Failure of Washington DC Child Protection (CFSA) Dr. Roque Gerald to Protect 7-yr Ariana-Leilani King-Pfeiffer from Drugging, Sex Use, Abuse, Drug-Induced and Untreated Life-threatening Illness - LaShawn Court Monitor Lettter With Attachments

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 17, 2010
Judith W. Meltzer, Deputy Director

Office of Children' s Issues
Center for the Study of Social Policy
1575 Eye Street, NW, Suite 500
Washington, DC 20005
Re: LaShawn v Fenty, Case 89-1754
Dear Ms. Meltzer,
Despite the efforts of an international NGO Innocence in Danger, the German Embassy,
several worldwide experts, and the child's mother (who lives in Germany), among others,
"ALM," a seven year old German/American citizen living in the District of Columbia, remains in
continuing danger from a very rare blood disorder, called Severe Chronic Neutropenia (SCN)--
i.e. severely very low immunity to potentially fatal infections -- of undiagnosed cause. The ex-
tensive documentation accompanying this letter demonstrates how DC's Children and Family
Services (CFSA)'s interference, improprieties of its personnel, and failures to properly investigate
pursuant to the LaShawn protocol, have caused ALM to be denied proper medical care and medi-
cine to address her risk of fatal infection.
The seriousness of her condition is without question. Dr. Carl Welte, a world expert in
pediatric neutropenia and co-director of the Severe Chronic Neutropenia International Registra-
try (SCNIR) has reviewed all of the medical reports, and has concluded that ALM's condition is
likely “induced by toxins” / drugs (see, Exhibits at 53). But no remedial medicine or independ-
ent medical examination, including drug testing, has been ordered by CFSA for ALM. Among
the types of psychotropic drugs that can cause this condition are those used by sexual abusers to
gain victim compliance and cause memory loss. Dr. Joy Silberg, an expert in dissociative disor-
ders caused by sexual abuse, has reported that there is strong evidence that this child's condition
is consistent with sexual abuse. (see, Exhibits at 5). Yet, with all this and other detailed infor-
mation -- far more than that typically found in a case of alleged abuse -- the CFSA has prema-
turely closed these "mandated reporter" cases within 30 days and claimed that they are all “un-
founded." (see, Exhibits at 1- 51)
What is also significant about this case is that it occurred, in part, during the period for
which the CFSA was held in contempt by the Court, and for the period covered by the Monitor's
May 24, 2010 report to the Court that found that upwards of 56% of all investigations were of
insufficient quality.
Despite calling on officials for an independent investigation of this matter (see extensive
letters, testimony, and records attached) iincluding Mayor' Adrian Fenty’s office, Dr. Roque
Gerald of DC Child and Family Services (CFSA), DC Councilmember Tommy Wells who is
chair of the Committee that oversees CFSA, the DC Metropolitan Police Department, and the
Letter to Ms. Meltzer
September 17, 2010 - Page 2
Children’s National Medical Center (CNMC), no independent investigation, protection, or

proper medical care resolving ALM's health crisis -- of clearly suspect cause -- has been forth-
coming. There has been no substantive response to the extensive medical documentation and
opinions that clearly demonstrate an urgent need for protection, and medical and psychological
assistance.
The documents speak for themselves, but here are some highlights:
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, Exhibits at 16),
CFSA has never properly investigated the cause or basis for ALM's two year old Severe Chronic
Neutropenia (SCN) -- which she has suffered with since Spring 2008 when she began to regu-
larly live with her German father in Washington DC. CFSA has completely ignored the Severe
Chronic Neutropenia condition, failed to properly follow its LaShawn mandated protocol for
such investigations (see, Exhibits at 59, attachment to June 30, 2010 letter to Tommy Wells and
Mr. Roque Gerald), and has not done any follow-up despite ALM's continuing worsening condi-
tion (See, Exhibits 66-71) [Her most recent Summer 2010 medical records show her ANC (the
measure of her ability to fight infection) has dropped to below 200 (less than 10% of the mini-
mum level of 3000) -- 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), see, Exhibits at
16), Dr. Joy Silberg (Shepherd Pratt Hospital PhD psychologist expert in abuse and neglect, and
dissociation (April 2009), see, Exhibits at 5), and Dr. Lee Schneyer (PhD psychologist expert in
child abuse (August 2008) made medical neglect and sexual abuse reports directly to 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 ALM'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 neutro-
penia). (Exhibit at 53) Because of the severity of her condition, she has been placed on the Se-
vere 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 ALM's
case. In his first October 2008 report to CFSA, Dr. Sklaroff complained that the underlying
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 (GUH), for a blood
test evaluated by a relatively inexperienced GUH hematologist/oncologist. The records show
that the father, a former GUH staff physician himself, gave the GUH staff physician false infor-
mation concerning the origins and purpose of the visit, as well as an incomplete and distorted
medical history of the child. (Exhibits at 90-95) The inadequacy of that first visit was demon-
strated by the fact that only two weeks later, ALM was forced to return to GUH (October 22,
2008) with what the GUH 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)." (Exhibits
at 27) That visit, where sexually transmitted herpes was suspected by another attending physi-
cian, was never followed up by CFSA.
4. CFSA's then General Counsel James Toscano has personally interfered with ALM's
case since 2008. His interference is consistent with the CFSA social worker complaints that
CFSA attorneys were closing cases, as stated to the Court in their letter of December 6, 2008.
(See, Exhibits at 107) He personally interfered with a case brought by the mother in DC Supe-
rior Court (King v Pfeiffer, Case No. 09 DRB 1167), where she sought a court order for an inde-
pendent medical examination for the Severe Chronic Neutropenia in April 2009. CFSA was not
a party to the case. The CFSA General Counsel, who had neither been subpoenaed or subject to
a court order to appear, showed up in that courtroom and remained for many hours, at the appar-
ent request of the alleged abuser's counsel. In the Courtroom, the CFSA General Counsel ap-
peared nervous and acted overtly subservient to the alleged abuser's counsel. The CFSA's Gen-
eral Counsel provided misinformation to the court concerning the alleged timing and nature of
CFSA's actions. He also resisted discovery that would have revealed to the Court the lack of ba-
sis for his claims and the conflict of interest surrounding his aberrant appearance. CFSA's Gen-
eral Counsel's misconduct in that court case are part of the subject of an appeal to the DC Court
of Appeals, King v Pfeiffer, Case No. 09-FM-1484 (pending, see excerpts of brief attached, Ex-
hibits at 115).
7. As explained in the attached letters to DC City Councilman Wells and Mr. Roque Ger-
ald, in the process of investigating possible connections between CFSA's General Counsel and
the alleged abusers counsel, it came to light that, in 2004, CFSA’s later-to-be-General Counsel
was arrested in Arlington for a sex offense, and agreed to one year probation as a condition to
having the charges dismissed a year later (2005). The 2004 arrest was for indecent exposure
(masturbating in a urinal while looking into a neighboring stall) in a public restroom in an area
frequented by minors. According to a 2007 DC CFSA policy memo, a probation before judg-
ment for a sexual offense should cause an immediate termination from any position involving
contact with children. CFSA's later-to-be General Counsel only recently (June 2010) had his
arrest record expunged from the Arlington County court records, 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 June 2010.
(Exhibits 51, 57, 72, and 100)
8. In April 2009, CFSA also interfered with ALM getting a proper medical examination
and, in turn, GCSF medicine at Children’s National Medical Center (CNMC). (See, Exhibits at
1-36) The Lashawn policy manual requires that all cases be brought to the CNMC within 24
hours. However, CNMC records show that when ALM was brought to CNMC by the father (the
suspect for neglect/abuse) many days after complaints were received. In addition, the CFSA
case worker did not direct the CNMC to look at the neutropenia -- which was the critical evi-
dence of the abuse -- and she did not provide to CNMC any medical test information on the neu-
tropenia! The CNMC staff was also given false information about who filed the complaints at
CFSA, and the CNMC were told not to interview the child, even though records obtained
through DC MPD show that the child had been last interviewed at the CAS in August 2008 (3/4
of a year before April 2009). On behalf of the mother, I wrote to the CNMC evaluation center's
director in May 2009 and pointed out the failures in the April 24, 2009 investigation. (See,
Exhbits at 1) CNMC has yet to provide any written substantive response, nor has it shown any
interest in correcting the obvious quality problems of its investigation. Furthermore, although
CNMC noted that its staff had diagnosed ALM with DSM 308.1 “post traumatic stress disorder,”
set forth notations of “concerns for sexual abuse,” and recommended psychological “therapy,”
both CFSA and CNMC failed to assure that ALM received the psychological treatment pre-
scribed, or do any other follow-up. Despite these open issues identified by CNMC, CFSA irre-
sponsibly closed the case as "unfounded."
9. A CFSA Social Worker wrote a letter in May 2009 to the alleged abuser stating the
case was closed as "unfounded." But, on June 9, 2009 -- one month after the social worker's
May 2009 letter -- CFSA's Dr. Cheryl Williams, who is CFSA's head medical officer, faxed a
request to Georgetown University Medical Center (GUH) requesting ALM's medical records.
Compare, Exhibits at 35, and 39-41). CFSA's Dr. William's fax request clearly indicated that
the CFSA investigation was ongoing -- far beyond the time that the CFSA social worker had in-
dicated the case had been closed as "unfounded." The June 2009 CFSA fax request to GUH was
the subject of an exchange of letters in July and August 2009 between CFSA's Director Dr.
Roque Gerald and myself (See, Exhibits 37-50). 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. William's request for records, the CFSA's General Counsel's repre-
sentations to the Superior Court, and the CFSA Social Worker's May 2009 letter.
10. On May 11, 2010, I testified before the DC City Council Committee on Health Serv-
ices (which oversees CFSA) asking for an independent investigation of CFSA and its General
Counsel's actions (see, Exhibits at 100). Once again, no apparent action was taken and no re-
sponse 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 of
ALM.
11. As recently as June 2010, Dr. King received a telephone inquiry allegedly from a
CFSA worker who claimed she was investigating a case based on “something the mother said.”
The caller was only interested in knowing the last time the mother had seen her child. This in-
quiry was highly suspicious because the caller was not interested in knowing about the child's
current medical condition. In turn, I wrote a letter to Councilmember Wells and CFSA Director
Gerald on June 6, 2010, pointing out the irregularity of that CFSA inquiry. (See, Exhibits 51-56)
Neither CFSA's Director Dr. Gerald or Councilmember Wells has responded to the letter, nor
have they explained that CFSA inquiry.
12. The DC public schools have produced nursing visits records for ALM that show 14
visits to the nurses office in less than 9 months for bruises, bumps, scraps, cuts, incontinence,
and hygiene. (See Exhibits at 113) The school system has been advised of ALM's serious con-
ditions (severe chronic neutropenia, asthma, and unusual weight gain) but they claim that they
are unable to help.
13. Investigations by the DC Police for criminal misconduct (which are routinely initi-
ated whenever CFSA receives a medical neglect or sexual abuse report) have also been flawed or
non-existent. Internal documents show that MPD's investigation in August 2008 relied solely on
information from interviews with the alleged abuser and his Attorney. The DC Police Investiga-
tors did not contact the mandated reporters who made the sexual abuse and medical neglect re-
ports, ignored the interviews they had with the mother and her counsel, and ignored the existence
and persistence of ALM's Severe Chronic Neutropenia condition. As recently as June 2010, the
mother received another suspicous telephone inquiry allegedly from the DC Police Department's
investigation unit. This investigator was only interested in knowing when the mother had last
seen the child. She expressed little or no interest in knowing about the child's current medical
condition. The investigator admitted that she was completely confused about why she was look-
ing at case, she said another investigator had looked at it only three weeks before, and she also
said that the text of prior investigation reports looked like they had simply been copied. I then
had a 42-minute telephone conversation with that alleged Police Investigator, and offered to pro-
vide her with up-to-date documentation. However, she failed to follow-up. A letter was written
to DC Councilmember Wells, CFSA Director Dr. Gerald and Police Chief Lanier raising con-
cerns about this aberrant DC MPD inquiry. (See, Exhibits at 57) In response, the Assistant
Chief of Police Newsham wrote back in August 2010 where he stated that the DC Police had no
record of the inquiry. (See, Exhibit as 112) We responded with a detailed letter to Chief Lanier
and Assistant Chief Newsham explaining both the long history the father has with the DC Police
(dating back to his disruptive behavior as an uninvited guest at a diplomatic reception at the
Zambian Embassy in July 2007 where he was ordered to leave by the US Secret Service), and the
phone record evidencing the 42 minute phone call with the alleged DC Police Investigator (see,
August 2010 Letter to Chief Lanier and Assistant Chief Newsham, and its attachments, see, Ex-
hibits at 72-146)
14. Using a Freedom of Information Act request, the mother has also sought from CFSA
information documenting its activities and correspondence relating to ALM and the mother. The
CFSA has refused to provide the mother with any information -- including refusing to produce
even redacted records and/or a Vaughn Index of any records. That FOIA is now 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, see, Exhibits at 138).
In summary, for over two years (2008-2010), even when presented with objective facts
and expert opinions that met textbook definitions for establishing the need for proper independ-
ent examination and medication, CFSA has refused to act, including failing to secure an inde-
pendent medical evaluation and proper medical care for ALM. It is more than coincidental that
CFSA has rarely found abuse or neglect. The CFSA has a very strong incentive to prematurely
close cases like ALM’s even when facts indicate otherwise; rematurely closing cases is less
work, avoids a papertrail, and helps CFSA's case management look artificially better to the
LaShawn Court. CFSA has shown itself to be an intellectually and morally corrupt agency, with
top officers with known serious personal sexual history problems. We also believe such back-
grounds make CFSA's officials biased and more sympathetic, and even protective to the alleged
abusers. The records indicate that in ALM’s case, CFSA treated the father of ALM (the alleged
suspect of abuse and neglect) as if he were a colleague, including freely sharing information
with him and his lawyer -- while excluding the mother and her counsel from the process, and re-
fusing to share any information with them.
An independent medical and psychological examination, with proper remedial medica-

tion, remains needed for this critically ill child. Independent means independent of all institu-
tions and individuals who were previously involved. Those involved with the prior flawed CFSA
investigations, where behaviors bordered on criminal conduct, would only have the incentive to
rubber stamp their prior conclusions to "validate" their prior flawed actions. Also, due to the
rarity of severe chronic neutropenia where the cause has not been diagnosed for over two years,
independence requires highly specialized forensic medical and psychology expertise that has no
interest in rubber-stamping CFSA's flawed work.
We believe the Court Monitor and the parties to the LaShawn case can learn a great deal
from this illustrative case of CFSA's failures and, in turn, implement improvements to better pro-
tect the children of Washington DC. An independent investigation of the circumstances of this
case would be particularly helpful to both ALM and the other children facing abuse and nelgect
in Washington DC. We share your interest in getting CFSA's performance up to a minimal stan-
dard that can provide some measurable level of protection for all of the children of Washington
DC. We also hope that the upcoming change in mayoral leadership will result in a new and
vastly improved CFSA -- which will not repeat the mistakes of the old one. I would be happy to
meet with you to discuss any questions you have, and provide any additional documentation (in-
cluding some of the attachments and other documents omitted to minimize the volume of pages).
Sincerely,
Roy Morris
Counsel for ALM's Mother, Dr. Ariel King
cc:
The Honorable Thomas F. Hogan, Chief Judge of the U.S. District Court
333 Constitution Avenue, NW, Room 4012, Washington, DC 20001
Marcia Robinson Lowry, Children’s Rights

330 7th Avenue, Suite 400, New York, New York 10001
Arthur B. Spitzer, American Civil Liberties Union of the National Capital Area
1400 20th Street, N.W., Suite 119, Washington, DC 20036
Richard Love, Senior Assistant Attorney General

Office of the Solicitor General, Office of the Attorney General, D.C.
441 4th Street, N.W., 6th Floor South, Washington, D.C. 20001
TABLE OF EXHIBITS
Page
1) May 29, 2009 Letter to Dr. Alison Jackson, CNMC 1
a) April 24, 2009 CNMC Intake Record 3
b) April 21, 2009 Abuse/Neglect Complaint of Dr. Joy Silberg to CFSA 5
c) April 21, 2009 Medical Neglect Complaint of Dr. Robert Sklaroff to CFSA 16
d) April 21, 2009 Complaint of Justice for Children to CFSA 24
e) April 21, 2009 Handwritten Note to Abuser from CFSA Social Worker to Alleged Abuser 26
f) October 22, 2008 GUH Medical Record with Physician Finding
“currently with mouth ulcers of recent onset suspicious for a viral infection (Herpes).” 27
g) January 9, 2009 GUH Medical Record Showing Worsening of Neutropenia—of Undiagnosed Cause—
after CFSA Closed Case as “Unfounded.” 31
h) May 12, 2009 CFSA Social Worker Ltr. to Alleged Abuser Claiming Case Was Closed as “Unfounded.” 35
2) July 23, 2009 Ltr to Dr. Roque Gerald Questioning Continuing CFSA Investigation After Case Allegedly Closed 37
a) June 9, 2009 CFSA Fax to GUH Requesting Records Based On Authority to Request Information for
“Committed Wards.” 39
b) June 9, 2009 GUH Fax Cover Sheet to CFSA 41
3) July 29, 2009 Initial Response of Dr. Roque to July 23, 2009 Letter 44
4) August 3, 2009 Ltr to Dr. Roque Gerald Asking Additional Questions Raised by His July 29, 2009 Response 45
a) July 21, 2009 Bone Marrow Aspiration Test Results Showing Peripheral Destruction of Neutrophils—Which Is
Consistent with Drug Induced Neutropenia 48
5) June 15, 2010 Ltr to Councilmember Wells and Dr. Roque Gerald Regarding Aberrant CFSA Inquiry 51
a) August 31, 2009 Dr. Welte Observations: “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.” 53
7) June 30, 2010 Letter to Concilmember Wells, Dr. Roque Gerald, and Chief Lanier Regarding Aberrant DC MPD Abuse
Investigator Inquiry 57
a) *Defects of CFSA Investigation—Failures to Follow CFSA LaShawn Protocol* 59*
b) Graph of ALM’s ANC—Measure of Severity of Neutropenia
(recently dropped to below about 200, compared to “normal” levels above 3000) 66
c) Table Showing Other ALM Abnormal Blood Measures Of Undiagnosed Cause 67
d) Sample Blood Results Report from March 10, 2010 68
8) August 13, 2010 Ltr to Chief Lanier and Assistant Chief Newsham Responding to Assistant Chief Newshams
Letter Claiming No Record of 42 Minute Investigator Inquiry 72
a) June 11, 2008 Montefiore Hospital Report Showing Medical Worker Interview With ALM Where
She Discloses “Bad Touch” While Pointing To Her Thighs 83
b) August 14, 2008 Defective DC MPD Report Omitting Interview with Mother and Her Counsel and
Lacking Interview with Psychologist Who Originated Report 85
c) October 10, 2008 Medical Record From First "CFSA" Investigation Visit Where CFSA Is Absent
and Only Alleged Abuser Is Present 90
d) October 10, 2008 “Prescription” Written By GUH Staff Physician Omitting Key Restrictions for ALM
That He Had In His October 10, 2008 Medical Record 94
e) October 10, 2008 Aberrant Email of GUH Staff Physician to “BZ” (Bethlehem Zewde) of CFSA 95
f) March 11, 2010 Testimony of Roy Morris to DC Council Committee Asking for
Independent Investigation of CFSA 100
g) December 6, 2008 Letter of Concerned Social Workers in LaShawn Case 107
h) June 22, 2010 Call Record of Call with DC MPD Call That MPD Claims It Could Not Find In its Records 111
i) June 30, 2010 Letter of Assistant Chief Newsham Indicating that MPD Could Not Find Any Record of the
June 22, 2010 Call 112
j) May 10, 2010 List of Extensive Trips of ALM to Nurse’s Office 113
k) March 1, 2010 (Factual Background Section) Brief to DC Court of Appeals Regarding Superior Court Case
With Which CFSA General Counsel Improperly Interfered 115
l) January 29, 2010 FOIA Complaint Regarding CFSA’s Complete Denial of Request for Records 138
LaShawn - Page 1
ROY L. MORRIS, ESQ.
! PO Box 100212
! Arlington, VA 22210
! 202 657 5793
! 509 356 2789 (Fax)
! Roy_Morris@alum.mit.edu
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).
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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
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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

410-938-4974
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04/21/2009 11:47 4109385072 TRAUMA DISORDERS
LaShawn - Page 6
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
41 0-938-4974
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TRAUMA DISORDERS PAGE B4/12
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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.
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TRAUMA DISORDERS PAGE B5/12
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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

2
LaShawn - Page 8
TRAUMA DISORDERS PAGE 06/12
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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.
3
LaShawn - Page 9
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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.
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B4/21/2BB9 11:47 41B93B5B72 TRAUMA DISORDERS PAGE m / 1 2
LaShawn - Page 11
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.
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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.
LaShawn - Page 12
LaShawn - Page 13
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.
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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
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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
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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
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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.
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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.
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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.
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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.
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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.
LaShawn - Page 21
LaShawn - Page 22
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.]
LaShawn - Page 22
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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
LaShawn - Page 23
04/23/2008 14:51 FAX 2024280657 RUBIN WINSTON DIERCKS HA
LaShawn - Page 24
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
LaShawn - Page 24
RUBIN WINSTON DIERCKS HA
LaShawn - Page 25
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
LaShawn - Page 25
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ALM
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The Children's Cancer Foundation

Pediatric Hematology Oncology Clinic
Department of Pediatrics
Georgetown Division of Pediatric/Hematology/
University Oncology, Blood and Marrow
Hospital Â¡-- Transplantation
Lombar& 3800 Reservoir Road, NW

Comprehensive Washington, DC 20007-2 113
Phone: 202 444 2224 * Fax: 202 444 88 17
Cancer Center
MedStar Health
Patient Name: ALM ALM R

MRN: 6412380
DOB: MayALM
PEDIATRIC HEMATOLOGY- ONCOLOGY FOLLOW-UP VISIT
INSTITUTION: Georgetown Pediatric Hematology Oncology
PATIENT: ALM R ALM

MRN: ALM
DATE OF BIRTH:MayALM
DATE OF VISIT: Oct 22, 2008
PHYSICIAN: Amal Abu-Ghosh, M.D.
REASON FOR VISIT:

5 year old with history of neutropenia presents today with oral mucosal ulcers for one day.
HISTORY OF PRESENT ILLNESS:

Interim History:
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
groin 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.
HPI:
ALM is a five year old, healthy female who presents to the hemelonc clinic for a consult regarding her persistent
neutropenia since May of 2008. ALM was seen by her pediatrician on May 2, 2008 for a WCC, and a routine CBC was
Electronically signed by: Arnal Abu-Ghosh, M.D.
LaShawn - Page 27
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Patient Name: ALM ALM

Visit Date: Oct 22, 2008
Page: 2
performed: WBC 4.6, granulocyte count 26%, ANC 1200, Hb 12, platelets 315. The pediatrician did not find any significant
physical findings at this WCC (only some shotty cervical lymphadenopathy). Prior to this WCC, ALM had been feeling
well, but did have a hx of very mild URI symptoms (clear to yellowish rhinorrhea and intermittent cough) since November
2007. These symptoms never caused her to miss school, she remained energetic (as usual) with a good appetite and she
did not have any fevers, palllor, or abnormal bruisinglbleeding. In light of this slightly decreased ANC of 1200,ALM was
re-evaluated on May 25, 2008, with a CBC at that time showing: WBC 4, granulocyte count IS%, ANC 600, Hb 10.9,
platelets 346. ALM was still essentially asymptomatic at this time. After this follow-up, ALM was referred to Dr. Rubio
(ID) on May 30, 2008 for further evaluation, at which time Dr. Rubio believedALM neutropenia to be secondary to viral
myelosuppression (ANC at this time 500).
On June 11, 2008 Adriana was hospitalized at Montefiore Medical Center in New York for 'neutropenia', although Dad
states that this was a 'social admission', as the staff was not comfortable releasing Adriana home with her mother. While
at Montefiore, Adriana was tested for EBC, CMV, HIV, Toxo, Parvo and ANA, all of which came back negative. During the
course of this hospital admission, she remained afebrile and asymptomatic, with her ANC ranging from 120 to 373. Her
peripheral smear was WNL. The hemlonc service sawALM during this admission, and diagnosed her with idiopathic
neutropenia, likely post-viral. She was discharged on June 17, 2008.
Following this admission, Adriana has been following up with Dr. Maria Marquez at Georgetown to track her ANC's, which
initially increased to 880, but again decreased to 560 on Sept 23, 2008. ALM father is not overly concerned about her
neutropenia, but she is here today for a second hemelonc consult for 'social reasons'.
ROS negative for fever, abdominal pain, chest pain, shortness of breathlwheezing, rashes, bleedinglbruising, mouth sores,
diarrhea, constipation, urinary problems, or headaches.ALM has no hx of otitis media, UTI's, sinus infections or
pneumonia, mucositis, and her father does not believe that she has ever been on abx.
ALM is currently living with her father in Washington, DC, where she attends kindergarten. She did not receive her
immunizations at the recommended ages but she is currently almost caught up with all of her vaccines.
PAST MEDICAL/FAMILY/SOCIAL HISTORY:

No History components were reviewed during this visit.
MEDICATIONS:
There is no information available for Current Medications - Treatment.
There is no information available for Current Medications - Patient.
Allergies:
This patient has no documented allergies.
REVIEW OF SYSTEMS:
Constitutional Normal - No loss of appetite, weight changes or fatigue; no fever, chills or

sweats.
Allergic/lmmunologic Normal - No complaint of allergies.
Head Normal - No trauma or headaches.
ENMT Abnormal - Clear rhinorrhea present. No hearing impairment, tinnitus or ear pain.
No ulcers, swollen gums, dental problems or change in taste, no sinus pain or
epistaxis.
Eyes Normal - No visual difficulties. No diplopia.
Neck Normal - No pain or dysphagia.
Electronically signed by: Amal Abu-Ghosh, M.D.
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Page: 3
Integumentary Abnormal - Hx of dermographism. No rashes, lesions, inflammation, purpura or

pruitis.
Breasts Normal -
Cardiovascular Normal - No chest pain or shortness of breath at rest or during exercise.

Respiratory Abnormal - Mild intermittent cough, no dyspnea on exertion, no wheezing
Gastrointestinal Normal - No nausea, vomiting, diarrhea, GI bleeding, or constipation. No
heartburn, change in appetite or bowel habits.
Genitourinary (F) Normal - No abnormal genital masses. No hematuria, hesitancy, incontinence,
vaginal bleeding, discharge or other problems with urination. Normal sexual
function. No frequency, urgency, dysuria, hematuria, bladder or flank pain.
Musculoskeletal Normal - No fractures, joint pain or back pain.
Neurologic Normal - No headache, blurred vision, and no areas of focal weakness or
numbness. Normal gait. No sensory problems.
HematologicILymphatic Normal - No bleeding or easy bruising. No enlarged nodes.
PHYSICAL EXAMINATION:
Vital Signs: Performed on Oct 22,2008 08:55

BMI 17.04 BSA (derived)
Pain (Faces) 0.00 BP
Height 111.00 cms Pulse
Temperature 36.00 C(L0W) Weight
Performance Status: 100% - Full active, normal. (Lansky)
Constitutional Normal - Alert, cooperative, oriented; mood and affect appropriate. Appears
developmentally appropriate for age.
Head Normal - Normocephalic, atraumatic
Eyes Normal - Conjunctivae and sclerae are clear and without icterus. Pupils are
reactive and equal. Extraocular muscles intact.
ENMT Abnormal - Moderate amount of clear rhinorrhea present. Sinuses are
nontender. 1x2-3 cm erythematous ulcer on lower with yellow crusting and
swelling; 4-5 shallow based erythematous ulcers on oral mucosa and right
buccal mucosa. Oropharynx clear. Tongue normal. Good dentition. TM's
normal. No fluid
Neck Normal - Supple without masses or thyromegaly. Some shotty, mobile, non-
tender cervical lymphadenopathy present
Integumentary Abnormal - No rashes, petechiae or bruises. Left thigh hyperpigmented area (-
3x3 cm)
Cardiovascular -
Normal Regular rate and rhythm; no murmurs, gallops; rubs or ectopy. Capillary
refill less than 2 seconds. Pulses palpable and equal bilaterally in all four
extremities.
Respiratory Normal - No tachypnea or nasal flaring. Clear to auscultation bilaterally with good
aeration. No crackles or wheezes.
Abdomen Normal - Non-tender, non-distended, no masses, ascites or
hepatosplenomegaly. Good bowel sounds. No guarding or rebound tenderness.
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Page: 4
No pulsatile masses.
GenitaliaIGroinlButtock (F) Abnormal - 4-5 1 cm papular lesions bilaterally in groin area; non-indurated, non
erthymetaous, no fluctulance
Normal female external genitalia.
Extremities Normal - No visible deformities, no cyanosis, clubbing or edema. Pulses 4+ and
equal bilaterally.
BackISpine Normal - No evidence of scoliosis or kyphosis.
Musculoskeletal Normal - No tenderness or swelling, normal range of motion without obvious
weakness.
Psychiatric Normal - Appears to be well adjusted.
Hematologic/Lymphatic Normal - No bleeding or bruising. No palpable lymph nodes in supraclavicular,
axillary or inguinal areas.
LABORATORY:
Most recent lab results are not available for this patient.
RADIOLOGY:
IMPRESSION:
5 year old female with history of neutropenia, currently with mouth ulcers of recent onset suspicious for a viral infection
(Herpes). CBC today showed an ANC of 1107/ul.
PLAN:
1. LABS
CBC: WBC 4.1 ; HgbIHct 11.3133.8; platelet 350. ANC 1107
2. Cultures of oral lesions are pending.
3. RTC in 3 months to recheck CBC or earlier if mouth lesions or skin lesions worsen.
4. Discussed with Dr Rubio as well who recommended Bacitracin to skin lesions.
cc:
Dr. Scott N Myers, M.D., M.P.H.
No 'Providers' exist for this patient.
Maria L Marquez, M.D.
LaShawn - Page 30
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The Childrop's Cancer Poundation

Department of Pediatrics
Georgetown Division ofPediatric/Hematologyi
Oncology, Blood and Marrow
Hospital @ Transplantation
~ombardi 3800 Reservoir Road, NW

Compt'ehensive Washington, DC 20007-2113
Phone:202 444 7.224 * Fax: 202 444 88 17
Cancer Center
MedStar Health
Patient Name; ALM ALM R

MRN: ALM
DOE: AL /, ALM
M
PEDIATRIC HEMATOLOGY- ONCOLOGY FOLLOW-UP VISIT
PATIENT: ALM R ALM

MRN: 6412380
DATE OF ALM y ALM
DATE OF VISIT Jan 09,2009
PHYSICIAN: Dr. Scott N Myers, M.D,
REASON FOR VISIT:

5 year old with history of neutropenia presents today for scheduled follow-up.

Interim History:
ALM was in clinic with her father again today who is pleased to report that she has been doing well. The oral ulcer which
Dr. Abu-Ghosh saw her for 10/22/08 resolved in a few days, treated with only bacitracin topically and mouthwash (as per
Dr. Rubio's recommendation). She tias had no intercurrcnt mucosal or skin lesions of any kind. She has had no fever or
any symptoms of illness. She is gaining height and weight, meeting her developmental milestones with no signs of delay.
She is doing well in kindergarten. She is on no medications.
ROS negative for fever, abdominal pain, chest pain, shortness of brealhlwheezing, rashes, bleedinglbruising, mouth sores,
diarrhea, constipation, urinary problems, or headaches. ALM has no hx of otitis media, UTI's, sinus infections or
pneumonia, rnucositis, and her father doas not believe that she has ever been on abx.
Electronitially signed by: Dr. Scott Myem, M.0
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Visit Date: Jan 09.2009
page. 2
Hlo persistent neutropenia since May of 2006. ALM was seen by her pediatrician on May 2, 2008 Tor a WCC, and a
routine CBC was performed: WBC 4.6, granulocyte count 20%, ANC 1200, Hb 12, platelets 315. The pediatrician did nut
find any significant physical findings at this WCC (only some shottycervical lymphadenopathy). Prior to this WCC, Arlana
had been feeling well, but did have a hx of very mild URI symptoms (clear to yellowish rhinorrhea and intermittent cough)
since November 2007. These symptoms never caused her to miss school, she remained energetic (as usual) with a good
appetite and sne did nul have any fevers, palllor, or abnormal bruisinglbleeding. In light of this slightly decreased ANC of
1200,ALM was re-evaluated on May 25, 2008, with a CBC at that time showing: WBC 4, granulocyte count 15%, ANC
BOO, Hb 10.9, platelets 346. ALM was still essentially asymptomatic at this time. After this follow-up, ALM was referred
to Dr. Rubio (ID) on May 30, 2008 for further evaluation, at which time Dr. Rubio believedALM neutropenia to be
secondary to viral myelosuppression (ANC at this time 500).
On June 11,2008 Adriana was hospitalized at Monteftore Medical Center in New York for 'neutropenia', although Dad
states that this was a 'social admission', as the staff was not comfortable releasing Adriana home with her mother. While
at Montefiore, Adrhra was tested for EEC, CMV, HIV, Toxo, Parvo and ANA, all of which came back negative. During the
course of this hospital admission, she remained afebrile and asymptomatic, with her ANC ranging tram 120 to 373. Her
peri~heralsmear was WNL. The hemlonc service saw ALM during this admission, and diagnosed her with idiopathic
neutropenia, likely post-viral. Sue was discharged on June 17, 2008.
initially increased to 880, but again decreased to 560 on Sept 23, 2008. ALM is now followed by our hemfonc service for
the chronic neutropenia.
ALM is currently living with her father in Washington, DC, where she attends kindergarten. She did not receive her
immunizations at the recommended ages but she is currently almost caught up with all of her vaccines.
Allergies:
This patient has no documented allergies.
REVIEW OF SYSTEMS:
Constitutional Normal - No loss of appetite, weight changes or fatigue; no fever, chills or

sweats.
Allergio/lmmunologic Normal - No complaint of allergies.
Head Normal - No trauma or headaches.
ENMT -
Normal No rhinorrhea present. No hearing impairment, tinnitus or ear pain. No
ulcers, swollen gums, dental problems or change in taste, no sinus pain or
epistaxls.
Eyes -
Normal No visual difficulties. No diplopia.
Neck -
Normal No pain or dysphagia.
Integumentary Abnormal - Hx of dermographism. No rashes, lesions, inflammation, purpura or
pruitis.
Cardiovascular -
Normal No chest pain or shortness of breath at rest or during exwclse.
Respiratory
Gastrointestinal
-
Normal Mild intermittent cough, no dyspnea on exertion, no wheezing
Normal - N o nausea, vomiting, diarrhea, GI bleeding, or constipation No
Musculoskeletal
Neurologic
-
Normal No fractures, joint pain or back pain.
Normal - No headache, blurred vision, and no areas of focal weakness or
Normal No bleeding or easy bruising. No enlarged nodes.
Electronically ti'igned by: Dr. Scott Myors, M.D
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Visit Data: Jan 09,2008
Page: 3
Vital Signs: stable, see Aria
Constitutional Normal -Alert, cooperative, oriented: mood and affect appropriate. Appears
Head -
Normal Normocephalic, atraumatic
Eyes -
Normal Conjunctivae and sclerae are clear and without icterus. Pupils are
reactive and equal. Extraocular muscles intact.
ENMT -
Normal Moderate amount of clear rhinorrhea present. Sinuses are nontender.
1x2-3 om arythematnus ulcer on lower with yellow crusting and swelling; 4-5
shallow based erythematous ulcers on oral mucosa and right buccal mucoaa.
Oropharynx clear. Tongue normal. Good dentition. TM's normal. NOfluid
Neck Normal - Supple without masses or thyromegaly. Some shotty, mobile, non-
Integumentary -
Normal No rashes, petechiae or bruises.
Cardiovascular -
Normal Regular rate and rhythm; nu murmurs, gallops; rubs or ectapy. Capillary
extremities.
Respiratory Normal - No tachypnea or nasal flaring. Clear to auscultation bllatwally with good
aeration, No crackles or wheezes.
Abdomen -
Normal Non-lender, non-distended, no masses, ascites or
hepatosplenornegaly. Good bowel sounds. No guarding or rebound tenderness.
No pulsatile masses.
Extremities -
Normal No visible deformities, no cyanosis, clubbing of edema. Pulses 4+ and
equal bilaterally.
BacK/Spine Normal - No evidence of scoliosis or kyphosis.
Musculoskeletal Normal - No tenderness or swelling, normal range of motion without obvious
weakness.
Psychiatric Normal -Appears to be well adjusted.
Hematologic/Lymphatic -
Normal No bleeding or bruising. No palpable lymph nodes in supraclavicular,
LABS;
CBC today showed an ANC of 480 Iul. Pit count WNL at 294k. Hgb 11.5g/dL. No evidence of leukemia on blood smear
ANC was 1100 /ul on 1O)Â¥/Â¥i/O
IMPRESSION:
5 year old female with history and labs consistent with chronic benign neuliopenia, currently asymptomatic.
PLAN:
CBC today as above.
RTC in 3 months to recheck CBC or earlier if any neutropenic symptoms, which I reviewed again today with her father.
G-CSF and antibiotics may be necessary if any neutropenic infection occurs Her father will call with any new symptoms.
Electronically s i ~ n e dby: Dr. Scott Myers, M.D.
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Visit Date: Jan 00,2009
Page: 4
They will pursue "common sense" neulrupenic precautions, including good hand washing and avoidance of sick contacts
and large confined crowds (as much as possible).
It is QK for ALM to attend school. ALM father will continue to communicate with her teacher's regarding the
importance of enforcing good hand-washing in the classroom, and trying to keepALM away from sink contacts when
possible.
Note ernaiied to father at michaelhpfeiffer@netscape.net.

ANC called to father cell at 202-4274009.
cc:
Maria L Marquez, M.D.
Tom Rubio, MO
Electronically signed by: Dr Sent* Myers, M.D.
LaShawn - Page 34
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ALM
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EXHIBIT ____
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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?
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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
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ALM
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ALM
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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. ...
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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.
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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
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ALM
ALM
ALM
ALM
ALM
ALM
ALM
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ALM
ALM
ALM
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EXHIBIT ____
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ROY L. MORRIS, ESQ.

! PO Box 100212
! 202 657 5793
! 509 356 2789 (Fax)
! Member of the Bars of the:
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
1
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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.
2
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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 Tel. +49-511-532-9188 Tel. +49-511-532-3288 Tel. +49-511-9411
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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 Tel. +49-511-532-9188 Tel. +49-511-532-3288 Tel. +49-511-9411
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Supporting Attachments Omitted
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EXHIBIT ____
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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-
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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
cc: Police CKLHI Lanier
2
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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
3
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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).
4
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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
5
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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
6
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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
7
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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)
8
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Page 9
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
9
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Updated ANC Chart Including March 12, 2010
Blood Results
LaShawn.LQJY3IHLIIHU&DVH1R)0
- Page 66
5$33
LaShawn - Page 67
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
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68
LaShawn - Page

ALM

ALM

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69
LaShawn - Page

ALM

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70
LaShawn - Page

ALM

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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
LaShawn - Page 72
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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,
LaShawn - Page 75
LaShawn - Page 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.
LaShawn - Page 76
LaShawn - Page 77
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:
LaShawn - Page 77
LaShawn - Page 78
Page 7
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
LaShawn - Page 78
LaShawn - Page 79
Page 8
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
LaShawn - Page 79
LaShawn - Page 80
Page 10
Exhibits
LaShawn - Page 80
LaShawn - Page 81
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LaShawn - Page 81
LaShawn - Page 82
LaShawn - Page 82
LaShawn - Page 83
ALM
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LaShawn - Page 83 /DQLHU*ULVKDP

LaShawn - Page 84
ALM
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LaShawn - Page 85
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"IETROPOLITAN POLICE DEPARTMENT
*** WASHINGTON, D.C.
SEX SUPPLEMENT REPORT SUMMARY
YDSX #: 08-0679
CCN#: UNI'OUNDED 1!or Sexual Abu.e
COMPLAINANTNICTIMI DOB: ............__
EMPLOYER/SCHOOL N/A
ATTENDED:
PARENT/GUARDIAN: • •_ _. . ._ (Father) . . . .
DATEITIME OF OCCURRENCE: Unknown
REPORTING PERSON: _ _• •
OFFENSE: No Crime Coma1tted
LOCATION OF OFFENSE: 4836 Re.ervoir Rd. NW. WDC. 13
ROC/ PSA: 2D
MOBILE CRIME LAB NO: N/A

SOCIAL WORKER Norkia Jack.on 202-48g-7659
HOSPITAL:
REPORTS: 123, ncte.,
WITNESSES: N/A
POLICE PERSONNEL: O.tective Oarryn Robin.on 02-1507 YID

O.tective Robin Blyden 02-14g7 YID
SUSPECT: Michael Pf'eif'f'er WIN 6' 1 190 • • •
/DQLHU*ULVKDP
LaShawn - Page 85
LaShawn - Page 86

Date received: Friday August 14,2008 @ 1730 hrs by Sgt. Torrence
Complaint:
I (mother of C-l ) called the CFSA hotline and reported that she had concerns of C-
l being sexuafl y assaulted by her father.
Interview with Norlda Jackson (CFSA Social Worker) 1730-1800hrs

On Thursday August 14, 2008, the undersigned spoke to Ms. Jackson from CFSA; she was also
assigned to this case. The undersigned met Ms. Jackson at the event location. Once on the scene
we told _ _ as to why we were there. was advised that we needed to
interview C-l to ascertain if she was sate in his care.
Interview with Mr. • (father) 1800-1845hn

On Thursday the undersigned spoke to e
about the allegation. • b provided
the undersigned with several documents that indicated that R-I had made similar reports in the
past. All the reports that provided revealed that the sexual abuse allegation were
Unfounded for sexual abuse. (Montgomery County Maryland & New York City). .
provided documents indicating that he has full custody of C-I.
Interview with C-l 2000-1021hn

On Thursday August 14, 2008, the undersigned called the Child Advocacy Center in efforts to
conduct an emergency interview of Cal. Detective Goldring was notified and he conducted the
forensic interview. C-I was attentive to the interview. The interview was taped. Cal made no
disclosure of any type of abuse.
Interview with Sean O'Connor (Father's Lawyer) 2030-2045

On Thursday August 14, 2008, 5 (lawyer called and informed the undersigned about
all of the allegations that. • has filed. Mr. O'Connor advised that a
is wanted in
Virginia at this time.
Conclusion:
After reviewing several documents that were provided by • 1 It it is highly unlikely that
C-I has been sexually assaulted. C-l was examined by Children's Hospital in New York in June
:W08, the findings were normal.
Disposition:
Based on the facts of the case the undersigned recommends that this case be closed as
Unfounded for sexual abuse
2 /DQLHU*ULVKDP
LaShawn - Page 86
LaShawn - Page 87
Attachment Copy Omitted Here

of August 2008 Lee Schneyer Letter
See, Attachments to May 2009 Letter to CNMC, Supra for Copy
LaShawn - Page 87
LaShawn - Page 88
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LaShawn - Page 88
LaShawn - Page 89
Attachment Copy Omitted Here of

October 2008 Affidavit of Dr. Robert Sklaroff Letter
See, Attachments to May 2009 Letter to CNMC, Supra for Copy
LaShawn - Page 89
FEDEX KINKO'S 0671 PAGE 01
LaShawn - Page 90
The Children's Cancer Foundation

-
Georgetown Department of Pediatrics
Division of Pediatric/Hematology/
University Oncology, Blood and Marrow
Transplantation
Hospital
Lombard! 3800 Reservoir Road, NW
Comprehensive Washington, DC 20007-2113
* Fax: 202 444 8817
Cancer Center Phone: 207- 444 2224
MedStur Health
Patient Name: ALM ALM R

MRN: 6412380
DOB: May 07, ALM
PEDIATRIC HEMATOLOGY-ONCOLOGY CONSULTATION

DATE OF VISIT: Qct 10, 2008
PHYSICIAN: Dr. Scott Myers
PATIENT; ALM R King-pfeffer

MRN: ALM
DATE OF BIRTH:May ALM
PHYSICIAN REQUESTING CONSULTATION: Dr. Marquex
REASON FOR CONSULTATION:

Consult for persistent Neutropenla

ALM is a five year old, healthy female who presents to the hemelonc clinic for a consult regarding her persistent
neutropenia since May of 2008. ALM was seen by her pediatrician on May 2, 2008 for a WCC, and a routine CBC was
performed: WBC 4.6, granulocyte count 26%, ANC 1200, Hb 12, platelets 315. The pediatrician did not find any significant
physical findings at this WCC (only some shotty cervical lymphadenopathy). Prior to this WCC, ALM had been feeling
well, but did have a hx of very mild URi symptoms (clear to yellowish rhinorrhea and intermittent cough) since November
2007. These symptoms never caused her to miss school, she remained energetic (as usual) with a good appetite and she
did not have any fevers, palllor, or abnormal bruisinglbleeding. In light of this slightly decreased ANC of 1200,ALM was
re-evaluated on May 25, 2008, with a CBC at that time showing: WBC 4, granulocyte count 159'0,ANC 600, Hb 10.9,
platelets 346. ALM was still essentially asymptomatic at this time. After this follow-up, Arlana was referred to Dr. Rubio
(ID) on May 30, 2008 for further evaluation, at which time Dr. Rubio believed ALM neutropenia to be secondary to viral
rnyelopsupression(ANC at this time 500).
On June 11, 2008 Adrian8 was hospitalized at Montefiote Medical Center in New York for 'neutropenia', although Dad'
Electronically signed by: Aziza Shad, M.D.
.LQJ
PAGE 02
LaShawn - Page 91

Page: 2
states that this was a 'social admission', as the staff was not comfortable releasing Adriana home with her mother While
at Monteflore, Adriana was tested for EBC, CMV, HIV, Toxo, Parvo and ANA, all of which came back negative. During the
course of this hospital admission, she remained afebrile and asymptomatic, with her ANC ranging from 120 to 373. Her
peripheral smear was WNL. The hemlonc service saw ALM during this admission, and diagnosed her with idiopathic
neutropenia, likely post-viral. She was discharged on June 17, 2008.
initially increased to 880, but again decreased to 560 on Sept 23,2008, ALM father is not overly concerned about her
neutropenia, but she is here today for ia second hemelono consult for 'social reasons1.
ROS negative for fever, abdominal pain, chest pain, shortness of breathlwheezing, rashes, bleedinglbruising, mouth sores,
diarrhea, constipation, urinary problems, or headaches.ALM has no hx of otitis media, UTI's, sinus infections or
pneumonia, mucositis, and her father does not believe that she has ever been on abx.
ALM is currently living with her father in Washington, DC, where she attends kindergarten. She did not reciave he1
immunizations at tho recommended ages but she is currently almost caught up with all of her vaccines.
PAST MEDICAL HISTORY:

Ms ALM medical history consists of birth history - no problems and developmental history
appropriate for age. PMH significant only for derrnatographia.
SOCIAL HISTORY:
Ms Kingpfeiffer is single. Parents divorced -father with custody of ALM
REVIEW OF SYSTEiMS:
Constitutional -
Normal No loss of appetite, weight changes or fatigue; no fever, chills or
sweats.
Allerglc/lmmunologic -
Normal No complaint of allergies.
Head -
Normal No trauma or headaches.
ENMT Abnormal - Clear rhinorrhea present. No hearing impairment, tinnitus or ear pain.
No ulcers, swollen gums, dental problems or change in taste, no sinus pain or
epistaxis,
Eyes -
Normal No visual difficulties. No diplopia.
Neck -
Normal No pain or dysphagia,
Integumentary -
Abnormal Hx of dermographism. No rashes, lesions, inflammation, purpura or
pruitis.
Cardiovascular -
Normal No chest pain or shortness of breath at rest or during exercise.
Respiratory Abnormal - Mild intermittent cough, no dyspnea on exertion, no wheezing
Gastrointestinal -
Normal No nausea, vomiting, diarrhea, GI bleeding, or constipation. .No
Genitourinary (F) -
Normal No abnormal genital masses. No hematuria, hesitancy, incontinence,
vaginal bleeding, discharge or other problems with urination. Normal sexual
function. No frequency, urgency, dysuria, hematuria, bladder or flank pain.
Musculoskeletal -
Normal No fractures, joint pain or back pain.
Neurologic -
Normal No headache, blurred vision, and no areas of focal weakness or
Electronically signed by: Aziza Shad, M.D.
.LQJ
FEDEX KINKO'S 0671 PAGE 03
LaShawn - Page 92
patient Name: ALM ALM

Visit Date: Oct 10,2008
Page! 3
Hematologic/Lymphatic Normal - N o bleeding or easy bruising. No enlarged nodes.
Vital Signs: see Aria
Constitutional Normal -Alert, cooperative, oriented; mood and affect appropriate. Appears
Head -
Normal Normocephallc, atraumatic
Eyes Normal -Conjunctivae and sclerae are clear and without icterus. Puplls are
reactive and equal. Extraocular muscles Intact. Fundi normal.
ENMT -
Abnormal Moderate amount of clear rhinorrhea present. Sinuses are
nontender. No oral exudates, ulcers, thrush or mucositis. Oropharynx clear.
Tongue normal. Good dentition. TM's normal. No fluid
Neck Normal -Supple without masses or thyromegaly, Some shotty, mobile, non-
Integumentary -
Normal No rashes, petechlae or bruises.
Cardiovascular -
Normal Regular rate and rhythm; no murmurs, gallops; rubs or ectopy. Capillary
extremities.
Respiratory -
Normal No tachypnea or nasal flaring. Clear to auscultation bilaterally with good
aeration. No crackles or wheezes.
Abdomen -
Normal Non-tender, non-distended, no masses, ascites or
hepatosplenomeQaly.Good bowel sounds. No guarding or rebound tenderness.
No pulsatile masses,
Extremities -
Normal No visible deformities, no cyanosis, clubbing or edema. Pulses 4+ and
equal bilaterally.
Neurologic -
Normal No sensory or motor deficits, normal cerebellar function, normal gait,
cranial nerves intact. Normal tone and strength In all four extremities. Reflexes
normal.
Hematologic/Lymphatic -
Normal No bleeding or bruising. No palpable lymph nodes in supraclavicular,
IMPRESSION :
Five year old, well-appearingasymptomatic female, with persistent neutropenia since May of 2008. Neutrophill count
trended down to 120 during mid-June, and has recently been trending upward (ANC today 1200). DDX includes
neutropenia secondary to viral myelosupression, chronic benign neutropenia, and cyclic neutropenia (less likley). Severe
congenital neutropenia highly unlikely givenALM asymptomatic presentation and ANC ;> 100. While anti-neutrophil
antfbody was found to be negative, this does not rule out chronic benign etiology (with autoimmune pathophysiology), and
therefore the diagnosis of chronic benign neutropenia remains likely-if neutropenia persists. Dx of cyclic neutropenia
would require hi or trl-weekly CBC's x6 weeks, which are not essential at this point in time. No signs leukemia or other
pathology.
PLAN:
1. LABS
CBC: WBC 4.1; HgbIHct 11.4134; platelet 328. 28% Granulocytes, ANG 1200. Blood smear revlewed--no blasts,
Electronically signer! by: Aziza Shad, M.D.
.LQJ
PAGE 01
KINKO'S
FEDEX 0671
LaShawn - Page 93

Visit Date: Get 10.2008
Page: 4
CMP: Within Normal Limits
2. RTC in 3 months to recheck CBC

-No indication for Neupogen at this time, as child is asymptomatic. If she develops fever or mucosltls, she would need to
be seen immediately for cx'dceftriaxone and possibly Neupogen if ANC is low.
3. Spoke with Dad at length about the importance of bringingALM back to clinic for any signs of fever or Infection or
mucositis. Dad understands this well- He is a physician himself, and is able to recognize the signs of potential infection.
cc :
ALM King-Weiffer family
Tom Rubio, MD
Maria L Marquez, M.O.
Electronically signed by: Aaza Shad, M.O.
.LQJ
LaShawn - Page 94
Division ofPediatric Hematology -

Oncology and BMT
M&&- Gemgetown university ~ o s p i t a l
3800 Reservoir Road, N.W Washington, D.C. 20007 Ttelephone: 202-444-7599
ALM
NAME: ALM
Label as to Contents 0NO

Generic Equivalent May be
DispensedUnless checked 0NU m- ^,
o,,
REFILL; 0 1 2 3 PUN
DOPHO-Bt ( 1 < W ) ADDRESS/OEPT.
.LQJ
LaShawn - Page 95
----- OriginalMessage-----
From: Myers, Scott N <Scott.N.Myers@gunet.georgetown.edu>
To: michaelhpfeiffer@netscape.net <michaelhpfeiffer@netscape.net>
Cc: bethlehem.zewde@dc.gov <bethlehem.zewde@dc.gov>
Sent: Fril 10 Oct 2008 2:43 pm
Subject: AK Letter
Dr PfeiÂ£fer
Per your requestl a letter is attached and CC'd to BZ..
Kind regards, Scott
Scott N. Myersl MDl MPH
Division of Pediatric Hematology/Oncology
Georgetown University Medical Center
3800 Reservoir Rd, NW

Washington, D.C. 20007
Pager: 202-405-3454
Division Phone: 202-444-2224
Division Fax: 202-444-8817
CONFIDENTIAL: The information contai

ned in this communicationl
including its attachments may contain confidential information and is
intended only for the individual (s) or entity (ies) to whom it is
addressed . The information contained in this comunication may also be
protected by legal privilege federal law or other applicable law. If
you are not the intended recipient of this communication you are
hereby notified that any distribution, dissemination or duplication of
this comunication is strictly prohibited. If you have received this
communication in error please immediately delete and destroy all copies
of this message and please immediately notify us of the error by
separate communication . Thank you.

LaShawn - Page 96

April 2008 Affidavit of Dr. Robert Sklaroff Letter
See Attachments to May 2009 Letter to CNMC, Supra for Copy
LaShawn - Page 96
LaShawn - Page 97

April 2009 Affidavit of Dr. Joy Silberg
LaShawn - Page 97
LaShawn - Page 98

April 2009 Letter of Eileen King, Justice for Children
LaShawn - Page 98
LaShawn - Page 99

May 2009 Critique Letter to CNMC with Intake Records and Other Attachments
Please see copy of May 2009 Letter to CNMC, Supra for Copy
LaShawn - Page 99
LaShawn - Page 100
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
"
LaShawn - Page 101
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
#
LaShawn - Page 102
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
$
LaShawn - Page 103
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
%
LaShawn - Page 104
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.
&
LaShawn - Page 105
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.
"!""#$% '())*+, +- ."-+(,$/0+" !1/ 2)3+(/ -+( '041$% 5)$( 6778 ( 91/+:)( ;< 677=
/>(+#?> @)3/),:)( A7< 6778< -(+, BC @)1()/$(D E):40/)F
'
LaShawn - Page 106
LaShawn - Page 106

LaShawn - Page 107

LaShawn - Page 108

LaShawn - Page 109
Attachment Copy Omitted Here

of June 2010 Letters to Councilmember Tommy Wells and Dr. Roque Gerald
See, Supra for Copy
LaShawn - Page 109

LaShawn - Page 110
LaShawn - Page 110

Customer
LaShawn - Page 111
Account Number Bill Period Bill Date
Roy Morris May 27 - Jun 26 Jun 30, 2010 6 of 6
Details, details (continued)...
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LaShawn - Page 112
*** 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

P.O. Box 1606, Washington, D.C. 20013-1606
LaShawn - Page 113
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

LaShawn - Page 114
EXHIBIT ____
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BRIEF STATEMENT OF THE CASE

!
The case below was marred by improprieties of blatant ex parte contacts and by
Court inaction that denied Appellant, Dr. Ariel King, PhD (the “Mother”)1 the most
rudimentary discovery. In particular, the Court arbitrarily refused to consider any filings,
motions, evidence etc. filed by Counsel for the Mother well after counsel entered his
appearance, refused to allow any expert testimony for the Mother, denied the Mother her
right to her criminal counsel in violation of the Fifth Amendment, and allowed the false
calling of the Mother’s counsel as a witness -- without any foundation in the evidence --
for the sole purpose of denying the Mother access to her full time civil and criminal
Counsel. The Court below abused its discretion, and made clear error, and abdicated its
role “parens patriae.”
In the case below, the Mother sought equitable relief in the form of proper
emergency medical evaluation and treatment of her then five-year-old daughter
(“A.L.M.K-P”). To this date her daughter continues to suffer from severe chronic
neutropenia, a very rare blood disorder (2 per million). The condition arose soon after the
Father -- a widely published medical neurology researcher with regards to drugs and
their effects on humans -- received physical custody of the child. Because of the Court’s
failure to take action within its power, the child’s life remains in danger at the hands of
the child’s father, Dr. Pfeiffer, PhD (hereinafter, “Father”) who refuses to press for
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
1
The Mother and Father remain married. A divorce and derivative custody proceeding
is pending in Bayreuth, Germany where the entire family (mother, father and child) is
registered. The Father is a German citizen, the Mother a US Citizen living in Germany,
and the child has dual German and US citizenship.
! 2
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proper diagnosis and treatment.2 Among other things, severe chronic neutropenia can be
caused by various drugs, including psychotropic drugs that are readily available to the
father (who does research in neurology, and who applied but failed to obtain a medical
license in the District of Columbia). Unexplainably unconcerned, for over a year, the
record shows Father took actions that placed the child in unnecessary danger -- including
dictating to a Georgetown Physician medical directions for the child’s school which
intentionally left out precautions that should be observed in the care of the child. To
this day, the condition’s cause remains undiagnosed and an independent evaluation of
the child’s condition remains lacking. The Superior Court below denied the Mother’s
request in an Order issued on December 2, 2009 (See, APP-33), which applied the wrong
standard.
The Court below clearly abused its discretion and made clear error. The Court’s
“parens patriae” responsibility required it to ensure that it has enough evidence before it
to make an informed decision. As in IN RE M.D. L.D., 758 A.2d 27 at ¶38 (DC 2000),
the Mother respectfully requests that this honorable Court reverse and remand the case
for a fair hearing, after the opportunity for an independent medical examination, and
proper discovery to assure there is enough evidence for an informed decision to be made
by the Court below.
STATEMENT OF FACTS
The Mother brought in equity DC Superior Court Case 09 DRB 1167 on April 21,
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
2
Severe neutropenia refers to the lowest white blood count, and making the person
unable to fight normal infections. See, Affidavit of Dr. Robert Sklaroff, to Original
Complaint, APP-20 (All references to the Appendix prepared by Appellant are “APP-
___”) Also, See, Graph of Severe Neutropenia, APP-44. Special precautions must be
followed to protect a neutropenic patient from developing what could become a fatal
infection.
! 3
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LaShawn - Page 118
2009. The Mother sought Court only emergency intervention to secure proper
emergency medical evaluation treatment for her now six-year-old daughter (“A.L.M.K-
P”), who has suffered for almost two years from life-threatening severe chronic
neutropenia of an undiagnosed cause.
The child was healthy and showed no symptoms of life-threatening illnesses until
she started to regularly live in the one bedroom apartment of the Father and began
making disclosures about suspected sexual and physical abuse. However, in a routine
medical exam in May 2008, the child’s blood showed Absolute Neutrophil Count (or
“ANC”) readings in her blood of well below 500 (a child’s normal ANC count is closer
to 3800) , a level that typically requires hospitalization for severe neutropenia. On the
child’s return to school on June 2, 2008 after spending the weekend of May 30, 2008 with
the Father (which is the weekend after the neutropenia was discovered), the child broke
down in school, had accidents in front of others, and begged, in the mother’s presence,
that she did not want to go back to be with her Father.
On advice of the Montgomery County Abused Persons Program counselor, on
June 2, 2008, the Mother, representing herself pro se, with her child was granted a
Temporary Protective Order (TPO). The TPO covered the child for “Statutory Abuse of
a child (Physical, Sexual)(Forward to DSS for Investigation)” and the Mother. The TPO
was issued by Judge Boynton of Montgomery County Maryland (where Mother lived and
the child lived part time and went to school) after she presented evidence of abuse and the
need for protection from the Father for both the child and Mother. The TPO called a full
investigation by CPS of Montgomery County and a Full Protective Hearing on June 9,
2008 -- strongly advising that both parties obtain legal counsel for the hearing. It is
! 4
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important to note that Judge Boynton has been the only Judge who has ever met the child
before making any rulings regarding her safety and welfare.
The Mother then sought medical diagnosis and care for her daughter at one of the
leading children’s hospitals in the US, Montefiore Children’s Hospital in the Bronx, New
York City. The Father, fearful of allowing the process, including investigations (child
sexual abuse and medical harm) had the TPO overturned in an unscheduled ex parte
hearing on June 5, 2008, and, a day later on June 6, 2008, went to a court in Virginia
(where none of the parties lived), in a 20 minute ex parte hearing claiming that the
mother had kidnapped the child and thus he needed to be awarded full physical and legal
custody, and the mother given “no contact,” so that she could me put on the NCIC data
base.
With this unlawful and arbitrary ex parte order in hand, the Father then reported
the child as being kidnapped to the Montgomery County police, and the Mother was
arrested at the child’s bedside at Montefiore Childen’s Hospital, while getting an
evaluation for the Severe Chronic Neutropenia (where ANC had dropped to as low as
120). The Father’s lawyers working with the Montgomery County detective caused a
misstatement of charges in the arrest warrant, claiming a non-parental kidnapping (which
carries a maximum 20 year sentence). Because of the mischarging, the Mother was held
without bail at Rikkers Island prison for almost a month. The maximum penalty for
“parental kidnapping” of less than 30 days is 30 days. After eight months of the case
pending trial, on the day before the trial, the criminal court in Montgomery County
denied the Mother any defenses and use of her expert witnesses. Without any defenses,
the Mother was forced to plead guilty in exchange for no probation or sentence, and
! 5
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avoiding the expense and uncertainty of a trial with no defenses or expert witnesses.
The child was delayed released on June 17, 2008 to the Father on the condition
that the Father take the child to a pediatric hematologist/oncologist to complete the
investigation of the, as yet undetermined, underlying cause of her severe neutropenia.
See, Graph of ANC Readings of the Child, APP-44. The Father was also directed to
take the child for regular psychological care to address her stress disorder and
dissociation.
Months went by, and the Father -- who had legal responsibility for taking care of
the child’s health and medical needs after having received custody of the child3 -- failed
to comply with the Montefore Children’s Hospital directives and, thus, purposely failed
to make any progress in determining the underlying cause of the severe neutropenia.4
During that period the child’s ANC levels remained low at critically severe Neutropenia
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
% The origins of the Virginia June 6, 2008 custody order that the Father claims to
have granted him custody is complex and brings its own set of legal improprieties by a
small family court in Arlington Virginia where no party was residing. It is undisputed
that: the Virginia order that the Court below identifies in its order was granted on an ex
parte basis and at a time the Mother was without legal representation to defend herself,
seek reconsideration or secure an appeal, and when no party was living in Virginia --
thus, it was entered without subject matter jurisdiction. In addition, since the August 5,
2009 hearing, another Virginia custody order -- which has a different ordering clause --
has been surfaced by the Father’s counsel in another proceeding which the Father did not
bring to the court’s attention below. Thus, even though the order in the record below was
marked “final,” due to the Father’s new finding of another order, it would not be a final
order because it was modified -- thus cannot be recognized and registered in the District
of Columbia for enforcement. DC Code §16-4603. However, because custody is not the
issue in the defects in the Virginia case and the non-enforceability of the Virginia Order,
details of that discussion will be omitted here.
& It is generally known that possible underlying causes of Severe Chronic
Neutropenia include cancer drug treatment, toxins or toxic drugs administered to the
child, a genetic disorder, an autoimmune disease (e.g., Lupus), or a virus (like HIV). The
child’s tests have excluded most possible causes of the very rare blood disorder but not
neutropenia cause by toxins. See, Opinion Letter of Dr. Karl Welte, one the world’s
leading expert on pediatric neutropenia. APP-140-143.
! 6
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levels almost the entire time.5 This left the child extremely vulnerable to infection by a
severely compromised immune system (only 15% of its normal capacity).
It was not until October 2008, when the Mother obtained the child’s medical
records to determine whether the Father had followed the medical directives of
Montefiore Children’s Hospital, that she learned what he had failed to do. The Mother
presented a complete medical history of the child (including five years of medical
records) to a Dr. Robert Sklaroff, a 35-year nationally recognized hematologist/
oncologist expert. Upon reviewing all those records, Dr. Sklaroff -- as a mandated
reporter -- filed a verbal and written formal complaint for severe medical neglect with
District of Columbia Child and Family Services Agency (CFSA) in October 2008.
As the direct result of Dr. Sklaroff’s complaint, CFSA intervened and required the
Father to take the child to a hematologist/oncologist. The Father took the child to Dr.
Scott Myers, at Georgetown University Medical Center (GUMC) on October 10, 2008.
Of note, the Father, while employed at GUMC, practiced unlicensed from July 1, 2007 to
June 30, 2008 in the District of Columbia.6 In June 2008, after one year of practicing
without a medical license, he was terminated from the staff of GUMC.
In April 2009, the Mother again obtained updated medical records from the
GUMC. From updated records, the Mother learned that, instead of getting better, the
Severe Chronic Neutropenia had become worse since Fall 2008, (See, Neutropenia
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
' The two times the child showed a briefly raised ANC of 1100 was when the
Father had time to prep the child’s system in advance of the tests -- first when the Father
had delayed the child’s ANC being taken for the DC CFSA in October 2008, and the
second in June 2009 at a visit scheduled by the Father where tests were being made for
later presentation to the court below.
6
The Father failed to receive a regular medical license in Washington DC
because he could not provide to the Medical Board of DC proof that he completed
medical school by providing foreign medical school transcripts
! 7
LaShawn - Page 121
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Graph, at APP-44), and the child had been presented to GUMC with sores on her swollen
lip and in her mouth, as well as lesions on both sides of her groin, prompting another
GUH physician to order a culture taken to test for “infection suspicious onset of
suspected herpes,” a sexually transmitted disease. (See, Affidavit of Dr. Sklaroff at ¶22,
APP-25)
After reviewing the updated medical records that were acquired since the Fall of
2008, Dr. Robert Skarloff, MD -- as a mandated reporter -- filed a second complaint with
CFSA on April 21, 2009 for the continued need for the proper medical evaluation
(specifically bone marrow aspiration) and GCSF medicine treatment for the child. In
his affidavit (See, Affidavit of Dr. Sklaroff (APP-20), attached to Original Complaint,
APP-17), Dr. Sklaroff concluded:
a) It shocks the conscience that these problems and uncertainties persist.
b) It is critical to determine the cause of neutropenia in cases (such as this)
which persist for at least several months:
i. Neutropenia developed between 2006 and May 2008,
ii. Neutropenia continues to persist (per the most recent CBC),
iii. 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,
iv. This work-up often includes examination of the bane marrow,

although to-date this procedure has not been performed.
v. 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
vi. Giving the child a full panel of vaccines when her ANC was
known to be below 1500 risked both compromise of her ability
! 8
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LaShawn - Page 123
to be immunized (as intended) and development of infections.
See, Affidavit of Dr. Robert Sklaroff, Attached to Original

Complaint, at APP-23-24).
In addition, Dr. Joy Silberg, PhD -- another mandated reporter who had reviewed
the medical records and other evidence -- filed a separate complaint with CFSA for
physical neglect and sexual abuse. (See, APP-74; a copy of that affidavit if found in the
record attached to Plaintiff’s Motion to Strike and In Limine, and Expedite Emergency
Hearing, and Request to Call Dr. Joy Silberg, filed June 10, 2009 (“Plaintiff’s Motion to
Strike, etc”) (APP-80)
Justice for Children is a national organization that advocates for children whose
best interest are lost between the failures of child protection systems. The regional
Director, Eileen King, filed a letter and complaint to CFSA on behalf of A.L.M.K-P (a
copy of Ms. Eileen King’s Letter (APP-78) to CFSA is found in the record at Exhibits III
of Plaintiff’s Motion to Strike, filed June 10, 2009).
On April 21, 2009, the Mother, through counsel, filed three pleadings with the
DC Superior Court in the case below (Case No. 09 DRB 1167) that sought emergency
medical attention for A.L.M.K-P:
a. Motion for a Preliminary Injunction ,

b. An Emergency Motion for Temporary Restraining Order, and
c. A Complaint for Negligent Treatment and Injunctive Relief, pursuant to
D.C. Code §16-2301 (24) (“Original Complaint”)
APP-8 – 20.
The Original Complaint and proposed order requested only proper medical
diagnosis and treatment:
Wherefore, the premises considered, the Plaintiff request the Court to

enter an order directing the Defendant to forthwith, make arrangements for
the Child to be taken to: Children's National Hospital, in Washington,
! 9
LaShawn - Page 123
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D.C., by someone other than the Plaintiff, for that hospital to perform a
complete medical examination, on the Child, and for them to diagnosis
and suggest a treatment plan for the Child's Neutropenia and any other
medical malady that they deem requires medical treatment; and issue an
order directing the Defendant to refrain from interfering, in any manner,
during the Child's medical examination.
- (emphasis added) See, Original Complaint at APP-18
No such independent medical examination for the severe chronic neutropenia has
yet to take place or has been ordered.7
On April 22, 2009 and April 23, 2009, the Court below held a preliminary
hearing. At the first hearing on April 22, 2009, the Mother’s Counsel Morris entered a
praecipe for his appearance. See, April 22, 2009 Docket Entry, APP-1. The Mother’s
only other counsel, Mr. Robinson/Mr. Long firm, were newly hired a couple of days
before to prepare and file the Original Complaint, and associated motions.
The Mother had arranged for Dr. Robert Sklaroff (who is located in Pennsylvania)
to come to testify at the April 22 hearing, but Mr. Robinson was advised by the Judge’s
chambers that Dr. Sklaroff need not appear in person, the affidavit was sufficient, and, if
necessary, he could testify by phone.
At the first hearing on April 22, 2009 and again on April 23, 2009, Mr. James P.
Toscano, the General Counsel for DC Child and Family Services Agency (CFSA),
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
7
By its published policy, CFSA takes all child abuse cases to CNMC. However, CFSA
did not do so in this case. Although the child was taken by CFSA to CNMC on April 24,
2009, the CNMC staff was told to limit the physical examination to only sexual abuse,
and not neutropenia. The were also told not to interview the child for sexual abuse. They
were told the neutropenia was being addressed at Georgetown University Hospital where
the father was a former staff member and where the father chose to take the child for the
inadequate diagnosis that led to the filing of the case below. See, Plaintiff’s Motion to
Strike and Limini, filed June 10, 2009 at 8-9 (APP-87-88).
! 10
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appeared in the court -- apparently at the demand of the Father’s counsel.8 CFSA was
not a party to the case, and Mr. Toscano did not appear in response to either a subpoena
or court order.
At the commencement of the hearing on April 23, 2009, the Father’s counsel
claimed he had intended to call the Mother’s long time primary attorney, Counsel Roy
Morris, Esq. as a witness. The Father’s counsel then asked that Counsel Morris be
sequestered. Counsel Morris objected. See, Transcript at 19-21, APP-48-51. The
Father’s counsel did not make any showing that could justify the calling of opposing
counsel as a witness, let alone having him sequestered. The Court denied Counsel
Morris’ objections, and directed Counsel Morris to leave the courtroom -- from which he
was excluded for the remainder of the day -- and yet was never called as a witness by the
Father’s counsel.
The Mother’s Counsel Morris had been at every court proceeding since 2007,
thus he was the only regular, most experienced and knowledgeable counsel for her in the
courtroom that day. His exclusion from the courtroom was damaging. Father’s counsel
used Counsel Morris’ absence as an opportunity to make unchallenged slanderous false
statements about the Mother, and engage in unchallenged questioning of the Mother on
irrelevant non-medical neglect matters, in particular, unrelated criminal and civil matters
of which only Counsel Morris was familiar and in a position to defend the Mother. With
no access to her only long time counsel Morris, the Mother lost her ability to effectively
exercise her Fifth Amendment rights, and raise other knowledgeable objections. The
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
8
Prior to his addressing the Court, Mr. Toscano limited himself to speaking several times
privately with the Father’s counsel, in what sometimes appeared to be a heated
discussion.
! 11
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remaining counsel Robinson/Long -- who were hired only days before -- had no
knowledge of the subject of those matters. The Mother was also forced to disclose
attorney-client privileged communications with Counsel Morris.
After sitting in the courtroom for two days listening to the testimony, Mr. James
P. Toscano on the second day requested, an ex parte meeting with the Judge in her
chambers over the Mother’s counsel’s protests. Counsel Morris -- who was still excluded
from the courtroom -- was the only counsel for the Mother who had directly
communicated with Mr. Toscano, Esq. and had familiarity with the matters relating to
both CFSA and Mr. Toscano. Without Counsel Morris in the courtroom, the Court
granted Mr. Toscano’s request, without the knowledge or input of the Mother’s primary
and most knowledgeable counsel, Counsel Morris. Counsel Robinson clearly stated he
did not know what Mr. Toscano could be possibly speaking to the Judge about and
expressed objections, while the Father’s gave permission without any reservation thereby
suggesting that there had been prior conversations and the Father’s Counsel knew what
Mr. Toscano intended to say to the Court in private:
THE COURT: All right.

MR. O'CONNELL: But here's the --
THE COURT: I'm looking at the person from Child and Family Services. What
are you going to do?
UNIDENTIFIED SPEAKER (Mr. James P. Toscano): Your Honor, I can stay as
long as you need me to or come back tomorrow --
THE COURT: I'm going to try to stay as long as I
can depending on what's happening.
UNIDENTIFIED SPEAKER (Mr. James P. Toscano): Would I have to -- would I
present the Court with the ex parte of this party -- confidentiality?
MR. O'CONNELL: I would do that, Your Honor.
UNIDENTIFIED SPEAKER (Mr. James P. Toscano): I can stay here as long as
you want to.
THE COURT: I mean for purposes of your representations to me, is there any
reason why you couldn't make them now so you could go?
UNIDENTIFIED SPEAKER (Mr. James P. Toscano): I could certainly make
! 12
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LaShawn - Page 127
them if the parties agreed to waive their confidentiality so I can make it as ex

parte to the Court.
MR. ROBINSON: Well, I don't agree to anything ex parte to the Court. I mean
my understanding he was going to make it open to the Court; is that correct: He
said, "Ex parte," Your Honor.
THE COURT: I think it's -- I took it that there was some kind of pending
investigation, and so that would not be something that would be disclosed in open
court.
UNIDENTIFIED SPEAKER (Mr. James P. Toscano): That is correct, Your
Honor.
THE COURT: But it would be disclosed to me based upon a waiver of
confidentiality by the parties.
MR. O'CONNELL: We have no problem with that, Your Honor.
MR. ROBINSON: I do, Your Honor. I don't know what the nature of it is, and I
wouldn't know how to cross-examine if Dr. Pfeiffer took the stand or how to
redirect if I'm given the opportunity. I just don't want to do that, Your Honor.
THE COURT: This would be made to me. It will be made to me and nobody
would be cross-examining me and --
MR. ROBINSON: That's fine, Your Honor. I understand. I do waive. Indulgence,
Your Honor?
THE COURT: And, since I have not the foggiest clue
what it is --
MR. ROBINSON: We waive, Your Honor.
THE COURT: -- it just doesn't make sense for him to sit here. He's been here for
two days.
MR. ROBINSON: I agree, Your Honor, and we waive.
THE COURT: Okay. Come on.
(EX PARTE CONFERENCE)
(Thereupon, the proceedings were reconvened.)
-- Transcript Aril 23, 2009 at 30-33 (APP-51-53)
After the private meeting with Mr. Toscano, the Court stated that Mr. Toscano
said in private that, among other things, that the CFSA investigation would be the
following Monday, April 27, 2009.
THE COURT: That's the way it is. I do what that to be clear though. The only
other information that I will receive is I will receive the final evaluation from Child
Protective Services as a result of their investigation, which is supposed to be closed and
results known by Monday.
MR. ROBINSON: Your Honor, are those results going to be made available to us
or just to the Court?
THE COURT: Well, what the counsel said to me is that if it is not founded, there
is no written report and they aren't required to do a written report by law.
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MR. ROBINSON: I understand.

THE COURT: And, so it really just depends on what the results are, and I don't
know what the results will be.
MR. ROBINSON: Your Honor, could I just -- and I'm not going to elongate it. I
just want to make it clear. I am not requesting any particular procedure at all, and my
client has not requested any particular procedure. All we've requested is, is that the
Children's Hospital get the records and do whatever.
See, Excerpts of April 23, 2009 Hearing Transcript at 56, See, APP-59.)
The Court then refused to consider Dr. Sklaroff’s affidavit without his testimony
which could have been taken that day by phone -- since he had not traveled for the
hearing from Pennsylvania because the Mother’s counsel had been told by the Court
previously he did not have to appear.9 The Court insisted that he travel to Washington
DC to appear at a future hearing in person. The Court also stated that the Father could
call his “expert” witness from Georgetown University Medical Center (Dr. Scott Myers)
at that future hearing. The Court set the next hearing date for May 22, 2009. (See,
Excerpt of April 23, 2009 Hearing Transcript, APP-58-66).
The Father’s Counsel voiced his opposition to Dr. Sklaroff’s advocacy of the
standard test of a “bone marrow aspiration” (BMA) as “reckless” and to “drill a hole in
the child’s pelvis” (Transcript of Aril 23, 2009 Hearing at 53-54, APP-56-57). The
Father’s Counsel further proclaimed that he wanted to depose Dr. Sklaroff before the next
hearing. The Court responded that:
If you want to depose him, I'm not going to stand in your

way from doing it.
See, Transcript of April 23, 2009 at 53-54,

APP-56-57
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
9
DC Code §16-4601.10; Taking testimony by telephone in another State being explicitly
permitted.
! 14
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After notices were sent out for the May 22, 2009 emergency hearing, the Mother
flew back from Germany to the USA to attend that hearing. Within days the court clerk
called to say that a vacation day was scheduled for May 22, 2009 and that it had been that
way since the beginning of the year. The Judge’s clerk requested that the next
“emergency” hearing be postponed another three months to August 5, 2009.10
On May 13, 2009, the Father filed a Motion file late file his counterclaims, one
day after the May 12, 2009 deadline for filing a response to the complaint. According to
the Docket, the Father’s Answer to the Complaint was also late filed on May 13, 2009,
but the Father did not file a motion to file his answer late.
On May 22, 2009, Appellant’s Counsel Morris filed his second notice of
appearance with the Court. (See, Praecipe: Entry of Appearance, filed May 22, 2009,
APP-67)
On May 27, 2009, the Mother’s other counsel, Wendell Robinson and Leonard
Long (who work together) filed a Motion to Withdraw and a Motion for Extension of
Time because “the services of Counsel (Robinson and Long) are no longer needed..” and
that Counsel Morris would remain and handle the case alone from that point onward.
(See, Motion to Withdraw and Motion for Extension of Time, attached hereto at APP-69
and 72.)
On June 10, 2009, on the Mother’s behalf, the Mother’s Counsel Morris filed a
Motion to Strike and In Limine and Expedite Emergency Hearing and Request to Call
Dr. Joy Silberg As An Expert Witness. The Motion sought to strike all references in the
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
10
Days before the hearing, Plaintiff’s Counsel Morris received a call from the Judge’s
Chambers informing him that there was a vacation day previously scheduled for May 22,
2009 so the hearing would be rescheduled for August 5, 2009. The docket mistakenly
lists postponement as being by counsel’s agreement.
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proceeding to the CFSA investigation and bar their further introduction because, as
demonstrated through documentation provided by CFSA and the Children’s National
Medical Center, the CFSA investigation referred to by James Toscano in his ex parte
meeting was irrelevant to issue of medical neglect, it failed to comply with CFSA
policies, and only involved a deeply flawed, investigation of sexual abuse --- not medical
neglect. (See, June 10, 2009 Motion to Strike and In Limine and Expedite Emergency
Hearing and Request to Call Dr. Joy Silberg As An Expert Witness, at APP-80)
On June 16 and 17, 2009, the Mother served subpoenas for depositions duces
tecum on the Father, and the four Georgetown University Medical Center (GUMC)
Physicians, including Dr. Scott Myers, who were involved in the treatment of the child.
See, Appellant’s Notice of Discovery filed July 2, 2009, APP-97.
On June 23, 2009, the Father’s Counsel filed Motions to Quash the subpoenas of
the Father and the physicians at GUH, including Dr. Scott Myers. The Mother filed
oppositions to those motions on July 2, and July 14, 2009, respectively pointing out that
the Court specifically gave the approval for deposition discovery prior to the upcoming
hearing. The Court did not rule on the Father’s Motions to Quash prior to the August 5,
2009 hearing, effectively granting them and denying the Mother any discovery.11
On June 26, 2009, after a separate complaint was filed with the Washington DC
Board of Medicine for failing to comply with medical standards of practice and with the
child’s condition worsening (her ANC dropped to 470), Dr. Scott Myers notes finally
came to agree with Dr. Sklarloff’s recommendation, and the Mother’s initial request to
the court (April 2009) to have the child given the standard investigation of a bone
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
11
The filing of a Motion to Quash automatically stays the discovery under the Court’s
rules. SCR Dom.Rel. §26(c).
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marrow aspiration test (BMA)12. See, GUH Medical Report of June 26, 2009, APP-93.
On July 2, 2009, Child and Family Services Agency (CFSA) attempted to file
under seal, a Motion opposing the Mother’s intent to depose and request document
discovery on CFSA. In that Motion, CFSA made many false factual allegations against
the Mother that CFSA had apparently obtained from the Father and his counsel. CFSA
intentionally did not serve the Mother’s counsel a copy of that Motion, nor did CFSA file
a separate Motion to file under seal. The Mother’s Counsel learned about the illicit
filing by chance when he made a routine check with the court clerk, and, then, the
Mother’s Counsel filed a timely opposition to the CFSA Motion. The Court did not rule
on CFSA’s Motion to Quash prior to the August 5, 2009 hearing, effectively granting
them and denying the Mother discovery. SCR Dom.Rel. §26(c)).
On July 2, 2009, the Mother served a subpoena for a deposition duces tecum of
the person at CFSA who it designated as the most knowledgeable of the investigations
relating to the child. CFSA filed a Motion to Quash that subpoena as well, and the
Mother filed a timely Opposition to said motion. The Court did not rule on CFSA’s
Motions to Quash prior to the August 5, 2009 hearing, effectively granting CFSA’s
Motion and denying the Mother her right to discovery. SCR Dom.Rel. §26(c)). Also, see,
August 5, 2009 Hearing Transcript at 13-16, (where the Court summarily granted the
CFSA Motion to Quash, APP-112-114))
On July 1, 2009, the Mother served a document discovery request on Father and
requested a meeting to discuss any concerns Father’s counsel might have regarding that
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
12
The BMA is a standard test for unexplainable Neutropenia, and had been
recommended to Appellee by the first pediatric hematologist/oncologist one year before
(June 2008) but the records fail to indicate he disclosed this information to the GUH
physician’s attention.
! 17
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request. The Father did not timely respond. On August 4, 2009, the Mother filed a
Motion to Compel responses to those discovery requests. The Court did not rule on the
Mother’s Motion to Compel prior to the August 5, 2009 hearing, and thus effectively
denied the Mother’s right to discovery. SCR Dom.Rel. §26(c)).
In a July 24, 2009 letter to the Court, the Mother’s Counsel reminded the Court of
the need for a timely ruling on these outstanding discovery matters prior to the August 5,
2009 hearing. See, Letter of Roy Morris, Esq. to Court, July 24, 2009, APP-97.
The August 5, 2009 Hearing

At the August 5, 2009 hearing, the Mother once again traveled from Germany to
attend the hearing to seek medical relief for her daughter.
At the beginning of the hearing the Court stated in open court that it would
disregard any filings made on the Mother’s behalf by the Mothers only counsel, Counsel
Morris, prior to August 5, 2009 hearing because, the Court did not yet recognized him as
“primary counsel.” The Court refused to acknowledge the praecipes for Entry of
Appearance Counsel Morris, filed on April 22, 2009, and again on May 22, 2009, all of
which were listed in the Docket and contained in the court file:
“as (far as) I'm concerned, you've not had any authority to do anything
until right this minute when I accept your praecipe.”
See, August 5, 2009 Transcript at 11-12, APP-110-112.
Also at the hearing, the Court granted the CFSA Motion to Quash Appellant’s
subpoena without allowing any discussion, See August 5, 2009 Transcript at 13-16,
APP-112-114. The Court denied all discovery requests because of her refusal to
recognize anything filed by Counsel Morris. See, August 5, 2009 Transcript at 11-12,
APP-110-112.
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Also at that hearing, the Court refused to allow Dr. Sklaroff to testify as an expert
on hematology/oncology, despite his extensive experience of over 35 years, and the
presentation of his credentials both orally and through his resume. The Court did not
dispute his expertise in hematology/oncology, however, the Court claimed he had not
demonstrated an expertise in the particular age group of six year olds. The Court drew
this conclusion even though Dr. Sklaroff testified that based on his own experience and
knowledge of the medical literature there was no material difference between the
diagnosis and treatment of severe chronic neutropenia for a six year old and an adult.
The Court admitting it independently knew nothing about the topic to enable it to know if
there were a difference. See, August 5, 2009 Hearing Transcript at 38-43 (APP-121-126)
At the beginning of the hearing on August 5, 2009, the Mother’s Counsel Morris
informed the Court that, in addition to Dr. Sklaroff, two other expert witnesses were
present to testify, Dr. Joy Silberg (a psychologist) and Don Lehew (a handwriting expert).
In preparation for their testimony, the Court sequestered them, yet the Court later refused
to allow the Mother to call those expert witnesses to the stand. See, August 5, 2009
Transcript at 19-20, APP-118-119.
The Lower Court’s Rulings

After several months, the Court issued a written order on December 2, 2009, in
which the Court attempted to justify refusing to provide relief, as requested by Mother.
The Court Order oddly reads and is formatted more as an advocacy piece written by and
for the Father -- rather than the child -- containing gratuitous dicta and irrelevant findings
that had little to do with the question before the court.
Although the Court cites as the source for its standard of analysis In Re MD, in
! 19
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fact, it ignores the actual holding of that case -- namely that the Court has a “parens
patriae” responsibility to ensure that it has enough evidence before it to make an informed
decision. This is illustrated by the Court’s admission:
“[i]ndeed, the Court Record is filled with attachments and exhibits, that were
Submitted by the Plaintiff that have not been considered by the Court, since they
are not part of the evidentiary record as produced and received by the Court
during the evidentiary hearings in April and August 2009.”
- Court Order at note 11 (APP-42-43)
Such an approach of disregarding evidence without valid reason is antithetical to
the Court’s “parens patriae” responsibility.
At some points the Court’s order is simply incoherent and nonsensical. For
example, it described the Mother as having filed a “Petition for Custody” to the
Montgomery County Court that was “dismissed” at a “scheduled” hearing on June 5,
2008, and described this event as “subsequent” to a June 6, 2008 order of the Virginia
Court. As a threshold matter, June 5, 2008 occurs before June 6, 2008. In addition, as
described above, the Mother had only sought and received a TPO on June 2, 2009, and
not a “Petition for Custody” from that Court. Moreover, the TPO had not been
“dismissed” on the merits, but instead quashed by another Judge at an unscheduled
hearing called by the Father’s counsel days before the scheduled hearing on the merits on
June 9, 2009. None of the Court’s observations are supported by the cited “Defendant’s
Exhibit 3.”13 It should also be noted that the Mother and child appeared before Judge
Boynton on June 2, 2008, where he determined that there was clear and convincing
evidence of sexual abuse, physical abuse and neglect neglect by the Father and stalking
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
13
It should be noted that the June 5, 2008 Order of Judge Craven -- upon which the Court
relies -- is currently under appellate review before the Court of Special Appeals of
Maryland. King v. Pfeiffer, Case No. 1007, September Term, 2009.
! 20
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of the Mother, and it was his findings that caused the issuance of the TPO, with the only
scheduled hearing to be held on June 9, 2008 -- after a full child abuse and medical
neglect / harm investigation by the Montgomery County “DSS” (their CPS). That
investigation and hearing was blocked by the Father’s Counsel’s unilaterally causing an
unscheduled ex parte hearing on June 5, 2008 before Judge Craven, before the June 9,
2008 scheduled hearing, and without the Mother or her yet-to-be appointed legal counsel
from the abused persons’ House of Ruth, or her witnesses who were not prepared to
appear until June 9, 2008. Finally, the quashing of that order in Maryland is subject to a
pending appeal -- a fact also not noted in the Court’s Order.
Other illustrations include the Court Order’s erroneous claim that the CFSA
investigations were “initiated by the Plaintiff.” In fact, they were all initiated in writing
by the very experts that the Court refused to allow testify -- Dr. Joy Silberg and Dr.
Robert Sklaroff. Nothing in the record supports the Court’s observations.
Furthermore, the Court order did not address her denial of all discovery by the
Mother, including discovery of CFSA and the child’s physician. The Court Order did
not explain why it denied Mother’s Motion to Quash Evidence Relating to the CFSA
Investigation.
Finally, the Court gave no reasons in its written order why it refused to allow the
Mother’s remaining two experts, Dr. Joy Silberg (Shephard Pratt Hospital) and Don
Lehew (hand writing expert) to testify. It also failed to explain why it would not let Dr.
Sklaroff testify as to a hematologist/oncology expert for at least the narrow issue of
explaining the nature of neutropenia. The Court’s order is filled with medical facts and
claims that are not supported by any expert testimony and the Court cites to no authorities
! 21
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for its medical knowledge.14
The Court concluded that Washington DC is the child’s home state -- but this is
irrelevant to the issue of obtaining medical help for the child and not in any way
developed by any sworn testimony as it was not an issue in the proceeding. The Order
also claims that child has been asymptomatic, however, there is no evidence in the record
to support that other than the Father’s claims as no discovery was allowed.15
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
14
The Father presented no expert witnesses. Certainly, Mr. Toscano, Esq. who had an ex
parte meeting, has not expertise in the field either. The Father, a neurology researcher,
has no demonstrated expertise in the field. The only witness that could have enlightened
the Court as an expert was Dr. Skarloff, and the Court -- which admitted it knew nothing
about the matter -- refused to allow him to testify.
15
The asymptomatic claims in the medical reports of the GUH doctor are always based
on the “Father reports that.” In addition, in a number of medical reports the child was
indicated with sores, lesions, fevers, and regularly afflicted with mucosis. Dr. Sklaroff
noted much of this in his affidavit, making the need for his testimony for a properly
informed court more important.
! 22
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EXHIBIT ____
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I.
Parties
1. Plaintiff is a US Citizen who lives in Germany at Grossweiglareuth 4a, D-95473
Creussen, Germany. Plaintiff and her husband, Dr. Michael Pfeiffer, are the parents of a
now six year old German –American child (hereinafter, “ALM”), who lives with her German
citizen father, Dr. Michael Pfeiffer, in Washington DC.
2. The District is the government for the District of Columbia and is in possession and/or
control of the records that Plaintiff seeks. In particular, Plaintiff seeks records from any and
all District offices responsive to the requests described more fully below. The District is
responsible for all of the acts and omissions of the CFSA and its employees and agents
described in this Complaint because, among other reasons, the CFSA are entities of the
District.
II.
Jurisdiction and Venue
3. This Court may exercise jurisdiction and venue over Defendant generally in accordance with
the DC Freedom Of Information Act (FOIA). In particular, this Court may exercise
jurisdiction over Defendant, and this entire matter, in accordance with, among other statutory
provisions, D.C. CODE ANN. §§ 2-532(e) and 2-537(a)(l). Plaintiff satisfied all filing
prerequisites prior to filing this action in accordance with D.C. CODE ANN. §§ 2-532(e) and
2-537(a)(l).
III.
Factual Background
4. ALM began suffering from life threatening severe Chronic neutropenia soon after she began
living with her father in Washington, DC in the Spring of 2008.
5. Neutropenia describes the medical condition where the number of neutrophils in the blood is
too low. Neutrophils are very important in defending the body against bacterial infections and
therefore, a patient with too few neutrophils is more susceptible to bacterial infections. The
ANC level is a measure of the neutrophils (Low, Moderate and Severe). Severe neutropenia
is when the ANC falls below 500 per mm3 (0.5 x 109/l). The lower the neutrophils and the
greater the duration, the more likely for fatal infection or sepsis and death.
#
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6. A child can acquire severe neutropenia by the administration of drugs.
7. During August and October of 2008, CFSA received oral and/or written complaints about
concerns of sexual abuse and medical neglect of ALM by Dr. Michael H. Pfeiffer. (See, King
APP-28) [All exhibit pages designated as “King APP - (page number)”]
8. At the request of the CFSA, the father took ALM for the first time to a
hematologist/oncologist of his choosing at Georgetown University Hospital.
9. CFSA’s standard protocol states that children involved with abuse are taken by CFSA
personnel for evaluation to Children’s National Medical Center (CNMC) for examination.
10. On or about October 10, 2008, Dr. Scott Myers of Georgetown University Hospital emailed
medical information to Bethlehem Zewde of CFSA and the father (See, King APP-52)
11. On or about April 21, 2009, CFSA received from Dr. Joy Silberg, a PHD psychologist from
Shephard Pratt Health Systems, a written and oral complaint about sexual abuse and medical
neglect of ALM by Dr. Michael H. Pfeiffer. (See, King APP-30)
12. On or about April 21, 2009, CFSA received from Dr. Robert Sklaroff, M.D., a
hematologist/oncologist a written and oral complaint about medical neglect of ALM by Dr.
Michael Pfeiffer. (See, King APP-41)
13. On or about April 21, 2009, CFSA received from Eileen King of Justice for Children a
written letter of concern about sexual abuse and medical neglect by Dr. Michael Pfeiffer.
(See, King APP-49)
14. On April 21, 2009, CFSA commenced an investigation as a result of the complaints and/or
letters of concern of Dr. Joy Silberg, Dr. Robert Sklaroff, and Eileen King (hereinafter the
“Investigation”)
15. On April 21, 2009, Kersten Magnuson, a CFSA Social Worker, disclosed CFSA’s
preliminary findings of that Investigation, including the identity of the child, in a hand written
note she provided to Dr. Michael Pfeiffer and/or his attorney, Sean O’Connell. (See, King
APP-53)
16. On April 22, 2009 and April 23, 2009, CFSA’s General Counsel, James Toscano, Esq
appeared in the courtroom of DC Superior Court where the case, King v. Pfeiffer, Case No.
09 DRB 1167, was being heard.
$
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17. CFSA was never was a party to Case 09 DRB 1167.
18. On April 22 and 23, 2009, Mr. Joseph Toscano, Esq. disclosed information about the
investigation in the court.
19. Upon information and belief, neither Mr. James Toscano’s appearance in the Courtroom of
Case 09DRB1167, or his disclosures of information about the Investigation, were at the
direction of an order issued by any court, or at the direction of any subpoena issued by either
party to that case.
20. On April 24, 2009, Kersten Magnuson of CFSA accompanied Dr. Michael Pfeiffer and ALM
to the Children’s National Medical Center (CNMC) (“CNMC Visit”)
21. Ms. Magnuson disclosed to Dr. Michael Pfeiffer information about the Investigation in the
course of their joint visit to CNMC visit (“CNMC Visit”) (See, King APP-54)
22. The CNMC staff informed the father, Dr. Michael Pfeiffer, that he should seek regular and
prolonged therapy for ALM .
23. Dr. Pfeiffer was informed by CNMC and/or Ms. Magnuson that ALM received a DSM
diagnosis of 308.3 which is Post Traumatic Stress Disorder (PTSD).
24. On or about May 12, 2009, Kersten Magnuson authored a letter directed to Dr. Michael
Herbert Pfeiffer that set forth information about the Investigation (“Magneson Memo”) (See,
King APP-56).
25. On or about May 14, 2009 at approximately 7:03 pm, the Magnuson Memo was faxed from
the CFSA offices to either Dr. Pfeiffer and/or his attorney Mr. O’Connell.
26. On or about June 8, 2009, Cheryl Williams, MD, authored and caused to be faxed a
memorandum directed to Georgetown University Hospital, Lombardi Cancer Center for
Children seeking information for, and also disclosing information about, the Investigation
(“Williams Memo”) (See, King APP-57)
27. The Williams Memo disclosed the identity of ALM to Georgetown University Hospital.
28. Cheryl Williams, MD is the Deputy Medical Director of CFSA, and is also a member of the
Board of Medicine of Washington DC.
29. On the evening of June 8, 2009 medical records were faxed from Lombardi Cancer Center for
Children, Dr Scott Myers, MD to the CFSA offices. (See, King APP-61)
%
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III
FOIA Requests to CFSA and Appeals to the Office of the Mayor
30. On or about October 10, 2009, Plaintiff, through her attorney, submitted a FOIA request with
the CFSA requesting:
Pursuant to the DC Code, on behalf of my client Dr. Ariel King, I request copies of all
documentation -- including those in committed to paper, videos, recording, electronic
files, or information recorded on any media -- relating to Dr. King’s daughter, ALM
and/or Dr Ariel R. King (Grossweiglareuth 4a, D-
95473 Creussen, Germany).
The term “documentation” as used here includes, but is not be limited to, all written
communications, such as emails, faxes (outgoing and/or incoming), telephone records,
interoffice and/or intra-office memos, interoffice and/or intra-office emails, letters
received and/or sent.
The term communications includes but is not limited to, those communications with any
member of the DC City Council and the Mayor’s office, any of their staffs,
communications with child protective service agencies of other jurisdictions,
communications with any courts, communications with any person at Georgetown
University Hospital, Medstar, Children’s National Medical Center, or any other –
psychological or medical office or facility, communications with any law inforcement or
judicial officer, communications with Dr. Michael Pfeiffer, and/or Mr. Sean O’Connell,
communications with Dr. Roque Gerald and/or Bethlehem Zewde and/or Pamela Hodge,
and/or James Toscano, and/or Cheryl Williams, and/or Darynn Robinson. and/or Kirsten
Magnuson and/or any other personnel.
See, Exhibits at King APP-1
31. On October 15, 2009, Ms. Dianne Hall-Simpson, FOIA Officer for CFSA, responded stating:
Dear Mr. Morris, please be advised that FOIA requests are for public information
only. Child abuse and neglect records are confidential and are not available for
inspection or disclosure D.C. Official Code Section 4 -1405 (c). Your client is
entitled to a copy of the investigation summary regarding this child which has
already been provided.
See, Exhibits at King APP-4
32. On October 18, 2009, the FOIA request was supplemented with a request for the location for
viewing the public file of all letters of denial authored by CFSA, pursuant to DC Rule 413.2
(Each agency shall maintain a file, open to the public, which shall contain copies of all letters
of denial) (hereinafter “FOIA 413.2 Public Rejection Letter File”). (See, King APP-2)
33. On October 19, 2009, CFSA acknowledged receipt of the FOIA request. (See, King APP-6)
&
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34. On November 4, 2009, CFSA stated it needed an extension because of the voluminous
number of files they needed to go through. (See, King APP-8)
35. On November 19, 2009, CFSA denied in full, the entire FOIA request. (See, King APP-10)
36. On November 30, 3009, CFSA stated in an email that it was forwarding correspondence for a
date and time for viewing the FOIA 413.2 Public Rejection Letter File (See, King APP-13 -
14)
37. CFSA did not forward any information to Plaintiff regarding the location and times allowed
for viewing the FOIA 413.2 Public Rejection Letter File.
38. On December 13, 2009, Plaintiff, through counsel, sought administrative appeal to the Office
of the Mayor of the wholesale denial of her FOIA request. (See, King APP-15)
39. On January 4, 2010, Plaintiff, through counsel, sent a reminder letter to the Office of the
Mayor, stating that the due date had passed. (See, King APP-20)
40. On January 20, 2010, the Office of the Mayor issued a letter opinion -- for different reasons --
denying in whole Plaintiff’s FOIA request, claiming:
Section 4-1303.06 qualifies as a withholding statute under Exemption 6 of the

DC FOIA. Section 4-1303.06 clearly states: "Information acquired by staff of the
Social Rehabilitation Administration of the Department of Human Services 1
which identifies individual children reported as or found to be abused or
neglected ... shall be considered confidential . . .. " This statute gives "no
discretion" as to whether the material can be disclosed; rather, the material
"shall" be confidential and remain undisclosed. Accordingly, we UPHOLD the
decision of CFSA and hereby DISMISS your Appeal.
(See, King APP-21)
41. On January 21, 2010, Plaintiff’s counsel wrote to Ms. Anthony of the Office of the Mayor,
and reminding her that no Vaughn index had been received, nor any copies of the
correspondence she refers to from CFSA to the Office of the Mayor. (See, King APP-24)
42. On January 22, 2010, Plaintiff’s counsel wrote again to Ms. Anthony in the Office of the
Mayor and pointed out that Dr. Gerald and Ms. Magnuson had disclosed information, and
therefore the prohibition could not be applied as broadly as they claim in their denial, and
they should reconsider their decision by January 27, 2009. (See, King APP-23)
43. Upon information and belief, from the period August 2008 through January 2010, CFSA has
received information about the Investigations from, and provided information about the
'
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Investigations to, Plaintiff, her attorney, Dr. Pfeiffer (the child’s father) and his attorney, Sean
O’Connell.
44. Upon information and belief, the “FACES” data information system of CFSA and other files
within CFSA and the District of Columbia contain information about the Investigation.
45. Upon information and belief, one or more CFSA employees have disclosed the identity of
ALM on one or more occasions to individuals who are not employees of CFSA.
46. Upon information and belief, one or more CFSA employees have disclosed information about
the Investigation on one or more occasions to individuals who are not employees of CFSA.
47. Defendant has not produced a Vaughn index.
48. Defendant has not claimed or substantiated that the child’s name and/or other identifying
information cannot be reasonably redacted from the documents for production.
49. Defendant has not produced any documents relating to ALM.
50. Defendant has not produced any documents relating to Plaintiff.
51. As of January 28, 2010, the Defendant has not produced any documents in response to the
FOIA Request.
52. As of January 28, 2010, the Defendant has not informed Plaintiff of the location where the
FOIA 413.2 Public Rejection Letter File may be viewed and when it is available to be
viewed.
Count I
Violation of the DC FOIA
- Request for Declaratory Relief -
53. Paragraphs 1-52 of this Complaint are incorporated fully herein.
54. Plaintiff has a legal right of access to all health and academic records of ALM.
55. Plaintiff is entitled to all of the records that it has requested from Defendant by and through
the Freedom of Information Act (FOIA) Request (including access to the FOIA 413.2 Public
Rejection Letter File), in accordance with the DC FOIA. Further, Plaintiff is entitled under
the DC FOIA to receive a timely, complete and non-obstructive response from Defendant
regarding the FOIA Request.
56. Defendant has improperly and willfully denied Plaintiff full access to public records and/or
(
LaShawn - Page 144
LaShawn - Page 145
improperly delayed in responding to Plaintiffs request for access to public records. These
actions are in violation of the DC FOIA.
57. D.C. CODE ANN. §§ 2-532(e) and 2-537(a)(l) provide, in relevant part, that Plaintiff is
entitled to seek this Court's intervention based upon Defendant's actions and the status of the
FOIA Request at this time. Defendant has acknowledged the applicability of these statutory
provisions. Pursuant to the terms of these statutory provisions, and the statements in
Defendant's correspondence outlined above, or lack thereof (incorporated herein by
reference), Defendant has denied the FOIA Request for purposes of this Complaint. Thus,
there exists an actual controversy of a practicable and justifiable issue between Plaintiff and
Defendant within the jurisdiction of this Court involving the rights and obligations of the
parties under the DC FOIA, which controversy may be determined by a declaratory judgment
of this Court.
58. Plaintiff has exhausted her administrative remedies.
59. Plaintiff has a statutory right to the records and information she seeks, and there is no legal
basis for Defendant's refusal and/or failure to adequately search for and disclose this material.
WHEREFORE, Plaintiff respectfully requests:
i. That this Court declare that Defendant's failure to adequately respond to the FOIA
Requests submitted by Plaintiff is unlawful; and
ii. That this Court award to Plaintiff its attorneys' fees and costs associated with this
action in accordance with D.C. CODE ANN. § 2-537(c), and such other further relief the
Court deems appropriate.
Count II
Violation of the DC FOIA
- Request for Injunctive Relief -
60. Paragraphs 1-59 of this Complaint are incorporated fully herein.
61. Plaintiff is entitled to all of the records that she has requested from Defendant by and through
the FOIA Requests in accordance with the DC FOIA. Further, Plaintiff is entitled under the
DC FOIA to receive timely and complete responses from Defendant regarding the FOIA
Request.
)
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Failure of Washington DC Child Protection (CFSA) Dr. Roque Gerald to Protect 7-yr Ariana-Leilani King-Pfeiffer from Drugging, Sex Use, Abuse, Drug-Induced and Untreated Life-threatening Illness - LaShawn Court Monitor Lettter With Attachments

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Failure of Washington DC Child Protection (CFSA) Dr. Roque Gerald to Protect 7-yr Ariana-Leilani King-Pfeiffer from Drugging, Sex Use, Abuse, Drug-Induced and Untreated Life-threatening Illness - LaShawn Court Monitor Lettter With Attachments

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ROY L. MORRIS, ESQ.

September 17, 2010

Judith W. Meltzer, Deputy Director

Re: LaShawn v Fenty, Case 89-1754

Dear Ms. Meltzer,

Children’s National Medical Center (CNMC), no independent investigation, protection, or

cian, was never followed up by CFSA.

An independent medical and psychological examination, with proper remedial medica-

Marcia Robinson Lowry, Children’s Rights

Richard Love, Senior Assistant Attorney General

ROY L. MORRIS, ESQ.

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

Diagnosis and Treatment of Traumatized and Dissociative Children, Bergen Norway,

Trauma-Informed Care: Lessons Learned in Protecting Children In Family Court,

Assessing Allegations of Abuse, DV LEAP Conference, George Washington Law

The Treatment of Traumatized Children and Adolescents, Workshop in Assen,

Custody Evaluation in Cases Involving Violence, half day workshop sponsored

Assessment and Treatment of Traumatized and Dissociative Children, Maryland

Child Abuse and Domestic Violence for Custody Cases: Presentation to

Treatment of Dissociative Cliildren, Invited Workshop, National Sexual Abuse

A Developmental Perspective on the Treatment of Childhood and Adolescent

Complex Management of Complex Tra-umain Children and Adolescents, Silberg

The Assessment and Treatment of Traumatized Children, International Family