IN THE UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT PAUL SHAFER AND JOSHUA HARDER. ) ) Plaintiffs, v.

RODERICK BREMBY, Defendants. ) ) ) JUDGE THOMPSON CASE NO. 3:12-CV-00039-AWT

MEMORANDUM IN SUPPORT OF ROBERT B. DAVIS MOTION TO INTERVENE AND IN OPPOSITION TO DEFENDANT BREMBYS MEMORANDUM IN OPPOSITION TO THE DAVIS MOTION TO INTERVENE As aptly noted by Defendant Bremby, the District Court has wide latitude in determining whether Intervention should be allowed. The key is whether or not there is any undue prejudice to Defendant, and in this case there simply isnt any undue prejudice to Defendant because Defendant has known for quite some time that the DSS inefficacies were causing families substantial heartache and grief. To wit, during the pendency of this case Intervenor King has witnessed Defendants repeatedly lie about their malfeasance, only to see the Truth come out with Intervenors archived email, see for example the July 20, 2012 email from case worker Diane Wood to Christopher King, J.D. as power of attorney and attorney-in-fact for Intervenor (see p. 2 of this Memorandum). Again, in such email Ms. Wood clearly indicated that the problems for the delays were all manifest from the DSS side of the equation. Moreover, the Court has time to rule on the Intervention such that Intervenors King and Davis may yet be included, and as we recall Intervenor King filed for Intervention half a year ago. The Court is aware of its schedule and has already, ipso facto incorporated time to administer the King Intervention and to incorporate her arguments at trial and the same issues countenanced by her Intervention are at play in the Davis Intervention.1 This is a bellwether case against government irresponsibility. Defendant Bremby continues to soldier on denying any accountability even in the face of emails that prove Intervenor King timely submitted financials and that the delays were the fault of Defendant.

Intervenor King assumes that the Court has not already made up its mind to dismiss her Motion to Intervene and attendant Motions to Strike the Flattery Affidavit and for Rule 11 Sanctions and is just stringing her along for the ride.

Even the Department of Homeland Security and the Department of Defense are reading along because they obviously know the significance of this case, and they too know that it is high time for Defendant Bremby to accept responsibility for his Departments (in)actions.

As such, an impartial trier of fact can see that it is a specific, overarching Modus Operandi and these Affidavits one from a daughter and one from legal personnel completely

buttress Ms. Kings position in this matter and Ms. Kings filings completely buttress the Davis filings. DSS Commissioner Bremby told lies against a grandmother with Alzheimers, which is about as low as a human being can go, and in that same twisted and sad spirit, in order to try to avoid telling lies about another elder, they move to strike the Motion to Intervene as untimely. Lastly, there is an implication that there is a lot of media coverage on this case, and that the knowledge of Attorney Toubman is somehow imputed to that of the Davis family. That is ridiculous. In the first instance most of the media coverage on this case has come from Betty J. Kings son, Christopher King, J.D. as a quick Google search will reveal pursuant to the following search: Title XIX lawsuit Connecticut http://tinyurl.com/d4fm7ce Almost all of the entries on the front page of Google are generated by and through KingCast, or Chris Kings First Amendment Page as the major press has never truly engaged in this case in any meaningful way. See p. 3 of this Memorandum. The Court may take Judicial Notice that while Mr. King has worked for large daily press, his literary efforts in this matter are more akin to the penny press and are not universal knowledge. As such, any implication that Intervenor Davis sat on his hands while his family struggled to get the respect that they are owed from Defendant is sadly misplaced, as such blame is better directed at Defendant.

CONCLUSION Defendant Bremby will sink to any level to avoid bearing responsibility for his departments gross malfeasance. Only this Honorable Court can see to it that he is held to answer for the misdeeds that have broken countless hearts across the State for months and years on end. /s/ Christopher King, J.D. _____________________________ Christopher King, J.D. http://KingCast.net -- Reel News for Real People kingjurisdoctor@gmail.com 617.543.8085

CERTIFICATE OF SERVICE I the undersigned, solemnly swear that a true copy of this Memorandum Was delivered via ECF service on 28 March 2012 to the following.

Defendant Roderick Bremby c/o Jennifer L. Callahan, Esq. ct 29033 c/o Hugh Barger c/o Rosemary McGovern CT AG 55 Elm Street PO Box 120 Hartford, CT 06141 hugh.barger@ct.gov rosemary.mcgovern@ct.gov

Plaintiffs Shafer and Harder Sheldon Toubman (ct08533) New Haven Legal Assistance Assoc. 426 State Street New Haven, CT 06510-2018 Phone: 203.946.4811 Fax: 203.498.9271 stoubman@nhlegal.org /s/Christopher King, J.D. __________________________________ Betty J. King By and through Christopher King, J.D. 617.543.8085m