Judge orders adopted child back to biological parents

If this is not justice gone blind then I don’t know what is. The court is taking a young child form the only parents he knows and plopping him down with strangers, this is in the child’s best interest? I don’t think so. Maybe we should not be so concerned about the rights of the biological parents and more with the rights of the family that has opened their home and their love to this child after all they are the ones that took Scott into their home and have cared for him. The Mother and father were not concerned before and right after the birth to stand up and take reasonability for this new life but now they are so interested in the child.

Just when is common since going to return to the courts. I feel that these judges should be held accountable for all their bad rulings and be allowed to be suited by the effected parties; this would end all the court backups and just maybe free of judges to apply the law as they should. I mean, before we rip the child out of the only home he knows lets subject these biological parents if we can call them parents at all to some kind of tests? Let’s be asking all the right questions before placing the child in their custody. This makes good common since to me. But their I go again injecting common since into the court system, what am I thinking?

The father physically assaulted the mother during her pregnancy. He also has a history of domestic violence, drug abuse and numerous other criminal convictions. She chose to put the baby up for adoption for her own reasons, but also to protect Evan from the birth father and his outrageous outbursts.

Ultimately the birth mother was given temporary custody over the birth father due to his outbursts in court which left the judge who was quoted as saying that "Mr. White obviously still has issues with anger control". The birth father has still not to this day been awarded anything other than supervised visitation.

So, Mr. Warren, know all the facts before you pass judgement. Given the chance I'm sure Mr. White would eventually put his hands on this small child, then what?????

this is another outrageous case of not putting
the childs best interest first. regardless
of what happened 3 years ago these are the
only parents this little boy knows and loves
and he belongs with them. I feel sick inside
just knowing he may never be with them again
and how this will affect him forever.

Oh how interesting and predictable that the birthmother who everyone praises as long as she is willing to have her child taken from her for the benefit of an infertile couple is then blamed for that very decision...adoption is barbaric, brutal and inhumane...does anyone think this child won't suffer to learn he is adopted later in life? You are obviously blissfully uninformed and wish to stay that way...ignorant and hateful, full of contempt for the very people who gave this child life? What's next, stealing the children of the poor in broad daylight and calling that a happy ending too? Sickening...incredibly sickening...

In our endeavor to make sure that our childen are looked after properly, we have
created something that may only have happened 2 other times in civilized
history. A system that takes Children away from their families to get Federal
money. It appears to be a rare thing to those of us that never had to suffer at
the hands of the system. I know that years ago I could not have believed it

Like in Argentina and switzerland, only more sophisticated,Our Juvenile system
is built upon the idea that if children are taken money is paid to children
services, judges, court officers and various support professionals. Everyone
feeding from the same trough. Lets hope thatit doesn't last nearly a hundred
years here.

Even though there are bench guides recommending and telling judges what
decisions they must make at various stages of dependency hearings to get Title
IV money, We thought it would be ok. It's not, by a long shot.

We have created a system where a child is 13 times more liey to be abused in a
foster home than in there own homes. II times more likely to be sexually abused.
and 6 times more likely to die than in their own homes.

A sytem where all of the children living in colonel times or the old west could
be decared to be abused because they had no electricity. Lamps for a day or so
is not good enough. A system that would rather take the children and reap
thousands instead of givng the family $200.00 to pay that electric bill. A
system that is simply too formidable for a poor person, so 90 percent of the
kids are from poor families. A system that can even lie and get away with it
because they have been put in authority to make determinations.

The number of children taken each year by the State can be calculated, not by
some empirical information showing the number of abused children in that State,
but the number needed to balance DCFS budgets.

DCFS with an acquiecent judge can thwart all justice.

I believe some changes in law will make little or no difference if the process
stays the same. As it is now, a bad Judge and CFS could evade all justice.

As long as CFS, Judges, ad litems and other professionals used in evaluating
and providing services to family and children feed from the same trough, there
can be little chance of justice.

As long as the richness of the State is pitted against the poor with possibly
only a court appointed attorney that doesn't have equal monies to spend on
defense as the State has to prosecute, there will not be justice.

As long as CFS is considered an arm of the State with authoritative veracity
and not just another adversary against the accused, no justice will be done.
Why? Because whatever they say is considered authoratative and serious.

As long as there is no real way to get an outside accounting of CFS actions, how
can their truthfulness and integrity be questioned?

As long as they are allowed exclusive control of the child, the process and the
information to be released. there can be little or no justice. How would you
make a measure of it?

As long as the States allows an Agency to take a poor person's children because
he or she had their electricity temporarily shut off for lack of $200.00, yet
the Agency will acquire 1000s of dollars for taking those children instead of
paying that 200 dollars, the situation is darn near hopeless

And as long as there is no regress for victums in those cases that has been
litigated under these conditions inproperly, justice will not have full
sway.Justice delayed is not justice at all.

Wither or not one believes in the Devil, it would be hard to think up a more
thorough way for something to appear benevolent while being utterly evil.

Yet there are a couple of things that would benefically make the system more
likely to protect rights and produce just results.

1. CAUSE CFS, to have to pay (by law) equally for the defense of the accused.
Then the court determine how much the person can reimburse the agancy.

2. A jury of 12. Should I not have a jury of my peers to decide if my Children
should be imprisioned or just if I may go to jail?

3. Allow the light to shine in. appointed ,non paid , Media observers

Any 2 of these things alone would prevent said system from abusing the innocent.


Those that are innocent are reduced to what I am reduced to doing, crying out to
the public. No one wants to hear it. No one believes it The process makes it
all look good and constitutional. Anyone looking over the data cannot easily see
wrong doing, unless there was an attorney that got all the accused objective
iformation in the record. Few do. You need to have lots of money for discovery
and experts gong against DHS.

Here are a series of letters that I sent to the media. that were written at the
time of the evenits. They have not been edited.

I hope somone finds time to read them. Then read what I say DCFS will do next.


Mr. Orielly. This will not be your typical email, I am sure. I think I will need
your help.

My Name is Bill Sullivan. I am a single parent of 3 children that live with me.
One 10 year old girl and 2 boys, ages 15 and 13. I lIve in North Little Rock
Arkansas.

Monday the second of May 2005. I took my little girl to the hospital, thinking
that she had a urinary tract infection.

Arkansas Children's Hospital finally saw her.

There came a point in the examination, when a number of doctors got involved. I
knew something was not right. They told me it was normal in cases like this.

They finally told me that my little girl had herpes. I was stunned and told the
doctor that there was only one way that I knew that she could get this. He
nodded in agreement.

Next thing I knew, social services shows up. and do a recording while I am
still shocked and not thinking critically. I asked them wasn't there different
"brands " (types) of herpes? The social worker didn't seem too sure.

I told them about everyone that I knew that could have had an opportunity to
do something to my child, although I found it hard to believe any of those
people would do anything. I told them everything that I knew. They said that
there was other signs of trauma.

Next , I went to my child and told her what the doctor said. I said that he
indicated that someone had to have done it.She said nothing like that ever
happened. She said that she wouldn't lie to me. She also began to cry, saying
that she didn't want anyone to have been fooling with her. She assured me that
she would tell me if she knew.

I knew she was telling the truth. She would not be afraid to tell on anyone,
because she is still at the age where she believes Daddy would break anyone's
neck. She would not have to be afraid. Therefore I suggested, maybe it happened
while she was asleep. She sleeps deep. She said that she knew nothing of it
happening, but I could tell she believed me that it could be possible. I never
thought that I could be making suggestions that may stick in her mind.

Later as I came to myself. I began to ask good questions to the doctor.

What type of tests were made? could medications, foods and a mixed sample cause
false positives? One doctor called another. They didn't know the answers.
Information was taken from me. I was told a pathologist would call me the next
day to answer those questions. I was also told that the tests may not hold up in
court. The social worker told me that it would hold up and that she had seen
them hold up only on suspicion. No pathologist called. I called to speak to a
pathologist. No one would speak to me.

Children and Family Services, took posession of my child that night. I helped
them by telling her to treat it as a vacation till we found out everything. I
had to do it with a smile. She was looking into my eyes. I knew if I wavered,
she would start bawling. She was told that she (SHELBY ) would be allowed to
call me every day. She was only allowed to call me a couple days.

I called the hospital, to obtain the test records. They would not give them to
me. I was told that I have to go through Social services. I had social services
to call them. Ms. Williams, of social services,said that they was told that the
tests were positive.

The doctor had told me that one of the tests was a culture test. Later I also
found out that those tests takes 2 to seven days to get results. I began to
wonder how I could be told exactly what or possibly what kind of herpes it was
that same night.

I learned that of the 2 types of herpes, type 1 and type 2, type 2 is the usual
genital kind.

I also learned that sometimes type one can be transferred to the genital region.
All it takes is a momentary weaken immune system and transference of the virus
from one area to the other. That could happen by kissing the genitalia or just
simply kissing the infected person on the lips and that person touching her or
himself. Even using the same towels, spoons etc.

I was finally able to get the tests results, by signing documents after the
social worker called.

The test showed these three things.

1. No type 2 herpes antigens (negative)
2. type 1 herpes antigens was (positive)
3. Her Hymen was intact.

After doing due diligence, I found that Children and Family Services can
interpret almost any disturbance as trauma. Examples; scratching or rubbing the
area.

After reading horrendous cases of false allegations today, that was later
reversed , sometime years later, I am very concerned.

The social workers treated me with kid's gloves, saying at times , everything
will be ok.

Today, I received a summons for court tomorrow evening 4pm.

I thought that after seeing it was type 1 and the fact that about 100 percent
of people get it at some point in their lives, as (Fever blisters) on their
lips, They would be ready to give her back.

Here in Arkansas, DHS and family services get paid thousands of dollars for
placing a child.

I found out today that they are suing me for permanent custody.

What's even scarier is I wasn't thinking that I needed an attorney. I talked to
one, but it seemed unnecessary. The attorney had told me not to trust them. Now
I have to appear and my attorney will not be back in town till a day after
court. She and I did not know of a court date when she left town.

Now here's the scariest thought of all. It is in the same court where a few
years ago, the State tried to sue me for Child support, even though they had
documented evidence that the children has always lived with me. I take care of
them without child support or any aid from the State. The documented evidence
was (get this) from Child support's own chief investigator and from DHS. The
Process was not going to allow me to say those FACTS. I spoke up anyway so it
would be part of the record because I was told that I cound not make speeches,
just answer questions.

I was threatened with contempt of court, when I asked, " Why are we wasting the
taxpayers money, and just who will I pay child support to, myself?"

Mr. Orielly, this will be the 3rd time that I have taken on the State. I won the
others. This time I am doing it unemployed or rather doing everything I can to
stay above board, without an employer.

All the pertinent things that I have told you are a matter of record.

I am going in without an attorney. If I have it put off till my attorney gets
back. They could have Shelby for months till a new hearing. It could happen
anyway.

Bill Sullivan
501-612-5890






SECOND LETTER: the day after court. (May 13th 2005)


Mr. Oreilly.
We went to court yesterday. I was right it was the same court, same Judge that I
sat under 4 years ago, in a child support hearing. She brought up the fact that
she did remember me in a disparaging fashion. She made it plain that I would not
be allow to say anything but what a court appointed attorney would ask. I
didn't ask for one. He was appointed at the hearing. It worked against me.

He approached me saying that the court had appointed him. I accepted it after he
said that I would be allowed to tell the Judge how it came about that deceptions
was used to get my child into DHS custody. I told the Judge. She would not allow
me to speak, except for about a minute and a half and that at the questions of
an attorney that didn't know what to ask of me.

She asked me if I had any previous encounters with DHS. I said not like this
one, and started to tell about the encounters. In the first sentence, she cut me
off and would not allow me to speak. Later she tried to accuse me of lying. I
reminded her that she stopped me from talking.

I have been before Judges before. I even argued my divorce from my first wife.
No children was involved. I am a pleasant guy. everyone says I am too nice. For
some reason, this judge cannot stand to allow me to talk. Somehow this one
person seems to have an aversion to me.

My court appointed attorney met with me and told me that DHS would win so we
were going to go along. I told him NOT SO, that DHS did not have a case. I said
that they may have had a reason to take the child at first but not after the
test results have come out positive for hsv-1. Doctors had told me it was hsv-2
and that it only was caused by sexual contact.

I explained that virtually everyone gets hsv-1 in their lives and that it can
be transferred by hand from friends , relatives or ones self to the genitalia.

He then went and got a fax from the doctor at Arkansas children's hospital that
let him know that the test used was an antigen test. That it was not certain
that it was even hsv-1. One thing that is certain is that it is not hsv-2.

My child's Hymen was still in place, doctors noted. She is still a virgin. (No
telling what will happen in foster care)

You may also want to know, that the antigen test cannot tell when , where or how
she first got hsv-1.

DHS was asking in court that the whole family be tested. I tried to explain that
since all of us in the family have had "FEVER BLISTERS" (hsv-1) and everybody
gets it sooner or later, it would prove nothing. It would just be an extra cost
to the family, with a Dad that is currently self employed while looking for
permanent work. I was not allowed to speak and the attorney was still just
getting acquainted with what it was all about.

My daughter told me that they told her that if she told them who did it , she
would get home quickly. She finally told them that her cousin might have done
something in her sleep. She thought she was coming home. I told her that she
had an attorney. She promptly asked me. "WHERE IS SHE? Shouldn't she be here?"
I didn't know how to answer.

When DHS got the new information from Children's hospital, my sister who was not
allowed in courtroom and was sitting in a separate room, over heard them
talking. They were wondering if they still had a case.

They didn't need one.

My Daughter finally got to tell her Attorney the promises DHS made to her, my
sister said. My sister even mentioned it to her attorney. When she came into
court, she never brought it up in court proceedings.

All we asked, was for my child who said that she had been crying everyday, be
allow to come home. DHS could keep the case going if they liked. There was
simply no reason that the State should continue harming my child's mental and
psychological well being.

Mr. Oreilly. I have watched and listened to you a long time. I know your care
for the children, but I need this story told. Governors cannot look into the
records of Children and Family services. They even have the right to burn their
own records, is my understanding.

They have become as grand inquisitors in my Family's lives and there is no one
to hold them accountable.

The Judge even brought up my past encounters with DHS to make a decision about
DHS keeping Shelby. She held it as strikes against me. Since I won the cases,
shouldn't she have held it as strikes against DHS?

My Child whom I had given so much hope that the system would work, dropped to
the floor when she learned what happened. I had to leave her in tears. I assured
her that I will do whatever it takes to let the world know what it going on here
, with her and my family. The Harassment we have received over the years .
without good reasons.

Please, tell the world. Don't stop telling everyone, till either me or DHS gets
what it deserves. My child deserves better.

Bill Sullivan
501-612-5890





INVESTIGATION DROPPED as unfounded (written May 13th 2005)


Mr. Oreilly,
I just learned today from Detective Julie Rose and North Little Rock Police
department, that they had dropped the investigation against me. Her number is
501-771-7154. She said they not only dropped it as unfounded, but notified the
lead attorney for Children and family services before court yesterday. His Name
is Mr. Honorable. I believe she said that she also told someone else in a
supervisory position at DHS.

Yet in court Children and Family Services argued that one of the reasons to keep
her was that there is (THEY SAID) an ongoing investigation by North Little Rock
Police Department.

Please check these things out. I know they are true. There is an ongoing
injustice here. I need it to be public so no one else will ever have to go
through this again.

Bill Sullivan
501-612-5890
North Little Rock, Arkansas


Mr. Oreilly.

Update on case DHS child protective services VS. Bill Sullivan.
Wed May 18th 2005.

I filed an exparte motion to the court to set aside its prior order because
DHS intentially lied to the court , saying there is an ongoing investigation.
There is
no such investigation going on. That was Mon. 16th 2005.

I left court the evening of May 16th 2005. As I was leaving court, I called DHS
to set
up visitations per the courts order. The person that I talked to could not
locate the
File. She said that she would find it and have someone call me.

My fledgling business is suffering.

Tuesday MAY 17th, 2005

I did research most of the day. The attorney that I have decided to use finally
call
me back. She had made it back in town. I told her that if she is going to run
off, now
would be a good time because I was intending to sue DHS. I said I know of no one
that
has really been successful, but I was going to do it how ever hard and
regardless of
the time that it would take. I told her that I could not believe this sort of
thing could happen in America.

The social worker called me later in the afternoon. She set up visitations on
recurring Thursdays at 9:30 am. These will began on May 19 2005. The court said
2 hrs. 2 times a week.

She also told me that after visitations, I will need to tell her about
everything that has happened in my life, beginning from childhood till now. That
she had to set up home visitations. She also mentioned an invitation that she
will send me, to another meeting.

I told her to talk to my attorney.

The investigation has been dropped by The police as UNFOUNDED, yet they keep
going and going Like the energizer Bunny. In their minds, I am guilty till
proven innocent.

Now AM I CRAZY? Since in Arkansas, they cannot investigate in a case when the
child is 10 years old or more and since the legal investigator (North Little
Rock police Dept) has
dropped the allegations as unfounded, These people are violating my rights. Can
they now declare it to be so, even though the investigation says it's not?

The Media and everyone not a principal, are excluded from hearings. They have a
process
that does not allow plain logical exposition in court, or many cases would end
right then
and there. All the participants except the defendants get monies from Child
protection services. This includes, Judges, ad litems, appointed attorneys,
social workers, psychologists and other so-called experts. All these people
huddle together and go along
with the plan. Whatever DHS says is excepted, even when the facts differ as far
as day is from night. They are immune from prosecution and do what ever they
want to do.

I believe , that only intense public attention and examination can have a hope
of breaking up this corruption.

If these people can do this with an allegation dropped as unfounded. What can
they not do?

I am contacting everyone I can think of. Governors, Senators, Congressmen,
advocates, media. No one has given me a clue of how to defeat this, so I endure
and press on.


Just an update. Makes me feel like I am fighting back, even though nothing is
happening.

I wonder how my child is doing!


Bill Sullivan
501-612-5890


EX-PARTE MOTION


THE CIRCUIT COURT OF PULASKI COUNTY ARKANSAS
JUVENILE DIVISION

ARKANSAS DEPARTMENT OF HUMAN SERVICES PLANTIFF

VS NO.

JENNIFER LYNETTE HILL (DOB 7-22-71, SSN 432-49-9203) MOTHER
WILLIAM SULLIVAN SR. (DOB 10-23-53) LEGAL/PUTATIVE FATHER OF

SHELBY LYNETTE SULLIVAN (DOB 2-28-95, SSN 432-87-8359)


EX-PARTE MOTION TO SET ASIDE

Comes the Defendant William Sullivan Sr. and for his answer to the complaint
filed herein against him in all documents and orders issued from this court
and extensions thereof in the matter of which plantiff brought before this
court;

Be it known to this court that plantiff secured an order obtaining probable
cause on false and misleading contentions. Neither did this court hear
information from ad litum that is required by law. Witness the facts below:

A. Plantiff argued before this court that Defendant's child should be held in
Child protective services,in part, because there is an ongoing investigation.

1. Detective Julie Rose of North Little Rock Police Department (her number
(501)771-7154)
had closed the case as unfounded. Furthermore she had notified DHS's Lee
Honorable Office of Chief Counsel (His Number (501-682-8934) She also left
notifacation for The social worker in this case Ms. Williams. Both things were
done before this court heard this case.

B. Below are the Arkansas Supreme Court rules for the attorney ad litum. Here
after referred to as AAL.

AAL Standards of Practice

AALs shall conduct an independent investigation of the case, either personally
or in conjunction with a CASA. The investigation must consist of a review of
all relevant documents and records, interviews with the child, and in
conjunction with a trained CASA volunteer, when one has been appointed,
interviews with parents, foster parents, caseworkers, and service providers,
school personnel, and others having relevant knowledge to assist in
representation;

AALs must continue to investigate and maintain regular contact with the child;

AALs shall determine the best interest of the child and shall present all
relevant facts to the court including the child?s wishes when they differ from
the AALs? determination of the child?s best interest;

AALs shall meet with his or her client prior to every hearing and shall make
earnest efforts to attend all case staffings, hearings, and court-ordered
mediation conferences;8

AAL shall advocate for specific and appropriate services for the child and
family, request orders that are clear and specific, monitor implementation of
case plans and court orders, file appropriate pleadings, review the progress of
the child?s case and advocate for timely hearings; and

A full-time AAL shall not have more than 75 dependency cases and a part-time AAL
shall not have more than 25 dependency cases, unless approved by the AOC.

2. Not only did NOT AAL interview defendant, but AAL did NOT notify the court
per the standards. because shelby requested her to tell the court DHS made
promises to her to allow her to go home, if she just told them who did it.
Neither did AAL notify the court that Detective Rose of North Little Rock Police
department, noted in Shelby's deposition that Shelby HAD TESTIFIED the same to
detective Rose.

Defense prays on either of these facts alone or together the order issued from
this court may 13th granting continuing probable cause for DHS to hold Shelby in
protective services AND in foster care, should be set aside.

IN ADDITION, because the court sited previous encounters of defendant William
Sullivan with DHS, the defence cites these facts that are available to the
court.

1. Defendant Won those cases. If they are to count as a strike against any of
the two parties, plantiff or William Sullivan, it should be held against the
looser of those cases, DHS. Otherwise, even winning a case will work against a
defendant.

Even though these Lies and errors have now been shown, the court may still for
reasons we cannot understand, be careful because of information in plantiff's
ex-parte custody petition affidavit, We also present before the cout the
following information and facts.



IN THE EX-PARTE CUSTODY PETITION: (AFFIDAVIT) of plantiff:

2. The statements in number two in the affidavit are false and misleading.

First paragraph. Doctors indicated to me and therefore family services, that
they believed it was type2 genital herpes and only could be caused by sexual
contact. Culture tests can take 2 to 7 days to get a result. Genital herpes
type2 is almost always caused by sexual contact. (almost) It turned out that the
tests ,once the cultures were grown, showed only positive for type 1 antigens.
Type 1 herpes is eventually gotten by about 100 percent of us citizens. It can
be auto-transferred to other parts of the body. Neither can an antigen test tell
when , where or how a person got fever blisters. One of the doctors told me,
that they could not say, it would hold up in court.

I told a social worker. She said that it would hold up, because she has seen it
hold up on suspecion alone. Suspicion alone is not a reason for holding and
placing a child in fostercare. violating both the child's and the parents
constitutional rights.

Defense contends, that this Whole matter really began with this
mis-understanding and grew.

For example: Paragraph 2:

I, William Sullivan, was made to think by Doctors and Social workers that it had
to be sexual, so I talked to my little girl. She said it didn't happen. I told
her it had to be true because the Doctor said so. I tried to think and get her
to think of a way it could have happened. We thought about sleep. I suggested
that maybe it happened while she was asleep. She said that she knew nothing of
it. I could tell that she was telling me the truth, that she knew nothing of
it. So we decided it had to be when she was sleeping, maybe. Never entered my
mind, that DHS would use it. I was trying to be helpful. She later suggested it
as possible that her cousin did it while she was sleeping


So when we both mention Sleeping as a possibility, it was my idea planted in
Shelby. She trusts me. Also I never said it happened. I said if it happened , it
had to be that way. I still thought it was type 2.

Paragraph 3.

Armed with this information, Shelby under well orchestrated pressure by social
services, even at school, answered like I did as a possibility. After all if
Daddy and all the nice people, including Doctors say it happened, it must have.
Having to choose between her brothers and her cousin, whom she loves also, she
said maybe. Even DHS documents show this. Shelby is more direct about what she
said and why she said it.

In addition to this, during the firsT days of her captivity, she was allowed to
talk to me. Shelby told me that it looked like they were trying to get her to
say something that it may help her come home. Detective Julie Rose, of Noth
Little Rock Police department Says Shelby told her the same. She has
discontinued the case as unfounded.

Paragraph 4

I have had Shelby all her life. I have protected her. She is my little girl and
she has a special relationship with her Dad. What Family services has done will
harm her mentally and psychologically. They never had a right to violate my 4th
and 14th amendment fundamental right to privacy. They also violated Mine and
Shelby's Rights against search and seisure.

They had taken away all contact rights promised by them , to allow her to
contact me at least once a day until they obtained the extended order on the
13th. She is sequestered. cannot see her family. Foster homes have been under
fire for being more dangerous that being with the people that children know and
love. The deaths an abuse many foster children suffer are horrendous as has been
reported. publicly.

In addition, Robert Chandler, My Nephew, is no longer in my home. He is
Married. He and his wife has gotten back together.

In addition to these points I deny any other statements expressed from plaintiff
that abridges my role as a sovern parent, with all of the rights a parent has
under the US Constitution.

Because of these false allegations and mis-representations,

Whereas; there never was any imminent danger for Shelby and that the sole reason
for the beginning of this process was misrepresentation (HERPES SIMPLEX 1)
everyone gets sooner or later and one can AUTOINNOCULATE onesself to other
regions of the body. (See documents submitted) The continuation of this process
has been based upon lies fostered upon this court by DHS.

Whereas; depraving shelby is causing her distress and much crying and
psychological effects that will surely be remembered all her life.

Whereas; plain verified and verifyable facts herein show that plaintiff obtained
Court order for probable cause with knowingly false information.

WHEREFORE, Defendant prays that the Complaint filed herein and all court orders
against him that came forth thereof be set aside; for his costs herein
expended; That the court will correct the injustice by ordering DHS to return my
daughter Shelby, not accepting further submissionsthought up by them to keep my
child and for any and all other just and proper relief.

____________________________, Pro Se
William T Sullivan
17 NEAL PLACE
North Little Rock, Arkansas,72217
Phone number: 501-612-5890




CERTIFICATE OF SERVICE
I hereby certify that I have this ____ day of _______________, 200___, served
[Lee Honorable, Office of Chief Counsel , P.O. BOX 1437 slot S280 Little Rock,
AR 72203-1437 (501)682-8934 with the foregoing Answer by placing same in the U.
S. Mail with sufficient postage attached.
_____________________________
[Signed]



By Bill Sullivan


Update: June 3rd 2005: Trial date extended....


We went to court yesterday only to find out that DHS asked for an extension

and received it. Now My Child has to wait till the 23rd to learn her fate.


A week and a day ago, Thursday the 26th of May, I met Shelby for a visitation.

I noticed
that it looked like she had not brushed her teeth. I mentioned it and the case

worker was watching.


The case worker noticed the way my whole household interacted with Shelby.

Shelby mentioned that I should bring her more clothes. The social worker said

that it would not be necessary because they have vouchers for that.


We had a great time. All of the family.


The social worker, Miss Carter, told Shelby that this would probably be the

last time for
visitations. She said the final decision would be up to the Judge, but that

she and her co
-workers had been talking and could,for the life of her,see no reason why she

should not be returned to me.


My Attorney was out of town. Miss Carter told me that she had to write a

social history of
my life and do a home visit. She did not say it was court ordered at that

time. I mentioned that I had talked to my attorney and had no intention of

giving up my privacy rights.Everything that I have heard says that these

people, when they have nothing, will seek something in your house of past life

to boaster their claims. So I was not about to do anything without my

attorney.


The day before, Wednesday, A Ms. Debora Hudspeth, called me. One of the State

Representatives that I had contacted had requested an explaination from DHS of

why they continued to hold my Child. She wanted to know the child that was

involved full name. She also said that they had to have a response ready for

the representative by Tuesday the 31st. She said that I would get a copy. It

is the 3rd of June and I was told today that by Monday I should know

something.
something.


If was after this that I begin to hear good things about Shelby being released

at the trial.


Friday, I got a letter from Arkansas State Police's Matt Caton, Stating that

they also found the allegations as UNFOUNDED. Now, both North Little Rock

Police department and the Arkansas State Police agrees with me. The evidence

does not support a claim of abuse.



THE STAFF MEETING:


May 31st 2005, my attorney and I met with DHS chief attorney, the foster

parent, Shelby,case worker ms. Carter and someone else from DHS.



In these meetings DHS outlines many pages of a plan to supposedly rehabilitate

a family for reunification. I remember thinking "HOW ODD". All this for a case

that the social worker can see no reason to continue.



I give it to Miss Carter, She gave a glowing report of my family with only

what she observed of us.


The foster parent did something totally different. She said that when she saw

Shelby, She was the most unkempt and scraggily looking child that she had ever

seen, She said that the child Stank and that it took 2 weeks to remove the

oder. I know this could not possibly be true, but I will save this for court.I

was shocked and caught myself shaking my head slightly, but I held my piece.

Now I began to think that I might be seeing the beginnings of a new strategy

of DHS.



Now the ad litem had her chance. She asked my attorney if she had advised me

to disobey court orders? My Attorney assured her that She had only recently

been retained and had not seen the order. She only advised me to allow her to

see anything before I signed onto anything.


Next the ad litem asked my attorney if she had anything to do with the ex-

parte motion to set aside the order because of falsehood and misrepresentation

on DHS' part. The motion also outlined by quotes from the Arkansas Supreme

court how that the ad litem had violated standards of her office. I have

explained this before, but in a nutshell, the court says an ad litem for a

child should do her own investigation, interviewing all revelant witnesses.

She is to also, represent what the child voices to her even if she disagrees,

along with what she thinks best. She did none of these things.



DAY OF COURT: June 2nd 2005


My Attorney was there before I was. She got a chance to talk to Shelby. I wish

I had not sat in the parking lot for 5 minutes. I only saw the attorney ad

litem getting in her car. Shelby was gone and I had expected to be able to

take her home as the Case worker had thought would likely happen.


I found out that the Judge, whom I have previously described as seeming to

have an aversion to me, was not there. We would have been under another Judge

(A blessing).When I think of it though, this is more insidious that having to

litigate under a new Judge. In fact if you are allowing the Child to go home,

what does it matter which Judge presides. No this was intentional with the

express purpose of saying that Shelby was not coming home. I had dared to

accuse my opposition (individually by their names) =of specific things that

could have to be accounted for before the supreme court of Arkansas, before

this is all said and done.


They had offered my attorney to have me sign a document saying that I had

ALLOWED MY CHILD to catch a Germ.(See letters to Mr. Orielly) My attorney

thought they were nuts.The bottom line is, my Child is still in captivity and

all the emotional distress that comes with being stripped away from your

family without a reason.


Bill Sullivan
501-612-5890



UPDATE SULLIVAN VS DHS 06-23-2005

I am sorry to say that I didn't get Shelby back today in court.
We got to court and my daughter was very happy to see me. She began
to tell me and my Sister about how the foster Dad had threatened to
hit her in the head with what she described as a fishing pole carrier
if she rolled her eyes at him just one more time. She assured me that she never
rolled her eyes.

I told her to tell her ad litem, so that I would not be accused of
discussing the case with her. She said that they never listen.

Everything seemed to be going fine at the trial until I got word that
Shelby was turning State's evidence. She was now saying, I was told,
that her cousin did it to her. I was shocked! She had always told me
that they were pressuring her to say he did. Now I thought, maybe,
she had finally broken. I thought, what child traumatized by familial
separation, could hold up very long. How could she consistantly resist
with no outside support. The only people that could talk to her about
the case was DHS. All her cries to her ad litem,had fallen on deaf ears.

Then another shoe dropped.

The same Judge that has granted probable cause in her previous order.
The same Judge that stated on the order that one of the reasons she
decided probable cause was because of an ongoing North Little Rock
Police investigation, now was saying that it was not relevant to the case.

You may remember that I had filed an ex-parte motion to set aside the
order because DHS has hidden the fact that the investigation was dropped
as unfounded. Documents submitted proved it.

It is ironic that the people breaking the law,the very person to whom
North Little Rock police had spoken to,said that it was not revelant
and the Judge concurred.

The ad litem got off the hook with breaking Arkansas law also when the
Judge allowed none of that evidence showing neither the lying nor her
refusal to follow the rules of an ad litem as laid down by the Arkansas
Supreme court.

Then an unexpected shoe dropped.

They called a young doctor to court that had treated Shelby in Children's
Hospital.

Under questioning by my attorney,he admitted:

1. The PCR test tested positive for hsv-1 and negative for hsv-2
2. That if Shelby ever had fever blisters, she would have tested positive
for the hsv-1 antibody at any point after.
3. That the PCR test could not tell,when, where, nor how Shelby got hsv-1.
4. That Hsv-1 could be auto-transmitted from one area of the body to
another. Even if she touched someone else's fever blisters.

Then everything went crazy. He was asked,that in his professional opinion
how did shelby get hsv-1. He said by mouth to genitals or genital to
genital. Thus in one sentence, he contradicted all that he had just said.
After all,he said,she could not have been born with it.

This young Doctor, get this, is having his graduation ceremony this evening
at 6 pm. He has had only one case of genital hsv-1 in a child. That child
is Shelby.

Another tragedy happened, all of a sudden a little girl (whom I cannot name,
because of court order) would finally to be allowed to testify. This she had
wanted to do for quite some time. Her ad litem would not cooperate.

My attorney, had tried to get her ad litem to allow her to ask the little
girl a few questions,to no avail. Now She would say what the State wanted.

I overheard what happened. This in itself was miraculous. These things are
usually kept very secret. That way no one will know of any injustice. It was
thought up as a way to protect children. This secrecy has permitted a
currupt system to operate without real oversight.

I could possibly go to jail for telling this.

What I overheard was that this LITTLE GIRL, had pulled one over DHS' eyes.
While on the stand, she told of how she lied to her ad litem. She said that
she knew lying was wrong, but that they promised her to allow her to go
home. Furthermore, it was the only way that she got to tell what her ad litem
refused to tell in court.

This little girl also told about how her Foster Father threatened to knock her
out cold with an instrument. She mentioned other abuses in Foster care.

This smart little girl had out-foxed all those feeding from the trough of DHS,
or so it seemed.

When the Judge made her decision,she ignored all the little girl's testimony.
She only mentioned the story told the ad litem by the little girl,to get a
chance to testify. She used it as a reason to keep her in foster care. Held by
the same people that has brought so much trauma upon her.

In my testimony under questioning,I pointed out that Shelby's mother
sometimes had gotten fever blisters before she was born and that Shelby had them
before this incident. I pointed out that the young Doctor was wrong because
under those circumstances, many had gotten Hsv-1 and hsv-2 at birth.

I offered information from the Center For Disease Control (CDC) and the Journal
Of Clinical Microbiology. I said the information was open to everyone.

Here is one quote from the Journal Of Clinical Microbology, A SIX YEAR STUDY.

http://jcm.asm.org/cgi/content/full/39/9/3321

Nonsexual transmission of HSV-1 also may occur by autotransmission. This could
include transmission of viral particles from oral lesions through the gut to the
perineum or by the direct inoculation of virus to the genitals on fingers or
fomites. The parasthesias associated with herpes labialis often lead patients to
repeatedly touch the infected lesion. Virus carried on the fingers could then be
transferred directly to the perineum during the placement of tampons or
indirectly transferred on toilet paper if adequate hand washing prior to
toileting is not performed. In vivo studies of autoinoculation from one site to
another with the patient's own strain of HSV has been demonstrated to cause new
foci of disease and reactivation (24). The spread of genital HSV onto the
patient's fingers or eyes or onto mucocutaneous sites adjacent to primary
genital regions late in the disease course suggests that autoinoculation is a
common occurrence (7, 14, 33). It is unclear why this rate of transmission would
be showing such a dramatic increase with time, unless it was concluded that
personal hygiene and hand washing practices have changed significantly.


I also had a report by the CDC,where a near epidemic of hsv-1 of various parts
of the body broke out in minnesota among high school wrestlers.

No one cared. You can't cross examine the CDC. I didn't know anyone questioned
the authority of the CDC.

I was asked if I would allow DHS into my house during questioning. I have to
admit,the social workers that had gotten to know me and my family, tried
their best. They said great things about me and my family. They recommended
that Shelby be allowed back into the home, only that they would monitor to make
sure certain people would not be allowed in my home.

I intimated that I would allow the devil in, if my child was allowed to come
home. (Of course I would need to be ready with an exorcist) I pretty much feel
this way about this EVIL entity.


To make a longer story shorter. The Judge gave her decision. She said that since
the doctor said it had to be transmitted sexually, DHS was to keep
Shelby.

The Judge looked me in the eyes, and said that it seemed like I needed some
psychlogical therapy, because I did not believe my child had been molested.
I am to pay child support,and complete other services. I was told in no
uncertain terms,that if I did not follow the regimen, my child will be given
to someone else.

I have allowed Shelby to believe that we are on track to go to counselling
together and that we could be together then. I am certain that DHS never intend
to give me back my child, whatever I do.

I will never allow it to stand!
Some how, some way, we will be together again.

Bill Sullivan
bsullivan79@comcast.net
501-612-5890


PREDICTION:

Athough, I have never been accused of needing a therapist, the therapist for
DCFS will find that I needed help. He Will likely find that I am in denial and
when I do not write an essay or somthing showing that I accept DCFS findings.
That by itself will be reason for them to keep my beautiful dhild. She thinks
she is coming home around August to October I have to let her think this. It
would be too painful for her to think otherwise. DCFS gets paid 5 different ways
for kids that they take all the way to adoption. When they give the Child back
to a family member the money stops. Do you know what those 5 different ways are?