CRIMINAL COMPLAINT: OVERT ACT ONE

SUBJECT: Interstate Parental Kidnapping, Conspiracy, and Obstruction of Justice

DATE OF INCIDENT: April 19, 2024

FEDERAL STATUTES: 18 U.S.C. § 371 (Conspiracy); 18 U.S.C. § 1201 (Kidnapping); 18 U.S.C. § 1204 (Parental Kidnapping)

I. COUNT ONE: CONSPIRACY TO COMMIT INTERSTATE KIDNAPPING

18 U.S.C. §§ 371, 1201, 1204

1. The Primary Overt Act (April 19, 2024)

On April 19, 2024, Allison Thomas (Mother) did willfully and unlawfully abduct the minor child (A.T.) from T.A. Lowery Elementary School in West Virginia. This act was executed for the express purpose of preventing the child’s scheduled transport to the Father’s custody in the Home State of Maryland.

  • Circumstances of Abduction: The Father arrived at the school to exercise his court-ordered parenting time and transport the child home to Maryland. The Mother, aware of the Father’s arrival, removed the child prematurely under the guise of an “emergency,” initiating a continuous criminal withholding that has now exceeded 500 days.
  • Due Process Deprivation: For over 500 days, the Father has been deprived of his parental rights and liberty without due process, with no findings of guilt, and in direct contradiction to the “Full Faith and Credit” of Maryland CPS findings, which had already deemed the allegations “unsubstantiated.”
  • Fraudulent Inducement of Police: To facilitate the abduction and prevent law enforcement from returning the child, the Mother provided sworn false statements to Deputy Ty Carroll. Per the Jefferson County Police Report (24SO07836), she claimed a doctor had “verified” signs of sexual abuse and that a Maryland CPS case prohibited the Father’s access.
  • Corroborating Testimony (Aug 6, 2025): During the August 6, 2025, adjudication hearing, Deputy Ty Carroll testified that the Mother provided these specific narratives to justify the school removal. This testimony confirms the Mother was manufacturing a “medical emergency” in real-time to obstruct the Father’s lawful custody.

2. Evidence of Premeditation and Prior Pattern (2023–2024)

The April 19, 2024, abduction was the culmination of a multi-year campaign of “litigation terrorism” and custodial interference.

  • The “Weekly Allegation” Scheme: Records indicate the Mother utilized a pattern of making false abuse accusations nearly every week the Father was scheduled for custody, totaling over 50 false allegations.
  • Exploitation of Medical Vulnerability (Stroke Recovery): Exactly one year prior to the April 19 abduction, while the Father was recovering from a stroke and required 24/7 monitoring, the Mother filed a False Protective Order and removed the child from the jurisdiction against the custody agreement.
  • Supervised Visit Malice: For the first six months of the Father’s recovery, his visitations were fully supervised. Despite the constant presence of neutral third-parties, the Mother continued to manufacture accusations, proving the allegations were independent of any actual opportunity for abuse.
  • The Recantation: Both the Mother and the child subsequently recanted the 2023 allegations, establishing a forensic history of utilizing manufactured crises.

II. FEDERAL JURISDICTIONAL VIOLATIONS (PKPA & UCCJEA)

  • Defiance of Maryland Orders: The April 19 abduction nullified the March 12, 2024, Maryland Consent Custody Order, which had settled the matter and established a lawful visitation schedule.
  • Jurisdictional Anarchy: The West Virginia investigation began over 500 days ago in a county where the Father has never set foot, highlighting the fraudulent nature of the jurisdictional claim.
  • The ICPC “Trojan Horse”: By using a limited Maryland “Courtesy Referral” (#443975) as a means to seize the child, the Mother and West Virginia Respondents bypassed the PKPA (28 U.S.C. § 1738A).

III. EVIDENTIARY PROOFS
Evidence Source Fact Established
MedStar Report (4/8/24) pH 7.0 and medical denial of abuse; proves the 4/19 report to police was a lie.
Jefferson County Police Report (24SO07836) Documents Mother’s false claims to Deputy Carroll regarding “doctor-verified” abuse.
Deputy Testimony (Aug 6, 2025) Deputy Carroll’s sworn testimony confirming the Mother’s fraudulent narratives on 4/19.
WV State/County Criminal Complaints Formal complaints filed by Father for abduction and fraud (Case #240515-053), which were ignored by the state.
Sept 8 Testimony Mother admitted she had no knowledge of abuse until 4/26, proving the 4/19 report was fraudulent.
Maryland MD Findings Maryland CPS “Unsubstantiated” finding and settled court-ordered visitation.
Supervision Records Proves Mother made abuse claims even during 6 months of 100% supervised visitation.

IV. CRIMINAL IMPLICATIONS

Under 18 U.S.C. § 1204, it is a federal crime to detain a child outside of their home state with the intent to obstruct parental rights. The Mother’s coordinate use of false medical narratives to prevent the child’s return to Maryland custody satisfies the “intent” element. The systematic concealment of these facts by West Virginia officials transforms a parental kidnapping into a State-Sanctioned Conspiracy (18 U.S.C. § 371).

V. CONCLUSION

The April 19, 2024, abduction was a calculated felony executed by exploiting a prior pattern of jurisdictional fraud. By ignoring the Deputy’s testimony, the 500-day deprivation of rights, the settled Maryland orders, and the April 8 medical exoneration, the State of West Virginia has become an accessory to Interstate Parental Kidnapping.****