The Section 20 Agreement was illegally obtained, in bad faith and through blatant lying and mispresentation. Stating it was for Medical/Health Reasons with respect to Catherine Brice. Moreover, the SW Clara Masenda was clear about my poor English on that moment, but there was no interpreter. Moreover, the LA of Merton breached my children's Human Rights as my older daughter Maija Zargaryan had never been considered as a potential carer for her little sister.    

It is not a legally valid agreement, it does not follow Contract Law. It was not signed by Merton, not witnessed, no  legal advice, no interpreter was provided/presented, it doesn't clarify or specify Merton's obligations with respect to Catherine Brice.   

All the information on the Section 20 is inaccurate. DOB and Names.

It was signed under duress (without informed consent).

I only received a copy of the Section 20 Agreement, despite numerous requests after the Care and Placement Order were issued by the Court. 

I revoked the Section on numerous occasions (via email, texts and orally) the London Borough of Merton blatantly ignored those demands. 

The La of Merton wrote in the Agreement that a "Notice Period" of 48 hours should be given. That is illegal & breach of the Law. 

My daughter was placed in a non-Russian speaking environment and she consequently no longer speaks Russian, which lead to speech delay. She was placed with muslim family, from Pakistan originally, this is to be a serious violation of her Human Rights, not to speak on her heritage and background. A LA has a duty to consider a Child's heritage, culture, language and religion.

When I informed the LA of Merton I was moving to a different Borough, Care proceedings were immediately initiated. That is in gross violation with the "Freedom of Movement" as described in EU Law. 

The LA of Merton frequently mentions my financial position in various documents. It is not a crime to be financially challenged, and it it absolutely not a legal reason to put my daughter for forced adoption.     

My daughter was abused emotionally and physically in care on a regular basis, but the LA would ignore all my complaints & requests to investigate.

For instance, on 23 th March 2011 Catherine become a subject  of car accident when was in a car driven by the contact supervisor Mechel Dixon. The LA of Merton ignored my formal requests re the accident & refused to investigate. (attachment) . Merton refused to provide me any information about the accident, moreover, Catherine wasn't taken to hospital for check.   

On 17 th June 2011 Catherine was taken by her FC to St Helier hospital A & E with HEAD INJURY. My daughter was a subject of Section 20, which doesn't give  parental rights to anybody else, and the duty of the LA is to inform the parent about every single accident re the Child, which the LA didn't. I wasn't informed about the accident nor given explanation about the nature of head injury. 

My daughter was abused physically by other foster kid  at FC's place, as well as by her classmates, she would be brought to contact center with bruises on many occasions (please see the attachment). None of my reports / requests would be considered.   

My daughter was also abused emotionally, on a regular basis,  by being told by SW Ruth Wilkinson that her mother wouldn't love her and she will abandon her shortly, so she will meet new "mummy & daddy soon". 

On 3 th November 2010 rehabilitation plan re Catherine was issued, she was supposed to get reunited with her family by 21 th November 2010. On 4 th November 2010 I received an email from Ruth Wilkinson, who introduced her self as a new SW allocated to our case. Despite the Rehabilitation plan Ruth Wilkinson had referred Catherine to another hospital, the Queen Mary's Hospital for Children to be assessed by Dr Nicolas Silva, Associate Specialist and Medical Adviser to the Adoption and Permanency Panel London Borough of Merton, the member of BAAF (British Association of Fostering and Adoption), which clearly proves that the Merton decided  not to return my daughter to her family, but, instead, to put her out for adoption against my / her sister's wish . Moreover, the LA of Merton didn't inform me about such referral nor asked my consent. 

The  Saint Heliers  Hospital appears to be among the members of the European Organ Transplant Society. 

Jane Farrer, SW for Adoption Agency of Merton, says: "You are a good mother, you have done everything we told you, but life is unfair, and in your case life is very unfair. You need to be realistic: in my practice judge had never made decision against Social Services. You must be prepared to the worse" (attachment..).

The Notice of Final court hearing  in respect of my child clearly reflects / proofs that Merton would not doubt in the outcome, the note states: "You need not attend the hearing". (Attachment).  So the LA & family courts were aware that the court will grant orders in favor of the LA.      

Adoption Panel Meeting - Complete compliance with the requirements of the regulations. 

"A child cannot be put before the adoption panel without parent's consent if the child is not subject to an interim or full care order obtained through the courts. Basically, when a child is subject to s.20 voluntary accommodation - the parent has PR and this is not shared with the LA. So,the LA would have to ask the parent's permission to take any action at all. " 

I highlight that Adoption Agency must not act in breach of European Convention Rights, but, in case of my child, the Adoption Agency of Merton did act this way.

The LA of Merton sent to me the letter from Foster Carer, stating that my daughter was deeply traumatized when she was told about moving to adopters. The LA of Merton inferring that "I was inflicting distress and causing my Daughter to be ill because I was exercising my legal rights in order to ensure the return of Catherine to my care."That argument has no validity whatsoever, on the contrary, Catherine has stated again and again that she wishes to be re-united with her Mother and Sister. I contend that it is the LA of Merton that has caused potentially  irreparable harm and distress to my child.  

Dr Silva reports on 25/02/13:  "Catherine has been smashing things in her room and has been tearful. 

She now knows that she is moving on to adopters and her emotional behaviour has been of some concern. I understand that her mother has been given leave to appeal. If this is going to mean further uncertainty for Catherine then this will need to be supported and some form of emotional support should be considered. I suggest that this is discussed with CAMHS."

So, the LA break up my family, cause unbearable trauma to my daughter, and then put her into Child and Adolescent Mental Health Services, that are supposed to deal those straggling with emotional, behavioural and mental health difficulties.

In the letter related to the Judicial Review  the LA of Merton essentially stays that "even if the Law has been breached, it doesn't matter and it is deemed insignificant." That means,  we the LA of Merton are above the Law, we can conduct ourselves as we wish & please.  Nobody will hold us accountable. However, there is a "Rule of Law" in the UK and even LA have to obey and abide them. 

The London Borough of Merton has a propensity to threaten , intimidate and bully my Family. This has been demonstrated on numerous occasions.

The LA of Merton and CAFCASS falsely and erroneously stated that I have never revoked the Section 20 agreement. Please see the list of instances/examples. 

Giving so much importance/credence to the "Expert Witness" and his mediocre medico-legal report and testimony is a fallacy. 

Additionally, the "Expert Witness" Derek Blincow, appointed by CAFCASS,  was not ordered to assess my self and could not under any circumstances reach those conclusions after a 75 minutes contact between Mother and Child. In addition, giving credence or believing in Attachment Disorders which is a catch-all "diagnosis" of the sort commonly identified with quack practices is a travesty of Justice.  

"The term attachment has no broadly agreed-on or precise meaning. The term is not part of any accepted standard nosology or system for classifying behavioural or mental disorders, such as the Diagnostic and Statistical Manual of Deseases (ICD). Officially, there is no such disorder". 

The LA of Merton has blatantly & willfully disregarded the Law/Statutory Guidelines (PLO) the Human Rights Act and the Equality Act with respect to me and my daughter Catherine Brice as well as her sister Maija Zargarjana. In addition, they have misrepresented material facts to the Courts. 

The LA of Merton acted unlawfully (i.e. "Ultra Vires"), in bad faith with malice & dis-honesty.  

The LA ignored Statutory Guidelines, i.e. The Public Law Outline. The LA violated the Human Rights Act, procedural fairness is something mandated not merely by Article 6 but also by Article 8. Merton engaged in Victimisation/Discrimination as described in the Equality Act of 2010, they also committed serious procedural irregularity, knowingly.  

The LA of Merton committed a crime classified by the Rome Statute as Genocide (Article 6), in point E ( Forcibly transferring children of the group to another group), and "Crime against humanity"(Article 7), in point  D  Deportation or forcible transfer of population, in point I Enforced disappearance of persons; in point K Other inhumane acts of a similar character intentionally causing great suffering, or serious injury to body or to mental or physical health.  as my little daughter become a subject of forced adoption, and her mother and sister are not allowed even to know her whereabouts or whether she is alive, and unbearable suffering for entire family may only be compared with life sentence. Parts E   "Enslavement" means the exercise of any or all of the powers attaching to the right of ownership over a person and includes the exercise of such power in the course of trafficking in persons, in particular women and children" is also about my child's case, as the LA of Merton actually exercised their unlimited power in the course of   "ownership" over my child. And, in addition, there is point I:  "Deportation or forcible transfer of population" means forced displacement of the persons concerned by expulsion or other coercive acts from the area in which they are lawfully present, without grounds permitted under international law".           

The LA & Guardian for my child, June Lewis, appointed by CAFCASS, provided to the Courts two false reports stating that my daughter was a subject of an Interim Order, when my child was only a subject of Section 20. That is serious procedural errors.  

Initially  CAFCASS organisation was developed to protect and safeguard Children involved in Family proceedings.