SUPERIOR COURT OF WASHINGTON FOR PIERCE COUNTY

Dated this 4th day of June, 1999, in Kirkland, Washington.

Address: 9757 Juanita Drive NE, Suite 124, Kirkland WA 98034

1. I certify under penalty of perjury under the laws of the State of Washington that the following statements are true and correct to the best of my knowledge. The documents referenced herein are true and correct copies that I have received from the referenced state agencies and persons giving the declarations.

2. I am over the age of eighteen, am competent to testify and have personal knowledge of the facts stated herein.

3. The purpose of this declaration is to address the specific fraudulent misstatements of facts set forth in my daughter’s, Hope Robbins, affidavit

filed in the States’ Motion for Summary Judgment filed in Cause Number 96-512RJB, Western District of Washington. I do not my believe my daughter perjured herself because I believe the declaration was prepared for her and she was on drugs when the declaration was presented to her. This belief has been confirmed in several ways. First, Hope Robbins did not write in the corrections on the declaration. The difference in hand writing is obvious and this has been confirmed by a hand writing expert. Second, a hand writing expert has indicated that given the purported signature of Hope Robbins, my daughter may have been on drugs when she signed it because the signature varies from her other signatures on other documents. Third, I know from personal observation that when the State has presented my daughter for hearings, she has obviously been on drugs to sedate her in the hearing. One such hearing is the one of the hearing before Judge Sellers in the Alternative Residential Proceedings.

This affidavit was contested when it appeared in the federal court case file because it is fraught with inconsistencies readily apparent when compared to the Department of Social & Health Services case file regarding my daughter, as well as the police and Administrative records. This is an affidavit sworn by a person disabled by mental problems from birth [SEE Judge Bauer Exhibit]. A disabled person for whom DSHS has assumed control , care and custody. As to her status as an adult, the Department of Social & Health Services and the Social Security Administration have deemed her to be in need of supervised care after DSHS sought and received an order to the effect that she is severely mentally disabled. On March 3, 1995, Administrative Law Judge John F. Bauer ruled that Hope "has been disabled since August 18, 1978, her date of birth." In his ruling he adds "Testing revealed seriously delayed mathematics and skill scores. On psychiatric evaluation, her affect was inappropriate, and she tended not to accept responsibility for her actions... This condition causes significant functional limitations, especially in personal-behavioral function with persistent serious maladaptive behaviors destructive to self and others and requiring protective intervention, under 112.02B.2.c. (2)... Accordingly, the claimant’s [Hope’s] condition equals the severity of section 112.08. Her condition has been of this severity since she was born." Judge Bauer’s findings also included this statement: "I recommend that the claimant undergo further treatment for substance abuse, but I also find that substance abuse is not material to the finding of disability in this case because the claimant would be disabled by mental problems even if free of alcohol and drugs." On the merits of this Administrative Law Judge’s findings, it is difficult to understand how the affidavit attributed to Norma Hope Robbins could be so easily accepted as valid or credible.

There are scores of contradictory statements, documents, evaluations, and records scattered throughout almost 10,000 pages of the DSHS case file. For example, DSHS presented its argument of ‘disability from birth’ for the purposes of obtaining roughly $39,000 in federal moneys from Social Security, yet when I had requested previously that DSHS care for Hope by having her psychologically treated and evaluated, I was told Hope was not in need of psychological treatment, my request was denied, and I was ordered to undergo psychological evaluation. When I read documents stating Hope will remain under DSHS care and supervision after her eighteenth birthday [SEE PECHMAN’S ORDER], I am outraged to know that DSHS ALSO refused to answer complaints before the Washington State Senate Law & Justice Civil Rights Subcommittee because they claim that they had no involvement in Hope’s life since she turned eighteen because she was an adult and had not told them her new address [SEE TRANSCRIPT OF ROSIE ORESKOVITCH SENATE SUBCOMMITTEE TESTIMONY]. Both cannot be true, but DSHS insists both are. The "Catch 22 Syndrome" as my son calls it. Either she is living in the Jeffery home and DSHS is her Trust Beneficiary because she is unable to care for herself [SEE IN RE TRUST OF NHR] or she is a normal adult with whom DSHS has no contact or control (as DSHS testified before the Senate Law & Justice Committee’s Civil Rights Subcommittee). Both cannot be true yet DSHS has sworn to both.

Apparently, multiple sets of ‘facts’ and documents exist, simultaneously, for the same situation depending on whether the system wants to obtain federal money, or to further limit or even terminate a parent’s rights and responsibilities. An example of this is the testimony of social workers before Judge Bauer on 2-13-1995. In certified Social Security recordings DSHS representative Karen Vallaincourt, and social worker Tina Bertness, misled the court to believe that my parental rights had been terminated, that I had continually ‘stalked’ my daughter and that there was a ‘history’ of physical and sexual abuse since Hope was one year old. None of these statements by Vallaincourt and Bertness are true. I categorically deny them in toto. When asked by Judge Bauer to produce the documentation supporting such statements, Vallaincourt and Bertness stated, repeatedly, that there were no records or documentary evidence to support this history (and thereby validate their claims). As far as evidence Vallaincourt could only provide one doctor’s report showing an injury to Hope’s arm when she was 4 years old. This doctor’s report cited the cause of injury as a fall to a hardwood floor. Negligence and abuse were not cited in any way in this report. Later in this proceeding Hope was asked to recount an early hospitalization. Although no records were produced to validate this claim and Hope could not recall the reason for the hospitalization, or it’s duration, Vallaincourt suggested to the court that the hospitalization was the result of abuse and that the Hope had been in the hospital for a very long time. DSHS knew specifically that this brief hospitalization was due to surgery to remove and correct a cyst in the bone of Hope’s upper arm. To this day Hope bears a scar in her armpit where this surgery was conducted. Bertness later made much harsher claims of physical and sexual abuse and accused me of stalking my daughter. Although she could produce no record of this alleged life-long abuse, or the more recent alleged stalking, she indicated to the court that she was going on ‘history.’

Hope was not even represented by an attorney for this hearing. She was represented by Karen Vallaincourt, an employee of DSHS, without a legal degree, who had not even informed Hope she could have an attorney present to represent her. Vallaincourt represented the interests of DSHS [SEE internal memos re Vallaincourt and the money], while also purportedly representing Hope’s interests at the hearing. Several times these divergent interests clashed as when Vallaincourt often contradicted Hope, cross-examined Hope, and led Hope into contradicting herself. Judge Bauer, himself, had to inform Hope she could be represented by counsel. Vallaincourt and Bertness also mislead the court to believe that my parental rights were terminated and that I was a dangerous and abusive parent, a risk to my daughter, and need not be consulted for verification or background information. In fact, he was told by Bertness and Vallaincourt that I had information and documentation that I refused to share with them. I was referred to as "a very hostile bio-parent." This is ludicrous as I was not even made aware of the existence of this proceeding until well after it was concluded. In this case, state employees perjured themselves, misrepresented the facts of the case, defamed the character of a parent not present (nor even notified of the hearing), and defrauded the court, and the U.S. Federal Government not only with impunity, but without the faintest hint of trepidation. When money is to be made from disability, the added benefit of fictional abuse and ensuing Post Traumatic Stress Disorder cannot be ignored, nor can the assertion that the child’s mother beat the child her entire life and is a dangerous stalker. These lies were proposed as fact, without any corroborating evidence, in direct contradiction with existing records. When state workers who were sworn under oath, whose job requires frequent testimony in court, so blatantly ignore their responsibility to be truthful under oath, or even in their own case histories; their purpose in our society becomes debased and pointless. I mention these occurrences because some of these same lies appear in the purported affidavit of Norma Hope Robbins.

An immediate example of such duplicity is the following scenario:

For the purpose of a disability hearing before Judge Bauer, Hope is portrayed as unable to work, unable to get along with others, unable to mentally function, unable to care for herself, unable to perform tasks a normal young woman would, should, or could. Additionally, she is classified as destructive to herself and to others. She is deemed in need of continued care and supervision, and "protective intervention." Yet when the intent is to dismiss a federal civil suit before the very first word of witness testimony is heard, the "severe disabilities" are forgotten and an affidavit portraying a perfectly rational and balanced individual who is capable of determining her best interests, stating her opinions, and apparently understanding complex legal arguments as well, is submitted in her stead. Which is true?

Hope was a missing person at the time the affidavit was submitted. DSHS claimed to have no idea of her whereabouts, welfare, or living arrangements, although the service plan at the time stated Hope was in the Jeffery’s’ foster home, although that home was not licensed as such, and although Jeffery’s’ stated Hope hadn’t been there since August 16, 1996. And still yet this document surfaces and is regarded with surprising credibility. I have to question how a child who is so completely out of the loop came to know about, or receive documents in regards to this case, when even her Guardian Ad Litem could not find her.

What little discovery I managed to get in a timely manner was disjointed and contradictory. I petitioned the court repeatedly for up-to-date discovery. I was forced to resort to submitting Freedom Of Information Act and State Public Disclosure requests to obtain records and files that should already have been provided. As more of the records involving my daughter came in, I was confused and angry about what I was finding in them. There were several different scenarios portrayed in these state documents. Caseworker notes for the same time-frame contained vastly different accounts of Hope’s treatment, welfare, living arrangements, and educational progress. I was told by Hope’s caseworkers at relevant times that Hope was in school and doing well, that she was clean of drugs and alcohol, and was adapting to foster care wonderfully. The records I obtained years later showed her to be a truant runaway who had drug, alcohol, and mental problems, and also a criminal record. I was not notified of significant events such as suicide attempts, drug treatment, car accidents, or arrests. When I did learn of such events and reported them, I was told that it would be investigated or looked into. The persons investigating these reports consistently were told by DSHS employees that I was an abusive mother who made false accusations and was stalking my daughter (the very same tactic along with a failure to notify me of the hearing, which excluded me from presenting any evidence during the Social Security hearing). These investigations were invariably ruled ‘unfounded’ and were dismissed as untrue. On many occasions the investigations were conducted without interviewing witnesses or viewing the documentation. The whole and sum of some such ‘investigations’ was a single telephone contact with the Department of Social & Health Services. It was not until after my daughter’s eighteenth birthday that I received the bulk of discovery documents pertaining to these events and discovered them to be much as I had initially reported them. I have even discovered records from one such ‘investigation’ that flatly stated, "I have already looked into all of these allegations: UNFOUNDED!." The most disturbing fact of this so-called investigation is that there were police and DSHS records available at the time showing the alleged incidents actually happened. Yet the officer quoted above never even looked for them. Her investigative technique was to phone DSHS.

Aside from Hope’s mental disability, or the inconsistencies surrounding state records, or incomplete police investigations, I would like to focus on the content of the affidavit itself.

In response to Section 1 of the Affidavit of Norma Hope Robbins:

This section states Hope was under the jurisdiction of the Department of Health and Human Services, Division of Children and Family Services. That department is a federal office based in Washington DC. Washington State’s analogous office is the Department of Social and Health Services. Although this is most likely a typographical error, the presence of various federal moneys may have placed jurisdiction with the DHHS. I have submitted FOIA requests to this federal department to determine what, if any, jurisdiction it held in Hope’s care and treatment.

In response to Section 2 of the Affidavit of Norma Hope Robbins:

The affidavit states that Hope reviewed the legal papers and came to some conclusion as to their meaning and was, it is implied, disappointed that such proceedings were ongoing without her direct involvement or consultation. Again, I must question how, if neither her GAL. nor DSHS could locate her, she came to be in possession of this information. Ironically, a major concern which lead to this suit were statements and records by state employees and contractors indicating Hope was missing, had been abused, and was in danger of continuing sexual, physical, and emotional harm due to the negligence of DSHS [See Lillivic’s motion]. It is only another example of this pervasive dichotomy that this affidavit exploits Hope’s status as missing, turning it around to say she was insulted she had not been consulted. Even her Guardian Ad Litem, Robert I. Deutscher, was unable to locate Hope during this time.

In response to Section 3 of the Affidavit of Norma Hope Robbins:

Again, it is very difficult to contact, much less converse with, a missing child. .GAL. Deutscher was unable to locate Hope due to a lack of cooperation from DSHS, and also Hope’s status as missing. Hope’s ‘understanding’ of the court orders is a very significant feat for such a severely disabled person with cognitive and other mental disabilities.

In response to Section 4 of the Affidavit of Norma Hope Robbins: Regardless of the wishes expressed in this affidavit, the ‘causes of action’ listed in the complaint were brought forward in good faith by myself and my attorneys based on witness accounts, state and federal documents, videotaped court testimony by social workers, and investigations by private detectives, attorneys, social workers, and my own family; all of which indicated abuses had, and were continuing to, occur.

In response to Section 5 of the Affidavit of Norma Hope Robbins: While technically correct, this does not say she became an adult. That ‘Catch 22 Syndrome’ again. The Administrative Law Judge’s ruling and subsequent actions by DSHS deem her to be in need of `protective intervention’ and continued care and supervision. Why not simply state, ‘I became an adult and am capable of pursuing my own legal remedies?’

In response to Section 6 of the Affidavit of Norma Hope Robbins: Beginning with this section, the affidavit attempts to tell what is reportedly Hope’s side of the story. A story with no relation to the witness testimony, state and federal records, or her own experience, caseworker’s notes, journals or diaries.

In response to Section 7 of the Affidavit of Norma Hope Robbins: Hope was removed from school on March 26, 1993 on allegations of physical abuse which were found baseless in three separate investigations by local, county, and state agencies. Although I did not receive the documents of these investigations until 1997, I found that Detective Elaine Hood of the King County Police reviewed the allegations and found the "initial referent information... incorrect." She also noted, "self defense." [See Elaine Hood’s report etc] She closed the case, indicating no abuse had occurred. [INSERT HERE THE MANY QUOTES FROM THE RECORD INDICATING HOPE’S UNRELIABILITY] The King County Prosecutor’s office found nothing to be prosecuted, since no crime had occurred.

In the agreed order of dependency mentioned in this section, you will NOT find my signature. I was not there (having been told by Jana Heyd, my attorney, that it was an informal hearing and my presence was unnecessary) and had not reviewed the proposed order. In fact, that very order wasn’t signed by my attorney either. It is signed by a third party reportedly for Jana Heyd for me as per telephone instruction. As I did not speak with Ms. Heyd or the third party on that date, and had no knowledge of that order until much later, I wonder whose telephone instructions these were, and to whom they were given.

In response to Section 8 of the Affidavit of Norma Hope Robbins:

From the thousands of pages of documents received in discovery, not one describes any educational progress by Hope, nor does it describe any continued education after the Autumn of 1993. After late 1993, there is no record of schooling at all. Neither at Highline High School nor in any GED courses. Interviews with the foster parent Peggy Jeffery, show Hope never went to school during the time she was placed there. Nor did she attend school while at the Blackwood home. In fact, in many Missing Persons Reports by King County Police we see the "Student at:" box marked with "Dropped out," or "Does not attend." To this date DSHS has refused to provide complete discovery relating to Hope’s several placements. So, while, it is possible Hope attended school briefly while in these placements, DSHS has made no action to provide me with evidence of such continued education.

In response to Section 9 of the Affidavit of Norma Hope Robbins: My position as to this accident is not solely concerned with medical treatment or lack thereof, it is concerned with the accident itself. The vehicle crashed head-on into the Hood Canal Bridge. The driver was Mikki Swindler a person who had no legal authority or permission to care for Hope, or to have her in her custody and who provided illegal foster care for Hope with Victoria Asher. Ms. Swindler is a lesbian who worked as a stripper. Ms. Swindler was also intoxicated at the time of the accident. Any injuries or medical treatments are secondary to the apparent negligence necessary to allow the accident itself to occur.

In response to Section 10 of the Affidavit of Norma Hope Robbins: Again, the pursuit of legal remedy in the ‘hit and run’ case is incidental; the concern was that Hope was involved in such an accident at all while supposedly under "constant care and supervision," while receiving "protective intervention." My family was not notified of this accident which occurred while Hope walked alone to her workplace. The accident did lead to medical treatment and was never reported to our family by CPS as is mandated by law. Another concern is how a "severely disabled" child "in need of constant care and supervision" came to be walking alone to her job in the first place.

In response to Section 11 of the Affidavit of Norma Hope Robbins:

This entire section is misleading. As was frequently the case with DSHS information, I did not learn of the foster home locations until well after they had become irrelevant. I did not ‘stalk’ my daughter at these various locations. I not only could not find her, I was rarely, if ever, notified she was even missing. Aside from blaming the cause of her runaways on ‘stalking,’ each of the several caseworker documents and police reports attributed her status as missing to not liking the house rules, leaving with adult women, and being physically abused or neglected. Again it seems the affidavit has overlooked evidence readily apparent in the casefile. In a confidential memo dated May 10, 1995 from Nancy Zahn Acting Regional Administrator to Bonnie Jacques, Field Services Office Chief, the stated reasons for Hope’s frequent runaway status are the following: "she did not accept the structure of the foster home," another was, "Hope ran due to restrictions," another was, "The foster parents were involved in the Lesbian community. DCFS was unable to stabilize Hope, and she continued to run a great deal of the time." This is the foster home referred to by Hope in caseworker notes as being, "political, weird, and pushy." Shortly thereafter she pleaded with the social worker, "Please don't place me in anymore lesbian homes." Not one such report indicates stalking of any kind, nor is it even mentioned. In transcripts of Administrative Law Judge John F. Bauer’s hearing on February 2nd, 1995, the following reason is given by Hope, herself, as to why she ran:

Karen Vallaincourt (KV): "What precipitated your running away, this last year[1994] in foster care?"

If, as this affidavit states, this stalking behavior has been documented, where are the documents? I think the ‘stalking’ excuse is ridiculous at best considering the dearth of evidence indicating so, and the wealth of evidence claiming otherwise.

In response to Section 12 of the Affidavit of Norma Hope Robbins: This brief dismissal of the dog-collar incident ignores the affidavits of eyewitnesses, one of whom was the manager of the property. It also ignores reports identifying Hope’s residence as the location of this incident at the time it occurred while living there with the suspects. Also ignored is the admission by Vikki Asher to the King County Prosecutor’s Office that the dog collar incident had actually occurred, in order to "screw with a nosey neighbor [verify this quote with the Larson interview]."

In response to Section 13 of the Affidavit of Norma Hope Robbins: Statutory rape and assault by adult lesbians is not only my ‘claim’ but the sworn testimony of Betsy Schelien, Hope’s caseworker, whose statements and case notes indicate she had direct knowledge of this matter and had discussed it with the perpetrator several times. She also felt the need to report this to the authorities because not to do so "would fall back on the department’s (DSHS’s) head." The investigations by police, mentioned in the affidavit, followed the pattern of failing to interview witnesses, or view documentation. Although it is true Hope was interviewed in regards to these allegations, the affidavit neglects to mention that the opinion of DSHS was, "The allegations of Hope’s involvement with Christine were accepted as probably valid; but were "hearsay" and not substantiated." Dr. Joan Davidson also documented Hope’s "`former lover’ A woman Hope met through A.A. in Burien. Hope seemed amused that this outraged her mother." In the psychiatric evaluation performed by Dr. Joan Davidson M.D. on April 7th, 1994, Hope readily admits to the sexual relationship with Kristina Leigh Auxier (who is more than 48.5 months older that Hope)[See Susan Flanagan Sill’s report for the Prosecutor’s Office].

The allegations of sexual assault "on numerous occasions" while in my care are baseless and false. While in my care, on only one occasion was the subject of sexual abuse of any kind raised. This happened after my oldest son, Thomas, came home to discover his sister in bed with an older boy. My son physically removed this boy and told me about the incident that night. He felt he had done the right thing and was open about it during our conversation. Hope admitted to the behavior and was ‘grounded.’ It was after this incident that Hope claimed to have been "touched" by Thomas. Thomas was angry and confused by the allegation. My younger son, Dennis, told me that Hope had said she would "get Tommy back." The truth of the situation was obvious to me. The subject was never raised again and at no time prior to her care by DSHS did she mention any sexual contact or abuse by her step-father. DSHS asserts this alleged sexual abuse occurred from the time Hope was one year old, and was ongoing for years in Kentucky. Why then is there no mention of it whatsoever in any of the doctor’s reports, medical records, social worker documents, etc. from Kentucky?

In response to Section 14 of the Affidavit of Norma Hope Robbins: This section is somewhat irrelevant in content, yet it is very informative when one realizes the information was supplied by someone other than Hope. What was the source of the initial, incorrect, and outdated information? If one is to believe Hope walked into the Northwest Women’s Law Center, alone and unaided to draft an affidavit, one would assume she would remember both of her tattoos. Yet whoever drafted this affidavit knew of only one. Both should have been listed as this affidavit was supposedly written when she had been eighteen for only eight days. Who provided the information used to draft this affidavit?

In response to Section 15 of the Affidavit of Norma Hope Robbins: The existence of the no contact order is very real. It is a subject which infuriates me to this day because of how it came into play. Judge Marilyn Sellers issued the no contact order due to allegations of ‘stalking’ that were reported to her. The ploy was that I was an unstable and dangerous mom out to do harm to my child. The exact opposite was true. I had evidence and testimony showing my daughter to be the victim of statutory rape. The caseworker verified this was occurring. I petitioned the court for a no contact order to be placed on the reported rapist, Christina Auxier. During her ruling, Judge Sellers ordered me to have no contact with my child, and refused to place Ms. Auxier under the same restrictions. She feigned ignorance of the law as it pertained to mandatory reporting of sexual abuse, or investigation of such, and then suggested Ms. Auxier obtain a restraining order against my daughter, for her own protection! In effect, she told the rapist to protect herself from the victim while denying the victim the same protections and ignoring the issue of rape itself. As for the "lengthy 72 hour Shelter Care Hearing," the length of time March 26th, 1993 when Hope was last in my home to March of 1995 is certainly far more than 72 hours out of the care and custody of her family. While the affidavit mentions the Shelter Care Hearing, it curiously neglects to mention that the Fact Finding Hearing required by law in the Dependency process was repeatedly postponed and had still not occurred by the time Hope turned eighteen.

The statement, "She has done nothing in the past several years which would lead me to believe that I would be safe if I were to have contact with her," causes me pain and anger because I have done nothing to harm my daughter. The position that I am dangerous to my child is preposterous. I have spent five years attempting to expose the neglect and abuse she and other children suffered while in state care. What parent would dedicate years of sacrifice and emotional turmoil to rescue her child from abuse or neglect in any form, then abuse the child further? The idea is ridiculous, that it would apply to this situation is doubly so.

In response to Section 16 of the Affidavit of Norma Hope Robbins:

This section illustrates perfectly the differences between the casefile and the reality of the situations it describes. The order by Judge Pechman says very clearly that Hope would remain in the Jeffery’ foster home, although it is unlicenced, after her eighteenth birthday. This is because of her evaluated need for "constant care and supervision." The truth is that on August 16, 1996, two persons identifying themselves as DSHS employees came to the Jeffery’ home and left with Hope who has not lived there since according to Ms. Jeffery. From this date forward DSHS has claimed no knowledge of Hope’s circumstances.

The original section of the affidavit reads, "I am not missing from state custody. Since February 1996 I have been residing in the same placement, which has been sanctioned by the court." This says very directly that Hope continued to live in the Jeffery’ home which was per court order. The amended section reads, "I am not missing from the state’s custody. From February 1996, to August 16, I resided in the same placement, which has been sanctioned by the court." The amendments change the content entirely. I have serious questions and concerns about this inconsistency. Why was the court order sanctioning Hope’s placement with Jeffery after her eighteenth birthday not followed? Why are there documents stating clearly that Hope would remain with Jeffery until her twenty-first birthday, yet she was moved from that home two days before her eighteenth? If she did not reside in the sanctioned home, where did she reside? Again there are two scenarios, diametrically opposed. DSHS asserts both are true when only one could possibly be. Why are such blatant inconsistencies not investigated? What is going on with Hope’s living arrangement, and why the discrepancies in the records? Especially concerning to me is the eviction from a one-room "cubby-hole" apartment in Seattle. DSHS, through the Seattle Guardianship and Trust, arranged tens of thousands of dollars for Hope’s care. Yet, she is evicted for non-payment? Where were those tens of thousands of dollars?

In response to Section 17 of the Affidavit of Norma Hope Robbins:

I have no personal knowledge of the interaction between my daughter and her caseworkers other than caseworker notes, and the interviews with Ms. Jeffery. Jeffery stated Tina Burtness would spend hours at her home, pacing in front of windows and telling Hope that I was stalking her and that she had better be careful, because I was looking for her. Jeffery also stated that Ms. Burtness purchased cartons of cigarettes for Hope, and had Hope’s DSHS casefile in her car’s trunk for months at a time while they were being requested by various offices and individuals, including myself. Such actions hardly seem to me to be "tremendously helpful" or even legal. Betsy Schelien’s testimony and case-notes indicate a sexual relationship between Hope and "Kris" (Kristina Leigh Auxier) that concerned her so that she felt it might "fall back on the department’s head." Yet she tells the King County Prosecutor’s Office that she had no knowledge of a sexual relationship. Again, this seems to me to be more like obstruction of justice than `tremendously helpful.’

In response to Section 18 of the Affidavit of Norma Hope Robbins:

The actual date of the assault mentioned is March 15, 1994. I find it difficult to believe that Hope was in the courthouse on March 12, 1994. Surely none of the rest of us were. It is not surprising that no assault happened on that date. The hearing in question was not until three days later at which time several witnesses (including parole officers and security guards) saw and described the assault that occurred. The investigation by the City Attorney’s Office is another of those that was performed by officers who first contacted DSHS and were told that I was an abusive mother who was dangerous to my daughter. Either that or they were so well qualified as investigators they need not interview witnesses or consult the victim before discerning the actual events, as they did neither. On this same date a fraudulent ARP was filed by Page Ulrey and David Richards for Hope that contained knowingly false and misrepresentative information. This ARP petition was used to provide false information to the Police.

In response to Section 19 of the Affidavit of Norma Hope Robbins:

The statements contained in this section of the affidavit are in direct contradiction with police, social worker, and administrative reports. The missing persons reports, regarding the Blackwood home, state "Suspected Reason for Leaving: UNHAPPY HOUSE RULES." The date was 3-04-94. Under the heading: "Has Left/Ran/Escaped Before" the answer is "Yes." The date of this previous run is given as "0993." When reviewing the previous missing persons report, the following information is given: "Suspected Reason for Leaving: UNK WHO SHE MIGHT BE WITH. LEFT BECAUSE SHE DOESN’T LIKE HOUSE RULES." When asked if child had left before, the answer was: "YES 1 ½ months ago." Yet the affidavit is unambiguous in stating Hope ran only once, due to stalking. The statement, "Neither Mr. Or Mrs. Blackwood ever assaulted me as alleged in the complaint. They never yelled at me and never raised a hand to me," is patently false. The confidential memo from Regional Administrator Zahn to Field Service Office Chief Jacques contains the following: "The foster mother (Marjorie I Blackwood) acknowledges the foster father slapped Hope; there were no bruises or injury." Hope ran from the Blackwood’s home for the final time soon afterwards. Questions: If Hope ran only once, and then after discovering, "Alma had found out I was staying with the Blackwoods," and "I felt very unsafe, so I left," then how can it be explained that Hope left repeatedly from the Blackwood home for Unhappy House Rules?" returning each time, and there was no mention of ‘stalking’ by me, or anyone else, in the reports? In fact, Hope ran so often from the Blackwood’s home that, in the Confidential Memo, it is stated, "The CPS worker who investigated the allegations about the foster home stated that over time the foster mom became discouraged to report runs due to what she perceived as a "don’t bother us" response from Law Enforcement." Why would the affidavit claim neither foster parent had ever yelled or raised a hand to Hope when even the in-house investigation found that Arthur Blackwood had slapped Hope presumably after at least raising his voice before striking her? Again, why are such inconsistent statements regarded as credible?

As a final statement on the matter, Hope’s own testimony to the Administrative Law Judge, states quite simply why she ran.

KV: What precipitated your running away, this last year [1994] in foster care?

In response to Section 20 of the Affidavit of Norma Hope Robbins:

While Ms. Jeffery’ number of offspring may certainly be impressive to some, I find it immaterial to the pattern of abuse and neglect documented in the 2,400 pages of her DSHS foster home licensing file we were able to obtain through State Public Disclosure requests and discovery. Whether she is Hope’s best friend is irrelevant as well. The "very emotionally safe environment" mentioned does little to describe the very physically unsafe environment of the home Jeffery ran for "about 30 years." The accounts of other children who once lived in the Jeffery’ foster home and the sheer number of complaints by children, neighbors, parents, boyfriends, and social workers who knew, and interacted in, the Jeffery home environment overwhelmingly paint a picture of squalor, drug abuse, sexual misconduct, unsafe living conditions, safety concerns, disease, pregnancy, and still other complaints deemed founded by DSHS. I pray such "open and non-discriminatory" foster parents are a rarity.

In response to Section 21 of the Affidavit of Norma Hope Robbins: Again because my attorneys could not consult a missing child, the charges should be dropped and the evidence should continue to be ignored. At least the implication of the affidavit suggest so. The allegations are implied to be laughable and unsupported while I am given the attribute of craziness. Yet so much evidence exists in the state documents, the witness affidavits and testimony, and the money trail, that to ignore them is arrogance personified, are we all to believe that these contradictory statements are somehow more reliable than our own common sense and factual documents?

These are only a few of the inconsistencies found throughout my family’s life in the past six years, and each was found in just this one document: the purported affidavit of Norma Hope Robbins.

I declare under penalty of perjury under the laws of the State of Washington that the above declaration of mine is true and correct to the best of my knowledge and belief.