SHIRLEY V. REMMERT, In Pro Per
Blog: callpsychiatryareligion.wordpress.com
(contains court papers and responses)
SUPERIOR COURT OF THE STATE OF CALIFORNIA
SAN MATEO COUNTY
Redwood City
EX PARTE
Hisham M. Al-Zaghari v. Eva D. Al-Zaghari
CO-RESPONDENT REMMERT’S REQUEST FOR
PRE-FILING ORDER UNDER CCP SECTION 391
ET SEQ.
PURPOSE OF PRE-FILING ORDER: TO FILE A
MOTION FOR PRELIMINARY INJUNCTION
OF DENIED VISITATION ORDER & OTHER RELIEF
CASE NO. F055586
_____________________
HON. JOHN L. GRANDSAERT
Real Parties in Interest:
Family Court Services ;
Public Guardian
___________________________/
NOTICE OF HEARING TO ALL PARTIES AND ATTORNEYS OF RECORD:
I, Co-Respondent Shirley V. Remmert, hereby give notice of an ex parte hearing for a pre-filing order under the vexatious ligitant statute, Code of Civil Procedure section 391 et seq. The previous hearing on my request for a pre-filing order in this case was held on November 24, 2015 before the Presiding Judge, Honorable John L. Grandsaert. The judge agreed to allow me to revise my application. I now propose to file a motion for a preliminary injunction of the Family Court order of September 15, 2005 pending an injunction of the conservatorship order regarding my daughter Conservatee Eva Al-Zaghari. The hearing will take place in the above Court at 400 County Center, Redwood City, CA 94063 on Dec. 9, 2015 at 2:00 p.m. in Department 11. Under the statute, this request is not meant for harassment or delay. I declare that the above statement is true and correct under the penalty for perjury of the State of California laws.
______________________________
Co-Respondent/ Applicant – Date
********************************************************
PROPOSED MOTION:
CO-RESPONDENTS’ MOTION FOR PRELIMINARY INJUNCTION OF FAMILY COURT ORDER OF 9-13-05 DENYING VISITS
AND RELATED REQUESTS
JUDICIAL COUNCIL FORMS 300, 311, 312, 320, 340
DECLARATION; EXHIBITS 1 ~ 11
MEMORANDUM OF POINTS AND AUTHORITIES;
PROPOSED ORDER
HON. ___________
NOTICE OF HEARING TO ALL PARTIES AND ATTORNEYS OF RECORD:
I, Co-Respondent Shirley V. Remmert, the maternal grandmother of the minor, hereby give notice of a hearing to take place in the above Court at 400 County Center, Redwood City, CA 94063 at ____________ a.m./p.m. in Department ____. I will move for a preliminary injunction of a Family Court order and for related relief. The order denying visitation was signed by Hon. Joseph C. Scott on September 13, 2005. The preliminary injunction, if granted, will last until a permanent injunction of the conservatorship order is granted or pending further court orders.The grounds for the motion is my belief that the mother (Respondent Conservatee Eva D. Al-Zaghari) and I are entitled to the relief demanded. The motion is based on the Family Court order of 3-16-01 granting my standing in this matter (Exhibit 1); the Code of Civil Procedure section 526, Judicial Council forms FL-300, FL-311, FL-312, FL-320, Declaration, Memorandum of Points and Authorities, and Exhibits 1 ~ 11.
DECLARATION IN SUPPORT OF GRANTING A MOTION
FOR A PRELIMINARY INJUNCTION AND RELATED RELIEF
BY CO-RESPONDENT MATERNAL GRANDMOTHER
I, Co-Respondent Shirley V. Remmert, declare as follows:
My family’s pursuit of happiness in re-uniting with the minor son of Eva Al-Zaghari should not be frustrated by the San Mateo County Public Guardian having overweening power to suppress our claims of capacity and fitness.
If the conservatorship order made for my daughter Eva Al-Zaghari is illegal, the following would have to be illegal: the Family Court order of September 13, 2005 (Exhibit 2); the Family Court Services report (Exhibit 3); the Probate restraining order regarding my mother Conservatee Julia Venoya (Exhibit 4); the Probate restraining order regarding my daughter Conservatee Eva Al-Zaghari (Exhibit 5); misdemeanor convictions, order for Eva’s assigned residence, and other vilifying judgments. Those orders and declarations based on the conservatorship findings should no longer cause my family grief, as the presiding courts could not have had jurisdiction over the subject matter of capacity first presented in the conservatorship process.
FACTS THAT SHOW, OR WILL SHOW,
THE CONSERVATORSHIP IS ILLEGAL
A related case alleging RICO violations is in the U. S. Court of Appeals.
In a related federal case, U. S. Court of Appeals for the Ninth Circuit, Case No. 15-16471, Remmert v. U.S. District Court for the No. District et al., filed August 31, 2015, request to file a RICO case, I am alleging that Probate restraining orders prohibiting my contact with my mother Conservatee Julia C. Venoya (Exhibit 4) and my daughter Eva, (Exhibit 5), as well as misdemeanor criminal convictions, and other orders or judgments, are illegal, as the conservatorship orders were made without a law enforcement investigation of a targeted, fraudulent detention for the conservatorship.
The first detention of my daughter Eva in June, 1990 for a schizophrenia diagnosis was never examined for the lack of civil rights and lack of due process for the detainee.
Before Eva’s conservatorship trial of June 7, 2005 and during the discovery phase, if any, Deputy County Counsel Judith Holiber and Private Defender Neal Winchell never served Eva and me with the first psychiatric report of June, 1990 that contains information about her first-time detention, first known drugging with a psychotropic, and first diagnosis of schizophrenia in June, 1990. Exposing that report would have given Eva and me an opportunity to challenge the report and to describe the detention as a kidnapping by the psychiatrist James Kevin Rist, M.D., who surrendered his medical license for undisclosed reasons in 2003. http://www.healthgrades.com/physician/dr-james-rist-2wsby#tab=background-check&scrollTo=BackgroundBackgroundCheck_anchor (Online background check of psychiatrist).
More significant than subsequent psychiatric reports, the first report by Psychiatrist Rist is material evidence showing the detention of a 15-year-old minor (then Eva Remmert) possessing all of her civil rights, with no record of breaking the law, eschewing all potential vices, such as smoking, drinking, drugs, having an A-/B+ average at Palo Alto High School, and having no previous diagnosis of schizophrenia.
Once Eva became stuck with that psychotic diagnosis, subsequent mental health experts accepted the decision as dogma. Mental health or crime investigators, never felt it necessary to look at any previous condition of Eva, because her loss of civil rights would already be stamped in the investigator’s psyche, able to observe only the total lack of her personhood from forced drugging and an injured capacity presumed to be self-imposed, making an investigation of a civil rights violation a waste of time .
By not giving Eva and me notice of a temporary conservatorship hearing and order, issued on April 14, 2005, the County Counsel’s Office under Thomas Casey was able to treat Eva as a permanent conservatee beginning on April 14, 2005 before she was even put on trial for the permanent conservatorship.
At a hearing on April 14, 2005, before Eva’s conservatorship trial, the County was granted a Temporary Conservatorship and certification for her to be cited for the conservatorship trial. An unlicensed psychiatrist, Beverly Cox, treating Eva, handled the certification process. She hid from the Court that Eva was in fact stabilized from the forced drugging and the PTSD induced in her.
On May 4, 2005, Deputy County Counsel Judith Holiber and others allegedly scrapped Eva’s hearing on a petition for writ of habeas corpus that was supposed to be held before Hon. Smithson in Case No. CIV 445892, Eva v. San Mateo County Hospital et al. (Exhibit 6)
While waiting for the said hearing to take place on May 4, 2005, Eva and I were directed to go to Hon. Quentin Kopp’s court. Posted on his courtroom door was a list of hearings. But the designation of Eva’s hearing for Judge Smithson’s hearing (Eva Al-Z. v. County,etc.) was changed by our adversaries to be read as: People v. Eva Al-Zaghari, Case No. 108876 LPS. The new designation automatically judged her as gravely disabled, danger to self or others, and as a criminal defendant. I did not realize the alleged fraud of the supplanting of Eva’s hearing until the Superior Court advised me ten years later in 2010 that Case No. CIV 445892 was still awaiting Eva’s motion for a trial (Exhibit 7).
Speaking off the record to Hon. Quentin Kopp on May 4, 2005, after he had denied her petition for writ of habeas corpus, Deputy County Counsel Judith Holiber answered Judge Kopp’s question about what would happen next to Eva. Ms. Holiber stated the County’s policy of intensive drugging or rehabilitation at Cordilleras Mental Health Center after the issuance of a conservatorship order, if granted. A trial was pending on June 7, 2005.
On May 12, 2005, mental health custodians allegedly kidnapped Eva from San Mateo Medical Center’s psychiatric ward to begin alleged illegal and brutal intensive drugging at Cordilleras Mental Health Center before a judge could order that the drugging was necessary after a trial.
All of a sudden, on May 12, 2005, just eight days after Ms. Holiber answered Judge Kopp’s question and implied the County’s policy to refrain from intensive treatment until trial and a conservatorship order, my adversaries sent Eva in her stabilized condition to Cordilleras, where unstable, severely ill patients shuffled about in a daze. Grueling torture by psychotropic drugs that caused PTSD or post-traumatic symptoms in Eva began. The trial for a permanent conservatorship was several weeks away.
At her conservatorship trial on June 7, 2005 Eva could not understand most of what was said because she was intensively drugged.
Whatever Deputy County Counsel Judith Holiber said about Eva to the jury members at the trial for a permanent conservatorship on June 7, 2005 was not challenged because Private Defender Neal Winchell knew nothing about Eva and refused to meet with her or me before the trial.
I was not permitted by the bailiff and Private Defender Neal Winchell to attend Eva’s trial.
The bailiff at the trial on June 7, 2005, approached me as I was getting off the witness stand (I was the first witness.) He told me I could not stay in the courtroom. He watched as I left. Mr. Winchell was too hostile toward me to invite my staying post-testimony. He did not make a motion so that I could witness the trial.
On October 16, 2008, at Eva’s petition to terminate the conservatorship, Deputy County Counsel Peter Finck and Private Defender Neal Winchell ignored the jury’s verdict that she is not gravely disabled (Exhibit 8) and refused to prepare an order for her release.
I believe Hon. Joseph Bergeron stated that the conservatorship was terminated. But Mr. Finck and Mr. Winchell refused to obtain the judge’s signature. Still languishing in her imprisonment, our adversaries manipulated her into another conservatorship trial whereupon Hon. Marie Weiner ordered her to be placed in a State psychiatric hospital at the option of the Public Guardian. The judge vaguely alluded to an alcohol treatment program at the State hospital (Eva does not drink).
BIAS IN FAMILY COURT SERVICES REPORT
Social Worker John Skucas, the author of the Family Court Services Report (Exhibit 3) was not motivated to practice due diligence in his research for the report. He was biased on behalf of the father, as Mr. Skucas is a father of all males. Had he researched the birth of the minor, he would have discovered that on April 13, 1999, the birthing hospital, Lucile Packard Hospital, was supposed to provide Eva after her delivery with an attendant physician, reported to have been Dr. Yasser El-Sayed, M.D. Eva was not conserved. We were not breaking laws.
Eva, having undergone Cesarean surgery, did not receive the benefit, under the birthing hospital’s policy, of any physician’s support at any time after her surgery and while San Mateo County social worker Selu Mapa and around six Palo Alto policemen were taking Eva’s baby away from the hospital. Out of nowhere, a rogue psychiatrist named Jose Maldonado, M.D. from Stanford Hospital came into Eva’s unit and threatened to put Eva in Stanford’s psychiatric ward. He harassed Eva and me for two days straight, so I left with Eva on April 16, 1999, although one of her surgeons surnamed Dr. Perl____ had verbally promised April 16 as the discharge date. Psychiatrist Maldonado tracked us to Eva’s apartment and sent Menlo Park police to bring her back to him. They refused to do his bidding, because nothing was wrong with her.
FRAUD IN PROSECUTION OF MY CRIMINAL CASES
Circumstantial evidence of Deputy County Counsel Judith Holiber’s signaling to Jury Foreman Skinnell during a short interruption in her testimony against me in my criminal trial on November, 2006 proves the alleged wrongful act of influencing a juror (Case No. SM340531A, trial for helping Eva leave what seemed to be a private mental health center run as a snake pit asylum under a County contract.
The transcript will show that hours before, Jury Foreman Skinnell, tried to alert my Private Defender Mitri Hanania about Mr. Skinnell’s communication with a witness in the case. Mr. Hanania in turn informed the court. When the court did not respond to the matter, I saw Mr. Skinnell communicate to Ms. Holiber, still on the witness stand, by making an OK sign with his fingers in answer to the question on her face.
Alleged: Deputy County Counsel Judith Holiber falsely testified at my criminal trial on November, 2006 that she did not criminalize Eva’s conservatorship case, which is supposed to be civil.
At Eva’s conservatorship trial on June 7, 2005, I was not allowed to attend the trial. Ms. Holiber represented the County against Eva, I learned the same evening that she informed the jury that Eva ran afoul of the federal law over an altercation with flight attendants in an airplane in 2002. No one informed Eva or me that the subject would be brought up as an alleged double jeopardy of the misdemeanor conviction in 2002.
In November, 2006, in an alleged violation of confidentiality rules at the said criminal trial, Deputy County Counsel Peter Finck advised Hon. Susan Etezadi, that Eva’s psychiatric records, alleged to be fraudulent, could be shown to the jury members.
Mr. Finck testified in court that based on his research, the court could rely on the Menendez case (twin brothers’ murder of their affluent parents). The judge in that case ruled that the records of the brothers’ psychotherapist were by law not exempt from disclosure, while a psychiatrist’s records cannot be disclosed. But Mr. Finck knew that the Menendez case does not apply in Eva’s case. Eva did not receive psychotherapy. He was present in the court when the County’s expert witness, Psychiatrist Beverly Cox, M.D., testified that Eva was mute throughout the psychiatric treatment she received. She could not get Eva to talk. Her muteness would indicate that psychotherapy ( a dialogue between the therapist and patient) could not have taken place. The eventual Guilty verdict in this case, therefore, hinged on Deputy County Counsel Finck’s exposing the false, inflammatory psychiatric reports about Eva and me without my right to gain discovery from Eva or to bring her to Court.
At the said criminal trial, Deputy District Attorney Josh Stauffer allegedly hid documentary evidence from the Court that would exonerate Eva from her defamed capacity and vindicate me from the accusation of abuse to a dependent.
In the transcript, Hon. Susan Etezadi expressed uneasiness and near-panic over the missing or unaccounted-for, original subpoenaed documents. Mr. Stauffer, not a party in the case, succeeded in hiding the evidence in Eva’s and my favor. Those reports were the Menlo Park Fire Department paramedics’ reports and the Sheriff’s 911 Communication re American Medical Response. The reports denoted the paramedics’ finding on March 26, 2005 that Eva was normal and the paramedics could not be used for detaining her. At my criminal trial, Deputy County Counsel Finck was able to deflect attention away from Mr. Stauffer’s alleged deceit by persuading the court under the / psychotherapy ruling to allow the jury to look only at Eva’s psychiatric records. The said subpoenaed documents in Eva’s and my favor, in Deputy D.A. Stauffer’s possession, were deemed unnecessary to show to the jury. But the psychiatric records disguise the fact of drugging Eva to create a shattered mental and physical condition and slough off the fact of a detaining officer named Sysum allegedly inducing her PTSD (post-traumatic) responses.
The records also omit material evidence of how fraudulent detentions were conducted.
In order to give Hon. Elizabeth Lee the impression that Eva was gravely disabled, Supervising Deputy Public Guardian, Marcelle Moon, had Eva drugged with a toxin that made her spastic at my criminal trial on May 29, 2007, (Case No. SM 351187A, involving my rescuing Eva from a dangerous halfway house on April 26, 2007.)
The detaining Sheriff Deputy, Joseph Vers, witnessed Eva as being limber and normal in her gait on May 3, 2007. About 26 days later, she turned into a spastic appearing before Judge Elizabeth Lee as gravely disabled. The unknown, unusual drug crippled her physically, but not mentally. She appeared to be in need of a cane to walk, but with arms flailing, she walked with energy on her rickety legs. She appeared not to be feeling the pain that I was seeing. Her testimony was reasonable (Exhibit 9)
RESTRAINING ORDERS AS EXTORTION
The restraining orders prohibiting my contact with my mother Julia C. Venoya and my daughter Eva D. Al-Zaghari, are two of many orders and judgments that were obtained to allegedly extort my cooperation.
I allege that since 2003, because I repeatedly failed to cooperate with my adversaries in showing a more than cordial interest in a private psychiatrist whose word to a judge would have granted everything I am asking for in this paper, my mother and my daughter suffered one abuse after another upon orders of their conservators, Deputy Public Guardian Susann Wood (2004 ~ 2005) and Supervising Deputy Public Guardian Marcelle Moon (2005 to the present). Since December, 2008, my mother was first drugged with the toxin that causes spastic movement and malformed limbs (Exhibit 10, photos, my mother in 2012). Ms. Moon obtained, to her disappointment, a five-year restraining order regarding my mother in 2012 and not a lifetime restraining order she asked for. She was granted a three-year restraining order regarding my daughter in 2014, capping a continuous restraining order for the past ten years. As a response to my judicial challenge to the current restraining order for Eva, Deputy County Counsel Peter Finck allegedly conspired with the custodians of Eva, suffering from diabetes induced by the board-and-care management, only one meal for the entire day of April 26, 2014. Since the restraining orders were filed in 2012 and 2014, respectively, I do not know what is happening to them.
Conclusion
Because Eva and I should prevail in the permanent injunction of the conservatorship order, my motion for a preliminary injunction of the Family Court order of September 13, 2005 and request for related relief should be granted in the interest of equitable justice giving me rights in the face of the County’s unconscionable power.
I declare that the above statements are true and correct under the penalty for perjury of the State of California laws.
_________________________ ____________________
Movant Date
MEMORANDUM OF POINTS AND AUTHORITIES
I, Co-Respondent Shirley V. Remmert, am the maternal grandmother of the minor. I request that the Court grant my motion for a preliminary injunction of the Family court order of September 13, 2005 denying Respondents’ contact with a minor and for other related relief stated in the proposed order. Exhibit 2 is the minute order of 9-13-05. I cannot find a copy of the order in the court file. The minute order refers to the Family Court Services report (Exhibit 3). Paragraphs 1, 2, and 4 (on last page) of the report became part of Judge Scott’s order. The preliminary injunction, if granted, will last until an injunction of the Respondent mother’s conservatorship order is granted or pending further court orders. The subject minor is the son of Respondent Eva D. Al-Zaghari and Petitioner Hisham M. Al-Zaghari. Eva, my daughter, has been conserved by the San Mateo County Public Guardian since June 13, 2005. The minor is my grandson.
The parties’ new titles for this motion are as follows: Eva and I are the Movants; Mr. Al-Zaghari is now the Respondent.
As the Movant, I hereby request the following injunctive and affirmative relief pending an injunction of the conservatorship order:
a. That the current Family Court order issued by Hon. Joseph Scott on September 13, 2005 be enjoined, so that visits will be resumed between the minor and his mother with me, his maternal grandmother (The details of the visit are listed on the Judicial Council form FL-311);
b. That any requirement for supervised visits, mental health assessments, and Family Court Services participation in the hearing be enjoined.
c. That Supervising Deputy Public Guardian Marcelle Moon be restrained from denying “home passes” for Eva’s stay with her aunt and me. (The details regarding Eva’s visits with me are on Judicial Council form FL-311, p. 2 of 2.
d. That the Court grant “Child Abduction Prevention” Orders stated on the attached Judicial Council form FL-312.
e. As affirmative relief, I request
(1) That Eva be made a party in this matter, since she was a party in the hearing for the current order on September 13, 2005 and testified on behalf of continued visits (Exhibit 2, minute order);
(2) That visits take place in San Mateo County or San Francisco County to avoid the minor’s commute to Stanislaus County, his mother’s assigned placement.
Law
I was a Co-Respondent in the original petition for custody by the father, Hisham M. Al-Zaghari. The order for my standing in this case was made by Hon. George R. Taylor on March 16, 2001 (Exhibit 1).
My request for an injunction of the Family Court order of September 13, 2005 is made pursuant to the Code of Civil Procedure section 526:
526. (a) An injunction may be granted in the following cases:
(1) When it appears by the complaint that the plaintiff is
entitled to the relief demanded, and the relief, or any part thereof,
consists in restraining the commission or continuance of the act complained of, either for a limited period or perpetually.
(2) When it appears by the complaint or affidavits that the
commission or continuance of some act during the litigation would
produce waste, or great or irreparable injury, to a party to the
action.
(3) When it appears, during the litigation, that a party to the
action is doing, or threatens, or is about to do, or is procuring or
suffering to be done, some act in violation of the rights of another
party to the action respecting the subject of the action, and tending
to render the judgment ineffectual.
(4) When pecuniary compensation would not afford adequate relief.
(5) Where it would be extremely difficult to ascertain the amount
of compensation which would afford adequate relief.
(6) Where the restraint is necessary to prevent a multiplicity of
judicial proceedings.
Issue
The issue is whether the maternal family of the minor is entitled to the relief of an injunction of the current Family Court order;
Argument
The statements in my Declaration in support of an injunction and affirmative relief are herein incorporated.
The commission or continuance of the Family court order during the litigation would produce irreparable injury, to the minor and his maternal family.
The minor is now sixteen years old. There is not much time left to repair the damage to his relations with his maternal family. There was a fragile pre-existing relationship between him and his mother and me, when he met us for the first time in September, 2003. Although Eva and I always had visitation rights, the frustrated visits were not enforced until Hon. Mark Forcum’s order of September, 2003. The order was shelved once Eva was conserved.
The paternal family of the minor appears poised to violate the civil rights of the minor rendering the best interest of the minor ineffectual.
According to information given to me by a United States Department of State officer by telephone, the father and the minor, a dual citizen of Jordan and the U.S. were in Jordan within the past two years seeking to renew the minor’s passport. I was told the passport was not renewed given my allegations of his frustrating past court orders for contact with the minor. In addition, the father violated the court order of March 16, 2001 (Exhibit 11) that states he must first have a noticed hearing for the court’s permission to travel beyond the local area. In my telephone conversation with the State Department, it was not clear whether the minor had to remain in Jordan or was allowed to come back to the U.S. He should not go to Jordan at this time because of his age, being subject to the draft in that country now at war with ISIS. To allow that injustice to occur only highlights the erosion of his American civil rights since he was taken from his non-conserved American mother upon his birth.
Pecuniary compensation would not afford adequate relief. Monetary relief is not requested in this matter.
The restraint is necessary to prevent a multiplicity of judicial proceedings.
Having to prove first that Hon. Scott’s order should be overturned would require me to prove that the conservatorship was brought by fraud committed by a great number of adversaries since my family suffered a home invasion in 1990. The complexities of fraud and medical issues demand numerous discovery motions biding their time. In the meantime, this Court could effectively stanch the damage to our maternal family’s rights by granting the injunction and affirmative relief.
The Court must consider whether the maternal family will prevail in court in a motion for a permanent injunction of the current restraining order or the conservatorship order.
Since the minor will turn 18 on April 13, 2017, I probably will not move for a permanent injunction against Judge Scott’s order. I believe my family will prevail in having the conservatorship orders overturned, as I have presented prima facie evidence of wrongdoing by our adversaries in the Declaration.
In this request for equitable relief, a test of the balance of hardships comes out in favor of the minor and his maternal family. In determining the weight of harm to the Movants as opposed to that of the Respondents, the maternal family, especially the mother, has suffered grievous harm, while the County has a questionable investment in depriving us of liberty. The crushing blow to our human rights will continue, if the Court will not issue the injunction. The visits between the maternal family and the minor is our natural right, which does not harm the State in the balance of equities test. I trust that the State does not seek to isolate progeny from parent in a Brave New World scheme, therefore, the State does not suffer by the reunification of my family.
Relief Requested
I request that all of the relief requested in the above Section ___ be granted.
Conclusion
For the above reason, the request for a preliminary injunction and affirmative relief should be granted.
I declare that the above statements are true and correct under the penalty for perjury of the State of California laws.
___________________________ _________________________
Movant Date
PROPOSED ORDER
Having heard the request by moving party(ies) Shirley V. Remmert, maternal grandmother of the minor, and Eva D. Al-Zaghari, the mother of A. A., as well as the opposition, the Court hereby GRANTS a preliminary injunction of the Family Court order of September 13, 2005 and affirmative relief as specified below:
1.
That the current Family Court order of September 13, 2005 be enjoined, so that visits will be resumed between the minor and his mother Eva Al-Zaghari with Shirley Remmert, his maternal grandmother (The details of the visit are listed on the Judicial Council form FL-311);
2. That any requirement for supervised visits, mental health assessments, and Family Court Services participation in the hearing be enjoined.
3. That Supervising Deputy Public Guardian Marcelle Moon be restrained from denying “home passes” for Eva’s stay with her aunt and me. (The details regarding Eva’s visits with me are on Judicial Council form FL-311, p. 2 of 2.
4. As affirmative relief, I request
a. That Eva be made a party in this matter, since she was a party in the
hearing for the current order on September 13, 2005 and testified on behalf of continued visits (Exhibit 2, minute order);
b. That visits take place in San Mateo County or San Francisco County to
avoid the minor’s commute to Stanislaus County, his mother’s assigned placement.
c. That the Court grant “Child Abduction Prevention” Orders stated on the attached Judicial Council form FL-312.
5. All other orders not in conflict with the above will remain in effect.
SIGNED ON
By: _____________________________
Judge of the Superior Court
Approved as to Form By
______________________________
Deputy County Counsel Peter K. Finck
LIST OF EXHIBITS
Superior Court of the State of California
in San Mateo County
1 Hisham M. Al-Zaghari v. Eva D. Al-Zaghari, (Co-Respondent Shirley V. Remmert), Case No. F055586, filed 03-16-2001, Order After Hearing Re Respondent’s Joinder Nunc Pro Tunc, Hon. George Taylor;
2 Id., Case No. F055586; Date: 09-13-2005, Minute Order, Hon. Joseph S. Scott;
3 [Report] To: Hon. Joseph Scott, From: Family Court Services (John Scukas), 5 pages; Case No. F055586, Date: 08-26-2005;
4 San Mateo County Public Guardian v. Shirley V. Remmert, current restraining order (Re Julia Venoya), Case No. PRO-113777, filed 09-11-2012, Elder or Dependent Adult Abuse Restraining Order After Hearing by Hon. George Miram;
5 Id., current restraining order (Re Eva Al-Z), Case No. PRO-114069, filed 04-11-14, Elder or Dependent Adult Abuse Restraining Order by Hon. George A. Miram;
6 Eva D. Al-Zaghari v. San Mateo County… et al, Supplement, Petition for Writ of Habeas Corpus, Case No. CIV 445892, filed 04-11-2005, 3 pages;
Exhibit of Eva’s and Remmert’s last visit with minor.
7 Superior Court’s Notice of Dismissal of Case No. CIV 445892, filed 4-30-2010;
Shirley Remmert’s Response, May 13, 2010;
Letter to Presiding Judge Hon. Hall; From D. Shea, May 14, 2010;
8. Conservatorship of the Person and Estate of Eva D. Al-Zaghari, Case No. 108876 LPS, filed October 16, 2008, Jury Verdict: Eva, not gravely disabled;
9. People of the State of California v. Shirley V. Remmert, Case No. SM340531A, Date: 05-29-2007, section of transcript, pages 53 ~58;
10. Photos Julia Venoya, aging normally until December, 2008. Spastic movements and then paralysis.
11. Al-Zaghari v. Al-Zaghari, Case No. F055586, Date: 03-16-2001, Order After Hearing of March 13, 2001, [Restrictions on Minor’s Travel].◊
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