TAIJ GRAHAM LAWSUIT AGAINST CHILDREN AND YOUTH SERVICES

                                    IN THE UNITED STATES DISTRICT COURT
                                         FOR THE DISTRICT OF MARYLAND



TAIJ GRAHAM,
PLAINTIFF
                                                                                 CASE NO.______________________
V.

DAVID C. WRIGHT D/B/A
CSP CAPES INC;
LATRESHA T. CRUZ;
TEAGAN STALLONE;
JEANNE HILL;
TINA LINKOUS;
MICHAEL J.SCIBINICO II ESP;
KIM WAGNE ESQ,
MARYLAND CHILD PROTECTIVE SERVICES,
DEFENDANT'S


                                                 UNDER 42 U.S.C. 1983
                                            _________________________

    COMES NOW, The Plaintiff, Taij Graham, in pro-se, Moves this Honorable Court
to issue an order for Defendant's named in this suit to respond. Plaintiff brings this claim
under 42 u.s.c. 1983, violation of civil rights against the Defendant's in their official
capacity and in their individual capacity. Plaintiff seeks $ 2,000,000.00 million dollars
in punitive damages collectively from the defendant's.Plaintiff seeks a jury trial.


                                                       JURISDICTION
                                          __________________________

  This Court has subject matter Jurisdiction under 18 U.S.C. 1331, as the Defedant's reside
and their offices are in The District of Maryland, and this a Jurisdiction is where the
offenses occurred

                                                               FACTS
                                         ___________________________

1) My claim of 42 u.s.c. 1983 and Racketering has predicated serveral malicious acts done
by the Defendant's collectively and individually which violates my rights under the
United States Constitution and under the Parental Rights and responsibility act by:
    Starting a business in taking illegal custody of Maryland Children, including my own,
using children as a means of profiting for their business, which is R.I.C.O
2)The Defendants illegally took custody of my child.There was no prior consent interview
with my child,which was a clear violation of my Constitutional rights under the 4th & 14th
Amendments of the Constitution.The defendants interview of my child constitutes a "search
and seizure"and was conducted on private property without consent, a warrant, probable
cause,or exigent circumstances.
Doe v. Heck et.al. No. 01-3648 2003 Lexis 744
In Hulman v. Rice (2nd cir 1991)- The mere possibility of danger does not constitute an
emergency or exigent threat that would justify a forced warrantless seizure of a child.
3)Defendant's violated my Constitutional Rights under the U.S Constitution , Amendment
XlV,section 1, by taking custody of my child without due process of law and illegally
detaining my child which violates my sons 8th Amendment rights for cruel and unusual
punishment.
In Quilloin v. Walcott, 434 U.S. 246,255, (1978)
A due process violation occurs when a state required breakup of a natural family is founded
solely on a best interest analysis that is supported by requisite proof of parental unfitness.
4)The Defendant's are placing my child in harmful situations , my Child faces imminent
danger and bodily harm due to the Defendant's facilities with inadequate heating and
cooling, poor sanitation, employees with criminal records, employees including the defen-
dant's are handling my child with drug/alcohol/gambling addictions, my child is being
deprived of inadequate nutrition by the Defendant's also lack of healthcare, education, which
has caused my child to develop mental health problems that my child may never overcome.

                                                         RELIEF
                                      ____________________________
   
     As wherein, Plaintiff respectfully moves this Honorable court to issue an order for the
Defendant's named in this suit to respond, Plaintiff seeks the return of his child into
Plaintiff's custody, Plaintiff seeks $ 2,000,000.00 million dollars in punitive damages
collectively from the defendant's in their official & individual capacity. Plaintiff prays
this Honorable court will grant this suit for relief.

Date: May 26th, 2016


                                            Respectfully,
                                                                  _________________________________

                                                                  Taij Graham
                                                                  825 E. Church ln
                                                                  Philadelphia, PA 19138