# Opposition Brief — Maurice M. M. v. Bouknight (Nos. 88-6651, 88-1182) > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385012_0551%3A04 ## Record - **Collection:** Supreme Court brief - **Document type:** Opposition Brief - **Published:** January 1, 1989 ## Text EDITOR'S NOTE THE FOLLOWING PAGES WERE POOR HARD COPY AT THE TIME OF FILMING, IF AND WHEN A BETTER COPY CAN BE OBTAINED, A NEW FICHE WILL BE ISSUED, ——— eS Supreme Court, U.S. FILED FEB 17 3989 IN THE JOSEPH F. SPANIOL, UR. CLERK SUPREME COURT OF THE UNITED STATES ‘ OCTOBER TERM, 1988 \V No. 88-1182 8) 668 ‘ BALTIMORE CITY DEPARTMENT OF SOCIAL SERVICES, Petitioner, Vv. JACQUELINE BOUKNIGHT, Respondent. BRIEF IN OPPOSITION TO PETITION FOR WRIT OF CERTIORARI MOTION FOR LEAVE TO PROCEED IN FORMA PAUPERIS The Petitioner, Jacqueline Bouknight, who is indi- gent and who has been found to meet the qualifications for representation by the Office of the Public Defender for the State of Maryland, asks leave to file the attached Brief in Opposition to the Court of Appeals of Maryland without prepayment of costs and to proceed in forma pauperis pursu- ant to Rule 46. The Petitioner's Affidavit in support of this a Petition is attached hereto. IN THE SUPREME COURT OF THE UNITED STATES Be ? afternoon, and she has not appeared. So, I would support the Department's position, and I do have concerns about the whereabouts of this child. | THE COURT: Ms. Parsons, have you shared the information that you have as to the whereabouts of your client with other counsel? MS. PARSONS: Yes, and also with Master Price earlier this afternoon. TEE COURT: You did speak with Miss Bouknight today? MS. PARSONS: Yes. > THE COURT: Are you sure it was Miss_ Bouknight you spoke with? MS. PARSONS: Yes. THE COURT: You have spoken with her on the phone before? You recognize her voice? MS. PARSONS: Yes. I have been on this Case since Pebruary 1987. I have spoken with her a number of times, and I am quite sure it was she with whom I was speaking. Also, as I said, I spoke with her several days ago. She called me. She called me several times and left messages. I got back to her, and we spoke about this. And I had no reason to think and still don't have any reason to believe pare t 1 2 —— there is anything wrong. She didn't seem upset or panicked in any way. It: sounded as if she-were . certainly intending to be here on time. She was very clear that she would be here at one o'clock. THE COURT: She fooled all of us including you, didn't she? MS. PARSONS: Well, I am not so sure. There may be something that happened along the way that may have prevented her from being here. TEE COURT: Like something happening to this child. How long has it been since you've seen the child? , MS. PARSONS: I have not seen the child Since we were last in court. THE COURT: In September of last year. MS. PARSONS: But the individual that I Spoke with said she had seen the child just a few hours ago with the mother. THE COURT: Do you know that person? MS. PARSONS: No. THE COURT: Did you ever meet that individual in person? MS. PARSONS: No. THE COURT: So, you have no way of determining who that. person even is. A- 9012 | 2, . -. Pia MS. PARSONS: Well, I could call the number and ask. I have spoken with hee not once but about four times today. That's the only way of contacting the mother is through this number she gave me of a friend. And I have spoken with the friend at least four times. I have been calling all day. THE COURT: Well, that would indicate to this court that you are as concerned about this child as Ms. Blimline and Ms. Watts. MS. PARSONS: No, Your Honor, I just wanted to be sure that my client appeared and did what she was supposed to so she could continue to have her child in her custody. That is my concern, because obviously, she wants to continue taking care of her child and going to school. THE COURT: What school is she going to? MS. PARSONS: I am not sure. THE COURT: Do you have the name of the school or the type of school? MS. PARSONS: No, I don't, just that she said she was in school. THE COURT: She said she was in school. She is how old? 21 and a half? She will be 22 in June? MS. PARSONS: Right. a-2012 ; 24 25 THE COURT: You don't have any idea what school she is going to. Has anyone else been able to tell you that? MS. PARSONS: No. MS. BLIMLINE: Your Honor, if I could point out too, this mother came through the juvenile system. She has an extensive psychiatric history dating back to the time when she was four years old. I have copies of that. I don't think it is necessary to take up the Court's time to have you read them right now, but she has some serious problems. Also, the mother herself is not hiding from the Department. The social worker saw her yesterday. But she is refusing to divulge the whereabouts of the child to the worker or to the police or to the Homicide detective wno recently became involved. THE COURT: We'll issue -- who issued a warrant for this lady? MS. PARSONS: Master Price did about an hour ago. THE COURT: She submitted that warrant to Judge Mitchell for approval. MR. NEAL: Michael Neal, Juvenile Court Administrator. Judge Mitchell is on jury duty today. RA- 3013 24 25 The warrant is being processed now. [I will be bringing the warrant to you for signature. MS. BLIMLINE: There is also a Missing Persons already out on the baby that nes not produced the baby yet and the shelter care to the Department on the infant. THE COURT: What was the reason that the shelter care was terminated last year? MS. BLIMLINE: The shelter care expired at the time of disposition. TEE COURT: Why was it permitted to expire? That is what I want to know. MS. BLIMLINE: On July 17, 1987, when Master Mitchell ordered shelter care in the home of the mother, the Department opposed that at that time. However, an exception was not filed. I can't explain why it was not. I was not the attorney of record. I have no idea. At the time of disposition, I should point out to the Court that the parties entered into a stipulation for order of protective services as opposed to commitment. So, the parties were in agreement at the time, but keep in mind this is without the benefit of Dr. Eisenberg's psychological evaluation, they were in agreement the child should be hone. A- 3014 The child, in all fairness to the mother, evidently, she has been doing fairly weil up until last month when the child's father was killed. , Evidently, it was a drug killing. -And something has happened to this young mother since that time. People who have seen her think she has not been quite right since the killing. THE COURT: Ms. Watts, do you have anything further you are offering to the Court? MS. WATTS: No, I don't, only I recently have acquired this case. I was not the attorney for the chilc when the case first came in last year. So, I wouldn't know how to answer that. ss MS. BLIMLINE: Your Honor, I would also like to ask the Court that if it is possible, when this lady is picked up, if she is ever picked up by the police, that she receive a psychiatric evaluation to in some way judge her ability to provide care for this child now. THE COURT: Well, Mr. Conti from Medical Services is prsent in the courtroom. MS. PARSONS: Your Honor, we would be opposed to that. Until the mother is located and until there is some evidence, some reason to believe there is something wrong with her or the baby, or AR: 3015 24 25 both, I would oppose any ordering of the psychological or psychiatric. MS. BLIMLINE: Your Honor, I think there is more than enough reason to suspect that something is wrong. She failed to appear today. Ms. Parsons pointed out to her our concern, many people's concern, that the baby is dead. So, I think she has indicated by her failure to appear there is definitely something wrong. Whether that be with the child's health or welfare or whether that be with her own emotional health, I don't know. THE COURT: What is the quickest way we can get ahold of this lady physically? “ MS. BLIMLINE: I would suggest the police send, that you send the police out to see if you can pick her up at the home where Ms. Parsons contacted her earlier this morning. The social worker has an extensive list of addresses for relatives. I think if the police made a concerted effort to seek her out at all those relatives’ homes, I think that would perhaps be a sood idea. I am really concerned about the passage of every day that this child -- I just received this case the day before yesterday. But after speaking with DOr. Eisenberg last night on the phpone, to say lt A- 3016 - a that he was extremely concerned about the child's wellbeing is putting it very, very mildly. I think we need to do whatever Can be done to try to locate the mother and the child. Your Honor, I also have copies of the mecical reports that deal with the child's injuries \ at the time this first came before the Juvenile Court if you would like to see those. THE COURT: Can you highlight those injuries for the Court so that Mr. Conti is aware of them, please? MS. BLIMLINE: I shared these with Mr. Conti earlier yesterday. TSE COURT: Mr. Conti, you are onde a0 all of this? MR. CONTI: Quite aware. THE COURT: Are you aware of Dr. Eisenberg's position dated July 27, that he is concerned about the safety of the child? - MR. CONTI: Yes. . THE COURT: What would your view be of all this, Mr. Conti, based on your knowledge of the ~ circumstances? ~— MR. CONTI: My belief after reading the material is that if this individual is arrested, she RA: 4017 li —— — — -_ =o 7 -- . . . > . . 1 2 a 4 is unquestionably in need of urgent evaluation because of the potential possibility of harming herself. When I learned earlier this afternoon that apparently Master Price issued a warrant -- is that correct? MS. BLIMLINE: Yes, it is. MR. CONTI: -=- I called Baltimore City Jail in fact to be sure she would be handled special if she came in today. I would suggest that if this court takes some other kind of action, that I would leave my private office answering service number so that I may at least be in touch to see that she receives any special handling she misht need after her arrest. I see this as an individual in a crisis Simply from the paperwork. MS. PARSONS: Your Honor, I'd like to underscore he has not met my client. He has information he has only read and what Ms. Blimline has told him. THE COURT: Ms. Parsons, this whole matter cov e cleared up if your client comes in and bs. the baby in. MS. PARSONS: I know. THE COURT: You yourself said that you spoke with her at least four times -- A- 4018 li 24 25 MS. PARSONS: No, with a neighbor, a friend. THE COURT: With a neighbor or a friend, whoever it is, and she allegedly left her residence to come to court. She was to be here at one o'clock. That was two hours and 40 minutes ago. She has not appeared. You yourself told her according to what you told me that there was concern that the baby was dead. Quite frankly, that concerns the daylights out of of this court. The child representative, Ms. Watts, has joined in with the Department of Social Services. Apparently, a decision was made to terminate the foster care relationship even in light of the finding by Dr. Eisenberg that it is not recommended that she regain custody of the child, because it does not appear that she is emotionally capable of providing the protection, nurturance, and ones that wouid be required for the child's safety and security. So, she is in — of intensive and extensive intervention both on emotional and social levels to help her deal constructively with not only her own internal issues but also those requirements for independent and self-sufficient functioning. What that tells me is we have a lady in a severe _ - 9019 RE 24 25 crisis nece. We also possibly have a dead child somewhere which just depresses me to no end, I am not going to kid vee. Since Master Price has recommended the issuance of a warrant, and I have to sign the warrant, I am going to sign the warrant. I'd like to get in touch with somebody in the Police Departmenc to have them go out and take a look into this Situation as rapidly as possible. MS. BLIMEINE: Your donor, we had a Homicide detective downstairs in Juvenile Court. TEE COURT: Is he still there? a MS. BLIMLINE: Detective James Jones. THE COURT: Is he still there? MS. BLIMLINE: He was there when we came up here. In fact, he said he was coming up. THE COURT: Could you bring Detective Jones in here, please? Let me have, if I may, please, Ms. Parsons, the addresses and the phone numbers that you have for Miss Bouknight. MS. PARSONS: The last address I have is 1829 North Washington Street. THE COURT: That's near Pederal, isn't it? MS. PARSONS: Zone 13. R- {020 THE COURT: That's near Federal. Go ahead. MS. BLIMLINE: The social worker who just left would probably have the most p-eordine address. THE COURT: What is the phone number you used to contact the client? MS. PARSONS: The phone number is 327-8873. TEE COURT: And what is the phone number of the person who claimed to be a friend? MS. PARSONS: That's it. The only phone number I have for Jacqueline is the phone number, this phone number which is not hers but is that_of a friend or relative. . THE COURT: Do you know the name of that person? MS. PARSONS: No, I don't. MS. BLIMLINE: Your Honor, if it would be possible too, if the police were sent out, Dr. Eisenberg was concerned that this girl not be treated in any kind of threatening way. He said emotionally, she is functioning at about an eight to ten year old level. So, he feels, especially with the suicide threat she has made, which he thinks we all should take very seriously, he thought the best thing ta do A- 0021 ee —-—- 1 2 r —_ —_ - ——— —— was to deal with her as if she were a ten year old child, a very nonthreatening kind of eggceath.: I don't know what happens when the police go out and pick someone up. But if they could be made aware of, if we ever expect to find out what happened with the child, that we're going to have to treat this lady very gently, I think. THE COURT: I had already come to that conclusion, Ms. Blimline. My problem is, I don't know where she is, and I don't know who is going to come in contact with her first anc what the reaction she is going to have with that individual is going to be. And we are not picking her up for purposes of punishing her. We are picking her up in an attempt to find the child. MS. BLIMLINE: Sut I am not sure she will kow that. Ms. Parsons said the last time she called that number, she did inform her a bench warrant had been issued and the police were going to be looking for her. MS. PARSONS: I did forget to say when I spoke with my client, I explained she hac to be here. And she said, “Well, if I come, they just want me to come so they can snatch the child." I said, “Well, there is no guarantee A- jo2z2% ' rer ere. § & — N ~ they are net going to remove the child from your ones if you come to court with the child." I said, “But they want to see the child, and they have an even bigger concern that there is something wrong with the child and that the child could be dead." And she said, "Oh, no." And I said, "Well, we can clear it up by just bringing the child in." So, that was the conversation. She appeared absolutely horrified when I said that. MS. BLIMLINE: Of course, she was aware already that was what we were suspecting, because the social worker had contact with her as I explained to you. -- MS. PARSONS: I think she may be, if she is deliberately staying away, it is probabiy because she doesn't want to lose the child. She is afraid, and, of course, that is what is going a» henmen if she brings the child. The child will be removed. THE COURT: What this court has to look at is what is in the best interest of this child. And quite frankly, that child is paramount on this court's mind. That child was born on October 3, 1986 which means the child is about 18 months old now, and the child is a baby. Based on all the information before the Court, it is obvious the child is in some A- 9023 ea. $- 3 _—- angel toes. _ a . . . 4 Ma . - i i eet i ee ey ol ee -é > atin 5 --~ _- , my e ‘ 7 . 1 Watts, has joined in with the Department of Social ; 1 eopardy because of the actions of the mother in : es | | inate 2 Services, and in balancing the obligation of the ’ 2 refusing to bring her in. The'very fact she. has. “ . 3 Court to look out for the best interest of the child, 3 failed to come today tells me after you told her the . - 4 I am persuaded the Court's action is appropriate at 4 reason for coming, that something is seriously wrong. ; 4 5 this time. " S| And I can't shake that from my mind. | . 4 6 I obviously am not going to make a finding 6 MS. BLIMLINE: The social wowrker also | 7 of a contempt. I am going to issue a contempt 7 attempted to get in touch with medical clinics around Sn - “. d 8 citation against her for failing to appear.- She knew 8 the city to see if she has been bringing the child in 7 “ od =“ 9 she was to be here today. She failed to appear. So, 9 for any kind of medical care, and he has not been f : 10 she will be cited for contempt. 10 able to locate one where the child has been seen. 11 I will issue the Order to Show Cause. The ll THE COURT: Well, the motion to cite Miss ; ee 12 pench warrant will be signed by me as soon as.-it is 12 Jacquline Bouknight for contempt is granted. . 13 presented to me. And I would like to have the-. 13 MS. PARSONS: Your Honor, I am sorry to -~ 14 detectives go out and try to pick her up in as 14 interrupt, but I will oppose that on the basis that . 15 unobtrusive a fashion as possible, keeping in mind 15 the mother has not been served, and we had not been 16 that we have to find the child. 16 given notice, neither she nor I. I just received the ’ 17 If she fails to produce the child, then I 17 motion this morning but certainly have not had a , 18 will order her held without bail in Baltimore City 18 reasonable time to prepare a defense. And the rules 19 Jail until ™ 6 QO ow oer 1 2 I, Carol J. Robinson, an Official Court Reporter of the Circuit Court of Baltimore City, do hereby certify that I stenographically recorded the proceedings in the mattter of IN THE MATTER OF MAURICE M_ —w, in the Circuit Court for Baltimore City, Division for Juvenile Causes, Petition No. 88704202, before the Honorable EDWARD J. ANGELETTI, Judge, on April 20, 1988. I further certify that the page numbers 2 through 28 constitute the official transcript . the proceedings as transcribed by me from my stenographic notes to the within typewritten matter in a complete and accurate manner. In Witness Whereof, I have affixed my sisnature -—- this 19th day of May, 1988. rol J. Robinson Cfficial Court Reporter = _ “ie Man's X 7 For Period Prom:_ August 16, 1987 “Fo Pete 2s¥ S998) Date: “#7 13, 1988: to Mey 5, 1988 Maurice L. M way 18-87 vs Name) B03) (Doaxet No.) Court Urder) Type of Court Orders Order of Protective Suervis ion WOTEER; Jacqueline L. Boudoighe et - »- - ADDRESS; 1726 5. Street ADDRESS: (deceased as of 3/11/88) : y NO ee, TELEPHONE BO.: SELEPHOHE WO. : Child Protective Service investigscion initiated on 1/23/87 substareiared 1. yt yt pe physical abuse and neglect. Meurice had suffered severe physical injuries when — while in che care of his avther. én Maurice was placed in Foster Care from 2/10/87 uneil 7/17/87. Maurice wes > ae ae. ordered returned to the care of his mother by the Court oi 7/17/87. S- School progress = grade, | : — “type of ad— justment. ‘ NOT aPPLICULE . 6. Deseription of contacts - a — og ee SEE ATTACHED CONTACT EES. Te. Service plan for -child child's parents. [1 supporting (3 tot supper: ——ADDEFE Status _ C2 Eligible C5 tneligibie Fe Ctker problems and/ar 4 Agency contacts since went ani in- further needs). On 8/30/87, Maurice was seen at Prancis Scott Key Buergency Room due to a high temperature. Prescription given. Mother filled prescription on 8/31/87 with assistance of Foster Care worker. No loxam subsequent eedical acocintmencs. ; ®- 9030 . = “a @ + . SO EE ee —— - 9/1/87 9/4/87 : _>_ eee . aie nine eee LEER igtiny: «tinea DSS Contacts 8/18/87 througs-5/3/88- Disposition Hearing; Crild to remain with aocher; Order of Procective Supervision; Intake CPS Worker obtains signed consent from Ms. Bouknighr co obtain written copy of the Psychologist's report; Family and Crildren's therapist hed s copy but could not give such to the Department on S-i8-87. Foster Care Worker to Lill con, Income Maintenence. Ghee needs 6 ua catatshen chan Dest CHUL es Ten, te, Stated aan age antatving A00C.” Foster Care Worker T/C from Mrs. Dixon, In-home Aide. Jackie Boukxight is noc receiving AFDC yet; In-home Aide 4.V. Sev mother and child. Foster Care Worker - Client requested Similac with Iron formule axi diapers Maurice 104° temperature and she took him to the doctor. ye ee php a ony Clienc requested a new MA card for Meurice; Foster Care Worker and referral co Emergency Services. Took Ms. Bouknight co 1500 Greemmoue - Foster Care Worker T/C to WIC. WIC requested a letter saying thet client applied © for Emergency Food Assistance, give client some tokens, have her get a lecter from the people she is staying with stating that they are providing housing and some food and have her bring these letters to the WIC office Wednesday corning on Eastern Averum. Took Mocher and child to Sears for clothing. CPS Worker Appointmene letter sent to Ms. Boulcright at 1726 N. Washingron Streec. Foster Care Worker T/C fron J. - Ms. Bouknight said she never came to pick up che forms WIC and tokens because it was too hoc. She wanced m cé mail it to her. Mrs. Dixon, In-home Aide, comes every Tuesday morming from 8230-11230; to and H.V. with and Maurice; Meurice appeared well-fed with - Service agreemert discussed and signed by Ms. GS Worker H.V. to Ms. good affect ax outright | In-home Aide - H.V. Sew mother and child. In-home Aide - H.V. with mother. Child noc there. In-home Aide = H.V.; Sev mother who said not needed today. - - F.C. Worker from cliere and H.V. Ms. Bouloright called and said she hed a requested a home visit. said she knew she hed to aove in November but she will be aoving codazy as socom as she gets her check. I told her I would be closing her case and thec she hes a P.S. worker but cher I would com au. When I arrived, I wes told that her grandfather hed. juse caleen her over to Apple's houses-_ He said thet he.doss.nce like ths psople-she-essociates with amd chet one of them stole bis T.V. Greandfacher’s come is Join Bram. A- 032 ° ° CEs 2 PORMECET, Jacqueline 11/10/87 In-home Aide - unable to keep scheduled home visic with client. 1/17/87 In-home Aide - Attempted H.V. — no one responded. 11/24/87 In-home Aide = Attempted 1.V. — no one responded. L/25/87 CPS Worker - Acterpted H.V. — no one responded. oe a 12/1/87 CPS Worker ~ Sent appointment, lecter to schedule H.V. on 12/7/87. 12/7/87 Attempted T/C Contact. CPS Worker uneble to keep appoincment due to emergency - in aother case. a. 12/7/87 CPS worker - T/C contact with F.C. Worker; client reportedly hes moved. 12/8/87 In-home Aide — Home Visit with mother; child was noe there. Client stated she had moved to another residence ari would call. Plamed to go shopping next week. 12/10/87 In-home Aide = T/C - child answered the phone and said Ms. Bouotight had just lefe. 12/14/87 In-home Aide - T/C with Ms. The Aide wanted to schedule a home visit for 12/15/87. Ms. Boulcright declined saying she wes plarming to see Meurice’s father. Se ee nae es Se nea Sh. SRPNEGS aes Und CEES GAS CRED Sep eee Oo Wetlg Gs Gites. 12/18/87 In-home Aide T/C with Ms. Brown. Was cold Ms. Boukrighe did noc Live there anyoore. s * 3/22/88 Informed by D.S.S./P.S. worker, Angela Collins (paternal relative) thec Terrance Miles, father, has been shoc to death on 3/11/88 ac Washington and Lamale Streets. Both parents alleged co be drug abusers. Ms. Boulcright reported to be wandering about in a daze since the death of Mr. Miles. All addicional contacts were by CPS Worker. #12/23/87 Attempted H/V by CPS Worker - no response. . 2/5/88 Master File Clearance - attempt to locate new address. Old address still listed. , ae Ct) lake A- 9033 4 3/23/88: 3/23/88: 3/23/88: 3/23/88: * 3/23/88: 3/23/88: 3/23/88; 3/23/88: 3/23/88: 3/31/88: 4/7/88: ROUIWICET, Jacquel ion , PACE | Emergency HV to Ms. Jacqueline Bouknight at 9 2.2. Ms. Bouknight not home. Worker spoke to former foster father of Ms. Bouknight, Mr. John Brown to and from hospical. T/C €e Elle Smith of Medical Records of Francis Sco: Key Hospital; last appointment for Maurice 5/22/87, check-up, no concerns noted. Appointment scheduled 9/9/87, no show. - T/C co U of Md. Hospital Infant Study Progra, Director, Ms. Gundy (328-6975 or 828-2485 and 828-2 T/C to Ms. Barbara McGhee, Intake Specialist, U ef Md. Infant Study Program (328-2485) T/C co Ms. Rose Blum, Secretary, Family & Children’ Society; no recent contact by Ms. Bouknight. Counselom, Leslie Morris and Carol Hubbard have lef Case closed on 7/31/87. AMF clearance on Ms. Bouknight; current address for AFDC grant - 1726 HN. Washington Street. AMP clearance on paternal grandmother, Ms. Florence mo current 30 case. AMF clearance on Terrance M. Miles; last home addre 2250 Gable Avenue, $54214-76-8970, food stamp case . 30-635 304, case closed 11/1/87. T/C co Ms. Jacqueline Bouknight (327-8873); no ensw 4/7/88: 4/7/88: 4/7/88: 4/7/88: 6/7/88: 4/7/88: 4/7/88: 4/7/88: 4/7/88: 4/7/88: 4/7/88: 4/7/68: 4/7/88: 4/8/88: . . pt ze - b to Ms. Edna Gardner of Chesapeake Health Pla: at the FSKH; last sppointment by Maurice, 5/22/8: appointment scheduled in September, tio show. . Unsnnounced HV to former address of Terrence Mil« at 1623 N. Durham Street; message left; no one he T/C to Parent Aide Supervisor, Ms. Gloria Dixon (X2076) to forward parent aide report Attempted t/c to Parent Aide,Joanne Dix (X2075); message left. Attempted t/e to Dr. Timethy Deran (550-0967) Attempted t/c to Dr. Sceven Cohen (955-6070) t/e to Dr. Patricia Shearer of JHH (342. T/C to JHB Social Worker, Rose Cariddi (955-8103) last contact with Maurice in 4/87. = T/C to Ms. Florence Dean (675-2683); last saw Maw in 9/87. Ser son, Terrance Miles, was in North Carolina. Ms. Dean confirmed thar her son, Terra Miles, was shot to death on 3/11/88. T/C to Parent Aide Supervisor, Gloria Dixon; 4/8/88: 4/8/88: 4/8/68: 4/8/88: 4/8/88: 4/8/88: 4/8/88: 4/11/88: 4/12/88: 4/12/88: . 4/12/88: 4/12/88: 4/12/88: 4/14/88: _ BOUOMLCET, Jacqueline | PASE WY to Ms. Lillie Mae Bouknight at 5116 Avenue; message left regarding worker's concern about Mseurice. Attempted HV to Andrea Miles at 1450 Montpelier Street (243-8934); no answer; no doorbell or asil bx T/C to Ms. Florence Dean at 675-2683 and 522.2100; Be new information Maurice. = Mr. Charles Bouknight; worker spoke toe a Mr. Lee. Attempted HV to Ms. Geneva McNeil at 1615 Biddle St: (243-8934); no answer. Attempted EV to last AMF address for Mr. Miles ~ 2250 Gable Avenue; no such address. Bouknight with- her (327-8873). T/C to Ms. Bouknight; would not schedule time wher worker could see Maurice. At 4 p.m., worker advised by PS Supervisor, James i .- to file missing person's report with police. Missing person's report or police report filed with Officer Charles Klein of Eastern District (396-2433) at 4:30 p.m. at 312 E. Oliver Street. Officer to go directly to Ms. Bouknight’s address at 1726 BN. Washington Street. T/C to Ms. Lillie Mae » Paternal grandmothe 5116 Queensberry Avenue (466-4904); Ms. Lillie Mac Bouknight saw Maurice once in 10/86; has had no contect with Ms. Jacqueline Bouknight. Ne relative in T/C te Mr. Charles Boukmight at Traveler's Aid —~—" 4/12/88: 4/13/88: 4/13/88: 4/13/88; 4/14/88: 4/15/88: 4/15/88; 4/15/88: 4/15/88: 4/15/88; 4/17/88: 4/18/88: in the evening when the vorker coul see T/C te Officer Charles Klein at 396-2433; OV wich PS Unit Chief, Leslie Ogungbemi; vorker directed to contact SAO. Letter to IM worker to suspend grant. Letter to Ms. Bouknighe iaformin of actions taken. . : T/C from Officer Klein , ‘wefer case to Homicide to Sgt. Landsmann.(396~-272: Perry had never seen the baby. Case looks kinky. Officer thinks Ms. Bouknight 4: something that has hurt Maurice. . BOUKNICET, Jacqueline Pas , ica | 4/19/88: T/C to Mr. Charles Bouknight, Sr.; M-3, West 4/18/88. saagt, this worker surprised Ms. Jacqueline Boukni, . ° mot discuss Maurice with worker. Stated he did Coming inte the home. Ms. Bouknight was in the | mot have Maurice. Company of a man. Stated she vas emroute to pick 4/19/88: T/C te Charles Bouknight,Jx. (685-3569); had noc oP Meurice and to take him to Francis Scott Key ¢)_ seen child in a long tine. Ms. Bouknight did nce to be seen by Dr. Doran and that she would recorn mention child. Mr. Bouknight believed Ms. Bouknig¢ with Maurice at 4:30 p.m. on 4/18/88 to mot capable of caring for child. 1726 NH. Washington Sereet, for the worker to seq 4/19/88: T/C co Det. James Jones and OV by Det. Jones | Maurice. Ms. Bouknight informed of the 4/21/33 1; 4/19/88: T/C to Chorles Bouknight; address ef his -facher ‘en court _ ; »+t @ Thomasina in North Carolina given to worker. 4/18/88: T/C te Sgt. Stine of the Youth Division; Sgt. Sein, Mr. Bouknight requested that these relatives not to have police officer meet worker at BN. Wash: - be contacted until after the 4/20/88 court hearing at 4:30 p.2. A Worker stated urgent necessity of safeguarding chi 4/18/88: Worker flagged Baltinore City Police Officer Opher, and indicated that they would be contacted imeediz: ef the Zastern District. Worker and Police Woman 4/20/88: T/C to Mr. Charles Bouknight (803) 796-2538 st 11:: went ta 1726 N. Washington Street. Only Mr. Brown and 12 noon; no answer. at home. Mr. Brown stated that Ms. Bouknight but 4/20/88: T/C to a Thomasina (803)799-$567; a man named not Msurice had slept at 1726 4B. Washington Street John B. answered; not a relative; didn't know anyt! om the might of 4/17/88, but the person, Thomasina did live at that address. 4/16/88: Alert subsitted to Henry Hunt of Foster Care Intake 4/20/88: T/C to Parent Aide Supervisor, Gloria Dixon; messa; end to Screening. left. 4/18/88: AMP clearance for Valerie Miles; no active case. 4/19/88: Unannounced HV to Leslie Miles, paternal sunt, et 4/18/88: T/C co Sgt. Seine of Youth Divisen (396=2042); case | 913 E. 30th Screet; last saw Maurice at the 2000 bt! assigned te Det. Jones. | of Oliver and Gay Streets, in aid February, 1988. 4/18/88: T/C to Charles Bouknight (685-3569) at 104.2. " 4/20/88: Telegram sent to Thomasins Bouknight, regarding Mr. Bouknight to call worker at 1 p.a./ whereabouts of Maurice Miles. No personal delivery _ 4/18/88: Worker waited between 1 and 2 p.m. for_phone call f. of telegrams for West Columbia or Charles Boukni ght : Mr. Charles Bouknight; no call. Operator #636. - 4/18/88: Attempted t/e to Andrea Miles, paternal aunt, who 4/20/88: Emergency court review hearing. Shelter care of contacted DSS Supervisor, Merle Smith; who indicat« Maurice granted to DSS by Master Tesette Price. she had not seen Maurice. Present - DSS Attorney, Marilyn Blimline; child's 4/18/88: T/C to Det. James Jones; nothing new on case. Work: attorney, Lisa Watts, Legal Aid attorney for Mauric suggested photograph of mother end to accompany end Robin Parsons, OPD for Ms. Bouknight. Also Det. Jenes. rn Jones Stated he would rely on : wee Jones of the Youth Division, cooperation Ms. Bouknight. Worker emphasized the ° possibility of this being a murder case. 4/20/88: Motion fer contempt and petition for the issuance 4/19/88: 9 a.m. effice visic by Ms. Bouknight. Ms. Bouknighrt Suan — ye he ay a questioned this worker Tegarding court hearing for Lisa Watts, Robin’ Parsons, and this worker. 4/20/88. “Aare geing to snatch wy child?” Det. Sunes eae present although informed of court Worker replied that it was up to court. Ms. Boukni,! hearing. a oa all I wanted to know.” Ms. Bouknt ° = lefe ice. She then returned asking for token: Edvard Angeletti (396-30 ssued to ge te school. In the waiting room Ms. Bouknight yy Cause —_ - sean Seem ¢ stated, “I'm going to kill myself. Are you going answer to the court . 1510 Guilford Avenue Department cf Social Services of Baltizore, Maryland 212 Baltimore City Legal Services Division 9048 1510 Guilford Avenue Saltimore, Maryland 21202 7 ’ — ‘elephone: pekon é? , Pw ' ee — ‘ ~ te . - . . 7 - a wos Telephone: 361-2443 ee ‘ --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385012_0551%3A04. Public record. Not legal advice.