President Obama Uphold Human Rights and "Expand Our Moral Imagination"- Today Save German African Jewish American 7-yr old Little Ambassador, Ariana-Leilani King-Pfeiffer - "All of us- we should do everything we can to make sure this country lives up to our children's expectations"

ROY L. MORRIS, ESQ.
 PO Box 100212
 Arlington, VA 22210
 202 657 5793
 509 356 2789 (Fax)
 Roy_Morris@alum.mit.edu
 Member of the Bars of the:
District of Columbia and
United States Supreme Court
September 29, 2010
President Barack H. Obama

The White House
1600 Pennsylvania Avenue NW
Washington, DC 20500
United States of America
Re: Please Save 7-year old “Little Ambassador” Ariana-Leilani King-Pfeiffer From
The Ravages of The “Silent War” of Child (Mis)Use, Abuse, and Neglect
Dear President Obama:
Right here and right now in the United States there is a silent war. In this "silent war," the vic-
tims of abuse and neglect include children who suffer, because no one will listen or believe their cries for
help. The perpetrators of this domestic silent war on children are child abusers, who are most often
trusted adults, including parents. They victimize their own children through sexual and physical abuse,
child pornography and even trafficking of their own children. Disturbingly, the enablers of this silent
war on children, including little Ariana-Leilani, are often the very institutions who are mandated to pro-
tect and help them, that includes the local family courts which often act in secrecy, and the "Child Protec-
tion Services" who treat everything they do as "confidential" void of any transparency thus making them
unaccountable and prone to corruption. In addition, in Ariana-Leilani’s case, even the US State Depart-
ment's Office of Children’s Services claims to be powerless to take effective action, even though Ariana-
Leilani is a citizen of Germany who is living in the United States. October is Domestic Violence Aware-
ness Month. This is not the time for excuses, but a time for action.
Ariana-Leilani King-Pfeiffer is a very ill child who is being denied life-saving medicine, G-CSF
to boost her immunity to normal levels. It is well documented by medical records that Ariana-Leilani has
suffered from Severe Chronic Neutropenia of undiagnosed cause since Fall 2008. Severe Chronic Neu-
tropenia is severely low immunity, similar to that suffered by those with HIV/AIDS, which renders them
very vulnerable to fatal infection. This very rare condition began when Ariana-Leilani was placed in the
custody of her father, Dr. Michael H. Pfeiffer, a German national living in Washington DC, who, as a
neurologist, would have easy access to psychotropic drugs (e..g, benzodiazepine "date rape" type drugs)
that can cause neutropenia. She is now only one of 1300 people worldwide on the Severe Chronic Neu-
tropenia International Registry (SCNIR). The Co-Directors of the SCNIR, Prof. Dr. Dale (US) and Prof.
Dr. Karl Welte (Germany) have written letters supporting the need for immediate intervention to save
Ariana-Leilani’s life with G-CSF. Without it, she is at high risk to suffer “toxic shock, loss of limbs or
loss of life” (Dr. Dale, July 2010). They have also stated that taking all the test results into account, the
Severe Chronic Neutropenia is likely “induced by toxins”/drugs (Dr. Welte, August 2009).
Since Fall 2007 various child protection institutions have documented that Ariana-Leilani has
been complaining about her father sleeping in her queen sized bed in a one bedroom student apartment,
and doing "bad touch," and “naughty touch.” Ariana-Leilani complained to a court officer, but, although
the officer noted it, she did nothing about it. Ariana-Leilani complained to a Montgomery County (Mary-
land) forensic investigator, but, although she noted it, she also did nothing. Ariana-Leilani has also com-
plained that her father gives her "green medicine" that "makes me sick." Ariana-Leilani has been diag-
nosed with Post Traumatic Stress Disorder (PTSD) and Dissociative Identity Disorder (DID) since 2008
with no treatment to date. No one in all of these "protection" systems has effectively protected her since
2007. It seems that the more people who don't act on her cries for help, the longer the list gets of those
"group thinkers" who completely ignore her obvious health problems and the abuse that has caused it.
Letter to President Barack O'Bama
September 29, 2010, Page 2
When her mother tried to get Ariana-Leilani protection with a domestic violence temporary protection
order and sought to get her a full medical and sexual abuse evaluation at New York's Montefiore Chil-
dren’s Hospital, the abusive father had her arrested and had the evaluation stopped. Since then the US
family courts have allowed him to fully isolate Ariana-Leilani from all of her family in the USA and
Germany, her friends, her religion and her school in order to gain full control. Ariana-Leilani has been
cut off from all contact with mother -- who was the only person who she could trust to help her.
The international community is horrified and outraged. The United Nations Human Rights
Commission, Convention on the Rights of the Child Special Rapporteur for Sale of Children, Child Pros-
titution and Child Pornography has sent an urgent formal letter to the United States Government in Janu-
ary 2010 requesting the US Government take action. Also, Innocence in Danger International (France),
the German Government through the German Embassy, and the Co Directors of the Severe Chronic Neu-
tropenia International Registry, have all expressed serious concern that this child is not getting the medi-
cine and/or full independent medical and psychological evaluation and protection she desperately needs.
The US's apathy to the child's medical and abuse condition is unexplainable. Why are these institutions
more interested in protecting the abusive father rather than addressing the child's obvious life-threatening
medical and debilitating psychological needs. Could it be that because Ariana-Leilani’s father does hu-
man medical research in Neurology for the United States Government at the Veterans Administration
Hospital in the District of Columbia, he is being protected at the expense of his severely ill daughter? As
you have said many times, “No one is above the law.” Such US misbehavior would not be anywhere in
the vicinity of the "moral high ground."
As a human being, Ariana-Leilani was born with “human rights.” As a German child, Ariana-
Leilani is entitled to protection under the UN Convention on the Rights of the Child, including her rights
to life, health and health services, and freedom from torture or cruel, inhuman or degrading treatment. As
an American child she is entitled to protection under the CRC Optional Protocol on Sale of Children,
Child Prostitution and Child Pornography as requested by the Special Rapporteur to the US Government.
To date these basic human rights have been denied by the US institutions.
We appeal to you, as the President, our moral leader, and as a father, to lead your administration
to get this child the necessary medicine and the full medical (as well as criminal) investigation into the
root cause of her very rare illness and the associated psychological issues. Alternatively, we request that
your administration allow the German Government to take the lead in protecting this German child. Her
possible death, as a result of this “domestic silent war” in Washington DC, the backyard of our White
House, would be an international tragedy that would bring into question the United States’ commitment
to the human rights of all children within its borders. We are confident that immediate action, including
a thorough investigation of Ariana-Leilani's situation, will pull back the curtain to expose and help cure a
growing silent cancer of our society, child (mis)use, abuse and neglect in America. Please listen to the
drumbeat of international voices that continue to plead to get her the help to save her life.
Attached are the letters from the Germany Embassy to the State Department and from The Severe
Chronic Neutropenia Registry Professor Dale and Professor Welte, and my letter to the Department of
State, Office of Children’s Services explaining the failures of the US local institutions to protect this
child. I would be happy to provide additional information at your request and meet with members of
your administration to get this problem investigated and addressed before it is too late.
Sincerely,
Roy Morris, Esq.

Public Interest Attorney and
Pro Bono Counsel for Dr. Ariel King (who lives in Germany)
cc: Honorable Hillary Clinton, Secretary of State,

US Department of State, 2201 C Street NW, Washington, D.C. 20520
Eric Holder, Attorney General , US Department of Justice

950 Pennsylvania Avenue, NW, Washington, DC 20530-0001
Exhibits to September 29, 2010
Letter to President Barack Obama
1
2
&

I Embassy
.. of the Federal Republic of Germany
I,* Washington
Mr. Michael B. Regan

ADDRESS
Director 4645 Reselvoil RO<ld . N.W.
Office ofChildren' s Issues Washington, D,C, 20007
U.S. Department of State
220] C Street N.W., SA-29, 4th Floor iNTERNET www.germany.info
Washington, D.C. 20520 TEL + 202 298 8140 (Switchboard)
rAX' 202 411 5558
Klaus Botzel
Consul Genera! and Legal Adviser
TH,OIRECT 2022984361
Tk,;@wash,dipiode
Ariana-Leilani Margarita Alexandra KING-PI<EIFFEH
Ref. No, {please .::itt: in respons.:): RK 520, SE King-Pfeiffer
Washington, D.C., August 17,20 I0
Dear Mr. Regan ,
Please allow me to bring to your attention and seek your assistance in the case of
seven year old KING-PFEIFFER, a child with dual German and American
citizenship. She is living with her father, the German national Dr. Michael Pfeiffer, ill \Vash-
ington , D,C. Her mother, Dr. Ariel King, a U.S. citizen, lives in Germany.
Earlier this year, the NOO Innocence in Danger International has brought serious concerns
about possible medical mistreatment and possible sexual abuse of the child by the father to
the attention of the Embassy. The concern s related to based. on the
child's extensive medical and school records, and were supported by physicians of the Severe
Chronic Neutropenia International Registry and the German NGO Avalon.
The German Embassy so far has had no direct access to the child nor to information fi'o m an
independent source. As of today, the F,mbassy has received documentation on the child's
case consisting of medi ca l test records from George Washington University Hospital
(GWU H), opinions and school health records. UnfOitunately, without the consent of the fa-
ther who has sole custody, the Em bassy has no way of veri tying the status of the chi Id, orthe
information it has been given,
In any event the allegat ions are of such a serious nature. that we feel that a fully independent
medical examination of rhe child should be ordered by the competent U.S. authorities. A
divorce and custody case is currently pending in Bayreuth, Germany. The mother claims that
the father refuses to agree to allow her, or anyone actin g on her behalf; to have direct contact
with her child, the child's sole treati ng physician at G\VlJH, and GWUH itself. The mother is
represen ted by Mr. Roy L. Morris, Esq., Arlington, VA. The father is represented by Mr.
Sean W. O' Connell, Arlington, VA.
3
' ..?.:;.,
GWUH health recOrds, which were forwarded to the Embassy, state that the child suffers
from Severe Chronic Neutropenia, a medical condition which consists of severely low immu-
nity levels over an extended period of time that leave the child vulnerable to potentially fatal
infections. The Embassy was also provided with opinions from international experts in the
field of pediatric hematology who expressed serious concerns for the child's safety. In the
opinion of these experts there is a lack of a thorough evaluation of the cause of the medical
condition of the child and a lack of an appropriate treatment with a rnedical drug called
GCSF which boosts immunity to more normal levels. However, these medica! experts have
not yet had the possibility to examine the child in person.
The mother believes that the medical condition of the child could have been induced by the
administration of a particular psychotropic drug. According to her, the sole treating physi-
cian's reports are biased because he is an associate of Dr. Pfeiffer at GWUH , and his reports
show inconsistencies with regard to the medical tests and school reports.
The Embassy was informed that Dr. Pfeiffer has been working at GWUH as a physician until
2008. Reportedly he is currently working for the Veteran's Admini stration Hospital in
Washington, D.C.
The report from a guardian ad litem in 11 past child clIstody case notes that the child purport-
edly lives ina one-bedroom apartment with her nlther. The representative of the mother, rvlr.
J\1orris, forwarded documents which include a statement of a clinical psychologist from
Maryland who, based on medical records, interviews of the mother, and other documentation,
utters her professional opinion in writing that the child Ariana-Leilani " ... continues to be at
risk in her current environment of both physical and medical neglect, and likely sexual
abuse. "
The German Embassy has a legal obligation under Art. 5 of the German Consular Act to sup-
port German citizens in need of assistance. A written proposal fI'om the Embassy dated
March 30, 2010, to let the child undergo a full independent medical examination on a volun-
tary basis -- and which costs the mother's health insurance in Germany would cover - has
been declined by the father's lawyer, Mr. O'Connell. So far, the father has refused to com-
municate I.",ilh the Embassy directly.
The possibilities of the Embassy are limited to voluntary cooperation and have been ex-
hausted. The German Embassy would therefore be grateful if the Department of State could
lake up this matter in order to obtain an independent medical examination of Ariana-Leilani
King-Pfe iffer. Once her true health status is clarified, optimal medical care for her seemingly
serious medical condition can be ensured .
If you have questions in this matter please do not hesitate to contact me. [am including a list
of points of contact and a copy of a letter from the University of Washington , Department of
Medicine, in this matter for your information.
With many thanks for your support.
./CL
Botzet
4
TRANSLATION
Medical School
Hanover, Germany
Lower Saxony Professorship – 65 plus Research
Prof. Karl H. Welte, Dr. med.,

Director, Department of Molecular Hemopoiesis
Dr. Kerstin Niethammer-Jürgens Center for Pediatrics and Adolescent Medicine
Am Neuen Garten 4 OE 6790
Phone +49-(0)511-532-6710
Fax +49-(0)511-532-6998
14469 Potsdam welte.karl.h@mh-hannover.de
Germany
Carl-Neuberg-Str. 1
30625 Hanover, Germany
www.mh-hannover.de
31 August 2009
Medical Opinion
ALM ALM born 7 May ALM
Dear Dr Niethammer-Jürgens,
This report deals with the abovementioned patient whose mother accompanied by Ms Hebart-
Herrmann with medical records consulted us on 31 August 2009. Unfortunately the child is at
present in the USA so that we were unable to examine her in person.
On the basis of the medical documents produced we have arrived at the following evaluation:
Diagnoses:
• Severe chronic neutropenia of unknown origin,
no exclusion of a mutation in the genes ELA2/HAX1/SBDS
• To date no indication of an antibody-induced immune neutropenia
• To date no therapy with hematapoietic growth factors
Case history (Anamnesis):

For the detailed anamnesis you are referred to the numerous records. According to information
provided by the mother, the child developed normally relative to its age until May 2008. There was
no unusual increase of infections. In a hemogram during a routine check-up, the primary care
physician discovered the neutropenia which was subsequently confirmed. At the time the child was
without infection, and there was no indication of an underlying primary disease. The absolute
neutrophil count in the majority of findings was under 500/µl.
Further diagnostic investigations to clarify the cause of the severe neutropenia with continuous
absolute neutrophil counts under 500/µl were only undertaken in July 2009 at the Georgetown
Pediatric Hematological-Oncological Outpatient Dept. Day Unit Roof Terrace Ward 64a Ward 62
Tel. +49-511-532-3214 88 Tel. +49-511-532-3288 Tel. +49-511-9411
5
University Hospital, Washington, by Dr Myers. There was no sign of maturation arrest of
granulopoesis as an indication of a congenital neutropenia. At the same time there was no
evidence of a malignant systemic disease. Taking the bone marrow findings and the persisting
severe neutropenia together, the most likely assumption is a bone marrow disease caused by an
infection or induced by toxic agents.
Recommendations:
ALM is suffering from a severe chronic neutropenia of hitherto unknown origin.
In view of the fact that a chronic neutropenia with absolute neutrophil counts of under 500/µl
involves the risk of a life-threatening infection, treatment with the hematapoietic growth factor G-
CSF, e.g. Filgrastim, should be initiated urgently.
In view of the unknown origin of the neutropenia we recommend that the diagnostic investigation
be continued in order to exclude an autoimmune disease, an infectious disease and a malignant
systemic disease.
Independent of this we recommend that a bone marrow screening with histology and cytogenetics
be repeated in approx. one year.
A conclusive assessment is only possible after personal consultation with the child.
Yours etc.
[signature]
Prof. Karl Welte, Dr. med.

Co-Director SCNIR (Severe Chronic Neutropenia International Registry)
Pediatric Hematological-Oncological Outpatient Dept. Day Unit Roof Terrace Ward 64a Ward 62
Tel. +49-511-532-3214 88 Tel. +49-511-532-3288 Tel. +49-511-9411
6
David C. Daile, MD
Professor of Medicine
Anna Bolyard, RN, BS
Research Nurse
July 9, 2010
The Honorable Klaus Botzet

Consul General and Legal Advisor
Embassy ofthe Federal Republic of Germany
4645 Reservoir Road NW
Washington, DC 20007 -1998
RE: Ariana-Leilani King-Pfeiffer

German Passport No: 875289379 (per mom, Dr. Ariel King)
Dear Mr. Botzet:

i
I an1 wTiting on behalf of Ariana-Leilani King-Pfeiffer who has been recently enrolled as a
participant of the Severe Chronic Neutropenia International Registry (SCNIf) in Germany. The
SCNIR was established in 1994 to study the rare condition of Chronic Neutfopenia and is funded by
the NIH. I
Neutropenia is the condition of having lower than normal neutrophils. A nqrmal absolute neutrophil
count (ANC) is maintained at approximately 2000-5000 lemm, allowing a person to fight off
infections. Mildly neutropenic patients have an ANC between 1000 to 150q Icmm, moderately
neutropenic patients have an ANC between 500-1000 Icmm, and severe chrrnic neutropenia is the
rare condition where the bone marrow doesn't produce sufficient neutrophils to keep the levels in the
blood above the 500/cmm level, resulting in not enough neutrophils to fightlinfection. Ariana-
Leilani has severe chronic neutropenia; her neutrophils were consistently be~ow 500 without G .. CSF
treatment. .
Neutrophils are very important because they fight infection. When bacteria!invade the body a
chemical signal is sent out and the neutrophils, like fire fighters responding 0 a blaze, rush to the site
of infection. The bone marrow also responds by speeding up its production bf neutrophils to replace
those involved in fighting the infection. If, however, production of new neWrophils is suppressed or
slowed down, a shortage may develop, and any infection can overwhelm th~ few neutrophils
available. Therefore, a person with only a few neutrophils is at particular risk for developing a
serious bacterial infection. j
Department of Medicine • University of Washington .. Box 356422
1959 NE Pacific St .. Seattle, WA 98195-6422 .
Dr. Dale: Phone 206-543-7215 • Fax 206-685-4458 • Email: ds:dalc(ZiJu. tvashington.edu
7 Audrey Anna Bolyard: Phone 206-543-9749 .. Fax: 206-543-3668. E-mail: bol\1ardra;tl.washington.edu
Many SCN patients are treated with G-CSF, a hormone that increases the neutrophil level. This
medication will help fight infection by raising the neutrophil count. Even With the administration of
G-CSF, the neutrophils may still drop to critical levels. G-CSF allows the patient to fight infection
better than the untreated patient, but infection is still a constant concern. T~e treated patient "rill
continue to experience infections, hopefully not life-threatening infections' i The neutropenic
person's life may be greatly affected by her/his inability to fight infectionS,\
The SCNIR follows over 1300 SCN patients. We have tracked each ofthe$e patients, gathering
medical information over the last 16 years for the Registry and 7 years beDl'rc that in clinical blaiS.
Our mission is to follow closely the health of neutropenic patients and to e .ntinue to research::he
mechanisms causing this condition. The SCNIR is actively distributing infprmation regarding SCN
to doctors and patients. The goal is to help the local physician become mo~e knowledgeable about
this rare and difficult condition, and to prevent the severe consequences odmtreated SCN: Toxic
shock, loss oflimbs, and loss oflife.
If you have any questions, the SCNIR web site is very helpful: 1=1t"",t~="'-'t=s.,+.,!ashington.edulrcgistm
Please feel free to contact me directly at 1-800-726-4463.
Thank you.
Sincerely,
David C. Dale, MD
Professor of Medicine
AUdrc~d' RN, BS
Clinical Manager SCNIR
DCD/las
i
Department of Medicine. University of Washington. Box 356422 ..
1959 NE Pacific St. Seattle, WA 98195-6422
Dr. Dale: Phone 206-543-7215. Fax 206-685-4458 • Email: lli:da!e:(vu.\ ·ashington.edu
8 Audrey Anna Bolyard: Phone 206-543-9749 • Fax: 206-543-3668 • E-mail: =L'.4"~~~"';~'-"'=~~~
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ANC Below 500 (Severe Chronic
Neutropenia) Requires
Hospitalization
9
Low and High Values
!
BLOOD NORMAL 8/13/2008 10/10/2008 10/22/2008 1/9/2009 3/27/2009 6/26/2009 7/21/2009 10/16/2009 11/10/2009 11/11/2009 12/18/2009 12/21/2009 3/12/2010
Before GCSF After GCSF

WBC 4.8-10.8 L 3.5 L 4.1 4.1 3.3 3.2 L 3.1 L 2.9 L 4.1 L 3.5 L 7.0 N 2.6 L 3.2 L 3.7 L
RBC 4.2-5.4 3.93 L 4.13 L N 4.13 L 4.01 L 4.07 L 4.13 L
HGB 12.0-16.0 10.8 L 11.4 L 11.3 L 11.5 L 11.2 L 11.6 L 11.8 L
HCT 37.0-47.0 32.3 L 34 L 33.8 L 33.8 L 32.4 L 33.7 L 34.1 L
MCV 81-99 80.4 L 80.3 L 80.7 L
RED CELL Distrubition width 11.5-14.5 14.6 H
MCH 27-31 26.9 L 26.8 L
MCHC 31.8-34.6 35.1H
RDW 12.2-14.4 12.0 L
MPV 7.4-10.4 6.7 L 6.8 L 7.0 L 7.0 L 7.3 L 6.7 L 7.1 L 7.2 L 6.8 L 7.9 L
GRAN % NEUT 53-79 28.0 L 25.0 l 16.5 L 14.9 L 32.8 L
LYMP 13-46 62.4 H 58.5 H 63.1 H 48.6 H 63.8 H
MONO % 3 TO 9 12.3 H 15.1 H 15.2 H 17.2 H 12.1 H 14.1 H 12.2 H 13.8 H 16.7H 13.4 H
EOS 0 TO 4 13.5 H 15.2 H 6.8 H 6.6 H 8.8 H 12.4 H 12.4 H
NEUT ABSOL # 1.8-7.8 1.20 L 1.00 L 0.50 L 0.50 L 0.5 L 0.9 L 0.4 L 0.4 L 0.5 L
NEUTRO% 29.8-71.4 9.4 L 12.7L 49.8 N 16.4 L 12.6 L
Differential Manual
NEUT 53-79 25 L 20 L 20 L 10 L 12 L 15 L 33L
NEUT ABSOL # 1.3 - 8.1 .88 L 0.82 L 0.33LL 0.38 LL 0.47 LL 0.96L 0.4 L 0.5 L 3.5 N 0.5 L
LYMP 13-46 55 H 48 H 48 H 72H 68 H 69 H 49H
LYMP MAN % 16.7-57.8 63 H 59.7 H 30.6 N 62 H
MONO 3 TO 9 14 H 12.3 H 12 H 14 H 12.2 H 5L
SEG MAN 30-71
MONO MAN 4 to10 14 H 12 H 12 H 18 H
EOS % 0-4 13.5 H 15.2 H 6H 7H 18 H 8.5 H
Eosinophil Abs 0.0 - 0.5 0.7 H 0.6 H
EOS MAN 0 TO 4 8H 10 H 17 H 14 H 8H 6H
BASO 0-2
BASOPHIL % 0.0-0.6 1.1 H 0.9 H 1.9 H
BASOPHIL MAN 0-1 3H 2H 14 H
ATYP LYHP 0 -0 2H 2H 2H 3H
Ldh 91-180 213 H 209 H
Alko Phosphatatse 39-117 169 H 135 H 216 H
Phosphorous 2.4-4.5 4L 4.6 H
Sodium Lvl 137-145 136 L
Sodium 137-145 136 L
Chloride 101-111 100 l
Sed Rate 0-20 36 H
Sodium 135-145 134 L
10
ROY L. MORRIS, ESQ.
! PO Box 100212
! Arlington, VA 22210
! 202 657 5793
! 509 356 2789 (Fax)
! Roy_Morris@alum.mit.edu
! Member of the Bars of the:
Mr. Michael B. Regan

Director
Office of Children' s Issues
U.S. Department of State
2201 C Street N.W., SA-29, 4th Floor
Washington, D.C. 20520
Ariana-Leilani Margarita Alexandra KING-PFIEFFER
via
Klaus Botzet
Legal Adviser and Consul General
Embassy of the Federal Republic of Germany
4645 Reservoir Road, NW
Washington, D.C. 20007
Tel: (202) 298-4361
Fax: (202) 471-5558
Mail: rk-1@wash.auswaertiges-amt.de
Ref. No, {please cite: in response:): RK 520, SE King-Pfeiffer
Washington, D.C., August 30, 2010
Dear Mr. Regan,
At the request of Herr Botzet, Consul General to the Embassy of Germany, I am writing
to provide a brief factual and legal basis for the impropriety of, and objections to, any involve-
ment of Washington DC Child and Family Services Agency (DC CFSA) in the Embassy's re-
quest for aid in obtaining independent medical and psychological examination (including needed
immunity-boosting GCSF medicine). It is undisputed and supported by medical and school re-
cords that seven year old Ariana-Leilani has suffered for over two years from a life-threatening
and very rare case of severe chronic neutropenia (SCN) of purposely undiagnosed cause, as well
as showing evidence of physical and sexual abuse. This letter complements the August 17,
2010 letter of Herr Botzet to Mr. Regan, and thus will not repeat the significant objective evi-
dence and broad scale concern that exists for Ariana-Leilani's life-threatening health condition.
Documentation presented along with this letter includes letters to the DC Mayor (still
pending a response), CFSA Director Dr. Roque Gerald (still pending a response), DC City Coun-
cilmember Tommy Wells (whose committee oversees CFSA, still pending a response), the DC
Chief of Police requesting an independent investigation of DC CFSA (still pending a response),
testimony before the DC City Counsel Human Services Committee requesting an independent
investigation of the CFSA actions (still pending a response), a Freedom of Information Request
Complaint against CFSA/DC in the DC Superior Court (still pending), a letter to Children's
11
Letter to Mr. Regan, US Department of State
August 30, 2010 - Page 2
dren's National Medical Center pointing out the flaws in its April 2009 examination of Ariana-
Leilani due to misinformation and manipulation by DC CFSA (still pending a substantive re-
sponse), briefs before the DC Court of Appeals regarding an appeal of a DC Superior Court
medical neglect case with which CFSA interfered (still pending), and the April 2010 Decision of
Lashawn case US District Judge Hogan holding DC CFSA in contempt for the time period dur-
ing which CFSA was investigating reports by mandated reports of abuse and neglect of Ariana-
Leilani. These documents and their exhibits clearly demonstrate that CFSA cannot be involved
in any independent evaluation and treatment because:
1. Despite verbal and written reports by mandated reporters in October 2008 (by Dr.
Robert Sklaroff, a 30 year expert in hematology/oncology) and again in April 2009 (by Dr. Rob-
ert Sklaroff, after reviewing updated records since his October 2008 report), DC CFSA has never
properly investigated the cause or basis for Ariana-Leilani's two year old Severe Chronic Neu-
tropenia (SCN) -- which she has suffered with since Spring 2008 when she began to regularly
live with her German father in Washington DC. DC CFSA has completely ignored the Severe
Chronic Neutropenia condition, failed to properly follow its LaShawn mandated protocol for
such investigations, and has not done any follow-up despite Ariana-Leilani's continuing worsen-
ing condition [Her most recent August 2010 medical records show her ANC (the measure of her
ability to fight infection) has dropped to below 200 (less than 10% of the minimum level of
3000) as recently as June 2010 -- which should require hospitalization].
2. Even within its statutorily limited mandate to investigate "medical neglect" and "sexual
abuse," DC CFSA has failed to properly investigate where three mandated reporters (Dr. Robert
Sklaroff (hematologist/oncologist expert witness (October 2008 and April 2009)), Dr. Joy Sil-
berg (Shepherd Pratt Hospital PhD psychologist expert in abuse and neglect, and dissociation
(April 2009)), and Dr. Lee Schreyer (PhD psychologist expert in child abuse (August 2008 and
April 2009)) made medical neglect and sexual abuse reports directly to DC CFSA,
3. Since the time when those original reports to CFSA were made and not properly in-
vestigated, two world experts who are the Co-Directors of the Severe Chronic Neutropenia Inter-
national Registry (Prof. Dr. Karl Welte of University of Hamburg, and Prof. Dr. Dale of Univer-
sity of Washington) have written opinions expressing concern about the continuing failure to
properly diagnose and treat Ariana-Leilani's SCN, and the continuing failure to give the child
therapeutic GCSF medication (to boost her immunity to avoid fatal infection and help eliminate
the neutropenia). Because of the severity of her condition, she has been placed on the Severe
Chronic Neutropenia International Registry (SCNIR) where only the most severe cases in the
world are selectively listed -- 1300 in total.
4. From the beginning of the case, CFSA has chosen not to properly investigate Ariana-
Leilani's case. In his first October 2008 report to CFSA, Dr. Sklaroff complained that the under-
lying cause of the child's life threatening condition had not being properly diagnosed and treated,
and that the father failed to have her seen by a hematologist/oncologist, CFSA, in violation of its
own policy, failed to take the child to the Children's National Medical Center (CNMC) within 24
hours for a physical examination of the neutropenia condition. Instead, after four days of nego-
tiations with the father, CFSA let the father (who was suspected of medical neglect) take the
child on his own to his former workplace, Georgetown University Hospital, for a blood test
evaluated by a relatively inexperienced GUH hematologist/oncologist, Dr. Scott Myers. The
records show that the father gave Dr. Myers false information concerning the origins and pur-
pose of the visit, as well as the complete medical history of the child. The inadequacy of that
first visit was demonstrated by the fact that only two weeks later, Ariana-Leilani was forced to
return to Georgetown Hospital (October 22, 2008) with what the medical records described as
"mouth ulcers of recent onset suspicious for a viral infection (Herpes)" and "Abnormal - 4-5 1
cm papular lesions bilaterally in groin area," leading to the taking of a culture for “suspicious for
a viral infection (Herpes)." That visit, where sexually transmitted herpes was suspected by an-
other attending physician, Dr. Abu Ghosh, was never followed by CFSA.
12
4. DC CFSA's General Counsel James P. Toscano has actively interfered with Ariana-
Leilani's case since 2008. For example, he personally interfered with the legal case brought by
Dr. King in DC Superior Court (King v Pfeiffer, Case No. 09 DRB 1167), where Dr. King sought
a court order for an independent medical examination for the Severe Chronic Neutropenia in
April 2009. Mr. Toscano, who had neither been subpoenaed or subject to a court order to ap-
pear, showed up in that courtroom at the request of Mr. Pfeiffer's attorney, Mr. O'Connell. In
the Courtroom, Mr. Toscano appeared nervous and acted overtly subservient to Mr. O'Connell.
Mr. Toscano provided misinformation to the court concerning the alleged timing and nature of
CFSA's actions. Mr. Toscano successfully resisted discovery that would have revealed to the
Court the lack of basis for his false claims and the conflict of interest that caused his aberrant ap-
pearance. CFSA's misconduct in that court case are the subject to an appeal of the DC Superior
Court's, and raised in the DC Court of Appeals opening and reply briefs in King v Pfeiffer, Case
No. 09-FM-1484 (see attached). It places CFSA in an adversarial posture to Dr. King. The DC
Court of Appeals has scheduled oral argument for October 20, 2010.
7. Since his aberrant April 2009 appearance, it has been discovered that DC CFSA’s
General Counsel was arrested for a sex offense and agreed to supervised one year probation in
Arlington — where Mr. O’Connell regularly practices. The arrest was for indecent exposure
(masturbating in a urinal while looking into a neighboring stall) in a public restroom frequented
by minors. Mr. Toscano's Arlington sexual offense arrest came to light when possible connec-
tions between CFSA's James Toscano and Sean O'Connell (Mr. Pfeiffer's Arlington lawyer) were
being investigated. According to the 2007 DC CFSA policy statement such an arrest with pro-
bation should have resulted in an immediate termination from any position involving contact
with children. It is assumed that Mr. Toscano avoided that adverse outcome possibly through
some type of loophole or by hiding his arrest record from the CFSA. Mr. Toscano only recently
had his 2004 sex offense arrest with probation expunged in June 2010, but then only after it was
brought to the public's attention in testimony before DC CFSA Director Dr. Gerald and the DC
City Councilmember Tommy Wells in March 2010, followed by a letter to them in May 2010
(see attached).
8. In April 2009, CFSA also interfered with Ariana-Leilani getting a proper medical ex-
amination and, in turn, GCSF medicine at Children’s National Medical Center (CNMC). As
noted above, the CFSA policy requires that all cases be brought to the CNMC within 24 hours.
However, CNMC records show that when Ariana-Leilani was brought to CNMC by the father
(the suspect for neglect/abuse) and the CFSA case worker Mr. Magnusson, the CNMC staff were
specifically instructed not to look at the neutropenia, the CNMC staff were given false informa-
tion about who filed the complaints at CFSA, and the CNMC were told not to interview the
child, even though the records show that the child had not been interviewed since August 2008
(3/4 of a year before any of the April 2009 mandated reporter complaints were made to CFSA).
After Dr. King was able to obtain the CNMC medical records, a letter critical of CNMC was
written to its CNMC evaluation center's director in May 2009 that pointed out the serious prob-
lems with its handling of Ariana-Leilani's case. CNMC has yet to respond or correct the obvi-
ous problems identified in that letter. Furthermore, although CNMC noted that its staff had di-
agnosed Ariana-Leilani with DSM 308.1 “post traumatic stress disorder,” had “concerns for sex-
ual abuse,” and recommended psychological “therapy,” both CFSA and CNMC failed to get Ar-
iana-Leilani the psychological treatment prescribed, or do any follow-up. Despite those open
issues that CNMC identified, CFSA irresponsibly closed the case as "unfounded."
9. The May 2009 Letter of DC CFSA Social Worker, Kerstin Magnuson (who is also a
law student a Georgetown) was apparently written as a personal favor, because it does not reflect
the record. On June 9, 2009 -- one month after the May 2009 letter of Ms. Magnusson that
claimed that the case was closed as "unfounded" -- CFSA's Dr. Cheryl Williams, who is its head
medical officer, faxed a request to GUH for Ariana-Leilani's medical records. Dr. Williams fax
request indicated that the CFSA investigation was ongoing -- conflicting with Ms. Magnuson's
13
May 2009 letter's claims. The June 2009 CFSA fax request to GUH was the subject of an ex-
change of letters between CFSA's Director Dr. Roque Gerald and myself (found among the at-
tachments here). To date, Dr. Gerald has failed to substantively respond to the issues raised in
my most recent letter of August 3, 2009, including the obvious inconsistencies between Dr. Wil-
liams fax, Mr. Toscano's claims to the Superior Court, and Ms. Magnuson's May 2009 letter to
Mr. Pfeiffer.
10. Dr. King's Counsel has also testified before the DC City Council Committee on
Health Services (which oversees CFSA) asking for an independent investigation of CFSA and
Mr. Toscano's actions (see attached Testimony of March 11, 2010). Once again, no action was
taken and no response has been received from the Committee Chair DC City Councilmember
Wells or CFSA's Director Dr. Roque Gerald. In the past, US Congressman Christopher Van
Hollen, Maryland Representative Brian Feldman, and Eileen King, The Director of Justice for
Children have all written letters requesting a thorough investigation into the medical neglect and
sexual abuse.
11. As recently as June 2010, Dr. King received an inquiry allegedly from a CFSA
worker who claimed she was investigating a case based on “something the mother said.” I wrote
a letter to Councilmember Tommy Wells and CFSA Director Gerald on June 6, 2010, pointing
out the irregularity of that CFSA contact. Neither CFSA's Director Dr. Gerald or Councilmem-
ber Wells has responded to either letter and nor have they explained that CFSA inquiry.
12. The DC public schools have produced nursing visits records for Ariana-Leilani that
show 14 visits to the nurses office in less than 9 months for bruises, bumps, scraps, cuts, inconti-
nence, and hygiene. The school system has been advised of Ariana-Leilani's serious conditions
(severe chronic neutropenia, asthma, and unusual weight gain) but they claim that they are un-
able to help.
13. Investigations by the DC Police for criminal misconduct (which are supposed to be
initiated whenever DC CFSA receives a medical neglect or sexual abuse report) have also been
flawed or non-existent. Internal documents show that DC Police's investigation in August 2008
relied solely on information from and interviews with Mr. Pfeiffer and his Attorney. The DC
Police Investigators did not contact the mandated reporters who made the sexual abuse and
medical neglect reports, ignored the interviews they had with Dr. King and her counsel, and ig-
nored the existence and persistence of Ariana-Leilani's Severe Chronic Neutropenia condition.
As recently as June 2010, Dr. King received an inquiry allegedly from the DC Police Depart-
ment's investigation unit. The investigator admitted that she was completely confused about why
she was calling and the facts of the case. Counsel for Dr. King had a 42-minute telephone con-
versation with that alleged Police Investigator, and offered to provide her with up-to-date docu-
mentation. However, she failed to follow-up. A letter was written to DC Councilmember Wells,
CFSA Director Dr. Gerald and Police Chief Lanier raising concerns about this aberrant inquiry.
In response, the Assistant Chief of Police Newsham wrote to Dr. King's counsel in August 2010
where he claimed that the DC Police had no record of the inquiry. Dr. King's counsel responded
with a detailed letter to Chief Lanier and Assistant Chief Newsham explaining both the long his-
tory of Mr. Pfeiffer has with the DC Police (dating back to his disruptive behavior as an unin-
vited guest at a diplomatic reception at the Zambian Embassy in July 2007 where he had to be
ordered to leave by the US Secret Service'; that violent incident resulted in a Temporary Protec-
tive Order to protect Dr. King and Ariana-Leilani from Mr. Pfeiffer), and the phone record evi-
dencing the 42 minute phone call with the alleged DC Police Investigator (see, August 2010 Let-
ter to Chief Lanier and Assistant Chief Newsham)
14. Using a Freedom of Information Act request, Dr. King has also sought from CFSA
information documenting their activities and correspondence with regard to Ariana-Leilani and
Dr. King. The DC CFSA has refused to provide Dr. King with any information -- including re-
fusing to produce any redacted records and/or a Vaughn Index of any records. That FOIA is now
14
being litigated against CFSA in DC Superior Court (see attached DC Superior Court Complaint
King v District of Columbia, 10 CV 565B, filed January 29, 2010). This case also placed CFSA
in an adversarial position to Dr. King.
15. DC CFSA is under a US Federal Court monitor and was found in contempt as re-
cently as April 2010 for the period of October 2008 through 2009 for failing the children of the
District of Columbia (Lashawn v. Fenty, US District Court Case 89-CV-1754 (TFH)). The con-
tempt order covered the period during which DC CFSA conducted its alleged investigations of
Ariana-Leilani. That contempt order places CFSA in an adversarial position to Dr. King. The
LaShawn case is ongoing and the CFSA remains under a Court monitor due to their continuing
inadequacies -- which Ariana-Leilani has experienced. The CFSA has a demonstrated inability
to follow proper investigative procedures even when ordered by the US District Court Judge Ho-
gan in LaShawn v Fenty (with the court's power to sanction). Given that Judge Hogan with his
power to sanction cannot incent CFSA to act properly after 20 years of oversight, it is unlikely
that the US State Department (which has no power over CFSA) will have any greater success.
In summary, for over two years 2008-2010, Dr. King has exhausted DC CFSA's capabili-
ties and inadequacies, and appealed to the highest levels of oversight for action for Ariana-
Leilani medical and psychological needs, including appealing to the DC City Council and Mayor
Adrian Fenty. All to no avail or success. CFSA has clearly placed itself in an adversarial pos-
ture to Dr. King. Despite the many efforts, these institutions have sat idly by while Ariana-
Leilani remains seriously ill without proper medicine, or oversight care. Even when presented
with objective facts that meet textbook definitions for establishing the need for proper independ-
ent examination and medication, DC CFSA has refused to act. It is more than coincidental that
CFSA has rarely found abuse or neglect in upper middle class non-minority families. Most
likely due to his connections, DC CFSA has clearly gone even further out of its way to give Mr.
Pfeiffer a "free pass," and privileged treatment not normally afforded any other alleged abuse or
neglect subject.
The DC CFSA has a very strong incentive to prematurely close cases like Ariana-
Leilani’s even when facts indicate otherwise -- because CFSA had been primarily graded under
the LaShawn case based on how quickly it closes its cases. The US Federal Court Monitor in the
LaShawn case has observed that CFSA has erroneously prematurely closed as “unfounded” 50%
of its investigation cases. CFSA has shown itself to be an intellectually and morally corrupt
agency, with top officers with known serious personal sexual history problems. Such back-
grounds make CFSA's officials biased and more sympathetic, and even protective to the alleged
abusers. In Ariana-Leilani’s case, CFSA treated Mr. Pfeiffer (the alleged suspect of abuse and
neglect) as if he were a colleague, including freely sharing information (written and verbal) with
Mr. Pfeiffer and his Arlington attorney. At the same time, the CFSA has not shared a single
piece of paper with Dr. King or her counsel — forcing Dr. King to file the currently pending
FOIA lawsuit in DC Superior Court.
An independent medical examination requires that it be independent of all institutions

and individuals who were previously involved — which means that CFSA,1 DC MPD, George-
town Medical Center (and Medstar Health (which owns GUH) affiliated physicians and institu-
tions), and CNMC cannot be involved in any independent investigation because they have all
had previous involvement. These entities only have the incentive to rubber stamp prior conclu-
sions to "validate" whatever flawed actions they previously took. Independence requires an or-
ganization that has the specialized expertise in these matters and does not have an interest in rub-
ber-stamping what has already been done.
1
It is also our understanding that DC CFSA, on its own, cannot require a medical examination if
the father refuses to cooperate. It is also our understanding that DC CFSA is limited by statute
to looking into only the narrow statutorily defined "medical neglect" and "sexual abuse."
15
The Department of State, along with the German Government, should consider a solution
that takes advantage of the many factors that differentiate this case from the "typical" case,
including:
1) the father is a German citizen (whose permanent residence card expires in 2012 and
for whom Dr. King was his sponsor),
2) the child is a dual German and American citizen, and has only a German passport,
3) The father and the child are both living in Washington DC -- which is a federal terri-
tory and under federal jurisdiction.
4) The only divorce and custody proceeding involving this child is in Bayreuth Germany,
5) Top world experts for Severe Chronic Neutropenia both within and outside of the
United States agree that medicine and an independent examination for Ariana-Leilani's
two-year-old SCN condition of still undiagnosed cause is urgently needed,
6) The UN Special Rappateur on Sale of Children, Child Prostitution and Child Pornog-
raphy has communicated its urgent concerns to the US Representative,
7) The father is a federal employee working as a drug researcher–physician at the VA
Medical Center in Washington DC, a federal government facility. and
8) The father has refused to communicate directly with and cooperate with his German
Embassy.
We urge that the State Department consult with the Department of Justice, the ICE, Inter-
national Social Services, The Severe Chronic Neutropenia International Registry, Innocence in
Danger, Avalon (Bayreuth), the Bayreuth Family Court, and the German Embassy, to come up
with a solution based on the unique set of facts here. The US Federal Government has expansive
powers with regards to foreign citizens, immigration and international relations in this set of cir-
cumstances where it is documented that a child's life is in danger.
Ariana-Leilani has unnecessarily spent two year (from five to seven years old) with a
very rare, life-threatening SCN blood disorder of purposely undiagnosed cause, and without
proper medical treatment. Prompt and independent action must be taken now in order to prevent
her from becoming another child abuse/neglect fatality statistic in the District of Columbia.
Sincerely,
Roy Morris
16
ROY L. MORRIS, ESQ.
! PO Box 100212
! 202 657 5793
! 509 356 2789 (Fax)
Dr. Alison M. Jackson, MD, MPH

Director
Children’s Hospital
Child and Adolescent Assessment Center
111 Michigan Ave., NW
Fax: 202-476-3790
May 29, 2009
Re: Mandated Reporters-Based Investigation of ALM ALM DOB 05/ALM

(MR#020787632)
Dear Dr. Jackson,
On April 24 2009 the DC Child and Family Services Agency presented ALM ALM for
an evaluation of “sexual abuse.” That evaluation was brought about by three experts reporting suspected
medical neglect and sexual abuse directly to the Child and Family Services Agency of Washington DC on
April 21, 2009. I represent Dr. Ariel King, the mother of ALM and who is her legal parent.
Based on the medical records we have received regarding that visit, Ms. Ashley D. Gardella, LICSW and
Dr. Deyes received statements of fact from the father, Dr. Michael H. Pfeiffer, the suspected abuser.
Much of that information was clearly inaccurate and misleading, such that it would necessarily have an
impact on the impressions of the evaluators at the Child and Adolescent Assessment Center at CNMC.
We understand that the Children and Adolescent Evaluation Center staff works hard to give your young
clients that best service possible in our nations capital. I am sure you would agree that the best evaluation
requires full and accurate information and disclosure of information – and in situations of alleged abuse,
information should not be gathered from that alleged abuser, but instead either objective sources, if
available, or parties other than the alleged abuser. In this case, where mandated reporters who are
experts in their fields originated the case (not the mother, who is the non-abusing parent, as reported in
the CAC intake record), the information those experts originally provided to CFSA should certainly be
considered. Based on the intake medical records we have been provided thus far by Children’s, your
staff was not afforded this information. The highlights of points of misinformation on the official record
that are corrected by the attached letters, affidavits and medical record are below:
1. Contrary to the Childrens’ intake form, the DC CFSA complaints were not reported by the Mother, but
were reported orally and by written reports by from Dr. Joy Silberg (of Sheppherd-Pratt Psychological
Hospital who reported both abuse and neglect), Dr. Robert Sklaroff (a board certified
hematologist/oncologist who reported problems with the medical neglect of the child), and Justice for
Children (which follows serious abuse cases throughout the United States) (See, Attached Reports):
2. Contrary to the Childrens’ intake form, the suspected herpes was not reported by the Mother, but
instead by Dr. Abu-Gosh of Georgetown University Hospital. (See, October 22, 2008 medical report of
Dr. Abu-Gosh).
1
17
3. Contrary to the Children’s intake form, CFSA has represented that CNMC has done a complete
evaluation of sexual abuse (including an interview with the child) and medical neglect – both of which
were clearly not done because CFSA specifically did not ask that they be done. In addition, neither the
suspected herpes found by Georgetown University’s Dr. Abu Gosh nor the possible use of drugs by Dr.
Pfeiffer which could be a likely cause of the severe neutropenia whose cause had been undiagnosed for
over a year, appear to have been investigated because of CNMC’s constraints on CNMC.
4. Contrary to the medical notes, there is no permanent no contact restriction between the mother and
child, instead the father has isolated her and opposed any contact, not only with the mother, but her
grandmother and others who she has known and loved for years....not even a telephone call.
5. CFSA allowed the child to be brought into CNMC by the Father, and be present, thus eliminating any
possibility of the child feeling free to speak without retribution by the suspected abuser.
6. Ms. Magnuson, the CFSA worker who accompanied the child to the CNMC, had already concluded on
the evening of the April 21, 2009 that the reports by the experts were “unfounded” and appeared to be
trying to guide CNMC in that direction to avoid an inconsistent result. In addition, she made no note of
physical injury of the child – even though the CNMC indicated a head injury occurring earlier that day.
7. The German School is under a legal obligation to provide medical and educational information to both
parents, including Dr. King, and even as of the most recent correspondence with Dr. King, they did not
mention any incident where ALM was injured or fell off a bike on April 21, 2009 (the same day
that the expert’s reported the abuse and neglect, and the same day that the child was seen by Ms.
Magnuson who did not report any injuries on the evening of April 21, 2009, and thus claimed that reports
of abuse were unfounded).
I would appreciate it if you would keep me informed of any developments, including the follow-up
therapy and evaluations that were recommended in the CNMC medical record. In that vein, please
forward records from the planned follow-up on 4/30/2009, per the “Intake Form Ambulatory Treatment
Record.”
On behalf of Dr. King, she thanks you for your caring and concern for her daughter.
Please review completely the attached material and incorporate it into your evaluation and medical
records. The experts who originated the CFSA investigation that are mandated reports are willing to
consult with you to discuss the materials, as is Dr. King.
Sincerely,
Roy L. Morris, Esq.
cc: Linda Matthews, Esq., Risk Management, Children's National Medical Center
Tel: 202-471-4862, Fax: 202-471-4870, Email: LMatthew@CNMC.org
Documents included:
Dr. Joy Silberg, DC CFSA, 21 April 2009 Report
Dr. Robert Sklaroff, DC CFSA, 21 April 2009 Report
Eileen King, Justice For Children, 21 April 2009 Report
Letter (hand-written) from Kerstin Rae Magnuson of CFSA, LICSW CPS SW, 21 April 2009
Dr Abu Ghosh, Georgetown University Hospital, October 22, 2008
Dr. Scott Meyer, Georgetown University Hospital, January 9, 2009
2
18
ALM
ALM
ALM
ALM
ALM ALM
ALM
19
ALM ALM
ALM
20
04/21/2009 11:47 4109385072 DISORDERS PAGE 0 2 / 1 2
Childhood Recovery Resources
Dr. Roque R. Gerald

Interim Director, CPS
444 North Capitol St., NW
Suite 515
Email: ioque.gerald@dc.gov
Fax: 202-727-7279
Dear Dr. Gerald:
I am a. clinical psychologist licensed by the State of Maryland, and I am internationally

recognized as an expert on child abuse and the protection of children. My CV is attached.
d reporter, I am writing to report my suspicion that the child ALM

ALM currently residing at 4836 Reservoir Road, Apt. 3, Washington, DC 20007
is a victim of sexual abuse, and physical and medical neglect. I fear the situation is
critical and believe strong protective action should be taken.
Dr King, the child's mother, 11725 Greenlane Drive, Poto~nae,M,D 20854,

Tel: 202-730-51 11, has been engaged in efforts to protect her child from abuse for almost
a year. Unfortunately, the alleged abuser has convinced multiple jurisdictions not to take
these claims seriously and no adequate investigation has been done. She has been
prevented from contact with her child for 1 1 months.
T have extensively interviewed Dr. Ariel King, spoken with two of her evaluating
psychologists, and reviewed numerous psychological and medical records regarding the
minor child ALM Lcilani.
Tn addition, I have reviewed a y a private investigator from February and

March of 2009. In this video, ALM appears to be sick, is wearing poorly fitted
and mismatched shoes, and does not appear to be receiving attentive and appropriate
care.
In addition, recent medical records indicate that the child is suffering from neutropoenia
and has not been receiving adequate treatment as documented in an affidavit by
Dr. Robert Sklaroff. Additional medical documentation indicates a possible diagnosis of
genital herpes.
Based on my review of these documents, the recent medical records and the DVD, ray
interviews with Dr. King and her evaluators, and my extensive experience in the area of
child safety, it is my professional opinion that ALM continues to be at risk in
her current environment of both physical and medical neglect, and likely sexual abuse, hi
Joyanna Silberg 6501 N. Charles St. P.O.Box 6815 Baltimore. MD 21285-6815

21
04/21/2009 11:47 4109385072 TRAUMA DISORDERS
Childhood Recovery Resources

the past, she has disclosed "bail touches," and seeing a "po-po" that "gets harder and
harder." None of this information has been adequately investigated.
There is 110 evidence in any of the materials that T reviewed or from my extensive
interview with Dr. King or with her evaluating psychologist that Dr. King has coached or
manipulated any information from her child.
I urge you to do whatever is in your power to help protect this child. Additional
professionals are sending their own letters and documentation, as this situation has
reached a critic,allevel and there is a broad base of concern for this child's welfare from
physicians and psychologists.
We have alerted several United States Congressmen of this ongoing issue, and I will
work to provide any cooperation you might need. Please let me know if I can offer any
other assistance.
Joyanna Silberg 6501 N. Charles St. P.O. Box 6815 Baltimore, MD 21285-6815
22
TRAUMA DISORDERS PAGE B4/12
CURRICULUM VITAE
March 3"', 2009
Jovanna Lee Silber~.Ph.D.
Psychologist
6501 N. Charles Street, P.T 136
P. 0. Box 6815
Baltimore, Maryland 21285-6815
(410) 938-4974
Licensed as a psychologist by the Maryland State Board of Examiners, April 1982.
EMPLOYMENT:
Current Position:
Consulting Psychologist - The Sheppard Pratt Health System, November 1,997-
Present.
Coordinator Trauma Disorders services for children, researcher, and therapist
Private Owner: Childhood Recovery Resources: Consulting, therapy, forensic

evaluation for children and adolescents, with specialization in family court issues,
tramna and dissociation.
Senior Associate Editor, Journal of Child & Adolescent Trauma.
Past Positions:
Haworth Press, Co-Editor, Trauma Books, 2005-2007
Senior Psychologist, Sheppard Pratt Hospital, Coordinator of Trauma Disorder
Services for children. 1994 - 1997.
Clinical Coordinator of School Consultation Program, 1988 - 1997.
Consultant to McDonough School, Key School, Friends School, Bryn Mawr
Coordinator of Psychological Testing - Responsible for coordination ofhospital-

wide testing, supervision of technicians and psychologists, staff training in testing
issues. Responsible for psychological and ncuropsycliological assessment and
coordination of testing related research.
Coordinator of Child and Adolescent Programs. Program included Custody

Evaluation program, eating disorder program, underachiever program, 1982-
1989.
Slieppard Ptatt experience includes inpatient short-term adolescent treatment,

participation in, special education Level V school, staff training on treatment plan
development.
23
TRAUMA DISORDERS PAGE B5/12
EDUCATION:
Graduate:
The Ohio State University, Columbus, Ohio
Fall, 1974 - Spring, 1979
Clinical Child Psychology and Developmental Psychology
-
Ph.D., March 1979 Psychology
General Cornprehensivc Exams, May, 1977
MA., ~ e c e m b e r1976, Psychology
Undergraduate:
University of Maryland, College Park, Maryland
-
1970 1971 and 1972 1973 -
B.A., August 1973, Psychology
Hebrew University, Jerusalem, Israel

1971 - 1972
POSTDOCTORAL FELLOWSHIP:
Postdoctoral Fellowship in Child and Adolescent Psychology,

The Sheppard and Enoch Pratt Hospital, Towson, Maryland
-
July 1980 July 1982. Two year, half-time appointment.
Supervised experience in individual therapy, psychological evaluations

and behavioral consultations with severely disturbed outpati,ent and,
inpatient population, neuropsychological evaluations.
Internship in,Pediatric Psychology, University of Maryland

Baltimore, Maryland, July 1978 -July 1979.
Experience in a broad range of psychological services in a pediatric

setting, including evaluations of children, adolescents, and families;
individual, group, and family therapy; parent training, staff education
and consultation: research.
TEACHING EXPERIENCE:
Faculty, Post-Doctoral Institute on Trauma, Maryland Psychological Association

2006-2008.
Faculty, Dissociative Disorders Psychotherapy Training Program, sponsored by

the International Society for the Study of Trauma and Dissociation, Teacher of
year long course for mental health professionals, October 2006 -June 2007.
Presenter, national and international conferences on treatment and assessment of

24
TRAUMA DISORDERS PAGE 06/12
traumatized children, 1990 -present.
Faculty, National Center for Human Development
Presentations on child and adolescent development, psychopathology, attention

deficit disorder to public and professional audiences. 1983 - 1984
Supervisor, Postdoctoral fellows, 1985 -present.
Instructor, Ohio State Univcrsity, 1975 - 1978.
Substitute teacher, Roarnokc, Virginia. Experience in elementary, junior high, and

high school. October 1973 -February 1974.
UPCOMING AND RECENT PRESENTATIONS:
Treatment of Dissociative Symptoms and Disorders in Childrcn and Adolescents:

Maryland Psychological Association, September 26,2008
Childrcn as Pawns, Police Academy of Baltimore County, Training on Domestic

Violence and Custody, June, 2008, Frederick Comity SherrifFs Office, October 2008.
Diagnosis and Treatment of Traumatized and Dissociative Children, Bergen Norway,

May 8-9,2008
Healing the Child Survivor: How Trauma Hurts Children's Brains and What We Can Do,
Allegheny County Department of Human Services, May 2,2008
Trauma-Informed Care: Lessons Learned in Protecting Children In Family Court,

January 2008, Thc Battered Mothers Custody Conference
Assessing Allegations of Abuse, DV LEAP Conference, George Washington Law

School, Dcccmber 7,2007
The Treatment of Traumatized Children and Adolescents, Workshop in Assen,

Netherlands, March 21-22,2007.
Custody Evaluation in Cases Involving Violence, half day workshop sponsored

by New York Psychological Association, April 15,2007.
Healing the Child Survivor: Treatment of Dissociative and Traumatized Youth, Widener
University, Plenary, June 12,2007.
Child of hicest: Child of Trauma: All day workshop on 1:reating effects of incest on
children, for therapists sponsored by Jewish Family Services of Dallas, February 15,
2007.
Myths About Abuse, May, 2006, Judicial Training, New York Suprcnie Court Judges.
25
M DISORDERS PAGE 07/12
Assessment and Treatment of Traumatized and Dissociative Children, Maryland

Psychological Association, Workshop, March 2005.
Child Custody vs. Child Protection: A Clash of Core Values, Presentation at the
International Family Violence Conference, San Diego, September, 2004.
The Voice of the Child in Family Court: Presentation to Israeli Bar Association, March
17, 2004, Tcl Aviv, Israel.
Child Abuse and Domestic Violence for Custody Cases: Presentation to

Maryland Volunteer Lawyer's Association, GAL Training Day, February 19,
2004.
Ethical Binds and Ethical Solutions for Psychologists in Custody Disputes where
Abuse i s Alleged. Nova Southeastern University, Ft. Lauderdale, March 2004.
Treatment of Dissociative Cliildren, Invited Workshop, National Sexual Abuse

Resource Center, Oslo, Norway, October 2003.
Thc Ten Biggest Mistakes Made in Protecting Children in Family Court, Judicial
Training, sponsored by Maryland Coalition Against Sexual Abuse and
Administrative Office of the Court, March 13, 2003.
A Developmental Perspective on the Treatment of Childhood and Adolescent

Dissociative Symptoms and Disorders, at Allegheny General Hospital, November,
2002.
Complex Management of Complex Tra-umain Children and Adolescents, Silberg

and ~erentz,ISTSS, I 8"' Annual Meeting in Baltimore, November, 2002.
The Assessment and Treatment of Traumatized Children, International Family

Violence Conference, San Diego, 2006,2005,2004,2002.
Diagnosis and Treatment of Childhood Dissociation, New Zealand, 2002,

presentation to child trauma workers of New Zealand.
Diagnosis and 'beatmcnl of Childhood Dissociation, Finland, 2001, prcscntation

to child trauma workers of Finland.
Workshop on Dissociation and Child Abuse: German Society for the Study and
Prevention of Child Abuse, March 2000
Diagnosis and Treatment of Child and Adolescent Dissociative Disorders.

APSAC Colloquium, San Antonio, 1999; Chicago, 1998.
An Integrative Developmental Model of Childhood Dissociation: Symposi~lm,

American Psychological Association Convention 1999; International society for
the Study of Traumatic Stress, Miami, 1999.
26
B4/21/2BB9 11:47 41B93B5B72 TRAUMA DISORDERS PAGE m / 1 2
Cross-cultural Case Studies in Dissociation, Stockholm, 1998, International

Association for Child and Adolescent Psychiatrists and Allied Professionals,
International Congress.
Dissociative Children: Impact on Learning and Behavior, Trauma Counseling

Center, University of Wisconsin, March, 1998, one day workshop.
Diagnosis and Treatment of Child Dissociative Disorders, November, 1998,
Dutch-Flemish Society for the Study of Dissociation, two-day workshop.
Constructing Consciousness in Dissociative Children, Plenary speech,,May, 1999

ISSD UK International Conferences, Manchcster, England.
PARTICIPATION ON TASK FORCES, SUMMITS, SPECIAL PROJECTS
Representative 017 Think Tank on Abused Children and the Family Court co-
sponsored by Our Children, Our Future, and the Family Violence and Sexual,
Assault Institute, September, 2000.
Representative on day long retreat, Childrcn's Issues in Family Court, Family

Violence and Sexual Assault Institute, September 2001.
Participation in the Massachusetts Citizens for Children, Summit on Children and

the Courts: Improving Court Responses to Child Victims of Intrafamilial,
Violence and Sexual Abuse, October 2002.
Department of Justice, Office of Victims of Crime, Contributor to Child

Treatment Guidelines for Child Victims of Crime, published, January 2003,
AWARDS AND HONORS:
Four-year University Fellowship awarded by Ohio State University

--
Fall, 1974 Spring, 1978,
General Honors and High Honors awarded upon graduation from

University of Maryland, 1973.
Walter P. Klopfer Award, 1992. for outstanding research paper on

assessment awarded by the Society for Personality Assessment.
Cornelia Wilbur Award, 1992, for outstanding clinical contribution,

International Society for the Study of Dissociation.
GRANTS RECEIVED:
Sidran Foundation Research Grant, 1992 - 1994.
27
Samuel Novey Memorial Fund, Research Grant. Sheppard Pratt Hospital,

1994 - 1995.
RESEARCH PROJECTS:
The Dcvcloprnent of Pronoun Usage in Psychotic Children, Master Thesis.
The Development of Pronoun Usage among Psychotic Children and its Relation
to Three Cognitive-Linguistic Skills. Doctoral Dissertation.
Patterns of Thought Disorder on Psychological Testing: Implications for

Adolescent Psychopathology (co-author of article, Journal of Nervous and Mental
Diseases, Vol. 184, No. 8,448-456.
The Rorschach Test for Predicting Suicide in Depressed Adolescent Inpatients.

Journal of Personality Assessment, (1992).
Factors Association with Positive Therapeutic Outcomes, Research published in

The Dissociative Child: Diagnosis. Treatment and Manasement.
Dissociative symptomatology in children and adolescents as displayed on

psychological testing. Journal of Personality Assessmcnt, (1 998(.
Normal and Pathological Fantasy in Traumatized Children, paper presented at

ISSD Inteniational Conference, 1997.
Factitious Disorder by Proxy and Dissociation, paper presented at International

Society for the Study of Traumatic Stress, 1998.
Dissociative Features of Traumatized Teenagers, Ongoing, 2004 - 2007.
PUBLICATIONS:
Silberg J. L. & Dallam, S.(2009) Out of the Jewish Closet: Facing the Hidden Secrets
of Child Sax Abuse - and the Damage Done to Victims In Neustein, A. Tempest i,n the
A, Bmdeis University Press. (113,
press, publication date, March, 2009.)
Silberg, J. L. & Dallam, S. (in press). Dissociation in Children & Adolescents: At

the Crossroads, in Dell, P. F. & O'Neill, 1. (eds.), Dissociation: DSM-V and
Beyond.
Dallam, S. & Silberg, J. L. (in press). Can children consent to sex with Adults7
In Walker, L.& Gold, S. Handbook or Sexual Abuse Treatment.
Dallam, S. J. & Silberg, J. L. ( J d F c b 2006). Myths that place children at risk

during custody disputes. Sexual Assault Report, 9, (3), 33-47.
28
04/21/2009 11:47 4109385072 TRAUMA DISORDERS PAGE 1 0 / 1 2
Silberg, J. L. (2004). The treatment of dissociation in sexually abused children,

from a familyJattachment perspective. Pwchotherapy; Theory, Research,
Practice & Training, 41,487-496.
Silberg, .T. L. (2003). Drawing conclusions: Confusion between data. and theory
in the traumatic memory debate. Journal of Child Sexual Abuse, Vol. 12 (2)
2003, 123- 128.
Whitfield, C., Silberg, 1. L. & Fink, P. J. Ed. (2002) Misinformation on Child

Sexual Abuse and Adult Survivors, Binghamton, N.Y.: Haworth Press.
Silberg, J. L. (2001). Treating maladaptive dissociation in a young teenage girl.

In H. Orvaschel, J. Faust & M. Hersen (Eds.), (pp. 449-474). Handbook of
.Conceptualization and Treatment of child Psycho~atl~ology. Oxford, UK:
Elsevier Science LTD.
Dallam, S., Gleaves, D. Cepeda-Benito, A., Silberg, J. L.. Kraeiner, H.,Spiegel,,

D. (2001,). The Effects of Child Sexual Abuse: An Examination of Rind,
Tromovitcb and Ba~isennati(1,998). The Psychological Bulletin, Vol 127, 6, 715-
733.
Silberg, J. L. (2001). A presidents' perspective: The human face of the

diagnostic controversy. Journal of Trauma & Dissociation, 2 (I), 1-5.
Silberg, J. L. (2000). Fifteen years of dissociation in maltreated children: Where

do we go from here? Child Maltreatment. 5, 119-136.
Silberg, J. L. (1997). Dissociative Disorders in Childhood. In J. Noshpite (ed,.),

gandbook of Child and Adolemx~.tP s y w . Volume 11, (pp. 278-2$1), Jolm
Wilcy & Sons.
Silberg, J. L., Stipic, D., Tagl~iza.dch,F., (1997). Dissociative Disorclcrs in

Children and Adolescents. Invited Chapter for Noshpitz, J. (ed.), Handbook of
Child and Adolescent Psychiatry. Volume 111. (329-355). John Wiley & Sons.
Silberg, J. L., (1998). Dissociative symptomatology in children and adolescents

as displayed on psychological testing. Journal of Personalitv Asscssrnel~t,71,
421-439.
Silberg, J. L. (ed.), (1996). The Dissociative Child: Diagnosis, Treatment and

Management. Baltimore: The Sidran Press.
Silberg, J. L. (ed.), (1998). The Dissociative Child: Diagnosis, Treatment and

Management. 2ndedition, Lutherville, MD: The Sidran Press.
Silberg, J. L., (1,998). Afterword, In J. L. Silberg, (ed.) The Dissociative Child:

Diagnosis, Treatment and Manag-. 2ndedition, Lutherville, MD: The Sidran
Press.
29
04/21/2009 11:47 4109385072 TRAUMA DISORDERS PAGE 1 1 / 1 2
Silberg, J. (1996). Interviewing Strategies for Assessing Dissociative Disorders

in Children and Adolescents, in Silberg, L. (ed.) The Dissociative Child:
D&g~osis,Treatment and Manag-, pp. 47-62, Lutherville, MD: The Si,dran
Press.
-
Silberg J. (1996). Psychological - Testing- with Dissociative Children and
Adolesce~i~s. ii, s ~ I L (cd.)
?~ The, Dissociative Child: Ui%r~osis~;I:reat~~ie~~t
m
g
J
VD: Tlic Sidran Press.
pp. 8.5 lo?. I.iithci~~~lle,
yf.'ina~?eiiieni,
Silberg, J. (1996). The Five-Domain Crisis Model: Therapeutic Tasks and

Techniques for Dissociative Children, in Silberg, 1. (eel.), The Dissociative Child,
pp. 113- 134. Lutberville, MD: The Sidran Press.
Silberg, J. & Waters, F. (1996). Factors Associated with Positive Therapeutic

Outcome, in Silberg, J. (ecl.). The Dissociative Child, pp. 103-112. Jdutherville,
MD: The Sidran Press.
Waters, F. & Silberg, J. (1996). Therapeutic Phases in the Treatment of

Dissociative Children. In Silberg, J. (ed.), The Dissociative Child, pp. 135- 166.
Lutherville, MD: The Sidran Press.
Waters, F.& Silberg, 1. (1996). Promoting Integration in Dissociative Children,

in Sill>erg,J. (ed.), dissociative Child,,pp. 167-190, Luthei~ille,MD: The
Sidran Press.
Silbcrg, J. L. Kishton, .I. M. Thrower, S. A., Mathews, W. D. and Smith, M. P.

Instmctor7sManual for Ed~~cational
, - y sP
Boston, Allyn and Bacon, 1978.
Armstrong, J., Silberg, J., Parents, F. (1986). Patterns of Thought Disorder on

Psychological Testing: Implications for Adolescent Psychopathology, Journal of
Mental,Diseases, Vol. 174, No. 8,448-456.
Silberg, J. & Amstrong, J. (1992). The Rorschacli Test for Predicting Suicide in
Depressed Adolescent Inpatients, Journal of Personality Assessment.
Silberg, J. L. (1978). The development of pronoun usage in the psychotic child,

Journal of Autism and Childhood Schizophrenia, 8 (4), 41 3-425.
SPECIAL INTERESTS:
Community education regarding mental health
Preventative interventions
Behavioral correlates of psychological test variables
Psychological trauma and dissociative disorders
Child abuse and Family court
Traumatic stress in children
30
PROFESSIONAL ACTIVITIES:
President, International Society for the Study oFDissociation, 2000-2001

Executive Vice-President, Leadership Council on Child Abuse & Interpersonal,
Violence (1998 -present)
Member APSAC, American Professional Society on the Abuse of Children
Member, A.P.A., American Psychological Association
Mcmbcr. M.P.A., Maryland Psvcl~ological-. Association
~ounder'ofcity-wide study group on Dissociative Disorders in Children and
Adolescents
Reviewer, Journal of Nervous and Mental Disease
Reviewer, Journal of Trauma Practice
Reviewer, Journal of Trauma. and Dissociation
31
32
Affidavit of Dr. Robert Sklaroff, MD
CONCERNING HEALTH AND WELFARE OF
ALM ALM
I, Dr. Robert Sklaroff, on oath, under penalty of perjury depose and allege:
1. I am Board-Certified in Internal Medicine (1977) and Medical

Oncology (1979), and there has been no interruption in my active
license to practice medicine in Pennsylvania.
2. I am fully aware of the prevailing professional standards of care that

pertain to providing medical services (diagnostic and therapeutic)
under like and similar circumstances as those encountered in this
case. I have no financial interest in the outcome of this case.
3. My practice includes patients with the medical conditions that are the
subject of this case—assessment of severe leukopenia/neutropenia,
both diagnostic and therapeutic—and I have experience treating
similar patients during the past 28 years of private clinical practice.
None of my opinions has ever been disqualified in a legal proceeding.
I have written hundreds of reports such as this affidavit, I have been
deposed on 60+ occasions, and I have provided in-court testimony on
30+ occasions; thus, sworn testimony has been rarely required.
4. Unless evidenced otherwise, I routinely rely on clinical information

[including medical records, nursing records, lab reports, diagnostic
tests and images, consulting physician reports and other patient data]
which are the type of data routinely employed by physicians and
paraprofessional clinical staff who provide (inpatient and outpatient)
patient care. I have worked with medical office and hospital staff,
including medical technologists and nurses.
5. I graduated medical school at the Thomas Jefferson University

(1974). I completed an Internal Medicine internship/residency
program at the Henry Ford Hospital (1977); I then completed
Hematology/Medical-Oncology Fellowships at the Memorial Sloan-
Kettering Cancer Center (1979) and Hahnemann University (1980).
I have been licensed in the Commonwealth of Pennsylvania (and
have been in continuous practice) since 1979.
1
33
6. I am a Fellow of the American College of Physicians. I have had 27+
years' experience in practicing medicine in office settings, hospitals
and others (e.g., summer-camp doctor, private clinic, locum tenens
for brief time-periods). Regarding assessment of the issues in this
case, my specialty is similar to that of the practitioners who were
involved therein.
7. I am familiar with the applicable (outpatient and inpatient) medical

standards of care. The minimum medical standard of care for the
assessment, diagnosis and treatment of patients with similar signs,
symptoms, and conditions as were harbored by this patient (at-issue
in this case and serving as the basis of this report) applies to
internists and hematologists nationally (/'A, it does not differ greatly
by community); nevertheless, specifically, I'm familiar with hospitals in
Washington, D.C. and neighboring Virginia.. .and their environs.
8. I was a leader (at multiple levels) of Organized Medicine's Hospital

(later "Organized") Medical Staff Section and was President of a
Medical Staff. Thus, I have participated in development and use of
protocols, policies and procedures for the care of patients with myriad
medical conditions including those experienced by this patient, and I
am familiar with Joint Commission for the Accreditation of Healthcare
Organizations standards.
9. I have composed hundreds of reports, have been deposed on 60+

occasions, and have provided in-court testimony on 30+ occasions.
I have never been disqualified as an expert witness, and none of my
opinions has ever been disqualified in any administrative forum, court
of law, or other legal proceeding. I have never been found guilty of
fraud or perjury in any jurisdiction. I have no financial interest in the
outcome of this case.
10. I have been advised that the definition of Negligence is as follows:
Negligence, when used with respect to the conduct of 8

physician means failure to use ordinary care, that is, failing to
do that which a physician of ordinary prudence would have
done under the same or similar circumstances or doing that
which a physician of ordinary prudence would not have done
under the same or similar circumstances.
34
11. 1 have been advised the definition of Proximate Cause is as follows:
That cause which, in a natural and continuous sequence,

produces an event, and without cause such event would not
have occurred. In order to be a proximate cause, the act or
omission complained of must be such that a health care
provider, using ordinary care, would have foreseen that the
event or some similar event might reasonably result
therefrom. There may be more than one proximate cause of
an event.
12. I have reviewed additional medical records ["Exhibit A" appended]

0/22/2008 - 4/9/2009].
from Georgetown University Hospital [I
13. I again observe the following as to the assessment of infection-risk:
a. Neutropenia occurs when the circulating neutrophils in the

peripheral blood decreases to a point whereby the absolute
neutrophil count (ANC) is less than 1500 cells per mm3.
[The! ANC is calculated by multiplying the percentage of bands
and neutrophils (segmented neutrophils or granulocytes) on a
CBC differential times the total WBC count.]
b, Because many modem automated instruments generate the

ANC by calculation, reports of granulocytes may combine
neutrophils and bands. Thus, if the band number is reported
separately, it must be added to the granulocyte number.
c. The severity of neutropenia is categorized as "mild" when the

ANC is 1000-1500 cells per mm3, "moderate" when the ANC is
500-1000 cells per mm3, and "severe" when the ANC is less
than 500 cells per mm3.The risk of bacterial infection is related
to both the severity and duration of neutropenia.
d. Possible causes of Neutropenia include:

i. infection,
ii. drugs,
iii. problems with the immune system (e.g., leukemia,
HIViAIDS, etc), and
iv. autoimmune and myeloproliferative disorders.
35
e. Assessment of a bone marrow (via aspiration, biopsy and
cytogenetics) is often considered to be helpful when assessing
the aforementioned differential diagnosis; this would permit the
detection of such findings as an intrinsic marrow defect (such
as arrested maturation) and could be invoked to support such
clinical findings as congenital neutropenia, fungal infection, and
a vitamin B-12 or folate deficiency.
f. In such patients, consideration is often given to instituting
prophylactic measures such as:
i avoiding exposure to large numbers of school-children,

ii. eliminating drugs that could contribute to neutropenia,
iii. altering her diet (perhaps, to avoid fresh vegetables),
iv. protecting her from cuts, and
v. administering a stool softener,
14. I reaffirm the points made in my Affidavit prepared in October, 2008

regarding the hematologic assessment of this five-year-old child,
ALM R, ALM [B.D. 5/7/2003], and It shocks the
conscience that these problems and uncertainties persist.
15. These conclusions included the following {as rephrased and distilled}:
a. It is critical to determine the cause of neutropenia in cases

(such as this) which persist for at least several months,
b. Neutropenia developed between 2006 and May 2008,
c. Neutropenia persists (per the most recent CBC),
d. Since June 18, 2008, there has been unnecessary delay in

acquiring a full hematological work-up for this child by a trained
hematologist to determine the cause of the Neutropenia,
e. This work-up often includes examination of the bane marrow,

although to-date this procedure has not been performed.
36
f. Since at least as early as last May, the child has been at-risk to
develop (suddenly) a major infection, but consideration has not
been given to imposing any prophylactic measures, and
g. Giving the child a full panel of vaccines when her ANC was
known to be below 1500 risked both compromise of her ability
to be immunized (as intended) and development of infections.
16. The clinical data provided in follow-up depicts events that transpired
following the 10/10/2008 visit (mandated by Child Protective Services
of Washington DC), justifying ongoing concern with the child's status.
17. There have been four clinical encounters (10/22/2008, 1/9/2009,

3/27/2009 and 4/9/2009), information about which has been acquired
belatedly (and immediately conveyed to this physician, for critique).
18. These data have served to reinforce concern that this child has been
neglected, a conclusion that the child's mother wishes to convey
promptly to any physician who can be encouraged to intervene.
19. This physician was contacted as a direct result of these concerns,

recalling that the aforementioned ORDER resulted (in part) following
a direct, professional conversation between CPS and this physician.
20. The child's father (Dr. Michael Pfeiffer) returned with the child on
10/22/2008, due to detection of oral and groin lesions, to wit:
Father states child began developing shallow based ulcers

yesterday on her lower lip which have spread into her
oral mucosa. States child has been tolerating PO liquid and
solids well, playing, and only told him that something was in
her mouth in passing. Denies fever, NIV, sore throat, ear
pain. Also states she has multiple circular, pruritic, dry
lesions in her grain area without any drainage. Dad only
noticed them yesterday. States that he came today because
Dr. Myers told him to come to clinic immediately if he notices
any signs of mucositis.
37
21. The child was found to have corroborative physical findings, to wit:
b. One (2-3 x 1 cm2)erythematous ulcer on lower [lip] with yellow

crusting and swelling [sic],
c. Four-to-five shallow based erythematous ulcers on oral mucosa

and right buccal mucosa,
d. Four-Five (1 cm2)bilateral groin popular lesions, and
e. Hyperpigmented region (3 x 3 cm2)on right thigh.
22. The ANC was 1100, but additional studies (e.g., lesion cultures for
possible Herpes Simplex) were not obtained.
24. The child was given Bacitracin and mouthwashes.
25. On 1/9/2009, during a routine follow-up visit, the child was said to be
asymptomatic; persistent oral physical findings [see 21. (a-c)] were
noted, and the child's ANC was back down to 480 (with 14 blood-
parameters significantly out-of-range). The doctor's impression
was benign cyclic neutropenia (despite the absence of documentation
of any "cyclic" component thereof and despite the oral abnormalities).
26. Again, no work-up or testing of persisting oral lesions was ordered,

not even (infectious disease, dentistry, dermatology) consultation.
27. The child was provided "common sense" neutropenic precautions,

including good hand-washing and avoiding sick-contacts and large
confined crowds; yet, she was allowed to attend school.
28. This advice appears to have been oxymoronic (particularly noting the
absence of any bone marrow interpretation, previous or immediate);
it can reasonably be anticipated that a school is a site comprised,
in part, by the presence of the "sick-contacts and large confined
crowds" that it was advised the child explicitly eschew.
38
29. The plan to employ G-CSF if a neutropenia-associated infection were
to arise, also inexplicably, was not invoked in the presence of the
persisting possibly-Herpetic lesions (recognizing that they can spread
regionally and systemically in patients with compromised immunity).
30. On 3/27/2009, the ANC was 576, reflecting severe neutropenia.
31. On 4/9/2009, the child was not taken to a scheduled appointment.
32. A review-article illustrating the complexities of this overall situation

(and the assumptions that have been made regarding the diagnosis)
exists [httl~://emedicine.medsca~e.com/article/204821-overvie~.
33. This article [under "Procedures"] cites bone marrow assessment,

among a number of infection-related samples.
34. It appears that a pattern of "neglect" exists, if for no other reason than
to note the fad that the patient has now not been reassessed for a
persistent oral infection (on 10/22/2008 and 7/9/2009) because her
father did not take her for follow-up (on 4/9/2009).
35. I harbor continued concern that the child's father continues to avoid
ensuring that the child receives timely, high-quality follow-up care;
determining the cause of her neutropenia presages the capacity to
plan proper ongoing manaaement (of the hematologic and infectious
concerns) for, absent treatment, neutropenia can cause (and will
cause, if left untreated) severe and irreparable harm to the child.
36. A full evaluation at an independent tertiary institution is required

immediately to insure the life and safety of this child.
37. The child needs to be placed in the custodial care of someone

who will assure that the proper independent medical evaluation
and treatment is obtained immediately.
[The rest of this page has intentionally been left blank.]
39
All of the information and facts contained in this AFFIDAVIT are true and correct
to my best knowledge and belief.
*'
Date ' Signature
Sworn to and Signed before me

this April 15, 2009
In Montgomery County, Pennsylvania ,,.,
. ^.r?0/\3 \/^A*
Commission Notary Publid~fficiaiand Title
40
04/23/2008 14:51 FAX 2024280657 RUBIN WINSTON DIERCKS HA
BOARD OF DIRECTORS
N F@R CHILDREN
Dr. Roque R,Gerald

Jill B. Deal
Pmer Interim Director
Venable. LLP DC CFSA
444 Notth Capitol St., NW
Suite 515
James P. Gillece, Jr. Washington, DC 20001
p&er Email: roque.gerald@dc.gov
Whiteford, Taylor Fax: (202) 727-6505, Fax: (202) 727-7279 (ACSF)
&Preston. LLP
April 21,2009
couke~
Alston & Bid, LLP In the interest of ALM M.A. ALM DOB May ALM
Dear Dr.Gerald:
Katie Bornq Moose
Author Justice for Children (JFC) is a national child advocacy organization with headquarters in
Houston, Texas and ofices in Washington D.C. JFC was founded in I987 by Randy
Burton, a former Chief Prosecutor of the Family Offenses Section of the Hartis County
LaKesha P. Pope, M.A.
National Alliance to (Texas) Dishict Attorney's office, and a group of concerned citizens within the community
End Homelessness in response to the inadequacies and failure of child protective systems to protect abused and
neglected children.
Max Riederer von Paor JFC's mission is to provide legal advocacy for neglected and abused children and to
Partner develop and implement collabotative solutions to entrenched pfoblems impeding the quality
Rubin, Winston, Diercks, of life for these children, as well as to raise consciousness ab'out the failure'of governmental
Harris & Cookc, LLP agencies to protect victims of child abuse,,~hildrenare 0uy2,~@?irst and oyly priority. JFC
works together with Child Protective Services and other agenci'es for themwelfareof these
children, and, when appropriate, opposes coutt or agency actiin that threklens to compound
Eileen King the abuse already suffered by these helpless ,yictims. !, ..:',
, ...:
. ,!,,..,
Regional Director ,#
Washington W.C.Chapter
I I55 Connecticut Ave., N.W. JFC's expert opinion is recognized and valued by local a d national media, legal and'
St@.600 medical professionals, child abuse experis,'and other children's rights organizations~JFC
Washington, D.C. 20036 has appeared as amicus curiae in numerous appellate cases throughout the counhy., JFC was
202-462-4688 the lead amici',for,'the,Wilkins v Ferguson case,(l$trict of Columbia Court of Appeals)
81.5-301-5516Fax conhibuting to~~the~ucce~sful appellate decision'i$ ;29?7'that protected a young child who
&n~~iusticeforchlldren.or~ had been sexuali$itiused by her father. :
,',,,
~ # ,, i ,;,;
,
:.,. . ,: ,,
,, , 8
1. .' ,, ' t' t
.:,, ,, , ,
Shelley Rubin, LICSW Our work has been featured on ABC's Primetime Live, ABC's Primetime documentary
Staff entitled "Crimes Against Children," a PBS documentary entitled "Boy Crying, Baby
Crying," as well as Good Morning America, Donahue, the Discovery channel's %stice
Eliot Nelson, BA Files." and on HBO.
,
Staff
,,,
.,# . , , '
, , ,, ;> ,!,; , ,.,.'?'
Most recently, Eileen King, J F C - D ~ S , ; R ~ ~ ~ ~,w& ~ ~interviewed
I , ~ D I ~on~WC ~S O
A~ ~
Channel 9 regarding the case of Le%ieGi~ver
. ,;,,;,.I?,.,,, ~$o&.,bod.yyas
, : ,.,, , F :,.s. !
, h ,found,ina creek, allegedly
J a m s A. Sl~ields
Executive Director placed there by her own mother. ~ex~~'s;manp,Bespefate,bries
.,,,.,.,,,),.,,,,I . , ~ fo;%lp were ignored by
National Headqunrier8 both CPS and law enforcement in Virginia, resultirig,~hlier.mgic , . and preventable death.
, , , ,
2600 Southws~Freeway ,
, ,,,,
..
Suite
. 806
... In ALM Lei1ani7scase, we are houbled r ~ ~ a ; d i the
" ~ inadecyte follow-up care for this
Houston,Texu 77098
713-225-4357 child's neuhopenia as documented in an affidavit by RoBeti Sklaroff, M.D., who has
Fax 713-225-2818
jshields~usticcforchildr~n,org
ww.justic~f~rchildrcn,org
41
RUBIN WINSTON DIERCKS HA
thoroughly reviewed the available medical records. We understand that Dr. Sklaroff has
sent you his affidavit which states his concerns,
In October 2008, ALM presented with oral mucosal ulcers and papular lesions
bilaterally in her groin area. The medical notes from Georgetown University Hospital state
that the oral lesions were suspicious For herpes and the source of the groin papular lesions
were unhown. A culture w a s ordered for both conditions but the results of the cultures
are (oddly) unavailable from Georgetown University Hospital records department. We are
concerned as to whether the cultures were actually completed, since if they were indeed
done, there should be no problem accessing this information. The culture results are vital in
assessing whether the causes of the ulcers and lesions were benign or if they arose fiom
serious medical conditions in which symptoms may appear at various intervals and then
disappear.
ALM has also disclosed (as Joy Silberg, Ph.D. writes in her letter) "'bad touches,'
and seeing a 'PO-PO' fiat 'gets hmder and harder.' None of this information has been
adequately investigated." The child has also disclosed that her father (allegedly) sleeps in
her bed at home. In the opinion of Justice for Children, this information should he cause for
serious concern and ought tn be immediately and thoroughly investigated.
All of this information creates a picture of a child who is falling through the cracks. The fac
t that her father is a physician (neurologist) may provide false reassurance, deflecting
attention from ALM need for adequate follow-up treatment as well as a thorough
investigation of her disclosures of (alleged) inappropriate touching.
We urge that DC Child and Family Sewices Agency intewene and conduct a thorough
medical evaluation as well a5 child sexual abuse investigation for this child.
Sincerely yours,
Eileen King, Regional Director

Justice for Children
Washington, D.C. Chapter
I I55 Connecticut Ave. NW Ste, 600
Washin@on, D.C. 20036
202-462-4688 direct line
42
ROY L. MORRIS, ESQ.
! PO Box 100212
! 202 657 5793
! 509 356 2789 (Fax)
July 23, 2009
Dr Roque Gerald
Director
Child and Family Services Agency
400 Sixth Street, SW, Suite 5023
(via email: roque.gerald@dc.gov and fax)
Re: ALM
Dear Dr. Gerald,
As you know, I represent Dr. Ariel King, the mother ofALM

We recently obtained from Georgetown University Hospital a memo stating
that ALM is a “committed ward of the District of Columbia” and that CFSA, as
her legal guardian, was seeking information for its continued neglect and abuse
investigation -- on June 8, 2009. (See, Exhibit I).
Could you please provide us the following information immediately:
1) Does CFSA know the whereabouts of ALM at this time? In whose

physical custody is she? Where is she? Who is taking care of her during the day?
2) What is her current medical condition? What prompted the June 8, 2009 inquiry?
3) Has CFSA received the latest medical report that shows that she has become worse
with and ANC of 470 (500 requires hospitalization)?
4) What medical directives have been given and/or medical information obtained by
CFSA since June 8, 2009 regarding her health? Has CFSA received the updated
information from Georgetown University Hospital indicating that she requires a
bone marrow aspiration? Does CFSA know if this procedure has been done? If so,
when?
5) Please provide a printout of all information contained in the Register and the
FACES systems regarding ALM
6) As a “committed ward,” who is ALM attorney that has been assigned to

represent her interests?
43
We are particularly distressed to have learned of this new legal status (as of at least six
weeks ago) and not having been informed in any way. Please provide responses to these
inquiries for her mother by the close of business July 24, 2009.
As always, if you wish to discuss or have any questions, please feel free to contact me.
Sincerely,
Roy L. Morris, Esq.
Cc: James Toscano, General Counsel

Peter Nickels, Attorney General, District of Colombia
44

45

ALM
46
ALM
47

48
49
50
51
52
ROY L. MORRIS, ESQ.
! PO Box 100212
! 202 657 5793
! 509 356 2789 (Fax)
August 3, 2009
Dr. Roque Gerald, Director

Child and Family Services Agency
400 Sixth Street, SW, Suite 5023
(via email: roque.gerald@dc.gov and fax)
Re: ALM M. A. ALM DOB 05/ALM
Dear Dr. Gerald,
Thank you for your letter of July 28, 2009. Your letter raises more questions than it
answers, and is inconsistent with itself and with information provided by other sources in
DC Child and Family Services Agency (CFSA).
First, you point out that CFSA was requesting information from Georgetown University
Hospital with a “form letter” on June 8, 2009 that identifies ALM as a “committed
ward.” Information was previously requested by the same CFSA department on October 7,
2008 from Georgetown University Hospital without this “form letter.” Thus, it is suspect
that CFSA would use a form letter clearly identifying ALM as a “committed ward”
of the District of Columbia, but not need to do so on October 7, 2008. Why did CFSA use
this letter on June 8, 2009?
Second, if the cases were closed, then why was CFSA doing a “follow-up to an
investigation” on June 8, 2009? If the original claims were “unfounded,” then there would
be no reason to be doing either an “investigation” or a “follow-up to an investigation.”
Please be more candid with what is going on here. Is there an investigation going on now?
Why the need to follow-up? Either way, there is information in the FACES system on all of
these activities, as next explained.
Third, as to the FACES system, I was advised in an email on October 27, 2008 by Dionne
Bryant of CFSA where she “clarified” that:
The Agency simultaneously maintains a confidential database of all client records

(aka FACES) wherein all information that we collect regarding individuals referred
to the Agency via the hotline or previous and existing clients is maintained. ....The
report does and will continue to exist in FACES for internal use by the Agency.
I personally read the investigation summary report completed by CFSA Child
Protection Services unit and it was deemed unfounded. ...
53
Re: ALM M.A. ALM
August 3, 2009
This is inconsistent with the statement in your letter: “As a result of the prior investigations
having been unsubstantiated, there is no additional information available to provide to you
from the Register or FACES system as these records have been expunged.” Thus, your
letter is inaccurate on this point, and the FACES system records are not expunged. Please
provide the information from FACES, as requested (see below).
Fourth and finally, as CFSA’s top lawyer Mr. Joseph Toscano knows from both personally
appearing in the case on April 22 and 23, and the Complaint that is pending in the DC Court
-- the complaint of Dr. King before the DC Court is for “medical neglect”. I once again
forward to you the Bone Marrow Aspiration (BMA) report July 21, 2009 that Dr. King and
the mandated reporter , Dr. Robert Sklaroff, has tried to get for almost one year -- which
your agency erroneously found to be “unfounded.” The report clearly shows that this six
year old is still very ill and needs more tests to figure out the ideology and the
treatment….this delay is in itself, “medical neglect.” CFSA’s inaction has contributed to
the delays in getting her the proper treatment, and created unnecessary pain and suffering on
the part of Dr. King and her daughter.
If the case before the DC court is a “custody” case as your letter claims, then the DC Code
would appear to have been criminally violated by Mr. Toscano when he appeared before
that court in that case on April 22 and 23, and by CFSA filing “sealed” Motions on July 2,
2009 that attempted to introduce (false) evidence against the mother based solely on
information provided Dr. Michael H. Pfeiffer, the Father and Mr. Sean O’Connell, his
attorney. Please advise what disciplinary action will be taken against those in the CFSA
responsible for these violations.
Once again, using the information contained in the FACES system and the “follow-up
investigation” that CFSA is doing, please provide us the following information
immediately:
1) Does CFSA know the whereabouts of ALM at this time? In whose

physical custody is she? Where is she? Who is taking care of her during the day?
2) What is latest information CFSA has on her current medical condition? What
prompted the June 8, 2009 inquiry?
3) Now that CFSA knows from the latest medical report that she has become worse
with and ANC of 470 (500 requires hospitalization), has CFSA ordered additional
tests as a follow-up to the bone marrow aspiration on July 21 that showed peripheral
destruction of the while blood cells -- which can be caused by the administration of
drugs by the father. Has CFSA ordered tests to rule out this possibility?
4) Please provide a printout of all information contained in the FACES systems

regarding ALM M. A. ALM including each investigation, the date
it was opened, the date it was closed, and any other information contained in the
FACES system on them.
54
Re: ALM M.A. ALM
August 3, 2009
5) If ALM was not a “committed ward,” then why was it not false pretenses
for CFSA to use a “form letter” that states that she is on June 8, 2009? What
corrective actions will CFSA be taking?
Please provide responses to these inquiries for her mother by the close of business August 4,
2009.
On a final note, CFSA owes Dr. King an apology since the medical neglect of the father has
now been substantiated by the latest bone marrow aspiration test and the continuing
worsening of the child’s condition under the (possibly malicious) neglectful care of the
child’s father.
As always, if you wish to discuss or have any questions, please feel free to contact me.
Sincerely,
Roy L. Morris, Esq.
Cc: James Toscano, General Counsel

Peter Nickels, Attorney General, District of Colombia
55
ALM
ALM ALM
ALM
ALM ALM
ALM
56
ALM
ALM ALM
57
EXHIBIT ____
58
ROY L. MORRIS, ESQ.
! PO Box 100212
! 202 657 5793
! 509 356 2789 (Fax)
June 16, 2010
DC Councilman Tommy Wells

Chair of Committee on Human Services
1350 Pennsylvania Avenue, NW Suite 408
Dr. Roque Gerald, Director
CFSA
400 6th Street, SW
Re: ALM ALM
Dear Councilman Wells and Dr. Roque Gerald,
My client, Dr. King, received a call allegedly from a social worker at DC Child Protec-
tion Agency (CFSA). The social worker said that someone called into CFSA a complaint of
abuse and/or neglect with regard to ALM ALM (a German citizen with only a
German passport). ALM is d Dr. Ariel King (who is African-
American). We do not know who submitted the complaint, and do not have any confidence in
CFSA's ability to properly and thoroughly investigate such a complaint. As the CFSA should
know, if it had continued to monitor ALM very rare life-threatening condition it is
likely that she would no longer be suf nexplainable" severe chronic neutropenia,
and numerous severely abnormal blood measurements that reflect reduced liver and kidney func-
tion.
Prof. Dr. Karl Welte, the founder of the only widely used drug for severe neutropenia (the im-
munology boosting drug referred to as G-CSF) and the world's leading expert on pediatric severe
chronic neutropenia, has followed the case and reviewed the most up to date test results. He has
indicated that the severe neutropenia and other blood abnormalities that the child is suffering are
likely drug-induced (see attached opinion of Prof. Dr. Welte). If CFSA continued to investigate
the case it would also know that she is also having frequent urinary accidents at her school and
sleeps in diapers, which is highly abnormal for a seven year old that was toilet trained at three
year old. She is also having frequent visits to the school nurse at the Key Elementary School,
where she keeps changing her story to the school nurse about the origins of the bruises, bumps
and scrapes she has on her body. However, as with the history of this case and CFSA's history
of failure in 50% of the "unfounded" cases reviewed by the Federal Court monitor, CFSA has a
demonstrated inability to properly assess when there is a basis for finding abuse, but instead mis-
classifies those cases as "unfounded" -- particularly when the alleged abuser is Caucasian.
The child's father, who is a Caucasian German citizen living in Ward 3 in a one bedroom run
down student apartment, denies that the child receives drugs and tries to explain away the fre-
quent urinary accidents, incontinence, and bruises. He also has fully isolated her from all support
and social systems in the German, African-American, Jewish, and local communities that she has
59
once enjoyed. Except for school and some adult functions she has been thoroughly isolated from
anyone from everyone with whom she had or would develop, a bond and thus likely to confide
in. These actions and her state suggest that the source of the drugs is likely the father. He has
access to the types of psychotropic drugs that not only sedate and cause lapses in memory, but
also cause the very rare blood disease of severe chronic neutropenia through "peripheral destruc-
tion" in the bone marrow, as part of his neurology research at the Veterans Administration Medi-
cal Center in Washington DC. It should be noted that the father applied for, but failed to get a
medical license from the Washington DC Board of Medicine, as he could not provide proof of
his medical education with a transcript from a foreign medical school. The father has failed to
secure for ALM administration of G-CSF to boost her immune system, as well as non-
invasive drug tests to determine the true cause of the neutropenia. In addition, he has refused to
allow an independent medical and psychological exam, even though his own German Govern-
ment through the German Embassy has requested it for the benefit of ALM If CFSA
does a thorough investigation, what is said here will be found supported by documentation.
We do not know who brought this recent complaint, but I can confidently tell you that as far my
client is concerned CFSA should not, once again, do a bogus investigation where experts see
abuse and neglect, and CFSA cannot find any indication of abuse or neglect. It is imperative that
CFSA not repeat the mistakes of the past by failing to provide accurate, unbiased and complete
information to the evaluating physicians and by following CFSA LaShawn-mandated protocol of
not allowing the alleged abuser, the father, to accompany the child to or interfere in any medical
or psychological evaluations.
In addition, the CFSA General Counsel, James P. Toscano, who is directly and actively con-
flicted in this matter, should not be allowed to play any role, and, once again, interfere with the
investigation and her subsequent medical and psychological treatment. As you should know
from publicly available court papers, Mr. Toscano was arrested in Arlington, Virginia in 2004
for masturbating in a public bathroom frequented by minors while looking in a bathroom stall,
and was, in turn, charged with indecent exposure. Not until he completed a one-year supervised
probation (see attached), and went through with a sexual offender evaluation, were the charges
then dropped one year later. Despite this sexual offense background, he appears to have been
allowed to continue to work at DC Child Protection Services (CFSA) directly influencing the
lives of abused, used, and neglected children. He appears to be in no position to be involved
with or can view with neutrally those who are suspected of aberrant sexual behavior. As I raised
before your committee in testimony in May 2009 and again in March 2010, Mr. Toscano has a
history of collaborating with the father's attorney (whose law practice and family history have
been embedded in Arlington, Virginia for decades) in his successful effort to prematurely close
CFSA investigations of the father's alleged abuse and neglect, and effectively stop the medical
intervention a full independent evaluation and proper medication for ALM in 2009.
If CFSA does choose to go forward with a thorough and complete investigation, please do all
you can to assure that this time CFSA does a thorough, independent unimpeded mandated proto-
col driven investigation that is not interfered with by its conflicted General Counsel Mr. James P.
Toscano. CFSA hurts this child's opportunity to get proper medical treatment when it pretends
to investigate abuse and neglect and unjustifiably finds the complaint "unfounded", even in the
face of clear facts that warrant investigation and remedial action.
Abuse occurs in all skin-color, education, social, professional, financial, religious, gender orien-
tation and levels in Washington, DC, like all other societies.
Respectfully submitted,
Roy Morris, Esq.
60
Supporting Attachments Omitted
61
EXHIBIT ____
62
ROY L. MORRIS, ESQ.
! PO Box 100212
! 202 657 5793
! 509 356 2789 (Fax)
June 30, 2010
DC Councilman Tommy Wells

Chair of Committee on Human Services
1350 Pennsylvania Avenue, NW Suite 408
Director Dr. Roque Gerald,

Child and Family Services Agency (CFSA)
400 6th Street, SW
Re: CFSA and MPD Investigations for ALM ALM (05/ALM
Dear Councilman Wells and Dr. Gerald:

This is a brief follow-up of my letter of July 16, 2010 to Councilman Wells and Dr.
Roque Gerald. As described in my June 16, 2010 letter, it was prompted by an inquiry from
someone who claimed to be from CFSA and was working on a new investigation into the denial
of an independent medical evaluation of ALM severe chronic neutropenia (low im-
munity similar to that suffered by untreate tients) and other life-threatening blood
irregularities that have persisted for over two years. The letter specifically asked that process
errors of the past not be repeated, including not allowing Mr. James Toscano to be involved in
any investigation of the abuse, harm and neglect issues of this child given his prior misconduct.
June 24, 2010 Steinmetz Letter and the June 30, 2010 Response: The letter I sent on
June 16, 2010 concerned CFSA investigations of a minor and thus was addressed only Council-
man Tommy Wells and Director Dr. Roque Gerald. However, it apparently fell into the hands of
Mr. Toscano, who, in turn, disclosed it to his private "park arrest" attorney, Mr. Steinmetz. To
the detriment of the child, with the apparent goal of silencing my client's pointing out the inap-
propriateness of Mr. Toscano's misconduct in this case and the inappropriateness of his role in
investigations involving children, Mr. Toscano's attorney Mr. Steinmetz wrote a letter to me on
June 24, 2010, that was both threatening and factually inaccurate. The response on behalf of my
client is attached to assure that all of you have a complete and accurate picture of the facts. We
again, reiterate, that given his background, Mr. Toscano should not be involved in any investiga-
tion of abuse, harm or neglect of ALM Dr. King's child, or have access to any informa-
tion concerning her or her investig
The Irregularities Continue With Callers Claiming to Be from MPD: Despite the
June 16, 2010 letter, it appears that investigation irregularities continue. Late last week, the
child's mother received another call, but this time from a person who claimed they were a DC
Metropolitan Police Department (MPD) investigator. This caller stated that she was confused as
to what and why she had been given the case she was calling about, but insisted upon being pro-
63
June 30, 2010 Letter to Councilman Wells,
Dr. Roque Gerald and MPD Chief Cathy Lanier
Page 2
vided irrelevant information regarding the most recent contact between Dr. King and her child.
She said another investigator, Daryl Robinson at MPD, had been working on the file only three
weeks before (as he did in the other three CFSA investigations), and she could not understand
what she was supposed to do. I spoke with this caller (i.e., the one who claimed to be an MPD
investigator) and asked that the caller send me an email (which would verify her identity), so that
I could send back up-to-date documentation on Dr. King's child's severe neutropenia and other
blood illnesses and symptoms, that remain of undiagnosed cause and had gone untreated by the
child's father for over two years. The "MPD" caller to date has not sent me an email. Thus, we
have been unable to provide her with up-to-date information that would be essential to any inves-
tigation.
Additional Information On the Child's Unexplained Severe Chronic Neutropenia

and Many Blood Irregularities Is Provided Here: So that the files are complete, I am attach-
ing here the up-to-date documentation of the child's now two year long struggle with the very
rare (1 per million cases) severe neutropenia and other blood abnormalities that the child's father
has refused to have properly treated and its origins fully investigated. In addition, he has refused
to allow an independent medical and psychological examination of the child, which the German
Government (because both the father and child are German citizens) has requested.
DC Should Not Repeat the Mistakes of the Past and Get This Child Help: Because of
MPD's past and present involvement, I have included Chief Lanier in the distribution of this let-
ter in the hope that she will work with both Councilman Wells and Director Dr. Gerald to sort
this out and make sure that the irregularities and defects of the past superficial and defective in-
vestigations are not repeated. Attached to this letter is a summary of only some of the flaws of
the past evaluations done by CFSA and MPD in this case.
I would be happy to meet with the District of Columbia person in charge to brief them
and to provide further documentation. DC has a sincere interest in getting this sick child evalu-
ated and properly treated. For over two years, in spite of this known life-threatening illness, the
child has been denied an independent medical and psychological examination, and your efforts to
assure that she gets that examination and treatment are essential.
Sincerely,
Roy L. Morris, Esq

Lanier
cc: Police C
64
Page 3
Some of the Flaws of Past Investigations for ALM and Their Inconsistencies with
the LaShawn v. Fenty Mandated Protocol
Staff involved with ALM past abuse/neglect investigations:
1. Bethlehem Zewde, Social Worker, CFSA

2. Kirsten Magnuson, Social Worker, CFSA
3. Daryl Robinson, Metropolitan Police Department Special Investigations
4. James Toscano, Esq., General Council, CFSA
In addition to the obvious interference by James P. Toscano, including his collaboration

with the father's attorney in a private civil matter, the past investigations have been marred with
many flaws that must not be repeated, including:
1) Failing to follow the LaShawn v. Fenty protocol as specified in CFSA “Chapter

1000: Intake and Investigative Services” (Rev September 30, 2003) ("CFSA Poli-
cies")
a. the CFSA did not allow CNMC to perform an investigation of medical ne-
glect/medical abuse. (e.g., See, CFSA Policies at 9).
b. the investigator failed to call back the reporter(s) (See, CFSA Policies at 3)
c. the investigator did not conduct field visits to the child’s school and hospital (See
CFSA Policies at 4, and 6-7)
d. the investigator did not provide written notification of each investigation outcome
to the parent Dr. King (See, CFSA Policies at 4)
e. the investigator did not obtain statements from both parents (See, CFSA Policies
at 6-7)
f. the investigator did not obtain supporting data (See, CFSA Policies at 6-7)
g. the investigator did not contact the medical provider (See, CFSA Policies at 6-7)
h. the investigator did not obtain a forensic interview with the Child Advocacy Cen-
ter within 48 hours (See, CFSA Policies at 10)
i. the investigator did not perform at Medico-Legal for the victim within 48 hours
given that the child has a medical diagnosis for genital herpes and/or some un-
usual genital or anal findings are present (See, CFSA Policies at 11)
j. the investigator allowed the alleged abuser to take the child to the CNMC (and
other investigation sessions).
2. CFSA should not have made a determination of “unfounded” for medical neglect because
experts filed the complaints for medical neglect and abuse, and the laboratory records
supported those complaints:
a. No evidence supported a determination that those complaints of the mandated re-

porters – who are professionals, nationally and internationally recognized -- were
made maliciously. In fact, the Policies require that the CFSA document the rea-
sons for such a conclusion. (See, CFSA Policies at 53)
b. Given that the mandated reporters are experts and both of their reports were based
on facts that were current (including up to date medical records produced by
65
Page 4
Georgetown University Hospital, and video/audio observations of the Father and

the child), it would be impossible to determine that neither report had “no basis in
fact.”
3. The case was closed even though CNMC documentation shows a DMS 308.3 diagnosis
of “Severe Anxiety Disorder” / “Post Traumatic Stress Disorder” (cited as often stem-
ming from sexual and physical abuse), and noted “concern for sexual abuse,” and noted
that the investigation remained open.
4. CNMC documentation indicates that CNMC was improperly briefed by the social
worker, Kirsten Magnuson about the origins of those investigation, was provided misin-
formation, and placed unreasonable restrictions placed on CNMC's investigation (such as
“don’t interview her”), Given the restrictions placed on CNMC, the investigations could
only have been found “inconclusive,” or, more likely, with the full and correct informa-
tion, substantiated. (CFSA Policies at 25).
66
Page 5
Exhibit I: RELEVANT EXCERPTS OF CFSA POLICY MANUAL
POLICY TITLE: Investigations

POLICY NUMBER: CHAPTER 1000: Intake and Investigative Services
CHILD AND FAMILY SERVICES AGENCY
PROFESSIONAL STANDARDS
EFFECTIVE DATE: March 25, 2002

LATEST REVISION: September 30, 2003
REVIEW BY LEGAL COUNSEL: Yes
I. AUTHORITY
The Director of Child and Family Services Agency adopts this policy to be
consistent with the Agency’s mission and applicable federal and District of
Columbia laws, rules and regulations, including the federal Child Abuse
Prevention and Treatment Act and its implementing regulations, provisions in
Title 4 and 16 of the D.C. Code, and the modified final order and
implementation plan in LaShawn A. v. Williams.
Page 1
7. The investigation and assessment shall include, but not be limited to, the following:
a. contact with the reporting source to obtain additional information and determine if the
child is in imminent danger of serious harm;
b. review of closed case records, both hard copy and automated, and prior reports to ob-
tain a history for the family in terms of previous allegations and perpetrators;
c. face-to-face contact with all persons in the report and household including parents,
caregivers, and children;
d. interview with all children outside the presence of their parents or caregivers;
e. obtain statements from parents, caregivers, children, and collaterals;
f. safety and risk assessment to determine if the child is in imminent danger;
g. contact with Collaboratives for emergency assessment and supportive services;
h. investigation of the specific allegations contained in the report;
i. comprehensive neglect investigation in terms of food, clothing, shelter, education,
medical care, and supervision;
j. contact officials (DC Housing or Fire Department) for deplorable situations, structure
damage, or homes for inspection (take photographs);
k. obtain supporting documents;
l. contact with day care personnel, pre-school or school staff, including the child’s
teacher, school nurse, or social worker;
m. contact with the medical provider to obtain medical information regarding current
and historical information for the child (which may require an authorization);
n. assess the need for medical, psychological, and psychiatric evaluations for the child
and other children in the household and ensure that they are conducted prior to the
67
Page 6
completion of the investigation;

o. medical examination within 48 hours for all children for whom a report of abuse or ne-
glect has been substantiated and who have not received a comprehensive medical exami-
nation within the time period recommended by the American Academy of Pediatrics;
Note: In accordance with the Implementation Plan, full compliance with this requirement
shall be attained by December 2006.
p. contact and consultation with the Office of Clinical Services for initiation and coor-
dination of medical, psychological, and psychiatric services, to access a resource pool
available to assist workers conducting the investigation;
q. medical screening for all children within 24 hours of entering CFSA custody;
r. a full medical and dental examination within 30 days of entering agency custody;
Note: In accordance with the Implementation Plan, full compliance with this requirement
shall be attained by June 2006.
pages 6-7
15. If the Investigations Worker, upon investigation, determines that the following conditions are
present, the child shall be transported to CNMC for a medical evaluation, after consulting
with the Investigations Supervisor and health providers:
a. observable injuries, including bruises or scratches which are unexplained, at variance

with the explanation provided, or otherwise suspicious;
b. speech or behavior which suggests the possibility of internal injuries or the need for
medical care;
c. development (i.e., weight, height) which is inconsistent with the expected range for the
child’s age;
d. a report of the ingestion of any harmful substance;
e. a report or indication of sexual molestation or assault; and
f. other conditions which suggest the need for a medical evaluation.
Note: CFSA shall provide appropriate medical, psychological, evaluations of children as

part of the investigation of abuse or cases where it is determined that such evaluations
are necessary. Children, for whom such evaluations are necessary during the period,
shall receive the required evaluations during the investigation and prior to the time the
investigation is completed.
Procedure D: Sexual Abuse Investigations
1. Sexual abuse reports shall be conducted in collaboration with YPSD. The collaborative inves-
tigation shall include, but not be limited to, the following:
a. determining if the child requires medical attention;

b. ascertaining the identity of the alleged perpetrator;
c. detaining the suspect if he/she is on the scene (YPSD);
d. preserving the evidence;
e. interviewing the child (on-scene interview should be kept to a minimum) and other
68
Page 7
witnesses; and
f. processing the arrest of the perpetrator (YPSD).
Note: Every instance of sexual abuse shall be investigated by a multidisciplinary team. D.C.
Code § 4-1301.51
2. The procedures for conducting a sexual abuse investigation shall be as follows:
a. Investigations Supervisor shall contact YPSD upon receipt of the report to facilitate a
collaborative investigation;
b. Investigations Worker shall conduct a joint investigation with the YPSD investigator,
within 24 hours;
c. Investigations Worker shall not proceed with the investigation without YPSD until all
efforts have been made to collaborate;
d. a forensic interview shall be requested at the Children’s Advocacy Center (CAC)
as soon as possible, but no later than 48 hours where:
i. the child is 12 years of age or under;

ii. there is an intra-familial relationship between the child and the alleged
perpetrator regardless of the child’s age;
iii. the child has emotional, developmental, learning or other disabilities;
iv. the child is non-communicative on the scene;
v. the child discloses sexual abuse during an investigation;
vi. the child has not previously had a forensic interview;
! not including interviews for other matters; or

! situations where the story has changed
vii. another individual has observed the abuse; or

viii. there are physical findings of abuse.
e. Investigations Worker and YPSD investigator shall conduct a case conference, if the
child does not disclose, to determine a plan of action;
f. a Medico-Legal for the victim shall be obtained within 72 hours of the alleged
assault or within 48 hours if it is unknown how much time has elapsed or the report was
made more than 72 hours after the alleged assault for the purpose of a forensic examina-
tion when:
i. child has disclosed sexual abuse or been observed in sexual activities which
are abusive or the child has a medical diagnosis of the following: reportable
STDs (i.e., gonorrhea, syphilis, chlamydia), HIV positive with no alternative
source of transmission, other sexually transmitted diseases (i.e., tricho-
monas, genital herpes, or venereal warts) with no alternative source of
transmission; or
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Page 8
ii. child’s primary care provider indicated unusual genital or anal findings.
g. a Medico-Legal for the siblings/household members/other children to whom the known

perpetrator has had access shall be obtained for the purpose of a forensic examination
when:
i. the identified victim reports seeing abuse of the sibling;

ii. the identified victim or sibling has not disclosed abuse, but there remains
strong suspicion of abuse;
iii. the identified victim’s examination indicates that sexual abuse has most likely
occurred; or
iv. the identified victim has a diagnosis of reportable STDs.
Note: Genital symptoms such as discharge, itching, bleeding, or inflammation

not related to sexual assault should be evaluated by the primary care
provider. Sexualized behaviors without disclosure of sexual abuse should be
evaluated by a mental health professional.
h. the Investigations Worker shall complete referral to Crime Victims

Compensation Program when appropriate.
(pages 10-11)
7. The Investigations Worker shall complete the following for a Medico-Legal

(physical abuse and sexual abuse cases):
a. transport child to CNMC;

b. identify child as DC Kids;
c. enter demographics into database;
d. indicate Medico-Legal; and
e. contact CNMC CPS Unit.
Note: Medico-Legals are required for all children in the home (page 22)
Procedure W: Disposition
1. At the conclusion of an investigation (no later than 30 days from receipt of the report), the
Investigations Worker shall determine whether or not the maltreatment has occurred for each
allegation and victim. The following assessment findings are indicated for each allegation:
a. substantiated - a report which is substantiated by credible evidence and is not against

the weight of the evidence (e.g. educational neglect – a child’s school record reveals that
the child has never attended school)
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b. unfounded - a report which is made maliciously or in bad faith or which has no

basis in fact (e.g. the family has no children)
c. inconclusive - a report which cannot be proven to be either substantiated or unfounded

(e.g. the alleged maltreator is reported to be a substance abuser but Investigations Worker
is unable to locate the maltreator)
Note: Credible Evidence means any evidence that indicates that a child is an abused or
neglected child, including the statement of any person worthy of belief. D.C. Code § 4-
1301.02 (page 25)
MEDICAL NEGLECT
4. For medical neglect, the presumption exists that a parent or caregiver is fully responsible for
ensuring that the child receives routine and emergency medical and dental care. The following
criteria shall be used to substantiate medical neglect:
a. the child has not been receiving medical or dental examinations in accordance
with the standards set forth by the American Academy of Pediatrics;
b. the parent or caregiver has failed or refused to take the child for appointments to
evaluate a serious medical condition;
c. the parent or caregiver has consistently failed to comply with appointments for
routine medical care or appointments with specialists for a medical condition;
d. the parent or caregiver has failed or refused to take the child for treatment for a serious
and/or life-threatening condition;
e. the parent or caregiver has withheld medically indicated treatment from a dis-
abled infant with a life-threatening condition; or
f. the child has been diagnosed as failure to thrive by a medical professional and it is not
the result of a medical condition.
Note: A lack of immunizations may, but does not necessarily always, constitute medical neglect,
but educational neglect may be substantiated if the child is unable to attend school due to the
lack of immunizations. Also, no child treated solely by spiritual means through prayer in accor-
dance with the beliefs of a recognized church or religion by a duly accredited practitioner
therefore shall be considered a neglected child for that reason alone. See D.C. Code § 16-
2301(9)(B). Page 26
71
72
ROY L. MORRIS, ESQ.
! PO Box 100212
! 202 657 5793
! 509 356 2789 (Fax)
August 13, 2010
Police Chief Cathy Lanier

Assistant Chief Peter Newsham
Metropolitan Police Headquarters
300 Indiana Avenue, NW
Re: Child and Family Services Agency (CFSA) and Metropolitan Police Department
(MPD) Investigations for ALM ALM (05/ALM August 4, 2010 Letter of
Assistant Chief Peter New
Dear Chief Lanier and Assistant Chief Newsham:
If a child who has been directly infected with HIV/AIDS (which creates low immunity
that poses the risk of fatal infection) did not receive AZT medicine to prevent potentially fatal
infection at the hands of the child's parent, it would arouse immediate suspicion and action by
authorities to correct the life-threatening situation and an investigation of the criminal harm and
negligence. Then, why does a child now living in Washington DC who has been suffering from
a very rare blood disease referred to as "severe chronic neutropenia" or SCN (critically low im-
munity that can be induced with toxins/ drugs) for over twenty-six months, and not receiving
medicine to prevent potentially fatal infection at the hands of her parent, not arouse the same
suspicion, and thorough investigation? Possibly it is the rarity of SCN (only 1300 people in the
world are listed on the international registry) or the fact that the father is working as a “physi-
cian” (with easy access to drugs that can induce SCN) that has caused DC authorities, including
Child and Family Services Agency (CFSA), to be complacent and not take any action. Shall
this child unnecessarily be left at risk of fatal infection and death because of the ignorance of her
rare chronic low immunity condition or the prejudices with regard to her parent?
Assistant Chief's Newsham's recent undated letter (attached as Exhibit VII), while well in-
tentioned, is symptomatic of the systematic failures and the "group think" that has permeated the
District of Columbia's attitude towards seven year old ALM ALM (ALM), a
dual German-American citizen who lives with her Germ 83 Road, Apt.
3, Washington DC. It is undisputed that ALM suffers from SCN and numerous abnormal blood
measures, now for over 26 months. [See, Attachments of graph and charts of ALM's blood tests,
Exhibits Ia/b and IIa/b] Also, there has been very little effort to do all the required testing to
determine the true cause of her illness, including as Prof Dr. Welte (an SCN expert) suspected
“induced by toxins”/drugs (which would include the psychotropic drug available to the father
who works in neurology). Unexplainably, she has been denied the standard protocol treatment of
GCSF medicine to boost her immunity -- to help protect her from the potential grave conse-
quences of "toxic shock, loss of limbs, or loss of life.”
Her condition is so rare that she is listed on the Severe Chronic International Registry
(SCNIR), which lists only 1300 other people in the world as having the condition in the way
73
August 13, 2010 Letter to
MPD Chief Cathy Lanier and Assistant Chief Newsham
Page 2
ALM does. Her condition is so critical that two leading international SCN experts, Professor
Dr. Dale of the University of Washington Medical School, and Professor Dr. Welte (in Ger-
many), both Co-Directors of the Severe Chronic Neutropenia International Registry have
voluntarily written letters expressing alarm at the medical neglect, and potential harm of her life-
threatening medical condition.
ALM’s condition is so critical that the German Embassy has formally requested the
child's German father to voluntarily agree to an independent full medical and psychological ex-
amination. To date, the father has refused to allow the child to be given the needed medicine or
to be examined by any physician other than his former associate at Georgetown University Hos-
pital. Instead of welcoming the invitation from his own Embassy to help his daughter get the
medicine, treatment and evaluation that would save her life, he has refused to cooperate. No
doubt the father is confident that the "group thinkers" in the District of Columbia will do noth-
ing, despite the substantial objective evidence of ALMs severe health condition, its harm and its
neglect. One medical expert called ALM's untreated Severe Chronic Neutropenia a “ticking time
bomb."
When the evidence is viewed objectively, almost every major indication of neglect and
abuse is present.1 But, Assistant Chief Newsham's Letter does not reflect the raw evidence. In-
stead the letter cites CFSA's representations of its defective investigations, which were, by de-
sign, intended to find nothing wrong. After the first flawed investigation, CFSA chose to look no
further. It is our understanding from one investigator that the paperwork for each subsequent
investigation is identical to the prior paperwork -- as if it had been simply copied. It is easily
shown that the “investigations” were flawed by design and not compliant with the LaShawn v
Fenty mandated protocol. Some of the flaws of past investigations and their inconsistencies
with the LaShawn v. Fenty mandated protocol are listed in the attachments to my June 30, 2010
Letter to Councilmember Wells and CFSA Director Roque Gerald (See, Exhibit XVI). The fac-
tual background is as follows:
ALM's Father Has a History With the DC MPD and US Secret Service: The District
of Columbia MPD first came in contact with the father, Dr. Michael Herbert Pfeiffer, on July 6,
2007 when he was caught stalking Dr. King and their daughter at the Zambian Embassy on Mas-
sachusetts Avenue. Dr. King’s Foundation, The Ariel Foundation International
(www.ArielFoundation.org) was holding a diplomatic reception for ten Zambian young adults
who were invited to came to the US because they had won the Zambia YouthIT Competition,
sponsored by the Rotary Club International and the State Department. Uninvited, Dr. Pfeiffer
violently disrupted the reception at the Zambian Embassy and attempted to snatch ALM and
threatened Dr. King and the child in front of numerous witnesses. Dr Pfeiffer refused to leave
the Embassy. The US Secret Service, and the DC MPD were called to the Zambian Embassy to
have Dr. Pfeiffer involuntarily removed from the Embassy. See Exhibit III. After the US Secret
Service questioned Dr. Pfeiffer, the Secret Service agent then advised Dr. King “you have a
problem. You need to get a TPO.” Due to concerns for Dr. King's and her child's safety, a DC
Police Officer provided Dr. King a motor escort out of the District for her and her child. The
report attached here is from a FOIA request to the US Secret Service. No arrest was made of Dr.
Pfeiffer, even given these times of terrorism and homeland security concerns. The DC MPD
stated, in response to a FOIA request, that it retained no records of the incident.2
1
Signs of Abuse and Neglect: • Shows sudden changes in behavior or school performance • Has not received help
for physical or medical problems brought to the parents’ attention • Has learning problems (or difficulty concentrat-
ing) that cannot be attributed to specific physical or psychological causes • Is always watchful, as though preparing
for something bad to happen. Source: Recognizing Child Abuse and Neglect: Signs and Symptoms; Child Welfare
Information Gateway, US Department of Health and Human Services, 2007, from the CFSA Website.
2
A TPO was issued by the DC Superior Court. It was not extended to a FPO because the court determined that
since the incident was on international soil, the court had no jurisdiction.
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Page 3
Father's Legal Maneuvers Abort Investigation by Montgomery County: Soon after

ALM was placed in her father's primary custody in Spring 2008, a routine annual birthday medi-
cal exam (May 2008) revealed that ALM began to suffer from the very rare SCN. On June 2,
2008, a Montgomery County Circuit Judge Boynton heard from both the mother and the child in
a one hour hearing issued a Temporary Protection Order for the child against the father for sus-
pected sexual and physical abuse and medical neglect (and for the mother for stalking). The
child had previously disclosed in forensic interviews done by the Montgomery County "Tree-
house" that the father was sleeping in her bed, that the popo "gets harder and harder," that the
child equates "popo" with the father's penis, and the Father kisses her on the “mouth” [See, Ex-
hibit IVa]. The father had continued his practice of sleeping in the child's queen sized bed, in his
one bedroom apartment, despite being warned in Fall 2008 by a court social worker that such
behavior is inappropriate and should stop.
The Maryland Circuit Court TPO provided for a child abuse and neglect investigation to
be conducted and the results presented in the evidentiary hearing scheduled for June 9, 2008.
(See, Exhibit IVb) However, before the father could be interviewed and the investigation prop-
erly started, the father's attorney, Sean W. O'Connell, Esq. had the TPO vacated on June 5, 2008
in an ex parte hearing without the presence of the mother, the child or any attorney for the child
or the mother.
Father's Legal Maneuvers and Misrepresentations Abort Investigation by New

York's Montefiore Children’s Hospital (June 2008): When the mother again attempted to get
an independent medical and psychological examination for her child at Montefiore Children's
Hospital in New York, the father once again had that examination aborted by falsely claiming
that Montgomery County had fully investigated the charges -- which was not true. The father
had the mother arrested at the child's bedside for "non-parental kidnapping." Because of the fa-
thers’ actions, the last time the child saw and talked to her mother was when the child fell asleep
at her Montefiore Children’s Hospital bedside in June 2008. Without completing its own inves-
tigation of the SCN and sexual abuse, Montefiore Children’s Hospital released ALM to the
father with specific directives that she be seen and receives treatment by a pediatric hematolo-
gist/oncologist and a psychologist.
The hospital notes indicate that, without the mother present, the child spontaneously told
hospital medical personnel that:
"Daddy gives me bad touches and hits me." When asked where Daddy gives her bad
touches she pointed to her right thigh and then her left anterior thigh. When pressed to
say more she turned around and stopped answering questions.
- June 13, 2008 Observations of Montefiore Hospital (Exhibit V)
Incomplete and Flawed August 2008 Sexual Abuse Investigation in DC: In August
2008, Dr. Lee Schneyer, a psychologist who specializes in children who have suffered from
abuse, had reviewed many records, interviews, videos, and recordings of ALM. In a letter pro-
vided to CFSA, he raised concerns that ALM, who had been exhibiting dissociative behavior,
was likely “molested” for “a long period of time” and needed a full and specialized sexual abuse
assessment by a highly trained and specialized psychologist. Without following the required pro-
tocol of contacting Dr. Schneyer to discuss his findings or what actions he would suggest are
taken, CFSA closed the case within days and determined it to be "unfounded," because the child
did not, allegedly, disclose anything in her only CAC interview. As anyone familiar with abuse
is aware, children rarely disclose to strangers abuse particularly if they know they are likely to
return to the custody of the abuser.
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Page 4
The DC MPD August 14, 2008 Sex Supplement Report Summary (Exhibit VI):
Through an FOIA request, a copy of the DC MPD "Sex Supplement Report Summary"
was obtained and is found attached as Exhibit VI, hereto. A careful reading of the report
evidences three obvious flaws of the investigation of August 2008:
1) the mother was not interviewed,

2) the investigators ignored the information they were provided by the mother's
undersigned counsel. Detective Robinson and another officer of DC MPD at the
MPD Youth Investigations Branch precinct on Indiana Avenue, NE interviewed
him. Detective Robinson told the undersigned counsel that said interview was re-
corded. However, that interview and the clarifying information provided to De-
tective Robinson is nowhere to be found in the August 14, 2008 investigation
report. Instead, only the information provided by the father's counsel was
included and considered by the MPD investigator.
3) no mention is made in the report about the SCN condition of the child, and its
possible relationship to sexual abuse by the father.
4) no discussions were had with Dr. Lee Schneyer.
Father Controlled October 2008 “Medical Neglect” Investigation of Severe Chronic
Neutropenia That Had Been Initiated by Physician Mandated Reporter: In October 2008,
Dr. King obtained ALM's medical records from the Georgetown University Hospital. The re-
cords revealed that the father failed to take the child to a hematologist/oncologist to have the
SCN properly evaluated, as Montefiore Hospital had directed. A proper evaluation would have
included a bone marrow aspiration and tests to determine the underlying cause of the SCN. Dr.
King gave all of ALM's medical records to Dr. Robert Sklaroff, a hematologist/oncologist with
30 years experience, for review. He could not understand why the child was not getting the
proper medical attention given the seriousness of her condition, nor could he understand why the
child was allowed to go to school without proper precautions. See, Affidavit of Dr. Robert
Sklaroff, October 2008, Exhibit VII. Dr. Sklaroff had called in a verbal report to the CFSA hot-
line on October 7, 2008 reflecting his concerns of the neglect of ALM's serious medical condi-
tion by the father, including the failure to take the child to a hematologist/oncologist for a full
workup to determine the SCN's cause.
Under the LaShawn v Fenty court mandated protocol (see, more information at end of
this letter), CFSA was required to take the child to Children's National Medical Center (CNMC)
for an evaluation of the medical neglect issue of the Severe Chronic Neutropenia -- within 24
hours. Instead, CFSA allowed the alleged abuser/neglect father to wait 4 days and then sched-
ule an appointment, then on his own, to take the child only to his associates at Georgetown Uni-
versity Hospital (GUH) without an accompanying social worker. The medical records (along
with subsequent sworn testimony) show that the alleged neglect/abuser father was allowed to
privately brief and dictate to his Georgetown colleague, Dr. Scott N. Myers, who was a relatively
inexperienced hematologist/oncologist (who graduated medical school less than 10 years before)
at GUH's Lombardi Cancer Center. See, Exhibit VIIIa and VIIIb. The medical records indicate
that the father gave Dr. Myers a false and distorted self-serving version of ALM's medical his-
tory, did not tell Dr. Myers that this was a CFSA investigation of medical neglect by the father,
and Dr. Myers did not attempt to contact Dr. Sklaroff or Dr. King who had been the child's pri-
mary caregiver and knew all of the medical information and history. Both CFSA and DC MPD
had no direct involvement in the medical examination of the child for the SCN neglect. The
entire October 2008 examination was left in the direct control of the father -- the target of the
investigation for medical neglect!
In addition, at the request of the father Dr. Myers emailed "a letter" to Bethlehem Zewde,
76
Page 5
a social worker at CFSA, who was not the CFSA social worker handling the case. Dr. Myers
familiarly referred to Bethlehem Zewde as "BZ" (See, attached email of Myers to BZ and
Pfeiffer, Exhibit IX).
It is important to note that the October 2008 CFSA non-investigation caused the father to
be forced to take the child to a hematologist/oncologist, which the father had neglected to do
even though directed by Montefiore Children’s Hospital to do so four month before. Despite
this obvious evidence of medical neglect by the father's failure to get proper care and evaluation
of the child's SCN leading up to the October 2008 non-investigation, the CFSA unexplainably
concluded that Dr. Sklarloff's complaint of medical neglect was "unfounded." Since then CFSA
has distorted the facts surrounding the October 2008 investigation by claiming that: 1) the
complaint was brought by the Mother, even though it was clearly brought by Dr. Sklaroff and
2) it was "unfounded" even though the father had neglected to take the child to a hematolo-
gist/oncologist before the CFSA report had been filed by Dr. Sklaroff. By the very definition of
"unfounded," the medical neglect report of Dr. Robert Sklaroff could not have been unfounded.3
Reports By Two Mandated Reporters in April 2009 Leads to Sham CFSA Medical
Neglect Investigation: After several months went by, Dr. King again obtained a copy of ALM's
medical records and presented them once again to Dr. Sklaroff and also Dr. Joy Silberg. Dr.
Sklaroff found that the SCN had persisted and that the most rudimentary and basic test that is
conducted in the first month, a “bone marrow aspiration" had still not been done to determine the
cause of the SCN after one year of ALM suffering from the disease. In April 2009, Dr. Sklaroff
again filed a formal medical neglect report with the CFSA hotline both orally and in writing.
(See, Exhibit X) The CFSA social worker once again did not speak to the Dr. Sklaroff..
In addition, Dr. Joy Silberg, a child abuse psychologist expert from Sheppard Pratt Hos-
pital (Baltimore, MD), after reviewing documents and videos, also filed a report of suspected
sexual abuse and neglect. (See, Exhibit XI) The NGO, Justice for Children, through Eileen King
also sent a letter of concern that ALM was falling through the cracks in the system to the Direc-
tor Roque Gerald. (See, Exhibit XII) None of these reporters were contacted or spoken to about
their concerns and the evidence for their concerns.
Although CFSA did take the child to CNMC in April 2009, .it did so with the full in-
volvement, control, and accompaniment of the father, who was the suspect of abuse, harm and
neglect. Again, this was a clear violation of the LaShawn v Fenty mandatory protocol. Not only
did the father remain with the child throughout the investigative visit to CNMC (where he was
once associated as a physician), but also he was again allowed to direct CNMC's activities. As a
result, some significant irregularities occurred -- as clearly demonstrated by the written CNMC
reports (Exhibit XIIIB, also see, Unanswered Letter to CNMC Criticizing Their Investigation
(Exhibit XIIIa)):
1) CNMC relied solely on the false information about the complaint and the child as pro-
vided by the alleged abuser/neglect suspect, the father. CNMC was falsely told by the fa-
ther that the abuse report was brought by the mother. Both the father and the CFSA
worker failed to tell CNMC that the abuse reports were submitted by mandated reporters,
Dr. Sklaroff, Dr. Silberg, and Eileen King. CNMC was also not told that the child's “sus-
pected herpes” on the lip and in the mouth and groin was reported by a GUH physician
on October 22, 2008 -- not the mother, as falsely told to CNMC by the father. Also, the
CNMC staff was not given the actual written reports provided by the mandated reporters.
3
Procedure W of the CFSA LaShawn v Fenty Protocol defines "unfounded" as "a report which is made maliciously
or in bad faith or which has no basis in fact (e.g. the family has no children)." (see text at end of this letter). That
clearly was not the case here.
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Page 6
2) CNMC staff investigators were specifically told to limit their inquiry to physical
evidence of sexual abuse. They were not asked to look at the Severe Chronic Neutropenia
disease/medical neglect issue. Instead, they were told, the father's associate, Dr. Scott
Myers of Georgetown, was attending to it. They were not told that Dr. Myers was not
charged with investigating medical neglect involving the SCN, nor were they told that
Dr. Myers, through the father’s direction, has limited his medical inquiry to simply taking
blood samples every three months, which had come under severe criticism by the more
experienced Dr. Robert Sklaroff. CNMC was not given copies of the blood test results
showing both the SCN and the many other out-of-range blood measurements.
3) The CNMC was told that they should not interview the child because, they were told,
she had been interviewed before and it could cause her “harm”. However, they were not
told that the previous limited interview in August 2008 was eight months prior, which
would have been irrelevant to any inquiry in April 2009, nor were they given a copy of
that interview.
4) Despite the improper directives to CNMC by the father to limit its inquiry, the CNMC
evaluator wrote in her report “concerns for sexual abuse” and diagnosed the child with
308.1, “Post traumatic Stress Disorder” and recommended psychological intervention. To
date over a year later, the father has neglected to act on those medical directives by
CNMC. See, Exhibit XIIIB.
5) CNMC did not contact or talk to the mother regarding any background, but solely re-
lied on hearsay from the suspected abuser -- i.e., the father.
CFSA's General Counsel, James Toscano, Comes to the Father's Aid in an

Unauthorized Appearance In a Private Civil Suit for Medical Neglect: In April 2009, Dr.
King brought her own complaint in DC Superior Court for medical neglect, in the hopes that the
court would order an independent medical examination (including bone marrow aspiration) as
required by the law of the District of Columbia (King v Pfeiffer, 09 DRB 1167). However, as
noted in my letter to Councilmember Tommy Wells and CFSA Director Roque Gerald dated
June 16, 2010 (Exhibit XV) and in my testimonies before the DC Council Committee that over-
sees CFSA in May 2009 and March 2010, Mr. James P. Toscano, the General Counsel for CFSA
with a lurid past, made a personal appearance in this civil litigation at the request of the father's
lawyer. Mr. Toscano inappropriately interfered with the effort to get an independent medical
examination for the child by falsely telling the Court that CFSA, through the CMNC, was inves-
tigating the life-threatening SCN/medical neglect issue (which it clearly had not been) and, ap-
parently, already knowing the outcome was decided before the CNMC visit, told the Court that
the CFSA case would be “closed by Monday”, within one business day. Not surprisingly, given
the predetermined outcome, he ultimately told the Court that CFSA found the medical neglect
reports of the mandated reporter unfounded -- even though none of those reports were substan-
tively investigated by CFSA. Mr. James Toscano's behavior in the courtroom was bizarre, to say
the least, as he had spent two days and many hours in the courtroom doing nothing. When he did
move about the courtroom, he acted beholden to the father's attorney, as if the father's attorney
had forced him to be there. The Court, relying upon Mr. Toscano's false and erroneous informa-
tion, came to its own erroneous decision, which is currently on appeal before the Court of Ap-
peals for the District of Columbia. More importantly, the malicious acts he took in the court
have resulted in ALM not receiving both needed standard protocol GCSF medicine and a full
independent medical examination to date. (See attached, March 11, 2010 Testimony: Call for
CFSA Investigation of Corruption and Cover-up, Exhibit XIVA, and Exhibit XIVB From Con-
cerned CFSA Social Workers)
June 2010 CFSA Calls the Mother Claiming Someone Filed A New Abuse Report:
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On June 15, 2010, "Sarah Du Kinder Cook" called Dr. King claiming to be from CFSA. Ms.
Cook said she was calling to gather information in a complaint investigation against the father
that was called in by someone (who she did not identify) who claimed that her complaint was
"based on something the mother said." Dr. King's suspicion was aroused because "Ms. Cook"
showed no interest in knowing anything about ALM's medical condition of SCN. Ms. Cook only
wanted to know when Dr. King last had contact with her daughter. Given the past irregularities
of CFSA, Dr. King did not respond to the inquiry. Instead, I wrote, on behalf of Dr. King, to
Councilmember Wells and CFSA's Director Dr. Gerald expressing concern about the authentic-
ity of the inquiry, and to request that, if any investigation were to be done, Mr. Toscano be ex-
cluded from any involvement given his prior irregular, lurid, dishonest, and harmful conduct that
had interfered with ALM receiving medicine and an independent medical investigation. (See,
June 16, 2010 Letter Exhibit XV)
DC MPD's "Inspector Garner" Calling About a New Investigation: About one week
later, on June 22, 2010, "Inspector Garner" called Dr. King. She claimed to be from the DC
MPD and that she too was calling to gather information because someone called in a complaint
against the father "based on something the mother said." Again, Dr. King's suspicion was
aroused because "Inspector Garner" showed no interest in knowing anything about ALM's seri-
ous SCN medical condition. Detective Garner only wanted to know if Dr. King had recently
been in contact with her daughter. Dr. King contacted me on June 22, 2010, and then I called
back Inspector Garner at 202-576-7700. (See, Exhibit XVII showing Call Detail of 42 Minute
Call with Inspector Garner) Inspector Garner told me the same story that she had said to Dr.
King. In addition, she also stated that Detective Robinson of MPD had been investigating and
working on the file less than three week earlier. I offered to both direct her to documentation
and to give her documents regarding ALM's illness -- including documents that showed that
ALM made an abnormally high number of visits to the school's nurses office with suspicious
“bruises, bumps and cuts,” hygiene, and that she was having frequent urinary accidents during
the day (See, Exhibits XIX). I gave Ms. Garner my email address, but to date I have not received
an email from her. Again, on behalf of Dr. King, I wrote a follow-up letter on June 30, 2010 to
Councilmember Wells, CFSA Director Dr. Gerald, and copied Chief Lanier expressing concern
about the authenticity of the call. (See, June 30, 2010 Letter, Exhibit XVI)
August 4, 2010 Letter of Assistant Chief Newsham: In response to the June 30, 2010
Letter, Assistant Chief Newsham's wrote a letter to me stating that the MPD had no record of
any investigation in June 2010, nor any call to Dr. King. See, Exhibit VIII. However, as men-
tioned above, on June 22, 2010, Dr. King did receive a call from MPD Investigator Garner, and I
called back Inspector Garner at 202-576-7700. The undocumented inquiries of both CFSA's Ms.
Cook and Inspector Garner, including their pre-occupation with when Dr. King last had contact
with her child, while ignoring her current life-threatening condition, along the irregularities sur-
rounding the neglect and abuse investigations of CFSA and MPD, should raise serious concerns
and demand an independent investigation into the conduct of the CFSA and the MPD's Youth
Investigation Division with regard to this matter since July 2007.
***
Let me quickly summarize the facts of this situation:
a) ALM has suffered from untreated life-threatening SCN for twenty-six months. GUH
has stated that they must get the father’s permission to give medicine (it must be injected
each day) and to do a toxicology and any other necessary tests. Thus, she is not receiving
the protocol medicine needed to boost her immunity to avoid unnecessary risk of fatal in-
fection. Based on the SCN's severity, and all the laboratory and bone marrow results
done so far, the world experts of SCN believe that her illness is likely “induced by tox-
ins” (which would include drugs) which are most likely being given by the father given
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his denial of any drugs being given. This would explain the reason ALM's father has
shown no interest in getting the SCN properly treated with medicine or allowing an inde-
pendent examination (with toxicology test) to determine its real cause.
b) every major indication of abuse and neglect is present here,
c) because of the father's involvement and influence, among other reasons, CFSA and the
DC MPD have yet to conduct any independent “investigations” in conformance with the
LaShawn protocol, and both CFSA and DC MPD have ignored the objective information
that was presented to them,
d) Dr. King received a call from of CFSA on June 15, 2010 from a person who claimed
that a new investigation of the father had begun, but the caller was only was interested in
knowing from the mother when the child last had "contact" with the mother, and
e) Dr. King received a call from DC MPD on June 22, 2010 from a person who claimed
that a new investigation of the father had begun, and, yet, that caller also was only inter-
ested in knowing when the child last had contact with the mother. I returned that call
with a 42 minute conversation with MPD Inspector Garner, as evidenced by call records.
Inspector Garner did not followup with an email as she had promise, so that she could be
provided information.
f) Assistant Chief Newsham's letter states that MPD has no record of these June 2010
investigations or inquires, even though both Dr. King and the undersigned counsel both
had extended telephone conversations with the alleged MPD investigator.
Stepping back and closely examining the documented facts, the conduct of the CFSA and
the DC MPD in this case defies logic. Instead, myths appear to be perpetuated by certain key
officials (including, James Toscano who, by his actions, appears to have a personal interest in
this child's case), thus causing this child to remain critically ill with her life precariously hanging
in the balance. Other than the German Government, the NGOs Innocence In Danger and Justice
for Children, and the UN Rappateur, no DC goverment institutions have had the courage to take
notice of the obvious and, in turn, attempt to prompt corrective action. This systematic failure
may be why so many children in Washington DC end up dead, with citizens and news reporters
later asking "how could the District of Columbia Government allow this to happen?" In the
hopes of preventing a fatal disaster for this child and her family, let's ask ourselves now: "How
can we prevent this child's life from being lost in Washington DC?" Please do what you can to
first get this child the medicine and independent medical evaluations that she needs. Second, re-
quire an independent investigation of this matter now and get to the bottom of why these DC
goverment divisions are failing this child and why individuals, such as James Toscano, are so
intent on perpetuating that failure in order to protect the abusing parent. Action must be taken to
give this child the protection, medicine and independent medical and specialized psychological
exams she needs to have the safe and normal life she deserves.
I would be happy to meet with you and/or Assistant Chief Newsham to discuss this
matter. Thank you for your attention to this matter.
Sincerely,
Roy L. Morris, Esq
80
81
82
Testimony Calling for Independent Investigation of CFSA
Before the DC Counsel CFSA Oversight Hearing of Mar. 11, 2010
-- Roy Morris, Esq.--
Chairman Wells, and Members of the Committee, my name is Roy Morris, and I
am here as a public interest advocate. Today I urge the City Council to initiate an
independent investigation by either Federal Authorities or an independent counsel,
like Mr. Bennett, to look into the depth and breadth of the corruption at Child and
Family Services Agency (CFSA).
It has been almost a year since I last came before you highlighting the case of
how CFSA failed a now six-year- old child living in Ward 2. It is my opinion that by any
reasonable standard, CFSA failed to properly investigate complaints filed by mandated
reporters in that case. In this case, CFSA went out of its way to avoid finding abuse and
neglect.
My experience supports many of the allegations found in the December 6, 2008
letter of the “Concerned Social Workers.” That insightful letter was sent to the
Washington Post, Chairman Wells, and Federal Judge Hogan. It spoke of unethical
CFSA practices in closing cases, including cases being closed by administrators and
lawyers at CFSA.
For the suffering little girl mentioned, her situation appears to me to have become
worse due to CFSA’s failures. Those failures have left her in unnecessary danger
with severe chronic neutropenia of undiagnosed cause -- a life-threatening very
rare blood disease, which evidence strongly suggests is induced by drugs commonly
used for covering up abuse. CFSA ignored these and other facts.
When I came before you a year ago, I sincerely believed that the irregularities we
had witnessed were simply caused by an agency that did not have the will or skill to do
!
83 /DQLHU*ULVKDP
its’ job. As the irregularities have become greater and certain CFSA employee
actions more antithetical to the agency’s purpose..... including attempts to prevent
other institutions from finding abuse and providing help for this child –- an innocent
explanation no longer seems plausible to me.
Disturbing facts have come to light that give answers, I believe, as to why high
ranking CFSA employees have abdicated their responsibilities, interfered with the
CFSA investigations, and, also in my opinion, have acted beholden and protective of
abusers and their attorneys.
Today, we must take a stand to save this child, and others like her, by giving them
immediate relief and safety. Organizations from around the world and the US,
including members of Congress, have been made aware and are looking for this
situation to be corrected. Will Washington DC once again make the headlines and
have to explain why another child’s life was lost while this agency looked the other way?
The explanation for this corruption that I refer to is both disturbing and appalling.
One very egregious example involves one key high-ranking official of CFSA. Not a
widely known fact, it involves a high ranking CFA official who was arrested for a
sexual offense, and went into a sex offender diversion program that included: one year
supervised probation, and psychological evaluation.
Why would a person with such a background be allowed to work in CFSA, or any
other agency involved with the welfare of children?
How was the District made aware of this person’s background, and what did it do
about it?
What is the magnitude of the impact this little known fact can have on such a
person’s independence to advocate for abused children, rather than for suspected
"
84 /DQLHU*ULVKDP
abusers -- who would be inclined to use this information to pressure such a
CFSA official to prematurely close and improperly dismiss abuse cases?
Only through an independent investigation can the depth and breadth of this
problem be uncovered, and the damage it has caused to the children of Washington DC
corrected. In the interim, we ask that the DC Counsel order the immediate reopening,
investigation, and corrective action in all cases, including the case of the six year
old neutropenic little girl, that were wrongfully interfered with by those corrupted
employees.
Background
Based on my understanding, the six year old child lives isolated in a small one-
bedroom apartment, in a windowless bedroom, sleeps in a queen sized bed that takes
up most of that windowless room. She has – on a number of occasions – told medical
and psychological personnel and forensic interviewers that her father sleeps in her bed,
the “poppo gets harder and harder,” and that her father does “bad touch” while pointing
to her inner thighs. Consistent with medical harm, she now has a very rare blood
disorder, that only appeared soon as she disclosed that her “papa gives me green
medicine to make me sick. But don’t tell him I told you.” Dr. Joy Silberg, a mandated
reporter who is an internationally recognized specialist in abused children, submitted a
written complaint to CFSA. However, even after CFSA social workers claim to have
visited this one bedroom apartment that is used as an a multibedroom living quarters,
and examined these documented facts, that was not enough for CFSA to investigate
further.
The six year old child suffers from a very rare blood disease called severe chronic
neutropenia that can be induced with drugs, – a condition similar to AIDS –that leaves
#
85 /DQLHU*ULVKDP
the body with little defense to fatal infection. With this disease, one day the patient can
look fine, ....the next day catch an infection,.... and the next day die from the infection
that your and my body can easily tolerate, but hers cannot. However, when the father
failed to take the child to a hematologist/oncologist on his own for months – it hardly
raised an eyebrow at CFSA. This is despite the fact that at least two medical experts
had expressed concern that the suspected abuser failed to take such basic diagnostic
actions. One of the world’s leading pediatric severe chronic neutropenia expert
researcher and physician who is the Co-Director of the Severe Chronic Neutropenia
International Registry, has reviewed the same records as CFSA, and concluded that the
child’s severe neutropenia is likely due to toxins/drugs – including the type that a
neurologist, such as the father, would have access to. Again, this CFSA did little for the
child, and failed to follow its own protocol for independent evaluations.
Based on the records, a sexual abuse investigation at Children’s National Medical
Center (CNMC) appears to me to have been made purposely superficial and
misdirected by the unexplainable actions of CFSA. The CFSA social worker involved --
who had already preliminarily concluded that there was no abuse – allowed the
suspected father to accompany the little girl to CNMC. Once there, the CFSA social
worker appears to have instructed CNMC not to interview the child, misinformed them
by telling them that the mother was the source of the reports about abuse, and failed to
mention that the written complaints were submitted to CFSA by multiple mandated
reporters. As any person familiar with sexual abuse investigations knows, an interview
can only be successfully done without the abuser present and such an interview is
critically important to such an investigation. To make matters worse, CFSA used that
superficial sexual abuse investigation as a fraudulent basis for claiming in other venues
$
86 /DQLHU*ULVKDP
that the medical neglect concerns involving the severe neutropenia were “unfounded.”
In addition, even without speaking to the child, the records show that CNMC diagnosed
her with “post traumatic stress disorder,” and recommended regular therapy for the child
but there is no record of any follow-up by the father or CFSA to assure that therapy was
provided. That alone should have been a basis for finding neglect.
After that very brief irregular investigation was quickly opened and closed as
“unfounded,” a high level executive of CFSA demanded medical records from
Georgetown University Hospital – where the CFSA request made the material
misrepresentation that the child was a “District of Columbia committed ward.” When
questioned, Dr. Roque Gerald wrote a reply claiming that the high level CFSA executive
was simply the using a generic form – but he did not explain why a generic form having
such a material misrepresentation was used. No explanation was given why additional
inquiry was being made by CFSA after it supposedly had closed the earlier investigation
as unfounded. Were those earlier cases really closed? Where they really found to be
unfounded? Was CFSA having second thoughts? Did CFSA know that the records it
received from Georgetown were incomplete because they did not include all test
results? How many other instances has CFSA used this generic form to obtain
information knowing that it contained misrepresentations of the status of the child.
When asked for a report on the investigations, one CFSA official told us in writing
that we would get a summary report. Later, when asked again, we were told that such
reports are not provided for “unfounded cases.” However, the suspected abuser father
received not just one, but three different reports – including one faxed to him at 6:30pm
in the evening from CFSA’s offices. Those reports were never forwarded to the
mother.
%
87 /DQLHU*ULVKDP
in what appears to me to be a wholesale cover-up, CFSA refused to provide
copies of any documents in response to a FOIA request, including even documents it
had filed publicly, documents it had previously exchanged with the abusing Father and
his counsel, and as well as those it had exchanged with the mother and her counsel.
No attempt was made to even provide a Vaughn index, nor redacted versions of the
documents – even though required by law for documents even when they contain FOIA
exempt information. Furthermore, given that CFSA’s FOIA statistics from the City’s
Secretaries office indicate that a complete denial of a FOIA request by CFSA is rare
[none out of 19 FOIA requests in FY2009 were denied in whole]1 – it only adds to
further evidence that CFSA is attempting to cover up the corruption in its ranks.
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88 /DQLHU*ULVKDP
89
EXHIBIT ____
90
91 /DQLHU*ULVKDP
92 /DQLHU*ULVKDP
93
Customer Ac ll Period Bill Date
Roy Morris May 27 - Jun 26 Jun 30, 2010 6 of 6
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94 /DQLHU*ULVKDP
*** GOVERNMENT OF THE DISTRICT OF COLUMBIA
METROPOLITAN POLICE DEPARTMENT
Roy L. Morris, Esq.

PO Box 100212
Arlington, VA 22210
Re: CFSA and MPD Investigations for ALM King-Pheiffer
This letter is in response to your correspondence dated June 30, 2010, sent to Chief of
Police Cathy Lanier. In this correspondence you cited irregularities with individuals
contacting the mother ofALM King-Pheiffer claiming to be investigators with
the Metropolitan Police Department.
Multiple allegations involving ALM King-Pheiffer have been previously

investigated. During the course ofthese investigations, ALM King-Pheiffer was
interviewed by multiple detectives, social workers, and health care professionals.
ALM King-Pheiffer has undergone medical examinations at Georgetown
University Hospital and CNMC-Child and Adolescent Protection clinic as well as a
forensic interview at the Child Advocacy Center.
The. Commander of Youth Investigations Division has researched this matter and could
not find a record of investigators contacting the child's mother during the month of June,
2010. If you have additional information regarding who contacted Ms. King-Pheiffer,
please forward so it can be researched.
Should you have any additional information regarding this matter, please do not hesitate
95 /DQLHU*ULVKDP
P.O. Box 16 n .C. 20013-1606
SCHOOL NURSE VISITS
BUMPS, BRUSES/ CUTS, INFECTION, INCONTINANCE
(25 August 2009- 10 May 2010)
PLACE PAGE DATE PROBLEM TREATMENT COMMENTS
School nurse August 31, 2009 Bump Cold compress First aid – 5 min
SN October 8 2009 Hygiene referral 16 min Refer to parent/
guardian
SN October 13, 2009 Non medical Copy form
SN October 12, 2009 Hep b#4 Vaccine
SN October 20, 2009 Other Other 5 min
SN November 18, 2009 Knee Bump
SN December 9, 2009 Neuro. Head Ice Fell off playground
equipment
SN December 10, 2009 Exch. records Faculty Conference
SN January 27, 2010 Bump Cleanse, ice
SN Face? Symptom relief
SN March 2, 2010 Scrape/ Face, cleanse,
Abrasion bandage, dressing
SN March 8, 2010 Abrasion/ Parent request for health
Scrape report
SN – Faculty March 11, 2010 Abrasion/ Fell off playground Document, informed parent
Conference Scrape equipment
SN –Parent March 12, 2010 Abrasion/ Medical information 10 min-Discussed legal
contact Scrape exchange custody of child. Father has
sole custody with a
document with a document
court order no contact order
for the mother
SN- Parent March 12, 2010 Abrasion/Scrape Info. Exchange 5 Min.
Illness March 20, 2010 Bladder/Kidney, Incontinence / “Had 2 urinary accidents this
assessment Frequency morning in school. Spoke to
parent who is a physician.
He said she had a long
bubble bath the night before.
He will have her checked for
bladder issues. Child has a
change of clothing”
SN-Parent April 6, 2020 Bladder/Kidney, Incontinence /
Frequency
Head office April 22, 2010 Cut finger, fingernail Dressing, wash,
SN May 4, 2010 Bump Ice , wash hand and
face
96 /DQLHU*ULVKDP

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ROY L. MORRIS, ESQ.

President Barack H. Obama

Dear President Obama:

Roy Morris, Esq.

cc: Honorable Hillary Clinton, Secretary of State,

Eric Holder, Attorney General , US Department of Justice

Mr. Michael B. Regan

Ariana-Leilani Margarita Alexandra KING-PI<EIFFEH

Ref. No, {please .::itt: in respons.:): RK 520, SE King-Pfeiffer

Washington, D.C., August 17,20 I0

Dear Mr. Regan ,

With many thanks for your support.

Prof. Karl H. Welte, Dr. med.,

ALM ALM born 7 May ALM

Case history (Anamnesis):

Prof. Karl Welte, Dr. med.

The Honorable Klaus Botzet

RE: Ariana-Leilani King-Pfeiffer

Dear Mr. Botzet:

Please feel free to contact me directly at 1-800-726-4463.

Before GCSF After GCSF

Mr. Michael B. Regan

Washington, D.C., August 30, 2010

Dear Mr. Regan,

An independent medical examination requires that it be independent of all institutions

Dr. Alison M. Jackson, MD, MPH

May 29, 2009

Re: Mandated Reporters-Based Investigation of ALM ALM DOB 05/ALM

Dear Dr. Jackson,

Roy L. Morris, Esq.

Childhood Recovery Resources

Dr. Roque R. Gerald

Dear Dr. Gerald:

I am a. clinical psychologist licensed by the State of Maryland, and I am internationally

d reporter, I am writing to report my suspicion that the child ALM

Dr King, the child's mother, 11725 Greenlane Drive, Poto~nae,M,D 20854,

Tn addition, I have reviewed a y a private investigator from February and

Joyanna Silberg 6501 N. Charles St. P.O.Box 6815 Baltimore. MD 21285-6815

Childhood Recovery Resources

March 3"', 2009

Jovanna Lee Silber~.Ph.D.

Licensed as a psychologist by the Maryland State Board of Examiners, April 1982.

Private Owner: Childhood Recovery Resources: Consulting, therapy, forensic

Senior Associate Editor, Journal of Child & Adolescent Trauma.

Clinical Coordinator of School Consultation Program, 1988 - 1997.

Consultant to McDonough School, Key School, Friends School, Bryn Mawr

Coordinator of Psychological Testing - Responsible for coordination ofhospital-

Coordinator of Child and Adolescent Programs. Program included Custody

Slieppard Ptatt experience includes inpatient short-term adolescent treatment,

Hebrew University, Jerusalem, Israel

Postdoctoral Fellowship in Child and Adolescent Psychology,

Supervised experience in individual therapy, psychological evaluations

Internship in,Pediatric Psychology, University of Maryland

Experience in a broad range of psychological services in a pediatric

Faculty, Post-Doctoral Institute on Trauma, Maryland Psychological Association

Faculty, Dissociative Disorders Psychotherapy Training Program, sponsored by

Presenter, national and international conferences on treatment and assessment of

traumatized children, 1990 -present.

Faculty, National Center for Human Development

Presentations on child and adolescent development, psychopathology, attention

Supervisor, Postdoctoral fellows, 1985 -present.

Instructor, Ohio State Univcrsity, 1975 - 1978.

Substitute teacher, Roarnokc, Virginia. Experience in elementary, junior high, and

UPCOMING AND RECENT PRESENTATIONS:

Treatment of Dissociative Symptoms and Disorders in Childrcn and Adolescents:

Childrcn as Pawns, Police Academy of Baltimore County, Training on Domestic