AFFIDAVIT

AFFIDAVIT OF ADASHA KNIGHT

CAUSE NO. FC21111111

On October 17, 2007 the Texas Department of Family and Protective Services, Children’s Protective Services (CPS), received a referral of physical abuse of Amanda (newborn) by her mother, Jane Smith. The referral stated Miss Smith and the child tested positive for cocaine at her birth.  The child is currently in Beaumont Regional Hospital, but hospital staff indicated the child is not currently showing any affects from being exposed to the drug in utero.

I contacted Miss Smith who stated she had been experiencing severe depression throughout her pregnancy.  She had been laid off from her job and was evicted from her apartment, causing her to move her entire family in with her Godmother.  Miss Smith stated this was an unplanned pregnancy of which she was embarrassed, as her youngest child is only a year old, and she was unable to adequately provide for them like she needed to. 

On the eve of October 13, 2007, she obtained two small packets of cocaine and snorted the cocaine from Friday evening into the early morning hours of Saturday, October 14^th.  On Sunday she began to feel some pain with pressure.  Although it was not time for her delivery, she realized she was in labor and promptly went to the hospital.  She also realized upon delivery she would be tested and it would be determined that she had been using illegal drugs.  She was aware that CPS would be called.  Miss Smith stated she had not used illegal drugs prior to the 13^th, but that she just wanted the depression to stop.

The alleged father of Amanda (DOB 10-17-2007) is John Jones (DOB 06-01-1992).

The alleged father of Joseph (DOB 07-01-2006) is Joseph James (DOB 07-01-1982).

The father of Kevin (DOB 06-01-1992) is Kevin Johnson (DOB 03-01-1972), believed to be incarcerated in New Orleans, Louisiana. There is a court of continuing jurisdiction.

The father of Brian (DOB 04-01-1990) is Brian Thompson, who is now deceased. There is a court of continuing jurisdiction.

The family has the following CPS history:

06-20-1989 - Unable to determine for medical neglect of Brian, a now adult child of Miss Smith.  Miss Smith participated in Family Based Safety Services (FBSS) from 06-20-1989 until 12-15-1989. 

12-17-2004 - Ruled out for medical neglect of Kevin by Miss Smith. The report alleged that Kevin broke his wrist and the mother didn’t follow up with the orthopedic specialist to ensure proper healing.

07-01-2006 - Reason to believe physical abuse of Joseph by Miss Smith; unable to determine for physical abuse of Kevin and Brian.  Miss Smith tested positive for cocaine at the birth of Joseph.  Miss Smith participated in FBSS until 02/2007, where she completed a drug/alcohol evaluation, participated in outpatient treatment at Beaumont Hospital, and successfully completed parenting classes. 

Due to the physical abuse of Amanda by her mother, Miss Smith, and the alleged risk of neglectful supervision of Brian, Kevin, and Joseph, it is felt that the children would remain at substantial harm should Miss Smith continue to assume sole conservatorship over their care, custody, and control. The Texas Department of Family and Protective Services is requesting to be named Emergency Temporary Managing Conservator of the children in order to provide a safe and stable environment.