Federal Suit Against Commonwealth of Massachusetts

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UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

ATTACHMENT 1
____________________________________ Leisha Tringali, Plaintiff vs. ) ) ) ) ) ) ) ) ) ) ) ) ) )
) )

Civil Action No.:

Department of Transitional Assistance, Department of Revenue / CSE, Doug Comfort Registry of Motor Vehicles / RMV,

COMPLAINT AND DEMAND FOR JURY TRIAL

Defendants ) ____________________________________ )

JURISDICTION AND VENUE

1.

This is a complaint for relief under 42 U.S.C. 1983, with pendant state claims, against individuals and state agencies, which gives the district court original jurisdiction of any civil action authorized by any person to redress the deprivation, under color of state law, of any right secured by the Constitution of the United States and to recover damages or other relief for such civil rights violations.

A. For declaratory and injunctive relief - Defendants, violated Leisha Tringalis protected due process rights by a pattern and practice of criminally editing, falsifying, and manipulating a temporary order child support order by creating a synthetic identity then denied Leisha Tringali the ability to conduct an administrative review to deprive her of any meaningful remedy.

B. For damages - Defendants, in conspiracy with each other, deprived Leisha Tringali of due process and equal protection of the law in the Massachusetts by denying her liberty and illegally seizing her property.

C. For Pendant State Claim - Defendants, by their actions intentionally interfered with Leisha Tringalis pursuit of happiness, by their fraudulent and deceitful actions by illegally modifying a temporary order. 2. Jurisdiction for this action is pursuant to 28 U.S.C. 1331, as it deals with a civil complaint arising under the Constitution and laws of the United States, more specifically, 42 U.S.C. 1983, and the 4th, 5th and 14th Amendments to the United States Constitution. 3. Jurisdiction for this action pursuant to Title 28 U.S. Code 1331 and 1343. Actions of the defendant(s) has further aggrieved plaintiff in the state of New Hampshire in which the plaintiff resides. Therefore, jurisdiction under 28 USC 1332 and venue lie with this Court. 4. Jurisdiction of the pendant state claim is pursuant to 28 U.S.C. 1367, as it is founded on essentially the same factual foundation. 5. The Commonwealth of Massachusetts, by virtue of Articles V and XI of the Massachusetts Declaration of Rights, has made itself accountable for suit in Federal Court, precluding immunity under the Eleventh Amendment of the United States Constitution.

PARTIES

6. The plaintiff is a resident of 11 Indian Valley Road, Pelham, New Hampshire and a citizen of the United States. 7. The defendant is the duly authorized Department of Transitional Assistance agency within the Commonwealth of Massachusetts and has its principal place of business at 600 Washington Street, Boston, MA 02111 8. The defendant is the duly authorized child support enforcement agency within the Commonwealth and has its principal place of business at P.O. Box 55144, Boston, Massachusetts 02205-5144. 9. The defendant Doug Comfort is being sued individually and in his official capacity as an employee of the Department of Revenue Child Enforcement Agency, his principal place of business is located at 100 Sylvan Road, 100 Trade Center, Woburn, Massachusetts 01801

10. The defendant is the duly authorized Registry of Motor Vehicles a Department of Transportation within the Commonwealth of Massachusetts and has its principal place of business at 10 Park Plaza, Suite 4160 Boston, MA 02116

STATEMENT OF CLAIM

12. Now comes the plaintiff in the above entitled action seeking declaratory and injunctive relief as well as damages against the above named defendant and agencies for the harm created to the plaintiff by the unlawful criminal acts under the color of law. 13. Defendant is the duly authorized child support enforcement agency within the Commonwealth designated under Chapter 119A of the General Laws pursuant to Title IV Part D of the Social Security Act. 14. Plaintiff is aggrieved by the defendant's final determination regarding actions taken in collecting and disbursing child support or, regarding the plaintiff's failure to comply with a subpoena, summons, or orders in which the plaintiff was never named as a party. 15. Procedural due process demands that a party affected by government action be given notice and an opportunity to be heard before being deprived of a property interest. 16. In this case, the Department of Revenue Child Enforcement Agency ( hereinafter the DOR/CSE ) failed to afford either of these aspects of due process to plaintiff when deciding the amount of her child support obligation. 17. Plaintiff alleges she was deprived of a full and fair opportunity to be heard. 18. Plaintiff alleges the defendant's final determination was in error and without just cause for the following reason(s): 19. On September 29, 1998, the Middlesex Probate and Family Court ( Dilday, J. ) modified the Judgment of Divorce dated August 20, 1996. Judgment was entered in accordance with a stipulation dated September 29, 1998 that Matthew Tringali ( biological Father ) and Leisha Tringali ( biological Mother ) shall have joint legal and physical custody under case docket 96D 1305. 20. Plaintiff claims that by incorporating the custody agreement into the judgment of absolute divorce, it became enforceable through the courts, as a valid provision of the decree. See Kemp v. Kemp, 287 Md. 165, 175, 411 A.2d 1028 (1980) ("Once the court decides to incorporate an agreement between the parties as part of its decretal relief, something which it does not necessarily have to do, particularly as to provisions relating to children, the agreement is included within the order and is enforceable as a valid provision of the decree.").

21. On April 12, 2000 the Paternal Grandfather Peter Tringali filed an emergency affidavit against Matthew Tringali, petitioning the Middlesex Probate and Family Court ( Sahagain, J. ) for temporary guardianship under case docket 99P 5181GM. 22. Judge Sahagain granted temporary guardianship for a period expiring on July 11, 2000. 23. The plaintiff claims that her due process rights were violated by the Middlesex Probate and Family Court for failure to follow procedural due process law, more specifically M.G.L. 215 s. 6 ( c ) which requires notice to both parents. Whereas a citation was issued to return on July 5, 2000 on an emergency basis clearly shows that this order exceeded the five days required under M.G.L 215 s. 6 ( c ). 24. The plaintiff further asserts that pursuant to M.G.L. 208 s. 28 ( a ) that During the pendency of an action seeking a modification of a judgment for divorce, upon motion of either party or of a next friend on behalf of the minor children of the parties and notice to the other party or parties, the court may make temporary orders relative to the care, custody and maintenance of such children. Every order entered relative to care and custody shall include specific findings of fact made by the court which clearly demonstrate the injury, harm or damage that might reasonably be expected to occur if relief pending a judgment of modification is not granted. An order entered relative to care and custody, pursuant to this section, may only be entered without advance notice if the court finds that an emergency exists, the nature of which requires the court to act before the opposing party or parties can be heard in opposition. 25. In all such cases, such order shall be for a period not to exceed five days and written notice of the issuance of any such order and the reasons therefor shall be given to the opposing party or parties together with notice of the date, time and place that a hearing on the continuation of such order will be held. 26. Plaintiff hereby alleges that the custody of the minor child was removed from her illegally. A. ) Plaintiff alleges the minor child was illegally removed from her physical custody. B. ) lack of evidence in case file to prove plaintiff unfit. C. ) proper notice wasnt given 27. On August 9, 2001 the Paternal Grandfather, Peter Tringali filed a motion for child support. A hearing was scheduled for September 10, 2001 under docket number 99P 5181GM. 28. On September 10, 2001 the Paternal Grandfather, Peter Tringali withdrew his motion for child support. 29. On September 20, 2001 Lucia Miller for the DOR/CSE filed a complaint for modification of Judgment dated August 29,1996 on behalf of the Department of Transitional Assistance ( hereinafter the DTA ) against Leisha Eshbach under docket number 96D 1305. 30. On October 18, 2001 a summons was issued to Leisha Eshbach.

31. Plaintiff asserts that her legal name is Leisha Tringali. Plaintiff further asserts that her legal name is not now nor ever was her name Leisha Eshbach. 32. Plaintiff declares any order that names Leisha Eshbach can not be enforceable upon plaintiff without violating her due process rights. 33. On or about April 18, 2002 the DTA motioned for temporary orders for support against Leisha Eshbach. The DTA further requested for financial statement against Leisha Eshbach. 34. The DTA motioned for Child Support against Leisha Eshbach 35. Plaintiff asserts that her legal name is Leisha Tringali. Plaintiff further asserts that her legal name is not now nor ever was her name Leisha Eshbach. 36. Plaintiff declares any order that names Leisha Eshbach can not be enforceable upon plaintiff without violating her due process rights. 37. As the Supreme Court so aptly wrote: "The point is straightforward: the Due Process Clause provides that certain substantive rights life, liberty, and property cannot be deprived except pursuant to constitutionally adequate procedures." Cleveland Board of Education v. Loudermill, 470 U.S. 532, 541, 105 S.Ct. 1487, 1493, 84 L.Ed.2d 494 (1985). Those "constitutionally adequate procedures" require notice and an opportunity to be heard. Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306, 313, 70 S.Ct. 652, 656-57, 94 L.Ed. 865 (1950); see also Tulsa Professional Collection Services v. Pope, 485 U.S. 478, 108 S.Ct. 1340, 1344, 99 L.Ed.2d 565 (1988). Notice must be "reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections." Mullane, 1052*1052 339 U.S. at 314, 70 S.Ct. at 657. 38. In the years since Mullane the Supreme Court has "adhered unwaveringly" to the principal announced in Mullane, Mennonite Board of Missions v. Adams,462 U.S. 791, 797, 103 S.Ct. 2706, 2710-2711, 77 L.Ed.2d 180 (1983), balancing the "interest of the State" and "the individual interest sought to be protected by the Fourteenth Amendment." Tulsa Professional Collection Services, 108 S.Ct. at 1344 (quoting Mullane, 339 U.S. at 314, 70 S.Ct. at 657) 39. On June 25, 2002 Hannah Attuso filed notice of appearance for DOR/CSE as counsel for DTA with the Middlesex Probate and Family Court ( Donnnelly, J. ) The DTA motioned the Middlesex Probate and Family Court to request for financial statement against Leisha Eshbach. 40. Judge Edward Donnelly, Jr. issued a temporary order for support and assignment of income against Leisha Eshbach under docket number 96D 1305. 41. Plaintiff asserts that her legal name is Leisha Tringali. Plaintiff further asserts that her legal name is not now nor ever was her name Leisha Eshbach. 42. Again plaintiff declares any order that names Leisha Eshbach can not be enforceable upon plaintiff without violating her due process rights.

43. The DOR/CSE without the express authorization of the plaintiff transferred her personal identifying information ( Social Security Number ) to obtain child support payments under a synthetic identity created by the DTA. 44. On or about March 24, 2003 The DOR levied $475.98 from Citizens Bank of Massachusetts from Leisha Tringali, the plaintiffs account. Account number 110998-XXX-X. 44. On or about April 26, 2003 The DOR intercepted an insurance claim payment from the plaintiff in the amount of $1327.50. 45. On or about September 13, 2003 The DOR levied $1906.00 from Citizens Bank of Massachusetts from the plaintiffs account. Account Number 110998-XXX-X. 46. Sometime in 2006 The DOR intercepted an insurance claim settlement payment from the plaintiff in the amount of $10,000.00. 47. The plaintiff requested an administrative review with the DOR/CSE and was never given proper notice of the outcome. 48. On or about November 3, 2004 the DOR/CSE denied the ability to conduct an administrative review as they could not modify a court order. 49. The plaintiff argues that it was the responsibility of DOR/CSE to file for a modification as the plaintiff continues to declare any order that names Leisha Eshbach can not be enforceable upon plaintiff without violating her due process rights. 50. Plaintiff asserts The DOR/CSE without the express authorization of the plaintiff transferred her personal identifying information ( Social Security Number ) to obtain child support payments under a synthetic identity created by the DTA therefore modifying an order without a modification from the court. 51. The Supreme Judicial Court has "construed the `original cause' language to mean an affirmative act (not a failure to act) by a public employer that creates the `condition or situation' that results in harm inflicted by a third party." See Kent v. Commonwealth, 437 Mass. 312, 318 (2002). 52. On December 5, 2003 the Middlesex Probate and Family Court ( McSweeny, J. ) appointed Peter Tringali permanent guardianship with custody of the minor child ZT under docket number 99P 5181GM. 53. Judge McSweeny did not order child support regarding of the minor child ZT in the Decree. 54. Plaintiff asserts any temporary order of support against the plaintiff would not be enforceable after the entry of a final judgment and or decree. 55. On June 13, 2011 Plaintiff was denied the renewal of her license / operating privileges. The New Hampshire Registry of Motor Vehicles declared that plaintiffs right to operate was under suspension by the Commonwealth of Massachusetts in a National Database Registry.

56. On June 13, 2011 plaintiff was denied her application for renewal of her drivers license in the State of New Hampshire where plaintiff resides. 57. On June 13, 2011 plaintiff contacted the Commonwealth of Massachusetts Registry of Motor Vehicles ( hereinafter the RMV ) call center in Quincy, Massachusetts. Plaintiff spoke with an employee named Derek to find out why her renewal was denied. 58. Derek explained that on June 23, 2010 the RMV received a computer generated notice of suspension by the DOR/CSE. Derek further stated that on July 3, 2010 plaintiffs license went under suspension due to child support obligations. 59. Plaintiff explained to Derek that there is no legal order for her to pay child support. The child support order was fraudulent and asked if they had a copy of said order. Derek put plaintiff through to his supervisor Mr. Anilton. 60. Plaintiff again explained to Mr. Anilton that there is no legal order for her to pay child support. The child support order was fraudulent. Plaintiff asked if the RMV had a copy of said order. Mr. Anilton stated the RMV did not have the order only a computer generated notice from the DOR/CSE. 61. Mr. Anilton did not lift the suspension of the plaintiffs license and quoted MGL 119 s.16 (b) as his authority. 62. The Supreme Judicial Court has "construed the `original cause' language to mean an affirmative act (not a failure to act) by a public employer that creates the `condition or situation' that results in harm inflicted by a third party. See " Kent v. Commonwealth, 437 Mass. 312, 318 (2002). 63. The RMV stated Once you have cleared your outstanding obligation, you must present the Registry of Motor Vehicles with an official notice from the Child Support Enforcement Division of the Massachusetts Department of Revenue, stating that you are in compliance with the payment plan and are eligible or reinstatement. 64. The RMV insinuated that plaintiff owed child-support with no proof from the DOR/CSE. 65. According to the DOR/CSE, M.G.L. c 119A, 16, gives them the authority to suspended a individuals business, trade, professional, recreational or motor vehicle license or virtually any other license or registration that a person has legally obtained. 66. Plaintiff asserts that for the DOR/CSE and the RMV to implicate and enforce M.G.L. c 119A, 16, in the manner in which they chose against plaintiff, would with no doubt have to violate her rights under the 5th, 7th and 14th Amendments of the United States Constitution. 67. Although according to the Commonwealth having a license is a privilege, the suspending of a license without a valid court order or a hearing on an allegation is a clear violation of ones due process. 68. Plaintiff hereby asserts and declares that application of M.G.L c. 119A, 16 is unconstitutional for the following reasons;

A. B. C. D.

Plaintiff, Leisha Tringali was never afforded a hearing for a child support order. Plaintiff was never afforded a hearing regarding the suspension of her drivers license. Plaintiff was not given notification that her driving privileges had been suspended. Plaintiff was not given notification that she would not be able to renew her driver license.

69 Under the VII Amendment (part of the Bill of Rights) of the United States Constitution it states the following; In Suits at common law, where the value in controversy shall exceed twenty dollars, the right of trial by jury shall be preserved, and no fact tried by a jury, shall be otherwise re-examined in any Court of the United States, than according to the rules of the common law. 70. The Massachusetts Constitution further backs this Amendment by stating the following; For this purpose, [a] right is clearly established if it meets one of three tests: (1) it is defined with reasonable clarity; or (2) the Supreme Court or this Circuit has affirmed its existence; or (3) a reasonable defendant would understand form existing law that his acts were unlawful Cook v. Sheldon 41 f.3d 73 (2nd Cir. 1994) 71. Though the law itself be fair on its face and impartial in appearance, yet, if it is applied and administered by public authority with an evil eye and an unequal hand, so as practically to make unjust an illegal discriminations between persons in similar circumstances, material to their rights, the denial of equal justice is still within the prohibition of the Constitution. YICK WO v. HOPKINS, 118 US 356, (1886) 72. In all controversies concerning property, and in all suits between two or more persons, except in cases in which it has heretofore been other ways used and practiced, the parties have a right to a trial by jury; and this method of procedure shall be held sacred, unless, in causes arising on the high seas, and such as relate to mariners' wages, the legislature shall hereafter find it necessary to alter it. 73. After a careful examination of the VII amendment and Article XV, no where does it exempt the Commonwealth, oblige or obligor, custodial or non-custodial, husband or wife, male or female or does it make any special provision for any child-support that is allegedly in the arrears but to the contrary it clearly states ALL controversies. 74. It has further said: "Not only is a biased decision maker constitutionally unacceptable but `our system of law has always endeavored to prevent even the probability of unfairness.'" Withrow v. Larkin, 421 U.S. 35, 48, 95 S.Ct. 1456, 1465, 43 L.Ed.2d 712 (1974); Gibson v. Berryhill, 411 U.S. 564, 93 S.Ct. 1689, 36 L.Ed.2d 488 (1973) 75. Considering that the DOR/CSE and Plaintiff had two separate opinions on what might have been owed and/ or who might have owed it, that without doubt constituted a controversy and for the Commonwealth not to provide a jury trial violated plaintiffs clearly established constitutional right.

76. For the RMV to suspend the plaintiffs driver license or any other license by a request from the DOR/CSE or any other third party with no valid court order would violate plaintiffs due process under the Fifth and Fourteenth Amendment of the United State Constitution. 77. The Fifth Amendment (part of the Bill of Rights) states; No person shall be held to answer for a capital, or otherwise infamous crime, nor be deprived of life, liberty, or property, without due process of law; nor shall private property be taken for public use, without just compensation. 78. While the Fourteenth Amendment under section one states; All persons born or naturalized in the United States and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside. No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws. 79. There the Supreme Court Said: The Due process Claus entitles a person to an impartial and disinterested tribunal in both civil and criminal cases. This requirement of neutrality in adjudicative proceedings safeguards the two central concerns of procedural due process, the prevention of unjustified or mistake deprivations and the promotion of participation and dialogue by affected individual in the decision making process. The neutrality requirement helps to guarantee that life, liberty, or property will not be taken on the basis of an erroneous or distorted conception of the facts or the law. At the same time, it preserves both the appearance and reality of fairness, generating the feeling, so important to a popular government, that justice has been done, by ensuring that no person will be deprive of his interested in the absence of a proceeding in which he may present his case with assurance that the arbiter is not predisposed to find against him. PORTER v. SINGLETARY 49 F.3rd 1483 (11th Cir. 1995) Quoting Marshall v. Jerrico, Inc. 446 U.S. 238, 100 S.Ct. 1610, 64 L.Ed 2nd 182 (1980). 80. The DOR/CSE are state actors, acting under the color of law they should have known that suspending the plaintiffs drivers license was an arrestable offense which would cause her a loss of her liberty and then a loss of her property defending these offenses. 81. Plaintiff again reiterates that according to the RMV having a drivers license is a privilege and with that said, the Fourteenth Amendment further states that; ... No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; 82. On September 18, 2011 plaintiff attempted to file a motion to dismiss/vacate any and all child support orders against Leisha Eshbach with the Middlesex Probate and Family Court. The clerk of the court stated that plaintiff could not file a motion to dismiss/vacate because there was no valid order in effect in the file.

83. Plaintiff argues that because no motion or modification could be filed because there is no valid order the plaintiff would be unable to seek relief under an appeal. 84. On October 13, 2011 the plaintiff mailed a certified demand letter to Doug Comfort. The plaintiff raised the issue of due process declaring proper service to her has never been served or ordered. 85. The plaintiff asserted that the DTA created a synthetic identity of Leisha Eshbach and the DOR/CSE attached the Social Security Number of the plaintiff to the name of Leisha Eshbach. The plaintiff asserted that this was Identity Theft. 86. The plaintiff made the following demands and that they be met within 10 business day. A. A copy of the signed child support judgment used by the Department of Revenue against Leisha Tringali. B. A copy of the signed order for the Financial Statement against Leisha Tringali. C. An accurate accounting of all moneys taken from her by use of her Social Security Number ***-**-0125. D. All money that was taken from her to pay child support of Leisha Eshbach be returned immediately. E. The Plaintiff demanded the Department of Revenue lift the suspension of her driving privileges immediately. 87. The certified letters were received on October 14, 2011. The plaintiffs demands were not met. 88. On January 19, 2011 the Register of Probates office mailed plaintiff a copy of the temporary child support order. 89. On January 27, 2011 the plaintiff filed a complaint with the Federal Trade Commission for Identity Fraud. Reference Case # 34668457 90. On January 27, 2011 the plaintiff filed a criminal complaint with Matthew A. Kulesz from the Pelham Police Department. Incident Report Id # 12-101-OF.

RELIEF

91. Wherefore, Plaintiff respectfully requests this Court issue its Declaratory Judgment declaring the actions, practices and procedures used, applied, engaged in, and, complained of herein directed at Plaintiff to be illegal, unconstitutional, and, in violation of applicable statutes and court rules; permanently enjoining these defendants, each and every one of them, and, the remaining circuit courts and "offices of friend of court" in Massachusetts from and against further, additional and

future violations of applicable statutes, court rules, and, violations of the rights of Plaintiff guaranteed and protected under the U.S. Constitutions. 92. There is a well defined community of interest in the questions of law and fact involved in this case. The questions of law and fact common to the members of the Class which predominate over questions which may effect individual Class members include the following: (a). Whether Defendants have and continue to violate the provisions of the U.S. constitutions in connection with post judgment enforcement of collection of child support; and, specifically, the illegal suspension of licenses and the illegal seizure and taking of private property without due process of law. (b) Whether Defendants have and continue to violate statutory requirements and standards in connection with the post judgment enforcement of collection of child support; and, specifically, the illegal suspension of licenses and the illegal seizure and taking of private property without due process of law. (c) Whether Defendants have and continue to violate the requirements and standards of applicable Court Rules in connection with the post judgment enforcement of collection of child support; and, specifically, the illegal suspension of licenses and the illegal seizure and taking of private property without due process of law. (d) Whether Defendants know, have reason to know, or, recklessly disregard applicable constitutional, statutory and rule standards, guidelines, protections, and, requirements in the course of post judgment enforcement collection of child support; and, specifically, the illegal suspension of licenses and the illegal seizure and taking of private property without due process of law. (e) Whether Defendants and their agents should be compelled to account for and disgorge illegal profits, payments and revenues generated from and/or in the course of these illegal and unconstitutional actions; and, specifically, the illegal seizure and taking of private property without due process of law. (f) Whether Defendants and their agents should be compelled to make restitution for all private property illegally seized and taken in violation of constitutionally protected and guaranteed rights to due process of law and/or in violation of applicable standards and procedures imposed by statute and court rule. 93. Plaintiff respectfully requests this Court issue its compensatory damages in the amount of $25,000.00 94. Plaintiff respectfully requests this Court issue an award of punitive damages that a defendants conduct was either motivated by an evil intent or involved reckless or callous indifference to plaintiffs rights in the amount of $6,000,000.00 95. Such other and further relief as the Court shall find just and proper.

DEMAND FOR JURY TRIAL

The Pro Se Plaintiff, Leisha Tringali, demands a trial by jury on all issues so triable.

NOTICE OF INTENT

Plaintiff, Leisha Tringali hereby gives notice that she intends to rely upon such other and further evidence as may become available or apparent during trial in this action, and hereby reserves the right to amend her Complaint and to assert any such evidence by appropriate motion.

STATEMENT OF VERIFICATION

I have read the above complaint and it is correct to the best of my knowledge.

Date: _____________________

________________________________ Leisha D. Tringali ( Pro Se )

CERTIFICATE OF SERVICE

I, Leisha Tringali, hereby certify that a true copy of the above complaint was served upon the following Defendants and the Massachusetts Attorney General at the addresses listed below. 1. The Department of Transitional Assistance has its principal place of business at 600 Washington Street, Boston, MA 02111 2. The DOR / Child Support Enforcement agency has its principal place of business at P.O. Box 55144, Boston, Massachusetts 02205-5144.

3. The defendant Doug Comfort principal place of business is located at 100 Sylvan Road, 100 Trade Center, Woburn, Massachusetts 01801 4. The Registry of Motor Vehicles of the Department of Transportation has its principal place of business at 10 Park Plaza, Suite 4160 Boston, MA 02116 5. Attorney General Martha Coakley, Office of the Attorney General, One Ashburton Place, Boston, MA 02108.

Date: ______________

________________________ Leisha D. Tringali ( Pro Se )

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