Virgins are a dying breed and need to reproduce. I am here to give a new perspective on what it means to be a young lady in a world of predatory men. Ladies, there are some amazing men out in the world; and if your mother and father failed at showing you how to make wise decisions about the different types of men, then my wish is that you take some wisdom away with you from reading this true story. The following complaint is presently filed in Burlington, VT. Vermont is were this journey hopefully will come to rest after several years, of dealing with a bad decision, of being involved with a man who would lead to a long road of economic oppression through the choice of sustaining life instead of aborting it. My son is an amazing gift; it is his father's behavior directed towards me that leads to this complaint. The complaint is to invalidate federal regulations pertaining to title 51.90 "Denial of passport Services":
UNITED STATES DISTRICT COURT
FOR THE
DISTRICT OF VERMONT
Plaintiff Jane Doe)
)Case no:___________________
v. )
)
Defendant(s) )
)
DEPARTMENT OF CHILDREN AND FAMILIES, )
COMMISSIONER, individually and officially, on behalf of )
OCS, )Assigned Judge:
Office of Child Support, State of Vermont, et. Al ) ______________________
)
Complaint for Declaratory Judgement and Injunctive relief - To invalidate and prevent enforcement of federal agency regulations - Failure to comply with essential procedural requirements
COMPLAINT
(Trial by Jury Requested)
1. Comes now Plaintiff, Jane Doe, PO BOX 3154 Burlington, VT 05408; by and through herself, without waiving jurisdiction or venue thereof; and complains of the above-named defendants and shows the court as follows:
2. There is now existing between the parties hereto an actual, justifiable controversy in respect to which plaintiff is entitled to have a declaration of her rights and further relief, including mandatory injunction, because of the facts, conditions, and circumstance hereinafter set out pursuant to 28 U.S.C. A 2201; Fed R Civ P Rules 8(a) 57.
Parties
3. The Plaintiff's, Jane Doe is a resident of Burlington, Vermont. Defendant is Department for Children and Families Agency of Human Services, Office of Child Support, 103 Main Street, 2&3 North, Waterbury, VT 06571-1901, Northwest Regional OCS Office
32 Cherry St., Suite 310 Burlington, VT 05401. Commissioner's office, Commissioner David Yacavone, is located at Department for Children and Families 2nd Floor, 5 North 103 South Main Street.
JURISDICTION
United States of a federal official or agency is a party.
Claim arises under the Constitution, laws, or treaties of the United States.
Violation of federal rules and procedures, civil rights.
Diversity of Citizenship (a matter between citizens of different states in which the amount in controversy exceeds $75,000.00)
ELEMENTS OF CLAIM
I.
4. This action arises under 504 of Title 42 chapter 126 section 12101 of the United States Code. The suit is filed pursuant to 703 of Title 5 of the United States Code and 2201 and 2202 of the United States Code. This action arises under sec 7302 of the Deficit Reduction Act of 2005/amended 2007 and under Title 42 of the Social Security Act section 654.
II.
5. The court has jurisdiction under 1331 and 1337 of Title 28 of the United States Code. 28 U.S.C 1331, 137(a), 1345, and 1335, and 15 U.S.C 45(m)(1)(A), (53)(b), 56(a), and 16921.
III.
6. Venue lies in this court under 1391(e)(3) of Title 28 of the United States Code. Title 1391(e) provides jurisdiction pursuant to: “[(3)] the plaintiff resides if no real property is involved in the action. In addition the office of child support for the state of Vermont is located in Vermont pursuant to (e). Additional persons may be joined as parties to any such action in accordance with the Federal Rules of Civil Procedures. Venue is properly in the District Court for the State of Vermont under 15 U.S.C 53(b) and under 28 U.S.C 1391(b), (c) and 1395(a).
IV.
7. Plaintiff is a resident organized under the laws of the State of Vermont and her principal mailing address is PO BOX 3154 Burlington, Vermont 05408.
V.
8. Plaintiff is afforded reasonable accommodations (see attached exhibit P-1) by this court and is afforded pursuant to Federal Procedure 11:319; “[p]ro se complaints are to be liberally construed; the court has an obligation, in civil-rights cases where the plaintiff is pro se, to afford the plaintiff the benefit of any doubt. 8th Circuit: Quam v. Minnehaha County Jail, 821 F. 2d 522 (8th Cir. 1987); Munz v. Parr, 78 F. 2d 1254 (8th Cir. 1985); Miller v. Solem, 728 F. 2d 1020 (8th Cir. 1984). Pro se complaints are held to less rigorous standards than formal pleadings drafted by lawyers .
VI.
9. Defendants, The Office of Child Support is a Federal Agency and Commission organized and existing under 666 section 654(2)(a)(b)(ii)(iv) and 667(a)(b)(2) of Title 42 of the United States Code.
VII.
10. Defendants, The Office of Child Support and Commission is responsible, among other things, for regulating child support payments, arrears (alleged arrears), and enforcement of such valid (alleged) court orders effectuating payment of child support. The agency is further responsible to comply with federal laws pertaining to the under Title 42 U.S.C chapter 1305 Deficit and reduction Act of 2005/Amended 2007 Act; sec. 7302 Mandatory Review and Adjustment of Child Support Orders for Families Receiving TANF:
“[e]ffective October 1, 2007, section 466(a)(10) of the Act is amended to require States to enact laws requiring the use of procedures under which... or if there is an assignment under title IV-A of the ACT, the State shall review....adjust an order: using guidelines; a cost-of-living adjustment; or automated methods to identify orders to review and adjust...”
VIII.
11. Defendant, John Doe/Jane Doe,the director of the Vermont State of Child Support, and defendants, Keith Horton, Director of the Georgia Office of Child Support, and employed by the State(s) having been duly appointed and qualified with their offices in the District of Vermont, Georgia, and Columbia. Each is sued individually and as a employee of the State(s) agency's, Office of Child Support, Department of Children and Families.
XI.
12. On or about 2008, plaintiff having no prior knowledge, the defendants promulgated, 42 of the United States Code section 654(31) and Title 22 section 51.60(a)(2) Code of Federal Regulations, which authorizes promulgations of regulations to certify to the Secretary of State to refuse to issue a passport to the plaintiff, and may revoke, restrict or limit passport that was previously issued for valid [alleged] child support arrears over the $2,500.00 threshold; so long as the procedures specified by 533 of Title 5 of the United States Code are followed, the Fair Debt and Collection Act 15 U.S.C 16291, Federal and State Laws, Federal and State Constitutions, and the Deficit and Reduction Act of the United States Code(s) Title 42 U.S.C., due process of law, are followed. The Plaintiff has attempted to access the agency. The Agency has a duty to act in accordance with federal laws and mandates mentioned herein. The Agency has breached its duty by denying the plaintiff access to the agency and mandates under the Deficit and Reduction Act of 2005/amended 2007. sec. 7302, 14th Amendment. The agencies failure to preform their duties choosing to implement Title 42 654 and Title 22 section 51.60(a)(2) instead of Title 42 chapter 1305 section 7302; which are in conflict with each other, has directly resulted in the plaintiff being unable to obtain gainful employment due to her name being submitted for the passport denial program in opposition to the 7, 8, 5th, and 14th amendments of the United States Constitution. The failure of the agency to act since 2012 or about, in accordance with federal regulations and Constitutional law has created a breach of the agencies duties to act in accordance with federal mandates and has resulted in damages to the plaintiff.
XII.
13. Notwithstanding plaintiff's request that the Office of Child Support reconsider and rescind its determination that defendant's, agency, have violated the regulation; the Office of Child Support has threatened to enforce the regulation against the plaintiff. The Office of Child Support further refuses to act under the federal mandate of the Deficit Reduction Act of 2005/ amended 2007 sec. 7302 Mandatory Review and Adjustment of Child Support Orders for Families Receiving TANF; herein this case alleged child support.
XIII.
14. The promulgation and threatened enforcement of the aforesaid regulation is illegal, null and void for the reason that, in issuing the regulation, the defendants failed to utilize the following procedures required by section 553(a)(1)and 557 (b)(c) and 554 (a)(c) (1)(e) Adjudications of Title 5 of the United States Code, the Fair Debt and Collection Act 15 U.S.C. 1692(a)(6), section 805(a)(1) of the Act, 15 U.S.C. 1692c(a)(1). 15 U.S.C. 1692D, 806(2), Title 42 U.S.C Deficit and Reduction Act of 2005/Amended 2007 Act; sec. 7302 Mandatory Review and Adjustment of Child Support Orders for Families Receiving TANF; Code of Federal Regulations.
XVII.
15. In view of defendant's actual and threatened enforcement of the regulation and plaintiff's contention that the issuance of the regulation and its enforcement are null and void, there is an actual controversy within the jurisdiction of this court. Declaratory and injunctive relief will effectively adjudicate the rights of the parties.
16. Each of the following allegations is pled in the alternative, and without waiver.
17. On numerous occasions, in connection of alleged debts in English, without prior consent of the consumer given directly to the alleged debt collector or the express permission of a court of competent jurisdiction, defendant has communicated with consumers at times or places that the defendant knew or should have known to be inconvenient to the consumers, including their place of employment after the consumers informed the defendant's collectors that calls at work were inconvenient, in violation of Section 805(a)(1) of the Act, 15 U.S.C. 1692c(a)(1).When not reasonably necessary to effectuate a post judgment judicial remedy, in violation of Section 805(b) of the Fair Debt Collection Practices Act, 15 U.S.C. 1692c(b). On numerous occasions, in connection with the collection of alleged debts, in English, the defendant has engaged in conduct the natural consequences of which is to harass, oppress, or abuse a person, in violation of Section 806 of the Fair Debt and Collection Practices Act, 15 U.S.C. 1692D, including, but not limited to, the following:
a. Defendant, or a person acting on Defendant's behalf, has denied plaintiff access to the OCS in order to correct any alleged debt and the OCS office refuses to address the alleged debt, continues to enforce title 22 of U.S.C section 51.90 which is oppressing the plaintiff in future gainful employment, due to the inability to obtain her passport.
b. Defendant, or a person acting on Defendant's behalf has caused a telephone to ring, or has engaged a person in telephone conversations, repeatedly or continuously, with intent to annoy, abuse, or harass the person at the called number, without her express permission, with refusal to act in accordance with the Deficit Reduction Act of 1984 section 7302.
Complaint for declaratory judgement that federal agency has violated terms of consent decree, and for injunctive relief [5 U.S.C.A 703; 28 U.S.C.A 1361, 2201, 2202; Fed R Civ P Rules]
1. The court has jurisdiction over this action under 28 U.S.C 1331 and 1343(a)(3), in that plaintiff's claim arises under 29 U.S.C. 705 (2)(b)(i), “[is limited to information that is necessary to identify the rehabilitation needs of the individual and to develop the individualized plan for employment of the eligible individual...”(iii) “[n]eeded to make such determination, an assessment of the personality, interest, interpersonal skills, intelligence and related functional capacities, educational achievements, work experience...employment opportunities...that effect the employment and rehabilitation needs of the individual...”, 706 and 794. Social Security Act Sec. 401 [42 U.S.C. 601] (a)(1) (4), Title 42 U.S.C 1305, cited as the “Deficit Reduction Act of 2005” DRA. This court has jurisdiction to issue a declaratory judgement pursuant to 28 U.S.C. 2201 and 2202. Venue is proper in this court pursuant to 28 U.S.C 1391(b).
2. This is an action at law and in equity to redress the deprivation by defendants of plaintiff's rights, privileges, and immunities secured by 504 of the Rehabilitation Act of the 1973, 29 U.S.C 701 et. Seq., Title 42 of the Deficit and Reduction Act 2005/amended 2007 sec 7302.; and Title 42 of the Social Security Act 654 pertaining to plaintiff's passport.
JURISDICTION
United States of a federal official or agency is a party.
Claim arises under the Constitution, laws, or treaties of the United States.
Violation of federal rules and procedures, civil rights.
Diversity of Citizenship (a matter between citizens of different states in which the amount in controversy exceeds $75,000.00).
I.
3. The plaintiff, Jane Doe, is a resident of the State of Vermont. The individual defendants are the director of Office of Child Support, State of Vermont and the Office of Child Support state of Georgia. Jane Doe/John Doe, is the director of the office of child support on behalf of the state of Vermont. Keith Horton, is the director of the office of child support for the State of Georgia and herein are named in this official capacity on a cause of action arising under 1361 of Title 28 of the United States Code, Social Security Act Title 42 U.S.C and the Deficit Reduction Act Title 42 U.S.C, and regulations promulgated thereunder, as hereinafter more fully appears. The Office of Child Support is named as defendant on a cause of action for review of arbitrary administrative actions under 703 of Title 5 of the United States Code. Defendants are hereinafter collectively referred to as the Agency. The matter in controversy exceeds, exclusive of interest and costs, the sum of $75,000.00.
II.
4. The is an action for declaratory judgement pursuant to Title 28 of the United States Code 2201 for the purpose of determining a question of actual controversy between the parties as hereinafter more fully appears.
III.
5. The Office of Child Support, directors, at all relevant times, has unjustly denied and refused to allow plaintiff access to the agency under applicable governing laws. Furthermore, the agency has refused to act in accordance with it's manuals pertaining to closer of a case due to an alleged custodial parents refusal to assist the office of child support and continues to drag out the alleged case for the sole purpose of harassment and economic percussion of plaintiff for standing on her constitutional rights. On January 10th, 2012 or thereabout the agency, by way and through Delores Hill, Personal Advocate, Georgia Department of Human Services – Division of Child Support Services, sent a letter claiming plaintiff to be in arrears of $24,872.78 dollars. (see exhibit P-A). On or about 7/30/2012 the Division of Child Support Services, sent a Status Update Letter claiming plainitff to be in $20,521.66 in child support arrears. (exhibit P-B)
6. On or about August the 29th, 2006, Mr. Adam Todd George, a pilot with Atlantic Southeast Airlines, received and obtained a copy of plaintiff's Social Security Statement in contrary to federal laws at his primary residence located at 4723 Bradford LN, Powder Springs, GA 30127.(exhibit P-B-1) Plaintiff has never resided at this residence and the SSA and the IRS confirm that she did not change her mailing address. Their computer systems show her last known address as 1407 Country Park Dr, Smyrna, GA 30027 (Exhibit P- B-1.1) Per the Social Security Administration on August 29, 2006, evidence Mr. George, his attorney, and the court had in possession. Plaintiff's earning in the year 2005 is recorded as: $6,419. (Exhibit P-B-1) According to the SSA, in 2006 and 2007 plaintiff's earned income is recorded as actual: 2006-$6647; 2007-969. According to SSA Plaintiff's earning ability is recorded as: $14003, 2009- $4.00, 2010-$16324.00, 2011-0.
7. On or about December 2008, Plaintiff was furloughed from her company, Comair Holdings, Inc. and income dropped to $99.00 a week from the maximum allowed unemployment benefits. At no time did the OCS or Mr. George move the Kentucky court or the Kentucky Cabinet for garnishment of plaintiff's unemployment insurance compensation. Plaintiff returned to her full-time position with Comair Holdings, Inc. In July 2010, or thereabout. On or about 02JAN12, plaintiff was once again furloughed from Comair Holdings, Inc. due to reduction in work-force. Comair Holdings, Inc. announced it's plans for ceasing of operations effective 29SEP12. There has been and continues to be a material and unforeseeable change in plaintiff's finical ability towards gainful employment. Pursuant to SSA statements, plaintiff has never made an amount of income to warrant alleged child support in the amount of $601.00 a month to Mr. George who makes upward of a six figure salary and ships the minor child off to his parents for 3 months during the summer.
7. Prior to January 13, 2012, Mr. George, the alleged custodian of Alexander Garrett George, refused to supply the illegal garnishments from plaintiff's bi-weekly paychecks from her employer Comair Holdings, Inc. Comair Holdings. The alleged garnishment, which provided Ms. Adams no service or notice or opportunity to be heard. The alleged garnishment was sent directly to Mr. George located at his primary address 4723 Bradford Land, Powder Springs, GA 30127 contrary to O.C.G.A. According to O.C.G.A the alleged garnishment was to go to the office of child support and/or court and then be turned over to Mr. George. The alleged garnishments payments where served directly upon Mr. George in the following months (see exhibit C): 2008 for the months of Aug, Sep, Oct, Nov, totaling in 2008 $1890.88; 2009 Jul $2.32 (exhibit C); 2010 Jan - a tax return in the amount of $1086.41; Aug, Sep, Oct, Nov, Dec, in the amount of $4194.96; 2011 Jan, Feb, Mar, Apr, May, Jun, Jul, Aug, Sep, Oct, for the amount of $6445.17, and 2012 Jan for the amount of $301.00 and Nov for the amount of $301.00. (see attached exhibit C) For a total of $12533.33 paid in alleged child support contrary to federal and state mandates. From 01JUL11 or thereabout, plaintiff has attempted to correct the issues surrounding the alleged child support with the office of child support both at the Division of Child Support Services Cobb County and Georgia, and the Georgia Department of Human Services Child Support Services, and the Office of Child Support in the State of Vermont. To-date, plaintiff has been denied access to the federal agencies in order to correct the issue at hand. Pursuant to the United States Court of Appeals for the Eighth Circuit 8 F.3d 1258; 1993 U.S. App. Lexis 26605 held:
“The United States District Court for the District of South Dakota entered judgement in favor of applelles, a class of Indian mothers, recognizing their rights to enforce claims for child support enforcement services under Title IV-D of the Social Security Act (Title IV-D) 42 U.S.C.S 651 et. Seq. Appellants, state social services officials and the Health of Human Services secretary (secretary) sought review.” The overview is that “[t]itle IV-D imposed mandatory requirements, Title IV-D itself did not provide a comprehensive remedial scheme that left no room for additional private remedies. The class had no alternative enforcement remedy because the state had refused to assist them in obtaining Title IV-D services to which they were entitled.”
8. The Deficit Reduction Act of 1984 provides that a non-custodial parent of an Aid to Families with Dependent Children (AFDC) child makes a support payment to the state pursuant to a plan under Title IV-D of the Social Security Act, 42 U.S.C.S 651 et. Seq., the AFDC families under 42 U.S.C.S 657(b)(1). If a state fails to comply with any of the Title IV-D child support enforcement regulations, it risks losing federal matching funds, this includes the Deficient and Reduction Act of 1984 section 7302, mandatory review and adjustment of alleged orders.
9. In the Deficient and Reduction Act of 1984; the Office of Child Support is mandated to review, investigate and adjust any alleged child support order which they are attempting to enforce. The office of child Support for the State of Vermont and Georgia denied the Plaintiff her federal rights by refusal to act in accordance with the Social Security Act 45 C.F.R 303.3(b); must periodically review and adjust child support orders. The mandates of the Title IV-D of the Social Security Act of 42 U.S.C.S 651 et. Seq. are particular and specific enough to impose binding obligations on the State of Vermont and Georgia, and accordingly, create substantive enforceable rights in a class. The IV-D of the Social Security Act, 42 of the U.S.C.S 641 et seq. Contains an enforcement scheme in the form of fiscal sanctions the federal government may assert against the state, but these remedial measures are neither comprehensive nor available to the class. The federal government's authority to audit and impose monetary sanctions does not constitute “comprehensive” remedies.
10. The district court describes the AFDC program as a “federal-state cooperative effort administrated by the states.” Howe v. Hellenbecker, 774 F. Supp. 1224, 1226 (D.S.S 1991). Under the program states make monetary payments to financially needy families, including children deprived of parental support...if a state operates its plan in compliance with the statutory requirements and regulations promulgated by the Secretary of Health and Human Services.”
11. In order to have standing in federal court, plaintiffs must show that they have suffered or are about to suffer a 'personal injury' that is “fairly traceable” to the defendant's conduct, and that the injury is “likely to be redressed by the requested relief.” Allen v. Wright, 468 U.S. 737, 751, 82 L. Ed 2d 556, 104 S.Ct 3315 (1984). First Congress expressly provided in 42 U.S.C 651 that the purpose of the Title IV-D is to “assure that assistance in obtaining support will be available... to all children.” Alexander George is being denied support due to the office of child support in the State of Vermont refusal to effectuate and enforce the valid order dated August 2009 on behalf of plaintiff.
Finally, the decisions of other courts are consistent with the view that Title IV-D was intended to benefit needy families. See Carelli v. Howser, 923 F. @d 1208, 1211 (6th Cir. 1991)(Title IV-D was intended to benefit both AFDC families and “the public fisc” by reducing public welfare); Behunin v. Jefferson County Dep't of Social Services, 744 F. Supp.255, 257-58 (D. Colo. 1990) Congress enacted Title IV-D to reduce welfare costs where this court can conclude that Congress enacted Title IV-D to benefit “putative plaintiffs” such as Ms. Adams. Once a state decides to enter the AFDC program, the requirements of Title IV-D and its corresponding regulations are mandatory and unambiguous. Thus the deficit reduction Act is mandatory and shows that the law which the office of child support is attempting to enforce is in conflict with the Deficit and Reduction act which is intended to reduce welfare.
The office of child support has a duty to plaintiff to act in accordance with the Deficit and Reduction Act pursuant to the Social Security Act of 42. U.S.C.S code. The Office of Child Support has breached that duty by denying plaintiff her mandatory review and/or adjustment to any alleged child support orders which is presently affecting her ability to obtain gainful employment with three corporations by denying her access to her mandatory job-required passport and applicable visas.
The Agency assets rule 42USC 654(31) of the United States Code. The agency to-date has refused to supply any agency rules which would allow for expectations to this law which it asserts under the specific circumstances pertaining to the alleged case of plaintiff prior denial of due process of law; denial of applicable appeals, denial of access to the court under the American With Disability Act of 1990 under the 504 rehabilitation Act; and has afforded plaintiff no legal remedy to address the issue of the alleged child support. (exhibit P-D-1) When Plaintiff, on or about 12JUL12 at 4:02:32PM via certified mail 70110110000228673858 and 701101100022867365 provided notification of the agencies duty to act in accordance with the Deficit Reduction Act of 2005/Amended 2007 act. Sec 7302 Mandatory Review and Adjustment of Child Support Orders for families receiving TANF, the agency failed to preform their requirements and agreement under the Social Security Act annexed hereto as Exhibit E. It provides in part: “[t]he commission or any respondent may file a motion in the case to set aside such consent settlement in whole or part on the grounds that the public interest so requires; and after opportunity for hearing upon the issues formed, the agency may, if it finds that a change of law or fact, or the public interest so requires, set aside the consent settlement or any part thereof which is separable from the remaining provisions without changing their effect. Therefor, the agency may, by adversary proceeding harm the public interest and private interest of plaintiff, and the minor child Alexander George.
Plaintiff is attempting to obtain gainful employment and as such is subject to a mandatory requirement to have in her possession a valid passport and the ability to obtain visas in the future for such employment. Plaintiff has attempted to interview with three different company's, the most recent on January the 5th, 2013 at 4:41 pm or thereabout. Plaintiff's application is placed on hold, (see exhibit P-D-1.1) On the 5JAN13 plaintiff was denied moving forward in the application process as a direct result of the issue surrounding her passport and the Office of Child Supports refusal to allow her access to the agency in order to correct this issue at hand by their failure to enforce the valid August 9th, 2005 order. (exhibit P-D-1.2)
Plaintiff, had a witness to this interview process, who attest to the freeze of Plaintiff application. (P-D-1.3) Plaintiff, has had two emails since the freeze of her application from the company which she is seeking employment, demonstrating the potential to move forward in the application process when the passport issue is resolved and her passport is released to her. (Exhibit P-D-1.4) Plaintiff, has attempted to address the issue of her passport with Mr. George in order to quickly effectuate release of her passport and her name removed from the passport denial program, which has been submitted in opposition to due process of law due, overt violations of laws, and breach of agencies duties. (exhibit P-D-1.5).
Plaintiff has exhausted her administrative remedies and has been denied access to further administrative remedies and had no specific statutory remedy under the Social Security Act in which to address the issue ripe before this court. Only review of the administrative action by this court pursuant to the statues aforesaid and issuance of injunctive relief can relieve plaintiff from being denied administrative due process by being twice tried on the same charges, being made subject to two orders on the same facts, being twice unjustly publicized as a law violator, and from having its property taken without a hearing.
Demand for jury trial pursuant to FED R Civ P Rules 38(b), 57.
Wherefore, plaintiff prays for
1. The said Title 22 section 51.90 regulation be declared null and void, of no effect, and unauthorized by law.
2.That the court restrain defendants, their officers, employees, agents, and servants from enforcement of the regulation.
3. That pending the final hearing and determination of the court of this matter, a preliminary injunction be issued restraining defendants, their officers, employees, agents, or servants from the enforcements of the regulation.
4. That the court issue such other and further relief as it deems necessary and proper.
5. A judgement of this court pursuant to 2201 of Title 28 of the United States Code declaring the rights of the parties under the deficit reduction act section 7302 and the inability to obtain due process of law.
6. A mandatory order of this court pursuant to 703 of Title 5 of the United States Code and 2202 of Title 28 of the United States Code requiring defendant to withdraw the alleged case from the Office of Child Support denying plaintiff her passport and subjecting her to continued economic persecution in opposition to law and confine any further efforts to rescind its prior action to the agreed procedures of the law requiring agency's and courts to act in compliance with Due Process of Law.
7. A temporary restraining order and preliminary stay of the agency proceedings and alleged actions taken in opposition to plaintiff's passport and removal of her name from the passport denial program to the secretary of state and the department of state.
8. Such other and further relief as deemed necessary
9. Attorney fees.
10. fees and cost associated with bringing this action and such other relief deemed appropriate.
Respectfully submitted,
Dated : 01/14/2013 PO BOX 3154
Burlington, VT 05408
All rights reserved UD-UCC
VERIFICATION
I declare under penalty of perjury under the laws of the State of Vermont, that I have read the above complaint and I know it is true of my own knowledge, except as to those things stated upon information and belief, and as to those I believe it to be true. Executed on this 15 day of January 2013.
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