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TO WHOM IT MAY CONCERN I AM KAREEM H WARD WRITING THIS LETTER IN REGARDS TO AN IDENTITY THIEFT THAT CONTINUE TO BE A DISADVANTAGE DO TO THE ON GOING USE OF THE ORIGINAL NUMBER,BECAUSE OF THESE OFFENSES I AM BEING DEPRIVED OF ENTITLED BENEFITS,I AM ALSO BEING HELD RESPONSIBLE FOR OVER DRAFT PAYMENTS WHICH THEY RECOUP FROM MY MONTHLY BENEFITS THATS CAUSING ME TO FALL UNDER THE AMOUNT OF MONEY NEEDED TO COVER MY HOME BILLS. I CANT AFFORD MY ELECTRIC THIS MONTH, I CANT FOOD SHOP,WHICH IS ALL DO TO THE FACT OF ME BEING HELD RESPONSIBLE FOR A OVER DRAFT PAYMENT THEY ARE HOLDING ME ACCOUNTABLE FOR DURING THE TIMES OF ME BEING A MINOR WHEN I WASN'T THE ACTUAL PAYEE OF MY OWN BENEFITS AT THE TIME. ATTACHED IS THE CIVIL ACTIONS REGARDING THE MATTER,WHICH HAS NOT CAUSE ANY CHANGE TO THE CURRENT MONTHLY BENEFIT SITUATION I AM DEALING WITH   George M. Gilmer, Esq. (Gg5479) 26 Court Street Room 1708 Brooklyn, New York 11242gilmerlawfirmpllc@gmail.com

UNITED STATES FEDERAL COURT EASTERN DISTRICT OF NEW YORK __________________________________ KAREEM WARD,

Plaintiff,

Case No.:

page1image1697664page1image1697872 -against- UNITED STATES OF AMERICA, COMMISSIONER OF SOCIAL SECURITY and ADMINISTRATION FOR

CHILDREN AND FAMILY SERVICES and NEW YORK CITY BUREAU OF VITAL STATISTICS.

Defendants. ___________________________________

COMPLAINT FOR A CIVIL CASE

PARTIES

PLAINTIFFS: KAREEM WARD, 21 Truxton Street, Brooklyn, New York 11233

DEFENDANTS: OFFICE OF THE REGIONAL CHIEF COUNSEL, REGION II,, SOCIAL SECURITY ADMINISTRATION, 26 FEDERAL PLAZA, ROOM 3904, NEW YORK, NEW YORK 10278; NEW YORK CITY LAW DEPARTMENT, ADMINISTRATION FOR CHILDREN’S SERVICES, AND NEW YORK CITY BUREAU OF VITAL STATISTICS.

page1image1698080page1image1698288page1image1698496 JURISDICTION AND VENUE

This is an action for injunctive and monetary relief and damages pursuant to 42 U.S.C. § 1983 based upon the continuing violations of Plaintiffs’ rights under the First, Fourth and Fourteenth Amendments to the United States Constitution. Jurisdiction exists pursuant to 28 U.S.C. § 1331 and 1343 based on 42 U.S.C. §1983 and questions of federal constitutional law.

FACTS

This is a Civil Lawsuit filed against the United States government, Social Security Administration, the Administration of Children’s Services, and the NYC Bureau of Vital Statistics for the Violation of the Kareem Ward’s (Plaintiff’s) civil and constitutional rights. The Plaintiff reserves the right to name further Defendants.

The Plaintiff was made an orphan at birth because his biological mother passed away while giving birth to him.

The plaintiff was not aware of the fact that he lost his biological mother when he was born until a Social Security administration hearing date of January 10, 2014.

At this hearing the Defendant made him aware in sum in substance that someone was using his original social security number to obtain benefits, and the Agency had five files on their desk concerning his case but they were unable to provide him with any information concerning his original social security number.

page2image3796272page2image3796896 That on October 28, 1983 Charlotte Octavia Moore fraudulently filed a birth certificate with the New York City Department of Vital Records naming Kareem Harold Ward (“Plaintiff) as her child and Clarence Harold Ward as the Plaintiff’s birth father.

The Department of Vital Records negligently and fraudulently assisted Ms. Moore in changing this birth certificate.

Ms. Moore was the foster parent of the Plaintiff.

Ms. Moore is not the actual biological mother of Mr. Ward.

There are no adoption records regarding Ms. Moore adopting Plaintiff.

Mr. Ward’s father, Clarence Ward, passed away in 2001.

In order to obtain the benefits of the Plaintiff’s true biological mother’s estate, various actors, which will be revealed through the discovery process in this matter, used the Plaintiff’s social security number and received certain benefits that the Plaintiff was entitled to.

The Social Security Administration is aware the identity theft has been perpetrated against the Plaintiff but refuses to provide the information about Mr. Ward’s true biological mother.

As a result of the Social Security Administration hearing mentioned in paragraph six, Mr. Ward was awarded $99,997 based upon the work history of his biological mother.

The Plaintiff first learned that he was entitled to his mother’s benefits in 2014.

In 2014 Plaintiff was in the process of trying to obtain housing and to leave the purview of the Department of Homeless Services (“DHS”).

The Plaintiff was told to go to the Social Security Administration by DHS because of issues involving his assets and entitlements.

The Social Security Administration gave him a piece of paper and told him to go back to ACS.

ACS then sent the Plaintiff to 150 William Street, who sent him to 180 Water Street.

Neither agency was able to provide him any help.

The Plaintiff then made a Complaint to the Attorney General’s Office.

After this Complaint was made the Plaintiff then was invited to his local security office who made him aware that he was entitled to benefits but they could not provide him information regarding these benefits because he didn’t have any of his mother’s information.

Nevertheless, the Plaintiff went to a Social Security hearing in 2014 and was awarded money because of his entitlement stemming from his mother.

The Plaintiff’s non biological father Clarence Ward Jr., has two social security numbers, XREF: XXX-XX-7701 and XXX-XX-9928). The Plaintiff was made to understood that the XREF denotation indicates that someone was removed as beneficiary from the social security profile involving that number.

The Plaintiff was unjustly and fraudulently removed as the beneficiary. The named agencies are co-conspirators in this plot to defraud Plaintiff of his money.

It is believed that the reason he had two social security numbers is because Clarence Ward stole Kareem Ward’s identity at birth, used Plaintiff’s assigned social security number to access the benefits of Plaintiff’s mother’s estate. This effectively removed Plaintiff as the beneficiary of his mother’s estate.

Clarence Ward with the help of Ms. Ward, the negligence of Vital Records and ACS created a new identity for the Plaintiff and hence a new Social Security number.

The Plaintiff has made numerous attempts to ascertain his true identity from the Social Security Administration, the New York Department of Vital Records and the Administration of Children’s Services but has been told because of his deceased mother’s right to privacy he could not obtain this information.

The removal of the plaintiff from the original birth certificate deprived him of financial benefits of his mother’s estate.

Furthermore not knowing who its mother is has caused the Plaintiff great emotional harm.

It is believed that Plaintiff’s biological mother worked for the railroad and her death entitled the Plaintiff to multiple benefits as the rightful beneficiary.

The biological mother has setup trust fund accounts for the Plaintiff. The Plaintiff knows this because when he was with Services for the Underserved, an agency that provided

him housing, this agency was provided access to the Trust Fund accounts to pay a portion of his rent.

Without aid of this Honorable Court, there is no way Plaintiff can properly identify himself as the son of his biological mother without the various above the named agencies releasing information concerning her.

Upon information and belief, these trust accounts are located in Bank of America and Chase. Matter fact, the Plaintiff’s Con Edison bill was being paid from a trust found located in the Bank of America Account but Bank of America also refuses to provide pedigree information regarding who created this account.

There other Trust fund accounts set up for Plaintiff’s benefit but he can get access to them because he doesn’t have his mother’s information.

It is believed that the Plaintiff’s real biological mother created a trust fund for the Plaintiff but that due to identity theft, various actors, including the Plaintiff’s biological father, step mother and foster mother, changed the Plaintiff’s identity when a child to benefit from various bequests arising from his deceased mother’s estate.

The foster mother, Ms. Moore, received numerous financial benefits from the social security administration and the administration for children services because she stole the Plaintiff’s identity from 1992 until the present.

The above named defendants are aware of this identity theft that but Have refused to do anything about it.

The plaintiff was placed in Lincoln Hall group home, a state run agency. While in this home, Ms. Moore was collecting money because of her relationship to Mr. Ward and the underlying identity theft. She was collecting about $3000 a month from February 1999 until July 1999. Ms. Moore’s receipt of these benefits caused the Plaintiff harm in that other benefits he was supposed to have received were stopped.

All of the named defendants have been put on notice about this identity theft but have refused to provide the Plaintiff with his biological mother’s information because of privacy issues but it is clear that a different social security number exists under the Plaintiff’s real name and identity.

The Defendants are wrongfully all in possession of information of the Plaintiff’s true mother, and their unwillingness to release this information deprives Plaintiff of his right, and violates his Constitutional rights. It also makes them co-conspirators in the ongoing defrauding of the Plaintiff.

Furthermore, the Defendant’s possession of this information, the identity of the plaintiffs true birth mother, make the Defendant’s coconspirators with the individuals, Clarence Ward and Octavia Moore.

FIRST CAUSE OF ACTION, Violation of Plaintiff’s Constitutional Rights under

the 1st, Fourth and Fourteenth Amendments

The failure of the Defendants to provide Plaintiff with this information deprives him of his constitutional right under the 1st Amendment, 4th and Fourteenth Amendment of the United States Constitution because the failure to disclose information concerning

page7image3798352page7image3798976 Plaintiff’s biological mother violates an individual's right to receive information and ideas which is protected by the First Amendment.

The refusal to provide Plaintiff with this information also violates the Fourth Amendment in the the US Government wrongfully may be in possession of property of Plaintiff, constituting an impermissible seizure of his property, namely money that may be available to him from social security and pedigree information regarding his biological mother which he is entitled to under the First Amendment.

Finally the wrongful possession of Plaintiff’s property by the Social Security Administration is a violation of his 14th Amendment due process rights because this property was taken from him without due process.

Interference with these rights undermines one's freedom to participate in and contribute to social and governmental decision making processes.

Such participation requires a healthy mind, free from emotional and psychological stress.

Plaintiff cannot fully participate in the decision making process and the inability to learn his biological heritage has damaged his emotional and psychological development.

Thus, the first amendment's guarantee of the right to receive information gives Plaintiff the right to require access his true birth records because the receipt of the information is essential for his self-fulfillment.

The restrictions imposed by the Defendants impede the individual's mental growth and thus deny meaningful participation in social and political decision making.

The right to privacy guarantees an individual both privacy in the most fundamental aspects of life and the right to make choices about personal matters.

Based on the rights emanating from the fundamental guarantees of the first amendment, that the privacy right must protect the individual's identity development because an individual's ability to make decisions is governed by identity formation.

Any restriction on an individual's emotional growth is viewed, therefore, as a denial of the autonomous control over the development and expression of one's intellect, interests, tastes and personality.

The natural parents' right to privacy does not overrides the child's right to know his biological parents.

Under the Fourteenth Amendment, the unlawful actions (failure of the Defendants to provide the the Plaintiff with information about Plaintiff’s birth mother and the Social Security Administration possible possession of monies owed to the Plaintiff) were done with the specific intent to deprive Plaintiff of his constitutional right to be secure in his property.

Plaintiffs are informed and believe that the acts of the Defendant and their employees and agents were intentional in failing to protect and preserve Plaintiffs’ property and that, at minimum Defendants were deliberately indifferent to the likely consequence that the the Defendant, begin deprived of property rightfully his would suffer pecuniary loss and emotional distress as a result of this improper seizure.

WHEREFORE, Plaintiff prays as follows: 1. For a temporary restraining order, preliminary and permanent injunction compelling the Defendants to provide Plaintiff with pedigree information concerning his birth mother; 2. Compensatory and punitive damages for at least 1 million dollars for the Defendants intentional violation of Defendants constitutional rights and 3. Such further relief as this Court Deems Just and Proper.

Certification: Under federal rule of civil procedure 11, by signing below, I certify to the best of my knowledge, information and belief that this complaint, 1) is not being presented for an improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation, 2) is supported by existing law or by a non frivolous argument for extending, modifying, or reversing existing law, 3) the factual contentions have an evidentiary support, or, if specifically so identified, will likely have evidentiary support after a reasonable opportunity for further investigation or discovery, and 4) the Complaint otherwise complies with the requirements of Rule 11.

Dated: Brooklyn, New York November 15, 2018

/s/ Kareem Ward

Kareem Ward, Plaintiff By: Gilmer Law Firm, PLLC

/s/ George M. Gilmer (gg5479) George M. Gilmer, Esq.

page10image1702864page10image1703072 26 Court Street, Room 1708 Brooklyn, New York 11242gilmerlawfirmpllc@gmail.com