IN THE UNITED STATES COURT OF APPEALS
FOR THE FIRST CIRCUIT
_________________________________________________________________
Civil Appeal No. 09-1610
______________________________________________________
IN REMOVAL
PROCEEDINGS
In the Matter of:
1. OFUME, PHILLIP CHUKWUMA
2. OFUME, MAUREEN NGOZI
3. OFUME, KLEBER ODIMEGWU
4. OFUME, KEYNES ONYERO
5. OFUME, ISABELLE IFEOMA
6. OFUME, LYNDA LAFAYETTE
7. OFUME, BARNETT CHIDI
8. OFUME, CHRISTIAN TOBECHUKWU
9. OFUME, GLORIA CHIYEM (US BORN CHILD, ALSO RIDER)
APPLICANT/PETITIONER (OFUME FAMILY -PRO SE & FORMA PAUPERIS)
V.
ERIC J. HOLDER, JR. (United States Attorney General) AND DEPARTMENT OF HOMELAND SECURITY (US IMMIGRATION AND CUSTOMS ENFORCEMENT - ICE)
RESPONDENTS/PLAINTIFFS
_____________________________________________________________________
Verified Emergency Motion of the Applicant/Petitioner for An Order or Other Relief, Nature of Return of Deported Child or 3rd Applicant to the United States Pursuant to Federal Rules of Appellate Procedure 27 (a), Federal Rules of Civil Procedure Rule 5.1., United Nations Convention of July 28, 1951, U.N. Convention on the Rights of the Child/Parents, U.N. Universal Declaration of Human Rights (12/10/1948), Bill of Rights of the
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Ofume v ERIC J. HOLDER, JR. (United States Attorney General)
United States
____________________________________________________________________
On Appeal from the Decision of The US Board of Immigration Appeals (BIA) before Panel Members: Pauley, Roger
LEAD FILE NO. A 97-446-370
_____________________________________________________________________________________
I, Dr. Phillip Chukwuma Ofume, lead Applicant/Petitioner move per the aforementioned Motion for an Order or Other Relief to return to the United States, One (1) Child (Kleber Odimegwu Ofume) or 3rd Applicant /Petitioner of the Ofume family who was deported to Nigeria on March 10, 2009 while the Appeal before US Board of Immigration Appeal ( BIA - LEAD FILE NO. A 97-446-370) remain active, pending and undecided. Kleber is a student at THE NORTH SHORE COMMUNITY COLLEGE, LYNN, MA and expected to earn his Associate Degree in 2010 and now homeless and in harms way in Lagos, Nigeria.
Reason of the vast personal, domestic and international protests on this deportation and/or mass public interest and that his return prejudices and harms nobody, Kleber Odimegwu Ofume, parents, siblings, friends and domestic and international publics are entitled to complete relief or order in nature of return of Kleber to NORTH SHORE COMMUNITY COLLEGE, LYNN, MA and family in Lynn, MA because of the following reasons:
1. Background
a. Kleber Odimegwu Ofume is a student at The North Shore Community College, Lynn,
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Ofume v ERIC J. HOLDER, JR. (United States Attorney General)
MA, without criminal record. On January 7, 2009 Kleber was arrested, detained, ex-communicated and deported to Nigeria because he requested Respondent or Immigration and Customs Enforcement (ICE) to correct the deliberate change which it made (10/12/2005) on his (Kleber’s) 1-94 card (EXHIBIT “A” in this Motion) in which his date of birth was altered by ICE from January 23, 1988 to January 23, 1998 purpose of political sanction and persecution reliant and fully connected with parent’s Dr. Phillip Chukwuma Ofume’s bid for the President of Nigeria 2007 or 2011. ICE’s change on Kleber’s 1-94 deeply affected his access to right to education, social security, Mass ID card, health insurance, student loan/bursary, travel, etc.
b. Prior and after January 7, 2009 deported child’s (Kleber Odimegwu Ofume‘s - with rider A# 96-416-430 of Lead File No. #A 97-446-370), parents’ and siblings’ Appeal on their Application for Asylum is active and pending before Court or Board of Record [see BIA’s Lead File No. #A 97-446-370 with other riders A# 96-416-429, A# 96-416-430 (Kleber Odimegwu Ofume), A# 96-416-431, A# 96-416-432, A# 96-416-433, A# 96-416-434, A# 96-416-435 - EXHIBIT “B” in this Motion] in the United States and Applicant had filed several applications (complaint) for stay of deportation.
c. Kleber’s bail hearing for the arrest, detention, ex-communication stated above was scheduled for March 10, 2009 at 1.00 p,m. in the Immigration Court, Boston, MA and Department of Homeland Security and ICE were served Notice of Hearing. Information revealed that on March 8 or 9, 2009 mid or early morning, Kleber was removed to Batavia and on March 10, 2009 into aircraft to Nigeria without specific or general contact information in Nigeria. Kleber was eight (8) years when parent fled with him into the on-going exile.
d. In Lagos, Nigeria and other Nigerian cities where Kleber is hiding here and there his homelessness and hardship has expanded because the two parents of Dr. Ofume and Mother of Mrs. Ofume are deceased or dead and the father of Mrs. Ofume and Mrs. Ofume and her siblings are all in dispute and living in the civil war/conflict region of the NIGER DELTA [see subparagraph 2 (b)] below.
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2. Reason Kleber’s return to the United States falls within emergency and fast track :
a. Parents, Kleber and other siblings hail from the NIGER DELTA REGION of Nigeria and lead Plaintiff in this Complaint, Dr. Phillip Chukwuma Ofume is potential presidential candidate for Nigeria’s presidential election 2007 and 2011 and because of this mandate and campaign for civil liberties particularly that the civil war/conflict in the NIGER DELTA REGION and action of the Civil Liberties fighters and demand for oil/gas derivation and environmental rights are lawful and constitutional within any law of environmental protection, self-defence and self-determination, Dr. & Mrs. Ofume are charged for treason and other political felonies.
b. Since March 10, 2009 when Kleber was deported to Nigeria, he has been hiding because of the suspected harm by Kleber’s parents’ political opponents and the position of his parents on the on-going war/conflict in the NIGER DELTA REGION. The two parents of Dr. Ofume and Mother of Mrs. Ofume are deceased or dead and the father of Mrs. Ofume and Mrs. Ofume and her siblings are all in dispute. The brothers and sisters of Dr. Ofume are living in the heart of the on-going Nigeria’s second civil war/conflict (Niger Delta people and government of Nigeria) and unsafe for Kleber to live in the South (Niger Delta Region).
c. In the United States, Parents and siblings suffer over 98% zero-income including lack of job authorization and their income is limited to under-14 year child food stamps and $240.00/month paid to one-US born child. Parents, Dr. & Mrs. Ofume have no money to send to Kleber without engaging in painful street begging which is hard now under the on-going suspected global recession. At present, information reveals that Kleber is being hunted by Nigeria’s and foreign securities. Parents are not aware of the type of another trump up charge they may bring against him soon as he is arrested but before the arrest, detention and ex-communication in the United States, parent (Dr. Ofume) was told that Nigerian/Canadian government and Nigeria‘s oil/gas companies planned to abduct his children and hand them over to the government of Nigeria in other to use them as bounty to force parents return to Nigeria to face treason and other political felony charges against them.
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d. Kleber’s college resumed lecture on January 20, 2009. He has missed several lectures and other learning activities. Kleber suffered under night work and pay fee shift at 7-ELEVEN STORES, Lynn. Americans and international communities are shocked that a child who has suffered to take over parents responsibilities because of parents’ political persecution and performing greatly at school and work place could be snatched from his studies, parents and siblings. Reference letters and other submissions of The Vice-President of The North Shore Community College, Lynn, MA and Director of the 7-ELEVEN STORES, Lynn are attached and marked EXHIBITS “D” & “E”.
3. Kleber Odimegwu Ofume, Parents and siblings pose no threat to Americans, America and society in general:
a. Inside and outside the United States, Applicant/Petitioner has contributed to their neighborhood, community and nation in general in assuring the success of people and government. 1996 - present, Kleber and his parents and siblings have been fleeing political persecution and torture in Nigeria, Togo, Canada but they continued to incorporate NGOs that help government, people and society in general including “INTERNATIONAL TEACHERS, LEARNERS, VIOLENCE AND RETENTION MONITORING PROJECT (LIMPT, INC USA)” which grants parents/guardians, students and government extensive and versatile opportunities to succeed.
b. Kleber Ofume is without past and present criminal records and highly dedicated to teaching people how to become great via education and community and national services. Kleber and his parents and siblings are devout members of The Church of Jesus Christ of Latter-day Saints and they pose no threat to America and Americans and other people inside and outside the United States. Under political conspiracy between Lynn Police Department, ICE and other defendants afore-listed, Kleber was arrested, detained, ex-communicated and deported when ICE has no criminal charges pending against Kleber and his parents and siblings. In part allegation particularly one designed by the Lynn Police Department, ICE and others on December 23, 2009
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was irresponsibly abandoned and struck on May 4, 2009 by Lynn District Court and application for expunge of the records will be made soon.
c. Kleber Odimegwu Ofume has been an A & +B student at the CLASSICAL HIGH SCHOOL, LYNN MA and maintain the same scholarly assiduity at THE NORTH SHORE COMMUNITY COLLEGE, LYNN CAMPUS and have about one year and half to graduate. Under the on-going extensive sanction, persecution, embargo, and zero income (over 98%) against the entire family, Defendant’s siblings are also A+, A, B+, B and honour students at Lynn Public School System. If Kleber is not returned to the College immediately, he will forfeit his college education and suffer irreparable loss and harm.
d. Kleber and his parents and siblings are members of THE CHURCH OF JESUS CHRIST OF LATTER-DAY SAINTS. They do not smoke, drink alcohol and other intoxicants or hard substances, engage in fight, use indecent language and related indecent conduct, create harm against themselves and the entire society. Inside and outside the United States, they have focused on education, community services and development, peace, campaign for civil liberties and good government.
e. On March 1, 2008 at about 2.00 a.m. Kleber told parents that a young man ran into 7-Eleven Store where he does student work-pay fees and claimed that some people were chasing him and that Kleber should help him telephone the police and the man alleged that the people were in the premises of 7-Eleven Store. Kleber further told parents that when Lynn police officers came they forced him to abandon his work and go out with them in the dark to identify these people whereas the young man was standing with the police as the police was forcing Kleber to go into the dark to find these people. Kleber feared that police may kill him should he refused to respect their instructions and command. On call for lawsuit against the police, under personal kindness to community and neighborhood and desire to make peace with people, Kleber said, “no need for civil action against these police officers, God has final say on the action of people on earth.”
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f. On December 23, 2008 on about 1.00 a.m. Kleber said that a young man drunk and suspected to be on special assignment and may have been positioned in and around the 7-Eleven Store where Kleber do student work-pay-fees and soon as some two female customers entered the store and picked some merchandizes, the young man emerged and joined the customer queue directly behind these ladies and started bullying these customers. Kleber merely advised the young man to stop harassing his customers. Upon this polite and soft advise the young man was infuriated for no just cause and expanded premeditated anger to telephone LYNN POLICE DEPARTMENT but as usual the police waited for the young man to escalate the brawl. Police arrived late and with unfounded anger rushed to place handcuff on Kleber and disrupted his work. Police held Kleber somewhere outside Lynn Police Station and after much pressure, the police brought him to the station and bail and release processes were completed at about 3.15 a.m. (12/23/2008). More shock was felt by parents, Americans and internationally that without investigation police brought a serious dramatic charge of assault with dangerous weapon and about 5 hours at 9.00 a.m. (12/23/2008) Kleber was arraigned in Lynn District Court and quickly police distributed the arraignment across media system and published.
g. On January 11, 2008 one young man telephoned Kleber with the threat that he will be coming few minutes time to break and enter 33 Arlington Street, #1 Lynn, Massachusetts 01902 into his room to kill Kleber. Kleber telephoned police but police did not come and parents also telephoned the police. Parents found that over 45 minutes, police did not come to wait
for this person. Few minutes after 45 minutes, the man and another young man arrived and requested Kleber to open his door and parents called police the third time with direct advise on the implication of the department‘s plot. When parent saw them from the window, we requested Kleber to stay indoor and let’s watch them. But when parents observed the insistence of these men, they opened the door to ask them to explain what may have triggered their anger and also parents used our experiences to calm them down. They did not say what may have angered them to the extent of armed threat to kill Kleber. Lately, as parents were calming them down and succeeded in making them happy, shamefully Lynn Police officers arrived and met parents
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standing with these men. Lynn Police Officers said, “this what we expect parents to be doing.”
h. Reason of this paragraph (and) return of Kleber to North Shore Community College, Parents and Siblings in Lynn, MA will not prejudice or harm parties in this case and will reduce public anger which grew as result of the forcible removal of Kleber from his college, parents and siblings.
4. FACT OF THE PENDING IMMIGRATION CASE (ASYLUM) OF THE DEPORTED CHILD, PARENTS AND SIBLINGS, SEPTEMBER 2005 - PRESENT
a. On September 29, 2005 via Halifax International Airport Kleber (minor under ACT 208 - Asylum) accompanied by parents and siblings (hereinafter, “Ofume family” ) fled political persecution in Canada. Lead Plaintiff, Dr. Phillip Chukwuma Ofume campaigned (2007) and now campaigning for the President of Nigeria 2011 with overwhelming opposition by Nigerian and Canadian governments and their allies. In Massachusetts’ schools and communities (Lynn and Braintree) the family has been politically attacked by tugs and severely persecuted by Lynn Police Department.
b. Application for Asylum made on September 29, 2005 after forcible landing at Boston Logan Airport en route to Washington, DC. Interviewed for over 12 hours by US Immigration Official and admitted or granted Asylum in the United States reliant on the initial adoption by the United Nations High Commission for Refugees and Amnesty International. To sanction further voyage to Washington, DC ICE impounded and seized Applicant’s UN Refugees travel documents and passports; academic and professional qualifications and awards; birth certificates; photographs relating to torture suffered by my family; books and submissions relating to politically criminal charges in Canadian and Nigerian law courts; etc
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c. On October 5 & 6, 2005 Applicant was interviewed by US Asylum Officer. On October 7, 2005 granted CREDIBLE FEAR OF TORTURE OR PERSECUTION and released and the Asylum Officer advised the family to leave the detention facility (Hilton Hotel) immediately but soon as the Asylum Officer left, ICE re-arrested the entire family without reason.
d. Also without reason on October 12, 2005 deliberately ICE issued Applicant’ family 1-94 and with deliberate cancellation and self created error to the extent of issuing 3rd Applicant, Kleber Ofume’s 1-94 with date of birth of 1998 whereas he was born in 1988. Applicant was wrongfully paroled for one year with mounted harassment and persecution with the hope that the family would default under over 98% sanction, several harassments and bullies but the parole was successful and ICE has no pending charges against applicant including Kleber. Change of status including temporary job authorization was denied to leave the family afloat under zero-income and pains.
e. October 12, 2005 - January 7, 2009 Applicant has telephoned and written to ICE to correct the error on Kleber’s and others 1-94 without action taken in the circumstance. Kleber who is a student at the North Shore Community College, Lynn, MA has been unable to apply for social security card, Massachusetts ID card, student loan/bursary, etc. January 7, 2009 Kleber decided to take the risk of going in person to see ICE to plead his pains and sufferings but Kleber was arrested, detained, ex-communicated and deported to Nigeria on March 10, 2009 which was the day scheduled for Kleber‘s Bail Hearing in the Immigration Court, Boston.
f. On October 12, 2005 ICE collaborated with the agents (Dorchester, MA) of the Nigerian military dictator General Ibrahim Babaginda in part who forced the family into the on-going and endless exile to accommodate the family in one of the worst secret torture detentions/prisons located at 8 Hall Avenue Braintree, MA and 33 Arlington, Street Lynn, MA. One of the general’s agents was used by ICE as attorney for the family. This mistreatment resulted to several lawsuits including on-going Petition to The Supreme Court of the United States for a Writ of Certiorari to The United States Court of
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Appeals for the First Circuit No. 08 - 1450 Ofume family v. George W. Bush, DHS, et als and ended in The Supreme Court of the United States Docket No. 08-8873.
g. On October 13, 2005 the mock attorney invited Applicant to his Office (Dorchester) and in his office (10/13/2005) the invitation was to announce his resignation and information that ICE told him that my family’s court date before an Immigration Judge was on October 13, 2005 which was less than 24 hours of my family’s transfer to second secret torture detentions /prisons (8 Hall Avenue, Braintree, MA).
h. On November 16, 2005 Applicant was brought before The Honourable Justice Thomas M. Ragno and the case was consolidated with Lead Case File A# 97-446-370.
i. On January 25, 2006 my family appeared before The Honourable Justice Eliza C. Klein and important Order was issued including disclosure and production of the documents (on before March 30, 2005) issued by the Asylum Officer (10/07/2005) , US Immigration Officials (09/29/2005), etc
k. January 26, 2006 - September 8, 2006 The Honourable Justice Matthew D’Angelo heard Applicant’s case absentia in Massachusetts and Florida without NOTICE TO APPEAR on the family. Three complaints to Office of Chief Immigration Judge and three appeals to the USCIS ADMINISTRATIVE APPEALS OFFICE (AAO). Charge were unspecific and in-between time designated as something like allegation of “entering into US without unexpired travel documents.” On this charge the Plaintiff (DHS) encounter setback when the District Attorney lately acted upon Order of Court (01/25/2006) of The Honourable Justice Eliza C. Klein and disclosed copies of the family’s unexpired travel documents. At this point all charges failed (10/16/2007).
I. But in place of granting relief pleaded by Applicant, on October 16, 2007 which was the end or final master individual hearing The Honourable Justice Matthew D’Angelo assumed uncharged ground by picking on EXPIRED BIOMETRIC TEST and declared Applicant’s application as “ABANDONED.” The BIOMETRIC TEST remained expired at the instance of
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the Clerk of Court and Judge D’Angelo, because they refused to write, sign and stamp simple phrase, “BIOMETRIC TEST IS REQUIRED IN THIS CASE” which the USCIS (Nebraska Service Center) requested before appointment to redo the BIOMETRIC TEST could be issued to Applicant. At this point all Relief was denied including riders that do not require Biometric Test.
m. Motion to Reopen was made/filed with several new evidence (contacts made to the Court and Nebraska and other new evidence) dated October 20, 2007. Motion to reopen denied.
n. Completed Notice of Appeal to Board of immigration Appeal (BIA) dated 01/17/2008 and delivered in person, received and stamped by the BIA. At this point (Appeal) the Respondent/Plaintiff dropout and abandoned the case.
o. BIA’s Notice of receipt of Applicant/Petitioner’s NOTICE OF APPEAL dated January 23, 2008 containing BIA’s Notice of Brief Schedule was received by the Applicant. Upon contact with the BIA, official there confirmed that the Respondent/Plaintiff (DHS) also received BIA’s Notice of Brief Schedule. Respondent did not reply.
p. According to BIA’s Notice of Brief Schedule Applicant is granted until 02/13/2008 to submit a Brief to the BIA. Applicant submitted its Brief on February 11, 2008 and service made on the Respondent/Plaintiff (DHS - ICE) with Proof of service also filed with the BIA. Respondent/Plaintiff did not reply.
q. Respondent/Plaintiff (DHS - ICE) or the opposing party is granted until 03/05/2008 to submit a reply brief to the BIA. Applicant did not receive anything from Respondent/Plaintiff (DHS - ICE) including defence on Appellants’ NOTICE OF APPEAL to the BIA. Nothing sent by the Respondent.
r. Under BIA control and failure of justice thus, towards waste of two years without reason for censoring the appeal and several applications (complaints) for Stay of Deportation including censoring decision, lately on April 9, 2009 BIA’s Decision was issued and also censored and
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Applicant has to get information on the issuance of the decision from anonymous insider. BIA knew that several Americans, international communities, attorneys/lawyers and others would hold them responsible for being the major cause for the deportation of this child and question them for compromising justice and rule of law of expired Biometric Test and process to redo it are located under the labour economics particularly, the principle and theory of Adams Smith’s SHARED RESPONSIBILITY or DIVISION OF LABOUR and under Applicant’s case responsibility to redo the biometric test is shared between, Judge D’Angelo, Clerk of Court, Applicant and Nebraska Service Center and that evidence published nationally and internationally, show that Applicant has constituted a complete binder of the requirements per the immigration law of the United States and mailed same several times to Nebraska Service Center and because Judge D’Angelo, Clerk of Court, and Nebraska Service Center neglected, failed and refused to meet their responsibility.
s. Applicant appealed the decision of BIA (04/9/2009) and Petition for Review and Motion for Stay of Deportation jointly filed on May 6, 2009 and under the new government, Stay granted within only one month whereas under politicized conditions of the former government BIA and DHS received several applications for stay of deportation but were abandoned to scatter my family and enable gradual deportation of my family to Canada, Nigeria and detention of my new baby in the United States.
5. LEGAL QUESTION AND ARGUMENT
Whether Respondent (ICE) erred when deported child’s (Kleber Odimegwu Ofume‘s - rider with A# 96-416-430 ), parents’ and siblings’ Appeal on their Application for Asylum is active and pending before US Board of Immigration Appeal [see BIA’s Lead File No. #A 97-446-370 with other riders A# 96-416-429, A# 96-416-430 (Kleber Odimegwu Ofume), A# 96-416-431, A# 96-416-432, A# 96-416-433, A# 96-416-434, A# 96-416-435 - EXHIBIT “B” in this Motion] in the United States and ICE jumped US and international laws aforementioned and proceeded to arrest, detain, ex-communicate and on
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March 10, 2009 deport Kleber to Nigeria when March 10, 2009 at 1.00 p,m. was Kleber’s Bail Hearing in US Immigration Court, Boston, MA and Department of Homeland Security and ICE were served Bail Motion/Bond Notice of hearing. Also see para 4 above;
whether Department of Homeland Security and ICE erred , during the illegal deportation flight to Nigeria upon arriving in Cape Verde, Kleber said that the deportation Lieutenant-in-charge discovered that there was improper process including mistaking identity and also further convinced of the said illegal process when he (deportation Lieutenant-in-charge) discovered that Kleber’s Bail Hearing was scheduled on the same date of his deportation (03/10/2009) and his appeal is pending before the BIA and the bail hearing for the arrest, detention and ex-communication mentioned above is scheduled for the same day, March 10, 2009 at 1.00 pm. but shocking the deportation Lieutenant-in-charge failed to put Kleber back on aircraft to the United States. Kleber’s personal statement which is letter dated May 5, 2009 to Attorney John J. Loscocco is hereto attached and marked EXHIBIT “C”.
whether under the laws of the United States, Applicants for Asylum and other services maybe arrested, detained, ex-communicated, and deported for requesting
providers of such services to correct their own error or mistakes. As stated in paragraph 1 above, on October 12, 2005 ICE altered Kleber’s date of birth from January 23, 1988 to January 23, 1998 and January 7, 2009 after parents have pleaded for correction, Kleber went to ICE’s office in Bostonb and upon presenting his request, ICE arrested, detained and ex-communicated Kleber and deported on March 10, 2009;
whether under the immigration laws of the United States, Applicant for Asylum whose application is pending and active before court or board of record could be arrested, detained, ex-communicated and deported without breach of past or any bail and parole conditions or without charges which appeared before Judge and earned conviction.
Reference to the four (4) questions presented above including the political charge (Lynn District Court against Kleber on December 23, 2008 and the pending Asylum case before the BIA, the
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Ofume v ERIC J. HOLDER, JR. (United States Attorney General)
Immigration Judge, Lynn District Court Judge (charge dated December 23, 2008) and BIA have power to decide all the allegation and issue Order which will give ICE directions as to whether Kleber is deportable or not. On before March 10, 2009 these cases were still pending and the Judge of the Immigration Court has not received the decisions of the BIA and Lynn District Court to enable ICE get deportation Order from the Judge of the Immigration Court.
The decisions of BIA and Lynn District Court were issued on April 9, 2009 and May 4, 2009 whereas Kleber was hastily deported on March 10, 2009. On May 4, 2009 the charge before District, Lynn, MA was closed and the Decision of the BIA was appealed to this court (Civil Appeal No. 09-1610) and Applicant’s Motion for Stay of deportation was filed, heard and granted.
Process under § 240 of the immigration & Nationality Act (INS) by the Judge of the Immigration Court extends to other authority under 8 C.F.R. § 319 to review Bail Bond issued by INS by the Director of the INS but Kleber was deported on the day (03/10/2009) when Kleber was to appear before Immigration Judge.
Parents of Kleber, Dr. & Mrs. Ofume were charge with treason and other political felonies and conviction in Nigeria is death by hanging or public firing squad. The government of Nigeria and her allies have been trying to adduct and send parents to Nigeria to face this charge or use abduction and deportation of children to setup bounty to return parents to Nigeria.
US Constitution against torture, Bill of Rights, United Nations Convention of July 28, 1951 and UN Convention against deporting children, men and women to countries where they may face torture, death and other harms. From secret record to open record in Nigeria, in part Dr. Ofume was charged for supporting the conflict in the Niger Delta Region and Dr. & Mrs. Ofume were charged jointly for campaign for different forms of civil liberties campaigns.
6. CONCLUSION
Therefore, reason of the foregoing Applicant request this Court to grant this Motion with
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Ofume v ERIC J. HOLDER, JR. (United States Attorney General)
Order which may include Order on Defendant to pay all costs to return Kleber Odimegwu Ofume to Parents, Siblings and North Shore Community College all of which are in Lynn, MA.
VERIFICATION
I, Dr. Phillip Chukwuma Ofume, hereby verify and signed, under the pain and penalty of perjury, under the laws of the United States of America, without the “United States”, that the above statement of facts and laws is true and correct, according to the best of My current information, knowledge, and belief, so help me God.
Sworn date: June 15, 2009 A.D.
_____________________
Phillip C. Ofume, Ph.D. – Representative/Advocate for the defendant
33 Arlington Street, Suite 1
Lynn, Massachusetts 01902
E-mail: confid1by1@hotmail.com, global
aids_hivcureinteraction@yahoo.co.uk
CERTIFICATE OF SERVICE
I, Dr. Phillip C. Ofume, Representative/Advocate for the Plaintiff or co-Plaintiff hereby certify that I have this 15th day of June, 2009 served the foregoing document, upon all parties, by mailing a copy, first class, postage prepaid to:
Tony West - Assistant Attorney-General (Civil Division)
Barry J. Pettinato - Assistant Director
Tim Ramnitz - Attorney
U.S. Department of Justice
Office of Immigration Litigation
P. O. Box 878, Benjamin Franklin Station
Washington, D.C. 20044
Tel. (202) 616-2686
Fax: (202) 305-4829
_____________________
Phillip C. Ofume, Ph.D. – Representative/Advocate for the Ofume Family
Date: June 15, 2009
Further copies to:
President Barack H. Obama
President of the United States of America
1600 Pennsylvania Avenue, NW
Washington, DC 20500
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Ofume v ERIC J. HOLDER, JR. (United States Attorney General)
Vice- President Joseph Biden,
Washington Office:
Eisenhower Executive Office Bldg.
Washington, DC 20501
Honourable Eric H. Holder, Jr.
US Secretary of Justice and Attorney General,
U.S. Department of Justice
950 Pennsylvania Avenue, N.W.
Office of the Assistant Attorney General, Main
Washington, D.C. 205 30
United Nations High Commission for Human Rights
United Nations High Commission for Refugees
Geneva, Switzerland.
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