Declaration ignored by all in county, sheriff 122 was counter supportive n used insider as chain of command to follow...

Desiree Peterson Mother of Baby K Fairfield CA 94533 DesireeNeverFails@gmail.com STATE OF CALIFORNIA JUVENILE DEPENDENCY COURT COUNTY OF SOLANO THE UNITED STATES OF AMERICA, In the Matter of Baby K TALBOT, a Minor Coming Under the Juvenile Court Law. DESIREE PETERSON (mother) vs. Sacramento County DHHS Case 237867 & Subsequent Petition Case 43896 The Department of Human Services Solano County DECLARATION TO ALL PARTIES OF PRESENT CIRCUMSTANCES WHICH REQUIRES CHANGE IN DEPENDENCY JURISDICTION Case No.: J43896 BOTH Original Petition and Subsequent Petition DECLARATION I, Desiree Peterson (mother of baby K, Talbot), declare the following for informative protection against DOES 1 - 100 INCLUSIVE re 2018cv000836, and their associate parties and peers, the following Statements are true and provable by documentation either in the following Appendix's or have already been submitted to a California Court. 1. A different families paperwork was received instead of Baby K's for filing of the 342 Subsequent Petition. 2. A different families paperwork was received again for the appeal not filed by Father Talbot's Appellate Attorney. 3. A date at the bottom of C-Dat Hair Panel results printout done by DHHS Solano County is dated 09-14-2017, and is followed by a different case number 14968. The Department allegedly received results on 09-15-2017. 4. Baby K was only in Fathers physical custody for half of the test period, caretaker the other half ( cleared drug screen ) . 5. An MRO will not give a positive result without consulting the patient ( parent . caretaker ) to check if any medications had been taken. No one asked either of Baby K. Talbot's parents this before 09-15-17. It was brought to the attention in the hearing following her removal. See transcripts. 6. The "test results" have no unit of measurement which makes it un-scientific, not conclusive or declarative of anything. 7. C-Dat, Quest, and I3 MRO have been informally asked to provide all documentation in relation to this test and have failed to do so. Mother Peterson has asked the court and Department for documentation and did not receive anything until the Extraordinary Writ of Habeas Corpus was filed with the Supreme Court of California. 8. Was told at last hearing the court never received MC-050 from mother dismissing Ken Lee as counsel. Ken Lee refuses to submit anything mother Peterson authors. Mother agreed to have Ken Lee represent her during what they are claiming "contested hearing". The judge and all parties provided by the court swore cross examination of the Social Worker was sufficed by any person in the department. Author of the report held against the FAMILY, Claudia Orozco, had not returned from Mexico and would not be available for cross examination. Admissibility of Social Worker's Report A social workers report containing information relevant to the jurisdiction hearing is admissible if, on the request of the parent, the social worker is made available to be cross examined on the contents of the report [welf & inst. Code 355(b); In re Malinda S. (1990) 51 Cal. 3d 368, 376, 272 Cal Rptr, 787, 795 P2d 1244] . Moreover, the evidence contained in the Report include any out of county evidence relevant to jurisdiction [ in re Hadley B. (2007) 148 Cal App 4th 1041 1049 - 1050, 56 Cal Rptr 3d 234]. Where the social workers report merely attaches reports from another social worker, the right to cross examine the preparer of the report has been held to also include cross - examining the social workers who wrote the attached reports [ In re Stacy T. (1997) 52 Cal. App. 4th 1415 , 1425, 61 Cal. Rptr. 2d 319 ] 9) None of Baby K. Talbot's parents have a history of drug charges, both parents have a completed education, both parents are / were homeowners, neither have ever been hospitalized or diagnosed with psychiatric problems, and ALL 6 OF THEIR COMBINED CHILDREN HAVE NEVER BEEN HARMED, by EITHER PARENT. 10) No drugs were confiscated and the only drug allegations stem from Social Workers that have not been available for cross-examination. 11) Social Workers have no explanation of requested "services" and cannot explain the need for them other than it being court ordered, even after it's brought to their attention the services are per their request and not the courts. 12) Imminent danger did not exist during either County's seizure, in Sacramento, children were not home during any entry with 7 day late filing and warrant, and Solano did not file until protest day of Mother September 18th, 2017. 13) Admission of guilt has never occured. 14) Contestment to Jurisdiction has existed since January 20th 2017. 15) Complaints and/or notification of this horrific terrorism done to my FAMILY have been filed and / or submitted with The Honorable Brennan and The Honorable Mueller in the Federal Court for Violations of Civil Rights, Risk Management of West Sacramento State Claims office, HIPAA, Special Investigations Oversight of Sacramento County, FBI, DOJ, and OIG. 16) Stanke and Parker are both Stakeholders in 2003 Solano County CWS Redesign Stakeholders Group and Stanke is the Co-Chair, and profit significantly in the faster smoother Juvenile Dependency Proceedings. This is a huge conflict of interest of fair proceedings. Human Services for bettering a society CANNOT be a Corporate model. (Increased percentage of profitability annually is inverse the Core Goals and functions until non-monetary value is equal to money.) 17) Baby K. Talbot’s siblings will be reunited with her mother as soon as the Family Court allows. In re Angel B. (2002) 97 Cal.App.4th 454, 461 [if the petition presents any evidence that modification might promote best interests of the minor, must hold a hearing]; In re Clifton V. (2001) 93 Cal.App.4th 1400, 1401 [must hold hearing to resolve credibility and factual disputes]; In re Zachary G. (1999) 77 Cal.App.4th 799, 807 [if every fact true would be entitled to relief]; In re Aljaime D. (2000) 84 Cal.App.4th 424, 432 [need only show prima facie case or probable cause]; In re Edward H. (1996) 43 Cal.App.4th 584, 593 [“A ‘prima-facie’ showing refers to those facts which will sustain a favorable decision if the evidence submitted in support of the allegation by the petitioner is credited.”Can be based on new evidence. (In re Hirenia C. (1993) 18 Cal.App.4th 504, 513 [even if old information ; In re Brandon C. (1993) 19 Cal.App.4th 1168, 1170-1171 [habeas petition alleging new evidence to challenge jurisdiction dismissed because a 388 petition provided an adequate remedy at law] 18) Mother was only found guilty by preponderance in sacramento and did not live with father during subsequent petition filing. Collateral estoppel has limited application in juvenile cases. “Allegations of child molestation are serious; they merit more than a rubber stamp. With the exception of death penalty cases, it is hard to imagine an area of the law where there is a greater need for reliable findings by the trier of fact. The consequences of being wrong—on either side—are too great.” (Blanca P. v. Superior Court (1996) 45 Cal.App.4th 1738, 1754.) Accordingly, “substantive justice is best served in sexual abuse cases when the common law doctrine of collateral estoppel 3 is applied narrowly.” (In re Jessica C. (2001) 93 Cal.App.4th 1027, 1039, fn. 11.) In In re Nathaniel P. (1989) 211 Cal.App.3d 660, the juvenile court found at a jurisdictional hearing that the father had sexually and physically abused his children. (Id. at p. 664.) Subsequently, the Department of Social Services (DSS) sought to terminate the father’s parental rights under former Civil Code section 232, subdivision (a)(7). The Court of Appeal held that it was error for the juvenile court “to conclude that collateral estoppel barred the father from producing evidence he had not sexually or physically abused his children since DSS previously had prevailed on that issue only under the lesser standard of preponderance of the evidence. The father is entitled in the termination proceeding to have the issue redetermined under the standard of clear and convincing evidence.” (Id. at p. 672.) The court can modify an order made erroneously, improvidently, or inadvertently under Welfare and Institutions Code section 385 without requiring a modification petition to be filed under section 388. (Nickolas F. v. Superior Court (2006) 144 Cal.App.4th 92.) Dates and Documents have been modified , altered , damaged , lost , never submitted , inadmissible , crossed - out , doubled , switched and ultimately entangled into my FAMILY'S case of Juvenile Dependency. Should the parties of Sacramento and Solano Juvenile Court, the Department of Human Services, the "nonprofit parent advocacy group" and any other Does unknown to the PLAINTIFF MOTHER PETERSON continue to falsely imprison, Baby K. Talbot, using the government of California and or Federal Funds and/or hold County authoritarian titles such in this Juvenile Case, it is done with full knowledge to the facts of illegal activity that has occurred and is continuing to the present. I cannot express the significance of this matter, it is the line that has been crossed, and it must be corrected the right way by you in those positions entrusted with the duty to do so. I ask again, to release Jurisdiction of Minor Baby K. Talbot, and any retaliatory actions to be seized instead. If the Appellate Court Rejects Habeas Corpus, than all State remedies have been exhausted and I will file a separate Federal Case of Habeas Corpus.