Christina Dawn Illsley

Post Office Box 1765

Great falls, Montana 59403
Telephone numbers:
Daytime # (310) 341-4257
Evening # (310) 941-1804

Case No. CK61041

SUPERIOR COURT OF CALIFORNIA

COUNTY OF LOS ANGELES
201 Centre Plaza Drive
Monterey Park, California 91754

Hearing Date Hearing Time Dept. / Room Hearing Type/ Subtype

08/22/2007 08:30 a.m. 407 Special/TPR

IN THE MATTER OF

Name Date of Birth Age Sex Court Number

Justin Croix Illsley 01/13/1999 8 M CK61041

(Hoffman)

CHILD (REN) WHEREABOUTS

Justin has lived with his Aunt Cindy VanDeKop, 223 25th ave South, Great
falls, Montana for a year. As of August 12, 2007 moved from Aunts home to
confidential address due to the fact of CPS abuse toward the VanDeKop's
family became unbearable.

PARENT / LEGAL GUARDIANS

Name / Address / Relationship/

Birthdate Phone To Whom

Christina Illsley P.O Box 1765 Mother/

March 18, 1961 (310) 341-4257 Justin Croix Illsley
Robert Peter Hoffman Unable to Locate Father /
June 13, 1963 Unknown Justin Croix Illsley

ATTRONEYS Address/Phone Representing

SUI JURIS P.O. BX 1765, Great Falls Christina Dawn Illsley

Montana, 59403

Raumak Eshraghi 201 Centre Plaza Suite 7 Justin C. Illsley

Monterey Park, Ca. 9175-2178
(323) 526-6257

Roy Daniel 201 Centre Plaza Suite 1 Child Welfare

Monterey Park, Ca 91754

I CHRISTINA DAWN ILLSLEY SWEAR IN AS FOLLOWING:

FOLLOWING MOTION AND DECLARATION OF CHRISTINA ILLSEY,

1. MOTION TO REMOVE NATHAN HOFFMAN AS COUSEL FOR CHRISTINA

DAWN ILLSLEY.

AFFIDAVIT TO SHOW CAUSE:

Nathan Hoffman has violated

TITLE 28 >PART II > CHAPTER 31 > SUB SECTION 530B. Ethical standards

Nathan Hoffman has not acted in best interest of Christina Illsley. Failure to
submit evidence. Failure to Motion the court in best interest of Christina Illsley.
Failure to defend, allowing heresy to be presented as fact on record. Nathan
Hoffman failed to provide Christina Illsley with any and all of requested case files
pertaining to all case hearings.

EXHIBITS

A. See attached letter from Dr. Patrick David PhD

B. See attached motions requested by Christina Illsley

DECLARATION OF CHRISTINA D. ILLSLEY

I, CHRISTINA D. ILLSLEY, declares as follows:

I am over the age of eighteen (18) years and have personal knowledge of each
of matters set forth below. If called and sworn as a witness, I could and would
testify competently thereto.
Sui Juris NO RIGHTS WAIVED
All Rights by the Citizen and None Waived.

Freeborn Natural People, expressly not a corporation

Artiicle. IV.
The Citizens of each State shall be entitled to all Privileges and Immunities
of Citizens in the several States.

2. MOTION TO RETURN CHILD TO HOME OF BIOLOGICIAL MOTHER

CHRISTINA DAWN ILLSLEY.

AFFIDIVIT TO SHOW CAUSE:

For the following reasons:

2a) overwhelming new evidence submitted to the court

As a result of lack of counsel the Christina Dawn Illsley was not allow to submit
the following evidence.

EXIBIT Y Initial Allegations

Michelle Tolosa claims the following:

1. Parent skills negatively affected by drug abuse.

2. Parent does not utilize community resources to he meet the needs of the
child.

3. Parent’s lack of cooperation indicates risk to child.

5. Mother lacks adequate resource to obtain stable residence.

6. Mother has failed provide child Justin with appropriate food, shelter, and also
education.

7. Child’s medical health and medical needs are questionable.

Michelle Tolosa has failed to provide any evidence, to these allegations except
for one invalid U.A. Test. The worker failed to submit my prescribed medication
list. At the test site they advised me not to test telling me the medication I was
taking would result in a false positive. I stated they could always call by doctor to
validate. The Child Protective Services worker and the test site failed to do so.

I called Children Protective Service on Sept.3, 2005 asking Mr. Miller a CPS
worker if he could enforce a court order a had for LA COUNTY to assist my son
and I. We had move out of our home into a nice hotel across the street from
Justin’s school. Justin had been attending the school of Sound of Music in
Redondo Beach for a year. We had moved out of our home where we been
residing for a year. We were having problems with the landlord’s daughter Diane
Tracy. She was an alcoholic whom started to get violent, breaking our personal
property during her temper outburst. I had sought help for a month prior from
various agencies to enable our move. We received Domestic Violence
assistance through the court. I had received compliance letter a month later
stating they were complying by not complying. The letter stated due to my
disability I did not qualify for their assistance.

This is why I called Child Protective Services for my son and my safety. Thinking
Child Protective would have protected us from discrination. Mr. Miller a worker
stated that their Dept could not assist us. But he would send some one later to
see if we were doing alright. That is when Michele came along. She started
verbally abusing me right away telling me I did not look disabled. I try to explain
my disability. I told her this wasn’t a disability issue but a domestic violence issue
and I had a court order. She continued to verbally attack me about my disability
so I finally told her unless she is a Dr. who could x-ray her better back off. This
when she demanded me to take a drug test. I said no problem but be sure you
list my prescribed medication. She did not. Then she came back and accused
me of doing street drugs. That I better admitted it or she would. I stop her and
said what are you going to do take my son if I don’t lie, She said no and I said I
admit I take my prescribed medications but I do not use streets drug and she
insulted me by even stating that. I said look at me my hair, my skin, my teeth if I
was so strung out on street drugs I would not be so healthy. I asked her how
could you even state that to me I have just found a home to move into and a new
job watering plants for several restaurants and hired a new IHSS worker who had
children Justin’s age. I was in the process of enrolling him in a new school after
summer vacation. Her replied was people with this high level of drug in their
system can accomplish a lot. The she went upstairs and took my son from IHSS
worker.

Exhibit H---EVIDENCE OF CPS TAMPERED WITH DRUG TEST RESULTS

DOCUMENTS

Exhibit I---Letters Dr. Bedikian care

Exhibit J---Medical reports and records from Little Company Hospital

Exhibit K---Declarations of Witnesses totally 7 various individuals

Exhibit L---MPI***U.S. Department of Transportation APPROVED and Drug &

Alcohol Testing Industry Association ACCREDITED Collection Facility***
Exhibit H---EVIDENCE OF CPS TAMPERED WITH DRUG TEST RESULTS
DOCUMENTS

Exhibit I---Letters Dr. Bedikian care

Exhibit J---Medical reports and records from Little Company Hospital

Exhibit K---Declarations of Witnesses totally 7 various individuals

Exhibit L---MPI***U.S. Department of Transportation APPROVED and Drug &

Alcohol Testing Industry Association ACCREDITED Collection Facility***

Exhibit Q----Housing receipts prior to illegal removal of Justin Croix Illsley

Exhibit S---Letter to Governor

Exhibit U---Compliance Letter from the County of Los Angeles

Exhibit W---Copy of Justin Croix Illsley Health Insurance Card and other
services including School Records

2b) prior referee did not have JURUSIDICTION:

2c) Child Protective Services Initial Removal of child Justin Croix Illsey was
illegal and unwarranted. Child Protective Services did not obtain a Court ordered
Warrant to remove child Justin Croix Illsley from custody of mother Christina
Dawn Illsley

2d) Children Protective Services fabricated all initial findings and negative
evidence and suppressed all positive findings and evidence

2e) Child Protective Services falsified child identity in order to suppress true
record of fact

2f) Christina Illsley has not been convicted of any crime.

2g) Christina Dawn Illsley has completed all court ordered services

2h) Christina Dawn Illsley has no illegal drug history

2i) Christina Dawn Illsleys drug test results all test negative for drugs and
alcohol
2j) Child Protective Services failed to submit prescribed medication list for Initial
UA test which produces an invalid test result.

2k) Child Protective Service has not produce any testifying witnesses

2l) Child Protective Services removed child Justin Croix Illsley out of LA COUNTY
and place him in ORANGE COUNTY forcing mother to travel back and forth
between counties to achieve court ordered services.

2m) Child Protective Services and prior court referee forces mother to travel from
Montana State to California State for court ordered services and court order
hearings. Request for case to be transfer to Montana denied.

2n) Child Protective Service has failed to provide evidence in this case

2o) Christina Dawn Illsley (mother) and Justin Croix Illsley (child) are not
residents of the state of California but have been residents of the state of
Montana for over a year.

2p) Child Protective Service is in CONTEMPT of court

TITLE 18> PART 1>CHAPTER 21>SUB SECTION 402 CONTEMPT

TITLE 18> PART> CHAPTER 109 > SUB SECTION 2234. SEARCHES AND
SEIZURES

TITLE 18> PART1> CHAPTER 13 > SUB SECTION 246. Deprivation of rights
under color of law.

This Court showed lack of procedural sufficiency.

Christina Dawn Illsley was denied to have right to choose her own attorney.

Christina Dawn Illsley was forced to have court appointed attorney.

Court appointed attorney, Barry Herzog threaten Christina Dawn Illsley , to sign a
paper which denied her of right to present evidence, her right to present
witnesses, her right to face her accusers, and her right to a jury.
Barry Herzog stated that if Christina Dawn Illsley did not shut up and sit down
and sign the paper that he and Child Protective Services would lose her son
Justin Croix Illsley in the L.A. County system. Barry Herog also stated it would be
at least two and half years before any judge will ever see the evidence.

Honor Judge Milton refuses her right to attain another attorney of her choice and
forced her to take another court appointed attorney name Nathan Hoffman.

Honorable Judge Milton refuse to allow Christina Dawn Illsley to exercise her
parental rights forcing her son to be place on unwarranted mind altering drugs
resulting in a plea of help from Justin Croix Illsley to his mother Christina Dawn
Illsley begging for her to make them to stop making him take drugs that he
wanted to be drug free like she had taught him.

Honorable Judge Milton refuses to allow any motions or evidence submitted by

Christina Dawn Illsley into court.

Christina Dawn Illsley have completed all court ordered services, relocated to
Montana, bought a car, obtain housing, obtain employment, provided son with
clothes, shoes, educational expensive, misc. items, allowances.

Child Protective Services refused funding court ordered services

EXHIBITS
C. see attached letter to Judge Milton
D. see attached THE STATE BAR OF CALIFORNIA COMPLAINT FORM
E. see attached motion to court submitted by Christina Dawn Illsley
F. see attached CERTIFIED MAIL RECEIPT

TITLE18> PART 1> CHAPTER 73 > SUB SECTION 1505. Whoever violates
the due and proper administration of the law.

Up to date, Christina Dawn Illsley has not been allowing discovery from Child
Protective Services on any or all hearings.

EXHIBIT
E. see attached motion to court submitted by Christina Dawn Illsley

Child Protective Services has failed to prove all or any evidence against Christina
Dawn Illsley.
Child Protective Services, Cerise Dossman refuse to release copy of records,
documentation, files, or any paperwork pertaining, or relating to the this case.

EXHIBIT
E. see attached motions to court requesting thereof
G. see attached signed request letter to release records

Child Protective Service failed to provide or pay for court ordered services.

EXHIBIT
E. see attached motion to court submitted by Christina Dawn Illsley
V. see attached unpaid court ordered services

TITLE 18 >PART 1> CHAPTER >73> SUB SECTION 15009. Obstruction of

court orders.

Child Protective Services, case worker Roy Weinberger refused to release any
and all information needed by Patrick Davis PhD., to perform court ordered
Psychological examination which resulted in termination of reunification service
for Christina Illsley.

EXHIBIT
A. see attached letter written by Dr. Patrick Davis PhD

Dept. 407 court clerk failed to provide court order for psychological evaluation to
Patrick Davis PhD. In fact, Dept.407 court clerk inform Patrick Davis PhD that
there was no such order.

EXHIBIT
A. see attached letter written by Dr. Patrick Davis PhD

TITLE 18 > PART 1 > CHAPTER 79 > SUB SECTION 1623. False declarations
before grand jury court.

Child Protective Services worker Michelle Tolosa falsified documentation

submitted to court, to cover up her illegal removal of Justin Croix Illsley.

Child Protective Services worker Michelle Tolosa falsified Justin Croix Illsley’s
name as Justin C. Hoffman to court so no school records, or medical records or
such could be found.

Child Protective Michelle Tolosa fabricated negative evidence and suppressed

positive evidence.

.Child Protective Services worker Investigator Tamika Love fabricated negative

evidence and suppressed positive evidence to court to cover up illegal removal of
child Justin Croix and enable Child Protective Services to obtain temporary
custody.

Child Protective Services worker Cerise Dossman fabricated negative evidence

and suppressed positive evidence and declarations to the court to justify
termination reunifications services and reason for TPR.

Child Protective Service fabricated drug history. Christina Dawn Illsley has no
illegal drug history

EXHIBITS
H. see attached EVIDENCE SHOWING CPS TAMPERED WITH DRUG
TEST RESULTS DOCUMENTS
I. see attached letters from Dr. Bedikian care
 J. see attached medical reports and records from Little Company
Mary Hospital
K. see attached Declarations of Witnesses totally 7 various
individuals

L. see attached MPI drug testing site Report

M. see attached Gateway Recovery Center Reports
N. see attached Kaloni Taylor, LCSW update report
O. see attached Parent/ Anger management completion
P. see attached letter by Center of Mental Health, Arlena Cradle
Q. see attached housing receipts
Y. see attached Initial Case Plan - all fabricated evidence and
suppressed evidence.
W. see attached Health Insurance Card and other services, including
School Records

3. MOTION TO ALLOW MEDICAL REPORTS FROM TREATING MEDICAL

SPECIALISTS OF CHRISTINA ILLSLEY SUPPORTING FALSE POSITIVE UA.

AFFIDAVIT TO SHOW CAUSE:

3a) Medical Reports from Little Company Hospital specialist stating no

intoxication and no addiction and no sign of withdrawal at time of illegal removal
of child Justin Croix Illsley.

3b) Medical Reports stating prescribed medication Christina Dawn Illsey was
prescribed at time of False UA result.

3c) Medical Reports and letters from Dr. Bedikian Chiropractic Care, treating
doctor.
4. MOTION TO PRESENT EVIDENCE OF DISABILITY DISCRIMINATION

AFFIDAVIT TO SHOW CAUSE:

EXHIBITS
K. Declaration of Witnesses
Q. Copy of Discrimination Complaint Filed
R. LA COUNTY Compliant letter
S. Letter to Governor
T. Prior court orders to assist
U. Compliance Letter from County of Los Angeles
Aa. Domestic Violence Fund LA COUNTY denied me causing me to go
to Child Protective Service asking for help to enforce court order instead
Child Protective Service too my son away.
23
5. MOTION TO PRESENT WITNESSES

Dr. Vic Bedikian

Treating Doctor for Christina Dawn Illsley, who has prior knowledge of

Katrina Williams
Close friend of the Illsleys who has prior knowledge of

Tara
Close friend of Illseys, babysitter, and mother of Justin Croix Illsley close
friends, who has prior knowledge of

5. MOTION TO PRESENT WITNESSES CONTINUED

Christina Dawn Illsley

Mother of Justin Croix Illsley

CONCLUSION:

Christina Dawn Illsley Constitutional Civil Right for counsel has been
violated in this case against her. Due to lack of proper counsel, and
defense, the Initial Jurisdiction findings were incorrect. An overwhelming
amount of fabricated negative evidence by Child Protective Services was
allowed on record as fact. Child Protective Services initial removal of her
son was obtain illegally and without warrant. Her son Justin Croix Illsleys
welfare and well being was threaten and used as a tool to force her to give
up her right to submit evidence, her right to present witnesses, and her
right for a jury trial. Based on the evidence and testimony of witnesses in
her behalf I respectfully ask the court for an immediately dismissal of this
case and the prompt return of her child Justin Croix Illsley back to her
custody with complete parental rights intact.

EXHIBITS ATTACHED AS FOLLOWS:

Exhibit A-- Letter from Dr. Patrick David PhD, works with Child Protective
Service in the state of Montana.

Exhibit B—MOTIONS requested by Christina Dawn Illsley

Exhibit C—Letter address to Judge Milton

Exhibit D—THE STATE BAR OF CALIFORNIA COMPLAINT FORM

Exhibit E---MOTIONS submitted by Christina Dawn Illsley

Exhibit F---CERTIFIED MAIL RECEIPT

Exhibit G---Signed request letter to release records

Exhibit H---EVIDENCE OF CPS TAMPERED WITH DRUG TEST RESULTS

DOCUMENTS

Exhibit I---Letters Dr. Bedikian care

Exhibit J---Medical reports and records from Little Company Hospital

Exhibit K---Declarations of Witnesses totally 7 various individuals

Exhibit L---MPI***U.S. Department of Transportation APPROVED and Drug &

Alcohol Testing Industry Association ACCREDITED Collection Facility***

Exhibit M---Gateway Recovery Center Report and fax to lawyer stating

attempts to get in treatment since Sept 2006, but treatment not necessary

Exhibit N---Kaloni Taylor LCSW update report

Exhibit O---Parent/Anger management completion

Exhibit P---Letter by Center of Mental Health, Arlena Cradle

Exhibit Q----Housing receipts prior to illegal removal of Justin Croix Illsley

Exhibit R---L.A. COUNTY Complaint Filed

Exhibit S---Letter to Governor

Exhibit T---Prior court orders to assist

Exhibit U---Compliance Letter from the County of Los Angeles

Exhibit V---Copy of Appeals Brief submitted by Anna Olinger

Exhibit W---Copy of Justin Croix Illsley Health Insurance Card and other
services including School Records

Exhibit X---Copy of Behavioral Service prior of illegal removal

Exhibit Y---Copy of Initial Case Plan with fabricated negative evidence, and
suppressed positive evidence.
Exhibit Z--- Unpaid court ordered services in which Cerise Dossman claims
to have paid.

Exhibit Aa---Letter from employer

Exhibit Ab---Proof of Domestic Violence Victim Witness Relocation

NOTICES Date

Attorney for Child Protected Services August 20, 2007

201 Centre Plaza Suite 1
Monterey Park, Ca 9175-2154

Attorney for Justin Croix Illsey August 20, 2007

201 Centre Plaza Suite 7
Monterey Park, Ca 9175-2178

Nathan Hoffman August 20, 2007

PO BX 333
Culver City, Ca 90232