page 2-3. Krishna reported to staff that her mother had asked her to put on fancy dress clothes and had been fimed on a webcam for friends of her mother. (...)
Krishna probably meant that that I (her mother), took many pictures of Krishna in fancy dress. I have many pics of her that show I used to have many pics of her in fancy dress. Please see photographs as evidence.
page 8. (...) Craig shared some concerns regarding these relationships and suggested that Luci may be prostitutin Krishna. (...)
(CAFCASS 22.10.13 my papers 24) reports:
This is a complete fabrication in order to get back at me.
(Craig) also told CAFCASS that he had lived at his current address (Howard street) for about 7 years, yet this was not the most recent address on the Police National Computer check. )
Craig lied to CAFCASS, as he didn't live in Horward street, but in Wallsend, so he is a lair and so are all the statements he made against me and my children, perhaps the court should do a little more research into his background and it would reveal that he already has a track record of violence as well as Cannabis growing.
( page 10.Craig lives in his firt floor flat in Wallsend where he has resided since 2007 (...)

page 12. Krishna has asked her mother questions about her biological father and it appears that Luci was not honest with her about this and provided a number of possible fathers to her. This will undoubtedly have an impact on Krishna's identity if she is not provided with an honest and age appropriate response.
This is another lie. Krishna knows well that her father is a German, perhaps Caffcass could do some honest research and then they would find out what is and isn't true. Craig told many lies about me, however, I can prove that he was not telling the truth.
page 12. Krishna currently sleeps in the living area of the property along with her mother and sister Kalindi although she does have a bedroomn of her own upstair. During the period when the family had no access to eletricity, heating or hot water the family all slept in the living room together, however despite this now being resolved Krishna has not returned to sleep in her own room. When exploring Krishna's view on this she appeared to accept this and described that she has always done this due to other adults sharing the bedrooms within the property. This must be quite difficult for Krishna who has no privacy of her own or a room for her own personal space.
There was no other adult living there apart from me, everyone, every professional and Alison included knew about it. Krishna has her room and sometimes, she chose to sleep in the living room, as Alison stated here herself.
page 12. He (Mr Flynn, Head of the year at St Thomas More RC Academy) described Krishna as being very intelligent girl.
Then again, how come her solicitor stated that my daughter was not intelligent to know her own mind in the morning, I believe that constituted a willful attempt on behalf of the solicitor to pervert the course of justice, the statement she made was false and will also become of a subject of a complaint to the bar for professional misconduct in court.
page 13. (...) Krishna reported that her mother made her dress up in fancy dress and dance in front of a video camera for her friends.
Here Alison Dodds changed the words of the Gateteshead Children Service, who also got their facts wrong in relation to this as I will endeavour to prove to the court. Krishna doesn't know how to dance and we didn't have a video camera at that time.

Krishna 5

CORE ASSESSMENT RECORD, 11/10/13, by Joana Dean, papers 29
page 10-11. Luci tells me of how she secured a place within a local school that has recently changed to an academy, Kings Priory School. Luci considered this to be a very good school and that she wanted the best for Krishna, Luci stated that Krishna was accepted due to her musical skills and talents. Luci had purchase a uniform and it was agreed that Krishna would attend this school. Krishna then told her mother that she had changed her mind and that did not want to be separated from her friends that were due to start St Thomas Moore after leaving St Cuthberts. Luci agreed to this and when we explored how she managed this as a parent, Luci explained that Krishna is very much 'a free thinker and that given her age she cannot be pushed into doing things that she does not want to do.'
(...) Luci promotes Krishna to do her homework, to study and say her prayers after school. She encourages her to walk to school to get the exercise that she needs. Luci has Krishna's art work displayed within the home and is very proud of her daughter achievements.
Not only does this prove that my daughter is very capable, but that she is also bright enough to pass an entrance exam for a prestigious school, so how come one of the Solicitors working for Social Services stated that my daughter was not emotionally nor mentally capable enough to speak in court. In disallowing my child to speak, when she is capable, it is obvious that North Tyneside Social Services are intent on perverting the course of justice and are also breaching Krishna's rights to express herself in court. This is directly contravening the law and is a breach of the Human Rights Act Which also proves that I listen, care for and respect Krishna's wishes.
Article 6 Right to a fair trial
"1- In the determination of his civil rights and obligations or of any criminal charge against him, everyone is entitled to a fair and public hearing within a reasonable time by an independent and impartial tribunal established by law."
My daughter is fully competent and capable of describing what she believes her needs are, she is intelligent, articulate and has no mental impairment. I firmly believe that my daughter is being denied her right to speak in the family court, not because she is unable in any way, but purely because North Tyneside Social Services can continue in their conspiracy to pervert the course of justice.
It is my belief that any Social Worker who has passed fraudulent and falsified information to the court, needs to repremanded at least. I would remind all concerned, that attempts to pervert the course the justice, through the use of falsified information, slander or libel, is illegal.
Counter Statement

HEALTH VISITOR. 31/10/13, by Joanne Pearson and Debbie Smith, papers 32
page 11. Krishna attends lots of activities in the local community, which includes Kung fu and piano lessons, which her Mum actively encourages.
Child/Young Person's Looked After Review, 28/02/14, by Alison Dodds, papers 33
Contradictory statements
page 10-11. The contract of expectation has remained in place, however concerns still remain regarding Luci's behaviour and her saying inappropriate things to Krishna during contacts. For example she has been heard to tell Krishna to stand up in court and tell the judge she wants to move back to the same placement as kalindi. (...) In January it was also found that Luci had given Krishna a mobile phone in contact, which was recovered in her foster placement the following Monday. Krishna has been adivised about thie conerns around this, and the reasons why she is subsequently not allowed on Facebook, and why any letters or cards she receives from her mother need to be vetted, to ensure there is not harmful or inappropriate messages in them from Luci.
The contract of expectation is null and void and it also decries me my right to speak in my Native language, which I believe to be done with racist intent. I have a full and legal right to speak in Portuguese and this contract violates that right.
I also believe this contract is unreasonable as it attempts to interfere with my right to speak to my child as laid down in Article 8 in the Human Rights Act. Right to privacy. Even prisoners have a right to speak confidentially to their loved one's as do those in mental hospitals. North Tyneside Social Services are once again, using this contract, by way of intimidation, to procure fraudulent evidence and statements made to the court. Since the court has not asked my daughter what we have been talking about, how can it be sure what Mr Robson is writing about here in terms of what has been said? -
This is yet another endeavour to create and permeate lies against me.

your children will be next

Krishna 1-2

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However regard this contract I feel that I need to point it out that my daughter Krishna brought up over the court case about a letter that she has to write for her Guardian. Krishna told me she didn't think the guardian couldn't be trusted enough to pass the letter to the judge. Therefore Krishna said that she would write the letter anyway but wanted to give it to the judge herself. Krishna was wondering why she was not deemed competent by her solicitor. Surely my child Krishna who is a competent 12 years old has a right to ask questions about a court case which directly relate to her personaly in terms of her future.
page 20.
krishna remains in her foster placement with Chris and Debbie Higgins. Krishna is struggling with being in foster care and has expressed that she wishes to return to the care of her mother. (...) Krishna has also recently expressed to Laura Grundy, Children's Guardian that she wishes to move foster placements and she is uncomfortable with having a male presence in the home. She would prefer a single female foster care, also with other young people in the home. Efforts are currently underway to identify such a foster carer through the Fostering Service.
There is no doubt at all that Krishna loves me as a mother, as I love her and that Social Services have endeavoured and continue to endeavour to break that bond, using whatever methods are at their disposal. Whether that is by issuing false statements to the court, or whether it is through the use of intimidating contracts, which they can then use to procure yet more fallacious statements. The truth is that my daughter's wishes are that she return home. Again I reiterate, that apart from the one occasion, where I left Kalindi in the care of Krishna, there have been no other occasions which could even remotely relate to significant harm. I have no mental health problems, I certainly never let Kalindi crawl by a dangerous road, that is a complete fabrication. I have had full access to health services and professionals and I have always looked after the needs of my children. Finally, it is a total lie to say that either Kalindi or Krishna are in any danger from me.
As a mother I have serious concerns about Krishna's foster placement, my daughter has complained to me about the fact that the male foster carer is spending too much time in her room. I believe Krishna's right to privacy is being violated and that she may be subject to risk of significant harm if this placement continues. The State is not protecting my daughter. However, my daughter has not been allowed to speak about her concerns and is silenced by Social Services. I believe this amounts to professional misconduct as Social Services are completely disregarding Krishna's own concerns.
1. INTODUCTION, by Victoria Manser, papers 27 page 8. Krishna has advised that she would like to return to her mother's care, but not to the the current family house, and not while her mother is still 'stressed'. Krishna has also expressed a view that she would like direct contact with her mother, however she is aware that Ms Da Costa has refused this.
This proves that Krishna wants to return to me and would be happy to do so, which is the opposite of what was stated in court, by her solicitor in January 2014. Where Krishna's solicitor made out that my daughter was immature, therefore incapable of expressing an opinion. I believe this was done in order to prevent her from representing herself in court, as Krishna has always known what she wanted and I suspect that causes problems for Social Services, who clearly do not want her to have an opinion.
It is completely untrue to say that I refused"direct" contact with Krishna but how she has become aware of this, is concerning. I I suspect in which case that Social Services informed Krishna this was the case; if so, then that amounts to emotional abuse, because there is no truth in it. However, it would be true to say, that I needed to spend more time with Kalindi, who was breastfeeding at the time. This statement is a totally distorted misrepresentation of events. As are many others.

page 9, 7.4 There are no other family members wishing to be considered as alternate carers of Krishna.
This is lie, I provided a list of 4 friends along with my Cousin for assessment, however Social Services have refused to undertake any assessment or investigate these alternatives. I believe that this is an intention to cover over the truth, as I am sure the solicitor at the time will confirm, as it was he, Mr Assadi from Hindle Campel, who put the names forwards.
page 9, 7.6 Ms Da Costa has advised that she does not feel direct contact between her and Krishna would be in Krishna's best interest at this time, although it is not clear what the reasoning is behind this. Krishna would like direct contact with her mother. Weekdays telephone contact was recomemended between Krishna and her mother, however Ms Da Costa has failed to take this up. Krishna has been having contact via FAcebook with her mother, however given Krishna's age and concerns of what information is being shared on Facebook, this means of communication has now been withdraw from Krishna.
1. The reason for this, as I have endeavoured to explain, is because I needed more contact with Kalindi, because she was still breastfeeding, even though that sadly meant that I had less contact with Krishna. However it is a gross misrepresentation of facts to say that I did not want direct contact with Krishna, of course I did. I had also clearly explained this to Alison Dodds and the health visitors.
2. It is a complete and total lie to say that there was ever any recommendation for me to take telephone contact with Krishna. This is simply not the case. Once again this is misinformation and obviously used with intent to mislead the court.

INTERIM CARE ORDER, 21 november 2013, by Victoria Manser, my papers 28.
D2.Krishna speaks English as her main language but is also able to converse in Portuguese with her mother.
As much as I would like this to be true, Krishna does NOT speak Portuguese, why have they not ask Krishna herself about this, instead of making unfounded allegations, which clearly prove they do not know my daughter.
D2. Krishna is a bright, articulate young woman who is making good progress at school. (...)
Then how come her solicitor stated in court that she was not intelligent enough to know what she wanted? - Once again, major conflicting statements and once again yet more contradiction amongst the professionals, along with the ongoing denial of legal rights.
D2. (...) Krishna does suffer from nightmares and always wakes early. Krishna advises me that ghost are part of the Hare Krishna religion (...)
Interpretively, Ghosts are not part of the Hare Krishna religion and anyone who has any awareness of the Hindu religion knows this to be true, indeed there are holy chants which deal with such things as ghosts, as there are prayers in the Christian religion to help deal with such things, are there not? Perhaps a little research into the Hare Krishna religion itself would not go amiss.
Also, it is not untrue to say, that many children and many adults too suffer from nightmares, sometimes horrible one's. The action needed is to reassure the child, as I have done many times with Krishna, that whilst such dreams can be alarming and distressing, as such, they are unreal and present no danger in the physical world.

D3 There are significant concerns tegarding Krisna's emotional wellbeing and presentation and the impact that her experience have had on her . (...) While Ms Da Costa speaks very positively about Krishna I have no observed any emotional warmth, comfort or affection being displayed from her towards her daughter, of for Krishna to seek this out. On the day the children were placed into foster care, no emotional comfort was displayed by Ms da Costa although this was provided to Kalindi.
Krishna and me have always had a beautiful relationship. On the day Social Services took her, Victoria, (the person who wrote this) was not in the room with us. Therefore she could not and did not see the emotional interaction which took place between me and Krishna. It is completely and totally both unfair and untrue to say this. This is a contrived statement made by someone who was not present in the room we were in, so she could not have known this. To say that I give more emotion to one child than another is grossly misrepresentative of the truth.
D3. Krishna has informed me that she would like to return to her mother's care, however she is aware that this is not possible at this time. Krishna is clear that she would not like to return while her mother remains at the flat in Howard Street, North Shields.
Krishna was concerned about the fact that the door would not lock and that the landlord would not fix it, she was also concerned about that Craig might cause further problems. Therefore she was anxious about returning to the flat. However, since then I have found new accommodation. But since finding that accommodation her solicitor, in order to stop Krishna from making a presentation in court, has said that my daughter is too immature to speak in court. This is a lie and also a contrivance, to prevent my daughter from speaking, probably in order to avoid any embarassment which Krishna could cause in speaking to the court. Again I reiterate the fact, that Krishna a bright and intellectually capable child.
D4. repetition of previous report.
D5. The Local Authority considers the risk to Krishna being at home are too high and not manageable at this time and therefore absolute precedence has been given to Krishna's safety and wellbeing in formulating this Care Plan.
Krishna was removed on 13/11/13. However, I got a new house on 29/11/13. Under the premise of this heading and if the concerns of the authority were based around any risks in the flat where I previously lived with my ex partner, then that situation now no longer exists. Therefore there is no reason, justification or excuse not to return Krishna or Kalindi, in order that they can both live with me, as Krishna wished for herself.
D8. Krishna is of an age of understanding to attend her Looked After Review and her wishes and feelings will be sought. however, Krishna will not form part of the decision making progress.
If Krishna is of an age of understanding, why couldn't she attend the LAR? Why can she not talk and discuss her situation with her mother and others? Is it because North Tyneside Social Services, know full well that Krishna is both competent and intelligent and therefore are afraid of her expressing her viewpoint through her legal right to speak? Which means, in turn that they have to tell lies and engage in defamation of character, in order that she is forbidden to speak to the court.
If this is the case, then in doing this, once again, North Tyneside Social Services, through the use of lies about Krishna's character and ability are endeavouring to deliberately pervert the course of justice.

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