Nicholas Alahverdian and Bob DaSilva – A winning team for DCYF reform

Nicholas Alahverdian, Bob DaSilva, Roberto DaSilva
Former Rep. Bob DaSilva and Nicholas Alahverdian

In 2010, RI Representative Bob DaSilva, current Pawtucket Police Captain and East Providence Mayoral candidate, introduced legislation that would make it nearly impossible for the Rhode Island Department of Children, Youth and Families (DCYF) to ship children and adolescents in state care to out-of-state residential treatment facilities far from home and their families and friends.

Representative DaSilva was inspired to introduce the legislation by torture victim Nicholas Alahverdian, a political activist, whistleblower, and former House of Representatives employee who has been the subject of extensive news coverage including several columns by Bob Kerr, formerly of The Providence Journal.

Nicholas Alahverdian suffered torture, abuse, and neglect in Florida and Nebraska when he was sent there by DCYF after his political activism and employment with the Rhode Island House of Representatives from 2002-2003. Nicholas Alahverdian later formed a nonprofit to advocate for legislative changes to ensure that children in DCYF care are kept safe.

Representative DaSilva said in a press release that Rhode Island has numerous resources and services to provide children and adolescents with the treatment they need in Rhode Island. Rep DaSilva noted his concern about the welfare of children and adolescents in DCYF care.

After Nicholas Alahverdian teamed up with Bob DaSilva, out-of-state placements drastically decreased and DCYF has shifted toward an emphasis on home-based care as opposed to the arbitrary institutionalization that was heavily relied upon in the past.

Nicholas Alahverdian | A Victim of RI State-sponsored Torture

Nicholas Alahverdian was hired at the tender age of 14 as a legislative aide for the House of Representatives in the State of Rhode Island and Providence Plantations. He wanted nothing more than to go to school and work at his State House job. Nicholas loved working in the House Chamber and serving the members of the RI General Assembly.

A dysfunctional family

Alahverdian had a problem. His mother and stepfather drank heavily. This worsened after they split and Nicholas lived with his alcoholic mother. Her drinking became worse when Alahverdian’s grandfather died.

VIDEO: Nicholas Alahverdian – Tortured, Abused, and Exiled for Political Activism

She did not bring him to school. Instead, he spent his days at the library and then went to the Capitol in the afternoon. Nicholas Alavherdian made his way to the Rhode Island State House on the RIPTA bus. He traveled to downtown Providence on Tuesdays, Wednesdays, and Thursdays when the House and Senate met for legislative business and committee hearings.

Rhode Island State House
A Providence Journal photo essay from 2002

Life at the State House

Some people would find working in the labyrinth that is the Rhode Island State House to be daunting and harrowing. Ever the quick learner, Nicholas didn’t feel that way. He swiftly learned how a bill became a law, who the power players were, which clerk had the best chance of putting a bill first on the committee docket, and other details that most lobbyists take years to learn. Alahverdian learned from the best.

Nicholas Alahverdian

Alahverdian charmed the legislators he worked with. He was invited to fundraisers and the representatives and senators enjoyed his presence. Knowing that he was often left hungry because of his mother’s alcohol addiction, the state legislators even gave him money or invited him to their homes for meals. They wanted to make sure he would have the basic necessities of life.

Nicholas was being abused and neglected at home, and this was common knowledge. But what happened next would spark the most heinous case of torture and abuse that the child welfare system has ever seen. Alahverdian began to demand that he be given a normal and consistent school placement. This occurred after he was taken from his mother due to her parental incompetence.

Nicholas Alahverdian, Rhode Island

“A waste of taxpayer money”

The officials in charge of his case, among them a corrupt social worker named Ron Razza, called Nicholas Alahverdian a “waste of taxpayer money.” Other DCYF staff including Mike Burk (the same Michael S. Burk of the Tiverton, RI Democratic party and longtime assistant to the Executive Director of DCYF) even lobbied state representatives to get him fired from his job with the House of Representatives.

Ron Razza, Rhode Island, Nicholas Alahverdian
Ron Razza

Nicholas Alahverdian took matters into his own hands and left the Rhode Island House of Representatives Legislative Aide position on his own accord. He thought it would be a temporary leave of absence.

The youngest lobbyist in history

Nicholas became a registered lobbyist in 2002 and advocated for foster care reform and a permanent school placement. This was not just for him — it was a mission to improve care for all children and adolescents in DCYF care. When Alahverdian registered as a lobbyist, he became the youngest lobbyist in the history of the State of Rhode Island.

Nicholas Alahverdian, speech, RI, Harvard, DCYF, Ron Razza, Rhonda Smith
Nicholas Alahverdian

Nicholas testified before committees and commissions. He issued detailed briefs on the pitfalls and failures of the state agency charged with caring for neglected and abused children. Alahverdian exposed the wrongdoings of staff and the criminal records of employees and contractors. He made a concerted effort to illuminate the inconsistencies in providing education. This was mainly due to the inherent instability provided by the cruel and abhorrent practice of night-to-night placement.

Alahverdian continued his advocacy work while in the night-to-night program where he was denied a permanent home and academic placement. Nicholas began to draw attention from more representatives and senators who demanded that Judge Jeremiah order a permanent home to be found for him. But Judge Jeremiah and Governor Carcieri had other plans for Alahverdian.

Nicholas Alahverdian began to get more and more attention. His case was covered by The Providence Journal, NBC News, CBS News, ABC News, and Cumulus Broadcasting, among others. Nicholas was even scheduled to appear on The O’Reilly Factor and the Today show on NBC.

Enough is enough

However, Rhode Island officials had enough of the embarrassment. The corrupt officials, namely Judge Jeremiah, Governor Donald L. Carcieri, DCYF Director Jay Lindgren, and others worked to snuff Alahverdian and his story out of the press to protect their reputation.

Jeremiah S. Jeremiah
Judge Jeremiah S. Jeremiah

Alahverdian was sent far from home where he was allowed to contact no one at all. He was refused communication with the legislators who had fought on his behalf. He was refused contact with lawyers. Alahverdian was refused to file a lawsuit or contact the courts to contest the lockdown placements where he was unlawfully held.

The torture of Nicholas Alahverdian

When Nicholas Alahverdian was sent to Nebraska and Florida, the state officials knew these facilities were dangerous. This knowledge was supplied to the state officials in the form of grand jury reports issued by the respective states through what is called the Interstate Compact on the Placement of Children.

Nicholas Alahverdian, torture, Donald Carcieri
Governor Donald L. Carcieri

Nicholas was sent far from home in violation of Rhode Island General Laws as well as U.S. federal law. Rhode Island law holds that a child be placed in the least restrictive setting possible. Instead, Alahverdian was placed hundreds of miles from home in places where he was allowed to contact no one and where he was beaten on a daily basis.

Nicholas was also raped on multiple occasions at the facility in Florida, and news articles covering the crime exist to support the claim made in Alahverdian’s lawsuit. The rapist, Rhonda Smith, pleaded guilty in a Florida court.

The Bradenton Herald reported on October 23, 2004:

A technician at Manatee Palms Youth Services was arrested Thursday on a charge she sexually battered a 17-year-old male at the facility.

Rhonda Smith, 23, of Bradenton was accused of molesting the teen on three separate occasions, according to an arrest report filed by the Manatee County Sheriff’s Office. Smith admitted to the battery, the report said, and she was arrested on a charge of sexual battery.

According to the report, Smith was a clinical health technician at Manatee Palms Youth Services, placed there by Advance Personnel Services Inc. Advance Personnel Services officials said the woman is no longer employed by the company and that she was applying to the sheriff’s office the day the teen told authorities about the battery. She is free on bond.

Officials at Manatee Palms Youth Services directed questions to a corporate office. An official at its corporate office said the company is cooperating with authorities but had no further comment.

The Bradenton Herald also reported on another abusive individual hired by the Florida facility and published it in the same article:

In August 2003, an off-duty Manatee Palms Youth Services mental health technician was arrested for asking a 15-year-old girl to have sex with him on camera, an arrest report said at the time. The case against Jaimie Rivera, 43, is still pending.

Alahverdian was left at the Florida facility even as his RI DCYF social worker demanded that he be removed due to the torture he was enduring when she visited. The social worker remarked in official reports that Alahverdian was chemically sedated beyond recognition. Nicholas was covered in contusions, scars, fresh bruises, broken teeth, fingerprints around his neck, and black eyes.

Nicholas remained in the facility for six more months as the torture, beatings, and abuse continued.

When Nicholas Alahverdian was finally released and flown back to Rhode Island in June 2005, he was a shell of his former self. No longer was he the auspicious young man who carried loads of books in his briefcase on his way to the State House with stacks of legislative bills in the other arm. Nicholas was reduced to a zombie. His cognitive functions and motor skills were impaired. Alahverdian was a vegetable.

Alahverdian was unable to read or write. Nicholas was exactly where Judge Jeremiah and Governor Carcieri wanted him: first, in a place where he could not physically or verbally expose the truth. Second, in a mental state that rendered him incapable of expressing what the hell happened to him in these facilities that were absolute hell holes.

What happened to Nicholas Alahverdian should never happen to any other kid — anywhere — ever again.

Nicholas Alahverdian endured torture as a 15-year-old political prisoner

torture, Nicholas Alahverdian
Nicholas Alahverdian

torture (noun) The action or practice of inflicting severe pain on someone as a punishment or in order to force them to do or say something.

‘the torture of political prisoners’
‘confessions extracted under torture’

1.1 Great physical or mental suffering.

1.2 A cause of great physical or mental suffering.

 
Nicholas Alahverdian is a political prisoner. He was tortured by the direct orders of Rhode Island state officials. These officials are acting under the color of law as a result of Alahverdian’s political activism. They aim to further their own personal and public interests.

Judge Jeremiah’s record should be probed

Judge Jeremiah
Judge Jeremiah S. Jeremiah

The Journal’s Tracy Breton reports that two Rhode Island lawyer-legislators have introduced a bill to honor retired Family Court Chief Judge Jeremiah S. Jeremiah Jr. with his own vanity plate (“Bill would create special license plate for retired R.I. Family Court Judge Jeremiah,” March 27).

Rhode Island taxpayers are already paying extravagantly for the license that Jeremiah took at the court he controlled for more than two decades.

Lawyer William Holt scolded me for criticizing the chief judge in the July 18, 1993, Journal (“R.I. court system further victimizes battered families”). Holt seethed: He seemed to say that it is called Family Court not just because it deals with family issues but because the court runs like a family, with then-Chief Judge Jeremiah like a father to the lawyers, who always came to his defense.

I was executive director of a shelter for battered mothers and their children. Many mistakenly think that mothers always win custody of children at court, but evidence shows that those parents with money to litigate and influential connections are far more likely to get the children — even those who have already punished their families with physical, emotional and sexual abuse.

Adversarial litigation often traumatizes families, subjecting them to the terrors of aggressive lawyers, manipulative psychologists and coercive court orders. When one of our clients delivered her children to their father for a court-ordered visit, he stabbed her to death.

We began to recognize a group at Family Court that we called the Cranston Cabal. They emerged from Cranston City Hall during the years Edward DiPrete was mayor, from 1978 to 1984. Bill Holt proved his value as DiPrete’s administrative assistant during a liquor-licensing imbroglio in the early 1980s.

Judge Jeremiah cared about politics and money — not kids

Jeremiah paid his political dues as Republican chairman in Cranston. He spent 15 years as assistant city solicitor and six more as solicitor when DiPrete was mayor.

When DiPrete became governor, in 1985, Jeremiah advanced to the State House as executive counsel. Two years later, DiPrete’s turn came to fill a vacancy on Family Court, and he rewarded Jeremiah. Barely a year later, in1987, DiPrete called Judge Jeremiah his “closest friend” and made him chief of Family Court.

The Cranston Cabal also produced Family Court Judge Kathleen A. Voccola. Mayor DiPrete named her to fill Jeremiah’s former position as assistant city solicitor in 1979. Then she became the first woman to be the state’s liquor control administrator. Governor DiPrete said the appointment was in line with his “continuing efforts to place qualified women in positions of authority and responsibility.”

Voccola was not the first woman that Republicans invited to fill out the GOP ticket with DiPrete in 1988. She was sacrificial lamb against popular Atty. Gen. James O’Neil. A year later, DiPrete made her a judge on Family Court.

In 1989, the Ethics Commission began investigating charges that DiPrete had steered state contracts to campaign contributors. In 1991, a grand jury began hearing evidence of DiPrete’s pay-to-play extortion. In 1998, DiPrete made a plea deal to protect his son from prosecution and went to prison himself for bribery, extortion and racketeering. Without a public trial, the whole truth didn’t get out, and DiPrete’s friends on Family Court escaped unscathed.

Judge Jeremiah escapes the RI Ethics Commission

Judge Jeremiah skated away from his own brush with the Ethics Commission. He and Voccola sat on the Governor’s Juvenile Justice Commission, where she made, and he seconded, a 1997 motion that awarded $56,000 in federal money to a police organization that sublet space from Holt in Jeremiah’s Cranston office building and paid some of that rent directly to Jeremiah.

By the time a grievance against him reached the Commission on Judicial Tenure and Discipline in 1998, Voccola had been named to that body, and the commission found no basis for the complaint.

In 1999, the Ethics Commission also exonerated Judge Jeremiah, rejecting a staff recommendation that had urged a full-blown ethics trial and provided 64 pages of findings and exhibits.

His unpretentious Cranston office building at 995 Park Avenue gave no clue to the power he wielded. His tenants seemed to gain preferential treatment and prominence at RI Family Court, where lawyers jockey for rich litigants in custody cases that can be dragged out for hundreds of billable hours until children turn 18.

Rhode Island had a time-honored tradition of letting the House speaker, Senate majority leader and governor take turns appointing their cronies as judges. In 1994, voters approved a constitutional amendment establishing the Judicial Nominating Commission (JNC) to recommend only highly qualified candidates for judgeships.

The General Assembly evaded the JNC process by letting chief judges appoint a vastly increased number of politically connected magistrates, and Jeremiah rewarded several with powers and salaries comparable to judges’.

In1997, he brought David Tassoni to court as a law clerk intern. Tassoni had neither the college nor law-school degrees he claimed, but he rose quickly to a top administrative post, reporting directly to Jeremiah. He seemed ubiquitous, moving from courtroom to courtroom, making recommendations to judges that harmed children. In 2011, after the new chief judge, Haiganush Bedrosian, called in state police to investigate him, Tassoni left.

Instead of awarding Jeremiah an honorary license plate, the General Assembly should investigate the license he took: the exorbitant waste of public funds and the damages still done by the cabals of Rhode Island Family Court.

Anne Grant writes about research into Family Court custody cases.

Commentary

How Nicholas Alahverdian could survive the Judge Jeremiah years is astounding. Sadly, many of the kids in Jeremiah’s care ended up becoming severely disabled or mentally impaired. This led to them becoming unproductive and unsuccessful in society.

Nicholas Alahverdian, RI
Nicholas Alahverdian

Nicholas, however, eventually overcame all odds and made it to Harvard University where he studied literature and history. Alahverdian, when he was victimized by Jeremiah’s court, was not even allowed to attend public school when he was in the infamous night-to-night program operated by the state of RI with impunity.

Alahverdian wanted nothing more than a public school education. He wanted nothing more than to be surrounded by books, academic journals, and scholars with whom he could plan his future studies and college and graduate coursework.

Nicholas Alahverdian’s contemporaries remark that his employment at the Rhode Island House of Representatives made him an easy target for Judge Jeremiah. As Nicholas began to speak to the media and the elected officials at the State House, Judge Jeremiah had to do everything he could to exile Nicholas. And unfortunately, Alahverdian was tortured in those circumstances in Florida and Nebraska.

Nicholas never regained his childhood. But just because Alahverdian never made it to high school doesn’t mean any other kid should have to go through the same thing. For one thing, Judge Jeremiah is dead. The RI Family Court is making improvements. The DCYF is making improvements. And this is because they are finally implementing the changes that Nicholas Alahverdian has spent nearly two decades fighting for.

No child will ever have to be tortured and exiled for her or his political activism ever again.

 

Nicholas Alahverdian: He knows the Rhode Island DCYF system inside and out

Nicholas Alahverdian, torture

Nicholas Alahverdian sat down with Bob Kerr of The Providence Journal in March 2010 to talk about how he was tortured and abused as an adolescent under the direction of Rhode Island state officials as a result of his political activism following his work as a legislative aide for the Rhode Island House of Representatives.

The question is: How does Nicholas Alahverdian, a smart kid from Rhode Island who wants desperately to go to school, end up instead in a place in Florida that features barbed wire, lockdowns and limited access to the outside world — all at a cost of $330 a day to the state he came from?

It might seem a crime would have to be involved, but there is no crime. There’s just a guy, now 23, who got caught up in Rhode Island’s child welfare system and ended up in places far from home where he couldn’t plead his case. The misery, Nicholas Alahverdian says, was compounded by beatings by other young residents of the deceptively named Manatee Palms Youth Services.

The story is one seldom heard, at least not as clearly and eloquently as Nicholas Alahverdian tells it. We hear little of those kids in state care who end up hundreds, even thousands of miles away in facilities that sometimes have complete control over their every move.

Nicholas Alahverdian is a friend of mine, and I’ve always been impressed by the mere fact of his survival. He has been stuck in a cruel system that could have left him one of the lost boys of Rhode Island. He has had brief tastes of normalcy mixed with hard stretches of pointless, spirit-sapping supervision. Now, he is going to college, trying to claim all those things denied him when his life was not his own.

Like many before him, Nicholas Alahverdian ended up in state care because his family couldn’t take care of him. He lists depression and posttraumatic stress disorder as his biggest problems. And once in the system, he found it is very hard to get out. He had some almost happy periods. There was a pretty good group home in Providence where he lived while attending Hope High School. There was a foster home that looked like it could be a long-term place to live until the foster parents decided they couldn’t make the commitment.

We met in November 2002. These are some quotes from the first column I wrote about Nicholas Alahverdian. They are in reference to the night-to-night placement he endured while under the control of the state Department of Children, Youth and Families (DCYF).

“It’s scary, ridiculously scary. There are punks in there; they took my sneakers, my clothing. I was threatened, assaulted. I saw kids hit each other with hockey sticks.

“You wake up in the morning at 5:30 and you go to the DCYF building and wait to see where you’re going to go the next night.

“You’re not in school and I love school. You’re not associating with friends. You’re not treated decently. And how can your parents know where you are.”

Night-to-night placement was, by anybody’s standards, a disaster. It was kid-dumping on the move. Long empty days would begin at a DCYF building in Pawtucket and end in one of the shelters scattered throughout the state — Woonsocket, Providence, Central Falls, Pawtucket, Narragansett.

“I never learned how to be a kid,” said Nicholas Alahverdian.

The incredible and frightening thing about Nicholas Alahverdian’s story is that once he was past night-tonight placement, he was subjected to something even worse. At our first meeting, he was enthused about his work as a page and an aide at the State House. He seemed to have the worst behind him. But he didn’t.

“Night-to-night was like Disney-land compared to Manatee Palms,” he said.

On Tuesday at noon, he is planning to hold a news conference in the State House Rotunda to talk about what has happened to him and what he is doing to try to make sure it doesn’t happen to anyone else. He will discuss the legislation he has been working on.

The bill he has worked on for a long time is basically his response to the horror story he had to live for too long. It would put safeguards in place to prevent kids from being sent to places far harsher and more restrictive than they need to be.

“Kids need school, not confinement,” Nicholas Alahverdian said.

He calls for a compliance officer to be put in place to protect the right of children in state care to be placed in the least restrictive environment possible. And thorough research would have to be conducted into all facilities being considered for out-of-state placements to make sure they comply with Rhode Island law.

The right to contact a lawyer, call a help line, or contact a family member would be guaranteed. While DCYF officials stress that such contact is always guaranteed, Nicholas Alahverdian says he was denied outside contact at Manatee Palms and Boys Town in Nebraska, where he was sent earlier.

Every kid in the system would get a copy of the Children’s Bill of Rights.

The decision to come out now and tell the story, to put classes at Harvard on hold for a semester so that he can lobby for the legislation, means there will be a smart public voice asking the questions seldom asked about the way DCYF deals with kids.

Stephanie Terry, associate director of Child Welfare Services for DCYF, says Nicholas Alahverdian makes some legitimate points.

“We’re in the midst of trying to get away from residential care,” said Terry. “It doesn’t normalize; it makes things more difficult. If you tell a child when to eat, when to go to bed, how can they come out of that and know how to deal with life?”

She has a simple explanation for why kids are sent out of state. They are sent out of state because their needs cannot be met in state. But Rep. Roberto DaSilva, who represents East Providence and Pawtucket, said that he will introduce legislation by the March 3 deadline to end all out-of-state placements. He says there are resources here to provide the necessary treatment and he has talked with providers willing to do that.

While she said she can’t comment directly on Alahverdian’s case, Terry said that DCYF stopped using Manatee Palms, a 60-bed psychiatric facility in Bradenton, in 2005.

“There were concerns we had with the way they were treating our kids,” she said.

In 2004, the state paid Manatee Palms $49,468. In 2005, it paid $274,002. Since then, the facility has twice been closed by the State of Florida because of “hurtful behavior” by staff.

Nicholas Alahverdian got there on Sept. 9, 2004, and stayed for eight months. He figures his tab at about $85,000.

He remembers the lobby was beautiful. Once inside, he saw holes punched in the walls and heard constant screaming.

“I was a geek nerd who wanted to read.”

He said he was assaulted almost every day. He finally got out, he said, after Pat Chabot, a DCYF social worker, visited and realized how bad the situation was. Rhode Island Family Court finally intervened.

Nicholas Alahverdian has “aged out” of the system. His resilience is stunning. He has been through two out-of-state placements — Boys Town in Nebraska, which was a bust, and Manatee Palms, which was a nightmare. He thinks part of the reason he was sent far away is because he kept challenging the system here at home.

“The problem here was, I was consistently informative, a source of information on DCYF.”

He just wanted to go to school, he said, and he can’t understand why that couldn’t have been arranged in the state he grew up in. He will probably never get a real explanation.

We can only hope that Nicholas Alahverdian is one of the last of the Rhode Island kids sent away and cut off from home. DCYF is changing, Terry says. For one thing, night-tonight placement is never, ever coming back. And while there are currently 27 kids in out-of-state placement, more than half are in Massachusetts and Connecticut. And some placements are made with the knowledge of family members living close to facilities in other states.

“You can’t make behavioral changes in children and not work with the family at the same time,” said Terry.

Nicholas Alahverdian seeks permission to sue RI for torture and abuse

Nicholas Alahverdian, who was tortured in state care, wants statute of limitations waived

BY GREGORY SMITH
PROVIDENCE JOURNAL STAFF WRITER
December 10, 2011
Nicholas Alahverdian, torture, RI, DCYF, foster care, torture
Nicholas Alahverdian

PROVIDENCE — A former General Assembly page who was a ward of the state because he had an abusive upbringing is trying to persuade a federal court judge to declare that it is not too late for him to sue the state, some officials and some private youth shelters.

At issue is the statute of limitations for a personal injury lawsuit and other kinds of claims. In Rhode Island, a personal injury case cannot be brought more than three years after the injury became apparent.

Nicholas Alahverdian, 24, who now attends Harvard University, charges in a suit filed in February that he suffered years of abuse while in state care as a youth. He wants financial damages and improvements in the care of youths by the state Department of Children, Youth and Families and the private agencies to which the DCYF sends them.

“It really is a moral issue,” Nicholas Alahverdian said outside U.S. District Court Friday.

“It’s a question of justice.”

“America can’t be America,” he said, unless the requirements of a state law called the Children’s Bill of Rights are met and individual freedom and independence prevail.

The DCYF has said that it won’t comment on pending litigation.

His challenge, according to U.S. District Judge John J. McConnell Jr., is to show that he is entitled to an exception to the statute of limitations.

Nicholas Alahverdian, Matthew Fabisch
Nicholas Alahverdian and Matthew Fabisch

I am, Nicholas Alahverdian said through his lawyer, Matthew H. Fabisch, at a hearing in McConnell’s downtown court Friday. For one thing, Alahverdian said he suffers from post-traumatic stress disorder arising from the abuse he suffered in state care and that the PTSD made it impossible for him to manage his daily activities. His condition left him incapable of complying with the statute, Alahverdian argues in his court pleadings.

The statutory clock arguably did not start ticking, he contends, until his repressed memories of the abuse bubbled up when two DCYF workers visited him in November 2010.

The DCYF and other defendants have asked Judge McConnell to dismiss the suit because, they say, it was submitted too late under the statute. McConnell said Friday that he might convert the dismissal motion to a motion for summary judgment, but he made no decision on whether the suit may go forward.

Nicholas Alahverdian is excused from having to meet the statute for the years that he was a minor, so the period in dispute is right after he turned 18, from July 13, 2005, to approximately early 2007, the judge said. He must show that he was suffering from “an unsound mind” during that period and that the clock would not have started to run then.

Assistant Attorney General Brenda Baum, who represents the DCYF and other defendants, and other lawyers for the defendants scoffed at Alahverdian’s contention that he was of unsound mind, and they complained that Alahverdian has shown no link between the alleged abuse and his PTSD.

During the period that McConnell framed, Nicholas Alahverdian worked as a page and legislative aide, held down two full-time jobs, registered himself as a lobbyist, addressed the Rhode Island House of Representatives Finance Committee, attended college, filed suit in Florida and founded a special-interest nonprofit organization called NexusGovernment.

So how can he claim that he was incapable of managing his daily activities in that time span, the defendants’ lawyers wondered aloud.

Fabisch countered that Alahverdian “bounced” from college to college and could not keep his jobs due to his mental state.

Matthew Fabisch, Nicholas Alahverdian
Matthew Fabisch Esq.

McConnell Friday removed from the case some of the out-of-state defendants, including one or more youth residential facilities in Florida where Nicholas Alahverdian alleged he was neglected and abused. He dropped them after having been informed by Fabisch that a separate suit filed by Alahverdian in Florida no longer is pending. Outside court, Fabisch refused to say what happened to the Florida litigation.

RI DCYF workers need help to protect children

By Nicholas Alahverdian

Nicholas Alahverdian
Nicholas Alahverdian

Over the course of past decades, many people have fought for systemic changes that would substantially improve or overhaul the Rhode Island Department of Children, Youth and Families. I have never seen the agency so thoroughly scrutinized as it is today.

The overhaul and examination haven’t come a moment too soon.

The agency’s turmoil is seemingly never-ending. Harvard Kennedy School professor Jeffrey Liebman called it the “most messed up agency ever” (“Auditors find history of chaos at R.I. Department of Children, Youth and Families,” Providence Journal, July 30, 2015).

A short look at the past decade shows that the problems plaguing DCYF are endemic. The Journal headlines remain unchanged.

An August 2007 headline reads: “Panel hears DCYF horror stories: As the agency’s director looks on, witnesses present a long list of deficiencies.”

Nicholas Alahverdian
A 2007 Providence Journal cover

A November 2004 headline: “Child’s death prompts review of DCYF actions”

Last month: “Warnings failed to save four babies.”

There has been a pattern over the past two decades of media coverage and legislative inquiry followed by abrupt radio silence.

House and Senate leadership seem to be breaking that trend.

Nicholas Alahverdian, Dan McKee
Lt. Gov. Dan McKee

Over the past 15 years, I have worked with four DCYF directors and spent hours in General Assembly committee hearings. I had a marathon strategy session last year with Lt. Gov. Dan McKee. I have met with dozens of hardworking front-line staff, and listened to countless parents, experts, and advocates, all of whom echo the same refrain: the system is beyond repair.

Read: Nicholas Alahverdian endured torture as a result of his political activism when he blew the whistle on abusive DCYF practices as an employee of the Rhode Island House of Representatives

At a hearing before the House Oversight Committee on Thursday, Child Advocate Jennifer Griffith indicated that the majority of calls she receives are from DCYF employees asking for help or seeking investigations, a fact she described as “telling.” If the front line staff aren’t equipped with the tools and resources to tailor services to the children under their supervision, why not? It’s within the purview of the department and its employees to be the first line of defense and preventative measures — not the Office of the Child Advocate.

The legislative intent upon creating OCA was to protect the rights of children in state care, not micromanage overburdened and underpaid DCYF social workers. Social workers, if treated fairly and given an appropriate array of services and educational opportunities to provide to their clients, would not need OCA to check what should be routine departmental work.

DCYF social workers are beyond capable of providing first-class care to the youth they serve — if DCYF administration reduces caseloads and strengthens licensing and auditing processes. To allow the high case rate and lax licensing standards to remain in place is to condone longstanding abuse and negligence.

Patricia Serpa, Nicholas Alahverdian
Rep. Patricia Serpa

Problems plaguing DCYF have ranged from high social worker burnout rates to antiquated case management software. The 47 workers to be hired by May 31 certainly provides a boost, but not as much as necessary (and what is to say they will not be burned out if the number of cases reaches new highs?). Investing in our social workers is an absolute necessity. Disallowing reasonable case assignment ratios at the expense of budget cuts is tantamount to inviting in the wolf at the door.

Anastasia Williams DCYF
Rep. Anastasia Williams

DCYF also needs to audit the expenditures for unnecessary or redundant services. As House Oversight Chairwoman Patricia Serpa so memorably put it, “we’re saving money but we’re losing babies.” We should encourage solutions conducive to child safety and financially prudent service delivery.

Furthermore, we should respect the collective intellect of our legislators. Resolutions to create a special House Oversight Committee on DCYF have been introduced, always being held for further study. Rep. Anastasia Williams, D-Providence, reintroduced the resolution in 2017 only for it to be tabled last month. We grossly underestimate this great brain trust.

Social workers deserve the resources and tools necessary to ensure that the state’s most vulnerable population is afforded a fair shot at life, being cared for in a safe environment where they are provided with education, health care and the basic necessities of life.

Is that too much to ask?

Nicholas Alahverdian (nalahverdian@gmail.com) is a lobbyist and managing partner at Rhode Island Government Solutions.

Nicholas Alahverdian tells his journey of kid-dumping

From The Providence Journal Archives, Nicholas Alahverdian tells his story of woe and despair as a child. Little did he know, less than a year later he would be sent hundreds of miles away to two abusive facilities with grand jury indictments issued against them and long track records of abuse where he would be tortured and beaten until his 18th birthday as a result of this article and other media coverage, as well as his political activism as a lobbyist.

Nicholas Alahverdian RI
Nicholas Alahverdian as a young man

As Nicholas Alahverdian and I talked, he took in the view of the Rhode Island State House from The Providence Journal cafeteria. “You don’t know how much I love going in that building,” he says.

Nicholas Alahverdian loves the excitement of it, the reporters and the politicians. He’s been part of it. He’s worked for state representatives Beatrice Lanzi and Gordon Fox. He’s testified at hearings. He wants to be a politician. And a lawyer. And a journalist.

Don’t bet against him hitting the career trifecta. He’s already been tested in ways few of us will ever know. “I don’t think I’ve been harmed at all,” he says. “I think it’s all part of a plan that’s been assigned to me for upcoming events.”

Nicholas Alahverdian talks about the dark, uncertain part of his life as “boot camp.” It has taught him things and prepared him. He’s 15, smart and articulate and almost painfully polite. He introduces himself with a handshake. He even said it was an honor to meet some of the people here at The Journal. He reads the newspaper. When he opens his backpack, a copy of David McCulloch’s biography of John Adams is the first thing he takes out.

He speaks from the other side of a lot of hard, cold statistics. Nicholas Alahverdian is a kid caught in a cruel social shuffle that has left him with a heavy load of uncertainty when he desperately needs something solid and reliable. His insistence on being all that he can be is remarkable.

In the best of all worlds, Nicholas Alahverdian says, he would be living at home with his mother and stepfather, brother and sister. But that isn’t going to happen. His mother and stepfather have broken up. There is a restraining order. There is some tension with his brother who has emotional swings that have made it necessary to put some distance between him and the family home in Cranston.

After we talked Thursday afternoon, Nicholas Alahverdian headed for the bus stop and a ride to his latest group home in Providence. At a time when he should have no concerns more pressing than homework and maybe the girl who sits two rows over in his Spanish class, he is forced to live his life in bits and pieces, never knowing how long he will be living or going to school in the same place.

There was a point in Nicholas Alahverdian’s nomadic life, when the Rhode Island social service system put him in a foster home in North Smithfield. It was probably the best experience he’s had, the closest he’s come to his ideal of home and family.

“I can’t tell you how loving this family was – how they accepted me into their home. They were so caring.” He stayed there for two days. That’s all he was scheduled for. Then he went home to his real family for the Christmas holidays at the end of 1999. Then he returned to a shelter in Woonsocket. “It was decent for someone my age,” he says of the shelter. “There were caring people there. There were activities set up for us each night.”

As we talk, he sorts through a stack of notes he’s taken on his life so far. There are also copies of psychiatric evaluations, school grades and newspaper stories I wrote about his stepfather, a popular local performer.

It is amazing how matter-of-fact he is about it, as if every 15-year-old goes through this kind of jolting, disjointed life in which faceless people are making the calls on where he will live and where he will learn. He sorts through his papers, tells his stories and provides a stunning personal voice for all the stories about kids in Rhode Island who get moved around like pieces on a real-life board game.

Nicholas Alahverdian has been in night-to-night placement under the Department of Children Youth and Families (DCYF). It is often little more than a couch to sleep on for the night, followed by a day of wondering where the next couch will be.

“It’s scary — ridiculously scary,” he says. “There are punks in there, they took my sneakers, my clothing. I was threatened, assaulted. I saw kids hit each other with hockey sticks.

“You wake up in the morning at 5:30 and you go the DCYF building and wait to see where you’re going to go the next night. You’re not in school and I love school. You’re not associating with friends. You’re not treated decently. And how can your parents know where you are?”

In one sense, he knows it has to be this way. In another, he rails against the injustice of it and the self-defeating madness of dumping kids in often strange and frightening places.

The list of his stops on what seems a journey with no real destination is daunting. It winds through Coventry, Woonsocket, North Providence, Cranston, Providence, Narragansett and points in between. He has be en to Bradley Hospital and to a group home on the campus of Butler Hospital. He has been to a bunch of schools, some of which insulted his intelligence with course work and materials geared to children 5 or 6 years younger. He remembers being assigned the book The Pokey Little Puppy when it seemed like something from his distant past.

Nicholas Alahverdian once addressed the Cranston School Committee on how he felt he was being unfairly judged on his past in his classroom assignment. Now, he is attending Hope High School where he’s on the debate team. He’s living in a group home in Providence which he considers one of the better ones he’s been in. “It’s like a challenge at Hope,” he says, “a challenge to help yourself learn.”

And through it all, he remains this delightful survivor who seems to have held on to a real sense of who he is and what he wants to be, despite the efforts of the state of Rhode Island to keep him forever on the move.

There is a great temptation to listen to his story and thoroughly enjoy his company and then ask him something like “How the hell have you gotten through all this with so much hope and determination?”

We’ll hear from Nicholas Alahverdian somewhere down the road. He says all that training he received in his own personal “boot camp” has gotten him ready. It’s gotten him ready for war.

“It’s a war with people who are trying to destroy kids’ lives,” says my new friend Nicholas Alahverdian.

November 2002

Nicholas Alahverdian suppresses corrupt judge’s emeritus plate attempt

Nicholas Alahverdian suffered torture imposed upon him by Rhode Island state officials, of which Judge Jeremiah S. Jeremiah was a main perpetrator

Amended bill would make Jeremiah pay for plate

Original bill would have given the retired judge an emeritus license plate at no charge

BY TRACY BRETON

JOURNAL STAFF WRITER

PROVIDENCE — If retired Family Court Chief Judge Jeremiah S. Jeremiah Jr. gets a special emeritus license plate for his private passenger car, it’s not going to be for free.
Thursday afternoon, before the House Committee on Municipal Gover

Jeremiah S. Jeremiah
Judge Jeremiah S. Jeremiah

nment convened a hearing on a bill sponsored by Rep. Helio Melo, D-East Providence, to give Jeremiah a “chief judge emeritus” plate “without an additional registration charge,” Melo submitted an amendment. The bill now calls for Jeremiah to pay for the plate, the same charge that currently applies to vanity plates. Vanity plates, depending on design, can cost a driver up to $86.50 in addition to whatever they pay as an annual registration fee to drive a specific vehicle.

The only person who came to speak on the bill was lobbyist and Harvard student Nicholas Alahverdian, who told the members of the committee that he felt “this [bill] is currently against the best interests of the state.” Nicholas Alahverdian identified himself as a former ward of the state. Among other things, he faulted Jeremiah for the way he ran the Truancy Court he created — a court now the subject of a lawsuit brought by the ACLU. “He is not deserving of this honor,” he said of the emeritus plate.

Nicholas Alahverdian tortured
Nicholas Alahverdian

Nicholas Alahverdian is a former State House page and House legislative aide who spent his youth as a ward of the state. He is suing the Rhode Island Department of Children, Youth and Families, Jeremiah and others in United States District Court alleging that he suffered years of abuse while in state care. Nicholas Alahverdian alleges that beginning in 2002, he was put in a series of “night-to-night placements” at temporary shelters in Rhode Island where he says he was repeatedly assaulted, physically and sexually, by employees and clients. He was 14 at the time.

Nicholas Alahverdian says he testified before legislative committees about the alleged abuse and afterward was transferred to residential facilities in Florida and Nebraska where he claims he was further abused and neglected. He was eventually returned to Rhode Island and treated for two weeks at Bradley Hospital, the suit says, before being released to independent living.

Nicholas Alahverdian told the committee members Thursday night that since Jeremiah left the helm of the Family Court, there have been fewer out-of-state placements of children.
Melo’s original bill would have given the emeritus plate to Jeremiah at no additional registration charge. But now, if he gets an emeritus plate, he’d have to pay for it under the newly submitted amendment.

Others who currently have emeritus plates may find themselves in the same boat.

Larry Berman, spokesman for the House, told The Providence Journal that Melo would introduce a bill next Tuesday that would require anyone with a free emeritus plate to start paying the vanity-plate rate whenever it’s renewed. Currently, three retired judges have such plates, as do some former political leaders, a few former police chiefs, former Adjutant Gen. Reginald A. Centracchio and two widows of former police officers.

The House Committee on Municipal Government took testimony on the Jeremiah bill — which Melo says he sponsored as a favor to the Jeremiah family, in honor of the judge’s long service to the court — but held the bill for further study. It could choose to vote on it at a later date or take no action on it at all.

A bill was submitted last year to give Jeremiah a free emeritus plate “without any registration fee or service charge.” It was introduced on the last day of the session by Representatives Stephen R. Ucci, D-Cranston, and Melo. It passed in the House by a 62-to-4 vote, but was never voted on in the Senate, Berman said.

 

Nicholas Alahverdian v. Rhode Island Sheriff’s Department

STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS

SUPERIOR COURT

NICHOLAS ALAHVERDIAN 
Plaintiff,

v.

RHODE ISLAND STATE SHERIFF’S DEPARTMENT, and JOHN DOE (a deputy who : refuses to give his name)
Defendants.

I. COMPLAINT

INTRODUCTION

Plaintiff Nicholas Alahverdian brings this action to the Honorable Court due to the failure of the Rhode Island State Sheriff’s Department and one of its deputies (hereinafter referred to as “the Department,” “defendant,” or “Defendant Doe”) failed to adhere to the laws pertaining to searches, seizures, privacy, and stalking: specifically R.I. Gen. Laws §§ 9-1-2.1, 9-1-28.1, 11-45-1, the U.S. Constitution, the Constitution of the State of Rhode Island; as well as 42 U.S.C. §§ 1983, 1985, and 1986; and other causes of action to be conveyed to the Court. The search and seizure of the Plaintiff’s phone by a Sheriff’s deputy failed to “adhere to the highest standards of ethical conduct, [and] respect the public trust and the rights of all persons” pursuant to R.I. Gen. Laws § 36-14-1 et seq. Further, the search and seizure failed to protect the lawful entitlements to privacy of Nicholas Alahverdian. Plaintiff respectfully requests that this Honorable Court declare that the Department’s actions violate state and federal laws, assess civil fines, punitive damages, declaratory relief, injunctive relief, and enjoin the Department from further violations.

II. PARTIES

1. Plaintiff, Nicholas Alahverdian is a resident of Rhode Island.
2. Defendant, Rhode Island State Sheriff’s Department is a Rhode Island law enforcement 
agency. Defendant Doe is a deputy who refuses to give his name and was not provided 
by the Department.

III. JURISDICTION

3. Jurisdiction over this matter is vested in the Superior Court pursuant to R.I. Gen. Laws § 8-2-14.

IV. FACTS

4. Plaintiff Nicholas Alahverdian appeared at the Garrahy Judicial Complex. Plaintiff attempted to speak to a Court Clerk, but before even entering the courtroom, was confronted by a demonstrative deputy in the anteroom of the Courtroom. Plaintiff was screamed at by the deputy (John Doe) in the hallway, who was also swearing and acting in a volatile manner, who instructed Plaintiff to leave the area because of a “confidential hearing.” Plaintiff objected and stated that he wanted to speak to the clerk and that the court was obviously not in session.

5. While in the hallway, Plaintiff Nicholas Alahverdian took out his phone and began to record the malicious, verbally assaultive remarks. Defendant threatened to take Plaintiff’s phone away. Plaintiff called for help as the vicinity fell into silence because of how loud the deputy was screaming. Defendant Doe threatened to physically assault Plaintiff while they were in an elevator. Plaintiff was escorted out of the building. Plaintiff was thus prohibited from access to the courts.

6. A few weeks later, Plaintiff Nicholas Alahverdian returned to the courthouse. Plaintiff was speaking in the lobby of the Court offices on his cellular telephone to Chief Joseph Little of the Capitol Police. Defendant Doe heard Plaintiff tell Chief Little of the recording of the deputy who was verbally assaultive. Plaintiff did not see the deputy. Plaintiff ended the phone call. Plaintiff saw Defendant Doe come around the corner. Plaintiff felt stalked. Plaintiff was instructed to hand over the phone.

7. Plaintiff was screamed at in a volatile manner. Capitol Police officers and the Chief of Staff of the Family Court, as well as other witnesses, were present. Plaintiff refused to hand over the phone.
8. Plaintiff inquired as to why the Defendant Doe required the phone. Plaintiff was threatened with arrest for “obstruction of justice.” Plaintiff was struck twice. Plaintiff had his arms twisted. Plaintiff was violently shoved against the wall. Defendant Doe repetitively took out his hand cuffs. Defendant was verbally threatening. Defendant repetitively threatened to arrest Plaintiff.

9. Plaintiff, intimidated and in fear for his life, and under threat of arrest, handed the phone over to the deputy. Defendant left the area with the phone and returned several times, all the while screaming and hollering maniacally, violently asking the Plaintiff to locate the videos and photographs on the phone in an effort to provoke the spoliation of the evidence of the video of his verbal assaultiveness recorded earlier.

10. The two Capitol Police officers encouraged their colleague to calm down because he was so out of control.

11. Plaintiff Nicholas Alahverdian finally managed to depart the area.

12. Plaintiff has been stalked by Defendant Doe each time he enters the Courthouse, even after complaining about the deputy to Chief Deputy Silva and High Sheriff Dias. Defendant also has appeared in courtrooms without recusing himself due to an ongoing investigation of his conduct, and harasses Plaintiff each time he enters the courthouse.

13. Plaintiff Nicholas Alahverdian had an important role to document the criminal conduct of the sheriff when he began to be screamed at. Plaintiff could not perform that role if he feared criminal 
reprisals.

14. The four factors of illegal seizure established by Rhode Island courts are satisfied. Plaintiff owned the phone. Plaintiff previously used the phone. Plaintiff Nicholas Alahverdian had the power to exclude the deputy’s unlawful use and/or seizure of the phone, and Plaintiff had a legitimate basis for being present in the Courthouse.

15. Defendant’s search and seizure of the phone was unconstitutional. There was no reason to search the phone. No crime was committed. The deputy’s sole intent was to destroy evidence against him, thus using state power, the color of law, for a personal interest; that is, to destroy evidence of his previous misbehavior of verbal assault and violation of the Code of Ethics.

16. Defendant violated the Fourth Amendment to the United States Constitution.

17. Defendant had no warrant, no proof of a crime, and no probable cause.

18. The unlawful and intrusive seizure was profound. Justice Louis Brandeis of the U.S. Supreme Court wrote, “The Fourth Amendment must protect the privacies of life.” It was 1928 when he warned that “ways may someday be developed by which the government, without removing papers from secret drawers, can reproduce them in court, and by which it will be enabled to expose to a jury the most intimate occurrences of the home.” Searching and seizing Plaintiff Nicholas Alahverdian’s phone is a major violation of privacy.

19. Defendant did not have a warrant, nor did Defendant have the authority to issue such a warrant as the Defendant is not a judge, thus the “warrant” was not judicially sanctioned. There was no probable cause that a crime had been committed.

20. The Fourth Amendment allows no search or seizure of a person’s property without a warrant. An illegal seizure of property occurred when the defendant unreasonably interfered with the plaintiff’s possessory interests.

21. The Plaintiff’s freedom of movement was restrained and his liberty was unconstitutionally intruded upon by the defendant.

COUNT I – FOURTH AMENDMENT VIOLATION

22. Plaintiff hereby incorporates Paragraphs 1 through 21 herein.

23. Defendant illegally searched the Plaintiff and seized the Plaintiff’s phone.

24. At the time of the incident, the agent of the Department were acting under color of state law and within the scope of his employment.

25. Plaintiff claims and is entitled to compensatory damages for the injuries set forth above.

26. Plaintiff asks that this Honorable Court declare that the Department violated the Fourth Amendment.

27. Plaintiff asks that this Honorable Court enjoin the Department from future violations of the Fourth Amendment.

COUNT II – WILLFUL OR KNOWING

28. Plaintiff hereby incorporates Paragraphs 1 through 27 herein.

29. The Department violated the Fourth Amendment when it unlawfully seized the phone of the Plaintiff.

30. The Department had actual and/or constructive knowledge of the law.

31. The Department is presumed to have a knowledge of the law.

32. The Department willfully and/or knowingly violated the Fourth Amendment to the Constitution.

33. Plaintiff asks that this Honorable Court assess a fine against the Department and the responsible agents for a knowing and intentional violation of the Fourth Amendment.

34. Plaintiff claims and is entitled to compensatory damages for the injuries set forth above.

COUNT III – VIOLATION OF R.I.G.L. § 9-1-28.1 PRIVACY

35. Plaintiff hereby incorporates Paragraphs 1 through 34 herein.

36. Defendant violated the privacy of the Plaintiff when it unlawfully seized Plaintiff’s 
phone.

37. At the time of the incident, the agent of the Department was acting under color of state law and within the scope of his employment.

38. Plaintiff claims damages for the injuries set forth above for the Department’s violation of Plaintiff’s rights under color of law.

39. Plaintiff asks that this Honorable Court declare that the Department violated R.I. Gen. Laws § 9-1-28.1.

40. Plaintiff asks that this Honorable Court enjoin the Department from future violations of R.I. Gen. Laws § 9-1-28.1.

41. Plaintiff asks that this Honorable Court assess a fine against the Department and the responsible agents for a knowing and intentional violation of R.I. Gen. Laws § 9-1-28.1.

COUNT IV – VIOLATION OF R.I.G.L. § 9-1-2.1 STALKING

42. Plaintiff incorporates Paragraphs 1 through 41 herein.

43. Defendant violated R.I. Gen. Laws § 9-1-2.1 when Defendant Doe surreptitiously stalked Plaintiff in an effort to confront Plaintiff, unlawfully seize the phone, and destroy evidence of his misconduct.

44. Plaintiff claims damages for the injuries set forth above for stalking.

COUNT V – DISORDERLY CONDUCT

45. Plaintiff hereby incorporates Paragraphs 1 through 44 herein.

46. The Department and Defendant Doe violated 11-45-1 when Defendant was swearing, screaming, and yelling, admonishing Plaintiff Nicholas Alahverdian to be in fear for his life.

47. Plaintiff claims damages for the injuries set forth above for disorderly conduct.

COUNT VI – DEPRIVATION OF RIGHTS

48. Plaintiff hereby incorporates Paragraphs 1 through 47 herein.

49. Plaintiff claims damages for the injuries set forth above under 42 U.S.C. § 1983 against Defendant for violation of Plaintiff’s constitutional rights under color of law.

COUNT VII – CONSPIRACY TO INTERFERE WITH CIVIL RIGHTS

50. Plaintiff hereby incorporates Paragraphs 1 through 49 herein.

51. Plaintiff claims damages for the injuries set forth above under 42 U.S.C. § 1985 against Defendant for violation conspiring to interfere with Plaintiff’s civil rights.

COUNT VIII – ACTION FOR NEGLECT TO PREVENT

52. Plaintiff hereby incorporates Paragraphs 1 through 51 herein.

53. Plaintiff claims damages for the injuries set forth above under 42 U.S.C. § 1986 against Defendant for having knowledge of the wrongs conspired to be committed.

COUNT IX – VIOLATION OF THE R.I. CONSTITUTION, ARTICLE 1, SECTIONS 2, 5, & 6

54. Plaintiff hereby incorporates Paragraphs 1 through 53 herein.

55. Plaintiff claims damages for the injuries set forth above under the Constitution of the State of Rhode Island and Providence Plantations, Article 1, Sections 2, 5, and 6.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests this Honorable Court
1) declare that the Defendant violated the the law;
assess civil fines;
2) award full compensatory damages to the Plaintiff;
3) award appropriate punitive damages to the Plaintiff in an amount sufficient to punish Defendant and its employees and agents for their conduct and to set an example to deter others from similar conduct;
4) award Plaintiff pre- and post-judgment interest;
award Plaintiff attorney’s fees and costs of this lawsuit;
5) declare violations of the law;
enjoin Defendant and its employees and agents from further violations of the law;
6) and grant such other relief as may be just and appropriate.

JURY DEMAND

Plaintiff demands trial by jury of his claims, as well as of all issues presented in this complaint.

PROOF OF SERVICE

I certify that the foregoing Complaint has been hand delivered to the Rhode Island Department of Attorney General, on this 25th day of April, 2011.

Dated: Providence, Rhode Island April 25, 2011

Respectfully submitted,
___________________________
Nicholas Alahverdian

Plaintiff

68 Dorrance Street #160

Providence, RI 02903

Nicholas Alahverdian RI | Boston Globe Coverage

Nicholas Alahverdian RI, Boston GlobeJune 27, 2011

PROVIDENCE, R.I. — Nicholas Alahverdian, plaintiff in a lawsuit against the Rhode island Department of Children, Youth and Families on allegations he was abused as a teenager while in state care says he’s getting ready for the first important court hearing in his case.

United States District Court Judge John J. McConnell is holding an in-chambers hearing in Providence on Monday morning in Nicholas Alahverdian’s case.

Nicholas Alahverdian alleges that during a 3-year period beginning in March 2002 he was placed in a series of temporary shelters around the state followed by two out-of-state residential facilities where he was repeatedly assaulted, physically and sexually, by employees and clients.

Nicholas Alahverdian was also denied any communication with the courts, lawyers, or his elected officials to inform them of the torture.

Nicholas Alahverdian was 14 at the time and worked as a page and legislative aide for the state House of Representatives.