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October 2,
2003
In The United States
District Court For
The Western District of Pennsylvania
This case arises from the unlawful seizure of two
infant children from the care and custody of their mother, Selena
Underwood, and the efforts to permanently separate Ms. Underwood
from her children. The seizure of the children in one case
separating a new born infant from her mother while both were in
the hospital recovering from delivery was the beginning of
Selena Underwood and her children's ordeal. Almost two years
after Defendants took her first child, Ms. Underwood's family
has yet to be reunited. The seizures of William Underwood and NaDayja Underwood Carter, and the prolonged and
continuing separation of the Underwood family, was without prior
judicial authorization, and without any basis to believe the
children were abused, neglected or in imminent threat of harm.
This action is brought, inter alia, to redress Defendants
arbitrary and malicious abuse of government power.

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