IN THE UNITED STATES COURT OF APPEALS
FOR THE THIRD CIRCUIT
Case Number; NO. 19-3528
NO. 19-3745
___________________________________
Mary Bush, Individually and as Daughter,
Next Friend and Trustee of Genevieve Bush
Appellant
v.
JUDGE KATHERINE B. L. PLATT
Appellee
Amicus Curiae Brief to the Court
Kristine A. Smith on behalf of
“A parent's right to the companionship of his or her children are
so fundamental as to be guaranteed protection under the First,
Ninth, and Fourteenth Amendments of the United States
Constitution.” 324 A 2d 90; supra 129 NJ Super, at 489.
DISCLOSURE STATEMENT
Outdated policy and greed drive Family Courts in Pennsylvania to issue orders that separate families to generate maximum financial gain for the state of Pennsylvania. The same judges, attorneys, therapists, police, psychiatrists who profit from high-conflict divorces also use fraudulent guardianships to callously and in Mary Bush’s case purposely, alienate parents from their children for money.
My name is Kristine A. Smith, Judge Katherine B.L. Platt signed a sole custody order in my case which limits my contact with my children to “supervised physical custody” (attachment 1). I contacted Mary Bush after reading the article journalist Juliette Fairly wrote on the case of her mother Genevieve, who has been ordered institutionalized and medicated by Judge Katherine B.L. Platt. Juliette Fairly is a respected investigative financial reporter who is currently focusing her exposes on fraudulent guardianships and court-enabled racketeering. Juliette Fairly then wrote a story on my case and my concern with Katherine B.L. Platt’s restrictive order regarding visitation of my three children, and in support of my non-profit documentary Erasing Family and the pending PA HB 1397, Equality in Parenting, pending Pennsylvania legislation I support.
Mary Bush, like many adult children across the country have experienced retaliation when they speak out against institutional, court appointed and guardian engendered isolation, abuse, neglect and degradation that often come in the form of stay away orders, bans on visitation, cost prohibitive visitation and accusations and charges of contempt. Mary’s experience with Chester County Justice Center has caused me to see my own bans and prohibitions as a systemic injustice with a purpose and a profit. I have had to take increased measures to protect my security as more on my case is released to the public sphere, I have moved to a safe house. I am afraid of the retaliation of those I am exposing. I apologize in advance that I am not the perfect victim, but as one of the few victims left with a voice, I must speak up for Mary Bush and her mom Genevieve.
I, Kristine A. Smith, the former Vice President of Membership of the Downingtown East Moms Club in Chester County Pennsylvania. I am also a mother of three children, who after years of lack of marital intimacy and attempts at marriage therapy, asked my husband of over 10 years for a divorce. Within two weeks, my husband, his therapist, my family, and a psychiatrist who spoke with me briefly, had picked out medicine, mental illness institutions. My father Fred Smith, West Point Class of 1965, had hacked my computer, Ashley Madison, and social media accounts for information on me to turn over to my ex husband and his attorney.
I never dreamed that Family Court Corruption combined with the criminalization of “mental illness” would result in being drugged against my will, having my right to contact and have relationships with my three children taken away. Judge Katherine B.L. Platt signed a sole custody order in my case which limits my contact with my children to “supervised physical custody” (attachment 1). Judge Katherine Platt also signed for me to have court-ordered therapy. I satisfactorily completed the therapy, but later found out my attorney neglected her attempts to communicate my results.
Another order placed was that someone over 21 was to pick up my daughter off the bus. Instead they chose as caregiver a juvenile neighbor from the Downingtown Area School District. This juvenile told me she was diagnosed with aspergers, was in an emotional disturbed students class at school, about her previous suicide attempts, her family issues with older brothers on drugs stealing, and the multiple pyschotic medications she had taken. My three children for years told me that they did not want her to care for them, that they did not like her.
Even though my children were court-ordered to continue therapy, their therapy was immediately terminated after I was removed as mother. This was done by the Shelby Riley and Associates, and it caused great emotional distress. As every avenue of communication with my children was shut down, I felt betrayed that the therapist simply dismissed them.
I will attempt to expose how her Judge Katherine B.L. Platt signing my court order is wilful negligence, based on her participation in the May 24, 2007 Commission for Justice Initiatives in Pennsylvania Changing the Culture of Custody Committee Report and Recommendations (attachment 2). I have also been written about in Jamil Hasan’s book BlockChain Ethics, in Chapter 4 “cracking the glass ceiling”, regarding my thoughts on blockchains ability to transform these legal transparency issues that are enabling mass fraud. Our current predatory-capitalist based judicial system and the institutions these courts feed is not focused on protecting the innocent children and elders. Victims just like myself and Mary Bush and her mother Genevieve Bush currently and tragically held against her will in a permanent detention, illegally medicated and psychologically abused. This is a national health crisis caused by judicial corruption and vindictive absolute power and judicial immunity.
Judge Katherine B. L. Platt sat on a committee called Changing the Culture of Custody for the state Commission for Justice Initiatives in 2007, which vowed to reform the current adversarial family court into a less contentious system, that would expose families to less trauma from separation, but she signed an order that severely restricts my visits with my children.
Changing the Culture of Custody for the state Commission for Justice Initiatives in 2007, was not a small undertaking, to quote the Chairman’s Introduction :
“The adoption of the Gold Standard Model set forth in this report, and the associated programs, will immediately change the course for the future of family separations and subsequent parenting arrangements. Children will be exposed to a far less contentious system, and will bear fewer emotional scars for the rest of their lives.
Beginning in 2005, at the request of the Supreme Court of Pennsylvania, a Committee of experienced practitioners from many disciplines began the process of seeking a truly new and innovative way to resolve “custody” cases with less cost, delay and anguish. Through their dedicated and continuous efforts this Committee now offers the following report.
Over the last two years, the Committee has held 21 full day meetings, and conducted research projects and numerous investigative visits to courts to determine the best options for separating families. Arnold Shienvold, Ph.D., brought great understanding to the dynamics of separation, as a clinical psychologist; Jusy Shopp, contributed vast knowledge on Alternative Dispute Resolution and mediation, and edited this report; Kathy Morrison represented the Domestic Violence community and their suggestions; Kim Nieves and Don Harris brought the expertise of the AOPC office, and its statistical gathering muscle; Maria Cognetti spoke for all the family law practitioners; Cindy Stolz and Amy Ross added the perspective of Court Administration who will have to ‘run’ any system created; Gregg Warner illustrated the legislative interests and needs; Frank Cervone spoke tirelessly on behalf of children and their needs; and the Common Pleas Judges Manny Bertin (Montgomery), Chet Harhut (Lackawanna), Katherine Platt (Chester), and Larry Kaplan (Allegheny) contributed their vast and varied experiences with family court matters over thousands of cases. This group was brought together and coalesced under the guidance and efforts of Marie Queen, of the Pennsylvania Bar Association. My sincere thanks and admiration go to each of them.
A member of the Committee summed up our optimism for this report by remarking that: “When this is implemented, it will be the most significant contribution of my entire career.” we all feel the same enthusiasm!
It has been an honor to Chair this important work.
Respectfully submitted,
Hon. Thomas King Kistler, Chair
CJI, Changing the Culture of Custody Committee
May 24, 2007”
Below is a quote from Page 35 of Changing the Culture of Custody for the state Commission for Justice Initiatives in 2007, which again, I would like to point out Judge Katherine B.L. Platt sat on strongly recommends continuity in judges. Also The report cites that Adams, Allegheny, Centre, Cumberland, Dauphin, Franklin and Montgomery Counties practice One Family/One Judge.
“The Committee strongly recommends the One Family/One Judge concept. Since the expectation is that the sitting judge will rotate among the judges, the cases that have not been previously assigned to a particular judge will now be assigned to the sitting judge when the families make their first appearance. If the family has been assigned to a judge, the sitting judge will consult with the assigned judge or the case will be referred to the assigned judge for resolution depending on the particular situation. The purpose is for the family to have continuity and for the judge with the most knowledge of the family be involved in the decision making process.”
Even though my heart is broken and I am stipped of my motherhood, I doubt Judge Katherine B.L. Platt is even aware of the trauma her court order has caused myself and my family. My case has had several judges and masters and has been shuffled well, I believe this is done to decrease the liability, and increase billable hours of the “divorce industry stakeholders”.
Below is a quote from page 55 Chapter V. Education and Training in Changing the Culture of Custody for the state Commission for Justice Initiatives in 2007, which again, I would like to point out Judge Katherine B.L. Platt sat on that is under B. Education of Judges, Court Personnel, and Outside Providers.
“Special attention will be paid to domestic violence training, as parenting time cases involving domestic violence comprise a substantial number of contested parenting time cases. Even though a large number of parenting time cases involve domestic violence, typically, judges and professionals, including attorneys, social workers, psychologists, psychiatrists and others, have little or no training in domestic violence. Reference American Psychological Association Violence and the Family , 13-14 (1996)”
In the case of Mary Bush’s mother, one would wonder if Judge Katherine B. L. Plattever recieved domestic violence and sexual violence awareness. One would hope so since training on this dynamic altering issues affects so many cases such as Mary Bush and her mother Genevieve Bush’s case, in which her mother is a victim of sexual abuse. In my case, I told everyone that my father was a bully, but it was at every turn either ignores, or used to further creates conflict by the agents of the court and the divorce industry.
I feel so strongly that the system is broken that I have devoted myself to expose not only my own family’s case, but also to this public advocacy. We need to let people know judicial immunity is corruption. Family court racketeering, fraudulent guardianships, foster child services abuses, kids for cash placements will soon be exposed so that not only drastic reform will be urgently adopted. Just as with Glen Mills, we need to investigate for reparations accounting the victims of Chester County Judicial Corruption. The rackeeting ring Mary Bush has exposed, includes predatory services with financial incentives to separate families, institutionalize , and medicate.
APPELLEE Judge Katherine B. L. Platt is and/or has violated 42 U.S. Code § 1983 [but not limited to], the Declaration of Independence, the First, Ninth and Fourteenth Amendments of the United States Constitution and her Oath of Office. Upon further inspection of this matter it is quite possible she is also in violation of 18 U.S.C. § sec 1961 et seq.,
U.S. Code § 453.Oaths of justices and judges, she is iv violation of the Judicial canons; ‘‘canon of . . . judicial ethics’’ referenced in Article V, Section 17(b) of the Pennsylvania Constitution, which states, in pertinent part: ‘‘Justices and judges shall not engage in any activity prohibited by law and shall not violate any canon of legal or judicial ethics prescribed by the (Pennsylvania) Supreme Court.’’
1. A judge shall uphold and promote the independence, integrity, and impartiality of the judiciary, and shall avoid impropriety and the appearance of impropriety.
2. A judge shall perform the duties of judicial office impartially, competently, and diligently.
3. A judge shall conduct the judge’s personal and extrajudicial activities to minimize the risk of conflict with the obligations of judicial office.
Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress, except that in any action brought against a judicial officer for an act or omission taken in such officer’s judicial capacity, injunctive relief shall not be granted unless a declaratory decree was violated or declaratory relief was unavailable.
Judge Platt is in violation of Rule 1.1. Compliance with the Law. A judge shall comply with the law, including the Code of Judicial Conduct.
Genevieve Bush has never been in any Orphans court issue. Pa title 20 Cons. Stat. Ann. § 5511(a). The respondent must be present at the hearing unless either (a) a physician or psychologist states (under oath) that the person would be harmed by being present, or (b) it is impossible for him or her to be present due to his absence from Pennsylvania.
20 Pa. Cons. Stat. Ann. § 5512.1(a)(3); see also In re Peery, 727 A.2d 539, 541 (Pa. 1999) (a person cannot be incapacitated and in need of guardianship services if his impairment is counterbalanced by assistance from friends and family or other supports).Genevieve Bush had a well-planned support system in place that included drafting the following documents for her protection from her sons plan of June 2005 to liquidate her alive for their tax-free inheritance.
GUARDIANSHIP VIOLATES THE INTENT OF THE VERY STATUTE
THAT CREATED IT
THE APPELLEE HAS COMMITTED A FEDERAL CRIME by acting in concert with state actors to deprive Mary Bush and her mother Genevieve Bush of their civil rights.
TABLE OF AUTHORITIES
U.S. Code § 453.Oaths of justices and judges
Pa title 20 Cons. Stat. Ann. § 5511(a)
20 Pa. Cons. Stat. Ann. § 5512.1(a)(3); see also In re Peery, 727 A.2d 539, 541 (Pa. 1999)
Sabree, 367 F.3d at 193
U.S. Court of Appeals, Third Circuit-Sarah Grammer v. John J. Kane
Regional Centers-Glen Hazel
Gonzaga Univ., 536 U.S. at 284-85, 122 S.Ct. 2268; Blessing, 520
U.S. at 341, 117 S.Ct. 1353. 367 F.3d at 193
Gonzaga Univ., 536 U.S. at 284-85, 122 S.Ct. 2268
Blessing, 520 U.S. at 341, 117 S.Ct. 1353. 367 F.3d at 193.
18 U.S.C. § sec 1961 et seq
OBRA
42 USC 1983
Medicaid Act
Department of Health and Human Services DEPARTMENTAL APPEALS
BOARD Civil Remedies Division NMS Healthcare of Hagerstown, (CCN:
21-5256), Petitioner, v. Centers for Medicare & Medicaid Services. Docket
No. C-14-1566 Decision No. CR3772 Date: April 10, 2015
Title XIX of the Social Security Act
STATEMENT OF INTEREST
I am Kristine A. Smith financial supporter and volunteer for the nonprofit documentary Erasing Family and the associated shared parenting legislative impact campaign with the National Parenting Organization. I am currently rallying support for a proposed Equality in Parenting Time bill that was introduced on Dec. 9 at the Pennsylvania State Capital before the Subcommittee on Family Law. I am an advocate for shared, safe parenting anything less will perpetuate the mental health crisis that is underlying many suicides, homicides and mass shootings in our society. PA HB 1397 promotes gender equality in custody determinations and aims to protect the right of children to continue to have both parents meaningfully involved in their lives following a separation or divorce.
My experience of profound loss of my children due Chester County family court corruption has inspired me to donate financially to the production of the non-profit feature-length documentary Erasing Family. Erasing Family, recently endorsed by the American Psychology Association, investigates family bond obstruction from multiple perspectives in order to build a coalition of mental health professionals, teachers, clergy, politicians, lawyers and judges to enact reforms and respond to this public health crisis. I want my children to know as they come of age that we aren’t the only family experiencing alienation, this has become an unwarranted practice in the courts that profit on conflict. The film will show how programs that encourage mediation and shared parenting which will prevent future childhood trauma, making divorce and separation less costly both financially and emotionally.
Philadelphia’s Department of Human Services removes children from their families at the highest rate in the country, triple New York City’s rate and quadruple Chicago’s, according to federal data. This rate is derived from federal Adoption and Foster Care Analysis and Reporting System data, which derives from a point in time count of all children in care. Philadelphia’s child removal rate is so high that DHS, itself, has asked the University of Pennsylvania Child Center to conduct a study of its programs – a study that will take approximately 18 months.
The Erasing Family Director/Producer Ginger Gentile director of also co-directed Erasing Dad, this spanish-speaking film made family bond obstruction front-page news and drove legislative and court reform in Argentina. Ms. Gentile has since moved on to the Executive Director position at the nonprofit National Parent Organization. Our impact & awareness campaign will encourage schools, doctors and court officials to respond to this growing public health crisis.
My work with the Erasing Family Documentary is as a volunteer organizer and a financial donor. My personal story is not told in the documentary. I do not work for , nor am I paid by any individual or organization. Neither a party nor a party’s counsel has contributed money intended to fund the preparation or submission of this brief; and no person, including the amici, has contributed money to prepare this brief.
I paid Sheryl Rentz to represent me to get rights to my childrens’ medical decisions. I gave her information about my scientifically valid concern over the Gardasil vaccine and my children' experiences with Lyme and tick borne illnesses. Due to a signed custody order by Judge Katherine B.L. Platt my rights to communicate and associate with my own three children, as well as have access to any of their educational and health records or decisions has been stripped from me. I also suffer the indignity of a supervised physical custody supervisor, who is also my medically documented psychological abuser who repeatedly has withelds my children in an effort to silence me.
I am particularly interested in the outcome of Bush v. Platt because there are many other victims and family members like Mary and Genevieve Bush similarly situated across the United States losing relationships with family for no just reason. Families caught in a domestic dispute such as Mary or myself are often seeking honest services yet wind up defrauded, extorted and abused at the hands of those they should be able to trust - judges, behavioral health services, and even their own lawyers.
The resolution of Bush v Platt in favor of Mary and Genevieve Bush will be of great public importance for thousands of family members and interested parties who are being subjected to administrative courts that are warring against our federal and state constitutions. More and more families are being stripped of guaranteed rights and liberties. Cases like Bush v. Platt show how the court attached allies retaliate against family members who tried to defend vulnerable elders and children.
Guardianships that alienate parents from their adult children are a violation of the Due Process Clause of the Fourteenth Amendment in which the parent-child relationship is a liberty interest. Other common hallmarks of abusive probate guardianships include the lack of medical care which results in loss of health and preventable decline, denial of nutritious food which results in starvation and malnourishment and, as noted, alienation from adult children who are concerned for the welfare of their elderly parent(s). Federal Courts can protect, under the "life, liberty and the pursuit of happiness" clause of the Declaration of Independence, the right of a man to enjoy the mutual care, company, love and affection of his children and this cannot be taken away from him without due process of law.
Further, in Carson v. Elrod, it was determined that no bond is more precious and none should be more zealously protected by the law as the bond between parent and child. Mary Bush spoke up because she was being alienated from her aging mother and as a result was physically assaulted and threatened by third parties incited by false pretense orders. She has been wiped out financially trying to uphold her mother’s fourteen advanced directives.
Thus, a ruling in favor of Appellee Platt would continue to endanger the health, emotional well-being and safety of the greater United States’ senior community, their adult heirs/beneficiaries and the general public.
We are aware that countless innocent Americans and the family members who advocate for them have been abused and exploited in locked facilities under illegitimate guardianships through court based schemes designed to enslave and isolate innocent vulnerable citizens, particularly those with assets, for the vile purpose of enriching the stakeholders in the guardianship system.
Bush v. Platt is among a rising number of public cases involving the adult children of elderly parents who have suffered from alienation, abuse and neglect caused by nursing home administrators acting in concert with state actors and guardians such as Carol J Hershey that violate the Civil Rights of not only the elderly but also their
concerned adult children.
According to one of our recent studies, some 90% of families report that the judge in their guardianship proceedings did not act in the best interest of the elderly, 80% suspected the judge was improperly influenced and 70% felt the offending facility did not act in their parent’s best interests. No one is immune to an attack by a court appointed guardian. Even our honorable Commander in Chief and President Donald J. Trump is the subject of a Petition to Determine Capacity in the 15th
Judicial Circuit for Palm Beach County Florida. The petitioner is James A. Herb, an attorney, residing in Boca Raton.
http://www.mypalmbeachpost.com/news/national-govt--politics/boca-lawyer-asks-palm-beach-countyjudge-declare-trumpincompetent/iXav6uwBk6eK1yGf2zXiqO/
SUMMARY OF ARGUMENT
Based on national surveys of abuses in restricted facilities and under state ordered guardianships, the actions undertaken by Appellee Platt are common tactics across the country and are designed to accelerate the “wards” death and utterly destroy the family member(s) that pose a challenge to the lucrative income stream enjoyed by not only restricted facilities, nursing homes and assisted living facilities but also by the state Court itself and attorneys who, rather than seek a resolution, choose to escalate cases that could easily be solved by allowing for true due process.
We write to inform the court that the malicious and abusive tactics to prevent Mary and Genevieve Bush’s constitutional rights are actions taken by court appointed guardians nationwide in concert with court officials including Lawyers and Judges in order to effectively hide any and all abuse and neglect perpetrated on elderly wards from concerned family members and friends.
In many cases, we have seen the Guardians covertly support the “nursing”
facility by remaining silent because they may have a financial interest
in the premature death of the elderly “ward.” According to a November 30, 2016 article in Investment News titled Abuse of Elderly by Guardians Often takes form of financial exploitation, relatives of the elderly consider it “accelerating the
inheritance when they are abusing the “ward.””
We encourage others to stand up and speak out against the tactics of greed employed by Guardians and Probate Courts nationwide that accelerate the deaths
of these elderly “wards” as detailed in Johnston v. Dexel. http://www.investmentnews.com/article/20161130/FREE/161139990/abuse-of-elderly-by-guardiansoften-takes-form-of-financial
Further, these egregious tactics of parental alienation are used to stop a family member, friend or interested party from actually looking out for the “best interests” of the elderly loved one. We write to advocate for Mary and Genevieve Bush (as we have for many other adult children elderly “wards” of the state who are now deceased) for Mary Bush her only crime has been her attempts to protect her mother Genevieve from abuse, sexual assault and neglect while a ward of the state of Pennsylvania.
Like in the case of the reported neglect, injury and sexual assault of Genevieve Bush ’s we, have heard from countless numbers of adult children like Mary Bush that the judge turns a blind eye to the state documented injuries and neglect of care
of the elderly “ward” by the facility, which eventually results in premature death.
Finally, when deciding a petition, a district court must “accept all factual allegations as true, construe the complaint in the light most favorable to the plaintiff and determine whether, under any reasonable reading of the complaint, the plaintiff may be entitled to relief.” Under the Declaration of Independence, it is an inalienable right to act in self-defense, whether it be for personal, family or nation and in this case Appellant Mary Bush sued Appellee Judge Platt for herself and her
aging mother who is still suffering from neglect and abuse without any due process whatsoever. Such liberty infringements can not be tolerated by any court of law.
ARGUMENT
Mary and Genevieve’s freedom of speech and their ability to peaceably
associate with her natural parent, natural daughter has been unlawfully curtailed and abridged with no due process by Appellee Platt in the lower state orphans court.
Article the sixth... The right of the people to be secure in their persons,
houses, papers, and effects, against unreasonable searches and seizures,
shall not be violated, and no Warrants shall issue, but upon probable
cause, supported by Oath or affirmation, and particularly describing
the place to be searched, and the persons or things to be seized.Mary and Genevieve have been subjected to illegal search and seizure of their personal belongings.
Article the seventh... No person shall be held to answer for a capital, or
otherwise infamous crime, unless on a presentment or indictment of a
Grand Jury, except in cases arising in the land or naval forces, or in the
Militia, when in actual service in time of War or public danger; nor
shall any person be subject for the same offence to be twice put in
jeopardy of life or limb; nor shall be compelled in any criminal case to
be a witness against himself, nor be deprived of life, liberty, or property,
without due process of law; nor shall private property be taken for
public use, without just compensation. Article the tenth... Excessive bail shall not be required nor excessive fines imposed nor cruel and unusual punishments inflicted.Appellee Platt has wiped out $1 million of Genevieve assets with a court order signed without jurisdiction and has cost Mary over $500,000.00 to defend herself and her mother in this still existing fraud. Now Appellee is giving the two estranged sons the all clear and go ahead to liquidate a living Genevieve’s possessions, home and personal property in a pre-probate selling under a false pretense act. Both mother and daughter have been persecuted with abject, cruel and unusual punishment in the form of unjustified arrest and incarceration to
silence them and hide from public view this estate trafficking .
Declaration of Independence ...Inherent rights of mankind.
SECTION 9. Due process.— No person shall be deprived of life, liberty or property without due process of law, or be twice put in jeopardy for the same offense
The Appellants have not only been deprived of her property, liberty and denied due process but the daughters have been subjected to illegal arrest and incarceration merely because she got her mother medical care that she needed by getting help via 911 on January 20, 2016.
SECTION 12. Searches and seizures.— The right of the people to be secure in their persons, houses, papers and effects against unreasonable searches and seizures, and against the unreasonable interception of private communications by any means, shall not be violated. This right shall be construed in conformity with the 4th Amendment to the United States Constitution, as interpreted by the United States Supreme Court.
SECTION 17. Excessive punishments.— Excessive fines, cruel and unusual punishment, attainder, forfeiture of estate, indefinite imprisonment, and unreasonable detention of witnesses are forbidden. The prohibition against cruel or unusual punishment, and the prohibition against cruel and unusual punishment, shall be construed in conformity with the decisions of the United States Supreme Court which interprets the prohibition against cruel and unusual punishment provided in the Eighth Amendment to the United States Constitution.
CONCLUSION
I have reviewed the Appellants complaint and evidence submitted and recognize that Appellee’s actions inflicted irreparable harm upon both Appellant’s constituting violations of Mary Bush’s rights as the biological daughter and many violations the natural mother Genevieve Bush’s rights that she has no way to pursue outside or inside her illegal incarceration.
By ruling in favor of Appellants, this court will set a precedent that will assist other “wards” and their concerned adult children throughout the country who have been alienated from their family either through improper unconstitutional county/state orders or premature, accelerated death by neglect and injury at the hands of nursing home administrators and/or Guardians appointed by judges like Appellee.
● We implore the Third Circuit Court of appeals to rule against the Appellee’s abusive actions against a loving mother and daughter. Since Appellee continues to act abusively towards Mary Bush strictly for her own financial interests and as such, we ask the court to consider the following:
● In Franz v U.S, it was determined that a parent's right to the preservation of his relationship with his child derives from the fact that the parent's achievement of a rich and rewarding life is likely to depend significantly on his ability to participate in the rearing of his children. A child's corresponding right to protection from interference in the relationship derives from the psychic importance to him of
being raised by a loving, responsible, reliable adult. (707 F 2d 582, 595-599; US Ct App (1983) The same fundamental right ( Due Process Liberty right ) applies between adult parents and adult child because nothing changes in the bonds of love and duty just because the child has reached legal age and now wants to care for the adult parent.
Respectfully submitted on _____________
By Kristine A. Smith
Address
CERTIFICATE OF SERVICE
I certify that the foregoing Amicus Curiae brief to the Court was served upon the Appellee through Counsel on ______________ by pre-paid first class U.S. mail.
/s/