Complaint Against the Attorney for the Child Who Opposes the Child and Sends Her into Abuse

The Foundation for Child Victims of the Family Courts (FCVFC) is engaged in evaluating charges of child abuse as well as seeking prosecution for such crimes, filing complaints with all oversight agencies, and litigation in the form of malpractice case evaluation and development.

The Defendant Mother in question is a client of the FCVFC. Her 4-year-old child, alleged to be the subject of ongoing, aggressive sexual abuse by her father, is the subject of advocacy support by the FCVFC.

Analysis of the Case

Our client is a domestic abuse survivor, the mother of a four-year-old child who has already been subject to, as documented, just under two years of heinous, perverted physical and sexual abuse. The veracity of this child’s multiple outcries and detailed descriptions of her abuse are verified, substantiated, and indisputable, fully documented in multiple forms by experts who are knowledgeable by training and experience to assert a diagnosis of child sexual abuse, trauma, and risk of not surviving the abuse to which she is subject.

Also documented is a disturbing level of coordinated obfuscation, minimizing and leaving out of court reports and psychological evaluation, evidence of child sexual abuse and information related to an understanding of the historical foundations that would support an understanding of disturbing family dynamics that make sense of how, why, and when the abuse described makes sense psychodynamically.

This case is fully documented as per the mental health competence of the victims and the accuracy of the extensive evidence that support claims of sexual abuse. The case for the suppression of evidence, lies, manipulation, exclusion of critical evidence that supports the criminal complaints of vicious child abuse, engaged in by more than one family member of the accused perpetrator’s family is exceptionally well documented.

An intellectual environment of ignorance of the clinical symptoms, the stigmata of sexual abuse that are present in all sexual abuse victims, allows those with power and position to present superficial arguments to easily dismiss dire circumstances of child endangerment.

By those with proper training and experience, however, abuse symptoms are recognized and rapidly understood. We also maintain a moral compass that is not amenable to undue influence to undermine accurate reporting.

Child’s Report of Abuse by Father and Grandmother

Clearly and dramatically visible in the child is the presence of a clinical dynamic known as a trauma bond, which develops in the context of a victim and abuser where Stockholm syndrome issues are present, even if not yet fully diagnosed.

Further, the child had very clearly identified her paternal grandmother as an abuser, hitting her with a variety of objects, leaving her alone with the father, and leaving the premises so that the father could be alone with her, as well as going to sleep while she should have been caring for her. Further, verbal, physical, and sexual threats have been reported, even threats with guns, leaving guns on the floor and threatening to shoot the child or her mommy if she tells on the father and paternal grandmother.

The child identified the paternal grandmother as someone who on more than one occasion menaced her with a knife, cutting her foot and then engaging in other highly disturbing behavior that is documented. The intense hostility of the paternal grandmother supports the evidence of a highly pathological relationship between mother and son. Significant evidence exists of an incest bond between mother and son, available in documentation but not discussed by any of the so-called experts evaluating this case. Cover up of evidence of abuse, witness intimidation have occurred, but some of the most disturbing hard-core evidence lies present, visible, and critical for review.

As per the times the father is in effect alone with the child and fully in charge we are most recently learning that she has been taken to a hotel and that as described by her, in baby terms, there is sexual activity going on that is interpreted by her as men fighting with each other and “punching penises.”

Ongoing work reporting to police, documenting the child’s commentary as a matter of course without alarming her has had to take place without the assistance of family court protection as the court is clearly the source of child endangerment, trafficking and potential death by murder of this child.

The Role of the Attorney for the Child in Discrediting the Child

The allegations of those associated with abuse of the child, the subject child’s father and paternal grandmother, aggressively, obsessively insist on having access to this child. This insistence is equaled by the endurance of the defense and denials of the father’s main advocate, the Attorney for the Child.

While the Attorney for the Child has no clinical training, forensic or academic, no training or experience in interviewing or working in any manner with children who have suffered abuse, and has never actually properly interviewed the child, he is the source of the most abundant testimony discrediting the child. He has also consistently contacted experts who have interviewed the child and have substantiated abuse. Mysteriously, following contact with the Attorney for the Child they have withdrawn their substantiations.

Medical practitioners at the University of Chicago Medical Center, the Department of Children and Families caseworkers, the psychological evaluator of the child, two therapists who have seen the child for an extended period of time—these are some of the experts who reported abuse, based on clinical and medical evidence.

Following contact with the Attorney for the Child, these individuals have altered their reports by withholding critical material in their possession, they have allowed themselves to be manipulated into filing verbal reports that then were misrepresented in the work product of the psychological evaluator, or they have gone to such lengths as to then repudiate their own statements, seeming to reinterpret their own expert statements as mandated reporters. The detailed documentation of these occurrences are present in transcripts and other forms of written communication in our possession.

The Attorney for the child has barely ever spoken with the child. When there was brief contact, the child is documented as having said that she felt that he did not believe her and did not care about her. The Attorney for the Child has never written a report or properly documented meetings with the child. There are no audio/video recordings interviewing her, yet his stalking her via discrediting witnesses is quite visible. The Attorney for the Child has openly in court and with multiple witnesses been antagonistic and overtly hostile to the child, whose intelligence and articulateness even at age four is evident.

The overwhelming hostile stance to the child was clear in the Attorney for the Child’s utterly implausible support for the father and his support for the father to have access to the child when he knew with a significant degree of certainty that abuse would take place and did.

This Court and the factotum who appear to function in lockstep with the Attorney for the Child has appointed so-called supervisors that facilitate the father’s access to the child, on his terms, on his schedule.

Case History

April 2016 — Defendant Mother became pregnant.

January 5, 2017 — Birth of Child.

Physical abuse of Defendant intensified soon after the baby was born. Father punched mother in the face as she was holding the baby.

April 2020 — Child’s first outcry.

July 16, 2020 — Emergency petition filed, result of father physically beating and strangling the mother and punching her in the face. Order of Protection was granted.

Aug. 5, 2020 — Plaintiff filed for divorce and filed an Emergency Order for Child Possession,

Plaintiff stated that he had no idea where the child was and had had no contact with the mother. Lies were debunked with the production of written notification informing him as to date, place and time of the whereabouts of herself and their child. This tactic became a consistent pattern of reporting.

Sept. 16, 2020 — Emergency Petition Filed By Mother to Restrict Father’s Parenting Time.

Child’s second outcry – documented by social worker at the University of Chicago Medical Center – DCF contacted.

Child was at the medical appointment as per court order.

Supervised visitation ordered – non-neutral supervisor appointed, paternal grandmother, mother of accused abuser

Sept. 2020 — Judge Maritza Martinez received but did not view CAC Video.

Nov. 29, 2020 – Child’s third outcry, involving vaginal penetration (reports of bleeding documented by University of Chicago Medical Center)

Dec. 1, 2020 – Judge Lopez presided over emergency hearing. Emergency Petition to terminate visitation by father / Terminate PGM as supervisor of the minor child – Videos not viewed by Judge Martinez or the Attorney for the Child

Dec. 2, 2020 – Unethical behavior documented regarding the court order submitted to the court by the Plaintiff’s attorney without notice to the Defendant’s attorney. One of many improper actions.

Outcries made to third parties – independent of defendant

Third-party reports to DCFS:

  • Of Chicago Med. Center Md, Rn, Sw, Md2
  • MG Parents
  • Child’s Godfather
  • Child’s Therapist
  • CLC Detective and Social Worker
  • DCF Social Worker 1,2,3
  • the Attorney for the Child – Child Representative
  • Kerry Smith – Court Appointed Evaluator

Outcry Involving Vaginal Penetration and Reports of Bleeding

Documented – University of Chicago Medical Center

Emergency Motion To Suspend Parenting Time Approved By Judge Lopez

Supervisor for all visitations was appointed:  paternal grandmother’s best friend and mother of Father’s best friend. All visitation must take place at this person’s home.

Under this supervision, the child continued to be abused, as documented as supervisor on Dec. 25, 2020, hospital and police reports.

Father violated Orders – taking child to his home with no supervisor present at all – the Attorney for the Child informed of violations repeatedly. The Attorney for the Child reported via email that he had “no problem with the violations.” The Attorney for the Child re-wrote the court orders on 2/17/21 to allow visitation wherever the father wished to take her and also allowed digital contact with the paternal grandmother. The prior orders specifically barred the paternal grandmother from all contact with the child related to multiple reports that the paternal grandmother was named in the child’s outcries describing severe, frequent beatings with various objects and cutting the child with a knife. The paternal grandmother was indicated as an individual who facilitated and encouraged acts of perverted abuse, described in medical records and other clinical reports.

Dec. 1, 2020 – Case Heard By Judge Lopez. Child reported aggressive corporal punishment by maternal grandmother. Child bit maternal grandmother to defend herself.

Court Ordered Supervision Ordered – Appointing MGM as the supervisor – Suspended – MGM restricted from all contact with child.

Dec. 2 – unethical behavior documented re: court order submitted to the court by plaintiff’s attorney w/o notice to defendant’s attorney – one of many improper actions – documented

Dec. 25, 2020 – Outcry – Bruises and Lesions all over child’s body

Ongoing Physical Injuries – Documented by Univ. Of Chicago Medical Center

Medical Documents procured.

Attorney for the child has consistently discounted injuries and outcries as well as violations of parameters set for supervised visits and reports of physical beatings by Father and Maternal Grandmother.

Supervisor assigned – “Best Friend Of MGM” – Non-Neutral.

Aggressive with Mother – confrontation with Mother at child’s school

Jan. 5, 2021 – New Court Complaint – Custody Evaluation ordered – New Psychological Evaluation Ordered – Outline of documentation Requests to be  Completed by Victim’s Family – Extensive Documentation Gathered –  Documentation / Affidavits, etc. never made their way into the report.

Evaluation Supported 50/50 Co Parenting.

Psychological Evaluation ordered. A superficial, grossly inadequate report was prepared, which ignored brutal domestic violence and made no reference to perverted acts of child sexual abuse, recommended 50/50 custody and co-parenting. The evaluator handed out a list of questions to be completed by family, therapist, and key observers of family interaction and witnesses to abuse. Extensive documentation of hundreds of pages written as affidavits and first-hand reports describing what was seen/ heard were completely ignored in the 25-page report prepared by the psychologist Kerry Smith.

Complaints against Kerry Smith, PhD, were sent to the Psychology Board based on her depraved indifference to the acute suffering of this child and Smith’s documented lockstep coordination with such court actors as the Attorney for the Child.

Pro Se Emergency Order Of Protection – An Act Of Desperation

When attorneys for the Respondent mother Tiffany Hughes and Brittany Hines no longer felt a need to maintain a facade of support for the child and were out of patience with placating the mother as she begged for protection of the child, they in unison in a meeting to discuss causes of action stated “Come on – really…… nobody believes … [mother and child]. It all sounds crazy!”

Attorney Tiffany Hughes consistently intimidated the client by stating that if she raised the sexual abuse issue the court would turn custody over to the father. The say-nothing-do-nothing attorney sustained a torturous relationship between the child and her obsessed abuser.

After billing for more than two hundred thousand dollars, these lawyers were out of excuses, out of prevarications and simply fed up with the drama, demands and increasing criticism from the clients.

Respondent Mother was convinced that she had to proceed on her own to secure an Emergency Protective Order for the child, to put aside her terror of the court, fear of offending authority figures, and despair that the authorities could be won over by sympathy for the child.

An Ex Parte Emergency Order of Protection was procured Dec. 6, 2021, Pro Se by the Respondent Mother. Service of the Order was issued through the Sheriff’s office.

as soon as they were made aware of the presence of a Protective Order, lawyers for the Respondent Mother petitioned the court to be relieved of representation for mother and child.

Criminal investigation was pursued. Criminal cases against the Petitioner Father are in Process.

An Emergency Order vacating the Protective Order was procured Dec. 8th, 2021 without notification to the Respondent Mother. The attorney for the Petitioner informed her of the removal of the Emergency Protective Order she had procured and told her to prepare for renewed visitation with the Petitioner, who intended to exercise his parenting time.

Zoom Meetings with the Father

The initial Zoom meetings initiated by the Petitioner Father aggressively confronted the child with the father’s clear intent to assert his control as his tongue wiggled and darted in and out of his mouth as he invited the child to assume sexual positions so that he could access her vagina visually just as he asserted control over her vagina when she was forced into his presence.

This facilitated a trauma bond between the accused abuser and the child as forced continued contact with the child was sustained. Clear evidence of the father’s inability to control his sexual appetites even on camera as he encouraged the child to engage in sexually provocative behaviors are fully documented.

Sept. 28, 2021 — Judge Maritza Martinez finally viewed the CAC VSI report.[1] She expressed her concern and “disturbance” upon viewing the videos.

Dec. 1, 2021 – Judge Mariza Martinez viewed one of the videos for the second time and recused herself from the case, leaving all orders in place for visitation and Zoom meetings three times per week.

Fraud Assessment Requested

Child protection mandated by law has come to be ignored, denied, campaigned against via the suppression of evidence, witness intimidation, and threats to witnesses of abuse. Those who have witnessed or seen evidence of abuse are ordered to recant, and the evidence is not investigated.

Physical evidence of abuse has been tampered with and or destroyed at the direction of the attorney for the mother. This obstruction of justice attests to multiple layers of intervention to protect the perpetrator (s) of crimes against the child and her mother are present in this case. The interventionists, court actors include the judge who most recently recused herself from the case but left intact draconian orders that continued a so-called “parenting plan” that continued the child’s exposure to adults who are most dangerous to physical, emotional, intellectual development, much less survival, as one inappropriate, non-neutral supervision after another was put into place.

The failure of competence and expertise, a “know-nothing” environment of so-called experts, have facilitated ongoing abuse of the child via video zoom sessions and so-called supervised visitation of the child. Because of indifference, arrogance, or ignorance, the very disturbing relationship between the accused abuser and his mother has never been addressed.

Assessment of fraud, collusion and malfeasance on the part Court Actors who may take advantage of the positions of vulnerable subjects must become part of the process of reviewing child sexual abuse allegations in order to assure proper interventions and protection of victims. As per the case presented in this instance, the mismanagement and malevolence displayed by the court-appointed attorney for the child are so venal, the level of naked hostility directed to the child so rank in comparison to the level of support for the father / accused abuser, that we are requesting an investigation by authorities of payoffs or some form of undue influence imparted by the biological father.

The complaint documentation that deals with the interactions of the Attorney for the Child with professionals that then appears to have led to the altering of their reports and testimony requires investigation by authorities.

The evidence of aggressive sexual abuse of this child who is four years and several months old has been ongoing, taking place with abandon, ignored by court authorities who have engaged supervisors that have facilitated the ability of the abuser to be in full contact with the child.

Physical and sexual punishment has included the father enforcing his ability to abuse the child anytime and anyplace he wishes, holding her down, touching her vagina and her anus as he pleases. As he forces himself upon her he lets her know that he can do as he pleases with her and no one will help her, a message reinforced by the Attorney for the Child and psychological evaluator Kerry Smith.

This child bears the emotional stigmata of all abuse victims. These wounds are universally, independently displayed out of spontaneous, impetuous, uncontrollable waves of emotion and unwelcome memories that intrude and are overwhelming. The cruelty of those who fail to protect children from abuse, much less ongoing, well-documented abuse, cannot be allowed to continue to profit from the suffering of the victims on whom they prey. Today’s victims evolve into suffering and often highly dysfunctional adults, the predators our institutions are supposed to fend against.

An issue never allowed to be explored by the court was how did the Petitioner Father afford the services of an attorney who was so thoroughly and completely responsive to the extensive legal work required by this case. How was a USPS truck driver able to afford the legal fees associated with this challenging, high-conflict case when working with court personnel who do not appear sentimental or forgiving of payment for their services. How is it that the so-called attorney for the child has displayed throughout the proceedings a consistent devotion to the interests of a demonstrably abusive father, taking action above and beyond the scope of his advocacy for a non-client, all along completely betraying the interests of his assigned/appointed client. These are some of the issues that we will be exploring with each and every oversight agency that investigates fraud, corruption, collusion, and racketeering as we forward documentation to the responsible authorities.


[1] For more than a year, Judge Maritza Martinez had access to two CAC VSI reports but did not view them. The Attorney for the Child is stated to have made a copy of the CAC VSI and dismissed their significance.







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