Questions Presented

QUESTIONS PRESENTED

1) Was the Administrative Law Judge Jones order that relied on quotes
by CPS Worker Bolden undermined and rendered void by the September 8,
2008 testimony of CPS Bolden in which she recanted her December 5,
2007 original allegations against Denise Bruns? (these quotes) her
testimony takes away her

2) Was Administrative Law Judge Jones order to keep Denise Bruns on
Central Registry based on Ms. Bolden’s report undermined and rendered
void by CPS worker Bolden’s subsequent testimony that the 26 times CPS
investigated Ms. Bruns they “found no substantiations of abuse against
Ms. Bruns” since Judge Jones’ order quoted Ms. Bolden’s original
report that she recanted?

3)Is the recantations of Ms. Bolden and the affidavits of Oliver
Bruns explaining he was misquoted by CPS worker Bolden who “blew the
hole thing out of proportion” is sufficient evidence to expunge
Petitioner Ms. Bruns name from Central registry as a category II high
risk for future abuse? (Ex. 24)

4) Did the Administrative Law Judge Jones’ December 11, 2007
decision and order determining the petitioner Ms. Bruns fits within
the central registry category II indicating a high risk of future harm
to the child have any basis in fact, or is it merely an arbitrary and
capricious ruling based on fabrication and hearsay quotes that have
been recanted, not corroborated by any evidence, is one of the legal
grounds under which a government official's official action may be
challenged in the state court of law?

5) Was Administrative Law Judge Jones’ December 11, 2008 decision and
order undermined by Kent County CPS Nyela Bolden’s November 21, 2007
face to face interview with the minor children that violated forensic
Interviewing Protocol when she interviewed the minor child Oliver
Bruns in the presence of his father Kim Bruns and Wife Sandy Bruns?
(Ex 21)

5) Was the Administrative Law Judge Jones’ order undermined by CPS
Nyela Bolden’s December 5, 2007 report that clearly establishes her
failure to follow the proper Forensic Interview Protocol during the
November 21, 2007 interview “contaminated” the child witness, put
words into his mouth that substantiated abuse that really did not
occur clearly establishing Oliver’s responses to questions were not
reliable?


5) Newly acquired evidence to be considered: Does Oliver Bruns (DOB
July, 21, 1990) July 28, 2009 sworn affidavit recanting the
allegations presented on November 21, 2007 in the presence of his
father Kim Bruns and wife Sandy Bruns clearly establish CPS Nyela
Bolden violated Forensic Interview Protocol, contaminated his
interview, put words in his mother and blew the situation out of
proportion? (Ex 26)