Post on 03-Jun-2018
8/12/2019 Rebuttal to defendant Lisa Rambo's motion to dismiss
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In the United States District Courtfor the Middle District of Georgia
Macon Division
Dr. Sharon Cross, et alia ))
plaintiffs in propria persona ) ) Civil action file number:v. )
) :!"#cv#$$$$%#C&' )
(isa 'ambo, et alia )) ur* +rial Demanded
defendants ))
___________________________________________________________________________________
Plaintiffs' rebuttal to defendant Lisa Rambo's motion to dismiss ___________________________________________________________________________________
laintiffs hereb* rebut defendant and ublic +rustee (isa 'ambo-s motion to dismiss this civil
action against her. laintiffs all five of them) have an interest in the ublic +rust and have the
fundamental right to remed* breaches thereof b* the named +rustee as /ell as to redress in order to
ma0e plaintiffs all five of them) once again /hole. & +rustee liabilit* for breach of the +rust is
personal no immunit* for defendant 'ambo) in character /ith all the conse1uences and incidents of
personal liabilit* and is enforceable against her estate. Defendant 'ambo claims to be a udge
therefore is also a +rustee b* /a* of provisions at &rticle 2I of the Constitution. Defendant 'ambo
/as a +rustee in the capacit* of a udge according to defendant 'ambo and her attorne*) at all times
during the instant matter.
laintiffs- statement of facts at paragraphs 3!, 34, and 35 /ithin the complaint /ere not rebutted
b* defendant 'ambo or her attorne* thus stand as undisputed fact before this Court.
+here is no evidence before this court to support the assertion that defendant 'ambo did not
breach the duties of a +rustee for the ublic +rust to the confirmed in6ur* of plaintiffs.
age ! of !%
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7o evidence has been presented to this Court to indicate that defendant 'ambo did not order
that plaintiffs- son 8.C. be sei9ed: absent a la/ful /arrant, /ithout probable cause, /ithout e igent or
emergenc* circumstances, absent imminent danger to 8.C., /ithout parental consent .
7o evidence has been presented to this Court to indicate that defendant 'ambo did not order plaintiffs- medical records to be sei9ed and searched: absent a /arrant, /ithout probable cause, /ithout
e igent circumstances, absent imminent danger to 8.C., /ithout parental consent .
Defendant 'ambo-s motion to dismiss relies e clusivel* upon the defense of 6udicial immunit*
buttressed b* the false assertion that in bringing and prosecuting this suit the plaintiffs, in their proper
persons and as beneficiaries of the ublic trust, are someho/ in violation of the (a/ of the (and.
laintiffs read the assertions that the* are someho/ in violation of the (a/ as a deliberate and
malicious attempt to intimidate and stop plaintiffs from proceeding for/ard /ith this meritorious case
as it is their obligation and inalienable right to do given the gross violations suffered b* the plaintiffs as
a result of defendant 'ambo-s breach of +rust. ;+here can be no sanction or penalt* imposed upon one
because of his e ercise of Constitutional rights.; Sherar v. Cullen, 481 F 2d 946 (1973)
No Immunity for a Trustee which has breached the Trust
to manifest injury of beneficiary
& +rustee liabilit* for breach of the +rust is personal no immunit* for defendant and +rustee
(isa 'ambo) in character /ith all the conse1uences and incidents of personal liabilit* and is
enforceable against her estate.
The Juvenile Court is not authori ed by or!anic Law
+here is no evidence in this Court indicating that the legally created uvenile Court is
authori9ed b* the (a/ e pressed at the Georgia Constitution. 7o evidence has been presented to
support the assertion that the Georgia legislature is authori9ed to legislate a 6udicial office into
e istence.
age 4 of !%
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7o evidence e ists to support the assertion that the Georgia 6udiciar* is la/full* authori9ed to
install appoint) a udge /ithin a legislativel* born e the eople settlors) and beneficiaries of the
ublic +rust have authori9ed the +rustees of one branch of government to create another branch of
government.
+here is no evidence supporting the assertion that defendants 'ambo, ?idson, @urt are not
utili9ing and enforcing private ;polic*; to substantial in6ur* of plaintiffs. laintiffs have seen of this
before: ;@e has combined /ith others to sub6ect us to a 6urisdiction foreign to our constitution, and
unac0no/ledged b* our la/s= giving his assent to their &cts of pretended (egislation=; &e'lara%i n
nde#enden'e *uly 4, 1776.
+here is no evidence to support the assertion that hearsa* is not at all times allo/ed as evidence
/ithin the uvenile Court.
+here is no evidence to suggest that standards s*mboli9ing the 6urisdiction of an organic Court
such as the 8ederal and State flags in addition to the Great Seal of Georgia e ist or have ever e isted in
the uvenile Court.
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+here has been no evidence presented to this Court that an* (a/full* authori9ed Court can
den* the accused the abilit* to confront his accuser. ;It is the dut* of the courts to be /atchful for the
constitutional rights of the citi9en, against an* stealth* encroachments thereon.; + yd v. ".S., 116 "S
616, 63!, (188!)29. ;+he 6udicial branch has onl* one dut* # to la* the &rticle of the Constitution/hich is involved beside the statute /hich is challenged and to decide /hether the latter s1uares /ith
the former...the onl* po/er it the Court) has...is the po/er of 6udgment.; ".S. v. +u%ler, 297"S(1936)
+here is no evidence /ithin this Court to support the assertion that the uvenile Court is not an
administrative entit* administering statutes appearing completel* at odds /ith the Constitution.
+here is no evidence in this Court to support the assertion that defendant 'ambo is not an
administrator of statutes.
+here is no evidence that defendant 'ambo-s uvenile Court is not primaril* a place of business
profiting her, the attorne*s hired to defend against her ;court orders;, and the prosecuting attorne*s
representing D8CS.
+here is no evidence before this Court in support of the assertion that defendant 'ambo is not
involved in barratr*.
+here is no evidence before the Court that 8.C. /as not sei9ed for the purpose of coercing his
famil* to parta0e in ;services; provided b* and profitable to the ;D? &'+M?7+;, U2?7I(?
C
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e isted #ri r to sei9ing 8.C. and prior to the ;probable cause hearing;.
+here is no evidence before this Court that defendant 'ambo has not violated her fiduciar*
duties as a +rustee to the beneficiar* plaintiffs in the instant matter.
+here is no evidence before this Court that defendant 'ambo has not e ceeded her la/fulauthorit*.
+here is no evidence before this Court that defendant 'ambo has not abused her official po/ers
to manifest in6ur* to the plaintiffs.
+here is no evidence before this Court that defendant 'ambo has not deprived plaintiffs of at
least "th, th, and %th &mendment rights inter alia.
+here is no evidence before this Court that defendant 'ambo has not enabled a false /itness to
provide hearsa* and baseless assertion /hich /ould be inadmissible e cept for e ceedingl* rare
circumstance) in a Court provisioned b* the Constitution.
+here is no evidence before this Court that defendant 'ambo did not fail to protect plaintiffs
from malicious and bad faith medical ;reporters;.
+here is no evidence before this Court that defendant 'ambo is not primaril* responsible for
8.C.-s ph*sical /rist in6ur*.
+here is no evidence before this Court that defendant 'ambo and defendant @urt have not
coerced under pains of plaintiffs- son being again unreasonabl* sei9ed) plaintiffs to sign documents, to
cooperate /ith a D? &'+M?7+ entit*, and to attend ;immuni9ation; class.
+here is no evidence before this Court that defendant 'ambo has not terrori9ed the plaintiffs
and their e tended famil* /hile economicall* benefiting from her treacher* and ma*hem at the
e pense of the public purse.
laintiffs direct the Court to defendant 'ambo-s affidavit /ithin document "%. Defendant
'ambo freel* admits that she collaborated /ith defendant ?idson to effect the unreasonable sei9ure of
age of !%
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8.C. +he sei9ure is evidenced as unreasonable for the follo/ing: !. Defendant 'ambo indicates that the
communication bet/een her and defendant ?idson had to do /ith, ; an e$ergen% si%ua%i n alleged
de#riva%i n a $in r 'hild ;. ?mergent is not evidence of ;e igenc*; +he ;alleged deprivation of a
minor child; does not evidence 6ustification for a reasonable sei9ure.4. ; #aren%s.... ere re using % all %heir 'hild % be i$$uni-ed r %e%anus, hi'h a'' rding % %he
%rea%ing #hysi'ian and h s#i%al s%a as ne'essary #ri r % $edi'al %rea%$en% %he 'hild.;
+here is no evidence before this Court to support the assertion that refusal to ;immuni9e for
tetanus; presents probable, logical, or reasonable cause or special e igenc* to sei9e an*one at an*time.
8or the record, plaintiffs never once refused to ;allo/ their child to be immuni9ed for tetanus;.
laintiffs refused to provide consent and /ere unable to provide informed consent for the
administration of a single tetanus ;vaccine; to 8.C.
+here is no evidence before this Court that tetanus ;immuni9ation; /as essential #ri r to
medical treatment surger*).
laintiffs are not a/are of an*one ever being forced to receive a tetanus vaccine against their
/ill.
laintiffs point out that 8.C. received surger* and at least % hours later /as force vaccinated
e periencing no ill effects as a result of not being vaccinated prior to surger*.
Defendant 'ambo-s affidavit does not evidence that she received a second or third opinion on
this point /hich plaintiffs perceive as being rec0less and neglectful.
Defendant 'ambo does not indicate if it /as revealed to her that there /as a high probabilit* or
an* probabilit* that 8.C. had been e posed to tetanus bacteria.
+here is no evidence before the Court to corroborate that 4 B of ;children; suffering from
tetanus infections die. ; % as e$#hasi-ed % $e %ha% %he 'hild s ell/being re0uired %he %e%anus
va''ina%i n and %ha% %he need as vi%ally i$# r%an%, i n % 'ri%i'al.
age 6 16
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+here is no evidence before this Court that Defendant 'ambo did not order this sei9ure based
upon uncorroborated, unconfirmed, and unsupported testimon* from anon*mous sources. ;In conte t
of a sei9ure of a child b* the State during an abuse investigation...a court order is the e1uivalent of a
/arrant.; ennenbau$ v. illia$s, 193 F.3d !81, 652 (2nd Cir. 1999. F. . v. a dis%ri'% C ur% r l C unr%, d.
+he
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Defendant 'ambo freel* admitted on December !4th 4$!4, ; %his en% n r h urs hursday a %ern n
and hursday nigh%. d n % n h $any 'alls g % ab u% %his.;
It /as not enough to have had information as per 'ambo-s affidavit) that 8.C. /as in some
form of alleged serious danger. ;+he 8ourth &mendment itself spells out the evidence re1uired for a/arrant or entr* order. 7o /arrant shall issue but on probable cause. +he United States Supreme
Court has held that courts ma* not use a different standard other than probable cause for the issuance of
such orders.; ri in v. is' nsin, 483 ".S. 868 (1987).
Defendant 'ambo asserted in her affidavit that she had 8.C. sei9ed based upon ;human concern;
/hich reads to plaintiffs as meaning ;personal feelings;. ersonal feelings are distinctl* different than
the much more e acting and rigorous ;probable cause;. Defendant 'ambo also asserts to have relied
upon the facts given to her, /hich have been evidenced as to be grossl* inade1uate insofar as to
establish probable cause .
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indefinitel*.
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critical or necessar* #ri r to surger*.
+here is no evidence in this Court that surger* for 8.C. /as not dela*ed as a result of defendant
Cartie or an* other medical) punishing plaintiffs for not follo/ing his medical recommendations.
+he plaintiffs /ill point out that /hile defendant Cartie and defendant 'ambo bandied about a4 B chance of death in the event of a tetanus infection, neither part* bothered to ascertain the incident
rate of tetanus. >hat good is a mortalit* rate /ithout an incident rate##the chances of d*ing from a
blac0 mamba bite are AAB, but the chances of receiving a blac0 mamba bite in this countr* are nearl*
none istent. Shall /e all stoc0 blac0 mamba anti#venomE In the case of tetanus, the actual mortalit*
rate is alleged to be closer to !!B per CDC) rather than the 4 B utili9ed b* defendants 'ambo and
Cartie.
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further ph*sical in6ur* to his /rist) /hile in the care of defendants &lbritton and arr. +his does not
evidence ;human concern.; Defendant 'ambo did not evidence concerns for 8.C. or the plaintiffs-
rights /hen she ordered him unreasonabl* sei9ed, nor did she have concerns for their rights /hen she
ordered 8.C.-s medical records to be unreasonabl* and unnecessaril* sei9ed and searched.laintiffs as0 this Court to consider that defendant ?idson /as appointed b* the attorne*
general. +he attorne* general no/ represents defendants and social /or0ers arr and &lbritton /ithin
this civil action. +his Court should 0no/ that the Governor of Georgia, 7athan Deal, /as at one time a
6uvenile 6udge and has been made /ell a/are of plaintiffs- deprivation of rights b* the plaintiffs
themselves. In Georgia and in the e perience of these plaintiffs, attorne*s /ithin our government
appear to have little problem /ith the unreasonable sei9ing of %her people-s sons and daughters. +his
is /hat state actor ;immunit*; from prosecution delivers to our societ*: anarch*, t*rann*, rampant
abuse, unaccountabilit*, and e ponentiall* increasing miser* for families as their inalienable rights are
needlessl* deprived b* unaccountable state actors .
Plaintiffs are not attorneys
In regards to document "% and at page 4, plaintiffs hereb* rebut the statement, ; Plaintiff "ann
#layden Cross and Plaintiff #haron $arvey Cross% both non&lawyers% are re resentin! their three
children in this court action( ; &s e ecutors of the estate of /hich plaintiffs- sons are part), plaintiffs
Dann and Sharon Cross have ever* right to act according the best interests of their estate....and there is
nothing in the supreme (a/ of the (and or an* positive la/ implementing it /hich bars plaintiffs from
doing so, 8'C 'ules not/ithstanding. If defendant 'ambo asserts to the contrar*, let her cite the
specific &rticle, Section, and Clause of the supreme (a/ of the (and or an* positive la/ implementing
the same /hich supports such claim of authorit*. &dditionall*, since /hen and b* /hat legitimate
authorit* has the ublic +rust been set aside b* or subordinated to mere corporation ;public polic*; as
is e pressed in various federal and state codes such as the cop*righted
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laintiffs freel* admit that their sons 8.C., D.C., and '.C. are not remunerating plaintiffs Dann
and Sharon Cross. +herefore, plaintiffs Dann and Sharon Cross are not ;practicing; la/ for hire.
8urthermore= a license b* definition) is permission to do something or not do something) that is
other/ise illegal to do or not do). Since /hen and b* /hat authorit* is the e ercise of plaintiffs-parental) 'ights made an ;illegal; activit*E
Defendant 'ambo brings to fore
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is *et another and currentl* inescapable conflict of interest. &lso consider that the plaintiffs are suing
at least three &' attorne*s that have /ell demonstrated their participation and inclination to deprive
plaintiffs- of their inalienable rights thus ma0ing the hiring of a &' attorne* *et another conflict of
interest. ;(ac0 of counsel of choice can be conceivabl* even /orse than no counsel at all, or of havingto accept counsel beholden to one-s adversar*.; +urge%% v. e;as, 389 "S 159
8urthermore, plaintiffs hereb* command defendant 'ambo and the currentl* unverified
;licensed to practice la/ for hire and profit attorne*; 7eSmith to substantiate his claims that plaintiffs
have committed an* crime /hatsoever at an* time and that plaintiffs, as beneficiaries of the ublic
+rust, are not properl* before this Court.
"efendant Rambo and )r( Ne#mith has thre e days
*from the date of this document's submission+
to une,uivocally rove to this Court and to these laintiffs
their alle!ations of criminal conduct on the art of the laintiffs and
that they* laintiffs+ are not ro erly before this Court(
&bsent proof of plaintiffs- ;criminal acts; and proof that plaintiffs are not properl* before the
Court /ithin three da*s it /ill be accepted that Mr. 7eSmith and defendant 'ambo have rescinded
those libelous accusations regarding plaintiffs.
In the event that defendant 'ambo, attorne* 7eSmith, district attorne* le9 @ardin, or an* state
actor elects to deprive plaintiffs- rights then here be the fee schedule, terms, and conditions for such
acts of deprivation: & fine of 5,$$$,$$$ per inalienable right deprived. &dditionall*, !,$$$ /ill be
fined for each minute an* member of the Cross famil* is deprived of their inalienable rights. a*ment
of said fines must be made in Constitution (a/ful mone* to plaintiffs /ithin 5 months of the
occurrence of said rights deprivations.
age !5 of !%
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-ther contributin! factors to the de rivation of laintiffs' ri!hts
for this Court's consideration
+he entire South/estern udicial Circuit is over/helmed /ith conflicts of interest. Man* of the
individuals are present in various organi9ations, agencies, and offices that ree0 of nepotismHcron*#ismat the least. +he S?G& C&S& South/estern Georgia Court &ppointed Special &dvocate) agenc*
claims at least verball* via its /or0ersHvolunteers) to be an independent non#court affiliated non#profit
group that is ;to provide a voice for children in court.;. +he idea is that the 6udge, re1uired to be a
neutral and unbiased presiding officer, /ill be hearing the t/o sides of cases /ithout the benefit of the
vie/point of the child. & C&S& volunteer is to provide a third vie/#point that is unencumbered b* the
;politics; or ;predisposed; notions of the various agenciesHdepartments that might be involved in a
case.
+he realit* is that C&S& is ver* political. ;Desire to please; is a real occurrence in ever*da*
life. +he li0elihood that volunteers ma* feel the need to side /ith /homever the 6udge appears to be
favoring is ever present. In the South/estern udicial Circuit, defendant (isa 'ambo goes so far in her
court as to provide D8CS prosecuting attorne*s /ith /hat their ne t move should be, so obviousl* she
tends to side /ith D8CS specificall* in the plaintiffs- 4 hour hearing, defendant 'ambo told
defendant @urt /hat she ;assumed; /as his motion). >hen individuals volunteer /ith C&S& and are
dul* appointed as advocates, the* are often attempting to ;net/or0; and develop their ;credentials;.
In going against a ;6udge; or an* other individual in the court /ho has ;pull; or ;clout;, the volunteer
is obviousl* potentiall* damaging their position for later recommendations. In this particular case, the
C&S& volunteer /as /ell a/are that the D8CS supervisor, defendant aran &lbritton, /ho sat at the
table during the initial ; 4 hour hearing; /as also a board member of C&S&. 8urthermore, the most
overriding concern of C&S& is for the child-s right to ;appropriate placement and permanent home. ;
Such a statement begs the 1uestion##do children have the ;right; to be unmolested b* state actors in
age !" of !%
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their o/n famil*.
C&S& is affiliated /ith the (ighthouse Child &dvocac* program that features defendant 'ambo
as a supporter. 8unding of the (ighthouse Child &dvocac* program allegedl* comes from court
probation fees more barratr*). +he ne/ coordinator of the &dvocac* program is none other than, thene/l* retired D8CS supervisor, defendant aran &lbritton. Defendant &lbritton /as the D8CS
supervisor /ho, along /ith defendant arr, too0 ph*sical possession of 8.C. at the Doctors @ospital in
&ugusta, Georgia. oth &lbritton and arr are responsible for 8.C.-s /rist in6ur*.
? #6uvenile 6udge and attorne* Governor 7athan Deal has appointed defendant 'ambo to the
Georgia Commission on Child Support. In turn, defendant 'ambo recommended to Mr. Deal the
appointment of S?G& C&S& e ecutive director rad 'a* to the Child &dvocate &dvisor* oard
of /hich defendant 'ambo is also a member). District attorne* le9 @ardin is on the board of
S?G& C&S&. ased on information and belief le9 @ardin-s spouse is the sister of the S?G&
C&S& that fa ed the C&S& document e hibit D in the complaint) to ediatric &ssociates to effect the
unreasonable sei9ure of medical records. +here is more but this /ill suffice in demonstrating that
plaintiffs /ere snatched b* a group of business people /ith significant potential for conflicts of
interest. laintiffs believe this group of people to be !$$B business, and 0ids are their 6ustification for
more funding. Could it be that there is substantial pressure revenues must al/a*s go up) to
unreasonabl* ac1uire 0ids b* the 6uvenile courtE Could this possibl* contribute to the unla/ful sei9ing
of 8.C.E &ccording to defendant 'ambo on December !$th, 4$!4, ; ve been %he :uvenile ' ur% :udge
12 years and never had ne %hese 'ases. ; laintiffs assert the reason is because most people reali9e
that refusing a tetanus vaccine is not reasonable grounds to sei9e, in this case, an alread* traumati9ed
little bo* from his parents /ho /ere obviousl* attempting to secure urgent medical attention for him.
laintiffs hereb* command defendant (isa Coogle 'ambo to immediatel* produce her
legitimate authorit* for her actions against these plaintiffs.
age ! of !%
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laintiffs further command defendant and alleged ublic +rustee (isa 'ambo to
immediatel* account for her breach of dut* to the plaintiffs beneficiaries).
8or the foregoing reasons and all the others revealed in the plaintiffsJ complaint, defendant
'ambo-s motion to dismiss should be denied.
age !% of !%
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8/12/2019 Rebuttal to defendant Lisa Rambo's motion to dismiss
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r,'*. ,A*fust x*{i*e*f,.th*,*rg*xrletrnrrys express*d .vifhin hs f'oundeti*nsl docunrents
ot' hc ltepublic uf Georgia, America
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