CAUSE NO. ____________________
I
AFFIDAVIT IN SUPPORT OF TEMPORARY RESTRAINING ORDER
BEFORE ME, the undersigned authority, on this day personally appeared Brandy Pfluger, and being by me first duly sworn, did under oath depose and state the following:
“My name is Brandy Pfluger. I am the Petitioner and Movant in this cause. I am the mother of the children the subject of this suit. I have personal knowledge of the facts and matters set forth in this Affidavit and those facts and matters are true and correct.
“My name is Brandy Routh. I am over the age of 18 and of sound mind and capable of making this affidavit. I am the mother of Emma in this interest in this cause no 349-6634. The facts and allegations stated in this affidavit are within my personal knowledge and are true and correct.
“The department received an intake alleging physical neglect and medical neglect of Emma Mae Routh age 5. I was contacted by Jackie Geer on Friday October 15 at about 10am Eastern Standard Time. I was made aware she wanted me to place all three of my children Emma Routh, David Carroll, John Routh in placement out of my care. I asked her why she said she would tell me when I came home from Boston. She made me aware that I had until 5pm central time to place my children. I called Ms Geer and other case workers many times with people to place all three kids together but I did not get a response. About 6pm Eastern Time when Ms Geer called and told me Emma was awarded to the state of Texas.
Some time before my child was taken the medical team at Boston Children’s Hospital had asked me to return to Boston for Emma’s bone marrow bio. I was to arrange travel as soon as possible. At that time I expressed concern about travel because Emma had just got out of the hospital and had endured 2 months of trouble. I requested Dallas Children’s Hospital to do the bio and to send the samples to Boston. I was told because of the medical study I would have to travel for Emma’s bone marrow bio and that Boston Children’s Hospital would pay for the cost of travel.
On October 1 2010 I was contacted by Susan Robinson, Hematologist social worker at Boston Children’s Hospital. I expressed my concerns to her about Emma having to travel to Boston. We talked over hydration and whether I could take Emma’s fluid on a plane for the 2 nights we would be in Boston. She told me she would call me Monday October 4 after she talked over my concerns with Doctor Raffaele Renella and David Williams. She assured me that everything would be fine that I was coming to a hospital and to take a deep breath and trust the team.
Over the weekend I thought more about it and I was worried about Emma. Susan Robinson called me back early on Monday October 4 and said she talked to the doctors and arranged for Emma to get to Boston on Thursday October 7 and for fluid to be given at the hospital on Friday October 8 the morning before the procedure. She told me that Emma would more than likely get admitted Friday night October 8 for additional fluid. She told me that the team would make sure Emma would be ok.
She informed me that the airlines would not allow me to bring the bags of fluid on the airplane. The instructions from the doctors were that Emma would be NPO after 10 pm on Thursday October 7 so no NG feeds till after BIO on Friday October 8. I agreed and she said she would send me the travel information by email.
On Tuesday October 5 Susan Robinson called me to talk about travel from the airport to Ronald McDonald house in Boston. We agreed that I would pay a cab and the hospital would pay me back. Susan Robinson said she would check in with me Wednesday October 6 to make sure everything was good and we were going to be on the plane Thursday morning.
We left for the airport at 2am for 2 flights to get to Boston. The flight was delayed. The flight from Washington arrived in Boston a little after 1pm. I went directly to the Ronald McDonald house and called Susan Robinson to let her know we made it and to tell her about Emma getting sick on the plane due to motion sickness. I told Susan that during the flight I continually offered Emma ginger ale to calm her stomach and to hydrate her. However, Emma refused as she was afraid that she would throw up her NG tube.
I asked Susan if we could come in to clinic for fluid she said the medical team had it in the schedule for 7am tomorrow October 8. I told her ok if she was sure, I would go to get Emma some lunch and try to encourage Emma to take food and drink by mouth. I got Emma in the stroller and took the nice walk to the store 3 blocks from the house. She picked all of her favorite Boston foods that she has missed in Texas. On the way back to the Ronald McDonald house she snacked on baby-bel cheese. When I got to the house I cooked Emma lunch at her request. I am so proud of Emma she is getting so big she made herself a cup of juice.
When we sat down to eat she ate very well of her rice and orange chicken. Then we cleaned up our mess and talked about what she wanted to do for dinner. She told me she wanted to order food from New China special rice and crab. So I did so. While we waited on our dinner we watched a movie and Emma took care of her zoo world on the computer. When dinner came she had 2 helpings of rice 2 crabs Rangoon which she only eats the middle and one helping of chicken from moo goo gai pan with a glass of tea. We had a good time and watched home on the range with our dinner after the movie Emma got a bath and then had a bedtime snack of a peeled apple cut in to 8 small pieces Emma ate 6 of the 8 and discarded the other in trash. We laid down about 9pm and Emma went to bed. From the time of our arrival, I continually offered Emma liquids and she ended up drinking 3 good size glasses of fluid.
On October 8 we were in the hospital as planed at 7am they hooked Emma up to fluid that was laid out already. After that they did 4 labs “2 large 1 medium 1 small top” and had me sign for the bio for her to be sedated and the procedure. Everyone kept telling me how good she looked, then we watched a movie though the 3 hours of pre bio stuff. Right before the Bio they came and took 3 more labs “1 large 1 medium 2 small top” before the bio they talked to me about other studies and wanted me to sign so I did. They took an extra table spoon of marrow. They told me that the total would be 3 table spoons. I asked is that ok or is that going to be too much for Emma to handle. They said the team was going to talk it over and they wanted her to come in for fluids and not miss Friday night’s fluids. I had no problem with that and felt relieved. After the bone marrow bio they came and needed more labs 3 more “1 medium 2 small tops” then we were discharged and told to be at the clinic at 11:30am.
At the clinic I talked about Emma growing almost 4 inches and agreed to admit her for fluid and thanked them because I was really worried about it. They sent me through the ER where they wanted to redo all Emma’s labs I told them no that they were already in the computer. I did let them do 2 blood cultures standard for someone like Emma being admitted. Then we went to 6 north for the night and planned to leave the next morning.
The next day Emma was bouncing off the walls, she felt so good. Our friend from Boston came by and was playing with Emma. The doctor came in and told me we could not leave because 1 blood culture grew back. I made plans to stay a few days till they got things worked out for transfer to Dallas. I was concerned because Emma had 1 blood culture positive but had 2 blood cultures taken the day before. I thought this could be a mistake, both should have been positive, but I went with what the doctors said.
For the next few days Emma was happy and healthy her doctor on the floor told us 2 more days of blood cultures had come back positive, so I signed to take Emma central line out. Through the weekend Emma and I had a good time keeping her sprits high making fun of one of the doctors saying it is not hot in Texas. Emma would tell her I can cook an egg outside and would just laugh. Boston Children’s took Emma central line out late Sunday October 10. On Monday October 11 Emma hardly ate or drink anything and would not get out of bed she could not even sit up on her own without hurting. I would not let her see me cry for her because she gets mad at me and tells me she will be ok. It is so hard to watch such a small little girl go through this and be so strong through it all.
A new team came to the floor on Tuesday October 12 and told me that Emma just had 1 positive blood culture total on Friday. I was upset and I did not understand why they told me for days something different and again Emma had to go though having her line taken out. We talked about adding more volume to Emma with feeds though the NG tube I was ok with trying with the understanding that when Emma got sick from the volume that they would slow down the feed and not push her anymore. Emma got up a little but not much. That became worried I made a mistake in coming to Boston.
October 13 was a good day Emma did ok with a little more feed and still ate enough and even played out of the bed most of the day. She is back to her normal self I can breath at last. The team said Emma looked good and wanted me to put in a G tube in Emma which I think is a great idea to stop putting her though replacement of the NG tube. When the G tube team came in they quickly asked me to come to Boston every 14 days to be followed and I declined because I thought coming to Boston every 14 days would do more harm to Emma than good. I talked to the team about could we do G tube and be followed in Dallas they said that what they were going to recommend was for the hematologist to transfer Emma as soon as they could to Dallas to get G tube and have a faster recovery.
On October 14 I was awakened and was told to come to meeting. I was told by the hospital that they turned me in to CPS and that I would have to wait for details. I kept asking for details and they told me that it was the dehydration of Emma. Now they wanted Emma to stay in Boston till Monday and not transfer her to get her G tube and finish treatment in Texas. This would slow her recovery. I could not help but cry and wonder why they would report me when I followed there instructions. We were more than 1800 miles away from home and family. Emma was missing her brothers and home. The hospital told me 3 times on October 14 that I was a good mother and did nothing wrong not to worry, I would not lose my kids as I had done nothing wrong. The hospital had to report by law any special needs child that comes to the hospital with dehydration to CPS. I was very upset with the way things went and how Emma was being treated.
October 16 Emma got sick again this morning but the plan is still to push 50mls an hour in her NG tube. Her throw up smelled like gasoline and burned Emma’s very sore throat from chemo sores from transplant. She would cry saying her thought was on fire. Nothing helped even not milk or water I felt helpless to help her. That night they called me into a meeting where I was told that I had to leave the hospital and to leave Emma alone I was very upset with this decision. The hospital got me a hotel room a few blocks from the hospital. The Hospital staff told me that they were upset with the CPS decision to have me removed. The staff told me that they had told CPS that I needed to stay with Emma.
October 17 I came for my 2 hour visit 9-11am with Emma in the morning and she threw up her NG tube and I had to leave and not help console her as she got a new NG tube. At my 2 hour visit at 1-3 I walked in as Emma was having a nose bleed. She was sitting in the floor trying to care for herself. I was very upset by this. The nurse said she did not like Emma throwing up like this and was going to talk to the team. The team never talked to me about Emma. At the 6-8 visit I found she had not ate much all day. This worries me I don’t want to get so much feed in her tube where she won’t want food by mouth I feel this is a step back for Emma.
October 18 I came to all Emma visits. She had more bloody noses today as well threw up her NG tube again. Her throw up keeps hurting and smells like gas from the medication they are giving Emma to help move feeds though her body. I wish I could do something to help Emma she is going though so much and I was made to leave her. This is not what is best for Emma and sets her back no one knows more about Emma than me her skin reactions, food reactions, how to make her feel better, I am her mother and I have spent the last 5 years and over 300 days in the hospital helping her deal with the diagnoses of Fanconi Anemia. Finding Emma a transplant was a must to help prolong Emma short life span. With this rare genetic disorder that Emma will have to face the rest of her life. With a 50% chance of over 20 well known cancers though her life before age 20. Her life span is 20-30 years even with her transplant which got her life span over the age of 12 with transplant. I want Emma to have a full happy life and would like to have common ground to raise Emma as happy and as healthy as we can to help her have a full and happy meaning full life with her brothers and family.
I have never harmed my sons. My home is not dirty and is regularly cleaned.
Further Affiant sayeth not.”
___________________________________
BRANDY PFLUGER
STATE OF TEXAS §
COUNTY OF TRAVIS §
SUBSCRIBED AND SWORN TO BEFORE ME, the undersigned authority, by the said Brandy Pfluger, on this the ______________ day of ______________________, 2010.
______________________________________
Notary Public, State of Texas
I
AFFIDAVIT IN SUPPORT OF TEMPORARY RESTRAINING ORDER
BEFORE ME, the undersigned authority, on this day personally appeared Brandy Pfluger, and being by me first duly sworn, did under oath depose and state the following:
“My name is Brandy Pfluger. I am the Petitioner and Movant in this cause. I am the mother of the children the subject of this suit. I have personal knowledge of the facts and matters set forth in this Affidavit and those facts and matters are true and correct.
“My name is Brandy Routh. I am over the age of 18 and of sound mind and capable of making this affidavit. I am the mother of Emma in this interest in this cause no 349-6634. The facts and allegations stated in this affidavit are within my personal knowledge and are true and correct.
“The department received an intake alleging physical neglect and medical neglect of Emma Mae Routh age 5. I was contacted by Jackie Geer on Friday October 15 at about 10am Eastern Standard Time. I was made aware she wanted me to place all three of my children Emma Routh, David Carroll, John Routh in placement out of my care. I asked her why she said she would tell me when I came home from Boston. She made me aware that I had until 5pm central time to place my children. I called Ms Geer and other case workers many times with people to place all three kids together but I did not get a response. About 6pm Eastern Time when Ms Geer called and told me Emma was awarded to the state of Texas.
Some time before my child was taken the medical team at Boston Children’s Hospital had asked me to return to Boston for Emma’s bone marrow bio. I was to arrange travel as soon as possible. At that time I expressed concern about travel because Emma had just got out of the hospital and had endured 2 months of trouble. I requested Dallas Children’s Hospital to do the bio and to send the samples to Boston. I was told because of the medical study I would have to travel for Emma’s bone marrow bio and that Boston Children’s Hospital would pay for the cost of travel.
On October 1 2010 I was contacted by Susan Robinson, Hematologist social worker at Boston Children’s Hospital. I expressed my concerns to her about Emma having to travel to Boston. We talked over hydration and whether I could take Emma’s fluid on a plane for the 2 nights we would be in Boston. She told me she would call me Monday October 4 after she talked over my concerns with Doctor Raffaele Renella and David Williams. She assured me that everything would be fine that I was coming to a hospital and to take a deep breath and trust the team.
Over the weekend I thought more about it and I was worried about Emma. Susan Robinson called me back early on Monday October 4 and said she talked to the doctors and arranged for Emma to get to Boston on Thursday October 7 and for fluid to be given at the hospital on Friday October 8 the morning before the procedure. She told me that Emma would more than likely get admitted Friday night October 8 for additional fluid. She told me that the team would make sure Emma would be ok.
She informed me that the airlines would not allow me to bring the bags of fluid on the airplane. The instructions from the doctors were that Emma would be NPO after 10 pm on Thursday October 7 so no NG feeds till after BIO on Friday October 8. I agreed and she said she would send me the travel information by email.
On Tuesday October 5 Susan Robinson called me to talk about travel from the airport to Ronald McDonald house in Boston. We agreed that I would pay a cab and the hospital would pay me back. Susan Robinson said she would check in with me Wednesday October 6 to make sure everything was good and we were going to be on the plane Thursday morning.
We left for the airport at 2am for 2 flights to get to Boston. The flight was delayed. The flight from Washington arrived in Boston a little after 1pm. I went directly to the Ronald McDonald house and called Susan Robinson to let her know we made it and to tell her about Emma getting sick on the plane due to motion sickness. I told Susan that during the flight I continually offered Emma ginger ale to calm her stomach and to hydrate her. However, Emma refused as she was afraid that she would throw up her NG tube.
I asked Susan if we could come in to clinic for fluid she said the medical team had it in the schedule for 7am tomorrow October 8. I told her ok if she was sure, I would go to get Emma some lunch and try to encourage Emma to take food and drink by mouth. I got Emma in the stroller and took the nice walk to the store 3 blocks from the house. She picked all of her favorite Boston foods that she has missed in Texas. On the way back to the Ronald McDonald house she snacked on baby-bel cheese. When I got to the house I cooked Emma lunch at her request. I am so proud of Emma she is getting so big she made herself a cup of juice.
When we sat down to eat she ate very well of her rice and orange chicken. Then we cleaned up our mess and talked about what she wanted to do for dinner. She told me she wanted to order food from New China special rice and crab. So I did so. While we waited on our dinner we watched a movie and Emma took care of her zoo world on the computer. When dinner came she had 2 helpings of rice 2 crabs Rangoon which she only eats the middle and one helping of chicken from moo goo gai pan with a glass of tea. We had a good time and watched home on the range with our dinner after the movie Emma got a bath and then had a bedtime snack of a peeled apple cut in to 8 small pieces Emma ate 6 of the 8 and discarded the other in trash. We laid down about 9pm and Emma went to bed. From the time of our arrival, I continually offered Emma liquids and she ended up drinking 3 good size glasses of fluid.
On October 8 we were in the hospital as planed at 7am they hooked Emma up to fluid that was laid out already. After that they did 4 labs “2 large 1 medium 1 small top” and had me sign for the bio for her to be sedated and the procedure. Everyone kept telling me how good she looked, then we watched a movie though the 3 hours of pre bio stuff. Right before the Bio they came and took 3 more labs “1 large 1 medium 2 small top” before the bio they talked to me about other studies and wanted me to sign so I did. They took an extra table spoon of marrow. They told me that the total would be 3 table spoons. I asked is that ok or is that going to be too much for Emma to handle. They said the team was going to talk it over and they wanted her to come in for fluids and not miss Friday night’s fluids. I had no problem with that and felt relieved. After the bone marrow bio they came and needed more labs 3 more “1 medium 2 small tops” then we were discharged and told to be at the clinic at 11:30am.
At the clinic I talked about Emma growing almost 4 inches and agreed to admit her for fluid and thanked them because I was really worried about it. They sent me through the ER where they wanted to redo all Emma’s labs I told them no that they were already in the computer. I did let them do 2 blood cultures standard for someone like Emma being admitted. Then we went to 6 north for the night and planned to leave the next morning.
The next day Emma was bouncing off the walls, she felt so good. Our friend from Boston came by and was playing with Emma. The doctor came in and told me we could not leave because 1 blood culture grew back. I made plans to stay a few days till they got things worked out for transfer to Dallas. I was concerned because Emma had 1 blood culture positive but had 2 blood cultures taken the day before. I thought this could be a mistake, both should have been positive, but I went with what the doctors said.
For the next few days Emma was happy and healthy her doctor on the floor told us 2 more days of blood cultures had come back positive, so I signed to take Emma central line out. Through the weekend Emma and I had a good time keeping her sprits high making fun of one of the doctors saying it is not hot in Texas. Emma would tell her I can cook an egg outside and would just laugh. Boston Children’s took Emma central line out late Sunday October 10. On Monday October 11 Emma hardly ate or drink anything and would not get out of bed she could not even sit up on her own without hurting. I would not let her see me cry for her because she gets mad at me and tells me she will be ok. It is so hard to watch such a small little girl go through this and be so strong through it all.
A new team came to the floor on Tuesday October 12 and told me that Emma just had 1 positive blood culture total on Friday. I was upset and I did not understand why they told me for days something different and again Emma had to go though having her line taken out. We talked about adding more volume to Emma with feeds though the NG tube I was ok with trying with the understanding that when Emma got sick from the volume that they would slow down the feed and not push her anymore. Emma got up a little but not much. That became worried I made a mistake in coming to Boston.
October 13 was a good day Emma did ok with a little more feed and still ate enough and even played out of the bed most of the day. She is back to her normal self I can breath at last. The team said Emma looked good and wanted me to put in a G tube in Emma which I think is a great idea to stop putting her though replacement of the NG tube. When the G tube team came in they quickly asked me to come to Boston every 14 days to be followed and I declined because I thought coming to Boston every 14 days would do more harm to Emma than good. I talked to the team about could we do G tube and be followed in Dallas they said that what they were going to recommend was for the hematologist to transfer Emma as soon as they could to Dallas to get G tube and have a faster recovery.
On October 14 I was awakened and was told to come to meeting. I was told by the hospital that they turned me in to CPS and that I would have to wait for details. I kept asking for details and they told me that it was the dehydration of Emma. Now they wanted Emma to stay in Boston till Monday and not transfer her to get her G tube and finish treatment in Texas. This would slow her recovery. I could not help but cry and wonder why they would report me when I followed there instructions. We were more than 1800 miles away from home and family. Emma was missing her brothers and home. The hospital told me 3 times on October 14 that I was a good mother and did nothing wrong not to worry, I would not lose my kids as I had done nothing wrong. The hospital had to report by law any special needs child that comes to the hospital with dehydration to CPS. I was very upset with the way things went and how Emma was being treated.
October 16 Emma got sick again this morning but the plan is still to push 50mls an hour in her NG tube. Her throw up smelled like gasoline and burned Emma’s very sore throat from chemo sores from transplant. She would cry saying her thought was on fire. Nothing helped even not milk or water I felt helpless to help her. That night they called me into a meeting where I was told that I had to leave the hospital and to leave Emma alone I was very upset with this decision. The hospital got me a hotel room a few blocks from the hospital. The Hospital staff told me that they were upset with the CPS decision to have me removed. The staff told me that they had told CPS that I needed to stay with Emma.
October 17 I came for my 2 hour visit 9-11am with Emma in the morning and she threw up her NG tube and I had to leave and not help console her as she got a new NG tube. At my 2 hour visit at 1-3 I walked in as Emma was having a nose bleed. She was sitting in the floor trying to care for herself. I was very upset by this. The nurse said she did not like Emma throwing up like this and was going to talk to the team. The team never talked to me about Emma. At the 6-8 visit I found she had not ate much all day. This worries me I don’t want to get so much feed in her tube where she won’t want food by mouth I feel this is a step back for Emma.
October 18 I came to all Emma visits. She had more bloody noses today as well threw up her NG tube again. Her throw up keeps hurting and smells like gas from the medication they are giving Emma to help move feeds though her body. I wish I could do something to help Emma she is going though so much and I was made to leave her. This is not what is best for Emma and sets her back no one knows more about Emma than me her skin reactions, food reactions, how to make her feel better, I am her mother and I have spent the last 5 years and over 300 days in the hospital helping her deal with the diagnoses of Fanconi Anemia. Finding Emma a transplant was a must to help prolong Emma short life span. With this rare genetic disorder that Emma will have to face the rest of her life. With a 50% chance of over 20 well known cancers though her life before age 20. Her life span is 20-30 years even with her transplant which got her life span over the age of 12 with transplant. I want Emma to have a full happy life and would like to have common ground to raise Emma as happy and as healthy as we can to help her have a full and happy meaning full life with her brothers and family.
I have never harmed my sons. My home is not dirty and is regularly cleaned.
Further Affiant sayeth not.”
___________________________________
BRANDY PFLUGER
STATE OF TEXAS §
COUNTY OF TRAVIS §
SUBSCRIBED AND SWORN TO BEFORE ME, the undersigned authority, by the said Brandy Pfluger, on this the ______________ day of ______________________, 2010.
______________________________________
Notary Public, State of Texas