Notice of claim. You are being sued. Stacia Ann Adams II Irizarry Raul Irizarry, INJURED PLAINTIFF (s) Suing additionally, on behalf of such minor Caeden Kenneth Raul Irizarry, The childs maternal Great Grandparents Richard Shields McGibbenyDiana Gail Brown McGibbenyThe Childs Paternal Grandmother Daisy RiveraV. Department Of Social Services, CBC. DEFENDANT (s) Seminole County Department of Social Services CBC
The date of when injury has arise causing such lawsuit (s) and notice of claim per government worker asothers to be promptly prepare, serve against all liable defendants for cause of child/parent injury as suchinjury arising has taken place on or about 1-31-2011. Violation (s) of staid nature is causing suchinnocent loving once happy family falsely accuse to take the appropriate action as available to such injureparty by a state worker (s) causing such federal right injury to immediate put on such warranted noticewhen such state worker (s) for such agency as others who are committing such violation under federal law. Such child has been FORCE to separate at no fault of the loving parent now bringing suit as beingtold what to sayhow to act, by such falsity involving HIS loving parents, who are continually fighting insuch court (s) to have their loving child now injured by the defendants, return based on such well establishlaw in Florida. The continue inequities, by such defendant (s) has cause ongoing harm TO OUR CHILD
Hence such lawsuit now shall be properly filed in due course as such adult claim (s) involving the plaintiff. 2Mr. And Mrs. Raul Irizarry, who elect to at this time exercise their U.S. Constitutional right tofile such notice, follow by such warranted lawsuit (s) for such staid injuries to their loving now injured family. Pursuant to such claims now being filed under U.S. C sec. 42 1983-85-88applicable for bringing such lawsuit in due course for violations resulting in the pain andsuffering from intentional infliction of emotional distress upon the removal of ones childAs such harm to the child and parent, for the removal of child from his loving home not evenwarranted by the state to take such drastic, unconstitutional action, has now put child liferepeat harm, serious danger without any end in sight. Plaintiff shall clearly enumerate below such nature of the claim that has now arise due to suchwrongful removal, continue removal, detention of ones loving un-abuse child who has notbeen abused until AFTER such unwarranted unconstitutional removal by all said defendant (s) CBC on such date of JANUARY 31,2011 FROM Stacia Ann Adams II IrizarryThen removed from Raul Irizarry March 8,2011The child is now being told he may beput up for adoption if case plan is notin time frame aloud to be completedYET NO ABUSE WAS SUBSTANTIATED Hence such adoption would be ILLEGAL. No abuse substantiated against plaintiffs yet being treated like acriminal whose been convicted of such abuse and or neglect by cbc. This is not the case. As by law, such pre-requisite involving ones child to be remove by a state agency worker at CBC inorder to simply avoid such placement OUT OF THE HOME;CBC FAIL TO WORK WITH THELOVING PARENTS BY OFFERING SUCH REQUIRED, MANDATE SERVICES TO RAULAND HIS WIFE, THE INJURED MOTHER MRS. STACIA ANN ADAMS II IRIZARRY HAS TRIED TO BE FULLY COPERATIVE BUT RATHER HASKEPT THE CHILD OUT OF THE HOME, EXTENDING EACH DAY THE VIOLATION TAKING PLACETHE CBC Defendant (s) never offer plaintiff service (s) to keep the child INSIDE of the parent homewhile such services, IF warranted are taking place. Rather such law (s) state/federal/involving thisonce happy family have been fully circumvent to have the remain where HE DOSE NOTbelong in such foster care system where the child has been, and WAS continually beingabused up until being placed with the maternal grandparents then placed with meternal great grandparents, mistreated for some time, prompting notice of plaintiff intent to sue against defendantsto be filed, serve to each defendant as such child was not being abused by either parent, shall be proven, in the proper forum after all notice (s) and lawsuit in federal court has been filed. The injured plaintiffs have been deprive such right to raisethe young child in the comfort, privacy of their loving homein violation of the fourteenth amendment. DEFENDANT (s) 3mentioned has failed to duly consider the loving father and loving mother asa good loving parent who love their child and want what is best for him. The Due Process Clause in our United States Constitution is not in any wayambiguous, however defendant (s) continue to ignore, not abide by suchlaw (s) pertaining to the child involve, and the loving parents now suing. Such child has been removed, yet has the Legal and the Constitutional RIGHT! To be home with his loving mother/father BOTH severely injure by such chain ofcontinual events that has allow the state to continue to violate and injured, the childwhile in state foster care and injure the parent (s) RAUL AND STACIA for far too longnow prompting plaintiff lawsuit and notices to be filed at once due to non-return of child andinjury to their sweet child while in such care of the state unconstitutionally. To make matters worse defendant (s) are feigning the law (s) do not require such child to be reunited, upon no abuse being established, when clearly such law is clear indicative of such fact. Upon further information and such belief, CBC Defendant (s) has made no effortof such reasonableness to return child to the parent, under FLORIDA LAWwhen abuse is NOTfound, proven, nor substantiated by a jury trial or an apealet court, as require by law to do so. Such Dismissal of action brought against the innocent parent has to take place. Child is to returned to the parents, falsely accused at once. Such reasoning for lawsuit to be properly fileddue to aState actorviolating a U.S. Federal right repeatedly involving the family shall be clearly notatedthroughout the plaintiff notice of intent to sue, followed by their lawsuit. As the law is clear. Child is suppose to be home with his loving, now injured parent, STACIA ANN ADAMS II IRIZARRY AND RAUL IRIZARRY. However, due to biascy, discrimination, ongoing illegal practice (s) by the caseworker and or the continuednegligent in the improper handling of this case such Defendant (s) has failed to return the child toparent causing such injury to take place for some time without any end in sight. Plaintiff hence is now filing such lawsuit (s) due to staid injury by not returning the child back to HISlegal primary care, when NO abuse has been found, substantiated against RAUL. As set forth in such clear statute, law in our state of FLORIDA child has a legal rightto be returned naturally once such investigatory process has been implemented involving;all of the parties, yet CBC has illegally been keeping child without a end in sight to returnCAEDEN now age 2, to his parents, in VIOLATION of his, and his parents U.S. Constitutional Right. Hence lawsuit now, shall be filed, as such plaintiff and the child right to do so at once, to prevent any further violation (s) causing staid injury to the child and loving parents, of such innocence
As such condition (s) for which has lead to the child being remove was found to be unproven in referenceto serious abuse, allegation (s) physical abuse etc. Yet the child has yet to be return inviolation of their right as the parents injured has now elect to bring forth such warranted lawsuit in duecourse for the failure to reunite parent and child as a host of other significant injuries to be enumerate
Child has, by no reason of such validity should have to remain out of the parent home andhas been for some time prompting lawsuit to be filed-as the child should have to not remain any longerfromhis parents, namely CAEDEN age 2, suffering severe trauma while away each day from mom and dadas unconstitutional. While child is still out of the plaintiff loving carehe has been horribly abused, mistreated, maltreated, injured, repeatedly as well as emotionally abusehas been force by either caseworker (s) over at CBC/Foster CareParents to say things that are wrongabout his own parent, and or force to hear things that are clearly about his own parents, is causing the boyto in furtherance become withdrawn, angry, unlike how he was when living under the care custody, controlof his loving parents fit to raise him, as they have done since birth. Just because Mr. Irizarry has a brain injury does not mean he is not capible of caring for his son Caeden as he has done since birth. RAUL IRIZARRY the childs father listed in such notice (s) has been CLEARED of any wrongdoing Raul Irizarry has a brain injuryin furtherance was not even arrested when falsely accused, but yet is branded by such state worker (s) forsome time as achild abuseras well as his loving wife, mother to the child Stacia Ann Adams II Irizarryprompting such warranted lawsuit (s) and notice of claim against Defendants to be filed. As the law (s) protecting our child as our parental rights shall not and are not in any way unclear. However defendant (s) continue to ignore such right of parent as importantly the child whose was beingtraumatize, emotionally verbally psychologically abuse and mistreated for some time, as shall be provenwhen such federal lawsuit is filed soon. Foster care or placement in great grandparents home is surely not what is best for the irizarry child. He should be with his father and or his mother. THIS CHILD WAS NOT ABUSED YET CANNOT RETURN HOME? There was a mis understanding with a injunction from Lee County Florida. If the police knew there was a injunction why was Raul and Stacia not taken to jail when the police arived on Jnauary 30 2011. When a person not living in the APPARTMENT locked Stacia out of the appartment. Her child was with Raul. The female that locked Stacia out of the APPARTMENT was there on a visit from Lee County. The child was not home when this happened he was with other children in a another persons care. The child did in fact return home while the police arrived. THE POLICE HAVE ALREADY STATED IN COURT THE CHILD WAS IN NO SUCH DANGER AND HAD NOT BEEN HARMED Stacia asked the police to make such female to leave.instead the 5 police officers of Altamonte springs told Stacia sleep on the sofa. This what Stacia did she was in structed to do so. The next morning this same female made false reports to the police also brain washing Mr. Irizarry into thinking Stacia had done things to him that HAVE BEEN PROVEN THAT. The way the police made the statements for stacia to be arrested were untrue. Mr and mrs irizarry had a confritation. The child was not in the home. The child was at the play ground. The police had both stated there was nothing wrong with the child and he had been in no danger. Cbc's report also stated caeden was not there he was in the visinity. Yes this is true the visinity of the appartment complexplay ground yet stacia went to jail stacia was made to speak with cbc in jail they gave her no right not to speak. Raul and Stacia have made this same statement time and time again WHY is no one listeing? Why has parenting classes been forced? Why has mental health been forced? Why has anger management been forced? Why has CBC and Seminole County Judges made false statements on Raul and Stacia? Stacia may have left her son in the care of Raul he is the father and Raul and Stacia had a parenting plan established in the court system Stacia had Caeden 4 days per week then 3 days off Then Raul had Caeden 4 days then 3 days off. This is not a case of child neglect this was a shared parenting plan. Stacia would have been in a volation of a parenting plan if she had not placed CAEDEN WITH HIS FATHER to spend his part of the parenting plan with the child. It has also been stated basicaly by Judge Galluzzo that Raul and Stacia told lies well this is a un founded. The Judge said this with out any contact with regurd to this parenting plan to Lee County Fl were the parenting plan was established. It is said that the parenting plan was good state wide. The case worker from CBC has tried to have Stacia and Raul arrested for volation on the injunction. The case worker has also failed many times to submit the injunction had been removed. The Judge and CBC had removed the child from Stacia for drug abuse along with D.V. At this time this Judge said Raul will supervise visits. Then it was stated to Raul this could not happen. Then Stacia and Raul were at the same publix. There was a police report made Stacia and Raul had been seen in the same store. It was also Stated they entered and left the store at different times. This family court is a civil court not criminal if in fact they were in a volation of an injunction. Why did altamonte springs police not arrest her for a violation of the injunction? Stacia grandparents hired calvo and calvo of lee county to modify the injunction placed in lee county florida and produce and file a parenting plan in 2010. If a common person is lead to believe in the county of Lee that this had been resolved then in fact they should have not been in any violation of law. Or in fact these attorneys need to be sued also for legal malpractice. It has also been stated and filed by cbc that there was on going d.V.in THE HOME AND HE HAD BEEN REMOVED IN LEE COUNTY TWICE THIS IS UNTRUE! Raul had an arrest for a statement made to police officers which there was no law broken and the Judge that heard Raul's case and Raul's attorney Phillip Stein-burg which was retained by Mr and Mrs Mcgibbeny said no law had broken and this was a false arrest. The irizarrys at this piont had there child returned with in a month. Caeden was removed falsely and there was no need for service. The case worker is lee county tammara. J. Made a plead for raul and stacia in november of 2009 with the judge in lee county florida. The judge had no option but to return this child. Raul and Stacia have been through enough with the state of FLORIDA'S DCF/CBC false and misleading untrue allegations. The Judge Galluzo has heard this from Raul and Stacia both but has yet to return the child to their custody. JUDGE GALLUZO HAS ALSO STATED ON 9-6-2011 AROUND 2PM THAT THIS CASE WOULD NOTA SERIOUS VIOLATION HAS TAKEN PLACE, NOTICE OF ONES INTENTION TO FILE LAWSUITAGAINST SUCH PUBLIC GOVERNMENT ENTITYand other liable parties, shall now be filed, followed by the plaintiff Federal Lawsuit in U.S. District Court ofFLORIDA, for each day child HAS been traumatize, as parent injured while family is torn part at no faultof the loving parents nor the child, in violation of the family constitutional right under the fourteenthamendment. The Plaintiff-Child has been clearly traumatize since such removal not warranted has taken place, and continueup to this day forcing such suit to soon be filed against all liable defendant (s) named in the aforesaid and throughoutnotice. The allegation (s) made against the plaintiff has not been SUBSTANTIATED, and or found guilty in a court of law and or appellate court. The child was NEVER ABUSED. Yet, He is Still being illegally detain allegedly by the CBC Defendant (s) for some time now. Stating such claim (s) for which plaintiff for which relief may be granted, under the United States FourteenthAmendment, in violation additionally of the FOURTH and Ninth. Suing under U.S.C. SECTION (42) 1988-19835claim (s) against defendant for such state actor whose allege to have violated the plaintiff (s) federal rightinvolving the wrongful and the continue removal of ones child from the home, causing such staid injuryto the entire family as there has been no reasonable grounds under C.K.R. IAs, the plaintiff YOUNGEST, child CAEDEN away from the loving home of HIS parents. Parents concede CAEDEN need help for MEDICAL needs by falsely accusing HISparents. And the parent right. Rather defendant (s) let her remain AS IS without no endinsight. However Caeden. Now age 2 deserve the right to be home with his loving parents, who are being injured each day bysuch removal for some time now, as the child is being equally injured as well, whose implore CBC to let him go home TODAY. Such violation by defendant (s) continue to undermine the family unit, their right to as by such well-establishconstitution as the right to familial association - being allegedly by being humiliated, by force supervise visitationwith their own child yet;NO CHILD ABUSE NO SUBSTANTIATED, NOR PROVEN in a court of law and or an appellate court has been noted by the court. The Plaintiff UN-abused child should be home. That is the law. Cbc defendants are ignoring the law, and are circumventing such lawto allow such caseworker to keep the boy in the care of the state in violation of suchright, involving parent and child, the right to such familial association hence lawsuitshall now be filed. Since child is still being illegally unlawfully detain by defendant (s) this lawsuit shall be officially filed against all liable defendant (s) causing plaintiff injury under the fourth/fourteenthamendment, the COLOR OF LAW as additional continuum violation (s) set forth giving such injure plaintiff (s) the rightto move forward and file their lawsuit in UNITED STATES DISTRICT FEDERAL COURT. The injured plaintiff (s) in violation hence, of the parents 14th amendment right, as right to such privacy intheir loving home under the 9th amendment to bereturn home. Child was never return when such ostensible abuse by parentwas allege, and then found to have not taken place. The childis still without his loving mother, and suffering in statesupervisecare of richard and diana mcgibbeny some time now. THIS IS A VIOLATION OF SUCH 14TH AMENDMENT involving the child beingcontinually unlawfully detain by CBC Defendant (s) and a staid injury to the lovingparent as the state has fail repeatedly to expedite to have child return evenallegedly after there was no abuse was even substantiated against the plaintiff. State continue to FAIL to work with parent (s) to have the child return by mandate/state require services the state has never issued a copy of a parenting plan to Raul. The state never gave Stacia her referrals for the parenting plan until at least 4 months had gone by. Although it states on her parenting plan she shall start services on January 31,2011. Then in the month of July there had been a staffing were Stacia had a phone staffing with CBC and SUSAN COX stated Stacia could take her classes online. Susan never stated which website that the classes could be taken on susan did state stacia you are good with computers take classes online since there are no aged appoved provider in lee county. So Stacia and Raul both took online parenting. Stacia also took a theft and anger management class. Stacia was found NOT GUILTY AND NEVER CHARGED WITH D.V.in the state of florida still to this day in a civil court cbc wants stacia to take a 6 month course with act ban in lee county florida. Although Raul has never gotten a copy of his parenting plan he had found out from GREATA PETERS OVER A PHONE CONVERSATION THAT HE WOULD NEED TO TAKE PARETING AND GO FOR A MENTAL HEALTH EVALUATION AT THIS TIME RAUL HAS DONE THIS. He has fully compleid with such pareting plan set forth by cbc. If CBC wanted Stacia and Raul to take such classes then these courses should have been offered to them when the parenting plan for Stacia was made in effect in January. CBC failed to give enough time to complete such classes. Now over 7 months have passed and neither have their child. If these classes had been taken starting January their child would have already been returned according to GREATA PETERS AND SUSAN COX. Greata peters has stated she was unable to send stacia and raul for services because susan cox was very hard to reach and cbc had not paid for such services. Stacia and Raul have had finical loss due to this parenting plan. These classes were only offered during the middle of a week day. All employers would not hire ether of them due to the fact they had these classes and they have had to travel to SEMINOLE COUNTY over and over for court. Stacia and Raul have only been able to get 3 phone hearings over the course of 7 months. The parenting classes that CBC was going to send Stacia to was not age approved. The instructor of this class was teaching about sex and condoms. This is very inapproriate for a child that is the age of 2. Stacia was in fear that if she talked about this with a child of the age of 2 there would be more false allegations on her. Such lawsuit now shall thus, be promptly and timely filed against ALL liable defendant (s) named in notice. 6All defendant (s) the parties officially now being named in the Notice shall be properly served within timeallotted by law followed by such lawsuit (s) that shall be accompanied by such facts, relevant to supportthe injure party claim (s) under such constitutional right allowing any per state actors who are violatingU.S. Federal Right is allowed to be sued IN FEDERAL COURT, whenever there is a federal civil rightviolation has accrued against the plaintiff. Family is suing under such federal/4th amendment for improper illegal unreasonable seizureas in addition under the State-Federal COLOR OF LAW. As in addition suing under such fourteenth (14th) amendment for damages. All state worker (s) named in such lawsuit now being prepared, as per notice of claim against eachdefendant shall be sued in their OFFICIAL and their INDVIDUAL capacity under law. The injured family, namely the child loving innocent parent (s) elect to exercise naturally so theirU.S. CONSTITUTIONAL RIGHT, Now that such serious injury to child, and violation has continue toworsen, each day the child once loved, taken care of, is being abuse, being learned by the devastatingparent (s) the plaintiff now bringing suit, as the injure parents now suing for money damages associatedwith such staid injury. All shall not be naturally illuminated in such notice but a clear outline shall beexerted below as above, causing such reason of such validity to have this lawsuit filed in due course. Summarily, On or about January 31 2011 the parents of herein; C.K.R.I. Have been violated. The child has not been returned, yet parent (s) in lawsuit notice should have been cleared of wrongdoing to suchchild, yet the child is still being made a Ward of the stateby FLORIDA CBC. The parents of CAEDEN. Are devastated over the loss of child forcibly remove from the home, has not been at all return as require by such well-establish law. The parents of C.K.R.I. Have beencompletely bereft of their loving child as the child were placed in the ostensiblecarecustody andthe control, of the Seminole CountyFLORIDA CBC. Of social services herein cbcthese defendants are now being sued in due course by such injured plaintiff. False allegation is the only reason as to why unconstitutionallythe child has been used, abused, deprive for a long period of time. Without end in sight. Such liable defendants, allegedly in one way or another has been abused since being remove fromhis loving parents, based on the premise the parent was harming the child, however not a shred7of evidence was found to support such abuse taking place to the child yet the child is still toremain out of the home in clear violation of the plaintiff (s) united states constitutional right. A false and mis leading statemnts, allegation is the reason why the child was taken. Stripped of his loving parents warmth, care, daily attentiveness from each loving parent securitytheir routine daily education empowerment from their UN-Abusive Loving homeunder the parent supervision primary care, a violation under the 14th amendment. Clearly being deprived for some time now, prompting such lawsuit notice to be filed servedagainst all defendants. Robbed of precious time daily with mother and his loving father, remove from the only home he knows and now is himself beingabused, while under state care, as shall be proven in due course. Child was Remove based on a non-secure removal where NO IMMINENT DANGERhad exist then were not return in violation of fourth and or fourteenth amendment as suchdeprivation of ones rights regarding their children still unwarranted. Needlessly the state of FLORIDA worker (s) at CBC are as of today by time such notice ofclaim of plaintiff intention to sue is being filed/served the state is allowing such inaction/action bythe state worker (s) to continue to take place. Are continuing up through the time such lawsuit is now being prepared, as notices against suchliable defts. The Defendant COX has violated the child's and the parents again recently by statingallegedly to the family: THE CHILD SHALL NOT BE GOING HOME. THE CHILD SHALL NOT BE RETURNED BACK TO YOUR CARENO RECOMMENDATIONS AT THIS TIME FOR CHILD TO BE RETURN TO THE PARENTSMost recent excuse isPARENTS ARE NON COMPLIANT WITH CASE PLAN? PER COURT HEARING 9-6-2011This is the outlandish and unjust reason as to why the little boy cannot return to his room thatis awaiting him and the home for which he has shared with his parents his entire life since birth. This is the explanation by CBC caseworker COX who recently adage such statement (s) tothe already deprive parents of the younger child CAEDEN, age 2 years of age, who flagrantly hasno reason to be outside of the loving parents home where abuse was NOT substantiated, 8nor proven in a court of law of very UN ethical practice. Such reason exert by COX is NOT a reason to keep a boy whowas NOT abused, by such loving parents, away from their primary care hence such violation istaking place, and parents intention to sue is now being brought forth against ALL defendant (s). Completely irrelevant if such law (s) ALLOW the child to go home when abuse is notproven is not relevantthe child is acting upin foster system under STATE Control, care and supervision when he was in Seminole county FOSTER H O M E S (3-4) Homes when the child is NOT suppose to even be there! The child has now been living with the MC gibbenys. The child has such constitutional right by well-establish law in FLORIDA as nationallyto be home. Yet CBC worker (s) named of plaintiff NOTICE OF CLAIM continue to make their own law, toignore state mandated/required law that allow the injure party to have her child home withthe parents. THAT IS A VIOLATION, and prompting such lawsuit to be filed in due course. Such acting upallegedly by child clearly is happened due to child NOT being in the lovingcompanionship and care and primary custody as he was since birth of his parents the nowinjured plaintiff. Child has a right to be HOME when no abuse/no serious injury/no serious risk by the parent istaking place, as such compliance by the parent (s) has been duly noted but yet the state hasstill, in violation detain child whose clearlyActing outby the trauma of him being away from hisparents, by continually being violated unconstitutionally prompting parents injured to bring suit. Caseworker COX the Defendant (s) violating the child right as per plaintiff adult states how heis NOT going home because YA'LL ARE BAD PARENTS while understate supervisionin foster careetc, so child cant go home etc. But yet the loving father is readily able to provideas always a loving secure home for HIS SON CAEDEN. Defendant (s) conveniently forget to mention how the child has been abused, while remaining insuch supervision, neglected, being forced to eat and things he did not like The parents could not provide things to eat and drink at YANA the child was having to drink apple juice which he should not have due to severe acid reflux. He was'ddress'd like he was homeless by the foster parents in Seminole County although the parents did provide nice new cloths and shoes for the child. The child would scream while the YANA worker would say to him NO no no YOU CAN'T STAY WITH MOM AND DAD. The child was forcibly removed from father and mothers arms screaming at top of lungs from YANA to go with the abusers. He was also placed with foster parents that has a non medical foster home in Seminole County. Caeden was moved from home to home which was causing the child to be very unstable and insecure with his well being. The parents saw many bruises on child and smelled UN clean while they visited child at a YANA centerin Seminole county Florida THE PARENTS WERE UNABLE TO VIDEO THE CHILD DUE TO THE CENTERS RULES. Raul and Stacia would make complaints every visiation about the child to Jenny about the way Caeden was dressed and the many bruises and cuts on the child. Caeden was placed into day care were he was beat up on by other children yet the day care and foster parents did nothing about the child almost getting his eye clawed out. The child had blood blisters under his tongue which Raul told Jenny and Jenny said I will ask the foster parents. Upon the next visitation Jenny said the foster parents said they did not know it was there. Raul and Stacia said to Jenny how could they not know it was there when Caeden cried about it at the visitation center. Caretaker a violation of the child as parent right as shall be further exerted in the properforum, as ALL violation (s) proving such injury when lawsuit is officially filed child being placed in a foster home that has not forchildren with the medical conditions that Caeden has a violation to him andhis entire family now bringing forward such lawsuit. Worker (s) clearly have demonstrate, clear bias allegedly involving the parents, that continue toundermine the child and the loving parents, now bringing such warrant lawsuit in federal court. Child belong home with his parents. Child was being abused in foster care in Seminole County, while out of loving parents home. Yet such defendant (s) at cbc are not returning the plaintiff children. 9A VIOLATION OF THEIR FOURTH/FOURTEENTH AMENDMENT RIGHT ;and a host of other continuum of violation (s) for which such damage to child parent shall besought, for non-reunification, non-return to the home of their loving child. Such factual discovery during such lawsuit phase of the plaintiff federal suit shall divulge moreinjuries, as it is clear the defendant (s) are engaging in biascy, discriminative act (s) against plaintifffor their own gain. As such case has nothing to do with two parents who are abusiveas noabuse of any sort has been established, proven in a court of law and or an appellate court, hence child deserve to be homeby LAW. Plaintiff (s) have been lied upon, slandered, completely defame, as libel involving such injury takingplace involving this once happy loving family as the plaintiff contend the child has been injuredas a result, as the plaintiff of adult age for some time due to the child NOT being returned to hisThe state allegedly involving the injure plaintiff STACIA AND RAUL IRIZARRY, have continuallybeen humiliated, have been violated by being completely bereft of their loving child, whoselast in SEMINOLE COUNTY residence during the foster care stay of Caeden causing them injury is FLORIDA foster care system, where they are beingsubjected to such REAL ABUSE. Child was not being abused in the loving parents home, hence this lawsuit shall now in duecourse follow as additionally as enumerated below, the injured plaintiff (s) are filing such lawsuitinvolving continual: Unconstitutional acts bestowed upon Plaintiff (s) without just cause. Based on such but not limited to: 1. Reckless disregard. 2. CAPTA Law (S) pertaining to proper procedures and protocol. 3. Illegal removal of one's child, whereas, there was NO LEGAL BASIS TO DO SO, unwarranted4..intentional Infliction of Emotional Distress, in regards to the non-return of CAEDEN, to his lovinghome. Continual violations of parental rights and civil rights for parent/child under such guaranteedfourth and fourteenth amendment. A LAWSUIT IN DUE COURSE SHALL FOLLOW THIS NOTICE OF TORT CLAIMThe information herein is putting ALL parties on Notice of Intent to Sue and will be properlydelivered to all Defendants. All parties shall be served accordingly for lawsuit with valid reasoning;10Below is prompting a warranted suit to be filed against all liable defendant (s) listed as: 1.) DEPT. Of social services, seminole county, florida. 2.) susan cox, liable defendant named in such notice of plaintiffintention to sue. Her position: caseworker current state employee, whose liable for such injuriestaking place involving all plaintiff (s) and caeden, by her failure toreturn plaintiff child when no abuse and or serious injuriesno neglect, no imminency et. Relating to the child is evident nor has ever taken place as defendant SUSAN COX hasconsistently blame parents for child being removed, slander the loving mother, as the innocent father, has continually FAILED to work with mother to keep child IN the home, by offering such Servicestherapy etc, to keep the child at their home to avoid continued!