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In California, homeless children were given emergency shelter only on condition that they be separated from their parents, until a successful lawsuit put an end to the practice.
Formal CPS Complaint
Kitsap County Court
Bremerton Office of CPS
To Whom It May Concern:
I wish to file a formal complaint against my caseworker, Moe Randles and her
associated CASA workers.
I have not been able to resolve our differences and I believe she is not
handling my case fairly or competently for the following reasons:
- She has falsified reports to the court. I refer to her giving inaccurate
dates as to her visit at my home on December 3, 2003 and her misleading statements implying
that she was there on December 4 and was not honest about the medications I was on (referring
to a UA that was on December 3 that showed positive for Vicodin). I was not on medication
at the time of her visit (12/2/03) and was not hiding anything. I was in a car accident
later that day after her visit whereas I was given medication, which I
showed KRC at the time of my UA.
- She has repeatedly lied about me regarding such important issues as my
compliance with the case plan, my current medical status, and my attitude.
- She has repeatedly lied to me.
- She has ignored the statements of my children regarding my parenting ability and alleged
abuse/neglect. She also ignores and denies my daughters consistent plea's to be allowed to
come home, statements which not only prove she was never abused or neglected but that
(contrary to reports made to court by Moe and Casa) she desires and has all along to be
reunited with her mother.
- She has repeatedly failed to return my phone calls.
- She has misrepresented my status pertaining to the case plan — she tells me one
thing and reports something else to the court and in the file. I cannot trust her to be
fair and honest with me.
- She has ignored or discounted collateral evidence that substantiates my claim that my
children were not abused/neglected, and were to the contrary, happy, healthy children.
- She has ignored or discounted collateral evidence that proves her claims were false.
- She has not acted in the best interest of my children by
traumatizing them with an unnecessary and illegal detention and keeping them from their home
and beloved mother.
- She has repeatedly violated the department's own policies and procedures as
well as Washington and Federal Statutes during the entire course of this intervention.
- She has repeatedly violated my and my children's rights during the course of this intervention.
- She has overstepped her authority and she is actually practicing medicine without a license
by second-guessing the diagnosis of my and my daughter's doctor and requiring more intensive
medical and therapeutic supervision than is necessary.
- Her behavior reflects a negative bias against me based on my disability and she has projected
her fears onto me. She has demonstrated an irrational fear of mental illness, which has caused
her to make unreasonable, and abusive decisions about my case and my status and to inaccurately
attribute my emotional state to some imagined or unjustified tendency to anxiety and stress and
violence/threatening. All of these actions are in violation of the Americans with Disabilities Act.
- Even though I have complied with the case plan, she refused to honor her explicit promise that my
daughter would be returned.
- She has acted to forward her own personal agenda, prejudices, and biases instead of acting to
protect the best interest of my child.
- I believe she is unqualified to be a caseworker in cases involving children. She has made
statements that she feels children do better in foster care; that in the 3 years she has done
this work I was the only person she had even considered returning a child to their homes, and
that all parents who do everything right are the ones she doesn't trust.
She also stated that she grew up in foster homes, and was bounced around a lot, that permanency
is the main issue. She shared that her father was an addict and had abandoned her, her mother
was mentally ill. She also discussed her husband's alcohol and addiction and relapses.
She has shown a total disregard for my daughter and my rights. She has gotten extremely angry and
irrational to the point of hanging up on me when I was merely asking some questions to clarify some
inconsistent statements she has made to me. She has tried to undermine my compliance with the case
plan by fighting to have all of my support people removed from my case.
She has blown off my reports that my daughter is being hit and bit by other children in her foster
homes and school. She in fact stated that it was probably payback.
She has showed no consideration at all in the history of my daughter's biological father and in fact
had sent him a proposed ISSP plan before paternity had even been established as well as informed my
daughter of her father and their upcoming paternity test. It is clear by the court records for my
case (refer to my attorney) and court records on Mr. Whitman that he has never been in our lives and
I have had numerous restraining orders on him and that he has a long violent criminal history and in
fact has current warrants out for his arrest in Kitsap County.
She also allowed my address and phone number to be put on that form and ultimately given to Mr. Whitman.
I could continue but feel that it is not necessary for me to do so when all that is needed is to investigate
the file. I have requested copies of all my records and files pertaining to my case but still have not
been given anything. I also have requested a copy of CPS's policy and procedures manual and have been
- Her expectations of parents are unreasonably high and exacting. She does not recognize
that events can conspire to thwart one's best intentions and does not allow parents to be
flexible in dealing with unexpected or overly demanding situations. She is entirely too
rigid in her unreasonable demands. She does not recognize or honor the intense bond of
love and dependency that binds parents and children into a family unit and she is too
casual about disrupting that all-important bond regardless of the damage done to the parties
- She has not made reasonable efforts to successfully reunify my daughter and myself in the time
she has had. She has shown blatant undermining efforts to reunify my daughter with myself,
including not allowing us the two-hour visit that has been provided at the Port Orchard Family
Community Services (since at least January 1, 2004) until ordered by the Commissioner at our
She has refused phone visits, extra visits, holiday visits, unsupervised visits, home visits, ect.
All this in-spite of a report by Dr. Oleary stating my capability to parent my daughter and
recommending reunification begin immediately. This report was in October 2003.
There was in fact an addendum made to his original report stating false information regarding
myself that changed his view. At this time I am unsure of who phoned in the false information
that would cause Dr. Oleary to do such a thing. I do know this is a violation of my rights
and is a bold act to discredit me and damage the initial report made by Dr. Oleary.
I did try to contact him after the addendum was made to find out why this happened but was told
he could not speak to me. Similar acts have been displayed with Jessica's child-find assessments,
her Dr. exam at Mary Bridge Hospital and other interviews that I was never allowed to participate
in. I was never informed of my parental rights at all and even after I found out some of them, Moe
has continued to deny them to me. When my own therapist tried to complain to Moe's supervisor about
her treatment of me, Moe tried to have her taken off as my therapist, she did this as well with my
Drug and Alcohol Counselor Bill Engle.
- Moe has refused to try to place my daughter with my 21-year-old niece (M. D. —
who has had someone at her home to talk to her but no-one ever completed the request)
even though I asked this while Jessica was still in my mothers home last September.
- She has lied to my therapist about my diagnosis as well as statements my support people and I
have made to her, slandering my friends. She told me that Bill Engle was identified as some
one else (this again was stated to me by Deanne Beddel GAL) and asked if I had seen his ID.
When Mr. Engle went to CPS office and asked her she denied making the statement. She lied, she said
this in the court house in front of myself and Chris as well as in phone conversations.
She also implied that I was pregnant which is completely false. She told my therapist I was threatening
her. She becomes very angry, loud and defensive every time we talk and I ask her any questions.
She has treated me rudely and unprofessionally and I see no effort to communicate and work together to
accomplish reunification. Actually I feel her behavior has always shown her to be against reunification
and has in fact worked at thwarting reunification. I believe that for whatever reasons, she has personal
issues that are affecting her ability to do her job fairly and properly.
Name and details removed by request
Updated: June 13, 2011