Bel Air, Maryland 21014

The undersigned spoke with Silvia Houzouris on several occasions. She also claimed that she has been "railroaded into jail" by corrupt lawyers and judges that usurped the judicial process to help her estranged husband, Nick Houzouris, and his attorney, John S. Karas, unlawfully gain custody of their minor son via Attorney Karas’ motions that deliberately omitted Nick Houzouris’ documented history of abuse and aggravated assault, and contained perjury and fraud upon the court.

Ms. Houzouris claims she submitted evidence to the court that proves Attorney Karas and Nick Houzouris used fraud upon the court and perjury to unlawfully incarcerate obtain custody of the minor Houzouris child.

Ms. Houzouris claims the court ignored and suppressed her exculpatory evidence, and based on a fraudulent allegation willfully filed by her ex-husband and his attorneys, Donlick and Karas, that she abducted her son the court unlawfully issued an arrest warrant for abducting the minor child across state borders.

Ms. Houzouris claims she was arrested at the Canadian Border based on the false arrest warrant and was released by the authorities after they reviewed her evidence that proved her innocence. But, she was arrested for a second time in New York and was transported to Maryland, arrested for a third time and maliciously prosecuted and forced into psychiatric interrogation.

Since her arrest, Ms. Houzouris claims the judges, state prosecutor and public defender have unlawfully refused to allow her to represent herself as a pro se litigant, and have conspired to suppress her exculpatory evidence. And, Ms. Houzouris claims the judges suppressed her psychiatric report and called in a corrupt state psychiatrist, a Dr. Kimberly Witczak, to diagnose Ms. Houzouris as incompetent to stand trial to unlawfully deny her a jury trial, silence her and suppress her evidence that a corrupt public defender has refused to submit to the court.

She claims there is a conspiracy between the court, prosecutor,

public defender and the psychiatrist – all to protect attorney John Karas and her estranged husband Nick Houzouris who have usurped the judicial process with fraud, perjury, subornation of judicial corruption, manipulation of the court, malicious prosecution, and more…

In the above cited divorce/custody case, the undersigned inspected motions submitted by attorneys John S. Karas and Daniel Donlick for their client, Nick Houzouris.

Exhibit 1 of this report is an "Amended Complaint for Limited Divorce" submitted by Attorney Karas on March 10, 2006, and a "Supplemental Complaint for Absolute Divorce".

Item #4 of the Amended Complaint for Limited Divorce states, "Plaintiff is a fit and proper person to care for and nurture the Parties’ minor child, and it is in the minor child’s best interest that his care and custody be awarded to your Plaintiff."

And, Item #6 states "Plaintiff has always been a kind, chaste and

affectionate husband, the Defendant without just cause or reason did desert and abandon your Plaintiff on or about February 24, 2006."

Item #4 of the Supplemented Complaint for Absolute Divorce state that "due to irreconcilable differences" the parties separated. And, "the separation was the mutual and voluntary act of the parties. Item #5 states again that "Plaintiff is a fit and proper person to care for and nurture the parties’ minor child"

Exhibits 2 – 4 of this report reveal the claims of Nick Houzouris and his attorney, John Karas, as fraud upon the court and perjury, as detailed;

Exhibit 2 of this report contains documentation of abuse in 2005. It contains a doctor’s report from Drs. Louderback and N.R. Harapanahalli. The report documents bruising on Ms. Houzouris. At the bottom of page one, it is important to note that the doctor wrote "patient is afraid to leave husband. ‘His family has a lot of money and he has threatened to take her son away if she divorced him"

Exhibit 2 also contains an apology letter from Nick Houzouris to Ms. Houzouris’ mother, Iveta, admitting he doesn’t treat Ms. Houzouris well.

Exhibit 3 of this report contains documentation of abuse in 2006. It contains a police report, doctors’ reports and judicial protective orders issued to protect Silvia Houzouris and the minor Houzouris child from Nick Houzouris’ domestic violence and aggravated assault regarding an incident of assault against Silvia by Nick Houzouris on February 20, 2006. The judge’s ruling gave sole custody of the minor Houzouris child to Silvia Houzouris.

Exhibit 3’s police report and temporary protective order had been served on Plaintiff and were on file in the court three weeks before Attorney Karas submitted his client’s "Amended Complaint for Limited Divorce"(Exhibit 1), and the one-year final protective order was issued March 2, 2006 one week before they submitted their Amended Complaint for Limited Divorce. The court’s final protective order in Exhibit 3 clearly reveals that Attorney Karas and his client, Nick Houzouris, perpetrated a fraud upon the court when they claimed Nick was a "fit and proper" parent and "a kind and loving husband." These statements were certified as true and accurate by Nick Houzouris and Attorney Karas. Their statements were clearly made in defiance of the police report and Judge Butanis’ finding that Nick Houzouris perpetrated a "physical assault" against Silvia Houzouris on 2/20/06.

Exhibit 1’s Complaint for Absolute Divorce was submitted in October 2007, twenty (20) months after the police reports, doctors reports and court protective orders began to document Nick Houzouris’ history of abuse – that continued into 2008 and drove Ms. Houzouris from the marital home.

Exhibit 2 & 3 also contain doctors reports documenting bruising in 2005 & 2006.

On June 1, 2006 Nick Houzouris and his attorney, John Karas, made an appeal of the Protective Order (Exhibit 3). Judge Plitt denied the appeal and issued a final protective order re-affirming Nick Houzouris ’ domestic violence finding him guilty of second-degree assault. The appeal by Nick Houzouris and his attorney indicate a palpable defiance of the doctors’ reports, police report, Judicial Protective Order and report of N.R. Harapanahalli (Exhibit 3) indicating their denial regarding Houzouris’ domestic violence and aggravated assault against Ms. Houzouris. Ms. Houzouris’ sole custody

Exhibit 4 of this report contains a temporary protective order issued by Judge Cooper on July 3, 2008 regarding a third assault by Nick Houzouris against Ms. Houzouris that occurred on July 2, 2008. On September 25, 2008, Judge Waldron issued another protective order.

Atty. Karas’ fraudulent motions, such as those in Exhibit 1, were partially used as the basis for the court’s unlawful ruling to award custody to Nick Houzouris, a person with a documented history of abuse.

.

Ms. Houzouris submitted a Motion to Void Judgment on June 22, 2009 and Motion to Correct the Record on 7.2.09 (See docket), which contains an authentic and corrected History of the Case with supporting police reports and final protective orders signed by a judge documenting Nick Houzouris’ history of abuse (Exhibits 2 & 3) that clearly demonstrates that Attorney Karas and Nick Houzouris willfully lied to the court in their Amended Complaint for Limited Divorce and Complaint for Absolute Divorce (Both in Exhibit 1).

The docket reveals Judge Carr did not correct the court record

to include Nick Houzouris’ documented history of abuse. Judge Carr did not report Attorney John Karas and Nick Houzouris’ fraud upon the court and perjury "to the proper authorities" as mandated by Judicial Canons and he did not sanction Mr. Karas in any way for knowingly representing a guilty party and perpetrating a fraud upon the court.

Instead, the docket reveals Judge Carr knowingly awarded custody of the minor child to Nick Houzouris, who as Exhibits 2 – 4 demonstrate has a documented history of abuse. Awarding custody to a parent with a history of domestic violence and aggravated assault in violation of the judge’s mandate "to act in the best interest of the child."

Ms. Houzouris’ Motion for Void Judgment documents that when the court awarded custody of the minor child to Nick Houzouris in November 2008, the court did so in willful violation of state law supported by the protective orders in Exhibits 2 &3 were on the record in the court and presented again to the court in June 22, 2009.

Judge Carr and Judge Waldron refused to acknowledge Ms. Houzouris’ Motion to Void Judgment or Motion Correct the Record Ms. Houzouris documented Nick Houzouris’ history of abuse to correct the fraudulent statements by Attorney John S. Karas in the Plaintiff’s motions contained in Exhibit 1, which willfully omitted, misstated and denied Nick Houzouris’ documented history of abuse (See Exhibits 2 - 4), which usurped the judicial process and robbed the court of jurisdiction over the subject matter.

Exhibits 2 - 4, the police reports, Drs. reports and court protective orders issued to protect Ms. Houzouris against Nick Houzouris, do not appear in Nick Houzouris’ motions written by Attorneys John Karas and Daniel Donlick (Exhibits 1, 5 & 6). This evidence is consistent with Ms. Houzouris’ allegations that attorneys Karas and Donlick willfully omitted from their motions Nick Houzouris’ history of domestic violence and aggravated assault against Ms. Houzouris. For the sake of the brevity of this report, See Exhibits 5 & 6 and the other motions written by Karas and Donlick on file in the above cited divorce/custody case, which willfully omit Nick

B. Arrest Warrants

Exhibit 5 of this report contains an emergency petition by Nick

Karas and an arrest warrant issued based on the petition’s false claims:

Item #4 – contains a claim that Ms. Houzouris has "vacated her

Item #6 – contains "information provided by counsel for the

The "emergency" petition (Exhibit 5) contains no first-hand evidence of any kind to support their claim that Ms. Houzouris "vacated her residence." The "emergency" petition contains no first-hand evidence or knowledge of abduction – or any other crime. The emergency motion "on its face" is legally insufficient and contains no first-hand evidence or knowledge, and overtly violates the False Claims Act. The histrionics and hearsay it contains "is legally insufficient" and, by law, does not provide probable cause to convene an "emergency" ex-parte hearing. Judge Carr did not have jurisdiction to convene an ex-parte hearing when no emergency existed and did not receive probable cause any emergency existed.

Exhibit 6 of this report is an arrest warrant for child abduction across international borders by Judge Waldron. Based on the arrest warrant, Judge Waldron awarded custody of the minor child to Nick Houzouris who has a documented history of domestic violence (see Exhibits 2 - 4). Judge Carr issued this arrest warrant based on an "emergency petition" that as with Exhibit 5 contained no first-hand

Judge Carr was aware that the petitioner, Nick Houzouris, had a history of committing fraud upon the court and perjury in his Amended Divorce Complaint (Exhibit 1) and Emergency Motions (Exhibits 5 & 6).

Exhibit 7 of this report contains copies of Ms. Houzouris’ passports that were clearly expired and were not valid for international travel outside of North America. This evidence proves that Ms. Houzouris had no travel plans outside of North America.

Exhibit 5 of this report contains an Emergency Motion dated November 6, 2008. On that date an emergency ex parte hearing was convened to address the allegations of Nick Houzouris and Attorney Donlick that Silvia Houzouris had abducted the minor child.

The hearing did not meet the requirements for an ex parte emergency hearing as no "party" or anyone presented first-hand knowledge that Silvia Houzouris had abducted the minor child, or that an emergency existed. The petition was legally insufficient.

At this point in time, Judge Carr, Mr. Houzouris and his attorneys had received from Defendant Silvia Houzouris motions that contained the police reports and court protective orders (Exhibit 3 & 4) proving Nick Houzouris had a documented history of abuse against Silvia Houzouris. The evidence Ms. Houzouris presented to the court also made it clear to Judge Carr that Nick Houzouris’ attorneys, Mr. Karas and Mr. Donlick, had committed fraud upon the court and perjury when they petitioned the court. Yet, Judge Carr convened an "emergency" ex-parte hearing without any evidence that an emergency existed.

Exhibit 5 of this report also contains an order by Judge Carr finding Ms. Houzouris abducted the minor child across state lines. The arrest warrant was issued in defiance of the fact that no one presented first-hand knowledge that child abduction occurred, and Nick Houzouris did not reveal that he knew Ms. Houzouris was on a pre-arranged holiday with their son, of whom she had sole physical custody.

Exhibit 7 of this report contains Ms. Houzouris’ passports, which were expired when Ms. Houzouris left for Canada to visit family. Judges Carr and Waldron did not perform due diligence to determine whether the allegations that Ms. Houzouris had abducted the child and was heading to Bulgaria were not even a possibility without a valid passport. The lack of a valid passport is clear evidence that the allegations that Ms. Houzouris was heading to Bulgaria had no validity whatsoever.

Exhibit 8 of this report contains an email Ms. Houzouris’ forwarded to Nick Houzouris that she was going on a holiday during her time with the minor child. Ms. Houzouris is a Bulgarian-American and has a limited grasp of English grammar and spelling. In the email, she suggested that Nick, too, take the minor child on a holiday during his time with their son. The email indicates that Ms. Houzouris had communicated with Nick Houzouris regarding her and Mr. Houzouris’ time with the minor child to accommodate his request for Thanksgiving time with the child.

Nick Houzouris and his attorneys, Mr. Karas and Mr. Donlick did not include this email as part of their Emergency Motions (Exhibits 5 & 6). They did not inform the court that Ms. Houzouris had an arrangement with Nick Houzouris to take the minor Houzouris child so that Nick could have him for Thanksgiving.

Exhibit 9 of this report is an affidavit by Ms. Houzouris that details what occurred when she was arrested at the Canada/US Border. Apparently, Ms, Houzouris was arrested by U.S. Border Guards based on the arrest warrant issued by the court (Exhibit 5), which was based on false allegations made by Nick Houzouris and Attorney Donlick.

After reviewing Ms. Houzouris’ email to Nick Houzouris

(Exhibit 8) and they saw that Ms. Houzouris only had enough clothes and accessories for a few days, the Border Guards made a telephone call to Judge Carr in Ms. Houzouris’ presence and informed Judge Carr that they were releasing Ms. Houzouris as the evidence she submitted to them proved the arrest warrant was unfounded. Subsequently, Ms. Houzouris was released. To date Ms. Houzouris’ public defender has not subpoenaed telephone records to prove that the Border Guards telephoned and spoke to Judge Carr informing him that they were releasing Ms. Houzouris as the evidence they reviewed proved that the arrest warrant was "unfounded."

After being released by the Canadian Border Guards, Ms. Houzouris was afraid to return to Maryland and face another false arrest and imprisonment. She sought relief at a New York State Shelter for Battered Women as she discerned that Nick Houzouris and his attorneys had suborned judges to issue false arrest warrants.

Ms. Houzouris sent a Motion containing a list of Nick Houzouris’ domestic violence w/attached letter to her attorney, Mr. Kleeman, and the Court stating she was in the shelter as a result of a "clear and present danger" to her and her son as a result of being victimized by domestic violence and arrested via an unlawful arrest warrant at the US Border. In the letter, she asked for a postponement of all hearings as she was seeking legal advice as Attorney Kleeman had refused to focus the court’s attention on Nick Houzouris’ history of domestic violence and his fraud upon the court and perjury.

Attorney Kleeman violated his client’s best interest and did not petition the court to postpone all hearings. He did not challenge the arrest warrant and did not focus the court’s attention on the fraud upon the court willfully perpetrated by Nick Houzouris and his attorney, John Karas, nor did he focus the court’s attention on Nick Houzouris’ history of domestic violence and aggravated assault.

Ms. Houzouris called her attorney, Mr. Kleeman, on the morning of November 8, 2008 to follow-up on sending her motion. She asked Attorney Kleeman to petition the court to have the arrest warrant dismissed and to postpone the divorce hearing. Attorney Kleeman stated to Silvia that he didn’t believe that Judge Carr would do anything or change his order. He did not submit her Motion and did not present to the court Nick’s documented history of abuse or his fraud upon the court and perjury.

On November 10, 2008, Attorney Kleeman again stated to

A. Due Process Violations

On November 12, 2008, a Hearing was convened in Circuit Court before Judge Waldron. In the hearing, Attorney Karas acknowledged that Ms. Houzouris had sent her Motion/letter to the Court requesting a postponement of all hearings as she and her son were in a Shelter, where the shelter checked Nick Houzouris’ history of abuse before they accepted her and her son into their care.

All parties, including Judge Waldron and Attorney Karas had been informed that Ms. Houzouris had been released by the US Border Guards and was in a shelter – where by law (Md. Rule 9-306) she had "complete protection and anonymity." Yet, they continued with the hearings in defiance of the law written to protect women and children who are victims of domestic violence.

Although Ms. Houzouris’ had paid Attorney Kleeman to represent her, he [and the previous lawyers Ms. Houzouris had hired] did not present to the court that Attorney Karas and Nick Houzouris had submitted fraudulent motions (Exhibits 1 & 5), including the Emergency Petition (Exhibit 6) upon which a second false arrest warrant was issued on Nov. 13, 2008. Attorney Kleeman allowed the hearing to proceed without objection, in defiance of the fact that his client was a victim of a pattern and practice of fraud upon the court and perjury as well as domestic violence by Plaintiff Nick Houzouris.

In the 11.13.08 hearing, Judge Waldron removed custody of the minor Houzouris child from Ms. Houzouris and issuing another arrest warrant for child abduction across international borders by Ms. Houzouris. This arrest warrant (Exhibit 6) is based on an hysterical fantasy that Ms. Houzouris could obtain a counterfeit passport to abduct her son to Bulgaria. Her EXPIRED passports can be seen in Exhibit 7 of this report. All she had to do was renew her passport if she wanted to

Attorney Kleeman did not present Ms. Houzouris’ exculpatory evidence that he knew and understood had freed her after the arrest at the Canadian Border, and claimed that he had "no witnesses" to testify on Ms. Houzouris’ behalf. Eleonora Multer spoke up and asked to testify in Ms. Houzouris’ behalf. A review of the hearing transcript revealed that Ms. Houzouris’ attorney, Mr. Kleeman, also failed to focus the court’s attention on Nick Houzouris’ Domestic Violence and fraud upon the court. Instead, the Judge and Attorney Karas grilled Ms. Multer as to where Ms. Houzouris was, despite that they had been informed that Ms. Houzouris was in a Battered Woman Shelter

On November 13, 2008 another hearing was held in front of Judge Waldron. Nick Houzouris and Attorney Karas submitted another Emergency Petition (Exhibit 6). This time the Emergency Petition contained the claim that Ms. Houzouris was kidnapping their son to Bulgaria, her native country. Judge Waldron issued an arrest warrant based on international child abduction (Exhibit 6). Judge Waldron awarded custody of the minor child to Plaintiff Nick Houzouris.

Exhibit 7 of this report contains copies of Ms. Houzouris’ passports that had expired. Judge Waldron and Attorney John Karas did no due diligence to even inquire to the Office of the US Customs to inquire as to whether Ms. Houzouris had valid passport. If they had, their hysterics may have been put to rest. Instead, with no party to the case reporting first-hand experience that abduction occurred, and no probable cause, Judge Waldron issued the arrest warrant (Exhibit 6) based on allegations of international child-abduction when that option was not available without Ms. Houzouris and her child possessing valid passports based on Plaintiff’s motions that contained no first-hand experience or knowledge.

On November 13, 2008, Dr. Patricia McGraw testified. It should be noted that Judge Waldron made Dr. McGraw wait for eight hours the previous day, and gave her no professional courtesy. When Dr. McGraw started to testify, the transcript and witnesses reveal that Judge Waldron shouted Dr. McGraw down, humiliated her and drove her out of the courtroom with an oral assault. [It should be noted that Judge Waldron also stifles Ms. Houzouris in future hearings, overtly stifling Ms. Houzouris and her expert witness to prevent them from placing Ms. Houzouris’ exculpatory evidence on the record. The willful stifling of parties and their expert witnesses violates due process and Judicial Canons, which state "all parties must be heard in full" and "be treated courteously".

Dr. McGraw spent twenty hours evaluating Ms. Houzouris and her son over five days. Her report (Exhibit 21) is the most in-depth evaluation of Ms. Houzouris to date. All other reports were done by "ringers" appointed by the court to condemn Defendant Houzouris. Judge Waldron’s unprofessional and disgraceful treatment of Dr. McGraw reveals an agenda to discredit Ms. Houzouris and all who support her competency and parenting skills, which are included in Dr. McGraw’s report (Exhibit 21) as exemplary.

The undersigned spoke with Dr. McGraw recently and she admitted to being intimidated and frightened by Judge Waldron and the "good ol’ boy network" that runs Harford County to the point that she doesn’t want to be bullied or intimidated by them anymore and does not wish to appear in their courts. She wasn’t surprised to hear that Judge Waldron also shouted down and stifled Ms. Houzouris.

Ms. Houzouris was arrested on November 20, 2008 by New

York authorities based on the false arrest warrants (Exhibits 5 & 6) subsequent to Judge Carr being informed by the US Border Guards that they determined the arrest warrant was "unfounded" and released Ms. Houzouris. Yet, Judge Carr allowed the arrest warrant to stay active.

Exhibit 10 of this report contains a letter from the New York

Office of Children and Family Services signed by its director and Chief Administrative Judge, Steven M. Connolly, who reviewed the evidence and determined that she was innocent and the arrest warrant was "unfounded." The judge closed the case and sealed the case documents.

Exhibit 10’s letter from Judge Connolly documents the second government authority that reviewed Ms. Houzouris’ evidence and determined that the arrest warrant was "unfounded."

After five (5) days in a New York jail, Ms. Houzouris was transported to Maryland and arrested based on charges she "abducted" her son "to Bulgaria" (See arrest warrant and Emergency Petition in Exhibit 6) despite that she had informed Nick Houzouris of her holiday plans with the minor child in her email to him (Exhibit 8).

Exhibit 11 of this report contains an affidavit by Eleonora Multer that documents what occurred when she and Ms. Houzouris visited the US Attorneys Office in Baltimore. The affidavit details that she and Ms. Houzouris witnessed Assistant US Attorney Richard Kay review Ms. Houzouris’ evidence and state that Ms. Houzouris was innocent and the arrest warrant was unfounded. He also stated that he felt there was "something wrong" with the court’s prosecution of Ms. Houzouris. This affidavit (Exhibit 11) is consistent with Ms. Houzouris’ claim that the Assistant US Attorney Kay stated she was innocent of the charges.

On 1/13/09, an criminal arraignment was convened despite the fact that the complainants, prosecutor and judge had been supplied with Ms. Houzouris’ email to Nick Houzouris (Exhibit 8), which contained evidence that Ms. Houzouris communicated with Nick Houzouris regarding her and his holiday time with their minor child.

The arraignment was held in defiance of the fact that the case docket reveals state prosecutor Tobin received the original file from the District Court on 12/15/08, including the Emergency Petitions (Exhibits 5 & 6) and arrest warrants (Exhibits 5 & 6) that on-their-face prove irrefutably that Nick Houzouris’ Emergency Petitions (Exhibits 5 & 6) are legally insufficient as they contain no first-hand knowledge, but only allusions to a "third-party", which is mere hearsay, and without the "third-party" being identified. And, Prosecutor Tobin received proof that Nick Houzouris and his attorneys, Mr. Karas and Donlick, committed fraud upon the court and perjury in their petitions by willfully lying about Nick Houzouris’ history of abuse and violence, and fabricating that an abduction took place.

All of the above is consistent with the claims of Ms. Houzouris

that state prosecutor Tobin, as well as Judges Carr and Waldron, is well aware of her exculpatory evidence that has been corroborated by the US Customs Border Guards, the New York Office of Children and Family Services and Assistant US Attorney Richard Kay (See below).

G. Public Defender Greenberg

Exhibit 13 of this report contains a letter from Ms. Houzouris to Public Defender Greenberg firing him for deliberately working against her. Consistent with her claims is the docket and eyewitness reports that reveal that Mr. Greenberg did not gather evidence, subpoena witnesses or perform any Discovery, whatsoever, in Ms. Houzouris’ behalf. Ms. Houzouris claimed to the undersigned that when she spoke to Public Defender Greenberg he boasted that he had no intentions of opening her file, gathering evidence or issuing subpoenas for the US Customs Guards, the New York Office of Children and Family Services’ Chief Judge Steven M. Connolly or Assistant US Attorney Richard Kay to testify that they determined the arrest warrant under which Ms. Houzouris was arrested was "unfounded".

The allegations in Ms. Houzouris’ letter are consistent with the fact that, to date, the case docket reflects no Motion to Dismiss has

been submitted by Public Defender Greenberg, and no subpoenas

have been issued to the US Customs Border Guards, the New York Office of Children and Family Services or Assistant US Attorney Kay, all of whom determined that Ms. Houzouris was innocent of the charges contained in the arrest warrant.

Three days later Ms. Houzouris received a letter from Judge Marshall (Exhibit 13) stating that he could not read her motions as she "was represented by Public Defender Greenberg" in overt defiance of the fact that the docket also reflects Greenberg was fired by Ms. Houzouris for ineffective assistance of counsel. Specifically, that Greenberg refused to present her evidence or defend her in any manner. His conduct repeats the exact reasons Ms. Houzouris fired Attorney Kleeman.

On August 6, 2009 a Show Cause Hearing was held in the Circuit Court for Harford County before Judge Carr. The judge

threatened to revoke Ms. Houzouris’ bond and throw her in jail if she didn’t comply with forced psychiatric interrogation by a ‘ringer" appointed by the Court in defiance of the fact that Ms. Houzouris submitted the psychiatric report of Dr. McGraw regarding her impressive abilities as a parent and in good psychological health.

Despite the fact that Public Defender Greenberg was fired by Ms. Houzouris in a letter (Exhibit 13) that is documented on the case docket, Judge Carr did not allow Ms. Houzouris’ to act as her own representation.

Silvia Houzouris attempted to present her exculpatory evidence, but Judge Carr stated he wouldn’t let her present any evidence. Ms. Houzouris requested that she be permitted to make a defendant’s statement. Judge Carr refused to accept her written defendant’s statement and stifled her attempts to make oral defendant’s statements and left the courtroom.

The case docket reveals that Public Defender Greenberg did not

submit any evidence from the US Customs Border Guards, the New York Office of Children and Family Services or Assistant US Attorney Kay, which is consistent with Ms. Houzouris’ claim that he boasted that he refused to even review her evidence and would do nothing more than present a plea bargain that would put Ms.

Houzouris in jail for two years in defiance of her letter firing him.

The undersigned interviewed Ms. Houzouris and witness Teresa Yoder, both of whom were present at the show-cause hearing. They reported that the judge shouted Ms. Houzouris down and did not

Houzouris’ repeated requests to have her right to represent herself upheld and to present the same evidence that convinced the US Border Guards, New York Office of Children and Family Services and Assistant US Attorney of her innocence.

Judges Carr, Waldron, Plitt and Marshall violated Judicial

Canons when they refused to allow Ms. Houzouris to make or submit

a defendant’s statement, and stifled all attempts on her part to present

exculpatory evidence that was reviewed by the US Customs Border Guards and New York Office of Children and Family Services who released Ms. Houzouris and informed Judge Carr that they released her as her evidence proved the arrest warrant was unfounded.

Judges Carr, Waldron, Plitt and Marshall did not allow Ms. Houzouris to present affidavits or testimony regarding her visits to the US Attorneys Office in which Assistant US Attorney Richard Kay reviewed her evidence and stated in front of Ms. Houzouris and a witness that she did not abduct her son and "something is wrong in the court" for prosecuting her. Exhibit 11 of this report contains an affidavit of Ms. Houzouris’ witness, Eleanora Multer, which confirms the above statements by Assistant US Attorney Kay.

The undersigned reviewed the case docket and, to date, there is no record of Public Defender Greenberg submitting a Motion to Dismiss containing the material evidence contained in this report, and contained in Ms. Houzouris’ Motion to Dismiss and Motion to Void Judgments, which are on file with the court, but suppressed Judges Carr, Plitt, Waldron and Marshall.

Exhibit 12 of this report contains a Motion to Compel Psychiatric Evaluation by State Prosecutor Diane A. Tobin in defiance of the fact that Silvia Houzouris competently and successfully presented her evidence to the US Border Guards, New York Office of Children and Family Services and Assistant US Attorney Kay (Exhibits 9, 10 & 11), all of whom stated Ms. Houzouris was innocent and the arrest warrant was "unfounded."

Prosecutor Tobin submitted this motion in defiance of the fact that Ms. Houzouris also proved that Attorneys Karas and Donlick willfully submitted motions containing fraud and perjury by Nick Houzouris in Exhibits 1, 5 & 6) and exposed by the remaining Exhibits. ouzouris’ allegations that HH

reports, doctor’s reports and judicial protective orders documenting

Nick Houzouris’ history of abuse (Exhibits 2 – 4), and Judge Carr’s orders are based on the fraud of Attorneys Karas and Donlick and the perjury of their client Nick Houzouris, all of which are detailed in Ms.

brevity of this report, her voluminous motions are on file with the court and appear on the docket.

Exhibit 14 of this report is a Motion to Revoke Bond submitted by Prosecutor Tobin, which Judge Carr approved. Both had received

Both had received an evaluation by Dr. McGraw (Exhibit 21) that found Ms. Houzouris was competent and in good psychological shape fit and caring parent. The motion was issued as a result of Ms. Houzouris’ refusal to succumb to orders for forced psychological interrogation by a "ringer" psychiatrist that worked for the state, and whom Ms. Houzouris correctly predicted would find her incompetent to deny her a trial and any other opportunity to present her exculpatory evidence.

Exhibit 16 of this report is an affidavit from Denise Bruns pointing out the similarities between her case and Ms. Houzouris’ Case, and other victims of the coalition to which they both belong.

Ms. Bruns lost custody of her daughter to her influential husband who has a documented history of abuse – similar to Nick Houzouris (Exhibit 2 - 4). When Ms. Bruns gathered and presented evidence that proved her husband and his influential attorney committed fraud upon the court and perjury in affidavits that contained no first-hand evidence of abduction – as occurred in the present case (Exhibits 5 & 6), the judge in Ms. Bruns case also convened ex-parte hearings when there was no probable cause that an emergency was present or imminent. And, judges issued orders based on affidavits that, on their face, were legally insufficient, and on-their-face contained no first-hand knowledge – just as in this case (Exhibits 5 & 6). Ms. Bruns and Ms. Houzouris were both falsely accused of child abduction in secret hearings that were convened without jurisdiction, under color of law.

But, unlike Ms. Houzouris’ case, when Denise Bruns presented

her prima facia evidence, the criminal charges were dismissed and

despite the fact that she had previously been ordered to have no

contact, whatsoever, with her daughter Ms. Bruns now has joint legal custody, and shared visitation with her daughter, and is seeking a return to her sole custody.

In the present case, Ms Houzouris had sole custody. Her custody was ended via fraudulent and perjured pleadings to the court willfully submitted by her husband, Nick Houzouris, and his lawyers, John Karas and Daniel Donlick ((Exhibit 1, 5 & 6).

Ms. Bruns and Ms. Houzouris contacted the undersigned as members of a national coalition of victims whose children were unlawfully removed via perjured affidavits and motions submitted in secret hearings convened by judges under color of emergency ex-parte hearings in state courts to unlawfully remove custody from the non-abusive parent and unlawfully award custody to the parent with a documented history of abuse - as in both Ms. Houzouris and Ms. Bruns’ cases.

The case docket reflects that Public Defender Greenberg has, to date, failed to submit a Motion to Dismiss that includes (Exhibit 8) the emails Ms. Houzouris sent to Nick Houzouris regarding their vacation arrangements, and the information from the US Customs Border Guards and the New York Office of Children and Family Services Chief Administrative Judge, Steven M. Connolly, that stated on the record that they reviewed her evidence and determined the arrest warrant was "unfounded."

On 8/12/09, letter of Judge Marshall was docketed advising Ms. Houzouris that the court will ignore her motions as she was "represented by public defender Greenberg", in contrast this claim is the fact that Ms. Houzouris fired Public Defender Greenberg. Judge Marshall’s refusal to allow Ms. Houzouris to represent herself is consistent with her claims that the judges are violating her pro se right to defend herself and her defendant’s right to a jury trial and to make defendant’s statements on the record.

The docket reflects Ms. Houzouris submitted a motion to act as a pro se litigant to submit her evidence that she successfully submitted at the Canadian Border (Exhibit 9) and to the New York authorities (Exhibit 10), and to Assistant US Attorney Kay, all of whom determined that Ms. Houzouris was innocent and the arrest warrant "unfounded."

The docket reflects that on 8/18/09 Ms. Houzouris submitted a Motion to Dismiss that contains all of the evidence contained in this report and more. Despite the fact that the state prosecutor Tobin failed to submit an Answer to Ms. Houzouris’ motion, the judge ignored the motion.

The case docket reflects that the Public Defenders Office has not subpoenaed the US Customs Border Guards that spoke on the phone with Judge Carr and informed him that they reviewed the evidence that Ms. Houzouris presented to them and they were releasing her as the evidence proved the arrest warrant was

The case docket reflect that Judge Plitt did not allow Ms. Houzouris sufficient time to submit an answer to counter State Prosecutor Tobin’s motion to have Ms. Houzouris Bond revoked and arrested – and had her arrested (Exhibit 17) for refusing to submit to forced psychiatric interrogation (Exhibit 14).

The undersigned reviewed voice-mail recordings Public Defender Greenberg recorded onto Ms. Houzouris’ telephone answering machine and was very disturbed to find that the messages are bizarre and malicious in nature, as they do not reflect the fact that Ms. Houzouris had fired him (Exhibit 13), which was clearly entered on the case docket. He has refused to present her prima facia exculpatory Ms. Houzouris gave to him for her defense. His messages reveal a bizarre and malicious agenda that ignores that he was fired and alleges Ms. Houzouris is irrational and not competent to stand trial in defiance of the exculpatory evidence that Ms. Houzouris submitted to him and the court (Exhibits of this report) that are being suppressed.

During the period between the arraignment and show-cause

Hearing, Ms. Houzouris again supplied her exculpatory evidence to the complainants, judges, state prosecutor and public defender in the form of a Motion to Void Judgment, a Motion to Dismiss and defendant’s written and oral statements, all of which have been ignored by Judges Marshall, Waldron, Plitt and Carr and suppressed by State Prosecutor Tobin and Public Defender Greenberg in defiance of her defendant’s rights to "any and all evidence proving the defendant’s innocence."

The case docket reveals Ms. Houzouris was arrested based on Prosecutor Tobin’s Motion to Revoke Bond (Exhibit 13) of which Silvia Houzouris was arrested before being allowed required amount of time to submit an Answer. The arrest warrant was issued with full knowledge that the exculpatory evidence proved that Silvia Houzouris was innocent of abducting the minor child are knowingly being suppressed by the Public Defenders Office and Prosecutor’s Office.

Ms. Houzouris was arrested for refusing to succumb to forced KGB-style psychological interrogation. She was arrested when she visited the court to submit a second Motion to Dismiss. The clerk would not let her submit the motion and called security to arrest Ms. Houzouris.

The overwhelming evidence of the case proves that State

Prosecutor Tobin requested that the court order a forced psychological evaluation of Silvia Houzouris in defiance of the fact that Ms. Houzouris had submitted Dr. Patricia McGraw’s report (Exhibit 21) to the court in her "Motion to Void Judgment" and two "Motions to Dismiss" that contain Exhibits that support all of her allegations.

Prosecutor Tobin abandoned and ignored the exculpatory

evidence, and along with Judges Carr, Waldron, Plitt and Marshall ignored the fact that Ms. Houzouris fired Mr. Greenberg for good cause, and that Ms. Houzouris competently and successfully presented her evidence to the US Border Guards, the New York Office of Children and Families and Assistant US Attorney Richard Kay all of whom determined she was innocent and the arrest warrant "unfounded."

Yet, Prosecutor Tobin and Judges Carr, Waldron, Plitt and

Marshall ignored the ample exculpatory evidence and the in-depth psychological report by Dr. Patricia McGraw that praised Ms. Houzouris’ commitment as a parent and documented her psychological good health, and along with Public Defender Greenberg adopted a bizarre and unlawful agenda to question Ms. Houzouris’ competency and ordered Ms. Houzouris to have a forced psychological evaluation without any basis in fact or law.

On Oct. 1, 2009, Ms. Houzouris was in the Harford County detention center. Police brought her to a secret hearing in front of Judge Plitt. She was not previously informed and no one from her family or witnesses was able to attend the secret hearing. Public Defender Greenberg was there, carrying out his collusion with the conspiracy that has suppressed the fact that Ms. Houzouris fired him, suppressed her exculpatory evidence and suppressed the fact that Dr. McGraw determined Ms. Houzouris demonstrated good mental health, and competently presented her exculpatory evidence to three government authorities who determined she wasinnocent. Ms. Houzouris again objected to Greenberg’s presence and claimed he did not represent her as she had fired him for good cause (Exhibit 13).

Houzouris that was issued without allowing Ms. Houzouris an opportunity to prove her competency with prima facia evidence and the corroboration of three government authorities who found her competent and innocent of the criminal charges, in violation of MD Rule 3-104 & 3-105.

Ms. Houzouris was arrested and forcibly interrogated by Dr.

Kim Witczak for only twenty minutes through bars in the county jail – as compared to Dr. McGraw’s evaluation, which took more than twenty hours for her to evaluate and formulate. Dr. Witczak’s diagnosis and report states Ms. Houzouris is "not competent to understand the charges against her" and "a danger to herself and others". Her diagnosis was reached without Dr. Witczak comparing Ms. Houzouris’ claims with the Exhibits of this report or any other real evidence. Dr. Witczak’s diagnosis is not based on, and does not reflect, any of the physical, documentary and testimonial evidence comprising Ms. Houzouris’ exculpatory evidence, and does not reflect any of Dr. McGraw’s determinations.

Ms. Houzouris has been relegated to a state mental Hospital for on indefinite amount of time, while custody of her son has been awarded to Hick Houzouris, who has a documented history of domestic violence and aggravated assault (Exhibits 2-4).

Exhibit 22 of this report contains a Petition to Free Silvia Houzouris with the signatures of eighty-eight (88) "Next Friends of Silvia Houzouris" who have first-hand experience and have reviewed the evidence and have put themselves on the record that Silvia Houzouris is competent, and a good mother that has never hurt anyone and has never broken any laws. The evidence in this case is substantive and proves Ms. Houzouris’ innocence, and is easily understandable even by lay people.

Exhibits 18, 19 & 20 of this report contain letters from the Next Friends of Silvia Houzouris to Dr. Witczak, Public Defender Greenberg and State Prosecutor Tobin requesting that they document any evidence that supports their determination that Ms. Houzouris is "incompetent." To date, none have been able to provide any evidence that supports their determination that Ms. Houzouris is "incompetent".

The minor Houzouris child is in the custody of Nick Houzouris, a man with a history of protective orders issued against him to protect Ms. Houzouris and the minor child from his domestic violence and aggravated assaults. Mr. Houzouris continues to abuse his son by deliberately destroying the child’s relationship with his mother by suborning lawyers and judges to railroad her into jail.

The undersigned investigated the claims of Ms. Silvia Houzouris and the "Next Friends of Silvia Houzouris" as detailed above. In addition to the evidence attached as Exhibits, the undersigned interviewed several of the Next Friends of Silvia Houzouris and Dr. Patricia McGraw.

In Exhibit 2 Ms. Houzouris’ doctor documented "patient is afraid to leave husband. ‘His family has a lot of money and he has threatened to take her son away if she divorced him." Ms. Houzouris’ ‘fear" that she reported to her doctor has come to fruition. And, Mr. Houzouris’ has carried out his threats to "take" their child from Ms. Houzouris.

All of the claims made by Ms. Houzouris are supported by material evidence detailed in Sections II through V above and attached as Exhibits that corroborate that she is innocent of abduction and has, indeed, been unlawfully railroaded into jail. And, custody of her minor son has been awarded to her estranged husband, Nick Houzouris, who has a documented history of abuse and aggravated assault, and it should be noted, just as Ms. Houzouris feared and predicted he would do (See Exhibit 2, Doctor’s report documenting her fear he would "take her child".

Specifically, Ms. Houzouris is a victim of serial domestic violence and aggravated assault by her husband, Nick Houzouris, fraud upon the court and perjury by her husband and his attorneys, and false arrest & incarceration, malicious prosecution, KGB-style forced psychological interrogation and unlawful incarceration in a state mental institution by judges that overtly carry out Nick Houzouris’ agenda/threat to "take" Ms. Houzouris’ son. During this process, Ms. Houzouris’ due process rights were violated, as well as her human and civil rights, pro se rights, rights of a defendant, and right to legal representation, right to a jury trial and her inalienable, natural right to mother her child.

The proof that Ms. Houzouris is rational and competent is

supported by the evidence she gathered (Exhibits), which is prima

facia in nature, not open to interpretation and able to be comprehended by lay people such as the eighty-eight (88) Next Friends of Silvia Houzouris (Exhibit 22).

Ms. Houzouris has been declared "incompetent" and "a threat to herself and others" and barred from representing herself in defiance of the fact that she is perfectly sane. Her sanity has been documented by a twenty-hour evaluation by Dr. Patricia McGraw, and Ms. Houzouris competently and successfully presented her exculpatory evidence to three government authorities, the undersigned and the "Next Friends of Silvia Houzouris" all of whom determined that the evidence she competently presented proves she and her son are victims of a conspiracy to unlawfully incarcerate her to suppress her exculpatory evidence and "take her son".

If Dr. Witczak’s diagnosis that Ms. Houzouris is "incompetent to stand trial" had credibility, it wouldn’t be countered by the first-hand experiences the US Customs Border Guards, the New York Office of Children and Family Services’ Chief Administrative Judge Connolly, Assistant US Attorney Richard Kay, Dr. Patricia McGraw, the undersigned and all of the eighty-eight "Next Friends of Silvia Houzouris" who have placed on the record their determinations that Ms. Houzouris competently presented her evidence to them. The prima facia Exhibits attached to this report reveal that all

of Ms. Houzouris’ claims are based in reality and supported by the Exhibits as follows:

Perjury and Fraud Upon the Court

child to Bulgaria in defiance of the fact that Ms. Houzouris’

passport (Exhibit 7) was not valid and she was unable to travel

to Bulgaria. If she were kidnapping the child to Bulgaria, she

would have simply renewed her passport and booked a flight.

                have her accuser identified, to contest their allegations orallowed to question

                them.  This fact corroborates Ms. Houzouris’ claim that false  arrest warrants were issued in "secret hearings" of which she was not informed or allowed to participate, or contest petitions based on a "third-party" that, as her accuser, she has not been allowed to question. Plaintiff Nick Houzouris’ Emergency Petitions (Exhibits 5 & 6) even by lax legal standards are not legally valid documents but prima facia evidence that the basis of Ms. Houzouris' arrest warrants was fraud upon the court.

Destroying a child’s relationship with either parent is child

Abuse. Considering that the judges carried out Nick

Houzouris’ threat that he would "take away" her son, it is not

unreasonable to assume that Nick Houzouris and/or his

attorneys paid the judges to "get rid of" Ms. Houzouris – and

award custody of her son to him – as part of a human

trafficking for profit scheme (divorce industry) operating under

color of law.