1,778 Matching Annotations
  1. Nov 2023
    1. when there is such variation in the connection in which the words are used as reasonably to warrant the conclusion that they were employed in different parts of the act with different intent."95 Context and statutory history can override the presumption.
  2. www.law.cornell.edu www.law.cornell.edu
    1. A motion can be written or spoken, as the relevant rules require.

      My statement in court to McLean I wanted a trial was a clear motion

    1. Summary Judgment

      ABA: Motion for Summary Judgment (sometimes called motion for summary disposition). This motion asks the court for a judgment on the merits of the case before the trial. It is properly made where there is no dispute about the facts and only a question of law needs to be decided.

      The was A HUGE DISPUTE of the facts. Not only the facts presented, but also the omission, AND ALSO THAT I NEVER HAD 1 CHANCE TO SPEAK AND STATE ANNNY FACTS! And, as federal civil procedure rules state, summary judgement can only occur after the close of Discovery...we NEVER HAD DISCOVERY

    2. motion for summary judgment shall be filed no later than 91 days (13 weeks) prior to tria

      The motion was filed 45 days prior to trial. ...I mean, beyond Haley being criminally fucking useless, when does the judge become accountable for not letting illegal shit happen in her case???? Regardless of what the attorneys do; isn't she the "trier of law" and "trier of facts"? I mean, what the fuck??

    1. prima facie evidence that such child is neglected or dependent,

      Preponderance of evidence and prima facie evidence based rulings are not "proof" or "conviction"

    2. on the motion of any interested party

      Haley's so fucking incompetent, even after my pounding into her the petition was false, omitting tons of evidence, and misleading...does again not know d and n law nor basic legal representation mechanisms to volunteer or advise on submitting a motion to amend petition not even use this as satisfactory argument responding to summary judgement request. Her degree of incompetence and neglect in a licensed and sworn position whose sole charge is to prevent the unlawful abuse and destruction of families via competent legal representation, necessitates criminal charges.

    3. but in no instance shall such hearing be held later than ninety days

      Method for defense, hold accountable, stop unlawful abuse? - sue for damages for loss and harm - writ of mandamus (oblivious to Haley) - when does not following law that results in withholding of a child go from civil damages to criminal kidnapping or custodial interference (and other offenses). Kate, FPS, and court was heedless' of lawfulness, enticed', with intent to conceal', and did not have reasonable' belief or attempt reasonable efforts' as expected of a reasonable peer to aquire reasonable belief' she was in harm. Clarity: the child's own instigation' was result of enticement' CRS TITLE 18 https://victimtohero.com/interfering-with-custody-is-not-just-a-civil-matter-it-is-a-crime/

  3. Oct 2023
    1. Requirements The health center must operate in a manner such that no patient shall be denied service due to an individual’s inability to pay.1
    2. discounts are adjusted on the basis of the patient's ability to pay.
    1. Early recognition is typically an important factor in delivering effective therapy.
    2. in the vast majority of these conditions defined by and/or accompanied by microvascular thrombosis, the diagnosis is typically made clinically and sometimes confirmed histologically if possible.
    3. The resolution of a computed tomography angiogram or magnetic resonance angiogram typically does not provide information about the structure of these microscopic vessels. Even a conventional angiogram of the brain does not resolve vessels smaller than 500 µm
    4. correctly identifying that there is an issue in that physiologic compartment.
    5. Clinical overview of microvascular thrombosis
    6. Imaging of the microvasculature
    7. key obstacle
    1. Neutrophils play a major role in tissue damage incurred during IRI. Activated neutrophils are a major source of ROS,
    2. An anti IL-8 antibody prevented pulmonary neutrophil infiltration and tissue injury in a rabbit model of lung IR
    3. The introduction of humanised antibodies including etanercept and infliximab, has provided encouraging results in the treatment of other TNF-α-mediated inflammatory diseases, including a number of forms of arthritis and inflammatory bowel disease (reviewed in18)
    4. Hypoxia and IRI both induce the expression of numerous cytokines, including tumour necrosis factor-alpha (TNF- α,) interleukin-1 (IL-1), interleukin-6 (IL-6), interleukin-8 (IL-8) and platelet activating factor (PAF), in association with elevations in activity of the transcription factor, NF-kB (reviewed in 16) these cytokines are released systemically and are thus important in the development of systemic inflammatory response syndrome and ultimately multi-system organ failure.
    5. Endothelin-1 inhibitors, including bosentan and tezosentan, inhibit neutrophil infiltration, increase functional capillary density, microvascular perfusion and hence tissue viability and function Following IR
    6. systemic distortion of NO kinetics by administering NOS inhibitors would be likely to induce wide-ranging physiological disturbances.
    7. inhibition of NOS activity using a non-specific NOS inhibitor greatly reduced the severity of muscle damage
    8. considerable evidence for a principal role for nitric oxide in the aetiology of IRI. Myocardial IRI has been well studied, with paradoxical results, where low doses of no were found to be protective and high doses harmful. The influence of NO in skeletal muscle IRI has been less well characterized, with some studies suggesting that NO may potentiate cytotoxicity and others suggesting a beneficial role for NO in extremity IR
    9. The reduction in ENOS levels that occurs in IRI may therefore predispose to vasoconstriction, a common response seen in IRI
    10. activated neutrophils, leads to further pulmonary neutrophil accumulation.
    11. The lung produces leukotrienes following remote IRI. The direct effects of leukotrienes on pulmonary micro vessels lead to increased permeability, transient pulmonary hypertension and the activation of the endothelium to produce thromboxane, resulting in additional vaso-constriction.
    12. leukotrienes C4, D4, and E4 modify the endothelial cytoskeleton, leading to increased vascular permeability and also enhance smooth muscle contraction, resulting in vasoconstriction
    13. Leukotrienes
    14. administration of thromboxane A2 antagonists may offer therapeutic potential
    15. thromboxane synthase inhibitors and synthetic thromboxane A2 receptor antagonists prevented pulmonary leukosequestration, thereby increasing blood flow to reperfused tissues and preserving tissue viability and function
    16. rapid rise in pulmonary artery pressure and a subsequent increase in pulmonary microvascular permeability
    17. promoting vasoconstriction and platelet aggregation
    18. thromboxane A2
    19. demonstrated better post-operative myocardial oxygen consumption after coronary artery bypass surgery8 and improved muscle blood flow following skeletal muscle IRI.9
    20. administration of prostacyclin was shown to improve postoperative graft function.
    21. Prostaglandins, synthesised from arachidonic acid via the cyclo-oxygenase pathway, have a protective vasodilatory effect in IRI. However, since prostaglandins are short-lived molecules, their rapid depletion subsequently leads to uninhibited vasoconstriction, reduced local blood flow and exacerbation of ischaemia
    22. ROS initiate lipid peroxidation of cellular membranes, releasing arachidonic acid, the main substrate for the production of prostaglandins, thromboxanes and leukotrienes
    23. A systematic review6 provided evidence that allopurinol was effective in some studies in reducing the severity of post-operative cardiac dysfunction and arrhythmias after coronary artery bypass grafting,
    24. administration of allopurinol prior to ischaemia, reduces the production of superoxide and hence reduces the severity of reperfusion injury
    25. superoxide in inducing damage to distant organs during skeletal muscle reperfusion injury
    26. During IRI, ROS also activate endothelial cells, elevating the activity of the transcription factor, NF-κB. Once activated, the endothelial cell produces E-selectin, vascular cell adhesion molecule-1 (VCAM-1), intercellular adhesion molecule-1 (ICAM-1), endothelial-leukocyte adhesion molecule (EMLMl Am -1) plasminogen activator inhibitor-1 (PAi-1), tissue factor and interleukin-8 (il-8). These adhesion molecules contribute to important interactions between the neutrophil and the endothelium and will be discussed in more detail later.
    27. The major consequence of hydroxyl radical production is peroxidation of the lipid structures of cell membranes resulting in the production and systemic release of proinflammatory eicosanoids, disruption of cell permeability and ultimately cell death
    28. Once the ischaemic tissue is reperfused, an influx of molecular oxygen catalyses xanthine oxidase to degrade hypoxanthine to uric acid and thereby liberating the highly reactive superoxide anion (O2-) (Figure 18.2, lower panel).
    29. COX-2 may promote the inflammatory response through the rapid and exaggerated production of nitric oxide and prostaglandins, contributing to organ damage.4
    30. Hypoxia itself also activates a number of genes, particularly transcription factors, including activating protein-1 (AP-1), hypoxia-inducible factor-1 (HIF-1) and nuclear factor-kappab (NF-kb). HIF-1 then activates transcription of other genes such as vascular endothelial growth factor (VEGF), erythropoietin and glucose transporter-1, which all play an important role in the cells’ adaptive responses to hypoxia (reviewed in3)
    31. repressed genes were largely involved in energy production, including mitochondrial respiration and fatty acid oxidation
    32. activated genes were largely clustered into cytokine genes and mediators of inflammation and immune cell infiltration
    33. found that expression of 962 genes was induced and 327 genes were repressed.
    34. multi-factorial process resulting in extensive tissue destruction
    35. IRI occurs in a wide range of organs including the heart, lung, kidney, gut, skeletal muscle and brain and may involve not only the ischaemic organ itself but may also induce systemic damage to distant organs, potentially leading to multi-system organ failure
    1. Serum creatine phosphokinase (CK) levels >4000 U/L, chloride (Cl) levels >104 mg/dL, and blood urea nitrogen (BUN) levels <10 mg/dL were found to have 100% association with the diagnosis of acute compartment syndrome in hospitalized trauma patients
    2. Serum creatinine kinase (CK) levels >4000 U/L, chloride (Cl) levels >104 mg/dL, and blood urea nitrogen (BUN) levels <10 mg/dL were found to have 100% association with the diagnosis of acute compartment syndrome.
    3. Previous studies show that physicians have a low sensitivity for detecting elevated compartment pressures when relying on physical examination findings alone
    1. public assistance for needy individuals and families who are residents of the state and whose income and property are insufficient to meet the costs of necessary maintenance and services as determined by the state department and to assist such individuals and families to attain or retain their capabilities for independence, self-care, and self-support, as contemplated by article XXIV of the state constitution and the provisions of the social security act and the food stamp act. The state of Colorado and its various departments, agencies, and political subdivisions are authorized to promote and achieve these ends by any appropriate lawful means through cooperation with and utilization of available resources of the federal government and private individuals and organizations.
    1. (12) "Individual responsibility contract" or "IRC" means the contract entered into by the participant and the county department pursuant to section 26-2-708.
    2. (15) "Participant" means an individual who receives any assistance or who participates in a specific component of the Colorado works program.
    1. 2. A client shall be given notice of any action by the county department, or any person or agency acting on its behalf, which adversely affects the client's eligibility for, or right to grant payments authorized under the Colorado Works program. Failure to give notice of an adverse action shall be grounds for setting aside the action on appeal. The notice must meet the following standards:

      Argue that: not providing notice of request for verification is "failure to provide notice"

    2. 3. Failure of the client to request a county conference within ninety (90) calendar days from the date timely notice of the proposed action was mailed, absent the client requesting a postponement within that same ninety (90) days, shall constitute abandonment of the right to a conference. The client does not lose the right to appeal directly to the OAC pursuant to section 3.609.7.
    3. Present new information or documentation to support reversal or modification of the proposed adverse action.

      "SHALL NOT.....PRESENT NEW INFORMATION OR DOCUMENTATION TO SUPPORT...MODIFICATION....OF ADVERSE ACTION"

    4. confidential informants, privileged communications between the county department and its attorney,

      This is only CIs and Privileged Communications. If I don't have the names, then I didn't get the owed "contents"

    5. A. The county department, prior to taking action to deny, terminate, recover, initiate vendor payments, or modify financial assistance provided under the Colorado Works program to a client, shall,

      PRIOR TO TAKING ACTION

    6. C. Clients shall receive written timely notice, giving at least eleven (11) calendar days advance notice before any adverse action taken during the certification period, becomes effective, except as specified in section 3.609.7.C

      Not sure what 3.609.7x.C is about. There is nothing meaningful I can see regarding giving timely notice.

    7. A. Each client of Colorado Works shall receive prior written notice of any agency action affecting his or her eligibility for or receipt of grant payments.
    1. "Verified upon receipt" means information that is provided directly from the primary source and is not questionable and no additional verification is required.
    2. "Adverse action" means a county action to reduce grant payments or to deny an application. A reduction may be the result of a sanction, a demonstrable evidence closure, or ineligibility based on income or household changes.

      was not given notice continued benefits would end at recert neither initially or terminally. In fact notice said would continue indefinitely until completion of appeal.

  4. Sep 2023
    1. Not be receiving financial assistance from other financial assistance programs administered by the state of Colorado;

      This obviously has to intend on meaning programs that are wholly designed, owned, controlled, executed, and funded by the state. Ex. SNAP is administered by the stat, in fact even declared by definition and not paid to do so. However, A.N.D. is I believe fully a state program (but I'd check the funding on that).

    1. substantial limiting factor in permitting them

      Note: The word "TEST", or "INCOME and ASSET TEST/REQUIREMENT/CRITERIA" are not terms used in this statue to define who is eligible to participate in SNAP. ...

    2. no State agency shall impose any other standards of eligibility as a condition for participating in the program.

      Neither State statute, nor state agency administrative rule shall not impose any additional standard for participation (i.e. eligibility criteria)

    3. shall be
    4. Eligible households
    5. other financial resources

      Which is TANF

    6. incomes

      Which is none

    7. except
    8. Notwithstanding any other provisions of this chapter

      [in spite of and not to be controlled by] any other l [statutory rules] of this chapter [of which "definition: household" is included See: statutory construction, SCOTUS, "20190611092122150_00000055.pdf" and Georgetown Law "A-Guide-to-Reading-Interpreting-and-Applying-Statutes-1.pdf"

    1. parents and their children 21 years of age or younger who live together

      Is not listed as an exception to categorical eligibility, and, therefore, is included in "all other provisions of this chapter" and is, therefore, overruled by categorical eligibility (as "households" are eligible "notwithstanding" all "other provisions of this chapter" except those exceptions listed, as m(4) of this definition of "household" was). If Congress wanted to mandate household categorical eligibility was bound by the requirement of parent and child living within the same 4 walls, then m(2) would have been included as m(4) was (see SCOTUS statutory construction)

    2. (2)
    3. individual or group of individuals constitute a household if they reside in an institution or boarding house,

      A listed overruling exception to categorical eligibility

    4. (m) (1) “Household” means—
    1. No later than October 1, 2010, the state department shall create a program or policy that, in compliance with federal law, establishes broad-based categorical eligibility for federal food assistance benefits pursuant to the supplemental nutrition assistance program.
    1. provide phased-in services aimed at reunifying families where a child has been placed out of the home, where appropriate, by tapping into other available federal funds or through moneys realized from cost avoidance in prevention of placement;

      Reunify Other federal programs (SNAP+ CAT EL)

    2. Out-of-home placement is often the most expensive and disruptive method of providing services to troubled families

      You are perpetuating the most disruptive service. And the most expensive.

    3. The general assembly finds and declares that: (a) Maintaining a family structure to the greatest degree possible is one of the fundamental goals that all state agencies must observe
    1. Upon application made to any court of competent jurisdiction by a party to any agency proceeding or by a person adversely affected by agency action and a showing to the court that there has been undue delay in connection with such proceeding or action, the court may direct the agency to decide the matter promptly.
    2. Every agency shall proceed with reasonable dispatch to conclude any matter presented to it with due regard for the convenience of the parties or their representatives, giving precedence to rehearing proceedings after remand by court order
    1. respondent, the guardian ad litem for the child, or a child who is twelve years of age or older may demand a trial by jury of six persons at the adjudicatory hearing pursuant to section 19-3-505 , or the court, on its own motion, may order such a jury to try any case at the adjudicatory hearing pursuant to section 19-3-505 .

      TRIAL BY JURY MANDATED....HALEY....YOU FUCKING SHAMEFUL INEXCUSABLE IMPOSTER OF AN ATTORNEY. Shaun, do you know about this? Does an appeal attorney for ORPC know the D&N law of which he'll be making appeals?

      See: https://hyp.is/go?url=https%3A%2F%2Fcasetext.com%2Frule%2Fcolorado-court-rules%2Fcolorado-rules-of-civil-procedure%2Fchapter-5-trials%2Frule-38-right-to-trial-by-jury&group=world

    2. the court shall advise the respondent of the minimum and maximum time frames for the dependency and neglect process, including the minimum and maximum time frames for adjudication, disposition, and termination of parental rights for

      I don't remember her doing this. She sure as fuck didn't execute it.

    1. will permit low-income households to obtain a more nutritious diet through normal channels of trade by increasing food purchasing power for all eligible households who apply for participation

      households who apply for participation

    2. Congress further finds that increased utilization of food in establishing and maintaining adequate national levels of nutrition will promote the distribution in a beneficial manner of the Nation's agricultural abundance and will strengthen the Nation's agricultural economy, as well as result in more orderly marketing and distribution of foods
    3. shall be eligible to participate in the supplemental nutrition assistance program. Assistance under this program shall be furnished to all eligible households who make application for such participation.

      -

    4. households in which each member receives benefits under a State program funded under part A of title IV of the Social Security Act (42 U.S.C. 601 et seq.),

      -

    5. Notwithstanding any other provisions

      -

    6. section 2012(m)(4) of this title

      §2012. Definitions.<br /> (m).<br />   (1)“Household” means—<br />     ~~(A) an individual who lives alone or who, while living with others, customarily purchases food and prepares meals for home consumption separate and apart from the others; or.~~<br />     ~~(B) a group of individuals who live together and customarily purchase food and prepare meals together for home consumption.~~<br />   ~~(2)Spouses who live together, parents and their children 21 years of age or younger who live together, and children (excluding foster children) under 18 years of age who live with and are under the parental control of a person other than their parent together with the person exercising parental control shall be treated as a group of individuals who customarily purchase and prepare meals together for home consumption even if they do not do so.~~<br />   ~~(3)Notwithstanding paragraphs (1) and (2), an individual who lives with others, who is sixty years of age or older, and who is unable to purchase food and prepare meals because such individual suffers, as certified by a licensed physician, from a disability which would be considered a permanent disability under section 221(i) of the Social Security Act (42 U.S.C. 421(i)) or from a severe, permanent, and disabling physical or mental infirmity which is not symptomatic of a disease shall be considered, together with any of the others who is the spouse of such individual, an individual household, without regard to the purchase of food and preparation of meals, if the income (as determined under section 2014(d) of this title) of the others, excluding the spouse, does not exceed the poverty line, as described in section 2014(c)(1) of this title, by more than 65 per centum.~~.   (4)In no event shall any individual or group of individuals constitute a household if they reside in an institution or boarding house, or else live with others and pay compensation to the others for meals.<br />     ~~(5)For the purposes of this subsection, the following persons shall not be considered to be residents of institutions and shall be considered to be individual households:~~<br />     ~~(A)Residents of federally subsidized housing for the elderly, disabled or blind recipients of benefits under title I, II, X, XIV, or XVI of the Social Security Act [42 U.S.C. 301 et seq., 401 et seq., 1201 et seq., 1351 et seq., 1381 et seq.].~~<br />     ~~(B)Individuals described in paragraphs (2) through (7) of subsection (j), who are residents in a public or private nonprofit group living arrangement that serves no more than sixteen residents and is certified by the appropriate State agency or agencies under regulations issued under section 1616(e) of the Social Security Act [42 U.S.C. 1382e(e)] or under standards determined by the Secretary to be comparable to standards implemented by appropriate State agencies under that section.~~<br />     ~~(C)Temporary residents of public or private nonprofit shelters for battered women and children.~~<br />     ~~(D)Residents of public or private nonprofit shelters for individuals who do not reside in permanent dwellings or have no fixed mailing addresses, who are otherwise eligible for benefits.~~<br />     ~~(E)Narcotics addicts or alcoholics, together with their children, who live under the supervision of a private nonprofit institution, or a publicly operated community mental health center, for the purpose of regular participation in a drug or alcoholic treatment program.~~

    7. except subsections (b), (d)(2), (g), and (r) of section 2015

      N/A

      §2015. Eligibility disqualifications

      (b) Fraud and misrepresentation; disqualification penalties; ineligibility period; applicable procedures (1) Any person who has been found by any State or Federal court or administrative agency to have intentionally (A) made a false or misleading statement, or misrepresented, concealed or withheld facts, or (B) committed any act that constitutes a violation of this chapter, the regulations issued thereunder, or any State statute, for the purpose of using, presenting, transferring, acquiring, receiving, or possessing program benefits shall, immediately upon the rendering of such determination, become ineligible for further participation in the program—

      (i) for a period of 1 year upon the first occasion of any such determination;

      (ii) for a period of 2 years upon—

      (I) the second occasion of any such determination; or

      (II) the first occasion of a finding by a Federal, State, or local court of the trading of a controlled substance (as defined in section 802 of title 21) for benefits; and

      (iii) permanently upon—

      (I) the third occasion of any such determination;

      (II) the second occasion of a finding by a Federal, State, or local court of the trading of a controlled substance (as defined in section 802 of title 21) for benefits;

      (III) the first occasion of a finding by a Federal, State, or local court of the trading of firearms, ammunition, or explosives for benefits; or

      (IV) a conviction of an offense under subsection (b) or (c) of section 2024 of this title involving an item covered by subsection (b) or (c) of section 2024 of this title having a value of $500 or more.

      During the period of such ineligibility, no household shall receive increased benefits under this chapter as the result of a member of such household having been disqualified under this subsection.

      (2) Each State agency shall proceed against an individual alleged to have engaged in such activity either by way of administrative hearings, after notice and an opportunity for a hearing at the State level, or by referring such matters to appropriate authorities for civil or criminal action in a court of law.

      (3) Such periods of ineligibility as are provided for in paragraph (1) of this subsection shall remain in effect, without possibility of administrative stay, unless and until the finding upon which the ineligibility is based is subsequently reversed by a court of appropriate jurisdiction, but in no event shall the period of ineligibility be subject to review.

      (4) The Secretary shall prescribe such regulations as the Secretary may deem appropriate to ensure that information concerning any such determination with respect to a specific individual is forwarded to the Office of the Secretary by any appropriate State or Federal entity for the use of the Secretary in administering the provisions of this section. No State shall withhold such information from the Secretary or the Secretary's designee for any reason whatsoever.

      (d) Conditions of participation (1) Work requirements.— (2) A person who otherwise would be required to comply with the requirements of paragraph (1) of this subsection shall be exempt from such requirements if he or she is (A) currently subject to and complying with a work registration requirement under title IV of the Social Security Act, as amended (42 U.S.C. 602), or the Federal-State unemployment compensation system, in which case, failure by such person to comply with any work requirement to which such person is subject shall be the same as failure to comply with that requirement of paragraph (1); (B) a parent or other member of a household with responsibility for the care of a dependent child under age six or of an incapacitated person; (C) a bona fide student enrolled at least half time in any recognized school, training program, or institution of higher education (except that any such person enrolled in an institution of higher education shall be ineligible to participate in the supplemental nutrition assistance program unless he or she meets the requirements of subsection (e) of this section); (D) a regular participant in a drug addiction or alcoholic treatment and rehabilitation program; (E) employed a minimum of thirty hours per week or receiving weekly earnings which equal the minimum hourly rate under the Fair Labor Standards Act of 1938, as amended (29 U.S.C. 206(a)(1)), multiplied by thirty hours; or (F) a person between the ages of sixteen and eighteen who is not a head of a household or who is attending school, or enrolled in an employment training program, on at least a half-time basis. A State that requested a waiver to lower the age specified in subparagraph (B) and had the waiver denied by the Secretary as of August 1, 1996, may, for a period of not more than 3 years, lower the age of a dependent child that qualifies a parent or other member of a household for an exemption under subparagraph (B) to between 1 and 6 years of age.

      (g) Residents of States which provide State supplementary payments

      (r) Disqualification for certain convicted felons

    1. (3) If a participant does not agree with or fails to participate in a program or service identified in the IRC, the participant shall continue to receive the basic cash assistance grant that the participant received at the time the appeal is requested during the pendency of any appeal process.

      This overrules the newer CCR that attempts (maybe, it's confusing wording) to stop continued benefits at the end of the current certification period which would be ridiculous and have no sound logic

    1. exercises responsibility

      C.R.S. § 19-1-103

      (119) “Residual parental rights and responsibilities” means those rights and responsibilities remaining with the parent after legal custody, guardianship of the person, or both, have been vested in another person, agency, or institution, including but not limited to the responsibility for support, the right to consent to adoption, the right to reasonable parenting time unless restricted by the court, and the right to determine the child’s religious affiliation.

      (120) “Responsible person”, as used in part 3 of article 3 of this title 19, means a child’s parent, legal guardian, or custodian or any other person responsible for the child’s health and welfare.

      (139) “Termination of the parent-child legal relationship”, as used in articles 3 and 5 of this title 19, means the permanent elimination by court order of all parental rights and duties, including residual parental rights and responsibilities, as provided in section 19-3-608.

    2. (II) Legal custody is held by an agency that does not have physical possession of the child; or

      1) "custody" has long been abolished in CO. The term as it was used is unusably vague legally. It's replaced by Allocation of Parental Responsibilities which is made up of 1)physically living with providing day to day in-person care, and 2) a set of "decion-making" jurisdictions, one of which is "legal decision-making".

      2) the statute states "physical possession" not "physical custody", which, as stated above, not a recognized legal contruct in CO and non-sensically vague. "physical possession" is less ambiguous and obvious to mean day to day physical in-person control

    3. of the following occurs:

      -

    4. or the care of the child

      -

    5. as long as the parent

      -

    6. who lives in the home

      -

    7. The parents of a dependent child

      -

    8. those persons or families who may receive assistance under the Colorado works program include:

      -

    9. Subject to the provisions of this section

      -

    10. 26-2-706. Target populations.
    11. even though one

      "one" reinforces that the list of exceptions are "OR' conditions and only "one" is requried

    1. benefits shall not be reduced or terminated prior to the receipt of the final agency decision unless:

      If they were cognizant enough to include in the rule for SNAP; we can assume they would've been cognizant enough to include it in TANF if they wanted it.

    1. Kendra Dunn Strengthening Families Director State - OEC
    2. Dennis Desparrois Placement Services Unit Manager-State - DCW
    3. Kit Thompson Family &, Children Services Division Director-Boulder County Housing and Human Services
    4. Alison Young Family Law Program Manager-State Court Administrator's Office
    5. Andrew Gabor Director of Child and Adolescent Services-State - OBH
    6. Kari Daggett Deputy Director Division of Child Welfare - DCW
    1. Colorado Family First Implementation Team was the Services Continuum workgroup
    2. The Court Improvement Program (CIP) is working collaboratively with CDHS, the Colorado County Attorney Association, the Office of Respondent Parents Counsel, and the Office of the Child’s Representative to maintain alignment and consistent messaging with Family First requirements
    3. BEHAVIORAL HEALTH TASK FORCEIn April 2019, Colorado Governor Jared Polis directed CDHS to spearhead the Governor’s Behavioral Health Task Force. The Task Force was charged with authoring a statewide strategic plan to transform Colorado’s behavioral health system with the goal of enabling every Coloradan with a behavioral health condition or in crisis to receive the services and support they need to live safe, productive lives in their own communities.
    4. elivery of Child Welfare Services Task Force.

      In May 2018, Colorado’s General Assembly showed significant support for Family First with the passage of the Child Welfare Reform Bill, which created the Delivery of Child Welfare Services Task Force.

    5. The CDHS Division of Child Welfare (DCW)’s Training Unit was recently renamed the Learning and Development (L&D) team.
    6. Child Welfare Prevention Task Group (“Prevention Task Group”) was created in Summer 2021. The purpose of the Prevention Task Group is to act as the child welfare prevention practice advisory group,
    7. Best Practice Court Team (BPCT)
    8. CDHS hired a Family First-dedicated Training & Development Specialist.
    9. ASSURANCE ON PREVENTION PROGRAM REPORTINGSee the Attachment for assurance that CDHS will report to the Secretary such information and data as the Secretary may require with respect to the Title IV-E prevention program, including information and data necessary to determine the performance measures
    1. Megan KearsleyFamily UnitCourt Improvement Program CoordinatorState Court Administrator’s Officemegan.kearsley@judicial.state.co.usCristina Ritchie Cooper, Esq.Senior AttorneyABA Center on Children and the Lawcristina.cooper@americanbar.orgJennifer Mullenbach, Esq.Deputy County AttorneyCounty Attorney's Officejmullenb@co.jefferson.co.usAshley Chase, Esq.Staff Attorney & Legislative LiaisonOffice of the Child’s Representativeashleychase@coloradochildrep.orgAlison Butler, Esq.Carrie Ann Lucas Disability Advocacy DirectorOffice of Respondent Parents Counselabutler@coloradoorpc.org
  5. docdrop.org docdrop.org
    1. Administrative Review Division (ARD)

      The Administrative Review Division (ARD) The ARD manages the qualitative case review portion of Colorado's child welfare quality assurance system. The ARD's vision is to create a safe and promising future for children and at-risk adults, by strengthening the communities, families, and systems that work to make that future possible. ARD is a neutral third party that facilitates case reviews, gathers, and analyzes data, publish research, and provides training and technical assistance to affect change in practice,

      In addition to these specific areas, the ARD's qualitative case review instrument has

      sets designed to measure the quality of case practice in the following areas:

      Mental health

      Substance abuse Educational stability and progress

      Frequency and quality of contacts with the child/youth and parents

      Engagement of the child/youth and parents in case planning Adequacy of visitation between the child/youth and their siblings and parer

      Timeliness of Title IV-E eligibility

    1. Rules governing QRTPS are still pending, so guidance available now may be revised in the future. Email pauline.hoekstra@state.co.us with questions about licensing.
    1. Mobile:303-927-8786Jon.Steinmetz@State.CO.US
    2. Trauma-informedServices are provided under a trauma-informedorganizational structure and treatment framework

      Find more on trauma informed care, because requires inclusion of whole family, necessary expertise, constantly argues it's necessary for misdiagnosis/treatment resulting in damage, danger, no-reunification (destruction of family), and inclusion of whole family

    1. Andrew Gabor at andrew.gabor@state.co.us.
    2. The information in this section was developed by the Colorado Department of Human Services and the Colorado Human Services Directors Association for Colorado's Family First Implementation Guide for County Directors.
  6. www.blueprintsprograms.org www.blueprintsprograms.org
    1. For more information, contact:Susan CaskeyIMPACT Executive Directorscaskey@bouldercounty.org303-441-1511
    2. Dave Bonaiuto, Manager – Assessment, Quality Assurance, &Process Improvement, Boulder County IMPACT Lane Volpe, Ph.D., Vice President, The Implementation Group Susan Caskey, Executive Director, Boulder County IMPACT

      Caskey is now BCDHHS Director

    3. BOULDER COUNTY IMPACT:Building and Sustaining Policy, Practice and Improvement Standardsfor a Multi-Program, Multi-System Collaborative
    4. immediate & ongoing data-driven case planning Moving away from always least restrictive to matching
    1. Child Protection Review Teams -- CPRT The final CPRT meeting has taken place. No additional reviews will be scheduled. Recent legislation, Concerning the Optional Creation of a Child Protection Team by a County, http://statebillinfo.com/bills/bills/17/2017A_016_signed.pdf was enacted to address the evolution of the child welfare system and to recognize the multiple layers of review that now exist across child welfare systems.

      For further information or questions, contact Terrie Ryan-Thomas, tryan-thomas@bouldercounty.org .

    1. Colorado Community Response (CCR) is a voluntary prevention program working with familiesthat have been screened out or assessed and closed without child welfare services. The program wasdeveloped around the Strengthening Families Protective Factors Framework to strengthen families andprevent child maltreatment. Program components include strength-based case management, family-driven goal setting, education, and support to improve financial well-being, flex funding, and resourcereferrals to support goal attainment. The program is awarded through a competitive solicitation. Awardshave been granted for the next five-year funding cycle (FFY 2022-2027), which began in July 2021. Thenext solicitation will be released in 2026. Reach out to Aaron Miller (aaronc.miller@state.co.us) for moreinformation.
    2. Caseworkers must be familiar with evidence-based programs and services available to children, youth,and families that reside in your community. Caseworkers not only need to know what services areavailable, but also the target population and desired outcomes of these services so they can makeappropriate referrals. Family First eligibility should not be a driver of these decisions, but rather theneeds and goals of the child, youth and family

      ALL OF THIS BOLD - Caseworkers must be familiar with evidence-based programs - not only need to know what services are available, but also the target population - so they can make appropriate referrals - eligibility should not be a driver of these decisions, but rather the needs and goals of the child, youth and family

    1. Citizen Review Panel What is The Citizen Review Panel? The Citizen Review Panel (CRP) is an independent group of Boulder County citizens who review complaints regarding unresponsiveness or unprofessional conduct by Boulder County Housing and Human Services’ Family and Children Services employees. Panel members are appointed by Boulder County Commissioners. No employees of the Boulder County Department of Housing and Human Services or the Colorado Department of Human Services are on the panel

    1. Senator Stephen FenbergSenate District 18E-mail: stephen.fenberg.senate@coleg.govWebpage: Stephen FenbergRepresentative Judy AmabileHouse District 49E-mail: judy.amabile.house@coleg.govWebpage: Judy Amabile

      Boulder, Colorado; State Senator and Rep: Senator Stephen Fenberg

      Senate District 18 E-mail: stephen.fenberg.senate@coleg.gov Webpage: Stephen Fenberg Representative Judy Amabile

      House District 49 E-mail: judy.amabile.house@coleg.gov Webpage: Judy Amabile

    1. Boulder County Commissioners Appoint Susan Caskey as Director of Housing & Human Services Boulder County, Colo. -- On Tuesday (August 23),

      scaskey@bouldercounty.org

    1. Division Director, Susan Grutzmacher This division administer benefits eligibility and renewals for basic needs programs including

      Boulder County benefits eligibility division

    1. using the best availablescience, to maximize physical and psychological safety, facilitate the recovery of thechild and family, and support their ability to thrive.”

      trauma-informed treatment model

    1. F742*, §483.40(b)(1), treatment/service for mental/psychosocial concerns (1) A resident who displays or is diagnosed with mental disorder or psychosocial adjustment difficulty, or who has a history of trauma and/or post-traumatic stress disorder, receives appropriate treatment and services to correct the assessed problem or to attain the highest practicable mental and psychosocial well-being;

      services to correct the assessed problem or to attain the highest practicable mental and psychosocial well-being;

      42 CFR § 483.40 - Behavioral health services.

    2. Trauma-Informed Care Regulations and F-tags   The regulations and F-tags that apply to trauma and trauma-informed care
    1. A trauma-informed approach to care acknowledges that health care organizations and care teams need to have a complete picture of a patient’s life situation — past and present — in order to provide effective health care services with a healing orientation.

      Trauma-informed care seeks to: * Realize the widespread impact of trauma and understand paths for recovery; * Recognize the signs and symptoms of trauma in patients, families, and staff; * Integrate knowledge about trauma into policies, procedures, and practices; and *** Actively avoid re-traumatization.**

      https://hyp.is/go?url=https%3A%2F%2Fwww.aapacn.org%2Farticle%2Ftrauma-informed-care-what-it-is-and-isnt%2F&group=world

    1. food intake and vasoconstriction

      Is this why eating is causing instant sleepiness? Non-digestive vessels vasoconstrict and shut off too much cerebral blood flow, then nerves instantly have reduced firing/waste and CO2 build up/diminished mitochondria output/oxidative buildup/ &or then resultant inflammatory triggering cytokine increase?

      Vessel endothelial enormous surface area, manipulator of blood flow vasoconstrictor system, and cytokine producer/influencer, and high vulnerability sensitivity to viral infection/corruption...and then it's role or adjacent system and the immediate available Google research on COVID affecting> the vascular elastin system and corrupted elevated production of destructive elastases resulting in reduced vascular compliance then resulting too narrow "pulse pressure" band essentially creating arteriosclerosis.

      Also, make sure to be thinking of the entire vascular system not as one system, but subsided by dynamic changing gated sections and inspect signaling creating changing locations and amounts of high/low pressure zones. Also, keep in mind 3 things about BP: 1, when taken with a cuff it is only measuring a reading at the elbow. 2, is a reading from the artery and not giving any direct data from vein part of the system. 3, BP is not the same as blood flow. So I conceive that you could read a good BP, but actual flow could be completely inadequate.

      Remember analogy, vascular system is just like car AC system, or any pressurized hydraulic system, or even actually electric circuits. Meaning that there is a high pressure side, the load component(s), and a low pressure side. Also remember veins act as the reservoir tank, and when they constrict it is injecting more blood into the system to, if functioning correctly, allow higher performance and meet increase load demand. It also, therefore has less direct effect on whole system BP vs artery constriction because it's downstream of the load. Arterial constriction conversely has immediate direct effect on systolic BP as it is essentially putting a wall directly downstream of the heart. Therefore, regardless if diastolic pressure is zero or high, when the heart contacts, the pressure shoots straight up.

      A working theory component: my pulmonary vein is inappropriately constricting too much. That causes high back up pressure at alveoli. Exercise then induces veinous reservoir injection and increased blood volume into the "working system" further increasing pressure. Possibly arterious had already been fully dilated at rest in order to compensate and then when exercise happens, it can't be dilated further to increase blood flow throughout and BP increases further all behind the pulmonary vein "dam". However it doesn't present as right side heart failure like might initially be guessed (with leg and belly edema) because the right side heart is not failing...yet. So it contains any further backflow and the alveoli are the weakest point and taking the most abuse and pressure is relieved as pulmonary edema. And therefore what may be present is if we look for it, we'll find that actual blood throughput output exiting the heart is too low. And this can exist with a normal ejection fraction because the heart is functioning correctly and pumping the right percentage of what is a low starting volume. And also this can support why right ventricle is showing first signs of enlarging because it's being overpressured and stretching out (enlarging). And this can support why normal BP readings are measured at the arm because it can completely handle the abnormally low blood volume being received in the downstream location it's at. And then therefore this further supports why BP is normal but HR is riding the high limit at rest and then instantly jumps on exertion AND why dizziness happens because the artery system was already maxed out dilation at rest and for any amount of exertion, increasing HR because of the immediate too fast rise in tissue hypoxia due to too low blood supply the brain keeps driving up HR to meet demand. Total result upon exercise: supply continues to more and more not meet demand, HR rises faster and faster to try to inadequately compensate, physically become weaker especially after high output anaerobic every supply deleted in 1-3 minutes and there is no aerobic capacity cavalry with it's O2 rushing in to take over and that's when I fall off the cliff> HR spikes even faster, chest pain immediately jumps, lung edema turns on full tilt as the HR spikes and the resulting pressure is forced to "spray out of the gaskets (alveoli), and brain blood O2 supply immediately becomes super inadequate and the dizziness and need to fall over is the instant result effect. And since dysfuntioning cerebral vasoconstriction is likely the cause or highly involved in migraines, this also supports why the headaches come. ... And perhaps this explaining the rest pain and how it increases with dex and exertion because blood flow o2 becomes inadequate. Then causing lactic acid waste and CO2 buildup... (ie pain). And then it, like all body tissues being deprived necessary blood flow trigger cytokine inflammation response. ... And then, fuck it, maybe this IS chronic fatigue syndrome, and IS long covid explaining PEM, explaining why every symptom imaginable in any combination permutation is being shown, is explaining the observed elevated varing soups of cytokinesis, explaining all variety of tissue damage depending on any person's unique amount of total hit and their particular systems vulnerabilities and ultimately how far down they went on the increasing spiralling cascading systems failure towards total shutdown, and explains why measures at addressing the variety of manifestations are all somewhat helpful, but inadequate and varing efficacy from patient to patient because they are all too downstream of the root cause trunk of the symptom tree where the need to relieve vascular over constriction is the root or next to the root of the symptom tree that is common to all patients. If this were all to be accurate, then the seed would be what caused the break in vasoconstrictor system and repairing/killing it, or perhaps it's a PC bootstrap phenomenon where the simple uncomplex virus was just enough bios code to place innocuous wrenches in any of machines of the systems and then those malfunctioning systems took over control in their new malfunctioning patterns and became the new bosses that are infact the disease, you become your disease, and the initial virus seed has long been killed/departed (they're the ultimate down the road end game that is the totally corrupted bcdhhs that will then exist now as a new monstrous organism slowly lingering and depleting itself and eventually all resources at which point it will have finally killed itself after it destroyed the once thriving self sustaining world it lived in. COVID then is the teenage abusive bf or mean drunk father from their past, that put in motion what would become decades and generations of monsters, years and years after they had been long since gone). And maybe this explains the phasing leaving and returning it symptoms. Because when enough if the symptoms start to be reset/repaired, that starts spiraling the spread of the shutdown of the corruption back to health, but if the spiral up isn't strong enough to overcome the consequential reactive spiral down response, the monster returns and the rebellion is quashed. And so explains why the overall, in every system, stronger less vulnerabilities less armor chinks youth are able to quash with ease the spiral down with their incumbent exceptional spiral up response. .... And aside, this explains why dysautonomia has become a top suspect. And explains why POTS has become almost synonymous with long COVID and CFS.

    1. 2019 CB issued revised and new policies that allow title IV-E agencies to claim federalfinancial participation (FFP) for administrative costs of independent legal representationprovided by attorneys representing children in title IV-E foster care, children who are candidatesfor title IV-E foster care, and their parents for “preparation for and participation in judicialdeterminations” in all stages of foster care legal proceedings.
    2. In April 2020, CB issued a new policy clarifying that administrative costs for paralegals,investigators, peer partners, or social workers may be claimed as title IV-E foster careadministrative costs to the extent they are necessary to support an attorney providingindependent legal representation to prepare for and participate in all stages of foster care legalproceedings for candidates for title IV-E foster care, youth in foster care and his/her parents andfor allowable office support staff and overhead expenses
    1. irst, judges do not receive sufficient information to make aninformed decision regarding reasonable efforts. Usually, the only information comes from the agency

      Haylie is not providing any information to the judge, e.g.: - harboring not addressed - intake lied - intake failed to meet promise - intake actually DROVE removal, as in "negative reasonable efforts" - intake did not provide allegations at first contact or ever; and also therefore, 2., did not collect response, and necessary danger data and necessary services/needs data - intake did not provide, therefore, a credible report informing court of true nature - intake offered no FFPSA designated services nor Core Services Program services - intake provided no list of services offered/provided, no list of identified needs, no explanation of how it succeeded or failed - magistrate did not examine, inquire, or document specifically and detailed the reasonable efforts in "The Prevention Plan"...I've seen no Prevention Plan and certainly not filed with the court - Visitation scheduler: 1) not competently trained in youth or resist and refuse; only 1.5 years licensed (probably no clinical practice) and self identified adult addiction, 2)provided no scientific backing for recommendations, omitted context to misrepresent truth, did not identify needs, provided no plan to resolve/address those needs especially science-backed (and found to be an intern), 3)was 3+ weeks late for 1wk due date - caseworker was assigned over a month later and is mandated to be immediate at time of 1st hearing - CASA was not assigned until 4 months later and i've still never heard from them - caseworker was told must provide allegations report and still did not and would not - family needs assessment was never done, certainly not in my presence, nor with my collaboration and agreement, if in the background there is one it is a lie or of completely insufficient quality and was not reported to me when asked for. It was not done even close to 60 day (therefore also does not meet mandate of "timely") deadline (and if it's dated as such it is a complete BS non-assessment only for the purposes of making it show up on a log as done). It does not identify needs/problems (most importantly resist/refuse) that brought forth D&N, it does not identify services that address the particular needs (most importantly a resist/refuse doctor; also actively blocked FUP) (and therefore nothing is science based "trauma informed" as mandated), it does not mandate what must be changed/achieved and the marker for that achievement; I still was not given Service Plan when I pried and pried for clear list of items that brought forth D&N-what was needed to change/achieved to end State's involvement-what services were/could/wanted to be done - DHS has failed to investigate it's actions of abuse to confirm/deny; which in the case that abuse did not happen 2. has failed to meet "timely" mandate of services to medically assess and treat resist/refuse and 3. failed "reasonable efforts to reunify" mandate - DHS has not only 1. failed mandate to offer/make available/refer & monitor and ensure execution of services/ (e.g. Core, FFPSA, "unique to family needs", "public or private/community bases", "evidenced based", "trauma informed...further defined in CCR as "complete situation assessment/treatment, whole family") they 2. made ME responsible for REFERRING THEM and with an expectation it likely WOULD NOT BE PURSUED, 3. was essentially told Core Services wasn't real (was ignored and then simply would not answer when i asked directly in-person about "Core Services" and changed the subject) when I specifically asked, 4. mocked when I gave science backed warning of imminent and severe risk and necessary doctor services needed - court did not set adjudication until 2+ months past federally mandated 90 day MAXIMUM (and is written as "should be much sooner and ASAP", and 2. almost 4 months after 20th District's filed D&N management commitment plan - Independent Assessment: did not meet many many mandates (see email to Haylie on objection to recommendation) - QI did not include family, claims 6 attempts to call but did not as mandated provide evidence of attempts, State did not meet mandate to make sure family was included in the process and ACTIVELY KEPT MOM & DAD & ATTORNEYS as mandated of the mandated Family and Permancy Team Meeting; did not complete in 10/14 day CDHS mandate nor did complete in 30 day federal requirement (which is also contractually owed by ASO); never held a 2nd Team meeting as requested (which resulted in a ruling based on false argument that would have been quashed in the meeting and also the QI realizing and changing her recommendations with the knowledge that the false claim was not only indeed false but that the credibility of information provided by state & CYF was now in question; and ultimately a result of a QI would have full & true understanding of medical need and severity and harm befalling child and family and would have urgently recommended necessary interventions which had so long been failed to be recognized/provided by State) - Court nor State was informed of fundamental FFPSA law as is absolutely expected to be known by a Child Welfare Judge and Child Welfare Attorney and Child Welfare Agency, at QRTP Assessment Review Hearing and made ruling on completely false law justification that child is not legally allowed to remain at the QRTP [b/c of course she is, which is the whole point of the hearing, b/c it's up to judge to determine if she should stay or not regardless of IA summary report recommendations

    2. One conclusion this book reaches is that reasonable efforts should belitigated early,
    1. Dr. Childress Second Opinion ConsultationThis handout describes various options for incorporating the second-opinionconsultation of Dr. Childress on an assessment, diagnosis, and treatment plan for court-involved family conflict. I am able to provide second opinion consultation to the involvedmental health professionals if they or the court believe this would be helpful in theresolution of the family conflict through my HIPAA compliant online telehealth office atdoxy.me/drchildress.
    1. RPC who address ancillary civil issues earlier in a case can make a significant impact and reduce thenumber of out-of-home placements. This is because unresolved civil legal issues can drive continualchild welfare involvement in the lives of some indigent families. Indeed
      • TANF
      • Child support
      • DUI and warrant
      • Car title
      • Disability
      • FUP
    2. Providing early help with lawyers trained to address housing, immigration, domestic violence,healthcare, and public benefits issues may help “prevent children from entering foster care or helpchildren return home sooner.”93
    3. Contracting with professionals to assist in providing agency supports and to conductquality assurance, supervision, and mentoring of ORPC contractors such as attorneys,social workers, family advocates, and parent advocates; and,
    1. State Government Agency Appeals 1. What is an appeal of a state government agency decision or action?

      Colorado Judicial -self help

    1. for other good cause shown, the appellate court may, except as otherwise provided in C.A.R. 26(b), suspend the requirements or provisions of any of these rules in a particular case on application of a party or on its own motion and may order proceedings in accordance with its direction.

      26(b)"Legal Holiday" Defined.

    1. If any information obtained from the household differs from that which the State agency obtained from available information or the household provided additional changes in information, the State agency shall arrange for the household or it authorized representative to initial all changes, re-sign and date the updated application and provide necessary verification.
    2. Discrepancies. Where unverified information from a source other than the household contradicts statements made by the household, the household shall be afforded a reasonable opportunity to resolve the discrepancy prior to a determination of eligibility or benefits. The State agency may, if it chooses, verify the information directly and contact the household only if such direct verification efforts are unsuccessful. If the unverified information is received through the IEVS, as specified in § 272.8, the State agency may obtain verification from a third party as specified in paragraph (f)(9)(v) of this section.
    1. effect of the decision in Hill v. Hawes is to give the district court power, in its discretion and without time limit, and long after the term may have expired, to vacate a judgment and reenter it for the purpose of reviving the right of appeal.

      Take this in combination with my previously made arguments of ccr meeting convenience, using electronic mail, law stating lack of receipt of notice as good cause....as well as ccr rules about good cause includes homelessness and disability. *Look for precedent on good cause (hell, look for a source of precedents and law interpretation period, and then look up perfect on everything,.. reopening appeal, BCE, reparations, damages, fcs case)

      Also, at minimum for strategy to reopen: use anything as an avenue for an action to be taken, then appeal it using misconduct as a just and request an opinion on the interpretation interpretation of law (if can't just directly ask the higher court to make a ruling as part of the lessor request). Mechanism thoughts: 1. With TANF final decision, ask for a reconsider or file a motion asking for both an order to reinstate snap as well as an interpretation of the law that the household in its ENTIRETY is included under BCE. 2. Going direct to higher court- I think can choose either. Might have read that COA lacks ability to order/remand/compel, technically speaking.

    2. party may, of course, serve timely notice of the entry of a judgment upon the adverse party and thus preclude a successful application, under Rule 73(a), for the extension of the time for appeal.

      Good to know. Plus, the county did not take advantage of this

    3. Time to Appeal

      See amendments notes below

    1. Using Court Facilities

      Call it email if you want

    2. court's electronic-filing system o

      Perfectly valid serving method allowed by law, state has one, both a court e system as well as regular email.

    3. person has no known address

      I had a known address. And I had also provided an option.

    4. mailing it to the person's last known address

      Lashley was not my last known address, my email address was my last known address.

      General delivery was not my address, it was discussed that it may be used as an option, "an alternative method which I gave consent to" which mandated notifying me by phone or email.

    5. must be served
    1. although the judge may agree there are no material issues of fact remaining for trial, the judge may also find that it is the non-moving party that is entitled to judgment as a matter of law
    2. In the United States, the presiding judge generally must find there is "no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law."[2

      Really Haley?? You could not argue that,

      1) there was no genuine dispute over the material facts....over "what happened, AND what realities/possibilities/options/resources/outcomes exist" ????

      2) that I was not entitled to "judgment" regardless of "material facts being in dispute" OR NOT "in dispute". For starters, a for a trial review of the facts regarding the determination of grounds that have been brought forth, not brought forth, and mis-presented, and additional are due and necessitate the compelling process of discovery in order to assure provision of, and of which a collection is already known by respondent and counsel to exist which the court has not been made of and who's determined clarity resulting from the analytical vetting the trial will provide holds the potential power to not just determine whether the state had grounds, but regardless of that outcome, to help all parties determine collaboratively and aided by the authoritative might of the court how the state can best provide help and services going forward, including if appropriate removing themselves from intruding a moment further in this family's lives and liberties. .... FACTS I'VE BEEN SHOUTING AT YOU FROM DAY ONE AND IN A MILLION EMAILS TO YOU OR BEEN CCED. YOU'RE A FUCKING MORON, BY WAY OF UNLAWFUL COMPETENCY OR NEGLECT TO YOUR CASE, YOUR DUTY TO SELF INFORM, AN ENTRUSTED BY AND SWORN TO THE PEOPLE OATH, AND YOUR KNOWN DUTY TO THE DEADLY VALUE, PURPOSE, AND CONSEQUENCE OF YOUR POST, a post for which you are additionally compelled to perform by, albeit less importantly, a meaningful wage.

  7. Jun 2023
    1. In a similar study design but with a longer follow up (3 months from diagnosis of COVID-19) 16 young adults were investigated for brachial FMD, cerebral vasodilator function and arterial stiffness. Out of these 16 participants, eight were still symptomatic while the others did no longer display signs of COVID-19