1 (19823) - Redacted Fixed 2 - Redacted 2

Case: 1:23-cv-01483-BMB Doc #: 1 Filed: 07/29/23 1 of 23.
PageID #: 1
IN THE UNITED STATES DISTRICT

COURT FOR THE NORTHERN DISTRICT OF
OHIO EASTERN DIVISION
(individually
and/or as parent/next friend
of Plaintiffs and
minors)
(Address Redacted) Case No.
and JUDGE
(individually COMPLAINT
and/or as custodian/next friend
of Plaintiff SFK, a minor, JURY DEMAND ENDORSED HEREIN
(Address Redacted),
and
(Address Redacted),
and
a minor
(Address Redacted)
and
a minor
(Address
Redacted),
and
a minor
(Address Redacted),
Plaintiffs,
Case: 1:23-cv-01483-BMB Doc #: 1 Filed: 07/29/23 2 of 23. PageID #: 2
v.
CRAWFORD COUNTY, OHIO

C/O CRAWFORD COUNTY COMMISSIONERS
TIM LEY, LARRY SCHMIDT AND
DOUG WEISENAUER
112 E. Mansfield Street
Bucyrus, Ohio 44820,
and
CRAWFORD COUNTY JOB AND FAMILY

SERVICES/CRAWFORD COUNTY, OHIO
c/o Melinda Crall-Cauley, Director
224 Norton Way
and
MELINDA CRALL-CAULEY(individually
and/or Director and/or agent
or employee of Crawford County
Job and Family Services/
Crawford County, Ohio)
224 Norton Way
and
MOLLY KIDWELL (individually and/or

as agent and/or employee of Crawford
County Job and Family Services/Crawford
County, Ohio)
224 Norton Way
and
BUCYRUS POLICE DEPARTMENT/

CITY OF BUCYRUS, OHIO
c/o Chief Neil Assenheimer
500 S. Sandusky Avenue
and
2
CITY OF BUCYRUS, OHIO

c/o Mayor Jeff Reser
and
DETECTIVE JAMIE CARVER

(individually and/or as agent
and/or employee of the City of
Bucyrus, Ohio in its Police
Department)
c/o Bucyrus Police Department
and
OFFICER DEVIN WIREMAN (individually

and/or as agent and/or employee of
the City of Bucyrus, Ohio in its
Police Department)
c/o Bucyrus Police Department
and
JANE/JOHN DOE(S) (in their individual

and/or official capacities)
Addresses to be determined,
Defendants.
INTRODUCTION AND PARTIES
1. The jurisdiction of this Court is invoked pursuant to the

provisions of 28 U.S.C. Section 1343(4), this being an action
in equity and a suit authorized by law to be commenced by any
person to recover damages for injury and to secure other
relief under acts of Congress providing for the protection of
civil rights.
3
2. The jurisdiction of this Court is also invoked pursuant to
28 U.S.C. Section 1331, this being a civil action wherein the

matter in controversy exceeds the sum or value of seventy-
five thousand dollars ($75,000.00), exclusive of interest and
costs, and arises under the Constitution and laws of the
United States.
3. The jurisdiction of this Court is also invoked pursuant to
the provisions of 28 U.S.C. Section 1343(3), this being a suit
to redress the deprivation, under color of any State law,
statute, ordinance, regulation, custom or usage, of any right,
privilege or immunity secured by the Constitution of the
United States or by any Act of Congress providing for equal
rights of citizens or of all persons within the jurisdiction
of the United States.
4. The plaintiffs are seeking remedies pursuant to 42 U.S.C.

§1983, wherein every person, who, under color of any statute,
ordinance, regulation, custom, or usage, of any State or
territory, subjects, or causes to be subjected, any citizen of
the United States or other person within the jurisdiction
thereof to the deprivation of any rights, privileges, or
immunities secured by the Constitution and laws, shall be
liable to the party injured in an action at law, suit in
equity, or other proper proceeding for redress.
5. The plaintiff is a resident of Crawford
County, Ohio and is the custodial p rent and next friend of
Plaintiffs and minors. He is married to Plaintiff
4
6. The plaintiff is a resident of Crawford
County, Ohio and at all times relevant was the guardian of CFK
who is a minor, by virtue of being his step mother in a prior
marriage. She has been married to Plaintiff since
in or about 2021.
7. The plaintiff, is a resident of Crawford
County, Ohio and at the time of the incident at issue was not
emancipated. She suffers from anxiety, PTSD, and depression.
8. The plaintiff, is a resident of Crawford County, Ohio
and at the time of the incident at issue in this Complaint was
sixteen (16) years of age. He is autistic and suffers from
anxiety, PTSD, ADHD, insomnia and depression.
and at the time of the incident at issue in this Complaint
was fourteen (14) years of age. He suffers from anxiety,
PTSD, ADHD, depression and insomnia.
and at the time of the incident at issue in this Complaint was
nine (9) years of age. She suffers from anxiety, PTSD, ADHD,
depression, insomnia and binge eating disorder.
11. The defendant, Crawford County, Ohio (hereinafter
referred to as "County") is a municipal corporation, duly
licensed and authorized to do business in the State of Ohio,
and is a resident of and/or does business within Crawford
County, Ohio.
12. The defendant, Crawford County Job and Family

Services/Crawford County, Ohio (hereinafter referred to as
5
"JFS") is a municipal corporation, duly licensed and

authorized to do business in the State of Ohio, and is a
resident of and/or does business within Crawford County,
Ohio. Said Defendant also provides child protective services
for residents of Crawford County, Ohio.
13. The defendants, Melinda Crall-Cauley, Molly Kidwell and
one or more defendants Jane/John Doe(s) are/were directors
and/or supervisors and/or agents, officers or employees of
defendant JFS and at all times relevant to this Complaint
were acting in such capacity, in furtherance of the business
interest of said defendant and within the scope of their
respective said authority and/or were acting in their
respective individual capacities.
14. The defendant, City of Bucyrus, Ohio (hereinafter
referred to as "City") is a municipal corporation, duly
licensed and authorized to do business in the State of Ohio,
and is a resident of and/or does business within Crawford
County, Ohio.
15. The defendant, Bucyrus Police Department/City of Bucyrus,
Ohio (hereinafter referred to as "BPD") is a municipal
corporation, duly licensed and authorized to do business in
the State of Ohio, and is a resident of and/or does business
within Crawford County, Ohio.
16. The defendants, Detective Jamie Carver, Officer Devin
Wireman and one or more defendants Jane/John Doe(s) are
agents, officers and/or employees of defendant BPD and at all
times relevant to this Complaint were acting in such capacity,

6
in furtherance of the business interest of said defendant and

within the scope of their respective said authority, and/or
were acting in their respective individual capacities.
17. The Defendants, Jane/John Doe (hereinafter “Does”), are
pseudonyms for the persons who planned, participated in or
otherwise engaged in the conduct complained of herein. The
names of said Defendants will be substituted after discovery.
FIRST CLAIM – 42 U.S.C. 1983, Equal Protection
18. The plaintiffs hereby incorporate by reference the facts
and law as alleged in paragraphs one (1) through seventeen
(17) of this Complaint as if fully rewritten herein.

19. Since on or about February 7, 2022, and up to the present
time and into the foreseeable future, the plaintiffs have and
will be denied equal rights with parents who do not have
children with disabilities and serious medical conditions,
thereby discriminating against them on the basis of same, in
violation of their Constitutional right to equal protection of
laws.
20. The denial of equal rights, and/or discrimination
referred to in the preceding paragraph of this Complaint
consist of the following, all or the sum of which shall be
deemed to be original instances of discrimination by
defendants and/or retaliation against plaintiffs for their
complaints concerning their discriminatory treatment by
defendants and/or which establish a pattern and practice by
defendants of violation of the Constitutional and legal rights
of parents and families in Crawford County, Ohio.

7
21. The discrimination against plaintiffs by defendants is

evident from the treatment of Plaintiffs throughout the ordeal
which forms the basis for their Complaint in this case.
22. These facts of the ordeal which form the basis for the
Plaintiffs’ Complaint in this case include, but are not
limited to the following, all of which pertain to each of
Plaintiffs’ claims in this case:
A. On or about February 7, 2022 Plaintiff then nine

(9) years of age, disclosed to her great aunt that she had
been raped the night before by CFK, a then sixteen year old
boy who lived in home with the other plaintiffs;
B. great aunt immediately informed Plaintiff

of the allegation, who in turn informed plaintiff
who was having surgery at the time;
C. great aunt took her to the local hospital
emergency room where I.A. was examined by a Sexual Assault
Nurse Examiner (SANE nurse) and Defendant Bucyrus Police
Department and JFS were advised of the situation by the
hospital as required by law;
D. was anxious, sweating and shaking and was
frightened to the point that she had anxiety attacks in fear
that she was pregnant or would become ill and could never have
a boyfriend or get married; further, anxiety did not
decrease even when her lab tests came back negative for STD’s
and pregnancy; further, was too frightened to stay at her
own house that night;
8
Case: 1:23-cv-01483-BMB Doc#: 1 Filed: 07/29/23 9 of 20. PagelD #: 9
E. Plaintiff - contacted the minor children's
counselor who conducted a three-way call between himself, said
Plaintiff and a caseworker at JFS and advised said plaintiff
to remove CFK from plaintiffs' home immediately to avoid
having the other children removed from the home;
F. As instructed by the counselor, Plaintiff
- removed CFK from the plaintiffs' home and took CFK to
live with said Plaintiff's sister in Columbus, Ohio;
G. During the ride to Columbus, CFK told Plaintiff
- that IA had climbed on top of him while he was
asleep; however, plaintiff - later learned that CFK
was unplugging the home's security cameras and drugging and
raping other family members, including said plaintiff herself,
in plaintiffs' home;
H. On or about February B, 2022 a JFS caseworker

supervisor from Defendant JFC spoke with ■ and informed
plaintiffs•••• and•••• ■- ■
that 's story
was inconsistent at times because
the
■ gave more detail to
investigator than she did to the SANE nurse despite the fact
that it was or should have been in the common knowledge of a
JFS Investigator that children are nervous in hospital
settings, particularly when they are first faced with
disclosure of rape or sexual abuse;
I. The JFS caseworker supervisor and defendant
Wireman thereafter told plaintiffs•••• and•••• -
■
that she believed that was
9
telling lies and that they were clear to
bring CFK back into the home, despite the fact that it was or
1
0
should have been common knowledge of a JFS investigator that

perpetrators of sexual abuse are cunning liars and further
that no such decision should be made until investigation and
testing of the rape kit occurred;
J. Because plaintiff sister was afraid
of CFK, upon said plaintiff’s insistence, the said caseworker
supervisor drove CFK to Cincinnati for mental health
evaluation, had him temporarily committed to a treatment
facility there, and by on or about August 24, 2022 moved to
have him permanently placed with JFS and remain at the
facility;
K. On or about March 8, 2022 a dependency complaint was
filed by JFS alleging that CFK was dependent and on or about
March 22, 2022 he was found to be dependent and formally
committed to the temporary custody of JFS;
L. The defendant caseworker supervisor did not change
her position even after she learned that semen was found in
the rape kit and even after she was advised that CFK had
drugged and raped others people in plaintiffs’ home;
M. Defendants JFS and Doe(s) advised Bucyrus Police
department that the case against CFK was unsubstantiated;
however, despite the foregoing, on or about March 24, 2022
said defendants advised Plaintiffs’ and
that abuse was “indicated”, yet continued to refuse to take

action against CFK;
N. On or about February 8, 2022 Plaintiff was
interviewed by Officer Devin Wireman of the Bucyrus Police

11
Department. Officer Wireman advised Plaintiffs
and - that he did not know how to investigate a

rape and informed said plaintiffs that it "did not look
like a case" because the nurse did not note forced entry ■;
signs on ■
0. A rape kit was obtained from at the Bucyrus
Police Department; however, the Department allowed the kit
to sit for twenty-nine (29) days before testing of the kit
was attempted, despite the fact that Defendant Wireman and
the Bucyrus Police Department knew or should have known
that rape kits must be tested within thirty (30) days;
P. Plaintiff - found a tablet

containing pornography, sexual violence and rape in
CIB's room and
- immediately took it to defendant Bucyrus Police
Department as evidence in ■ 's rape. Instead of utilizing
the tablet as evidence, said defendant read said Plaintiff
her rights and treated her as if she were the criminal, not
CIB;
Q. Thereafter, the Bucyrus Police Department
agents/officers, including but not limited to the
named defendants herein, claimed that there was no
porn on the tablet despite the fact that plaintiffs
and/or
- had taken pictures of the porn before they
-
delivered it to the police department and despite the fact
that the porn was easily recovered by said plaintiffs when
12
the tablet was returned to them;

R. Likewise, the Bucyrus Police Department
agents/officers, including but not limited to the
named defendants herein, were unaware that and
13
had also dropped off blankets at the Bucyrus Police Department

for testing as evidence in the case;
R. Because of the belief that CFK had drugged and raped
others in the household, when Plaintiff suffered
an irregular pregnancy which caused no baby to form, but
created tumors that turned into cancer requiring chemotherapy,
she requested pathology tests to determine whether she, too,
and been drugged and raped by CFK; however, defendants JFS and
the City of Bucyrus/Bucyrus Police Department refused to
consider such a possibility and refused to send a sample of
the rape kit to the pathologist; further, no Sane exam or rape
kit was performed on plaintiff
S. On or about March 22, 2022 Plaintiffs and
were presented with a document which they were
told was a termination of the dependency proceedings when in
fact it was a detailed case plan containing lies, false
statements falsely attributed to Plaintiffs and
numerous requirements for said plaintiffs,
including but not limited to requirements for parenting
classes, counseling and other restrictive activities, and
generally penalizing said plaintiffs and not CFK for the
action he took against
T. Defendant JFS advised plaintiffs and
that they would be provided resources and
services to assist them and the other plaintiffs with dealing
with the rape allegation and the turmoil it caused in their
home, including but not limited to parenting classes, trauma

14
counseling for the children and similar services; however,

neither such services nor information on where to obtain such
services were afforded to plaintiffs despite repeated
requests by and
U. When Plaintiff complained to JFS
concerning the inaction and dissatisfaction with the
caseworker assigned to the family, the caseworker created a
case plan consisting of lies, accusations and false statements
which she attributed to Plaintiffs and/or
to place them in a bad light;

V. The caseworker further chastised said plaintiffs for
having SANE and/or other medical examinations of the minor
plaintiffs based upon the allegations against CFK and their
fear that the said minors had also been assaulted and
reinforced her belief that CFK should be permitted to come
back into the home contrary to the wishes of and
W. Home visits by Defendant JFS investigators/

caseworkers were so accusatory and demeaning that Plaintiffs
and requested that their attorney be
present during same. Said defendants appeared to agree to
same; however, they timed their visits so that said
Plaintiffs were unable to give their attorney notice so that
he could be present;
X. Plaintiff filed complaints against the
Bucyrus Police Officers and the JFS caseworkers/investigators
15
and others because no action was taken to investigate and
16
prosecute CFK nor to assist plaintiffs in dealing with the

situation; however, no action was taken on said complaints nor
to protect the plaintiffs or their constitutional rights;
further, the caseworker supervisor who was the subject of the
complaint was promoted by JFS;
Y. Plaintiffs and thereafter
learned that defendants blamed said plaintiffs for not
stopping the abuse, while at the same time, took the position
that CFK was the victim of false accusations and not the
abuser, all without cause, justification or excuse;
Z. Plaintiffs complied with the case plan in order to be
allowed to keep their children in their home, all at great
expense and inconvenience to all of the plaintiffs;
AA. On or about September 28, 2022 JFS filed a motion to
terminate supervision as to all the minor plaintiffs except
the alleged perpetrator of the rape, CFK because he was
already out of plaintiffs’ home. Said filing included
statements by JFS and defendant Kidwell to the effect that CFK
was at low risk of reoffending and that “confusion on what has
been reported versus what has been proven to be true regarding
all of the allegations” such that the report was made to
appear that CFK was the victim. The report included
statements that and refused to care for
CFK, that he was doing well, knew what he wanted to do with
his life and other such supportive comments for the said
perpetrator, while disparaging and disregarding the other
children in the household because they had other medical

17
and health issues;
BB. Shortly before the hearing on said amended case plan

the caseworker supervisor described above committed suicide;
CC. On or about October 25, 2022 the case plan was
adopted as to CFK; however, the case plans for the other minor
children were not terminated until January 13, 2023 despite
the fact that the same case plan was utilized for the other
children;
DD. On or about June 29, 2022 Plaintiffs and
filed a complaint with the Bucyrus Police
Department concerning the misconduct of defendant Wireman.
Any wrongdoing on the part of said defendant was denied;
EE. On or about July 7, 2022 Plaintiffs and

filed a complaint with JFS to redress the unfair,
irresponsible and retaliatory treatment they had suffered and
continued to suffer at the hands of defendants and other
employees of said defendant;
FF. By letter dated July 14, 2022 Defendant JFS denied
any wrongdoing or impropriety by any of its employees; and
GG. Plaintiffs’ home continued to be disrupted by
defendants without cause, justification or excuse for almost
one year.
23. The acts and conduct and/or failures to act of the
defendants as set forth heretofore, constituted willful and
wanton misconduct and/or reckless disregard for the rights of
families such as plaintiffs.
24. As a direct and proximate result of the wrongful acts and

18
conduct and/or failures to act of defendants plaintiffs

suffered loss of income and such severe and intense emotional
and physical distress as to require medical care and
treatment, suffered loss of consortium and family relations
and were unable to carry on the activities of daily living
for several months and continue to suffer as a result
thereof; further, plaintiffs and were forced to
defend against unfounded insinuations of child abuse or
neglect and suffered injury and damage as a result of the
stigma attached thereto; further, said plaintiffs have and
will continue to incur medical expenses and legal fees and
expenses to seek vindication of their legal rights.
SECOND CLAIM 42 U.S.C. 1983, Due Process

and law as alleged in paragraphs one (1) through twenty-four
(24) of this Complaint as if fully rewritten herein.

26. Defendants' conduct and/or delay in investigating, making
unsupported conclusions and/or taking the action complained of
herein is unreasonable, unjust and unreasonable and/or unjust
under the circumstances.
27. The defendants JFS, County, Crall-Cauley, and City of
Bucyrus, respectively, are responsible for the policies,
statements, ordinances, regulations, customs, and/or usages,
which policies, statements, ordinances, regulations, customs
and/or usages are pursued by the respective defendants under
color of law.
19
28. Said defendants have promulgated and/or adopted customs,

usages, statements, ordinances, regulations and/or policies
whereby reckless disregard for the best interest of children,
failure to perform duties required by law, failure to
investigate serious crimes and denial of constitutional rights
under color of law including but not limited to due process,
equal protection, the right to government services and the
right to make decisions regarding the care, custody and
control of children have become the norm, the same being
condoned, uncontrolled and unpunished.
29. The plaintiffs have been subjected, because of those
actions and/or failures to act of defendants as set forth
foregoing, to deprivation under color of law and of the custom
and usage of defendants of rights, privileges and immunities
secured to plaintiffs by the Constitution and laws of the
United States, and particularly their rights to due process,
the right to government services and the right to make
decisions regarding the care, custody and control of children
30. Defendants each knew of and/or should have known, and/or
participated in the illegal acts and conduct set forth
foregoing and should have taken appropriate action to stop
and/or prevent such illegal acts and conduct from taking
place.
31. The extreme and outrageous acts and conduct and/or
failures to act of defendants were performed knowingly,
intentionally, wantonly, willfully, recklessly and maliciously
to the detriment and injury of plaintiffs.

20
32. As a direct and proximate result of each defendant’s

extreme and outrageous acts and conduct plaintiffs have
suffered those damages set forth in the foregoing paragraph
twenty-four (24).
THIRD CLAIM 42 U.S.C. 1983, Failure to Train

33. The plaintiffs incorporate by reference the facts and law
as alleged in paragraphs one (1) through thirty-two (32) as if
fully rewritten herein.
34. Defendants County, JFS, Crall-Cauley, City of Bucyrus and
Bucyrus Police Department have failed to adequately and
properly train its/their investigators/ officers/agents in
matters concerning DNA testing, rape kits, investigation
allegations of child rape and other matters related to the
health and welfare of children and families.
conduct and/or failures to act on the parts of said defendants
plaintiffs have suffered those damages set forth in the
foregoing paragraph twenty-four (24).
FOURTH CLAIM – Gross Negligence under color of law

as alleged in paragraphs one (1) through thirty-five (35) of
this Complaint as if fully rewritten herein.
37. The actions of defendants constitute gross negligence/
negligence.
conduct of defendants plaintiffs have suffered those damages
as set forth in paragraph twenty-four (24) of this Complaint.

21
FIFTH CLAIM Violation of Federal Law and the U.S. Constitution

as alleged in paragraphs one (1) through thirty-eight (38) of
this Complaint as if fully rewritten herein.
40. The actions of defendants constitute willful, wanton,
deliberately indifferent, intentional and/or reckless
violation(s) of federal and state law, including but not
limited to the Fourth and Fourteenth Amendments to the United
States Constitution and 42 U.S.C. Section 1983.
conduct of defendants plaintiffs have suffered those damages
as set forth in paragraph twenty-four (24) of this Complaint.
WHEREFORE, plaintiffs demand judgment on the foregoing
claims, whether considered jointly and/or severally, against
defendants jointly and/or severally, as follows:
1. Awarding compensatory and/or special damages in excess
of seventy-five thousand dollars ($75,000.00);
2. Awarding punitive damages in excess of seventy-five
thousand dollars ($75,000.00);
3. Granting injunctive relief ordering defendants to
cease and desist their unlawful conduct, to remove all
derogatory remarks concerning plaintiffs from any registry or
reporting agency, and to cease and/or take certain action as
appropriate, as determined at trial;
4. Awarding reasonable attorney fees and costs and
expenses of bringing this action; and
22
5. Awarding other and further relief as this Court deems

just and equitable.
Respectfully submitted,
James H. Banks
James H. Banks 0031958
Counsel for Plaintiffs
P.O. Box 40
Dublin, Ohio 43017
Tel. (614) 866-0666
Fax. (614) 396-7747
Email: Najjarbank@aol.com
JURY DEMAND
Plaintiffs demand a trial by jury of this action.
James H. Banks
James H. Banks, Esq.
23

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Case: 1:23-cv-01483-BMB Doc #: 1 Filed: 07/29/23 1 of 23.

IN THE UNITED STATES DISTRICT

CRAWFORD COUNTY, OHIO

CRAWFORD COUNTY JOB AND FAMILY

MOLLY KIDWELL (individually and/or

BUCYRUS POLICE DEPARTMENT/

CITY OF BUCYRUS, OHIO

DETECTIVE JAMIE CARVER

OFFICER DEVIN WIREMAN (individually

JANE/JOHN DOE(S) (in their individual

INTRODUCTION AND PARTIES

1. The jurisdiction of this Court is invoked pursuant to the

2. The jurisdiction of this Court is also invoked pursuant to

28 U.S.C. Section 1331, this being a civil action wherein the

4. The plaintiffs are seeking remedies pursuant to 42 U.S.C.

6. The plaintiff is a resident of Crawford

12. The defendant, Crawford County Job and Family

"JFS") is a municipal corporation, duly licensed and

times relevant to this Complaint were acting in such capacity,

in furtherance of the business interest of said defendant and

(17) of this Complaint as if fully rewritten herein.

of parents and families in Crawford County, Ohio.

21. The discrimination against plaintiffs by defendants is

A. On or about February 7, 2022 Plaintiff then nine

B. great aunt immediately informed Plaintiff

E. Plaintiff - contacted the minor children's

counselor who conducted a three-way call between himself, said

Plaintiff and a caseworker at JFS and advised said plaintiff

to remove CFK from plaintiffs' home immediately to avoid

having the other children removed from the home;

F. As instructed by the counselor, Plaintiff

- removed CFK from the plaintiffs' home and took CFK to

live with said Plaintiff's sister in Columbus, Ohio;

G. During the ride to Columbus, CFK told Plaintiff

- that IA had climbed on top of him while he was

asleep; however, plaintiff - later learned that CFK

was unplugging the home's security cameras and drugging and

raping other family members, including said plaintiff herself,

H. On or about February B, 2022 a JFS caseworker

that it was or should have been in the common knowledge of a

JFS Investigator that children are nervous in hospital

settings, particularly when they are first faced with

disclosure of rape or sexual abuse;

I. The JFS caseworker supervisor and defendant

Wireman thereafter told plaintiffs•••• and•••• -

telling lies and that they were clear to

should have been common knowledge of a JFS investigator that

that abuse was “indicated”, yet continued to refuse to take

N. On or about February 8, 2022 Plaintiff was

interviewed by Officer Devin Wireman of the Bucyrus Police

Department. Officer Wireman advised Plaintiffs

and - that he did not know how to investigate a

P. Plaintiff - found a tablet

- had taken pictures of the porn before they

the tablet was returned to them;

had also dropped off blankets at the Bucyrus Police Department

home, including but not limited to parenting classes, trauma

counseling for the children and similar services; however,

to place them in a bad light;

W. Home visits by Defendant JFS investigators/

and others because no action was taken to investigate and

prosecute CFK nor to assist plaintiffs in dealing with the

children in the household because they had other medical