IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division A.O.

, a child of 12 on 16 September, by her next friend, James Renwick Manship, and her next friend Delores OBrien Heffernan, A.B., N.B., O.B., T.B., Z.B., minor children, by next friend, J. R. Manship, and their next friend Salim Bennett, T.J., a minor child, by her next friend, James Renwick Manship, and her next friend Tiffany Johnson S.S., a minor child, by her next friend, James Renwick Manship, and her next friends Kit and Nancy Hey Slitor, Individually and on behalf of all others similarly situated, Next Friend Manship files Pro Se, and as Disabled Veteran, In Forma Pauperis Plaintiffs, v. SHERRI BROTHERS, et al. in their official capacities as Arlington County employees Defendants.

Case No: 1: 11CV1003 JCC/JFA

ANSWER to ORDER and MEMORANDUM OPINION of 21 SEPTEMBER Memorandum of Law on Next Friend Legal Status - History and Application 1. The Genesis of this Federal Court Complaint against Arlington County CPS and JDR Courts began in the Fairfax County Court Appointed Special Advocate training class in March a.d. 2001, a decade ago, where the principal Next Friend, Chaplain James Renwick Manship, Sr. of the God and Country Foundation Amos 5:15 Project Hate evil and love the good. Remodel your Courts into True Halls of Justice. was a volunteer. Chaplain Manship also was enrolled in Therapeutic Foster Parent training, completed in June 2001. Manship has successfully passed both State Records and FBI Records Checks in volunteer duties as an Adult Mentor in Boy Scouts for decades, and Civil Air Patrol since a.d. 2001, where he is a Major. 2. The CASA instructor stated that any adult could serve as a Next Friend to a minor in a Court action. The CASA instructor went so far as to say, the Next Friend did not even need to know the minors name. 3. While many, especially lawyers, will be quick to attack that CASA instructors statement, there is value in a Memorandum of Law on Next Friend Legal Status - History and Application. As an historian appointed by Governor Gilmore to the Mount Vernon Board of Visitors from 1998 to 2001, author of three books on History, as a Journalist for Justice, as a Court Reporter for clients in many Counties and Cities of Virginia, as a Legal Researcher the man who had the Law Librarian of the USCMAshepardize to learn that United States Code 804 (c ) has never been exercised by any President, and even a man who once served as the Auburn University Director of Legal Aid, Historian Manship is well suited to write this Memorandum.
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 8.01-8. How minors may sue. Any minor entitled to sue may do so by his next friend. Either or both parents may sue on behalf of a minor as his next friend. (Code 1950, 8-87; 1977, c. 617; 1998, c. 402.) 4. One definition of Next Friend is as follows: An individual who acts on behalf of another individual who does not have the legal capacity to act on his or her own behalf. The individual in whose name a minor's lawsuit is brought, or who appears in court to represent such minor's interest. The French term prochein ami has been used to designate such an individual, but the term GUARDIAN AD LITEM is more commonly used. Read more: Next Friend - Person, Court, Individual, Lawsuit, Litem, and Guardian - JRank Articles http://law.jrank.org/pages/8807/Next-Friend.html#ixzz1YzgjT6e8 5. Note the definition above uses the word individual, not Bar licensed lawyer, or Authorized Attorney, or even assistance of counsel as in this Constitution for the United States of America. 6. The definition above also mentions the term Guardian Ad Litem. While in recent years since around 2001 or so, the Virginia General Assembly passed a law that made financially able parents pay for Court Appointed Guardian Ad Litems, which has caused a flood of lawyers into the field where many non-lawyers dominated the occupation of Guardian Ad Litem prior to that change in the law. The preponderance of non-Bar Guardian Ad Litems may still be true as to numbers of Guardian Ad Litems assigned for incapacitated Adults, for whom the 2001 era law did not apply. 7. While Next Friend is usually seen in relation to a minor child, incapacitated adults, especially those who are evaluated as Mentally Ill with an IQ below a defined level (believed to be 70), are considered by the Courts to be minors for whom a Next Friend can file a lawsuit in Court. 8. Indeed, as a very detailed reader as a former Navy Special Duty Cryptology Officer, Delaney Award winning Commanding Officer, and as a former Virginia Chronicle newspaper Editor, Chaplain Manship, Next Friend in this case, was also Next Friend for a mentally retarded black man named Eddie Bell (IQ 68) on 19 February a.d. 2009 in an Emergency Motion for Stay of Execution and Petition for Writ of Error Coram Vobis filed with the Virginia supreme Court. The U.S. supreme Court ruling in Atkins v. Virginia appeared to command the stay, but it was denied, and Bell died. 9. Next Friend Manship saw from reading both State and Federal Court case pleadings and transcripts, since corroborated by a Private Investigator who had found an eye witness to the murder of Policeman Ricky Timbrook, Manship knew that Edward Nathaniel Bell, Eddie, was falsely convicted by a local prosecutor, Paul Thomson, sentenced on 26 September a.d. 2011 to prison for Evidence Tampering and Witness Tampering in a 2010 case, the same sort of corrupt misbehavior seen in the 1999 Bell conviction. Sadly, if a Citizen is not in the system as a law employee, the Courts rarely listen. 10. Yet that rabbit trail aside, the story is nonetheless instructive in the importance to True Justice of allowing any Citizen who is a critical, detailed reader, and an honest, independent thinker, whose income is not dependent on pleasing Police, Prosecutors, or Courts, to serve well as a Next Friend.
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11. Next friend, as a legal term, originates in common law. It refers to a person acting on behalf of a child or a person under a disability in a civil case. A next friend is not a party to the lawsuit, but is required to be included in the case caption of court pleadings, because the law considers children and persons under a disability to be without the legal capacity to sue on their own behalf. A person acting as next friend has no control over any proceeds from the lawsuit and no authority to assume custody of the child. Read more: http://www.wisegeek.com/what-does-next-friend-mean.htm 12. Next Friend Manship has a relationship as a Chaplain and Counselor, with no intent, and no authority to assume custody of the child, any of the eight named children named in this Complaint. Manship neither desires nor has control over any proceeds of the lawsuit, his purpose is purely the reunion of children safely with their parents, or in one case Court Order Guardian and grandmother. As a minister, he exists on funds derived separate from any of the named children or their parents. Manship is working in a Pro Bono Publico status for the welfare of the Children, and beyond, for Justice. 13. Due to the provision of the above stating no authority to assume custody of the child. originally, a parent could not act in Court as a Next Friend, but could do so as Parent. 14. In more recent history, in the case of a minor, the father is prima facie the proper person to act as next friend; in the father's absence the testamentary guardian if any; but any person not under disability may act as next friend so long as he has no interest in the action adverse to that of the minor. Read more: http://www.answers.com/topic/next-friend#ixzz1Yzho4LPn 15. Chaplain Manship has no interest in the action adverse to that of the minor, so may serve as Next Friend. That is not to say, that the Defendants agree with what actions are adverse to the minor, but the Defendants violation of United States Courts rulings in Child Seizure cases undermine their credibility. 16. A modern trend in the US is for courts to appoint a guardian ad litem to represent a minor or incapacitated person involved in legal proceedings. In situations involving minors, the court appoints a guardian ad litem for delinquency hearings, adoption proceedings, or abuse and neglect cases in family court. [Note: A trend does not dictate a legal requirement for Guardian Ad Litem to exclude Next Friend.] http://www.wisegeek.com/what-does-next-friend-mean.htm 17. Applying Next Friend to this case, minor child then10 year old A.O. has both verbally made a Cry for Help against the callous disregard of Court Appointed Guardian Ad Litem Karen Grane on or near 26 August 2010, but also a year later, on 15 August 2011, then 11 years old, during an unsupervised visit with her 18 year old sister Samantha, A.O. gave a letter addressed to Judge Varoutsos, in her own hand-writing, as a CRY FOR HELP to dismiss (Defendant) Guardian Ad Litem Karen Grane who conceals A.O.s wishes, and to report Child Abuse by Montgomery County Police Detective Sarit Scott. 18. After learning of the 15 August 2011 letter on or about 30 August 2011, Next Friend Manship has taken action in the best interests of A.O. with the Family Law section of Montgomery County Police Department Captain Kathi Rhodes, who referred the case to Internal Affairs. Chaplain Manship then conversed a couple times at length with a Sergeant Ridenour on the staff of Internal Affairs Captain Christina Faass, who decided to have Criminal Investigations Division Captain Diane McCarthy investigate the Child Abuse by Police Detective Sarit Scott, reported first over a year before.
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19. In December 2010, after A.O. had received from her Grandmother one of the history books written by Chaplain Manship, at the ofces of Arlington CPS at the conclusion of a supervised visit with her Grandmother Heffernan, A.O. came out of the secured area and made a bee-line over to hug Chaplain Manship and thank him for his History picture book, Second to None: Americas Washington. About that same time, Manship gave his card as a Court Reporter to GAL Karen Grane, and Grane within days led a frivolous Unauthorized Practice of Law complaint against Chaplain Manship with the Virginia State Bar, to which Manship quickly responded to the Virginia State Bar President Irving Blank, and heard no further on that frivolous complaint by Grane. 20. In early January 2011, trained Foster parent Manship learned that A.O. had been assaulted at the Burka Foster Parent house, when the Foster Parents took a trip to Texas for 2.5 days and had left their children and the foster child A.O. in the care of their 16 year old daughter C.J., a clear violation of Foster Care standards. During that Foster Parent trip away, CJ left the house, and put her 14 year old brother in charge, including in charge of an 11 year old girl foster child A.O. Unacceptable in itself. 21. However, even worse was the 14 year old son of Defendants Scott and Marci Burka, foster parents selected by Arlington CPS, blocked A.O. from going to the bathroom. When A.O. tried to run up the stairs to another bathroom, the boy grabbed her ankles and pulled her, causing her to fall on the steps. When A.O. got up the boy punched the 11 year old girl A.O. in the face and on the breasts. Not trusting her Guardian Ad Litem Karen Grane, A.O. reported the assault and child abuse at school. Arlington CPS was notied, as was G.A.L. Karen Grane. Neither acted to protect A.O. Defendant Sherri Brothers said in an email to Next Friend Heffernan being punched in the breasts, doesnt t criteria for child abuse. Miss Brothers, what about the criteria for criminal assault? 22. Instead of acting to remove A.O. from an unsafe Foster house, Arlington CPS and GAL Grane intervened to have a teacher force A.O. to write a letter of apology to foster parent Scott Burka. When that was learned, Next Friend Manship assisted A.O. by writing a letter to the School Principal, and making several in-person visits with school personnel, until that counter-pressure on the School, and the School on CPS, forced Arlington CPS to change the foster family of A.O. 23. Months later, at a meeting with the School Principal and a School Psychologist, the School Psychologist clearly told Next Friend, on digital audio recording, that the emotional well being of A.O. had markedly improved after her being moved from the first Foster house of Scott and Marci Burka. 24. In late January 2011, as a former Navy Inspector General staff ofcer, Next Friend Manship was with Next Friend Heffernan looking at the A.O. case les, that had NOT been sealed. Manship saw the Expense Voucher of Guardian Ad Litem Karen Grane, and from past Inspector General experience, could quickly tell that attorney Grane had padded her Expense Voucher, Fraud, so asked Next Friend Heffernan to cross-check the Grane Voucher with her own notes. Heffernan carefully noted several exaggerations, or Fraudulent entries by Court Appointed G.A.L. Grane. The notes of Detective Scott obtained from pre-trial Discovery provide other evidence of GAL Fraud. 25. Next Friend Manship asked for a copy of the GAL Grane Expense Voucher and was told No, you are not a party to the case. Next Friend Heffernan WAS a party, but was also denied. Manship then assisted Next Friend Heffernan draft a Petition for Writ of Mandamus to have Judge Varoutsos order the Court Clerk provide a copy. Instead, the next day Judge Varoutsos sealed the A.O. case le, especially noting the Expense Vouchers of GAL Grane, thus covering-up a crime of Fraud. 26. The Judge Varoutsos seal the AO file and Grane voucher Order was appealed to the Circuit Court.
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27. The Circuit Court judge said she saw the problem, but unless Pro Se Heffernan could give her the Virginia Code Section number for Fraud, she did not want to be accused of being an activist judge so refused to take any action. The A.O. case le was returned to Arlington JDR Court. 28. Later from 30 June 2011 to 08 September 2011, Mr. George Dodge was appointed by Arlington Circuit Court to serve as Guardian Ad Litem to Mrs. Delores OBrien Heffernan, when she was incapacitated by wrongful incarceration in Maryland on alleged two bad check rent checks from 2009 that had been the focus of investigations by Arlington GAL Karen Grane, and Montgomery County Police Detective Sarit Scott, the two who engaged in the 3 hour long Child Abuse interrogation of A.O. on 26August 2010. That conviction is on appeal and the Maryland Public Defender has contacted Mrs. Heffernan on or about 27 September stating their intent to represent her on Appeal. The key point is G.A.L. George Dodge stated ALL his vouchers are open to the Public to view. 29. Circuit Court Guardian Ad Litem George Dodge for Mrs. Heffernan filed a MOTION IN OPPOSITION OF CHANGE OF PROGRAM GOAL TO ADOPTION for a 4 August 2011 hearing in response to a change of program goal from 14 July Return Home to goal for Adoption on 21 July 2011. Key is item 18, where GAL George Dodge has a telephone conference with A.O., and writes: (A.O.) stated she does not want to be adopted However, Arlington JDR Court Guardian Ad Litem Grane reported in Court that Ashlie said she wants to return to her family, but that her recommendation is for Ashlie to be adopted out. GAL George Dodge objected, and asked for explanation, but Judge Varoutsos declined to direct GAL Grane to answer. GAL Grane has neglected to file a written report that is required after a change in Program Goal. 30. After Chaplain Manship visited Mrs. Heffernan in jail on 24 July 2001, he wrote a one page letter to the Montgomery County Circuit Court Judge on 31 July 2011 explaining the errors in charging a Crime that the Maryland Courts website states is not a crime, so at the sentencing hearing on 16 August 2011, the judge released Mrs. Heffernan with time served, and refused the requests of assistant States Attorney Karen McNeely for Parole or Probation. 31. Chaplain Manship has since assisted Mrs. Heffernan file an Appeal. Mrs. Heffernan has been selected for assistance by the Maryland Office of the Public Defender in Baltimore. The likelihood of reversal of the erroneous charges and conviction are deemed to be fairly high. All this is part of being a Next Friend to A.O. to remove any impediments to the program goal of Return Home. 32. On 29 August, Next Friend Heffernan went to search for the 15 August 2011 letter from A.O. to Judge Varoutsos in the JDR Court file and found it buried deep in the very thick file. Next Friend Heffernan asked a Clerk to make six copies and date-time stamp each copy, and watched one copy to be refiled on the top of the file so Judge Varoutsos would be sure to see it. 33. On the way out of the JDR Court Clerks office, Next Friend Heffernan saw Defendant Jason McCandless, assistant County Attorney, and gave him a copy of the AO 15 August 2011 letter, date stamped 29 August 2011. 34. Regarding the 15 August 2011 CRY FOR HELP letter to Judge Varoutsos by A.O. asking to remove Karen Grane as G.A.L., Citizens in the courtroom report Judge Varoutsos answered when asked by Next Friend Heffernan if he had seen the letter, yet derisively replied, I have seen the scribbles., and took no action to help AO.
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35. The signicance of the above paragraphs is that the Court Appointed, taxpayer paid Guardian Ad Litem Karen Grane did NOT represent the best interest of the child, A.O., Grane was representing her own nancial interests in extending the time of being paid as a Guardian Ad Litem. 36. Possibly as a consequence of all the media exposure by The Washington Examiner newspaper of the corrupt antics and orders of the Arlington JDR Court, a Whistleblower working in the Arlington JDR Court made copies of one Expense Voucher of Karen Grane, and provided it to Chaplain Manship. Review of the document copies obtained showed one voucher reduced by $1000 after exposure of the expense padding, and lawyer time sheets provide other incriminating evidence of Fraud and Collusion in the Obstruction of Justice by Court Appointed Attorney Grane. 37. This tragic example of AO paints a picture why a Next Friend as an individual not deriving money from serving the child, (but like G.A.L. Grane is clearly serving her own nancial interests, or maintaining favored status with DHS / CPS or the JDR judge for future nancially lucrative assignments), must be allowed to le a legal action in Court on behalf of a child, especially in a case where there is a taxpayer paid, Court Appointed Guardian Ad Litem. 38. If nothing else, a non-Bar citizen, non-taxpayer paid, Pro Bono Citizen as a Next Friend in Court provides accountability against Fraud, and a Balance of Power to Bar members in what is sometimes described as an Adversary Legal System, but becomes a clubby corner of corruption. 39. Karen Grane was also the Court Appointed Attorney assigned by Judge Varoutsos in the Civil case of Next Friend Salim Bennett and Next Friend Tiffany Johnson. In both cases Grane led a Motion to Withdraw, AFTER seriously undermining the legal position of her clients Tiffany Johnson, and Salim Bennett, claiming in ambiguous terms of Conict of Interests in their Civil case in relation to regaining Custody of their children. 40. On or about Tuesday, 27 September 2011, a female lawyer working with the Arlington Public Defenders Ofce, assigned to provide assistance of counsel to Mr. Salim Bennett, responded to Karen Grane when she approached and commented to Mr. Bennett and his Public Defender lawyer, Get out of here you st---- f---ing b-----. -- a new level of Civility in the Arlington Courthouse. 41. Whatever the precise words spoken by the lawyer, it shows Karen Grane is held in much disrespect, and yet her Fraud against the taxpayers is being covered by the Court, and her abandonment of assigned adult clients is being rewarded with new, paying GAL assignments by the same Court. 42. Karen Grane is not alone about Arlington JDR Court appointed Guardian Ad Litem with a very poor reputation, and yet the recipient of Court largess in G.A.L. assignments. Originally with different law rms, after late January 2011, Mina Ketchie and Karen Grane, share a law ofce with Ana Isabel Kaldenbach-Montemayor. The Bar license of Ketchie has been suspended by the D.C. Bar, and whose former law firm in Baltimore split as did the former law firm in Arlington of Karen Grane, after she and a senior partner had a phone conference about the Petition for Special Grand Jury. 43. Another child, JZ, was victim of choking of her neck by her father, about which abuse JZ told an Shirlington Branch Librarian in Arlington. Mina Ketchie was assigned as Guardian Ad Litem, and began to say JZ was lying, accusing the mother of Parental Alienation by inducing JZ to claim choking, falsely. Ketchie then wrote a persuasive GAL report saying the choking was not true.
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44. Guardian Ad Litem Mina Ketchie even wrote that the Librarian who called in the Police Report and four Police did not see any marks of choking. Again the report was very persuasive, but false. 45. Ketchies law ofce partner Ana Isabel Kaldenbach-Montemayor was late assigned to the father as a Court Appointed Attorney, and the Judge ordered the mother of JZ to pay Montemayor $1000, on the day the false statement filled GAL Report of Mina Ketchie was presented. A bit curious? 46. The letter from Dr. Cynthia Shen to the right pretty much proves the falsehood of the Mina Ketchie GAL report to the Arlington JDR Court. 47. Why would Mina Ketchie go so far off base on her GAL report? One theory is that the father was also reported for giving the daughter JZ a cell phone with him in suggestive photos -with another man, and Mina Ketchie used to be the President of the Gay Lawyers Association. 48. The Washington Examiner reporter who wrote back in 2008 about S.S. and Next Friends Nancy and Kit Slitor, that rst made Chaplain Manship aware of the gross injustice being perpetrated by Arlington CPS system and the Arlington Courts in the false front or facade of Best Interests of the Child, that 2008 discovery of poor little Baby Snatched S.S., evolved into his current service to many children in this case as their Next Friend. The Examiner reporter also informed Next Friend Manship about JZ, described above, and two weeks or so before about A.B., N.B., O.B., T.B., Z.B. Next Friend Salim Bennett has been an excellent legal researcher for the 53 Child Related Court Rulings. 49. Next Friend Manship learned about A.O. and T.J. when a DC Civil Rights lawyer spoke in Richmond at the Senate and House Courts of Justice Committee against Arlington JDR Court judge Esther Wiggins being re-elected. The lawyer was speaking on behalf his client Dr. Ariel King, and her daughter, other victims of Arlington CPS, as well as TJ and AO, and their parents. Next Friend Manship had as a professional speaker coached Next Friend Nancy Slitor to give her story about the Baby Snatching of S.S. before the Courts of Justice Committees. The Chairman, Bill Janis, now running for Henrico Commonwealth Attorney, commended the power and brevity of Nancys speech.

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50. Back in November 2008, Next Friend Manship had coached Next Friend Kit Slitor for his short Pro Se talk to the Court of Appeals of Virginia, and later helped them when their Bar card lawyers dropped their case after Dismissal at the Virginia supreme Court. Next Friend Manship in very short time tried to assist them file Pro Se to the U.S. supreme Court, but was told by an assistant Clerk, their Petition for Writ of Certiorari was one day late, that online days to date calculators dispute. 51. In the Virginia Lawyer magazine of October 2004 is a Special Feature article by Court of Appeals of Virginia Judge D. Arthur Kelsey, appointed by Governor Mark Warner in 2002 and reelected by the General Assembly in January 2011, on page 15 is the bold inset quotation: To many of the Framers generation, the jury was the lower judicial bench in a bicameral judiciary and the democratic branch of the judiciary power... and on page 14, Judge Kelsey wisely quotes Blackstone about the Citizens of the Jury: the best investigators of truth, and the surest guardians of public justice. Like a Juror, not a member of the Bar, the Next Friend is an advocate for a child, an investigator of truth, a sure guardian of public justice, and caring guardian of true justice for the child, without financial reward, with the only reward, the saving of a minor. 52. Former liberal Supreme Court Justice William O. Douglas wrote in: POINTS OF REBELLION Copyright 1969, 1970: Our fourth Chief Justice, John Marshall, who served from 1801 to 1834, said: "The very essence of civil liberty certainly consists in the right of every individual to claim the protection of the laws, whenever he receives an injury." Finding a right to correct a wrong is, however, the least of all the modern pressing problems. If poor and rich alike had lawyers to assert their claims, we would still be left with staggering problems. The search of the young today is more specific than the ancient search for the Holy Grail. The search of the youth today is for ways and means to make the machine and the vast bureaucracy of the corporation state and of government that runs that machine the servant of man. The Next Friend definition began with the word individual, individual right to protect a helpless minor. 53. When one man, male or female, truly a Next Friend to a minor incapable of defending oneself, is motivated by what is Right, what is Just, not just what pays well as a Bar member lawyer to make Right or Just, then that is when we may see what President Andrew Jackson said, A majority is made up of one man, with courage. 54. Too many Citizens feel like Second Class Citizens when standing before the Bar opposite a member of the Bar, and this Elitism in action is NOT healthy for our Republic, that claims Equal Justice for All. Non-Bar Citizens serving as Next Friend are one small but important way to constrain and even reverse this dangerous trend of Bar-barian over Citizen rule in our Country. 55. Former conservative Chief Justice William Rehnquist was quoted by the Center for Court Excellence of the District of Columbia: Justice is too important a matter to be left to the judges, or even the lawyers, the American people must discuss, think about, and contribute to the future planning of their courts. Next Friend is a small but important way one man from the immense power for Justice called the American people can discuss, think about, and contribute to the current day operation of our Courts.
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