knowing error as ruled by the Arizona Supreme Court decision in Kent K. and Sherry K. v. Bobby M. and Leeh M. where the Court, applying Matthews and Santosky, held that, "The private interest affected is commanding; the risk of error from using a preponderance standard is substantial; and the countervailing governmental interest favoring that standard is comparatively slight. Because the preponderance of the evidence standard essentially allocates the risk of error equally between the parents and the state, due process requires a higher standard of proof than “preponderance of the evidence”.

20. This petitioner spoke at Governor Napolitano’s CPS Reform conference in 2003 on domestic violence and the need for CPS to protect Mothers and their children. The recent horrific cases of Tyler and Ariana Payne and another unnamed father who dated a CPS supervisor parallels this case and the problem of Domestic Violence and CPS policies of separating Mother her child in favor of the noncustodial batterer, thus inflicting the sins of the batterer on the children, as addressed in an injunction against NY Child Protection in Nicholson et al v Scoppetta et al and Williams et al where the Court concluded:

“The City may not penalize a mother by separating her from her children; nor may children be separated from the mother, in effect visiting upon them the sins of their mother’s batterer” (In re Nicholson, 181 F supp 2d 182, 188 [ED NY Jan. 20, 2002], Nicholson v Williams, 203 F Supp 2d 153 [ED NY Mar 18, 2002] [108-pg elaboration grounds injunction]). The Court found that ACS unnecessarily, routinely charged mothers with neglect and removed their children where the mothers were the victims of domestic violence; that ACS did so without ensuring that the mother had access to the services she needed, without a court order, and without returning these children promptly; that ACS caseworkers and managers lacked adequate training about domestic violence, and their practice was to separate mother and child when less extreme measures should have been taken. The District court cited the testimony of a manager that it was common practice in domestic violence cases for ACS to wait a few days before going to court after removing the child because “after a few days of the children being in foster care, the mother will agree to ACS’s conditions without the matter even going to court” 203 F Supp 2d at 170.

See also: Pathologizing the Victim, a common tactic used in family court to applaud the actions of the abuser while labeling the victim unstable.

21. Common sense and civil law state that when government or agency policies are in violation of Constitutional Rights or of Federal Law or Federally protected rights, state and local governments and their agencies that institute or encourage policies are directly liable for wrongs and injuries that result. Governor Napolitano and the State of Arizona’s policies and deliberate indifference has assumed responsibility for injuries instilled upon families such as those of my child and of Emily Mays and Dwight Hill (infants) and further cases such as the Payne case (involving prior domestic violence and CPS change of custody) which show the sufferings and irreparable injury of parents and their children as a result. Children are no safer in state custody than with parents, nor are they any safer with CPS involvement. Child abuse is an issue for the police, not a social agency.

22. The federal law on child abuse and neglect is found primarily in Title IV-B&E of the Social Security Act transfers monies from the Social Security Fund to The State. Approximately seventy-five percent of the funds in Arizona is federal money which is available only if the state meets eligibility requirements; these funds can be withdrawn if requirements are not met.

The history and sources of the Child Welfare funding are primarily found in: Federal Payments for Foster Care and Adoption Assistance 42 USC 670-679b; the 1974 Walter Mondale Child Abuse Prevention and Treatment Act, PL 93-247, 88 Stat. 4, 42 USC 5101-5107; and the Adoption Assistance and Child Welfare Act, PL 96-272, 94 Stat. 500, 42 USC 670-676 (and amending 620-628); 42 USC 107(b), 5106a(b)(1) Grants to States for child abuse and neglect prevention and treatment programs, as well as other sources such as the Interstate Compact on the Placement of Children (ICPC), a contract which provides financial incentives for interstate placement of foster children, reportedly to find permanence.

23. The State of Arizona is the governing body of AZDES-DCYF-CPS. The State collects Federal Funding, (42 USC 670-679b) (17 Trillion in 2004, U.S. total) from the United States Government in the form of Title IV (Parts B & E) funding, mandated to be used primarily for prevention and reunification purposes (42 USC 671). Title 42 Chapter 67: Child Abuse Prevention and Treatment and Adoption Reform also offers federal funding grants to CPS agencies through various eligibility programs such as fostering, adoptions, interstate placements, etc., as do other additional grants/receipts.

24. ADES receives federal funding through the state which then provides funding to domestic violence shelters and programs through its Community Services Administration (CSA) and collects information such as Name, Address, Age, Phone Number, Children’s Names and Ages, Income, Disability Status, and other personal information. ADES maintains its own private database on Mothers and children who receive domestic violence services. Recent events in the Payne case as well as this petitioner and others show a pattern of disregard for Mothers and their children who are victims of domestic violence.

25. The Supreme Court of the State of Arizona has power to issue declaratory relief in the form of Arizona State Congressional investigation into state records of specific practices of this agency such as the use of federal funding to meet federal eligibility requirements regarding prevention, inconsistencies in individual case documentation, nonexplicit rubber-stamped judicial findings, paper-shuffling to meet federal statutory law, foster provider licensing, state-contractor conflict-of-interests (fishing expeditions to build a case through forced services to justify unlawful removals post facto), and for examination or positive enforcement of federal law that overrides state law matter of child welfare.

26. This petitioner prays this AZ Supreme Court will honor Declaratory Positive Relief to address the problems in the Child “Protection” Services of the State of Arizona, such as amending state statutes and state policy to properly comply with overriding federal funding contract law.

Dated this 17th day of May, 2007

Signed in ink for the court

Roma O. Amor, Appearing as herself

SUBMISSION OF TESTIMONY FOR THE RECORD

ABOLISH CPS. Let police handle it!

COMMITTEE ON WAYS AND MEANS

SUBCOMMITTEE ON INCOME SECURITY AND FAMILY SUPPORT

CHILD WELFARE HEARING 5-15-07

Submitted for:

Roma O. Amor and Dante R. Amor (Rafe)

All Arizona families and for those children that suffer.

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