Pleading Papers §¶

📄 Download Full PDF: 11.2.26 Burke Declaration Complete

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11/2/2026 11:01 AM

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SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF SANTA BARBARA

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In re the Coparenting / Custody / Visitation Matter of:

Pleading Papers §¶ — Chris Burke Bio Declaration — 11/02/2026

CHRISTOPHER PATRICK BURKE, SENIOR, Petitioner	CASE NO.: 23-8198 RAPE CHILD ABUSE
v.	UNIFIED DECLARATION AND FORMAL ADMINISTRATIVE COMPLAINT OF FATHER IN SUPPORT OF DEMAND FOR IMMEDIATE WELLNESS CHECK, RESTORATION OF CUSTODY/VISITATION, MANDATORY ADA ACCOMMODATIONS, AND REPORT ON FBI INVESTIGATIONS
COUNTY OF SANTA BARBARA CHILD WELFARE SERVICES, SANTA BARBARA CHILD PROTECTIVE SERVICES (CPS), EMPLOYEES RACHEL, HEATHER, ANGELA, AND ALL INVOLVED STAFF, Respondents	Dept: Dept 6

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I, CHRISTOPHER PATRICK BURKE, SENIOR, declare as follows:

1. I am the Petitioner and Father in the above-captioned matter concerning my minor son, CHRISTOPHER PATRICK BURKE, JUNIOR ("Son" or "Minor Child"). I have personal knowledge of the facts set forth herein, and if called to testify, I will and would competently testify thereto under oath in a court of law.

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BACKGROUND: CHRISTOPHER PATRICK BURKE

• United States amateur surfing champion, pro surfer.
• Co-founder of two iconic surf industry companies from concept to acquisition.
• Co-founder of Surfers for Missions International.
• Certified addiction counselor with over 10,000 supervised counseling hours dedicated to using my past mistakes and active addiction to help heal those who are still suffering.
• Since Christopher was born, I have successfully completed 2 Live Scan fingerprint tests with the Santa Barbara County Sheriff's Department and Juvenile Probation to work alongside them supporting in counseling, and father successfully passed 2 field wellness checks.
• #1 Live Scan background check, successful to work alongside Santa Barbara County Juvenile Probation counseling displaced youth.
• #2 Life Scan fingerprint background check with Santa Barbara County Sheriff's Department to work alongside law enforcement counseling inmates inside county jail.
• The only time I've been arrested was when Christopher's mother lied to the police and to the court, one of which ended up resulting in her getting her children awarded to the state.
• I am a dedicated father who is actively participating in our son's life every day for the past 11 years. Even with the 250 police reports and the violent assault, I still was able to hold a full-time job and show up for my son every day through all of it. To the point where we surfed together, both making the West Coast Championship finals, and Christopher winning the Rincon Classic, being "King of the Con" at age 10.
• The United States of America has been great to me, and I want to be able to pass the freedom and opportunities that it gave me along to my son. It saddens me that these domestic terrorists are tearing apart our freedom and families like they are here in the infiltrated government positions, like Child Protective Services, law enforcement, church leadership, and elementary school teachers, principals, and superintendents.

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OPENING STATEMENT OF ADMINISTRATIVE & CRIMINAL MALFEASANCE BY CWS STAFF

2. This Declaration and Administrative Complaint is filed against the County of Santa Barbara Child Welfare Services (CWS) / Child Protective Services (CPS), and specifically against individual employees Case Worker Heather, Case Worker Rachel, Case Worker Angela, and all involved staff.

3. CWS Case Worker Heather executed unauthorized, illegal "judgment calls" that directly contravened mandatory state child protection laws and enforceable judicial mandates:

a. UPON BEING PRESENTED WITH OVER 250 VERIFIED POLICE & FBI REPORTS documenting systemic abuse, severe violent threats, and physical endangerment inflicted upon the Minor Child by Respondent Mother (Alicia Lin Quinty), Case Worker Heather maliciously refused to open a protective child safety case, making an unlawful "judgment call" to ignore active child abuse.

b. WHEN FATHER DEMANDED STATUTORY PROTECTION FOR HIS SON BASED ON THESE 250+ POLICE REPORTS, Case Worker Heather responded with direct, slanderous, and accusatory hostility, stating to Father: "ARE YOU ABUSING YOUR CHILD?" This weaponized slander was calculated to deflect from CWS's statutory duties and discredit Father's legitimate protective reporting.

c. CASE WORKER HEATHER EXECUTED A SECOND UNLAWFUL "JUDGMENT CALL" BY UNILATERALLY OVERRIDING, SUSPENDING, AND NULLIFYING PRE-EXISTING, BINDING COURT ORDERS granting Father court-ordered supervised visitation. Case Worker Heather decreed that the Minor Child can neither see nor speak with Father, and deliberately concealed Father's whereabouts from the child, severing all parental bonds without judicial authority.

4. Father explicitly asserts that Case Worker Heather, Case Worker Rachel, and Case Worker Angela are functioning as part of a hostile, biased group within Santa Barbara CWS that has systematically harassed, abused, assaulted, and destroyed Father's family unit through color of state law.

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COUNT ONE

UNLAWFUL SCHOOLDAY AMBUSH, COERCIVE FORCE, AND BREACH OF DUE DILIGENCE / WITHHOLDING OF BINDING CO-PARENTING CONTRACT

5. On or about October 5, 2026, Father arrived at his Minor Child's elementary school for scheduled, court-authorized pick-up. Upon arrival, Father was ambushed, surrounded, and confronted by five (5) armed law enforcement officers deployed and directed by CWS personnel.

6. CWS employees and law enforcement improperly enforced a protective restriction against Father without conducting basic due diligence, failing to verify existing court orders, and willfully ignoring and concealing the responding officers' police report and statement to Father: "this is not criminal nor arrestable" — as well as the binding Co-Parenting Contract and Court Order that grants Father joint legal and physical custody.

7. CWS personnel failed to locate or evaluate the terms of the Co-Parenting Contract, as well as the active FBI investigation into over 250 verified police reports concerning Mother (Alicia Lin Quinty).

8. STATUTORY & PENAL CODE VIOLATIONS:

• a. California Penal Code § 148.5 (False Reporting of Criminal Offense)
• b. California Penal Code § 182 (Criminal Conspiracy under Color of Law)
• c. 42 U.S.C. § 1983 (Civil Rights Violations under Color of State Law — Deprivation of Due Process)
• d. Cal. Family Code §§ 3020 & 3040 (Frustration of Frequent and Continuing Contact)

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COUNT TWO

MALICIOUS REFUSAL TO OPEN PROTECTIVE CASE CONCERNING 250+ FBI-VERIFIED POLICE REPORTS; DIRECT SLANDER AND ABANDONMENT OF MANDATED DUTIES

9. Father repeatedly presented physical evidence and formally demanded that CWS open an active child protective investigation regarding Mother concerning over 250 law enforcement reports that are FBI-verified, detailing severe child safety threats, violence, and over 100 documented instances of child abuse.

10. Case Worker Heather, alongside Workers Rachel and Angela, explicitly refused to open a protective case. When Father presented the reports, Case Worker Heather engaged in malicious, accusatory slander, asking Father: "Are you abusing your child?"

11. CWS staff willfully abandoned their statutory duty under the Child Abuse and Neglect Reporting Act (CANRA), abandoning the child to an environment of unmitigated danger and utilizing state power to shield Mother's unlawful conduct.

12. STATUTORY & PENAL CODE VIOLATIONS:

• a. California Penal Code § 11166 et seq. (Child Abuse and Neglect Reporting Act — Breach of Mandated Duty)
• b. California Penal Code § 273a (Willful Cruelty / Endangering Health of Child)
• c. California Penal Code §§ 134 & 135 (Preparing / Suppressing Material Evidence)
• d. California Penal Code § 528.5 / Civil Code § 45 (Defamation, Slander, and Malicious Fabrication)

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COUNT THREE

COERCION OF LAW ENFORCEMENT TO ARREST FATHER DURING SUPERVISED VISITATION; MALICIOUS OPPRESSION UNDER COLOR OF AUTHORITY

13. During court-sanctioned, supervised father-son time conducted inside CWS / Social Services facilities, CWS personnel conspired with law enforcement to arrest Father during child visitation time at CPS and other visiting families.

14. Father was handcuffed and forcibly removed during his designated bonding time. CWS staff subsequently eavesdropped on private communications and weaponized state-induced trauma, using the child's distress — caused entirely by CWS's violent police intervention — as a pretext to indefinitely suspend Father's court-ordered visitation.

15. STATUTORY & PENAL CODE VIOLATIONS:

• a. California Penal Code §§ 236 & 237 (False Imprisonment)
• b. California Penal Code § 149 (Assault / Oppression Under Color of Authority)
• c. California Penal Code § 273a(a) (Inflicting Severe Mental Suffering / Child Endangerment)
• d. California Penal Code § 632 (Eavesdropping on Confidential Communications)

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COUNT FOUR

CWS ENDORSEMENT OF TOTAL COMMUNICATION CUTOFF, SEVERE PARENTAL ALIENATION, AND ENABLING CUSTODIAL INTERFERENCE / KIDNAPPING

16. Mother, with the active cooperation and shielding of CWS personnel, has completely cut off all communication between the Minor Child and Father, systematically liquidating Father's parental role and concealing Father's whereabouts from his son.

17. CWS created and enforced administrative "safety plans" isolating Father, while actively concealing from Father the findings of law enforcement wellness checks and the status of ongoing federal investigations involving Mother.

18. STATUTORY & PENAL CODE VIOLATIONS:

• a. California Penal Code §§ 278 & 278.5 (Deprivation of Custody / Child Abduction)
• b. California Family Code § 3028 (Reimbursement & Restitution for Stolen Parenting Time)
• c. California Penal Code § 182 (Conspiracy to Deprive Parental Rights)

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COUNT FIVE

FAILURE TO REPORT OR ACT ON MOTHER'S THEFT OF SON'S BIRTHDAY PRESENTS

19. CWS and assigned workers (Heather, Rachel, Angela) were fully informed that Mother stole the Minor Child's birthday gifts — specifically $800 in cash and an $800 watch designated for the child's financial security and personal benefit.

20. CWS refused to document, investigate, or assist in recovering these stolen assets, breaching their fiduciary and protective obligations to safeguard the child's assets under the Welfare and Institutions Code.

21. STATUTORY & PENAL CODE VIOLATIONS:

• a. California Penal Code § 487 (Grand Theft)
• b. California Penal Code § 484 (Petty / Grand Larceny)
• c. Cal. Welfare & Institutions Code § 300 (Failure to Protect Child Assets and Welfare)

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COUNT SIX

COMPLETE ABSENCE OF EVIDENCE-BASED RECONCILIATION PRACTICES AND SYSTEMIC PSYCHOLOGICAL HARM TO THE MINOR CHILD

22. CWS has implemented zero evidence-based, trauma-informed reconciliation practices to support the father-son relationship or assist the Minor Child in processing the 100+ instances of violent abuse and trauma documented in the 250+ FBI-verified police reports.

23. SPECIAL INTERROGATORY / INQUIRY TO CWS: What specific, evidence-based practices, clinical protocols, or trauma-informed frameworks is CWS utilizing to provide safe restoration, healing, and emotional stabilization for the Minor Child during this separation as he processes this severe trauma ALONE, deprived of his primary source of paternal support?

24. CWS's failure to employ evidence-based protocols constitutes professional malpractice and direct statutory breach.

25. STATUTORY & CODE VIOLATIONS:

• a. Cal. Welfare & Institutions Code § 16501.1 (Failure to Implement Evidence-Based Family Preservation Protocols)
• b. Professional Conduct and Professional Malpractice Standards in Child Welfare Services

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COUNT SEVEN

FAILURE TO INFORM FATHER OF HEARING FINDINGS (OCTOBER 23, 2026), CUSTODY MODIFICATIONS, ANKLE MONITORING, & VISITATION STATUS

26. Following the Court hearing on Friday, October 23, 2026, CWS failed and refused to update Father regarding the judicial findings, updated custody orders, probation ankle monitoring conditions, and revised visitation parameters.

27. CWS intentionally withheld official court updates, depriving Father of his fundamental procedural due process and statutory access rights as a joint legal custodian.

28. STATUTORY & CONSTITUTIONAL VIOLATIONS:

• a. California Family Code § 3025 (Mandatory Right of Access to Child's Legal & State Records)
• b. Procedural Due Process under the Fourteenth Amendment to the United States Constitution

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COUNT EIGHT

ADMINISTRATIVE FRAUD, PERJURY, AND FALSIFICATION OF CONTACT LOGS

29. Case Worker Heather committed official misconduct and administrative fraud by falsely logging and reporting that she attempted to contact Father to schedule court-ordered visits. Father's official telephone records confirm that ZERO incoming calls or outreach were ever initiated by Case Worker Heather.

30. Case Worker Heather explicitly refused to provide her direct supervisor's contact information upon Father's request, actively obstructing administrative due process and internal oversight.

31. STATUTORY & PENAL CODE VIOLATIONS:

• a. California Penal Code § 134 (Preparing / Presenting False Fraudulent Records)
• b. California Penal Code § 148.5 (False Reporting to Public Officers)
• c. California Government Code Violations (Obstruction of Administrative Oversight)

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MANDATORY DISABILITY ACCOMMODATION (ADA)

FOR SINGLE FATHER IN RECOVERY WITH ADHD & SUD

32. Father is a Christian single father in recovery with verified disabilities of Substance Use Disorder (SUD).

33. Under federal and state disability laws governing public administrative bodies, CWS IS MANDATED TO PROVIDE REASONABLE ACCOMMODATIONS to eliminate hostile environments, worker retaliation, and bias:

• a. Title II of the Americans with Disabilities Act (42 U.S.C. § 12132; 28 C.F.R. § 35.130(b)(7)): Requires reasonable modifications in rules, policies, and practices to ensure equal access and non-discriminatory participation.
• b. Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. § 794): Prohibits federally funded public entities from denying equal access to administrative processes.
• c. California Government Code §§ 11135 & 12926 / Civil Code § 54 et seq.: Guarantees non-discrimination and mandates neutral, accessible meeting formats.

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FORMAL DEMANDS & PRAYER FOR RELIEF

WHEREFORE, Father CHRISTOPHER PATRICK BURKE, SENIOR, respectfully prays for the following court orders and immediate administrative actions:

1. IMMEDIATE INDEPENDENT WELLNESS CHECK: An immediate, independent law enforcement and court-ordered physical and psychological wellness check on Minor Child, CHRISTOPHER PATRICK BURKE, JUNIOR.

2. IMMEDIATE RESTORATION OF VISITATION & CUSTODY: Unobstructed, immediate restoration of Father's court-ordered supervised physical custody and visitation rights pursuant to the binding Co-Parenting Contract and California law.

3. MANDATORY ADA REASONABLE ACCOMMODATION (NEUTRAL LOCATION & ADVOCATE): An order directing that all future CWS administrative meetings, communications, and visits occur at a designated neutral location, attended by a designated third-party advocate to eliminate hostile worker bias and retaliation.

4. MANDATORY DUAL-NOTICE RULE (PUBLIC ATTORNEY DYLAN GONZALEZ, ESQ.): An order requiring CWS to copy and issue all future scheduling notices, communications, and case files equally to Father AND Co-Counsel / Public Attorney Dylan Gonzalez, Esq., to ensure legal accountability.

5. IMMEDIATE REMOVAL OF CASE WORKER HEATHER, RACHELE AND ANGELA: Immediate administrative removal of CPS Workers from this matter due to documented administrative fraud, perjury, and malicious bias.

6. MANDATORY STATUS REPORT ON FBI INVESTIGATIONS & OCTOBER 23, 2026 HEARING: Order CWS to produce all records, disclosures, and status updates concerning:

• a. The active FBI investigation into the 250+ police reports regarding Mother.
• b. The official court findings, ankle monitoring status, and custody updates from the October 23, 2026 hearing.

7. MANDATORY DISCLOSURE OF EVIDENCE-BASED RECONCILIATION PROTOCOLS: Order CWS to formally file with the Court the clinical, evidence-based practices and protocols being used to safeguard and emotionally restore the Minor Child during this period of traumatic separation.

8. FORMAL REFERRAL FOR CRIMINAL PROSECUTION: Formal judicial referral of CWS personnel (Heather, Rachel, Angela) to the District Attorney and Federal Authorities for criminal investigation under Cal. Penal Code §§ 134, 148.5, 149, 236, 273a, 278, and 278.5.

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NOTICE OF PROTECTED CONSTITUTIONAL ACTIVITY

PLEASE TAKE NOTICE THAT THIS FILING CONSTITUTES ABSOLUTELY PROTECTED CONSTITUTIONAL AND STATUTORY ACTIVITY UNDER THE FIRST AMENDMENT TO THE U.S. CONSTITUTION, CALIFORNIA PENAL CODE § 11172(a), AND CALIFORNIA LABOR CODE § 1102.5. ANY ATTEMPT BY ANY PARTY OR AGENCY TO SUPPRESS, RETALIATE AGAINST, OR INTERFERE WITH THIS FILING WILL RESULT IN IMMEDIATE FELONY PROSECUTION UNDER CALIFORNIA PENAL CODE § 136.1 (DISSUADING A WITNESS / VICTIM — PENALTY OF UP TO 4 YEARS IN STATE PRISON).

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EDUCATION CLASS ON TREASONOUS ACTS

The victim, Christopher Patrick Burke Senior, does not appreciate being put in the position of demanding maximum penalties after numerous repeated requests to stop harassing him and his son, to the point of begging the mother, CPS, and the co-conspirators to stop. Because they willfully, maliciously, and arrogantly kept making the father relive a sexual violent episode in front of his minor son, terrorizing them for 10 years straight relentlessly, the maximum sentence of life imprisonment with the enhancement of the death penalty is demanded to protect his minor child and all the other fathers who are being terrorized and whose family lives are being destroyed. These rights are granted by the United States Constitution and rigorously protected by federal penal codes.

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RIGHT TO LIFE

"So God created mankind in his own image, in the image of God created them; male and female he created them." — Genesis 1:27

"We hold these truths to be self-evident, that all men are created equal, that they are endowed by their Creator with certain unalienable Rights, that among these are Life, Liberty and the pursuit of Happiness." — The Declaration of Independence

Applicable Penal Codes:

• 18 U.S.C. § 241 (Conspiracy Against Rights) — penalties include a fine or imprisonment up to 10 years, or up to life imprisonment or the death penalty if death or kidnapping results.
• 18 U.S.C. § 242 (Deprivation of Rights Under Color of Law) — penalties include a fine or imprisonment up to one year, or up to 10 years if bodily injury results, or up to life imprisonment or the death penalty if death outcomes occur.

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RIGHT TO LIBERTY

"It is for freedom that Christ has set us free. Stand firm, then, and do not let yourselves be burdened again by a yoke of slavery." — Galatians 5:1

"Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances." — The First Amendment

Applicable Penal Codes:

• 18 U.S.C. § 242 (Deprivation of Rights Under Color of Law) — penalties scale from fines and up to one year in prison up to life imprisonment or the death penalty depending on the severity of the injury.
• 18 U.S.C. § 245 (Federally Protected Activities) — penalties vary, but can include up to one year in prison for non-violent obstruction and up to death or life imprisonment if death results from the interference.

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PURSUIT OF HAPPINESS

"Everyone will sit under their own vine and under their own fig tree, and no one will make them afraid, for the Lord Almighty has spoken." — Micah 4:4

"...Life, Liberty and the pursuit of Happiness." — The Declaration of Independence

Applicable Penal Codes:

• 18 U.S.C. § 245 (Federally Protected Activities) — penalties scale based on the severity of the interference with federally protected rights.

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DECLARATION

I declare under penalty of perjury under the laws of the State of California and the United States of America that the foregoing is true and correct.

Executed on: November 2, 2026 Petitioner: Christopher Patrick Burke, Senior Location: Santa Barbara County, California

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