WHY DID PHILLIP L. BROWNING FAILED TO INVESTIGATE THE FOLOWING CASE?
COUNTY OF LOS ANGELES
STEPHANIE M. WILSON No. VD065587
HASHIM M. BOMANI
I, HASHIM M. BOMANI, declare:
I am the Respondent in the case entitled, Stephanie M. Wilson vs. Hashim M. Bomani, pending in this Court as case number VD065587.
Documents attached as Exhibits provide relevant evidence that shows, with certainty that the Petitioner intentionally and blatantly disrespected and disobeyed Court Visitation Orders issued by this Court.
Documents attached as Exhibits provide relevant evidence that shows, with certainty that the Petitioner has intentionally kept and withheld children from Non-Custodial Parent.
Documents attached as Exhibits provide relevant evidence that shows, with certainty that the Petitioner has used the children as pawns in order to cause pain, suffering and alienation to Non-Custodial Parent.
I. THE COURT IS REQUESTED TO AWARD 50% LEGAL AND 50% PHYSICAL CUSTODY WITH REASONABLE VISITATION OF THE MINOR CHILDREN TO RESPONDENT
Respondents rights in the companionship, care, custody, and management of Respondent’s children is a cognizable and substantial right that is extended to Respondent, and is within the protection of the federal due-process and equal-protection clause. Thus, absent a powerful, countervailing state interest, the Respondent’s relationship with his children must be protected (Stanley v. Illinois (1972) 405 U.S. 645, 649-659, 92 S. Ct. 1208, 31L. Ed. 2d 551; U.S. Const. amend. XIV; In re Keisha E. (1993) 6 Cal. 4th 68, 76, 23 Cal. Rptr. 2d 775, 859 P. 2d 1290). Furthermore, minimal due process requires that the state establish parental unfitness by clear and convincing evidence before terminating parental rights. (Santosky v. Kramer (1982) 455 U.S. 745, 747-748, 102 S. Ct. 1388, 71 L. Ed 2d 599). Moreover, direct evidence located in declaration filed, May 19, 2010, which documents Respondent’s character as a caring and loving father, a Credentialed Teacher authorized by the State of California to teach children in grades K-12, as well as his community role model status and honorably serving in The United States Military bares as conclusive and compelling evidence and testimony to Respondent’s outstanding character, and warrants this Court to consider granting all relief sought by Respondent.
Respondent prays that this Court considers FAMILY CODE SECTION 3040-3048, which specifically states in FAMILY CODE SECTION 3049(a), Custody should be granted in the following order of preference according to the best interest of the child as provided on Sections 3011 and 3020: (1) To both parents jointly pursuant to Chapter 4 (commencing with Section 3080) or to either parent. In making an order granting custody to either parent, the court shall consider, among other factors, which parent is more likely to allow the child frequent and continuing contact with the noncustodial parent, consistent with Section 3011 and 3020, and shall not prefer a parent as custodian because of that parent’s sex. The court, in its discretion, may require the parent to submit to court a plan for the implementation of the custody order.
II. PETITIONER IS A MEMBER OF A CULT RELIGIOUS ORGANIZATION WHICH ENGAGES IN PEDOPHILIA AND CHILD SEX ABUSE CRIMES
Respondent respects the right of the Petitioner to practice Petitioner’s religion. However, the fact of the matter is that the health, safety and welfare of the children are of paramount concern. Hence, Petitioner’s religious affiliations/membership is detrimental to the minor children in these matters. Direct Evidence in declaration filed May 19, 2010, conclusively establishes Petitioner’s religion as a clear affirmative showing harm, or being detrimental to the minor children. (In re Marriage of Urband (1977) 68 Cal. App. 3d 796, 797-798[FAMILY CODE SECTION 3003 mandates that the child’s religion may be dealt with as an aspect of granting either joint or sole legal custody.] Furthermore, pursuant to FAMILY CODE SECTION 3041(b) Subject to subdivision (d), a finding that parental custody would be detrimental to the children shall be supported
DIRECT EVIDENCE in declaration filed, May 19, 2010, warrants the courts attention to heed the health, safety and welfare of the minors in these matters. The court has the authority to investigate the direct evidence concerning Petitioner’s religious affiliation with the Jehovah’s Witnesses Congregation located at 7439 Florence Ave., Downey, CA. 90240. Furthermore, the court has before it, direct evidence that the Jehovah’s Witness Organization engages in acts of pedophilia and child sex abuse. Specifically, direct evidence states, “Watchtower Society, is covering up cases of child molestation, protecting molesters and keeping secrets that put children at risk.” Direct evidence states, “From the time she was 10, until she turned 13, Heidi, a Jehovah’s Witness, says she was molested by a member of her congregation.” Direct evidence states, “The Jehovah’s Witnesses recently agree to pay to settle that lawsuit and eight other similar cases, without admitting wrongdoing. The cases all involve men the church allegedly knew had sexually abused children.” Direct evidence states, “The Jehovah’s Witnesses have settled nine lawsuits alleging church policies protected men who sexually abused children for many years.” Direct evidence states, “Clifton Reed Jr. and the 14-year-old girl met at a Jehovah’s Witness social gathering…Reed was charged. Police say he was soliciting sex from a 14-year-old, both online and over the phone.” Direct evidence states, “Found guilty in Dec. 2006 of acts of sexual abuse of a minor – acts which took place between 1985 and 1992- Marcel Simonin, 67 year old, formerly an Elder among the Jehovah’s Witnesses of Chateauguay, at the time of the crime” (SEE EXHIBIT 1)
III. THE COURT IS ENCOURAGED TO ACKNOWLEDGE AND CONSIDER THE BEST INTEREST OF THE MINOR CHILDREN IN THESE MATTERS
Direct Evidence concerning Petitioner’s religious affiliation is conclusively detrimental to the health, safety, and welfare of the minors in these matters.
Declaration filed, May 19, 2010, provides direct evidence of physical, mental and verbal abuse perpetrated by Petitioner, and therefore, making Petitioner UNFIT to have custody.
[FAMILY.CODE SECTION 3020-3032 APPLIES: 3020(a) The Legislature finds and declares that it is the public policy of this state to assure that the health, safety, and welfare of children shall be the court’s primary concern in determining the best interest of children when making any orders regarding the physical or legal custody or visitation of children. The Legislature further finds and declares that the perpetration of child abuse or domestic violence in a household where a child resides is detrimental to the child. (b) The Legislature finds and declares that it is the public policy of this state to assure that children have frequent and continuing contact with both parents after the parents have separated or dissolved their marriage, or ended their relationship, and to encourage parents to share the rights and responsibilities of child rearing in order to effect this policy, except where the contact would not be in the best interest of the child, as provided in Section 3011. (c) Where the policies set forth in subdivisions (a) and (b) of this section are in conflict, any court’s order regarding physical or legal custody or visitation shall be made in a manner that ensures the health, safety, and welfare of the child and the safety of all family members.]
IV. PETITIONER HAS INTENTIONALLY VIOLATED COURT VISITATION ORDERS AND HAS USED CHILDREN AS PAWNS. PETITIONER CONTINUES TO KEEP AND WITHHOLD CHILDREN FROM COURT ORDERED VISITATIONS WITH RESPONDENT
Direct evidence in Declaration filed, May 19, 2010, reveal that on June 1, 2008 at 10:20:19AM, Petitioner refused to let Respondent visit with children. [FAMILY CODE SECTION 3048(a) (1) (A) applies: Not withstanding any other provision of law, in any proceeding to determine child custody or visitation with a child, every custody or visitation order shall contain the following: (1) The basis for the court’s exercise of jurisdiction, (A) Whether a party has previously taken, enticed away, kept, withheld or concealed a child in violation of the right of custody or of visitation of a person] [CALIFORNIA CODE OF CIVIL PROCEDURE SECTION 1209(a)(5)applies: The following acts or omissions in respect to a court of justice, or proceedings therein, are contempt of the authority of the court (5) Disobedience of any lawful judgment, order, or process of the court](SEE EXHIBITS 1-7.)
V. RESPONDENT REQUESTS THAT THE COURT CONSIDER TERMINATING THE RESTRAINING ORDER ISSUED OCTOBER 12, 2011 ON THE GROUNDS THAT RESPONDENT HAS NEVER POSED A THREAT TO PETITIONER OR HIS CHILDREN
There is no record and/or evidence of Assaultive, Abusive and/or Domestic Violence by Respondent towards Petitioner or their children. Therefore, it is in the interest of the children that Petitioner and Respondent engage in amicable and cordial communications. Respondent has maintained vigilant compliance with all restraining orders issued by this Court. However, as documented in incident reports by Downey Police Department on two occasions, Petitioner has left messages on Respondents phone, and written derogatory letters to respondent in an attempt to coerce Respondent into violating Restraining Order (SEE EXHIBIT 2.)