Tiiea-2a/20is- 272506 JOO? sine O7-731932-NA HOA —~—T-TAWVERE i | CHIG Y N [200° woce us i (GAN | LAWVER/GUARDIAN JUDGE LISA LANGTON ' GakLAND COUNTY AD LITENS St SP ee, | | y IN SUPPLEMENTAL eee BRIEF IN SUPPORT OF MOTION TO ALLOW | FOR THE j | IMMUNIZATION FROM | MEASLES AND ANY OTHER DISEASES FOR | THE FOUR MINOR | CHILDREN Hae In the Matter of JUDGE LISA LANGTON in the A Kenny Children | Jessica Cooper P 23242 gr 2 Prosecuting Anomney Slits 1200 N Telegraph 2] 2 Pontiac, MI 48341 g| 8 | H. Elliot Pames P28539 3! 2 | Lawyer/Guardian Ad Litem e 7117 Glenburnie 3 i Clarkston, MI 48346 Daniel J. Bagdade P 24698 Actomey for Respondent Father 5037 Bantry Dr ‘West Bloomfield MI 48322 Jennifer E. Mead P 57106 ‘Attomey for Respondent Mother PO Box 165 Keego Harbor MI 48320 INTRODUCTION ‘This Lawyer/Guardian Ad Litem filed my Motion to Allow for the Immunization from Measles and any other Diseases for the Four Minor Children on February 4, 2015. Hearing on the Motion is scheduled for February 11, 2015 at 1:30PM. This LGAL wishes to supplement my brief to inform the Court some relevant information regarding Respondent Father's serious and dangerous substance abuse history as a factor as to why the decision whi ther the minor childrenTil .272372615, 6 se688 should be immunized must not be left in the hands and discretion/wishes of Respondent Father. Based upon he evidence to be submitted, this Lawyer/Guardian Ad Litem strongly contends that this Honorable Court must intercede and make the decisions that are in the best of interests of my clients, the four minor children, Il, _ RESPONDENT FATHER’S SUBSTANCE ABUSE HISTORY. ‘The four minor children came into care as a result of Respondent Father overdosing on heroin and being rushed to the hospital in August 2014.The four minor children were in the house at the time. As this Honorable Court knows, this was not the first time the children had been removed from the home, In 2007, Child F was in the car when the Respondent Father was using marijuana, had drug paraphernalia and attempting to sale the drug. As 2 result of discovery provided in the present case, this Lawyer/Guardian Ad Litem has learned that in March 2013, Respondent father admitted to personnel at the Milford Counseling Inc. that he had admitted to experimenting in the following drugs: powdered Cocaine, crystal meth, “speed balls” (combination of cocaine and heroin) Xanax, Special K, Super K, LSD, Mushrooms, Mescaline, nitrous, DMT, Foxy, and AMT.! The initial evaluation report also stated the following: “The client admits to loss of control, increased tolerance, black outs, much time devoted to use, continued use despite adverse consequences, and persistent attempts to cut back or cease use of substances. The client admits to experiencing, physiological withdrawals, The client reports attending substance abuse treatment at many different facilites fro the age of 13 to the age of 24 years old, (31 at time of interview) The client reports that they did not complete treatment. The client has not tried AA or any other twelve step recovery systems. (EX 6) ‘This not a case of casual use of illegal and dangerous substances. Respondent Father has loss control regarding his substance abuse issue as evidenced by the recent overdose of the " This Lawyer/Guardian obtained information regarding some the drugs mentioned ané the documents (which have previously been delivered to all Counsel as par of discovery) are hereto as EX 1, Ex 2, Ex 3 EX 4.and EX S 2FIT. 272372015. 292506 30609 heroin. The Respondent Father has indicated in recent interviews with the press that he has “done some research and spoken to some of his friends” about the immunizations and decided against them for his four children. First it would be very interesting to this LGAL, and I am sure to this Honorable Court, the specific alleged authoritative medical journal or treatise read by the Respondent Father regarding the issue of the immunizations and some alleged and unproven link to autism and 2) what are the names of these supposed friends the Respondent Father has spoken to and what individual substance abuse history they may have? This is no game that exists. The lives and health of four minor children and the lives and the health of other children they may come into contact is at serfous risk. This LGAL for one is not willing to accept “some unknown research and some unknown friends” regarding the issue. This LGAL would clearly rather accept the opinion stated in WEB MD, where it states: “THROUGH STUDIES HAVE FOUND NO LINK BETWEEN VACCINES AND AUTISM.” (EX 7) (emphasis added) IL, CONCLUSION As stated in this LGALs initial brief, I am still of the firm conv jon that providing the immunizations for the four minor children fs in their best intezest. Respondent Father's utterly dangerous and longtime illegal substance abuse history, should not and eanmot allow him to make decisions regarding my clients" health, safety and welfare. This LGAL reiterates his request that this Honorable Court protect the children and enter van allowing DHS and/or the placement to consent for the immunizations for measles and any other diseases which are recommended and necessary.Tat .272372815 Respectfully submitted Ff Biliot Pames P285 Lawyer/Guardian Ad Litem February 5, 2015