JANET NAPOLITANO & OTHERS SUED - FAILURED TO STOP ILLEGAL AND POLITICIZED DEPORTATION

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UNITED STATES DISTRICT COURT
DISTRICT, MASSACHUSETTS

CIVIL
ACTION

NO.

COMPLAINT

OFUME FAMILY (PHILLIP OFUME, et al)
Plaintiff (Pro se &
Forma
Pauperis)

v.

1. JANET NAPOLITANO

2. US FEDERAL BUREAU OF INVESTIGATION, BOSTON, MA

3. DOMINIC FREDERICO

4. US IMMIGRATION AND CUSTOMS ENFORCEMENT (ICE)

5. MAJOR LOCKHART

6. LYNN POLICE DEPARTMENT

7. SUFFOLK COUNTY HOUSE OF CORRECTION

8. NANCY NORMAN

9. BOARD OF IMMIGRATION APPEALS

10. BRUCE CHADBOURNE

11. MASSACHUSETTS PRO BONO ATTORNEYS (Greater Boston Legal
Services, Catholic Charities, PAIR Project and International
Institute of Boston)

12. ROBERT HALPIN OR IMMIGRATION COURT ADMINISTRATOR.

Ofume family v. ICE et als 2/37

Defendants

_______________________________________________________________________________

PARTIES

Plaintiff

1. The Plaintiff, Ofume family - Phillip Ofume (Father) , Maureen
Ofume (Mother), Kleber Ofume (son) secretly deported to Nigeria on
March 10, 2009 whereas the family‘s appeal is pending before 9th
Defendant, Keynes Ofume (son), Isabelle Ofume (daughter), Lynda Ofume
(daughter), Barnett Ofume (son), Christian Ofume (son) and Gloria
Ofume (daughter) is resident of Lynn of Massachusetts of the United
States and Refugees and stateless person, Asylees and lawfully
admitted in the United States on September 29, 2005, granted Credible
Fear of Torture or Persecution on October 7, 2005 and paroled for one
year (October 12, 2005 - October 12, 2006) and the Plaintiff‘s Asylum
case is active and pending before US Board of Immigration Appeal
(BIA).

Defendants

2. The Honourable Janet Napolitano is the Secretary of the Department
of Homeland Security (DHS) and she is one of the federal actors of the
government of the United States of America contacted several times
regarding the secret removal of Kleber Odimegwu Ofume to Batavia,
Bufallo and the call continued directly on Ms. Napolitano when 3rd,
4th and 10th defendants were working in concert loading Kleber and
other deportees en-route to Nigeria and other countries.

3. US Federal Bureau of Investigation (FBI), Boston, MA is one of
the federal actors of the government of the United States of America
contacted several times regarding the secret removal of Kleber
Odimegwu Ofume to Batavia, Bufallo.
Ofume family v. ICE et als 3/37

4. Mr. Dominic Frederico is resident of Boston of the State of
Massachusetts and he is the case officer assigned to Kleber Odimegwu
Ofume, January 7, 2009 (date of arrest, detention and ex-
communication) and federal actor and remained case officer up to
deportation to Nigeria.

5. 4th defendant, US Immigration and Customs Enforcement (ICE) with
its state head office in Burlington, Massachusetts. ICE, MA is a
federal agency and directly facilitated the unconstitutional or
illegal deportation of Kleber Odimegwu Ofume to Nigeria where his
parents are facing treason and other political charges.

6. Major Lockhart is resident of Boston of the State of Massachusetts
and she is in charge of the detention of the 7th Defendant and one of
the state of Massachusetts’ actors responsible for detaining, ex-
communication blocking the line of communication between Kleber
Odimegwu Ofume and his parents and their access to the right to
interaction, information relating to reason for arrest, detention and
ex-communication, bail motions by parents on behalf detainee, etc.

7. Lynn Police Department is police department in-charge of the City
of Lynn of the State of Massachusetts and it is named the informant
which issued fake information which led to the arrest, detention and
ex-communication of Kleber Odimegwu Ofume.

8. Suffolk County House of Correction is a detention facility
located in Boston of the State of Massachusetts where Kleber Odimegwu
Ofume was inhumanely detained January 7, 2009 through unknown date of
disappearance from the facility.

9. Ms. Nancy Norman is Attorney of Record resident in Lynn of the
State of Massachusetts and major actor in chain of conspiracy which
fixed Kleber’s deportation.

10. Board of Immigration Appeals (BIA) is one of the federal actors
of the government of the United States of America which received
several complaints for stay of deportation and secret Removal of
Kleber Ofume to Nigeria. Kleber’s, parents’ and siblings’ notice of
Ofume family v. ICE et als 4/37

appeal, different applications, complaints, petitions, application for
summary disposition/judgment, etc were pending and active before 9th
defendant under Lead File No. #A 97-446-370 with riders A# 96-416-429,
A# 96-416-430, A# 96-416-431, A# 96-416-432, A# 96-416-433, A#
96-416-434, A# 96-416-435.

11. Mr. Bruce Chadbourne is at all material time the Field House
Director of the US Immigration and Customs Enforcement (ICE) in
Massachusetts. Mr. Chadbourne is one of the federal actors of the
government of the United States of America who received several
complaints on the status of Kleber in the United States and reason why
he appeared before ICE on January 7, 2009 at Boston Logan Airport and
BIA base reason why Kleber is not deportable or removable from the
United States pending determination of appeals through The Supreme
Court of the United States.

12. MASSACHUSETTS PRO BONO ATTORNEYS (Greater Boston Legal
Services, Catholic Charities, PAIR Project and International
Institute of Boston) are Pro bono attorneys of Boston of Commonwealth
of Massachusetts and they give legal assistance and representation to
poor peoples and other considered vulnerable. Plaintiff know 11th
defendant through Immigration Judge Thomas M. Ragno, Office of
Governor Deval Patrick, US District Court and Massachusetts Bar
Association.

13. Mr. Robert Halpin is Court Administrator of US Immigration
Court, Boston. Mr. Halpin is resident of Boston and he is one of the
federal actors of the government of the United States of America who
received Plaintiff’s (parents’ ) prop se or self-representation
(Kleber Ofume) Bond and Bail Motions on behalf child in Prison custody
or detention because of Plaintiff’s inability to find attorney in
January 2009.

JURISDICTION

Ofume family v. ICE et als 5/37

14. The United States District Court of the District of Massachusetts
has jurisdiction over this Complaint pursuant to,

a. United Nations Convention of July 28, 1951 - Deporting Asylee or
Refugees to country where they fear persecution or torture and death.
Parents of the child deported to Nigeria are facing treason and other
political felonies in Nigeria. In Nigeria conviction is death by
hanging or public firing squad and rarely get life in prison.

b. United Nations Convention Relating to the Status of refugees
(“CRSR” ) and Convention Against Torture and Other Cruel, Inhuman or
Degrading Treatment or Punishment (“CAT”) and Universal Declaration of
Human Rights (12/10/48);

c. US Immigration and Nationality Act Title 8 Chapter 12, Subchapter
II, Part I Section 1159 – Adjustment of Status of Refugees.
Plaintiff‘s case is pending before BIA and Plaintiff (seven children
including Kleber Ofume and two parents) is waiting for BIA’s Decision
when Kleber was forcibly rift from parents and siblings and entire
family and sent to Nigeria;

d. Title 8 Chapter 12, Subchapter II, Part I Section 1158 (3)(c)
including Section 1157; etc

e. US Federal Tort Claims Act particularly 28 U.S.C. sections 2674
and 2675 (a); Title 5 U.S.C sections 702 and 704; etc.;

f. United Nations Convention on the Rights of the Child (1989) and

g. US CODE: Title 28:2241 - Violation of Habeas Corpus and negligence
under sec. 2255. Power to grant writ was delayed and the family that
is in pain continued to ask “Why?” Pro bono Attorneys and others in
Massachusetts conspired, Pro se efforts for detained person were
sanctioned and secretly embargoed to carry out unlawful and moneyed
deportation of Kleber Ofume.

Ofume family v. ICE et als 6/37

h. U.S.C, Fourteenth Amendment - Due Process was stalled as if it
lacks place in the United states in Kleber’s case. In breach of Due
Process proceedings, the worst part is that the US District Attorney
was served Kleber’s parents’ Petition for Writ of Habeas Corpus
(Federal - 28:2241) and Bail Motion delivered to the Clerk and it
appears 8th Defendant served her purported Bail Motion on the US
District Attorney.

i. United States Constitution, Bill of Rights and Human Rights Act
and United Nations

j. The Constitution of the United States of America - 42 U.S.C.
sec. 1983 or Bivens action;

k. Eight Amendment to the United States Constitution - Kleber
Ofume was arrested, detained and ex-communicated without criminal
record and subjected to cruel treatment including but not limited to
chaining and handcuffing him from head to toe and while the handcuff
and all-body chain remain in place the child (Kleber Ofume) was fed by
stranger better than monkeys are fed.

l. Federal Rule of Civil Procedure 5.1. - Constitutional Challenge
to state and federal Statutes.

m. In this Complaint, the Plaintiff raised US and International
Constitutional STATUTE issues directly to this Court, United Nations
High Commission for Human Rights (UNHCHR), United Nations High
Commission for Refugees (UNHCR) and US state and federal secretaries
of Justice and Attorney-Generals, for the enforcement of their human
and constitutional rights and seeks immediate and unconditional return
of Kleber to Parents and siblings in the United States of America.

n. Plaintiff requests that subparagraph 14 (m) and related paragraph
above include EMERGENCY JUDICIAL INQUIRY with Jury claim.

Ofume family v. ICE et als 7/37

etc.

APPORTIONMENT OF FACT AND MISCONDUCT - PLAINTIFF, DEFENDANTS, ETC.

A

Plaintiff - Ofume family (Phillip Ofume, Maureen Ofume, Kleber Ofume,
et al)

15. This joint family Action or Complaint against the defendants
for forcibly deporting one child (KLEBER ODIMEGWU OFUME) of seven
children and two parents resident in Lynn of Massachusetts of the
United states of America to Nigeria where parents are facing treason
and other political felonies because of the lead Plaintiff, Dr.
Phillip Chukwuma Ofume’s bids for the President of Nigeria 2011. In
this Complaint, the Plaintiff raised US and International
Constitutional STATUTE issues directly to this Court, United Nations
High Commission for Human Rights (UNHCHR), United Nations High
Commission for Refugees (UNHCR) and US state and federal secretaries
of Justice and Attorney-Generals, for the enforcement of their human
and constitutional rights and seeks immediate and unconditional return
of Kleber to Parents and siblings in the United States of America.

16. Kleber Ofume has no criminal record and he is a bona fide
student at THE NORTH SHORE COMMUNITY COLLEGE, LYNN, MA and expected to
earn his Associate Degree in year 2010. Kleber’s college resumed
lectures or classes on January 20, 2009 but on March 10, 2009 which
was the date for Kleber’s Bail Hearing, defendants conspired together
and forcibly deported him to Nigeria.

17. Kleber’s, parents’ and siblings’ Asylum case is pending and
active before US BOARD OF IMMIGRATION APPEALS (BIA) as Lead Case File
No. #A 97-446-370 with riders A#
Ofume family v. ICE et als 8/37

96-416-429, A# 96-416-430, A# 96-416-431, A# 96-416-432, A#
96-416-433, A# 96-416-434, A# 96-416-435 . Additionally, with Notice
of Appeal (BIA) and immediately arrest, detention and ex-communication
were made on Kleber, parents filed two major Application/Complaint for
STAY OF DEPORTATION with BIA.

18. On October 12, 2005 4th defendant issued 1-94 to all
Plaintiff’s family. Deliberately, 4th defendant altered Kleber’s 1-94
and wrote his date of birth, January 23, 1998 whereas Kleber was born
on January 23, 1988. Acton of 4th defendant has severally impeded
Kleber’s access to right to education, social security, Mass ID card,
student loan/bursary, travel, MassHealth/Medicaid, etc.

19. Unbearably, October 12, 2005 -January 7, 2009 after several
letters, petitions and 100% unreturned telephone calls, on January 7,
2009 upon parent’s consent KLEBER ODIMEGWU OFUME was allowed to go to
Boston Logan Airport to further request 4th Defendant to correct the
deliberate change which 4th Defendant made on Kleber’s 1-94. Upon
presenting his request, 4th defendant Kleber was arrested, detained
and ex-communicated.

20. High conspiracy was also displayed by fee and pro bono
attorneys because on February 9 and 12, 2009, 8th Defendant took full
payment of the full amount ($480.00) negotiated to effect and secure
Kleber’s bail and thereafter 8th defendant went underground and
lately resurfaced on March 7, 2009 about six minutes after the
publication of the Plaintiff’s and NGOs’ petitions to the US
President, Vice-President, etc. to announce that she (8th defendant)
has filed Bail Motion with The Immigration Court Boston, MA and
secured hearing date for March 10, 2009 at 1.00 pm. 8th Defendant
refused to serve and show Plaintiff copies of the purported Bail
Motion.

21. On before March 8, 2009 5th Defendant proceeded for short
leave of full absent. On about March 9, 2009 Kleber was removed to
Batavia, Buffalo, NY and parents (Pro se and Forma Pauperis ) rushed
Motion for Stay of Deportation to the District Court, Buffalo and
Ofume family v. ICE et als 9/37

rejected by the Clerk for want or lack of jurisdiction. Swiftly, on
about mid-night or early morning of March 9 or 10, 2009 Kleber was
deported to Nigeria where parents are facing treason and other
political felonies against US and International laws.

- B -
1st , 3rd, 4th and 10th Defendants - US Department of Homeland
Security (DHS) / US Immigration and Customs Enforcement (ICE)

22. Particulars/Procedural History of Kleber‘s case in the United
States of America Prior to Forcible Deportation to Nigeria:

Name of Immigration Detainee: Kleber Odimegwu
Ofume PIN # 118418
Lead Case File: A# 97-446-370 (BIA)
Prisoner or Detainee: A#96-416-430 (one of the eight
riders in Plaintiff‘s application
for asylum pending before BIA)
Prisoner or Detainee’s Detention: ID#0900100
Detention Facilities: Transferred (03/09/2009) from
Suffolk County House of
Correction to Batavia, Bufallo, New York. Bail
Hearing scheduled for March 10,
2009 at 1.00 p.m. Removed from 7th defendant without
record and threw Plaintiff in
disarray, pains, psychological torture and stress.
Anonymous speakers advised
Plaintiff to intensive search because according to
them several innocent people are
brought to the facility without record and disappear
without trace.
Related Case: 1:07-cv10085-GAO
Cause: Petition for Writ of Habeas Corpus
(Federal 28:2241)
Date filed: 01/20/2009 by parents on behalf of their
detained child. Rejected by
the Immigration Court, Boston, MA because Parents
have no license to practice
law in the United States of Massachusetts
Jury Demand: None
Nature of Suit: 463 Habeas Corpus - Alien Detainee
Venue of Arrest: Boston Logan Airport
Date of Arrest: 01/07/2009
Detainee’s occupation: Student, North Shore
Community College, Lynn, MA

23. On September 29, 2005 via Halifax International Airport
Kleber (minor under ACT 208 - Asylum) accompanied by parents and
siblings (hereinafter, “Ofume family” ) fled political persecution in
Canada en route to Washington, DC but office of the 1st , 3rd, 4th
and 10th forced Plaintiff to stop at Boston Logan Airport and
application for Asylum
Ofume family v. ICE et als 10/37

was made on September 29, 2005 and remade on September 1, 2006.

24. On September 29, 2005 office of the 1st , 3rd, 4th and 10th
Defendants interviewed Plaintiff for over 12 hours and admitted them
into the United States. To sanction further voyage to Washington,
D.C. where the pains they have been suffering in Massachusetts would
have been limited, they impounded and seized the family’s UN Refugees
travel documents and passports; academic and professional
qualifications and awards; birth certificates; photographs relating to
torture suffered by the family; books and submissions relating to
politically criminal charges in Canadian and Nigerian law courts; etc

25. On October 5 & 6, 2005 Plaintiff was interviewed by US Asylum
Officer. On October 7, 2005 granted CREDIBLE FEAR OF TORTURE OR
PERSECUTION and released and the Asylum Officer advised the family to
leave the detention facility (Hilton Hotel) immediately but soon as
the Asylum Officer left office of the 1st , 3rd, 4th and 10th
Defendants re-arrested and re-detained the entire family without
reason.

26. Also without reason on October 12, 2005 deliberately 4th
defendant issued the family marked 1-94 with cancellation and self
created error to the extent of issuing Kleber Ofume’s 1-94 with date
of birth January 23, 1998 whereas he was born on January 23, 1988 and
issued Keynes Ofume’s 1-94 with more dreadful deliberate distortion of
official documents with the intention to punish for political and
other reasons.

27. Without good cause, office of the 1st , 3rd, 4th and 10th
Defendants wrongfully paroled Plaintiff for one full year (October 12,
2005 - October 12, 2006) with mounted harassment and persecution with
the hope that the family would default but the parole was successful
and 1st , 3rd, 4th and 10th Defendants have no pending charges
against the family including Kleber Ofume because the charge brought
against the Plaintiff under section 212(a)(7)(A)(i)(I) failed on
October 16, 2007 because of disclosure of the Plaintiff‘s unexpired
United Nations Travel Documents and Passports. Between November 16,
2005 and January 30, 2006 two Judges resigned from the Plaintiff’s
asylum case.
Ofume family v. ICE et als 11/37

28. 1st , 3rd, 4th and 10th Defendants brought this failed charge
against the Plaintiff after they have impounded and seized Plaintiff’s
unexpired UN Refugees travel documents and passports; academic and
professional qualifications and awards; birth certificates;
photographs relating to torture suffered by the family; books and
submissions relating to politically criminal charges in Canadian and
Nigerian law courts; etc but before October 16, 2007 which is the
final individual hearing of the Pliantiff asylum case, Counsels for
1st , 3rd, 4th and 10th Defendants exposed the atrocities defendants
and disclosed copies of the Plaintiff’s unexpired UN Refugees travel
documents and passports which the office 1st , 3rd, 4th and 10th
Defendants impounded and seized on September 29, 2005.

29. January 26, 2006 - September 8, 2006 The Honourable Justice
Matthew D’Angelo heard the family’s case in secret courtrooms located
in Massachusetts and Florida without NOTICE TO APPEAR on the family.
Three complaints to the Office of Chief Immigration Judge and three
appeals to the USCIS ADMINISTRATIVE APPEALS OFFICE (AAO). Charge were
unspecific and in-between time designated as something like allegation
of “entering into US without unexpired travel documents.” On this
charge the 1st , 3rd, 4th and 10th Defendants encounter setback when
the Assistant District Attorney lately acted upon Order of Court
(01/25/2006) and disclosed copies of the family’s unexpired travel
documents and passports to disprove this falsified or politicized
charge. At this point all charges failed (10/16/2007).

30. On October 16, 2007 which was the end or final master individual
hearing The Honourable Justice Matthew D’Angelo assumed uncharged
ground by picking on EXPIRED BIOMETRIC TEST and declared the family’s
application as “ABANDONED.” The BIOMETRIC TEST remained expired at
the instance of the “Court” or Judge D’Angelo and Clerk who refused
to write, sign and stamp simple phrase, “BIOMETRIC TEST IS REQUIRED
IN THIS CASE” which the USCIS (Nebraska Service Center) requested
before appointment to redo the BIOMETRIC TEST could be issued to the
family. At this point all Relief was denied by Judge D‘Angelo who has
severally and openly supported Plaintiff‘s political rivals (Canadian/
Nigerian governments and Nigeria‘s foreign and
Ofume family v. ICE et als 12/37

domestic oil/gas companies).

31. Plaintiff filed Motion to Reopen with several new evidence
(contacts made to the Court and Nebraska pleading effected stated in
para 30 above). Judge D’Angelo denied Plaintiff’s Motion to reopen
with strange conception that Plaintiff ought to have be come one of
the staff of USCIS (Nebraska Service Center) with the power to issue
appointment to redo Biometric Test.

32. Plaintiff’s Complete Notice of Appeal to Board of immigration
Appeal (BIA) dated 01/17/2008 and delivered in person, received and
stamped by the BIA. At this point (Appeal) the 1st , 3rd, 4th and
10th Defendants dropout and abandoned the case.

33. BIA’s Notice of receipt of Appellants’ NOTICE OF APPEAL
dated January 23, 2008 containing BIA’s Notice of Brief Schedule was
received by the Appellants (Ofume family or Plaintiff). Upon contact
with the BIA, officials they confirmed that the 1st , 3rd, 4th and
10th Defendants also received BIA’s Notice of Brief Schedule.

34. According to BIA’s Notice of Brief Schedule Appellants/
respondents (ofume family) is granted until 02/13/2008 to submit a
Brief to the BIA. Appellants/respondents submitted their Brief on
February 11, 2008 and service made on the Appellee/Plaintiff (DHS -
ICE) or 1st , 3rd, 4th and 10th Defendants with Proof of service
also filed with the BIA. 1st , 3rd, 4th and 10th Defendants
(Plaintiff) did not reply.

35. 1st , 3rd, 4th and 10th Defendants (Appellee/Plaintiff -
DHS - ICE) was granted until 03/05/2008 to submit a reply brief to the
BIA. Appellants/respondents did not receive anything from 1st , 3rd,
4th and 10th Defendants (Appellee/Plaintiff - DHS - ICE) including
defence on Appellants’ NOTICE OF APPEAL to the BIA. Nothing sent by
1st , 3rd, 4th and 10th Defendants. The procedural record of BIA
shows that Plaintiff’s (Ofume family) appeal is active and pending.
Also BIA and FOIA records show that 1st , 3rd, 4th and 10th
Defendants or DHS or ICE has not responded to the family’s appeal
since filled to present.
Ofume family v. ICE et als 13/37

36. Shocking that on January 7, 2009, 1st , 3rd, 4th and 10th
Defendants saw the submissions listed in paragraphs 30 to 35 above and
proceeded to arrest, detain and ex-communicate Kleber Ofume. In
several of Plaintiff’s petitions to 1st , 3rd, 4th and 10th
Defendants particularly dated February 5, 2009 Plaintiff attached
large list of documents relating to the procedural history of
Plaintiff’s case before the BIA and mailed to 1st , 3rd, 4th and
10th Defendants or ICE (Burlington, MA) by CERTIFIED MAIL NO. 7007
1490 0004 2366 7901.

37. Under severe acute ex-communication purpose of obstruction of
justice and Due Process, 1st , 3rd, 4th 5th, 7th and 10th
sanctioned and censored communications between Kleber’s parents and
siblings. Over 98% of the letters and gifts sent to Kleber were either
destroyed or shattered and copied and returned to Dr. Ofume.

38. Plaintiff requested 8th defendant to address Kleber’s Emergency
Bail Motion to SINGLE IMMIGRATION JUDGE, Eliza C. Klein or Thomas M.
Ragno because she/he knows Plaintiff’s case and in the past issued
several orders (consolidation, disclosures, etc) in the case ( Lead
Case File: A# 97-446-370 (BIA). Under this chain conspiracy to
facilitate the unlawful deportation of Kleber to Nigeria, Judge
D’Angelo who supports Nigeria’s looting, poverty in midst of abundant
wealth and political assassination schemes of the Canadian/Nigerian
governments and Nigeria’s foreign and domestic oil/gas companies was
preferred by 8th defendant and thereafter nominated and assigned to
hear Kleber’s bail motion.

39. Reason that 8th defendant went underground after receiving the
full payment of the legal fees negotiated for Kleber’s bail, Plaintiff
and its NGOs started telling the story about the odeal including
addressing petitions to Board of Bar Overseer, President and Vice-
President of America, etc. March 7, 2009 was the date Messrs.
President’s and Vice-President’s petition was published and
surprisingly, less than six minutes sequel this open letter, 8th
defendant sent e-mail but Plaintiff saw the e-mail few days later. The
e-mail informed Plaintiff that she has filed bail motion and set down
for hearing on March 10, 2009 at 1.00 pm but 8th defendant refused to
serve copies of the purported motion on the Plaintiff
Ofume family v. ICE et als 14/37

including prisoner or detainee, Kleber Ofume.

40. On March 10, 2009 1st , 3rd, 4th and 10th Defendants deported
Kleber to Nigeria instead of designated countries (Venezuela, Russia
and Iran) by the Plaintiff. January 8, 2009 - present all letters and
telephone calls to 1st , 3rd, 4th and 10th Defendants were not
answered, returned and responded to. 1st , 3rd, 4th and 10th
Defendants feel that they are above the law because they hold mantles
of office in a sovereign nation.

41. Under this unlawful deportation, in part 8th defendant failed to
answer the question as to whether US district or assistant district
attorney or attorneys for 1st , 3rd, 4th and 10th Defendants was
served the purported bail/bond motion. If the district or assistant
district attorney was served therefore it shows that 1st , 3rd, 4th
and 10th Defendants are aware that Kleber’s bail/bond motion would be
heard on March 10. 2009 at 1.00 pm.

42. Investigation and research on the record of the US district or
assistant district attorney or attorneys show that 1st , 3rd, 4th and
10th Defendants are aware that Plaintiff’s Asylum case and
applications/complaints for Stay of Deportation are active and
pending before 9th defendant and its Examiner. Under these secured
proceedings in the United States, is any members of the Plaintiff’s
family deportable or removable.

C

2nd Defendant - US Federal Bureau of Investigation, Boston, MA

43. On January 8, 9, and 13, 2009 Dr. Ofume telephoned
2nd defendant to inform it that some people under political cover with
the unlawful claim of power of Immigration and Customs Enforcement
(ICE), thus arrested, detained and ex-communicated Kleber Odimegwu
Ofume (hereinafter, “son and student of The North Shore Community
College , Lynn Campus“). Dr. Ofume requested for separate
investigation on cause of the moneyed arrest, detention and ex-
communication. Several times, Dr. Ofume reminded 2nd
Ofume family v. ICE et als 15/37

defendant.

44. On March 9, 2009 following early morning anonymous
urgent information brought to the Plaintiff’s family, Kleber was
reported to have been removed by 1st , 3rd, 4th and 10th Defendants
from the custody of the 5th and 7th defendants and en route to
Batavia, Buffalo, NY. Dr. Ofume telephoned 2nd defendant for urgent
action to intercept the smuggling or adduction activity. Dr. Ofume
(and) telephoned 5th defendant and the staff in the facility (7th
defendant) told the Plaintiff that 5th defendant traveled on before
March 7, 2009 which the staff tagged, “leave of absent and will be
back to work on about March 11, 2009.”

45. On March 9 & 10, 2009 Dr. Ofume severally requested the
staff of 5th and 7th defendants to check record of the facility
whether Kleber is still detained there. The staff told Dr. Ofume that
Kleber is not in the facility and only 5th defendant would know where
Kleber was. An outspoken staff told Dr. Ofume to wait on telephone to
enable him consult some senior staff. After this consultation, he
said, “something horrible must have happened yesterday ( March 8,
2009) or ICE must have transferred him but the record of transfer is
not here”. Another staff received another Plaintiff’s call and said,
“I have no power to talk about this case…this one of the cases which
defines our facility…start search immediately of your loved one…this
all what I can tell you…have good day.”

46. On March 9, 2009 Plaintiff, Dr. Ofume returned to 2nd
defendant from where he stopped to apply for emergency intercepts on
human smuggling scheme like this and Dr. Ofume issued trail lead to
2nd defendant such as, Boston  Batavia  (aircraft of deportees
loading Nigeria). On March 9/10, 2009 Dr. Ofume telephoned 2nd
defendant several times and provided 2nd defendant with extensive lead
to track 1st , 3rd, 4th and 10th defendants and Kleber particularly,
3rd defendant who has been defined by co-staff as having Bush’s crown
of being the most dreadful and deadly petit racist used as political
tool and opportunistic killer to destroy non-white immigrant
maintained policy of DO NOT WRITE & RETURN TEL. CALLS. Inside and
outside Burlington, MA

Ofume family v. ICE et als 16/37

certain White, Indians, Blacks, Asians, Hispanics and unidentified
nationalities called the work which 3rd defendant do as the work which
politicians, lawmakers, leaders and their agencies can not do under
covert politics.

47. Because of lack of interventuion by 2nd defendant, 1st ,
3rd, 4th and 10th defendants enjoyed free ride from the United States
to Nigeria. After they have conducted this illegal duty, Plaintiff
(Dr. Ofume and Kleber Ofume) received two different oral apologies and
oral promise limited to that process to return Kleber to the United
States is already underway because they made mistake and because there
was a Ghanaian that looks like Kleber. Over one month and Kleber’s
college resumed lecture on January 20, 2009 and Kleber has not been
returned to Lynn, MA.

48. On March 10, 2009 upon review of the action which 2nd
defendant has take, Plaintiff found that no action was taken.

D

5th & 7th Defendants - Major Lockhart and Suffolk County House of
Correction

49. From the standpoint of the expert definition of state and non-
state terrorists and terrorisms and their detention/prison facilities,
Suffolk County House of Correction may be compared with Guantanamo Bay
Detention Camp but may be stricter than Guantanamo Bay Detention Camp
on basis of ex-communication, feeding, etc - Kleber lost over 45 Ibs
within two (2) months because of physical and psychology tortures;
loss of his college education which he has suffered for years because
of the cruelties by the governments of Massachusetts and America
which placed Klebers’ parents on over three years zero-income
including sanction on right to job authorization and employment and
self-employment; lack of food; multiple drills with handcuff and
chains from head to toe; unable to telephone and write to parents and
siblings to send
Ofume family v. ICE et als 17/37

important messages including messages regarding his bail and college;
parents/siblings letters are in majority returned, cut open, shattered
and copied; 100% sanction on visitation of parents and siblings;
telephone, fax, e-mails, etc are blocked and inaccessible; advice that
parents are no longer in the United States; threat of deportation to
Nigeria where his parents are facing treason and other political
felonies charges which upon conviction earns convict death by hanging
or public firing squad; etc

50. Between January 8, 2009 and March 9, 2009 Plaintiff has
visited Suffolk County House of Correction over 3 times per week
purpose of plea to see Kleber Ofume but 5th and 7th defendants refused
and failed to grant Plaintiff access to right to see Kleber and to
present time has not seen their brother and son. All special visits
which are granted to other parents and guardians were denied Plaintiff
without reason.

51. Reason that the Plaintiff (7 children and 2 parents) suffer
almost zero-income to the limited extent that the Plaintiff gets only
$240/month paid to US born child and starvation food stamps given to
under 14-children, Plaintiff prepared Bail Motion because of lack of
money to pay fee attorney and pro bono attorney refused to take
Kleber’s case. 5th and 7th defendants refused and failed to grant
right to present the Motion to Kleber to enable him sign the Motion
under self-representation because 12th defendant of the Immigration
Court, Boston refused to allow parents sign and file the Motion on
behalf Kleber who was still minor on January 10, 2009 ACT 208
(Asylum), § 240 of the INA when the Bail Motion was presented to the
Clerk and Administrator of the Immigration Court, Boston.

52. The Bail Motion was delivered in person to the 7th defendant
by Dr. Phillip Chukwuma Ofume and Dr. Ofume pleaded either to escort
Kleber to the reception or visitors room to enable Kleber sign the
Motion, 5th and 7th defendants refused to allow Kleber come to the
visitor’s room. Dr. Ofume pleaded to drop-off the Motion with reply
envelope, 5th and 7th defendants refused. 5th and 7th defendants
advised Dr. Ofume to mail the motion to Kleber. Thereafter, the Motion
was mailed to Kleber. 5th and 7th defendants impounded and seized the
Motion.

Ofume family v. ICE et als 18/37

53. In addition to several letters to 5th and 7th defendants for
service upon Kleber, Plaintiff made several telephone calls over 260
calls none was connected to enable Plaintiff talk to Kleber. 5th and
7th defendants maintained severe acute ex-communication and denial.
Plaintiff registered with EVERCOMM and paid money to Western Union

54. All applications for visit were made and denied. Special visit
applications were also made and denied to the extent that one night
visit was approved without security and Dr. Ofume and one child were
granted night visit without security. Majority of Dr. Ofume’s
political rivals in the United States is located in Massachusetts. The
neighborhood whereat 7th defendant lies situate is made up of homeless
people and other street people and would be good point for harm
against Dr. Ofume and his child. Dr. Ofume ask 5th and 7th defendants
to give reason why special daytime visit was not granted and why
nighttime visit was approved without security under the conditions of
Dr. Ofume and Plaintiff in general in the United States. No answer was
given.

55. 5th defendant received over 80 telephone calls without return
call. Only one call was returned after the deportation of Kleber and
Kleber’s money in the facility has not been released to parents. After
over 78 calls Plaintiff and its NGOs entered into campaign against the
cruelties of the 5th and 7th defendants against Kleber and rest of his
family members.

E

11th Massachusetts Pro Bono Attorneys (Greater Boston Legal Services,
Catholic Charities, PAIR Project and International Institute of
Boston)

56. Office of The Honourable Governor Deval Patrick, Pro bono
Branch of the US District Court, Boston and Conference of Bishop
(Washington, DC) referred Plaintiff to the Pro bono attorneys in the
Commonwealth of Massachusetts.
Ofume family v. ICE et als 19/37

57. In both Kleber’s case and the entire family’s Application for
asylum (Lead Case File: A# 97-446-370 -BIA), 11th defendant refused to
take their cases. Particularly, Kleber Ofume’s falls within the object
of Greater Boston Legal Services, Catholic Charities , PAIR Project
and International Institute of Boston, they refused to take the
cases. In course of research and investigation, Plaintiff was
informed that 11th defendant receives donation and other monies from
the Canadian government, Nigeria’s foreign oil/gas companies and
several other governmental and non-governmental agencies that oppose
Plaintiff’s political ambition in Nigeria.

58. Plaintiff attended several sessions organized by 11th
defendant and on two occasions attorneys or representatives for PAIR
Project promised to visit Kleber Ofume at Suffolk County House of
Correction. Plaintiff relied on this promise but they did not visit
Kleber. At this point, the over 98% zero-income condition of the
Plaintiff threatened their ability to get lawyer without going from
street to street to beg money.

59. Kleber’s case is Immigration and his asylum case and parents’
and siblings’ case under the lead case file No. A# 97-446-370 (BIA) is
active and pending before The Board of Immigration Appeals and Kleber
is not removable and no established case under any inadmissibility
legislation of the United States. Bond/Bail Motions under this Asylum
Application is simple because Appellee or DHS (ICE) in the Lead Case
File: A# 97-446-370 -BIA abandoned this case since early December
2007 and the case is unopposed; Kleber Ofume has no past criminal
record; Kleber is College student with a very beautiful GPA which has
been endorsed and released by the Vice-President of North Shore
Community College, Lynn, MA; etc.

60. After several visits and submission of evidence in support of
proof of indigency, all the pro bono attorneys within the
specification of Asylum and Refugees cases rejected Plaintiff‘s case
including Kleber‘s bail motion. No reason was given for rejecting
Kleber’s emergency bail case and the lead Case File: A# 97-446-370 -
BIA .

Ofume family v. ICE et als 20/37

F
8th Defendant, Nancy Norman - Attorney of Record of the State of
Massachusetts

61. Kleber Odimegwu Ofume’s parents are lecturer, researcher,
Artist, prisoner of conscience, stateless person, refugee adopted by
the United Nation High Commission for Refugees (UNHCR) and Amnesty
International (Int. Secretariat, London UK, Asylee and resident in
Lynn, MA in company of Kleber and other siblings. Kleber, his parents
and siblings are in Exile and moved to the United States from Canada
to organize parents’ campaign purpose of becoming the President of
Nigeria 2011. Because of this campaign and oil/gas politics in
Plaintiff’s region of birth in Nigeria (NIGER DELTA REGION), certain
domestic and foreign leaders, politicians, lawmakers and oil/gas
companies have blocked Plaintiff’s household’s access to right to
education, justice system in Canada and United States, pro bono
attorneys under the status of refugee, fee attorneys and over 98% of
other services.

62. Defendant, Ms. Nancy Norman is Attorney of Record resident and
operates law office in Lynn of the State of Massachusetts which is a
good proximity to Plaintiff because Plaintiff is also resident of
Lynn. After massive politicized rejection by Massachusetts Pro bono
attorneys and time wasted, on February 3, 2009 in haste Plaintiff
returned to Massachusetts Bar Association (MBA) - Lawyer Referral
Services (LRS). All referrals are fee attorneys and first hour of
meeting with LRS’s attorneys cost $25.00.

63 Attorney Mark Horrigan and others were referred. Mr. Horrigan
convinced Dr. Phillip Ofume that Ms. Norman is his wife and that she
is trained in Immigration and Asylum law. Dr. Ofume or lead plaintiff
told Mr. Horrigan that his son, Kleber Odimegwu Ofume case is
emergency because he is facing accelerated and politicized
deportation. Before, 8th defendant, time factor was major point of
question in issue as to whether or not 8th defendant would take the
case. 8th defendant claimed that she has time to do Kleber’s case.

64. Between February 9, 2009 and March 10, 2009 date of Kleber’s
deportation, Dr. Ofume had one meeting (02/09/2009) with Ms. Norman
and the meeting lasted few minutes less than twenty (20) minutes
because Dr. Ofume has filed Bail Motions with Immigration Court,
Boston, MA and US District Court, Boston, MA and after few
Ofume family v. ICE et als 21/37

minutes meeting with Ms. Norman, Dr. Ofume gave her his Verified Bond/
Bail Motions and Memoranda and second Motion for Stay of Deportation
filed with BIA and Immigration Court, Boston, MA and her Secretary
made photocopies.

65. On February 9, 2009 Dr. Ofume told Ms. Norman and thereafter
wrote to Ms. Norman to express his dismay on the conduct of Lynn
Police Department on using local boys and girls to harass Kleber and
the role of Judge Matthew D’Angelo (US Immigration Court, Boston, MA)
and reason the Plaintiff filed three Administrative Appeals to The
Office of Administrative Appeals -INS and three Complaints to The
Office of Chief Immigration Judge against Judge D’Angelo and further
reason why Judge D’Angelo is unfit to hear Kleber’s Bail Motion. Dr.
Ofume listed Judges (Eliza C. Klein or Thomas M. Ragno) of The US
Immigration Court, Boston, MA that are familiar with Plaintiff’s
Immigration (Asylum) case and also issued important orders (disclosure
of important documents, consolidation, etc) in Plaintiff‘s case.
Attorney of record, Ms. Norman is entitled to certain discretionary
practice to address URGENT OR EMERGENCY MOTION like this to SINGLE
JUDGE.

66. On February 9, 2009, for about three minutes, Dr. Ofume
repeatedly told Ms. Norman fact about the urgency of Kleber’s bond/
bail motions and he further informed her that information revealed
that less than one week Kleber would be deported to Nigeria. Dr. Ofume
asked Ms. Norman whether she has time to take the case. Ms. Norman
told Dr. Ofume that she has time to take the case and she added that
her carriage of the family’s case will be limited to Kleber’s Bail and
that the family Asylum case before the BIA is not included. Dr. Ofume
and Ms Norman agreed.

67. On February 9, 2009 Dr. Ofume and Ms. Norman negotiated the full
costs to complete Kleber’s Bail. Notwithstanding that Dr. Ofume has
done all the motions and memoranda, Ms. Norman imposed $500.00. Some
staff at the Suffolk County House of Correction told Dr. Ofume that
there are some visiting lawyers that will bail out Kleber for less
than $300.00 because he in PULSE category and/or College Student
without criminal record. Dr. Ofume feared scam
Ofume family v. ICE et als 22/37

and relied on the accredited referral by MASSACHUSETTS BAR ASSOCIATION
and Ms. Norman is one of the local lawyers residing in Lynn, MA with
accessible proximity to the Plaintiff or resident of Lynn, MA. Dr.
Ofume pleaded for cut and Ms. Norman cut $20.00. Ms. Norman and Dr.
Ofume settled for $480.00.

68. On February 9, 2009 Dr. Ofume paid $280.00 balancing $200.00
agreed to be paid after Kleber’s bail.

69. Contrary to the agreed condition stated in para 52 above, on
before February 12, 2009 Ms. Norma telephoned Dr. Ofume several times
demanding full payment on February 12, 2009. On February 12, 2009 Dr.
Ofume paid Ms. Norman the balance of $200.00.

70. On February 13, 2009 Dr. Ofume telephoned Ms. Norman and her
secretary answered the telephone and she told Dr. Ofume that Ms.
Norman has problem and that she will be out of office for two (2)
weeks.

71. During Ms. Norman’s unexpected leave of absent, after several
telephone calls by Dr. Ofume on Ms. Norman, she returned one call and
warned Dr. Ofume to stop telephoning her office and that failure she
would call police. Based on this threat, Dr. Ofume filed Complaint
with The Massachusetts Board of Bar Overseer and the Board advised Dr.
Ofume to proceed to Small Claim Court to recover his legal fees which
he paid to Ms. Norman.

72. On March 7, 2009 Dr. Ofume and his NGOs and allied NGOs send Open
Letter to President Barack H. Obama, Vice-President Joseph Biden,
Secretary of DHS or 1st Defendant, Secretary of Justice and Attorney-
General, etc to complaint about the prison conditions of Kleber and
the conduct of Ms. Norman. Less or about 6 minutes sequel publication
of this Open Letter, suddenly Ms. Norman’s e-mail emerged claiming she
has filed Bail Motion for Kleber and according Ms. Norman hearing
scheduled and surprisingly, before Judge D’Angelo for March 10, 2009
at 1.00 pm. Why did the court assign the motion to Judge D’Angelo
under the pending animosities and complaint against his extra-judicial
conduct and appeals stated in para 29 above? Ms. Norman refused to
disclose the purported
Ofume family v. ICE et als 23/37

motion and failed and refused to serve copies on Kleber, Dr. Ofume and
Mrs. Marureen Ofume. The Plaintiff read, speak and write and is the
author of this complaint.

73. Per information, on about March 8, 2009, 1st , 3rd, 4th 5th,
7th and 10th defendants handcuffed and chained Kleber Ofume head
to toe and moved him to Batavia, Buffalo, New York and the information
was brought to the Plaintiff sometime around early morning (about 2.00
a.m.) of March 9, 2009 and urgent message was placed on Ms. Norman‘s
voice message and Plaintiff demanded for urgent Motion for stay of
deportation to Buffalo to stop the deportation. When Ms. Norman’s
office was opened on March 9, 2009 several calls were made by
Plaintiff through Ms. Norman’s secretary and when Ms. Norman failed to
reply, Dr. Ofume prepared Motion for Stay of Deportation to Buffalo
and there the Clerk denied because of want of jurisdiction and the
clerk advised that jurisdiction lies in Boston.

74. March 8 and 9, 2009 Ms. Norman failed to return Plaintiff’s
calls. On March 10, 2009 Plaintiff received information that 1st ,
3rd, 4th 5th, 7th and 10th defendants have deported Kleber to
Nigeria. Also on March 10, 2009 when different members of the
Plaintiff’s family and friends were already heading to The Immigration
Court Boston, Ms. Norman telephoned Dr. Ofume and informed him that
Judge D’Angelo called her stating his opinion that he has no
jurisdiction over Kleber’s case. Heartless people!!!

75. Under this elongated conspiracy, Dr. Ofume filed collection
claim with Lynn District Court claiming $480.00 which he paid to Ms.
Nancy Norman on February 9, 2009 and February 12, 2009 and $30.00
which will be paid to the Court to cover costs. As further readings to
this paragraph, Plaintiff attached Kleber’s letter which he wrote from
Nigeria. Kleber heard about Attorney John J. Loscocco during his
detantion and ex-communication and he was unable to transmit his
particulars to parents because of these cruel conditions.

G

6th Defendant, Lynn Police Department

76. Kleber’s father bids for the President of Nigeria 2011 and this
bid is one of the major
Ofume family v. ICE et als 24/37

reasons for the past and present cruelties against Kleber and his
parents and siblings. Defendants including 6th defendant which are
not a political organizations or agencies are used to implement their
political persecution and other cruelties against Kleber and his
parents and siblings. The people’s mandate which Kleber’s parent won
in Nigeria is one of the major causes of the action of the defendants
and others with gun-point interest in the natural resources of the
native place of birth and origin (NIGER DELTA REGION) of the Kleber
and his parents and siblings.

77. Kleber Ofume has been an A & +B student at the CLASSICAL HIGH
SCHOOL, LYNN MA and maintain the same scholarly assiduity at THE
NORTH SHORE COMMUNITY COLLEGE, LYNN CAMPUS and have about one year and
half to graduate. If Kleber is not return to the United States
immediately his college education will be forfeited and as usual 6th
defendant will blame a Black man and placed him in category of
Americans they brand NOT HARD WORKING. Under the on-going extensive
sanction, persecution, embargo, and zero income (over 98%) against the
entire family, Kleber and his siblings are A+, A, B+, B and honour
students at Lynn Public School System and North Shore Community
College.

78. 6th defendant is unable to deceive Kleber to engage in fight,
use indecent language and related harm against themselves and the
entire society, drink alcohol, smoke and engage in crime and
activities against the state, people and society because Kleber and
his parents and siblings are members of THE CHURCH OF JESUS CHRIST OF
LATTER-DAY SAINTS. 6th defendant is able to manipulate criminals in
Lynn to attack Kleber but Kleber has been ignoring and avoiding them
and focused on education, family, community services, peace, campaign
for civil liberties and good government.

79. 1996 - present, Kleber and his parents and siblings have been
fleeing political persecution and torture in Nigeria, Togo, Canada
and continued in the United States by infiltration of the parents’
political rivals with accomplice like 6th defendant. On October 12,
2005 1st , 3rd, 4th and 10th Defendants moved Kleber and his parents
and siblings into hell (8
Ofume family v. ICE et als 25/37

Hall Avenue, 2nd Floor Braintree, MA with harassment gang mounted 3rd
and 1st Floors). All day and night domestic disturbances were not
responded by Braintree Police Department. On January 27, 2006 8 Hall
Avenue, Braintree, MA was deliberately burnt down, Kleber and his
siblings and parents narrowly escaped the blaze. The mistreatment in
this detention/prison became the cause of long litigation/petition now
pending before The Supreme Court of the United States Docket No.
08-8873.

80. On February 3, 2006 Kleber and his parents and siblings were
moved to third torture and persecution detention/prison (33 Arlington
Street, Apt. #1 Lynn, MA with harassment group mounted 2nd Floor
engaged in heavy smoking, drinking, banging the roof, walls,
staircase, recruitment of children and adults and mounted 24hours/day,
etc). Several dreadful domestic harassments, were not responded to and
6th defendant advised Kleber’s parents to arrest the tugs and bring
them to 6th defendant station.

81. 6th defendant found that the Christian background of Kleber and
his parents and siblings puts restrain on the Plaintiff to engage in
domestic and public disobedience or act that would amount to breach of
peace. After 6th defendant failed to get what they want or criminal
charges from the action of these tugs, 6th defendant decided another
strategy which includes but not limited to call up aggressors that
would cause aggression and jump into reversed position to telephone
police 911 or regular police call up number to make criminal complaint
against any important members of the Plaintiff’s family (parents,
Kleber Ofume, Keynes Ofume, etc) or in the alternative dump any
important members of the Plaintiff’s family in serious criminal gang
case with witnesses position against the gang members and further
make the gang to see Plaintiff as their aggressors and enemy.

82. On March 1, 2008 at about 2.00 a.m. a young man ran into 7-
Eleven Store where Kleber do student work-pay college fees and claimed
that some armed people were chasing him and that Kleber should help
him telephone the police and the man alleged that the people were in
the premises of 7-Eleven Store. Kleber telephoned 6th defendant and
when 6th defendant,
Ofume family v. ICE et als 26/37

Lynn Police Department (officer) arrived at the suspected crime scene,
6th Defendant forced Kleber to abandon his work and further forced
Kleber to go out with them (6th defendant) in the dark to identify
these people whereas the young man who requested Kleber to telephone
6th defendant was standing with the police as the police was forcing
Kleber. Kleber feared that police may kill him should he refused to
respect their instructions. These suspected armed men where arrested
in the dark as if they were mounted or planted there and waiting for
the police to pick them up because no genuine criminals would wait for
police and related operatives to arrest them.

83. Same day March 1, 2008 at about 9.00 a.m. the men were charged
with robbery, possession of firearms, possession of dangerous weapons,
etc and 6th defendant submitted the full particulars of Kleber as
informant and pointer to the local media and the news was swiftly
published. Kleber was issued several subpoenas to appear for different
proceedings including probable cause hearings and other appearances
and exposures that would risky for witness in gang related and other
criminal cases.

84. On December 23, 2008 on about 1.00 a.m. young man drunk and
suspected to be on special assignment and may have been positioned in
and around the 7-Eleven Store where Kleber do student work-pay-fees
and soon as some two female customers entered the store and picked
some merchandizes, the young man emerged and joined the customer queue
directly behind these ladies and started bullying these customers.
Kleber merely advised the young man to stop harassing his customers.
Upon this polite and soft advise the young man was infuriated for no
just reason and expanded premeditated anger to telephone 6th defendant
or LYNN POLICE DEPARTMENT but as usual the police waited for the young
man to escalate the brawl.

85. 6th defendant arrived late and with unfounded anger rushed to
place handcuff on Kleber and disrupted his work. Police held Kleber
somewhere outside Lynn Police Station and after several telephone
calls on 6th defendant’s station, 6th defendant brought him to the
station and Kleber’s bail under self-recognizance and release
processes were completed at about 3.15
Ofume family v. ICE et als 27/37

a.m. (12/23/2008) with bail fees of $40.00 (Forty US Dollars).

86. More shock was felt by Plaintiff’s family, Americans and
internationally that without investigation police brought a serious
charge of assault with dangerous weapon and about 5 hours at 9.00 a.m.
same day (12/23/2008), Kleber was arraigned in Lynn District Court
and quickly distributed across media system and published and 6th
defendant posted criminal record on Kleber which will be ASSAULT WITH
DANGEROUS WEAPON and will show on 1st , 3rd, 4th and 10th Defendants,
government and other systems inside and outside the United States of
America.

87. After January 7, 2009 anonymous information revealed that 6th
defendant in collaboration with 1st , 3rd, 4th and 10th Defendants
created two secret tasks, network and underlining plan following,

a. several people designated and some that maybe friends with
special assignment to deceive Kleber to resign his job and apply for
what they claimed to be safe job and more lucrative job which will be
instructor at bodybuilding institute and another job in out state. In
Lynn, MA to execute this plan, there will be an open house during
which Kleber will visit the institute to review salary which will be
attractive to move Kleber out of 7-Eleven Store. Another prong of the
network is that Kleber will be advised to go to the office of the 4th
defendant to correct his 1-94 which 4th defendant deliberately issued
(10/12/2005) Kleber’s date of birth as January 23, 1998 whereas Kleber
was born on January 23, 1988;

b. after the mock open house stated in subparagraph 71(a) above, now
comes the last drill which will take Kleber into the hands of 1st ,
3rd, 4th and 10th Defendants. Prior to January 7, 2009, Kleber sought
consent of parents.

c. On January 7, 2009 upon arrival Kleber presented his request
before 4th defendant. 1st , 3rd, 4th , 8th and 10th contacted
themselves and used the posted plan established by the 6th defendant
(para 86 above) and Kleber was arrested, detained and ex-communicated
to the
Ofume family v. ICE et als 28/37

limited extent that 1st , 3rd, 4th , and 10th used their close
surveillance to know when Kleber’s parents were trying to dial 911 to
declare Kleber missing, phone rang and 1st , 3rd, 4th and 10th
Defendants allowed Kleber in few second to say (only), “I AM DETAINED
AT SUFFOLK COUNTY HOUSE OF CORRECTION.”

d. 4th defendant said that they arrested Kleber because of the
information provided by 6th defendant and office of the 1st , 3rd,
4th and 10th claimed that it has no time to verify the information

88. On several occasions, Dr. Ofume applied for Police Report
through 6th defendant to get 6th defendant’s allegation stated in
paragraphs 84, 85, and 86 above but 6th defendant entered denial with
the lay excuse that there was no information relating to Kleber‘s
arrest and detention on December 23, 2008. Dr. Ofume referred the
Police Record Officer to the date of arrest and time of detention and
bail and amount paid for bail on December 23, 2008 and charge pending
before Lynn District Court. 6th defendant maintained steady denial.

89. Again and again, on January 11, 2008 one young man telephoned
Kleber with the threat that he will be coming few minutes time to
break and enter 33 Arlington Street, #1 Lynn, Massachusetts 01902 and
further into his room to kill him. Kleber telephoned 6th defendant but
they did not come and parents also telephoned 6th defendant. Parents
found that over 45 minutes, 6th defendant or Lynn police did not come
to wait for this person. Few minutes after 45 minutes, the man and
another young man arrived and requested Kleber to open his door and
parents further called Lynn police via local and 911 lines with direct
advise and correct address. When parents saw them from the window,
they requested Kleber to stay indoor and let’s watch them. But when we
saw the insistence of these men, parents opened the door to ask them
to explain what may have caused their anger and also parents used
their experiences to calm them down. They did not say what may have
angered them to the extent of armed threat to kill Kleber. Lately, as
parents were calming them down and succeeded in making them happy,
shamefully 6th defendant arrived and met parents standing with these
men. 6th defendant said, “this what we expect parents to be doing.”

H

Ofume family v. ICE et als 29/37

9th Defendant, Board of Immigration Appeals (BIA)

90. Recognizing that Appeal to BIA from the Decision of the
Immigration Judge is not automatic stay of deportation Reason of
this, Plaintiff (pro se and forma pauperis) filed Notice of Appeal
and also filed Motion for stay of deportation. When parents of Kleber
observed the swift action of 1st , 3rd, 4th , and 10th defendants to
deport Kleber, they proceeded same speed manner to file Application in
nature of Complaint referencing past and present applications for
Stay of Deportation to the BIA.

91. Under recent stay application, starting from January 20, 2009,
Dr. Ofume telephoned BIA five times per week to know whether BIA has
issued past and present orders for stay of deportation on 1st , 3rd,
4th , and 10th defendants. On several occasions, Clerk’s Office
connected Dr. Ofume to extension which Clerk’s office called
“Examiner” and each time Dr. Ofume recorded voice message on the
Examiner’s voice sytem but she failed to respond to all the messages.

92. 9th defendant continued to remain underground to pave way for
the deportation of Kleber and without the Order of 9th defendant even
when Plaintiff’s served Notice of Appeal and Application for Stay of
deportation on the Assistant District Attorney for the , 1st , 3rd,
4th and 10th Defendants and bothe Notice of appeal and Applications/
Complaints for stay of deportation are active and pending before BIA,
1st , 3rd, 4th and 10th Defendants proceeded to heed the direction of
Plaintiff’s political rivals and deported Kleber on March 10, 2009 to
Nigeria where parents are facing treason and other political
felonies.

93. Under elongated moneyed conspiracy and hostile oil/gas politics,
US beautiful exemplary constitutional judicial system is dumped to the
scaring extent that, March 10, 2009 at 1.00 pm was Kleber’s Bail
Hearing in the Immigration Court Boston, MA and 1st
Ofume family v. ICE et als 30/37
, 3rd, 4th and 10th Defendants heeded the unfounded allegation of
the 6th defendant and deported Kleber and forcibly rift Kleber from
his nuclear family in the United states and his college studies.
I

12th Defendant - Robert Halpin or Court Administrator of US
Immigration Court, Boston.

94. Mr. Robert Halpin is Court Administrator of the US
Immigration Court, Boston. Mr. Halpin received Plaintiff’s
(parents’ ) self-representation (Kleber Ofume) Bond and Bail Motions
on behalf child in Prison custody or detention because of Plaintiff’s
inability to find attorney in January 2009. 100% of the times,
Plaintiff is in the Immigration Court, Boston to file any documents,
12th defendant must appear or Plaintiff is requested to wait until he
or his assistance comes to reject the papers and each time Plaintiff
ask why, he or his assistance calls the police.

95. When parents were unable to get Pro bono attorney and
further unable to get fee attorney with payment from street begging,
Plaintiff re-submitted Kleber’s Bond and Bail Motions several times to
the US Immigration Court, Boston, each time, Mr. Halpin refused to
accept the motions and the reason he gave was that Dr. Phillip Ofume
has no license to practice law in the United States of America and
also according to him, Dr. Ofume has no right to file child’s bond and
bail motions on behalf child who is in prison or detention.

96. According to Mr. Halpin, in criminal cases, prisoner or
detainee in the United States has no right to file his/her bail and
other motions and applications, “my advice to you is stop coming to
this court or you will be arrested like your son…come to this court
with authorized attorney…I will continue to call police to remove
you.” Is this true, America and Americans?

97. Between November 2005 and January 2009 Plaintiff has
presented several applications, petitions, motions and other documents
for filing with US Immigration Court, Boston, but Mr. Halpin or Court
Administrator and Judge Matthew D’Angelo have been using their
personal initiatives or judgments to reject the documents.
Ofume family v. ICE et als 31/37

98. Kleber is well educated to represent himself in any court of
record. Kleber has been “A” and “B” students from Lynn Classical High
School to North Shore Community College. In the United States and
Canada Parent, Dr. Phillip C. Ofume has excellently pursued highbred
and highly contentious litigations from the smallest law courts to the
Supreme Courts of Canada and United States and United Nations.

99. On January 12, 2009 Dr. Ofume presented the following Bond
& Bail Motions for filing to SINGLE JUDGE:

Motion for Waiver of Bond or Cash and Affidavit to Proceed in Forma
Pauperis and Pro se in support Prisoner Case Pursuant to INA: ACT 208
(Asylum), § 240 of the INA and Fed. R. App. P. 24(a) to Immigration
Judge Eliza C. Klein or Immigration Judge Thomas M. Ragno of The US
Immigration Court, Boston, MA

Petition for Writ of Habeas Corpus (Federal - 28:2241) : Verified
Emergency Bail Motion/Memorandum in Support of Prisoner Case Pending
Consideration of Petitioner’s Appeal before The Board of Immigration
Appeal (BIA - Lead Case File A# 97-446-370 ) from the Decision
(10/16/2007) of Immigration Judge, Boston, MA to Immigration Judge
Eliza C. Klein or Immigration Judge Thomas M. Ragno of The US
Immigration Court, Boston, MA.

Mr. Halpin or Court Administrator blocked the Clerk of Immigration
Court, Boston. Dr. Ofume requested to see the Clerk, he threatened to
call police and severally called the police on Dr. Ofume. Between
November 2005 and January 2009 for no just reason, Mr. Halpin or Court
Administrator has threatened to call police on Dr. Ofume over 17
times merely for requesting part of the duties sustained with tax
money.

100. Failure to get these motions docketed in the Immigration Court,
Boston was a major set back and move to uncertain jurisdiction which
is the following:

Petition for Writ of Habeas Corpus (Federal - 28:2241) : Verified
Ofume family v. ICE et als 32/37

Emergency Bail Motion/Memorandum in Support of Prisoner Case Pending
Consideration of Petitioner’s Appeal before The Board of Immigration
Appeal (BIA - Lead Case File A# 97-446-370 ) from the Decision
(10/16/2007) of Immigration Judge, Boston, MA to The Honourable
Justice George A. O’Toole, Jr., United States District Judge.

101. Self-representation would have been the best belt for
Kleber to stop his paid and organized deportation. On January 26,
2009, notwithstanding that at this stage Immigration Court has more
jurisdiction than US District Court, Boston same Motion which Mr.
Halpin or Immigration Court Administrator rejected was presented to US
District Court, Boston and accepted and filed with Docket No. C.A. No.
09-1079. To change the course at this point, on February 9, 2009 8th
defendant was retained.

J

Joint physical and psychological tortures, stress, and
related pain afflicted upon Plaintiff by the defendants

102. 1st , 2nd , 4th, 9th, and 10th defendants have opportunity to
stop deportation of Kleber Ofume. 6th defendant created the ladder for
1st , 2nd , 4th, 9th, and 10th defendants to use lies and fallacies
to arrest, detain and ex-communicate Kleber and thereafter careless
about US and International laws. 3rd, 4th, 5th , 7th, 8th , 9th, 10th
and 11th applied closure and censorship to achieve the plan to deport
Kleber to Nigeria in order to disrupt Plaintiff’s plan to relocate to
Iran or Russia or Venezuela to coordinate his campaign for Nigeria’s
election 2011. 12th was a very ample source to secure Kleber’s bail.

k

Relief
Ofume family v. ICE et als 33/37

Immediate and unconditional return of Kleber Odimegwu Ofume to Parents
and Siblings that are now in the United States of America to enable
Kleber resume his College studies pending appeals of their Asylum
Application.

Special Damage and General damage relating to stress; physical and
psychological torture; daily fear of safety and re-arrest of Kleber
in Nigeria; painful loss or forfeiture of Associate Degree at NORTH
SHORE COMMUNITY which the child struggled alone under the harsh zero-
income of parents and siblings and heartless; endless cry, tears and
anger of parents and siblings because of the disappearance of their
brother and son since January 7, 2009; pains and difficulties of
managing dependant child oversea under forcible deportation in midst
of harsh zero-income ; etc.etc.etc. Under this imposed added hardship
(deportation) the only income to Plaintiff’s family is $240.00 child
assistance paid to one US born child and under-14 child food stamps.

Reason of the foregoing Plaintiff jointly seeks, special and general
damages of $300 million against the 1st , 3rd , 4th, and 10th
defendants ; $100million against 6th defendant; $50million against
the 9th defendant; $50million against 5th and 7th defendants;
$50million against 8th defendant; $20million against 2nd defendant;
$30million against 11th defendant and $50million against 12th
defendant.

Finally, reason of the foregoing, the Plaintiff raised US and
International Constitutional STATUTE issues directly to this Court,
United Nations High Commission for Human Rights (UNHCHR), United
Nations High Commission for Refugees (UNHCR) and US state and federal
secretaries of Justice and Attorney-Generals, for the enforcement of
their human and constitutional rights and seeks commencement of
EMERGENCY JUDICIAL INQUIRY with Jury claim.

Complainant or Plaintiff intends to proceed FORMA PAUPERIS and PRO
SE, the Plaintiff also
Ofume family v. ICE et als 34/37

demands further judgment against the defendants for damages and such
other relief as this court deems just.

The Plaintiff demands a trial to proceed with jury.

ISSUED at Lynn, Massachusetts, this 20th day of April, 2009

______________________
Phillip C. Ofume, Ph.D. – Representative/Advocate for the Ofume
Family

For: Dr. Phillip C. Ofume, and Mrs. Maureen N. Ofume
and seven children (including deported child),
33 Arlington Street, Apt.# 1
Lynn, Massachusetts 01902
E-mail: confi...@hotmail.com, global
aids_hivcur...@yahoo.co.uk
Websites - enter with keyword, “ Dr. Phillip Ofume”

TO:

Sarah Allison Thornton - Clerk of Court
UNITED STATES DISTRICT COURT
DISTRICT, MASSACHUSETTS
1 Courthouse Way
Boston, Massachusetts 02210

FURTHER COPIES TO:

President Barack H. Obama
President of the United States of America
1600 Pennsylvania Avenue, NW
Washington, DC 20500

Vice- President Joseph Biden,
Washington Office:
Eisenhower Executive Office Bldg.
Washington, DC 20501
Ofume family v. ICE et als 35/37

Honourable Eric H. Holder, Jr.
US Secretary of Justice and Attorney General,
U.S. Department of Justice
950 Pennsylvania Avenue, N.W.
Office of the Assistant Attorney General, Main
Washington, D.C. 205 30

United Nations High Commission for Human Rights
United Nations High Commission for Refugees
Geneva, Switzerland.

PARTICULARS OF DEFENDANTS

The Solicitor General of the United States,
Room 5614
Department of Justice,
950 Pennsylvania Avenue,
N.W., Washington, DC 20530-0001

US Assistant District Attorney
Immigration and Customs Enforcement (ICE)
10 New England Executive Drive
Burlington, MA 01803
Tel. 781-359-7500
Suffolk County House of Correction
20 Bradston Street
Boston, MA 02118
Tel. 617-635-1000

Major Lockhart
Suffolk County House of Correction
20 Bradston Street
Boston, MA 02118
Tel. 617-635-1000 ext. 6510
Tel. 617-635-1000

The Chief of Police
Lynn Police Department
300 Washington Street
Lynn, MA 01902
Tel. 781-595-2000
Fax. 781-477-7069

Mr. Robert Halpin - Court Administrator
US Immigration Court

Ofume family v. ICE et als 36/37

JFK Federal Building, 3rd Floor
Government Center
Boston, MA 02203

Mr. Dominic Federico
Immigration and Customs Enforcement (ICE)
10 New England Executive Drive
Burlington, MA 01803
Tel. 781-359-7500

Mr. Bruce Chadbourne
Immigration and Customs Enforcement (ICE)
10 New England Executive Drive
Burlington, MA 01803
Tel. 781-359-7500

Ms. Janet Napolitano
The Honourable Secretary
U.S. Department of Homeland Security
DHS Headquarters
Washington, D.C. 20528
202-282-8000

Director - Complaint
Federal Bureau of Investigation
J. Edgar Hoover Building
935 Pennsylvania Avenue, NW
Washington, D.C. 20535-0001

The Clerk of the Board (BIA)
Board of Immigration Appeals
Office of the Clerk
5107 Leesburg Pike, Suite 2000
Falls Church, VA 22041

Attorney Nancy Norman
NANCY B. NORMAN
154 Lynnway, Unit I-C.
Seaport Landing
Lynn, MA 01902
781-592-4666 (Tel)
781-599-1441 (Fax)
Ofume family v. ICE et als 37/37

Greater Boston Legal Services
197 Friend Street
Boston, MA 02114
Tel. 617-371-12234

Catholic Charities -Immigration Services
75 Kneeland Street, 8th Floor
Boston, MA 02111
Tel.: 617-451-7979
Fax: 617- 629-5768

Political Asylum/Immigration Representation Project (PAIR)
254 Friend Street, 5th Floor
Boston, MA 02114
Tel.: 617-742-9296
Fax: 617-742-9385

International Institute of Boston
One Milk Street
Boston, MA 02109-5413
Tel. 617-695-9990
Fax 617-695-9191