Rebuttal to defendant Lisa Rambo's motion to dismiss

8/12/2019 Rebuttal to defendant Lisa Rambo's motion to dismiss

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In the United States District Courtfor the Middle District of Georgia

Macon Division

Dr. Sharon Cross, et alia ))

plaintiffs in propria persona ) ) Civil action file number:v. )

) :!"#cv#$$$$%#C&' )

(isa 'ambo, et alia )) ur* +rial Demanded

defendants ))

___________________________________________________________________________________

Plaintiffs' rebuttal to defendant Lisa Rambo's motion to dismiss ___________________________________________________________________________________

laintiffs hereb* rebut defendant and ublic +rustee (isa 'ambo-s motion to dismiss this civil

action against her. laintiffs all five of them) have an interest in the ublic +rust and have the

fundamental right to remed* breaches thereof b* the named +rustee as /ell as to redress in order to

ma0e plaintiffs all five of them) once again /hole. & +rustee liabilit* for breach of the +rust is

personal no immunit* for defendant 'ambo) in character /ith all the conse1uences and incidents of

personal liabilit* and is enforceable against her estate. Defendant 'ambo claims to be a udge

therefore is also a +rustee b* /a* of provisions at &rticle 2I of the Constitution. Defendant 'ambo

/as a +rustee in the capacit* of a udge according to defendant 'ambo and her attorne*) at all times

during the instant matter.

laintiffs- statement of facts at paragraphs 3!, 34, and 35 /ithin the complaint /ere not rebutted

b* defendant 'ambo or her attorne* thus stand as undisputed fact before this Court.

+here is no evidence before this court to support the assertion that defendant 'ambo did not

breach the duties of a +rustee for the ublic +rust to the confirmed in6ur* of plaintiffs.

age ! of !%


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7o evidence has been presented to this Court to indicate that defendant 'ambo did not order

that plaintiffs- son 8.C. be sei9ed: absent a la/ful /arrant, /ithout probable cause, /ithout e igent or

emergenc* circumstances, absent imminent danger to 8.C., /ithout parental consent .

7o evidence has been presented to this Court to indicate that defendant 'ambo did not order plaintiffs- medical records to be sei9ed and searched: absent a /arrant, /ithout probable cause, /ithout

e igent circumstances, absent imminent danger to 8.C., /ithout parental consent .

Defendant 'ambo-s motion to dismiss relies e clusivel* upon the defense of 6udicial immunit*

buttressed b* the false assertion that in bringing and prosecuting this suit the plaintiffs, in their proper

persons and as beneficiaries of the ublic trust, are someho/ in violation of the (a/ of the (and.

laintiffs read the assertions that the* are someho/ in violation of the (a/ as a deliberate and

malicious attempt to intimidate and stop plaintiffs from proceeding for/ard /ith this meritorious case

as it is their obligation and inalienable right to do given the gross violations suffered b* the plaintiffs as

a result of defendant 'ambo-s breach of +rust. ;+here can be no sanction or penalt* imposed upon one

because of his e ercise of Constitutional rights.; Sherar v. Cullen, 481 F 2d 946 (1973)

No Immunity for a Trustee which has breached the Trust

to manifest injury of beneficiary

& +rustee liabilit* for breach of the +rust is personal no immunit* for defendant and +rustee

(isa 'ambo) in character /ith all the conse1uences and incidents of personal liabilit* and is

enforceable against her estate.

The Juvenile Court is not authori ed by or!anic Law

+here is no evidence in this Court indicating that the legally created uvenile Court is

authori9ed b* the (a/ e pressed at the Georgia Constitution. 7o evidence has been presented to

support the assertion that the Georgia legislature is authori9ed to legislate a 6udicial office into

e istence.

age 4 of !%


3/18

7o evidence e ists to support the assertion that the Georgia 6udiciar* is la/full* authori9ed to

install appoint) a udge /ithin a legislativel* born e the eople settlors) and beneficiaries of the

ublic +rust have authori9ed the +rustees of one branch of government to create another branch of

government.

+here is no evidence supporting the assertion that defendants 'ambo, ?idson, @urt are not

utili9ing and enforcing private ;polic*; to substantial in6ur* of plaintiffs. laintiffs have seen of this

before: ;@e has combined /ith others to sub6ect us to a 6urisdiction foreign to our constitution, and

unac0no/ledged b* our la/s= giving his assent to their &cts of pretended (egislation=; &e'lara%i n

nde#enden'e *uly 4, 1776.

+here is no evidence to support the assertion that hearsa* is not at all times allo/ed as evidence

/ithin the uvenile Court.

+here is no evidence to suggest that standards s*mboli9ing the 6urisdiction of an organic Court

such as the 8ederal and State flags in addition to the Great Seal of Georgia e ist or have ever e isted in

the uvenile Court.


4/18

+here has been no evidence presented to this Court that an* (a/full* authori9ed Court can

den* the accused the abilit* to confront his accuser. ;It is the dut* of the courts to be /atchful for the

constitutional rights of the citi9en, against an* stealth* encroachments thereon.; + yd v. ".S., 116 "S

616, 63!, (188!)29. ;+he 6udicial branch has onl* one dut* # to la* the &rticle of the Constitution/hich is involved beside the statute /hich is challenged and to decide /hether the latter s1uares /ith

the former...the onl* po/er it the Court) has...is the po/er of 6udgment.; ".S. v. +u%ler, 297"S(1936)

+here is no evidence /ithin this Court to support the assertion that the uvenile Court is not an

administrative entit* administering statutes appearing completel* at odds /ith the Constitution.

+here is no evidence in this Court to support the assertion that defendant 'ambo is not an

administrator of statutes.

+here is no evidence that defendant 'ambo-s uvenile Court is not primaril* a place of business

profiting her, the attorne*s hired to defend against her ;court orders;, and the prosecuting attorne*s

representing D8CS.

+here is no evidence before this Court in support of the assertion that defendant 'ambo is not

involved in barratr*.

+here is no evidence before the Court that 8.C. /as not sei9ed for the purpose of coercing his

famil* to parta0e in ;services; provided b* and profitable to the ;D? &'+M?7+;, U2?7I(?

C


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e isted #ri r to sei9ing 8.C. and prior to the ;probable cause hearing;.

+here is no evidence before this Court that defendant 'ambo has not violated her fiduciar*

duties as a +rustee to the beneficiar* plaintiffs in the instant matter.

+here is no evidence before this Court that defendant 'ambo has not e ceeded her la/fulauthorit*.

+here is no evidence before this Court that defendant 'ambo has not abused her official po/ers

to manifest in6ur* to the plaintiffs.

+here is no evidence before this Court that defendant 'ambo has not deprived plaintiffs of at

least "th, th, and %th &mendment rights inter alia.

+here is no evidence before this Court that defendant 'ambo has not enabled a false /itness to

provide hearsa* and baseless assertion /hich /ould be inadmissible e cept for e ceedingl* rare

circumstance) in a Court provisioned b* the Constitution.

+here is no evidence before this Court that defendant 'ambo did not fail to protect plaintiffs

from malicious and bad faith medical ;reporters;.

+here is no evidence before this Court that defendant 'ambo is not primaril* responsible for

8.C.-s ph*sical /rist in6ur*.

+here is no evidence before this Court that defendant 'ambo and defendant @urt have not

coerced under pains of plaintiffs- son being again unreasonabl* sei9ed) plaintiffs to sign documents, to

cooperate /ith a D? &'+M?7+ entit*, and to attend ;immuni9ation; class.

+here is no evidence before this Court that defendant 'ambo has not terrori9ed the plaintiffs

and their e tended famil* /hile economicall* benefiting from her treacher* and ma*hem at the

e pense of the public purse.

laintiffs direct the Court to defendant 'ambo-s affidavit /ithin document "%. Defendant

'ambo freel* admits that she collaborated /ith defendant ?idson to effect the unreasonable sei9ure of

age of !%


6/18

8.C. +he sei9ure is evidenced as unreasonable for the follo/ing: !. Defendant 'ambo indicates that the

communication bet/een her and defendant ?idson had to do /ith, ; an e$ergen% si%ua%i n alleged

de#riva%i n a $in r 'hild ;. ?mergent is not evidence of ;e igenc*; +he ;alleged deprivation of a

minor child; does not evidence 6ustification for a reasonable sei9ure.4. ; #aren%s.... ere re using % all %heir 'hild % be i$$uni-ed r %e%anus, hi'h a'' rding % %he

%rea%ing #hysi'ian and h s#i%al s%a as ne'essary #ri r % $edi'al %rea%$en% %he 'hild.;

+here is no evidence before this Court to support the assertion that refusal to ;immuni9e for

tetanus; presents probable, logical, or reasonable cause or special e igenc* to sei9e an*one at an*time.

8or the record, plaintiffs never once refused to ;allo/ their child to be immuni9ed for tetanus;.

laintiffs refused to provide consent and /ere unable to provide informed consent for the

administration of a single tetanus ;vaccine; to 8.C.

+here is no evidence before this Court that tetanus ;immuni9ation; /as essential #ri r to

medical treatment surger*).

laintiffs are not a/are of an*one ever being forced to receive a tetanus vaccine against their

/ill.

laintiffs point out that 8.C. received surger* and at least % hours later /as force vaccinated

e periencing no ill effects as a result of not being vaccinated prior to surger*.

Defendant 'ambo-s affidavit does not evidence that she received a second or third opinion on

this point /hich plaintiffs perceive as being rec0less and neglectful.

Defendant 'ambo does not indicate if it /as revealed to her that there /as a high probabilit* or

an* probabilit* that 8.C. had been e posed to tetanus bacteria.

+here is no evidence before the Court to corroborate that 4 B of ;children; suffering from

tetanus infections die. ; % as e$#hasi-ed % $e %ha% %he 'hild s ell/being re0uired %he %e%anus

va''ina%i n and %ha% %he need as vi%ally i$# r%an%, i n % 'ri%i'al.

age 6 16


7/18

+here is no evidence before this Court that Defendant 'ambo did not order this sei9ure based

upon uncorroborated, unconfirmed, and unsupported testimon* from anon*mous sources. ;In conte t

of a sei9ure of a child b* the State during an abuse investigation...a court order is the e1uivalent of a

/arrant.; ennenbau$ v. illia$s, 193 F.3d !81, 652 (2nd Cir. 1999. F. . v. a dis%ri'% C ur% r l C unr%, d.

+he


8/18

Defendant 'ambo freel* admitted on December !4th 4$!4, ; %his en% n r h urs hursday a %ern n

and hursday nigh%. d n % n h $any 'alls g % ab u% %his.;

It /as not enough to have had information as per 'ambo-s affidavit) that 8.C. /as in some

form of alleged serious danger. ;+he 8ourth &mendment itself spells out the evidence re1uired for a/arrant or entr* order. 7o /arrant shall issue but on probable cause. +he United States Supreme

Court has held that courts ma* not use a different standard other than probable cause for the issuance of

such orders.; ri in v. is' nsin, 483 ".S. 868 (1987).

Defendant 'ambo asserted in her affidavit that she had 8.C. sei9ed based upon ;human concern;

/hich reads to plaintiffs as meaning ;personal feelings;. ersonal feelings are distinctl* different than

the much more e acting and rigorous ;probable cause;. Defendant 'ambo also asserts to have relied

upon the facts given to her, /hich have been evidenced as to be grossl* inade1uate insofar as to

establish probable cause .


9/18

indefinitel*.


10/18

critical or necessar* #ri r to surger*.

+here is no evidence in this Court that surger* for 8.C. /as not dela*ed as a result of defendant

Cartie or an* other medical) punishing plaintiffs for not follo/ing his medical recommendations.

+he plaintiffs /ill point out that /hile defendant Cartie and defendant 'ambo bandied about a4 B chance of death in the event of a tetanus infection, neither part* bothered to ascertain the incident

rate of tetanus. >hat good is a mortalit* rate /ithout an incident rate##the chances of d*ing from a

blac0 mamba bite are AAB, but the chances of receiving a blac0 mamba bite in this countr* are nearl*

none istent. Shall /e all stoc0 blac0 mamba anti#venomE In the case of tetanus, the actual mortalit*

rate is alleged to be closer to !!B per CDC) rather than the 4 B utili9ed b* defendants 'ambo and

Cartie.


11/18

further ph*sical in6ur* to his /rist) /hile in the care of defendants &lbritton and arr. +his does not

evidence ;human concern.; Defendant 'ambo did not evidence concerns for 8.C. or the plaintiffs-

rights /hen she ordered him unreasonabl* sei9ed, nor did she have concerns for their rights /hen she

ordered 8.C.-s medical records to be unreasonabl* and unnecessaril* sei9ed and searched.laintiffs as0 this Court to consider that defendant ?idson /as appointed b* the attorne*

general. +he attorne* general no/ represents defendants and social /or0ers arr and &lbritton /ithin

this civil action. +his Court should 0no/ that the Governor of Georgia, 7athan Deal, /as at one time a

6uvenile 6udge and has been made /ell a/are of plaintiffs- deprivation of rights b* the plaintiffs

themselves. In Georgia and in the e perience of these plaintiffs, attorne*s /ithin our government

appear to have little problem /ith the unreasonable sei9ing of %her people-s sons and daughters. +his

is /hat state actor ;immunit*; from prosecution delivers to our societ*: anarch*, t*rann*, rampant

abuse, unaccountabilit*, and e ponentiall* increasing miser* for families as their inalienable rights are

needlessl* deprived b* unaccountable state actors .

Plaintiffs are not attorneys

In regards to document "% and at page 4, plaintiffs hereb* rebut the statement, ; Plaintiff "ann

#layden Cross and Plaintiff #haron $arvey Cross% both non&lawyers% are re resentin! their three

children in this court action( ; &s e ecutors of the estate of /hich plaintiffs- sons are part), plaintiffs

Dann and Sharon Cross have ever* right to act according the best interests of their estate....and there is

nothing in the supreme (a/ of the (and or an* positive la/ implementing it /hich bars plaintiffs from

doing so, 8'C 'ules not/ithstanding. If defendant 'ambo asserts to the contrar*, let her cite the

specific &rticle, Section, and Clause of the supreme (a/ of the (and or an* positive la/ implementing

the same /hich supports such claim of authorit*. &dditionall*, since /hen and b* /hat legitimate

authorit* has the ublic +rust been set aside b* or subordinated to mere corporation ;public polic*; as

is e pressed in various federal and state codes such as the cop*righted


12/18

laintiffs freel* admit that their sons 8.C., D.C., and '.C. are not remunerating plaintiffs Dann

and Sharon Cross. +herefore, plaintiffs Dann and Sharon Cross are not ;practicing; la/ for hire.

8urthermore= a license b* definition) is permission to do something or not do something) that is

other/ise illegal to do or not do). Since /hen and b* /hat authorit* is the e ercise of plaintiffs-parental) 'ights made an ;illegal; activit*E

Defendant 'ambo brings to fore


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is *et another and currentl* inescapable conflict of interest. &lso consider that the plaintiffs are suing

at least three &' attorne*s that have /ell demonstrated their participation and inclination to deprive

plaintiffs- of their inalienable rights thus ma0ing the hiring of a &' attorne* *et another conflict of

interest. ;(ac0 of counsel of choice can be conceivabl* even /orse than no counsel at all, or of havingto accept counsel beholden to one-s adversar*.; +urge%% v. e;as, 389 "S 159

8urthermore, plaintiffs hereb* command defendant 'ambo and the currentl* unverified

;licensed to practice la/ for hire and profit attorne*; 7eSmith to substantiate his claims that plaintiffs

have committed an* crime /hatsoever at an* time and that plaintiffs, as beneficiaries of the ublic

+rust, are not properl* before this Court.

"efendant Rambo and )r( Ne#mith has thre e days

*from the date of this document's submission+

to une,uivocally rove to this Court and to these laintiffs

their alle!ations of criminal conduct on the art of the laintiffs and

that they* laintiffs+ are not ro erly before this Court(

&bsent proof of plaintiffs- ;criminal acts; and proof that plaintiffs are not properl* before the

Court /ithin three da*s it /ill be accepted that Mr. 7eSmith and defendant 'ambo have rescinded

those libelous accusations regarding plaintiffs.

In the event that defendant 'ambo, attorne* 7eSmith, district attorne* le9 @ardin, or an* state

actor elects to deprive plaintiffs- rights then here be the fee schedule, terms, and conditions for such

acts of deprivation: & fine of 5,$$$,$$$ per inalienable right deprived. &dditionall*, !,$$$ /ill be

fined for each minute an* member of the Cross famil* is deprived of their inalienable rights. a*ment

of said fines must be made in Constitution (a/ful mone* to plaintiffs /ithin 5 months of the

occurrence of said rights deprivations.

age !5 of !%


14/18

-ther contributin! factors to the de rivation of laintiffs' ri!hts

for this Court's consideration

+he entire South/estern udicial Circuit is over/helmed /ith conflicts of interest. Man* of the

individuals are present in various organi9ations, agencies, and offices that ree0 of nepotismHcron*#ismat the least. +he S?G& C&S& South/estern Georgia Court &ppointed Special &dvocate) agenc*

claims at least verball* via its /or0ersHvolunteers) to be an independent non#court affiliated non#profit

group that is ;to provide a voice for children in court.;. +he idea is that the 6udge, re1uired to be a

neutral and unbiased presiding officer, /ill be hearing the t/o sides of cases /ithout the benefit of the

vie/point of the child. & C&S& volunteer is to provide a third vie/#point that is unencumbered b* the

;politics; or ;predisposed; notions of the various agenciesHdepartments that might be involved in a

case.

+he realit* is that C&S& is ver* political. ;Desire to please; is a real occurrence in ever*da*

life. +he li0elihood that volunteers ma* feel the need to side /ith /homever the 6udge appears to be

favoring is ever present. In the South/estern udicial Circuit, defendant (isa 'ambo goes so far in her

court as to provide D8CS prosecuting attorne*s /ith /hat their ne t move should be, so obviousl* she

tends to side /ith D8CS specificall* in the plaintiffs- 4 hour hearing, defendant 'ambo told

defendant @urt /hat she ;assumed; /as his motion). >hen individuals volunteer /ith C&S& and are

dul* appointed as advocates, the* are often attempting to ;net/or0; and develop their ;credentials;.

In going against a ;6udge; or an* other individual in the court /ho has ;pull; or ;clout;, the volunteer

is obviousl* potentiall* damaging their position for later recommendations. In this particular case, the

C&S& volunteer /as /ell a/are that the D8CS supervisor, defendant aran &lbritton, /ho sat at the

table during the initial ; 4 hour hearing; /as also a board member of C&S&. 8urthermore, the most

overriding concern of C&S& is for the child-s right to ;appropriate placement and permanent home. ;

Such a statement begs the 1uestion##do children have the ;right; to be unmolested b* state actors in

age !" of !%


15/18

their o/n famil*.

C&S& is affiliated /ith the (ighthouse Child &dvocac* program that features defendant 'ambo

as a supporter. 8unding of the (ighthouse Child &dvocac* program allegedl* comes from court

probation fees more barratr*). +he ne/ coordinator of the &dvocac* program is none other than, thene/l* retired D8CS supervisor, defendant aran &lbritton. Defendant &lbritton /as the D8CS

supervisor /ho, along /ith defendant arr, too0 ph*sical possession of 8.C. at the Doctors @ospital in

&ugusta, Georgia. oth &lbritton and arr are responsible for 8.C.-s /rist in6ur*.

? #6uvenile 6udge and attorne* Governor 7athan Deal has appointed defendant 'ambo to the

Georgia Commission on Child Support. In turn, defendant 'ambo recommended to Mr. Deal the

appointment of S?G& C&S& e ecutive director rad 'a* to the Child &dvocate &dvisor* oard

of /hich defendant 'ambo is also a member). District attorne* le9 @ardin is on the board of

S?G& C&S&. ased on information and belief le9 @ardin-s spouse is the sister of the S?G&

C&S& that fa ed the C&S& document e hibit D in the complaint) to ediatric &ssociates to effect the

unreasonable sei9ure of medical records. +here is more but this /ill suffice in demonstrating that

plaintiffs /ere snatched b* a group of business people /ith significant potential for conflicts of

interest. laintiffs believe this group of people to be !$$B business, and 0ids are their 6ustification for

more funding. Could it be that there is substantial pressure revenues must al/a*s go up) to

unreasonabl* ac1uire 0ids b* the 6uvenile courtE Could this possibl* contribute to the unla/ful sei9ing

of 8.C.E &ccording to defendant 'ambo on December !$th, 4$!4, ; ve been %he :uvenile ' ur% :udge

12 years and never had ne %hese 'ases. ; laintiffs assert the reason is because most people reali9e

that refusing a tetanus vaccine is not reasonable grounds to sei9e, in this case, an alread* traumati9ed

little bo* from his parents /ho /ere obviousl* attempting to secure urgent medical attention for him.

laintiffs hereb* command defendant (isa Coogle 'ambo to immediatel* produce her

legitimate authorit* for her actions against these plaintiffs.

age ! of !%


16/18

laintiffs further command defendant and alleged ublic +rustee (isa 'ambo to

immediatel* account for her breach of dut* to the plaintiffs beneficiaries).

8or the foregoing reasons and all the others revealed in the plaintiffsJ complaint, defendant

'ambo-s motion to dismiss should be denied.

age !% of !%


17/18

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18/18

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Documents

Rebuttal to defendant Lisa Rambo's motion to dismiss