The family service plan that CPS employees created were illegal for many reasons. They did not follow protocol and they committed fraud.

1. Per CPS Policy and per state and federal law, CPS:

a. must work WITH parents to create a Family Service Plan, under 6312 Services to the Parent When Family Reunification Is the Permanency Goal

b. They must identify needs substantiated by facts. They are not entitled to create non-existent problems and force parents to do services for false problems. Per CPS Police 5162 "The Proof Required to Support a Court Order for Services:"

The caseworker must draft an affidavit with facts and evidence sufficient to satisfy the court to order the parent to:

  •   participate in services to reduce the effects of abuse or neglect or to reduce the likelihood of future abuse or neglect; or

  •   permit the child and any siblings to receive services.

The affidavit must demonstrate why the parent’s or child’s participation in services is needed in the case.

c. Per 6242.11 "Initial Family Plan of Service" When parents are divorced or live separately, CPS is to create separate Family Service Plans.

d. When it is found that there are errors on the Family Service Plan, the parents have the right to have this plan modified. When parents formally file an objection to the Family Service Plan for invalid "needs" the Court has a duty to review and modify the plan. CPS is supposed to change plans if they need correction.

2. Failure to properly create and enforce Family Service Plans is a violation of due process and it is fraudulent to coerce parents into performing services for unsubstantiated or otherwise fabricated "needs."

When CPS created a Family Service Plan, Kevin and I had been divorced since 2012 and lived in separate towns. Neither of us were invited to work with CPS in the creation of this plan. CPS put both of our names on the first Family Service Plan. CPS did not properly assess needs. CPS entered needs onto this Family Service Plan that were false and completely contradicted what the licensed professionals reported in Psychological Evaluation Reports and on the OSAR (substance abuse) screening.

Kevin and I each were coerced to sign the first Family Service Plan. Like most parents, it's hard to pay attention to what is on the paper when the threat of not getting your child returned to you is at play. After the case was transferred to Lubbock and we were assigned a corrupt caseworker by the name of Karonda Slay, we did a psychological evaluation, an OSAR screening for substance abuse, and we completed 12 hours of parenting class. We also passed all drug tests given to us. It was after we finished doing these things that another meeting was held to create a new family service plan, since they didn't follow protocol on the first one. Rather than correcting false statements that were on the first plan, CPS took things a bit further. Karonda, the caseworker, and Vecelia Mann, her supervisor entered slanderous and false statements on to the revised family service plan. On this new plan, they entered needs that contradicted the Psychological Evaluations and the OSAR drug screening. At this point, they also had my mental health records that I furnished to show them that I did not have any history of psychosis. They had evidence that my medical emergency was not a mental health issue but a medical one. Despite the evidence from my doctor and their own licensed contractors, they purported that I had hallucinations that I took medication for, which was a blatant lie. Kevin's psychological evaluation found absolutely no mental illness and his OSAR screening found no substance abuse issues. There were no needs for them to assess. On Kevin, these women purported that he had alcohol addiction and mental illness, although did not identify what his mental illness was. Kevin does not even like to drink. We did not sign this new revised Family Service Plan and we formally filed a rescission of signature on the first Family Service Plan. We also formally filed objections to the Family Service Plan, with the evidence showing that their purported needs were false, fabricated, and invalid. Per their own policy, CPS is also supposed to provide an affidavit to the court with evidence substantiated the purported needs when they want to Order services. There was no affidavit. Karonda Slay and Vecelia Mann are two very unethical and corrupt individuals. There is no doubt in my mind that there was private dealings in this matter based on their actions alone. They interfered with visits, they overlooked our repeated concerns when we observed signs of abuse in our daughter. The half sister and the woman she's with were constantly intimidating my daughter while we had phone visits, coaching her on what to say and what not to say. We observed our daughter go from a fun loving child to a bundle of nerves in a matter of months. These people stood by and either participated in psychological abuse (and likely more) or they were complicit in it.

3. Another important thing to note is that the stated "Reason for CPS Involvement" on these Family Service Plans contained mostly false information. They took an element of truth and completely twisted the facts and added false occurences that I disproved with direct evidence. Their Reason for Involvement was: "Mental health instability of Tracy contributing to the neglect of the child in her care. Tracy was also positive for amphetamines during the investigation of the case. Tracy placed Lainey in dangerous situations due to Tracy's hallucinations and erratic behavior. Behaviors included breaking out windows to escape the house and the demons that blocked other exits."

My behavior was not erratic. I was having hallucinations from poisoning. I had amphetamines in my system in the hospital, either from something in what was given to me or from my COPD medication. Whatever I was drugged with was not amphetamines alone. I did not neglect my daughter. I was the one who sought help. Now, a key thing to note is that the ONLY behavior they purport is that I broke out windows (notice plural) to escape the house and the demons that blocked other exits. This was a fabrication. The only window broken was a front window that I had to break while law enforcement was there to gain entry into the home because I had locked us out of the house when I took my daughter next door. This is a prime example of how CPS likes to take an element of truth and completely twist it to present a false narrative.