KALINDI 1
INITIAL CHILD PROTECTION CONFERENCE - 07 November 2013 my paper 22

3. INTRODUCTION
5.40 (Ms Peacock Health Vistior) She (KRISHNA) has spoke kindly of KALINDI (...)
5.30 Alison Dodds Social Worker stated in writing that she is concerned about KRISHNA's relationship with KALINDI. She is under the impression that the reason KRISHNA does not share a close relationship with KALINDI is due to Mr Robson being KA's father. (Here Alison Dodds Social Worker contradicted the opinion of Ms Peacock.)
5.45. Ms Smith (health visitor) stated that "she has observed a relationship between KRISHNA and KALINDI and she explained that she has seen KALINDI enjoy listening to KRISHNA play the piano.(...)"
5.56 Mrs Pearson, health Visitor, stated that there are "no concerns in relation to KA's development. Ms Da Costa is continuing to breast feed KALINDI although she does provide solid food for KALINDI." STRATEGY MEETING my paper 20
7 HEALTH

False Statement 1 made by Alison Dodds
Social Worker Alison Dodds described how "she" recently saw "Luci sitting on the ground outside the laundrette. KALINDI was crawling around."
from SUMARY OF CHILD/YOUNG PERSON'S DEVELOPMENTAL NEEDS AND STRENGHTS my paper 19
False Statement 2 made by Alison Dodds
Alison Dodds Wrote:-
On one occasion the Health Visitor observed KALINDI with her mother sitting outside a local laundrette on the floor, where KALINDI was crawling around close to the road.(...)
These two statements made above by the Social Worker Alison are a complete fabrication of events and have been clearly written with wilful intent to mislead the court and be detrimental to my case. There is no truth in the above, it is a clear misrepresentation of fact. At the time these reports were submitted, KALINDI was inside her pram. Health visitor Joane Pearson is happy to come to court to testify this.
"I contend that the statements made by Social worker Alison Dodds are illegal under perjury act 1911. Section 5"

Perjury Act Section 5
"5 False statutory declarations and other false statements without oath.
If any person knowingly and wilfully makes (otherwise than on oath) a statement false in a material particular, and the statement is made—
(a)in a statutory declaration; or
(b)in an abstract, account, balance sheet, book, certificate, declaration, entry, estimate, inventory, notice, report, return, or other document which he is authorised or required to make, attest, or verify, by any public general Act of Parliament for the time being in force; or
(c)in any oral declaration or oral answer which he is required to make by, under, or in pursuance of any public general Act of Parliament for the time being in force,
he shall be guilty of a misdemeanour and shall be liable on conviction thereof on indictment to imprisonment, . . . F1, for any term not exceeding two years, or to a fine or to both such imprisonment and fine."
I dutifully contest this statement and ask that it be struck from court documents, as inaccurate.
Furthermore I will pursue a formal complaint against North Tyneside Council, for maladministration, attempting to pervert the court of Justice and attempt to breach due procedure of court, along with a complaint of Gross Professional Misconduct.

SUMARY OF CHILD/YOUNG PERSON'S DEVELOPMENTAL NEEDS AND STRENGHTS my papers 19
I might remind the court that it is not illegal to breast feed my baby. I contend the statement made below. When Social Services took my baby from me she was continuing to breast feed and it was not as described a search of comfort.
(...) it is more likely that this is search of comfort, as opposed to her needing any milk.
(...) Kalindi's cot is three sided and is pushed next to her mother's mattress to support feeding through the night.
Any time KA needed milk I would provide for her. She required 6 feeds at night time, which is why the cot was arranged that way, in order to facilitate feeding.
EMOTIONAL AND BEHAVIOURAL DEVELOPMENT my paper 16
page 1. Child is excessively passive and hard to engage. (they said YES)
She was not, KALINDI easily engaged with me and her sister and the cats. I have a number of videos which proove KALINDI and KRISHNA were engaging with me, copies of which will be provided to the court in contention of this issue. The attributable positive agreement to this is a misrepresentation of fact.
Child can seem very wary over vigilant. (they said YES).
My Health visitor describes my baby as being peaceful, inquisitive and pleasant. This was stated it on page 2. My baby is not wary, or over vigilant. However, could someone please explain this as of course all children are inquisitive and watchful? This statement is at best factitious, at worst the agreement of the statemtent is intended to procure a false picture to the court.
Quote below from report! -
'KALINDI does present as an inquisitive and pleasant baby I have no witness her being inconsolable with Luci or any concerning behaviour'.
Child is distressed when others are distressed. (they said YES)
Any child can become distressed even at very little things; however the distress to KALINDI was at the very least kept to an absolute minimum at any time. Please again note the quote below, as reported by my Health Visitor.
Quote 2 contradictory.
"KA does present as a content and settled baby. She did have some contact with her father, CRAIG ROBSON recently and this was due to his requests and through the family court. Information from XX is that Kalindi did manage to settle, she was begining to respond to a routine and that he was able to comfort and soothe her."
I contend, once again, that the social worker Alison Dodds, ticked these boxes, without any proper assessment and that once again this amounts to professional misconduct, with intent to mislead or deceive the court.
XX told me she would cry loud and a lot while KA stayed at his flat with him. KA cried because she was hungry and would miss her milk 6 times at night. XX would attempt to comfort KAi by touching her head. However she would go back to sleep hungry, as she refused any other form of milk. (see page 2).

page5.(...) Luci is refusing CRAIG contact (with KALINDI) due a variety of reasons. (...) Luci has stated that she was aware of this (the cannabis farm).page 5.
This statement is speculative. I allowed my baby to have contact with her father, but on suitable hours, to which CRAIG agreed. When the COURT decided to let him have her at night, I did not agree, as Kalindi would go hungry through the night. CRAIG eventually agreed with me, as after one night the baby cried a lot in distress from being hungry as she needed feeding. One would have thought that this should have been obvious to both the court and to Social Services. Seemingly neither seem to be aware about how a "baby" is fed?
I wish to state at this point, my relationship with CRAIG had already ended, indeed it ended as soon as I became pregnant. Regarding the cannabis farm, I became aware of it when I found out, which was in August and in August I contacted the police. XX also apparantly had a cannabis farm in Wallsend, where he would attend to it.

1. Everyone has the right to respect for his private and family life, his home and his correspondence.
I contend that North Tyneside Social Services Department demonstrated a complete disrespect to my right to breast feed KALINDI, which was fully in alignment with the World Health Organisation recommendation and In terms of denying Kalindi regular feeding, that North Tyneside Social Services were not acting in the best interests of the child; this caused my child physical and mental distress which also amounts to both child negligence and abuse by the authorities concerned.
page 8. Child is bathed nearly every day. NO.
This is an outright attempt to decieve the court. I always bathed my baby everyday. However, how could any Social Workers know whether I bathe my baby everyday or not? So at best this is pure speculation and guess work at worst a deliberate attempt to misrepresent me in court.
On ticking this box, the Social worker is merely acting on supposition and assumption and with due respect may also be deliberately fabricating the answer in order to act in a manner which is clearly detrimental to my case, by trying to to portray to the court, that I am a poor parent. This is quite simply not the case, nor an accurate assessment of KA's bathing needs. I fully refute this.

INITIAL ASSESSMENT, my papers 13. By Joanna Dean, 28 August/13 Statement of fact, submitted as a counterstatement made to other false reports made by North Tyneside Social Service Division.
page 6. KALINDI presents as having a loving bond and attachment with her mother and older sister. (...)

Kalindi 2
Kalindi 3-4

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page 7. (...) There are no concerns regarding the presentation of either child. Both were wearing clean and tidy clothing. (...)
There do not appear to be any concerns with regard to Luci abililities to promote an apporpriate sense of identity.
page 7. KALINDI is a baby who will need all of her basic care needs to be met by her mother. There are no concerns with regards to Luci's ability to do this and meet her needs.
(...) There are no concerns with regard to Luci abilities to meet the needs of the children in this area of assessment.
FAMILY AND ENVIRONMENTAL FACTORS my papers 11-12 07/08/1 The Royal Victoria Infirmary 6/8/2012 (note, KA was born in 03/8/2012) my papers 12
page 1. However following an assessment from the Peri Natal Team no current issues were identified regardin Luci's mental health.
page 2. From the information gathered within this assessment and my obeservations there appears to be no saferguarding concerns at a Tier 3 Level and therefore no role for Children's Service at this time.
by Victoria Mckay/First Call service 15/08/2012
INTERIM CARE PLAN, 21 Nov 2013, my papers 6
page 2. (...) Ms Da Costa has continued to breast feed KALINDI, however it would appear that KALINDI gets little nutrition from this and rather seeks the physical comfort this provides.
Once again the Social Worker Alison Dodds, is making a presumptious and unfounded statement, which, I might add is also NOT qualified to comment on with respect. I might remind the court, that Alison Dodds, rarely visited me or saw me breastfeeding my baby. She has also contradicted the Health visitors, who were with me whilst feeding my baby, on several occasions.
page 3. The Local Authority hold signinficant concerns in regards to the parenting afforded to KALINDI whilst she was in the care of the mother, and therefore it is recommended that further assessments are needed before any plans in regards to KALINDI's care arrangements can be made. Absolute precedence has been given to KA's emotional and physical safety and wellbeing.
Statement Of Defense

North Tyneside Social Services have not acted with any concerns to KA's needs, they have engaged in a systematic and systemic attack on my right to breast feed my baby, they have insulted and sought to attack my parental abilities by using a series of false allegations, which are perjurous in themselves. They have sought to deny me my basic human rights to feed my child and oftimes acted in a manner which by all rights and remits falls into the category of Gross Professional Misconduct.
Their legal team has sort to procure and perpetuate lies about me, which are proven to be untrue and both their actions and reports are a total violation of human rights, not only in terms of the Human Rights Act but also as regards my right to a fair hearing. They have submitted false reports into the court and many of the reports submitted, have not only set out to taint me as regards my motherhood and parental ability, but are in themselves also untrue. Yes I have had my faults, but nowhere near to the level North Tyneside Social Services have insinuated I have.
I also contend that North Tyneside Social Service Division have descriminated me against me in terms of my religion and my race and that they have sought to conspire against my ability as a mother, by causing distress to KA, before I went to visit her,in the same manner as they did in court on 1st May. Which they then went on to deny, despite the fact there were other witnesses present.
All this action has been clearly done in order to deliberately maximise my distress, which they then used in a negative manner against me. I refer to the statements made below, in terms of my capability.
Professional Counterstatements issued below as regards my parental ability.
INITIAL ASSESSMENT 13/08/13 by Joanna Dean social worker my papers 14 page 10.Is the child/young person a child in need as defined in the Children Act? NO.
A child in need whose vulnerability is such that they are unlikely to reach or maintain a satisfactory level of health or development without the provision of services? NO
A child in need whose health or development will be significantly impaired without the provision of services (is suffering or is likely to suffer significant harm). NO
INITIAL ASSESSMENT. By Joanna Dean, 28 August/13 my papers 13 page 4. (...) The interaction that I witnessed between Luci and her baby were appropriate and positive.
page 6. KALINDI presents as having a loving bond and attachment with her mother and older sister. (...)
page 7. (...) There are no concerns regarding the presentation of either child. Both were wearing clean and tidy clothing. (...) There do not appear to be any concerns with regard to Luci abililities to promote an apporpriate sense of identity.
page 7.
KALINDI is a baby who will need all of her basic care needs to be met by her mother. There are no concerns with regards to Luci's ability to do this and meet her needs.
(...) There are no concerns with regard to Luci abilities to meet the needs of the children in this area of assessment.
FAMILY AND ENVIRONMENTAL FACTORS my papers 17
page 1. The home is clean and reasonably tidy and has a very lived in feel to it. KALINDI has room to crawl and explore her environment. There are many toys in the home for KALINDI to play with and these are in easy reach for her. KR has her own room in the flat, she keeps this tidy and has her own personal touches throughout. She is missing her laptop due to the lack of electicity but is occupying herself with the artwork and reading. There is a lot of KRISHNA's artwork throughout the home as well as religious statues that Luci prays to. KRISHNA will set up the praying item for Luci.

INTERIM CARE PLAN, 21 Nov 2013, my papers 6 page 2. (...) Ms Da Costa has continued to breast feed KALINDI, however it would appear that KA gets little nutrition from this and rather seeks the physical comfort this provides.
Repeat of statement (please also see answer above) Alison Dodds, rarely visited me or saw me breastfeeding my baby and as have stated above, she also contradicts the Health visitors, who were with me whilst feeding my baby on several occasions.
INITIAL ASSESSMENT my papers 14, 13/08/13 by Joanna Dean social worker page 10. Is the child/young person a child i need as defined in the Children Act? NO.
A child in need whose vulnerability is such that they are unlikely to reach or maintain a satisfactory level of health or development without the provision of services? NO
A child in need whose health or development will be significantly impaired without the provision of services (is suffering or is likely to suffer significant harm). NO
INITIAL ASSESSMENT, . By Joanna Dean, 28 August/13 my papers 13 page 4. (...) The interaction that I witnessed between Luci and her baby were appropriate and positive.
page 6. KALINDI presents as having a loving bond and attachment with her mother and older sister. (...)
page 7.(...) There are no concerns regarding the presentation of either child. Both were wearing clean and tidy clothing. (...) There do not appear to be any concerns with regard to Luci abililities to promote an apporpriate sense of identity.
page 7. KALINDI is a baby who will need all of her basic care needs to be met by her mother. There are no concerns with regards to Luci's ability to do this and meet her needs. (...) There are no concerns with regard to Luci abilities to meet the needs of the children in this area of assessment.
FAMILY AND ENVIRONMENTAL FACTORS page 17 page 1. The home is clean and reasonably tidy and has a very lived in feel to it. KALINDI has room to crawl and explore her environment. There are many toys in the home for KALINDI to play with and these are in easy reach for her. KRISHNA has her own room in the flat, she keeps this tidy and has her own personal touches throughout. She is missing her laptop due to the lack of electicity but is occupying herself with the artwork and reading. There is a lot of KRISHNA's artwork throughout the home as well as religious statues that Luci prays to. KRISHNA will set up the praying item for Luci.
CHILD PROTECTION INITIAL CONFERENCE 07/11/13 my papers 25 page 3. (...) In days following KALINDI's birth, positive observations between mother and daughter were made. (...) However following ana assessment from the Peri Natal Team no current issues were identified regarding her mental health.
page 4. (...) CRAIG contacted Police when Luci failed to bring KALINDI to his address as per the agreement. Whilst the Social Worker was at the address, Luci arrieved with KALINDI and handed her to Craig.
Another false statement, NO Social Worker was at the address, only a police officer was there.
However, page 5. (...) The police officer felt that CRAIG's flat was a little chilly and not greatly clean (...)
If a Social Worker had been in attendence, would she not have observed the state of the flat, the lack of heating, general appearance in terms of its cleanliness, or lack of it, and made a report on it. I contend that once again, Social Service Division of North Tyneside, are wilfully misleading this court.
I swear that all my statements are honest and factual and that all appear as have been reported and recorded by the various professionals concerned. I swear that all statements made by myself as regards both KALINDI are an honest reflection of the truth.
Yours faithfully
Luci Da Costa


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