Defend Foster Mom's Civil Rights

I. Background Introduction

II. The Case in Federal Court

III. The Forged Court Orders

IV. Pursuit of Justice

I. BACKGROUND INTRODUCTION

A loving mother of 4 young children and a licensed foster mother and pillar in her community was brutally attacked by a corrupt county system. Her four young children were unlawfully taken away by corrupt Pennsylvania authorities in retaliation for a whistleblower complaint she made to protect unrelated children. The county employees have abused their authority to cover up their crimes and she needs your help.

She is fighting for her civil rights in federal court and needs your help to fight a broken system. Her evidence is overwhelming, but she has limited finances.

Please, we must all stand together when civil rights are violated.

II. THE CASE IN FEDERAL COURT (excerpts from pro se complaint):

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

HADASSAH FEINBERG, individually, and :

as exclusive guardian and natural mother of :

E.F.; E.F; and A.F., and the exclusive guardian :

and adoptive mother of B.F., :

Plaintiffs :

v. :

DAUPHIN COUNTY SOCIAL SERVICES :

FOR CHILDREN AND YOUTH; COUNTY :

OF DAUPHIN; PENNSYLVANIA :

DEPARTMENT OF HUMAN SERVICES; :

VALERIE ARKOOSH; GEORGE P. :

HARTWICK, III; GABI WILLIAMS; CARRIE :

SELF; SALLY LUPINI; KENNETH W. :

KELLER; SCOTT SMITH; MARISA :

MCCLELLAN; RANDI YEAGER; ALLISON :

VAJDIC; MARCIE SMITH; AMANDA :

OZENBAUGH; LISA WHEELER; SHAPREE :

RANSON; NOELLE BARRETT; KIM :

DEIBLER; LEE ANN TARASI; :

PENN STATE HEALTH MILTON S. :

HERSHEY MEDICAL CENTER; KATHRYN :

CROWELL, M.D.; RYAN SPOTTS, M.D; :

MARC A. SCARINGI; ROBERT A. MARTIN; :

ADAM (A.J.) YOUNG; PAIGE KULSA; :

TAMARA B. WILLIS; ANDREA MARTIN, :

SUSQUEHANNA TOWNSHIP SCHOOL :

DISTRICT and SUSQUEHANNA TOWNSHIP, :

Defendants :

JURY TRIAL DEMANDED

"Plaintiff Hadassah Feinberg…owned her home located at 3807 Bonnyview Road, Harrisburg, PA 17109. Her current physical address has been redacted from the official public record by a Florida Court.

Plaintiff Hadassah Feinberg is, primarily, the mother of the four minor Plaintiffs.

Plaintiff was a licensed foster adoptive mother in Dauphin County from 2020 until April 2023. She has continued to receive funding as an adoptive mother contracting with Dauphin County, Pennsylvania through the present. She relocated to Cumberland County, Pennsylvania, then to Penney Farms, Florida, as a result of the events set forth herein.

Plaintiff was also a Guest Teacher (K through 12) for several central Pennsylvania schools from 2019 until 2023 when she and her family relocated to Cumberland County, Pennsylvania as a result of the events set forth herein.

From 2017 until 2019 Plaintiff was a certified and credentialed counselor at T.W. Ponessa and Associates Mental Health Counseling in Harrisburg, Pennsylvania.

In 2015 Plaintiff worked at the Pennsylvania State Police Headquarters, Harrisburg, Pennsylvania, as a Legal Assistant II for the PICS Unit.

From 2014 until 2016 Plaintiff worked as a KinderCare Group Supervisor in Early Childhood Education.

In 2014 Plaintiff worked as an Office Administrator for Harrisburg Area Community College Security Department.

In 2012 Plaintiff was Active Duty 92 A U.S. Army, Basic Training Fort Sill, Oklahoma, and she received Advanced Individual Training at Fort Lee, Virginia.

From 2017-2024 Plaintiff received Applied Behavior Analysis and Child Abuse trainings and certifications. These certifications included non-physical restraint techniques.

In 2017 Plaintiff received a Bachelor of Science in Criminal Justice from Central Penn College, Enola, Cumberland County, Pennsylvania, with emphasis on family law, forensic

investigations and criminal justice; she was admitted to the Phi Theta Kappa honor society.

In 2015 Plaintiff received her Associates in Criminal Justice from Harrisburg Area Community College; she graduated Magna Cum Laude.

Plaintiff Hadassah Feinberg’s performance at each of the above-referenced positions and/or tasks was and has been exemplary.

Plaintiff Hadassah Feinberg has been a law-abiding citizen all her life and is known in the community as an advocate for children in need and for victims of crime.

Plaintiff Hadassah Feinberg is known in her community to be a wonderful mother who always prioritizes every need of her children and has had sole and exclusive custody of her four children since their births.

On October 12, 2023, Plaintiff was contacted by a member of her community concerning the children of Defendant Marcie Smith, who Plaintiff had known most of her life; Plaintiff was told that Marcie Smith was homeless and that CYS took her children.

Upon information and belief, the Smith children had been unaccounted for and/or missing.

At the time the children were found they were unclothed and/or unkempt, soiled in feces, and showed signs of being undernourished.

Harrisburg Police Officer Ribec released the children to Plaintiff after being asked to do so by Marcie Smith.

Plaintiff had no official responsibility for the welfare of the Smith children as an adoptive or foster parent and voluntarily agreed to take custody while Marcie Smith attempted to work out her situation.

While bathing the children that evening Plaintiff noticed bruises and other apparent injury marks on some of the Smith children.

Plaintiff immediately emailed Defendant McClellan and other CYS personnel to inform them what she had observed.

At all times while Plaintiff Hadassah Feinberg made these numerous contacts she was mindful of the past issues concerning 1) the Pennsylvania Department of Human Services’ placement of the license of Dauphin County CYS into probationary status due to falling to meet Pennsylvania best practice standards, 2) the events leading to the tragic death of nine-year old Jarrod Tutko in Harrisburg, 3) the recent finding of liability against Adams County CYS in the death of a minor foster child, and 4) the sudden death of another foster care baby with Dauphin County CYS .

During the afternoon of October 13, 2023, Lori Teeter from the Commonsense Adoption Agency sent Plaintiff an email warning her that CYS was known to “bristle” at any intervention by perceived outsiders. Plaintiff also reported the suspected abuse to Child Line.

Plaintiff contacted UPMC Express Care who advised Plaintiff to take the Smith children to the UPMC Harrisburg emergency room for child abuse evaluations.

Plaintiff took three of the Smith children to the UPMC Harrisburg emergency room for evaluation.

The Smith children were diagnosed with “Suspected child abuse” by the attending Physician Assistant, Alyssa Schatz. Alyssa Schatz also made a ChildLine and police report.

On October 16, 2023, Plaintiff met with Defendant Marcie Smith, three of her children, and four CYS personnel including Amanda Ozenbaugh, Shapree Ransom and two others.

During the meeting Marcie Smith signed over custody of her children voluntarily to CYS.

Defendants Amanda Ozenbaugh and Shapree Ranson of CYS informed Plaintiff that they would work with her in keeping temporary, wholly voluntary, custody of the Smith children and would provide services through Families United, another private adoption service agency.

Plaintiff informed them that she was already working with PA Mentor with Kristin Rocourt and had preference with their agency.

The well-established customary practice of CYS is to work with the adoption and foster care service of the adoptive parent’s choosing.

Further, Plaintiff had a prior unsatisfactory dealing with Families United.

Vajdic responded by telling Plaintiff that no funding would be provided if she did not agree to work with Families United and left when Plaintiff expressed her preference again for PA Mentor.

Upon information and belief, Vajdic’s threatened removal of any funding for Plaintiff was motivated by CYS’ financial interest in its relationship with Families United.

Plaintiff immediately made a complaint to the Pennsylvania Office of Children and Youth Services, U.S. Representative Scott Perry, Pennsylvania Governor Josh Shapiro and other law enforcement personnel, public servants, and elected representatives.

On October 17, 2023, Plaintiff took three of the Smith children to Hershey Medical for an abuse evaluation and additional medical concerns.

Plaintiff showed Crowell the discharge paper from UPMC diagnosing the Smith children with suspected abuse.

Crowell snatched the UPMC discharge paper from Plaintiff and did not return it.

On October 13 and October 16, 2023 Plaintiff reported the misfeasance, malfeasance, and/or nonfeasance of the CYS Defendants to appropriate public officials; two days later CYS, through Defendant Scott Smith initiated an investigation on Oct 18, regarding a bed one of the minor Plaintiffs slept in, called the Super Sleeper 200, for which Plaintiff had a prescription that she offered Defendant Scott Smith the opportunity to view, and was viewed by Defendant Scott Smith on October 13, 2023, when Plaintiff showed Smith around her home, and he took photographs on his phone of the bruising and markings on the Smith children and told Plaintiff he would investigate.

During the tour of her home Plaintiff had pointed out a safety sleeper-bed (Safety Sleeper 200) prescribed by Defendant Ryan Spotts, M.D. for one of her children, A.F., who suffers from several physical and mental disabilities.

On October 18, 2023, Scott Smith submitted his own General Protective Service referral against Plaintiff and her children alleging that Plaintiff was restraining A.F. in a zipped tent-bed (the prescribed Safety Sleeper 200).

Smith arrived at Plaintiffs’ home to make an inquiry about the prescription bed that he had previously seen.

On October 19 and October 20, 2023 Defendant Scott Smith appeared at various times at the Feinberg Plaintiff childrens’ schools, seized them from their classes without supervision of any kind or notice to the Plaintiff Hadassah Feinberg, and made inquiry of the Plaintiff children about the safety sleeper-bed prescribed for A.F..

On October 19 and 20, 2023 Defendant Scott Smith went to the Plaintiff Feinberg childrens’ schools and with no actual or apparent authority, he demanded to see the children, seized them from their classes, and talked with no one present about the bed and other harassing things.

Smith told Plaintiff Hadassah Feinberg’s disabled child, Plaintiff A.F., that he will be taken from mommy and that he is bad.

At two of the schools Defendant Smith refused to even allow a witness to accompany the Plaintiff Feinberg children during the meeting, even after being informed that the children were fearful of Smith.

Plaintiff’s children, E.F., E.F., A.F., and B.F., came home from school in a panic over the contacts Defendant Scott Smith made with them at the school.

During the evening of October 19, 2023, Plaintiff A.F. was transported to the emergency room at UPMC Harrisburg Hospital where A.F.’s anxiety medication was increased to deal with the trauma.

On October 20, 2023 Leah Booker from UGRO, the daycare for B.F., called Plaintiff and told her that Defendant Scott Smith refused to wait for police to arrive to witness Smith’s meeting with A.F..

On October 20, 2023, Defendant (Police Officer) A.J. Young threatened Plaintiff Hadassah Feinberg with charges for child endangerment.

On October 23, 2023, Plaintiff had a meeting with Defendant Kenneth W. Keller, an agent of the FBI Washington, D.C. region, Manassas, Virginia office.

The meeting between Plaintiff and Defendant Keller lasted three hours during which Plaintiff reported the physical condition of the Smith children, the “Suspected child abuse” diagnosis by Alyssa Schatz at UPMC Harrisburg Hospital, the timeline reflecting all of the above, and specifically that CYS was retaliating against her and is moving into what Plaintiff considered an abduction of her children.

On October 25, 2023, Defendant Carrie Self of Pennsylvania OCYF visited Plaintiff and discussed the matters concerning the Smith children and the retaliation she was experiencing; Defendant Self specifically affirmed that Plaintiff Hadassah Feinberg’s complaints on October 13 and 16, 2023 preceded the apparent dependency investigation commenced against the Plaintiffs.

Plaintiff handed Defendant Self a copy of the prescription for the medically necessary bed in which A.F. slept, and always without incident.

On October 26, 2023, Plaintiff filed a Petition for Review against almost all of the CYS Defendants, and others, in the Commonwealth Court of Pennsylvania for the retaliation and abuse of Plaintiffs’ family and the emotional upset it was causing them.

Shortly after Plaintiff dropped Plaintiff A.F. off at the Sara Lindemuth Elementary school in Susquehanna Township, Defendant A.J. Young made a traffic stop of Plaintiff.

Defendant Young wrote a citation for a stop sign violation at a location a stop sign did not exist; Young pulled behind Plaintiff from the right when she was well-past the only stop sign in the area and pulled her over in an area where there was no stop sign.

Plaintiff contacted her mother who came to the scene to witness the absence of any observable stop sign at the location on the citation written by Defendant Young.

The charge was later dismissed by Susquehanna Township Magistrate Judge Urrutia after Plaintiff informed her of Defendant Young’s harassment and stalking as well as the retaliation against her.

Plaintiff Hadassah Feinberg began regular and extensive communications with Defendant Susquehanna Township Police Chief Robert Martin about submitting a report against Defendant Young for his stalking and harassment, and about getting assistance with the retaliation she was suffering.

Plaintiff had remained in contact with all her childrens’ schools throughout this period, prior to Defendant Scott Smith seizing Plaintiff B.F. while he was at school, and over the Plaintiff mother’s directions and objections.

Plaintiff then again contacted the Susquehanna Township School District including the Superintendent of Schools, Defendant Tamara B. Willis, and Sara Lindemuth Elementary Principal, Defendant Andrea Martin, again directing that her children were not to be permitted to be alone with Defendant Scott Smith or any other CYS or law enforcement personnel.

Plaintiff also received an email from Defendant Susquehanna Township Superintendent, Defendant Willis, informing her that the district’s legal team (identities unknown) has opined that CYS can access her children without her consent, without a witness, and over her express objection to both.

On November 2, 2023, with no dependency petition pending concerning the Plaintiffs, Dauphin County Court of Common Pleas Judge John J. McNally allegedly held an ex parte meeting, believed to include Defendant’s McClellan and Wheeler, and apparently gave them a “verbal order” that allowed them to seize the Plaintiffs E.F., E.F., A.F., and B.F., apparently wherever they could find them.

The unsigned Dependency Petition is stamped November 3, 2023, at 1:34 p.m. by the Dauphin County Clerk of Courts, Wherein Defendants McClellan and Wheeler stated that there was no evidence of abuse of the Smith children and that the medically prescribed bed for A.F. was not in compliance with Plaintiff Hadassah Feinberg’s best practices for her children.

Three of the Plaintiffs, E.F., E.F, and B.F., were seized from their schools by unknown CYS personnel on November 3, 2023.

Upon information and belief, there are no valid court orders for the removal of Plaintiffs E.F., E.F. and B.F. from Plaintiff’s custody care and control.

During a November 3, 2023, meeting between Plaintiff, Otstott, and Defendant Tarasi, Defendant Wheeler arrived to seize Plaintiff A.F. directly from the arms of Plaintiff mother Hadassah Feinberg.

Plaintiff A.F. left in a total panic with Defendant Wheeler.

Plaintiff asked Defendant Tarasi to take needed medication to her children; Tarasi refused.

At the CYS building after being seized, Plaintiffs E.F., E.F, A.F., and B.F. were locked by Defendants Wheeler, Smith and perhaps others, into separate rooms in the CYS building.

While Plaintiff A.F. was locked away in a panic, he threw papers and other things around the room and pulled the fire alarm to get attention and, when Defendant Scott Smith went into the room, Plaintiff A.F. punched Smith in the stomach.

Two of the Plaintiff children, E.F. and E.F., were placed with strangers in York County, Plaintiff B.F. was placed in Cumberland County and Plaintiff A.F. was placed with Plaintiff Hadassah Feinberg’s brother in Dauphin County, and was placed with him because no other available foster parents were equipped to deal with A.F.’s disabilities.

Plaintiff was informed by her brother that he was directed to report any attempts by Plaintiff to contact her children to CYS when she arrived at his residence to deliver A.F.’s needed medication.

The foster parents for two of her children, including Plaintiff’s brother, reported to CYS and Plaintiff that the children were not getting their medication.

Five days after B.F. was seized from the Plaintiff he developed a high fever from being deprived of his prescribed medication.

On Nov 3, Plaintiff immediately thereafter filed a hand-written Emergency Petition with the Cumberland County Court of Common Pleas regarding the seizure of her children.

On November 6, 2023, Plaintiff appeared in Judge McNally’s courtroom per the November 3, 2023 scheduling order with CYS representatives there.

The parties went back to Judge McNally’s Chambers to discuss the matters and Plaintiff agreed that the dependency matter should be transferred to the Cumberland County Court of Common Pleas, which it then was.

On November 6, 2023, Judge McNally transferred the Dependency Petition against Plaintiff to Cumberland County, where the Plaintiffs had officially relocated.

Cumberland County CYS caseworker Sandy Gibson was assigned to the case.

Plaintiff filed a response to the Dependency Petition together with her supporting evidentiary documentation with the Cumberland County Clerk of Court on November 8, 2023.

During a hearing in Cumberland County Court on November 8, 2023 Defendant Wheeler testified falsely under oath when she denied there was any evidence of abuse of the Smith children, and that Plaintiff Hadassah posed a risk to A.F. concerning the medically prescribed bed for A.F..

In response to prompting from Plaintiff, Cumberland County Judge Edward Guido directed Defendant Wheeler to permit A.F. to attend school in Cumberland County, which Wheeler was refusing to permit, keeping A.F. out of school since November 3, 2023.

On November 13, 2023, Defendant Gabi Williams sent a letter on behalf of Pennsylvania OCYF to Plaintiff saying Plaintiff’s reports of abuse of the Smith children and retaliation by CYS were unfounded.

On November 15, 2023, Cumberland County CYS asked the Court to dismiss the case against Plaintiff.

On November 16, 2023 the Cumberland County Court dismissed the dependency case transferred from Dauphin County.

On November 16, 2023, the Court of Common Pleas of Cumberland County dismissed the Dependency Petition against Plaintiff as unfounded, and the children were returned to her custody the next day.

Plaintiffs’ collective protected interest in the care, protection and familial bond of their relationship was completely interfered with and severed for thirteen days.

The Plaintiffs were reunited the same day.

Count 1 alleges a civil rights conspiracy to damage and injure the Plaintiffs in retaliation for her protected First Amendment activities.

Count 2 alleges unlawful seizure of the minor Plaintiffs without a valid court order and locking them away in separate rooms at CYS.

Counts 3 & 4 allege harassment, stalking, assault and battery upon Plaintiffs.

Count 5 alleges intentional infliction of emotional distress...

The loss to E.F., E.F., A.F. and B.F. includes educational issues they suffered, the gripping fear by they feel in general, and specifically concerning displays of authority, and the emotional and physical suffering of Plaintiff A.F.. whose disability was deliberately used as, not only the basis upon which the attack against Plaintiff but was used against him personally through abuse by some of the Defendant adults directed at him personally, and using his suffering from anxiety and withdrawal as a device and weapon to punish his mother.

Plaintiff E.F. additionally suffered personal injury when she bumped her head when try to avoid being abducted by the CYS Defendants.

Plaintiff Hadassah Feinberg additionally suffered provable physical medical injuries as a result of all of the foregoing."

III. THE FORGED COURT ORDERS

1. they are not time stamped by the court,

2. the handwriting of the case numbers is different, and

3. they contain CYS file numbers in the bottom right corner.

IV. THE PURSUIT OF JUSTICE

Hadassah Feinberg fled the corruption and retaliation from Pennsylvania law enforcement and CYS, with her children, to Florida and continued fighting in Court, as a pro se litigant.

Harris Legal Group is committed to seeking justice in this case, and it will require court reporters at depositions along with experts and resources that the Plaintiff victims do not possess.

Your help, however big or small, is greatly appreciated and will be used 100% in the fight for justice.