KATIE LEE

Plaintiff (Pro-se)
v.
. - RONDA BEGAY-
- DEFENDANT -
- TAMARA BRADFORD-
-DEFENDANT-
- MS. NETZEL -
(county social worker supervisor)
-DEFENDANT -
ET.AL.,
vs.
- The COUNTY of SAN BERNARDINO -
-DEFENDANT -
-Department Children and Families Services-
-DEFENDANT-
et.al.

PURSUANT TO U.S.C.

TITLE 42 SECTION 1983 claim et.al.,

A claim for relief shall be stated, by the injured party herein; refer to as “K.L.” to be served within
time allowed, by certified mail, or, via served by a magistrate, or Process Server, to effectuate service per
defendant being sued, in a timely fashion, to all defendant(s) being placed on one’s Notice of Intent; my
 constitutional rights, per civil violation, caused by the liable defendants, Social worker(s) as the

supervisors in charge of such casework duties, all took part, in the illegal and unlawful seizure
of my child, involving a warrantless removal, and conspiring between, San Bernardino County
Department Children Family Services employees, and, the "ALLEGED" Paternal family, as shall
be more expound throughout such lawsuit proceedings ,once federal suit has been
filed accordingly and timely, for damages, relating to the wrongful, unlawful and
warrantless removal of my child, in clear violation of, the constitutional rights of myself
and, my little boy.

I have not seen my child since (last spring), not regularly, and my child has
been cut off from me, where physical visit(s) have been sparse to none, as such
rights have been little to none, due to incompetance of state employees, not
following thier procceedural protocol, and, as a result, they are in clear violation
of, one’s constitutional right, to have access, to their child, in the state of
California, as long as the right, to such child, has not been legally terminated, at
time of violation.

Social workers are now pushing to, and or, are illegally preparing to on or
about December 8th, 2022, to sever my constitutional right, to my son, without
a legal basis to do so.

Such removal was based on false information, intentionally and knowingly

done by all, and or those who has had first hand knowledge, at the time of the
illegal removal that the court order (Detention Warrant) or the lack thereof of,
being non existant, tampered with, and or altered, to fit a narrative of what
DCFS employees, now being sued, wanted the judge to believe or be reliant
upon, was completely fabricated information FROM MAY and JUNE of 2021,
provided by such caseworkers, social workers being placed on required notice,
of the injured plaintiff, myself, herein; refer to as “K.L.”, and or, refer to as the
injured plaintiff, shall be placing defendants on required notice of one’s
intention to sue, PRIOR, to such civil rights lawsuit for damages, that shall be
filed, in due time, against per defendant, violating one’s rights.
-Supervisor MS. NETZEL, as the other defendants, TAMARA
BRADFORD, and RONDA BEGAY, conspired, to, outrightly deprive the
injured plaintiff , KATIE LEE, the right to raise such child, without
unlawful governmental interference, based on the fabrication of such
information, and, the illegal act pertaining to swearing to facts, known to
be false.

Defendant T. BRADFORD, and or, Defendant R. BEGAY, and or, supervisor MS.NETZEL,
conspired to, outrightly deprive me such right, to DUE PROCESS, and, lied under oath,
therefore, knowingly and willfully, causing myself and my family harm, when such defendant
allowed their subordinate(s), their social workers to file a false and or, knowingly false
detention report (as to why my son should be removed based on “imminent danger", and while,
"acting under the color of law", knowingly and willfully, further instructed the child's "alleged"
father, to go ahead, and violate the stipulations clearly set forth in a pre existing child custody
court order.

None of these false claims, on the day in question, as shall be proven existed. More shall be
shared in plaintiff`s official suit for civil right damages. Just a general descriptive, at this time is
warranted, to satisfy per notice requirement.

These individual defendants alluded that there was imminent danger at the time of my child,
being illegally and unlawfully detained, and or, withheld from me, (without a court order) , then
filed in court, to seize custody/control of the plaintiff`s happy and healthy child, who was
immeadiatley placed not in state dcfs foster care, but, was placed in the home of his
"ALLEGED" father, (whom has a conviction for corporal injury to a child, and numerous
manufacturing narcotics charges amongst others), and, the mother, of the "ALLEGED" father.
More shall be divulged, once plaintiffs injury civil rights lawsuit is soon filed.

Caseworker attempted to invoke the prior issue, and or, citing in false papers, that I am “unfit.”
Such was a falsity, and, clearly known to the defendants, citing such falsities as factual,
causing me harm.
SET OF FACTS THAT GIVE RISE TO PLAINTIFF CLAIM.

On or about:
(DATE OF INITIAL OCCURRENCE MAY 2021)
05/2021:
LOCATION of the violation (occurrence) taking place was my place of residence (and
dates throughout the entire year of 2021 and also so far in 2022)
My happy, healthy, and beautiful child was safe, and, was absolutely to my best of knowledge,
not at imminent danger of serious injuries, risk and or harm. My child was on a court ordered,
visit with the ALLEGED father, and paternl grand mother, on the day in question, furthermore,
proving that there is no way, my child couldve been in any imminent danger in my care, if the
child wasnt in my care? The above named defendants, furthermore instructed the ALLEGED
father, to WITHHOLD my child from me, clearly, and outrightly, undermining a pre exisiting
court order regarding visitation and custody, already in full effect.

The Defendant, based on false information, erroneously altered a report(s), for which is illegal,
and or, garnered false information, to remove my son, from my home, and conspired with
others, (later to be discussed in suit) to see to it, once the child is removed from my primary
residential and loving care, he will be able to be illegally adopted by a woman, of whom is
either “friends, and or, too friendly” with defendant.

My son, on the day of his illegal unlawful and warrantless seizure, in violation of such
well-established FOURTH AMENDMENT right was:
➢ Happy and Healthy
➢ Cared for
➢ and most importantly SAFE
➢ Loved by me, his loving mother, the injured plaintiff, now suing, herein; refer to as”K.L.”
At the time of the state worker forcing my child into state custody and detainment, there was
a lacking of imminent danger, my child was fine. DEFENDANT MS. NETZEL,
DEFENDANT TAMARA BRADFORD, (and or) DEFENDANT RONDA BEGAY, engaged
in, removing my child, without a warrant, or warning, and or, altered/tampered with “removal
order/ detention warrant" and petitioned to such court to remove my son, after he was already
removed, with information that was either:
1.) Known to be false, at time of lying to the court under oath and under penalty of perjury
and or
2.) Knew at the time that the erroneous and false information was being provided, to get a
 judge to “sign off”on the purported “imminent danger”, defendants should have known the
harm it would do to me, and my son, and indeed, has caused the worst harm possible, (also
known as, the " Parental Death Penalty", in dependancy cases) as the same defendants liable
for damages, are seeking to, and or, already have terminated my constitutional rights to my
child, Jack Rose.

3.) DEFENDANT TAMARA BRADFORD, DEFENDANT RHONDA BEGAY, and,

DEFENDANT SUPERVISOR MS. NETZEL, have failed, to adhere to their own
caseworker duties, by the failure to reunite me with my child, even though, there is no legal
basis to keep him from me, and or, that have chosen to ignore the progress I’ve clearly made,
such as to engage in services.

4.) All defendants aformentioned, took part, in a CONSPIRED action, and, colluded to
deprive, me, the BIOLOGICAL mother, the right, to have her child home, by
unlawfully seizing my child, without a warrant, and then, illegally submitting knowingly
false information, to see that my child remains out of my primary care.

All defendant(s) the caseworkers, (social workers)shall be sued, not only in their official
capacity, but, their INDIVIDUAL personal capacity as well, for damages, associated with such
lawsuit, being filed. Defendants engaged in, fraud upon the court, and, malfeasance during
entire year of 2021 and 2022, removing my happy, healthy and un harmed child from my
residential care, knowingly and willfully, leading to the destruction of the loving, healthy,
natural bond, between a son & his biological loving mother.

While swearing under oath, defendants lied, engaged in, perjury and had kept documentation
from me, involving my case, while she feign, that she had done everything she could, NOT TO
remove my child from my home, and, she claims, she has done everything she could, NOT
TO terminate my rights, and or, has lied under oath, to make it “appear” there was just “no way
my son and I can be reunited happily, healthy and safely, and or, that he would be at serious
risk, and or, seriously injured, if Jack Rose, was to remain living with his mother.

Such parent has a constitutional right, to raise one’s own child, as such BEST interest of the
child is paramount, and yet, defendants illegally, engaged in fraud upon the court, and
malfeasance, to undermine, one’s ability to parent their own child, hence, as a result, along with
such stated claim for relief, under the 4thamendment, “ILLEGAL SEARCH AND SEIZURE”,
and, the 14th amendment, “DUE PROCESS CLAUSE”. Pursuant to the fourteenth amendment,
causing severe emotional distress, as a result of such nefarious act(s) illegally done, by such
liable defendants, such right, has been, and or, is about to be severed, giving rise to such
lawsuit, per civil right violation against these liable defendants. Such legal right, to have a
steady flow of visit(s), time with my own child, has been clearly violated, along with my sweet
little boy, as such caseworker(social workers), under the direction of her supervisor, has failed to
craft a flexible visitation schedule to fit the complex needs of a families unique circumstances,
and, also all the while, failing to work toward reunification.

CLAIM AGAINST SAN BERNARDINO COUNTY

The County, through its agency, “DEPARTMENT CHILDREN & FAMILY SERVICES”, are
being sued for : once again, failing to train their employees, as such County Agencies are
required to do by state and federal law, premised on (based on) the fact, they work, (and or)
operate under a policy, customs, and practice, by which such defendant(s) DCFS, the County
of San Bernardino are required to do.

DCFS Employees , "acting under color of law", to seize one's child, regardless of whether the
statutory requirements of, "imminent danger” “serious harm" and or such "substantial risk" have
been met,

as such failure to train, once again, as in other lawsuit(s) prior filed against the County, as such
failure has caused, yet another child to be abused, traumatized, and or, harmed under state
supervision and care, of DCFS defendants, allowing also such workers to: present (knowingly)
false evidence, information, and or, reports with such intentional, per defendant, such
fraudulent documentation, in violation of HIPAA law(s) regulations, causing injury, and filing
false affidavit(s) to make it “appear” there was imminent danger, risk of serious injuries, and or,
harm, yet, none of these circumstances even existed, or to disseminate false information, while
knowing it is false, neglecting to adhere to state federal law and policies, warrantless removal
and failure to reunite.

County shall be served separately, in a timely fashion, copy of such warranted civil rights
lawsuit, being filed timely.

Plaintiffs 14th Amendment has been violated, as DUE PROCESS CLAUSE, under
fourteenth amendment, along with one's 4th amendment, ILLEGAL/UNLAWFUL
SEARCH AND SEIZURE, when DEFENDANT(s) removed such child, and shall be
proven, that at the time of such illegal seizure, premised upon the fact, that no warrant was
provided to Myself, the mother of said child, for the detention of my child, at time of his
illegal removal, and it shall further be proven that there was no imminent danger,
whatsoever, period. The Defendants then, on knowingly false affidavits, false petition(s)
and or, (false facts) , known to be false, then willfully, with malice, submitted it to a judge,
after the fact, knowing that the judge would be placing such high reliance on thier
fraudulent act(s) on the day in question, clearly, in violation of our rights.

AMOUNT OF DAMAGES SOUGHT BY PLAINTIFF:

( 40 ) FORTY MILLION DOLLARS

PUNITIVE DAMAGES ALSO SHALL BE SOUGHT.

DATE:

__________________

SIGNED:

_____________________________
KATIE LEE