Scribd Logo
Unggah

Selamat datang di Scribd!

  • Complaint

    Diunggah oleh

    Kaluminated1
    45 tayangan15 halaman
    Defendants have altered the Plaintiff's offense description by purposely employing the language and description of a child molestation statute. The sheer length of time the Defendant have been aware of the alteration and the harm it has caused the Plaintiff is an abuse in and of itself. The Defenders continue to publish and disseminate and use the alteration against the Plaintiff in Parole Hearings and purposely mislead the public and officials alike.

    Deskripsi Asli:

    Hak Cipta

    © Attribution Non-Commercial (BY-NC)

    Format Tersedia

    PDF atau baca online dari Scribd

    Apakah menurut Anda dokumen ini bermanfaat?

    Apakah konten ini tidak pantas?

    Laporkan Dokumen Ini
    Defendants have altered the Plaintiff's offense description by purposely employing the language and description of a child molestation statute. The sheer length of time the Defendant have been aware of the alteration and the harm it has caused the Plaintiff is an abuse in and of itself. The Defenders continue to publish and disseminate and use the alteration against the Plaintiff in Parole Hearings and purposely mislead the public and officials alike.

    Hak Cipta:

    Attribution Non-Commercial (BY-NC)
    Unduh sebagai PDF atau baca online dari Scribd
    Tandai sebagai konten tidak pantas
    45 tayangan15 halaman

    Complaint

    Diunggah oleh

    Kaluminated1
    Defendants have altered the Plaintiff's offense description by purposely employing the language and description of a child molestation statute. The sheer length of time the Defendant have been aware of the alteration and the harm it has caused the Plaintiff is an abuse in and of itself. The Defenders continue to publish and disseminate and use the alteration against the Plaintiff in Parole Hearings and purposely mislead the public and officials alike.

    Hak Cipta:

    Attribution Non-Commercial (BY-NC)
    Unduh sebagai PDF atau baca online dari Scribd
    Tandai sebagai konten tidak pantas
    dari 15
    UNITED STATE DISTRICT COURT DISTRICT OF MASSACHUSETTS KEITH. PHILLIPS, PRO SE PLAINTIFF, v. MASSACHUSETTS PAROLE BOARD, MARK A. ‘CONRAD, ROGER MICHEL, CEASAR ARCHILLA, LETICIA MUNOZ, CANDANCE KOCUIN, THOMAS MERRIGAN, PAMELA LOMBARDIN individvally nd in their capacity a5, ‘members ofthe Massachusetts Parole Board; SHEILA HUBBARD, MICHAEL POMAROLE, MAUREEN WALSH, individually and inthe capacity as former members ofthe Massachusets Parole Botcd; MARK DASNEVES, DONNA FENTIMAN, MARCIA CURTAIN, MARCIA HILL CONCETTA TRIFONE, individually and in ‘het capacity assaf offical f the Massachusets Parole Board OMPLAIN] CIVIL ACTIONNo#_ JURY TRIAL DEMANDED DEFENDANIS, Plaintiff Keith L. Phillipson bealf of himself and for his verified complaint against Defendant Massachusetts Parole Board ("Parole Board”) and Parole officials (collectively, “Defendants alleges: PRELIMINARY STATEMENT. 1. Defendants have altered the Plaintiffs offense description by purposely employing the language and desription of child molestation statute in place ofthe language and description of the statute the Plaintiffs convicted of. Th immediate effet ofthis tration woud bo to erroneously convert the Plait’ offense into that ofa child molestation offense. 2. Defendants alteration of the Plaintifs offense is no mere clerical eror of litle ono consequence. The sheer length of ime the Defendans have been aware ofthe alteration and the harm ithas caused the Paif san abuse inand of iste, 3, Defendants have previously admitted othe existence ofthe alteration and in conjunt with ther admission, ‘Defendants —nonsensially “amended” caly one document type instead of the Paints catire Parole file, This ‘obviously let the source ofthe alteration unaddressed, 4. The Defendants officially acknowledged the alteration, and di not excise the Plant of ts damaging ‘existence, The Defendants continue to publish and disseminate and use the alteration against the Plaintiff in Parole ‘Hearings and purposely mislead th public and oficial lle. In edition, the Defendants have used the ateation like a weapon to maliciously asa the Plaintiff's unsuspecting pregnant spouse. 5. Plaintiff seeks compensatory snd punitive damages for government defamation, procedural due process Violation othe 148 Amendment tothe U.S. Constitution and violation ofthe Civil Rights Act of 1964, 42 USC. {§1983 and seks injunctive, preliminary, temporary and penmanent reli pursuant to Federal Rles of Civil Procedure 65. SURISDICLION AND VENUE {6 Jwitction of is Cou is pursuant to §1989 of Til 42 of he US, Code, This Cour bas dona {ttoon snder28 USC. 1345 2) 7. Venue is proper pursuant © 25 US. C. 1391 ET Seq. The conduct het as given ris oth ction was comnts by Parle Board Offa residing in Masssheets athe ins Defendant Parle Boar has dy to ay cpestions tendguntred in Natick Massachsts, *ARTIBS 8 Paintif? Keith 1. Pilipe isan ndvidual imprisoned at S00 Colony Road, P.O. Box 456, Gardner MA 01440. 19. Defendant Parole Board wes crestd pursuant to M.G.L.27§ 4, and consist ofmembes appointed bythe CGoveror. The Parole Boards principal Pace of Business is 12 Mercer Road, Natick Massachuscts. 10, Pursuant to MGL. C.27 § 5 the Parole Boar sal determine which Prisoners inthe Cortona Instittions ‘of the Commonwealth of Massechusets may be released on parole. The Parole Board aso has the authority to LL, Defendant Mark A. Conrad (“Conrad”) isthe curent Chairman ofthe Parole Board. Conrad is the executive administrative head of the Parole Board and has the authority and responsibility of directing assignments of ‘members ofthe Parole Board. Conrad voted to revoke Plaintiffs Parole on Appeal 12, Defendant Leticia Munaz (“Munoz”) isa member ofthe Parole Board and voted te deny Plast’ parole on Appeal 13. Defendant Pamela Lombardia isa member of the Parole Board and voted to revoke Plant's parole 14, Defendant Thomas Merrigan is a member ofthe Parole Board and voted to revoke Plaintiff's parle 15, Defendant Cendance Kechin is a member of the Parole Board and voted to deny Plintif's parole on Appeal. 16, Defendant Ceasar Achill sa member ofthe Parole Board and voted to deny Paints parle on Appeal. 17. Defendant Roger Miche sa member ofthe Parole Board and voted to deny Paintf's parle on Appeal 18, Defendant Sila Hubbard ie former Parole Board member and was also Chairperson in 19. 19, Defendant Michael Pmarol is former Parole Board member and was sso a Chairperson in 2003. 20, Defendant Maureen Walsh is former Parole Board member snd wa also Chairperson in 2004, 21. Parole regulation 120 CMR 520 ET Seq, Definitions, Institutional Parole Officer” ("IPO") provides: “a staff member of the Massachusetts Parole Board whose work or location isa county or state correctional fii. Institutional parole offices prepare inmates for their Parole Hearings, asst inmates in formulating plans of parole and facilitate the decision making process by compiling information for Parole Hearings.” 22, ‘Defeadant Donna Fentman is an IPO forthe Parole Board 23, ‘Defendant Mark Dasneves i an TPO forthe Parle Board 24, Defendant Marcia Curtain isa Parole Board staff member 25. Defendant Conceta Trifone is an TPO fr the Parole Board. 26. Defendant Marcia Hill is a Parole Board staff member who denied Plaintf's Appeal on an administrative level FACTUAL ALLEGATIONS ‘27, Plaintisseeving 2 twenty yer sentence fora 1990 jury tial conviction of rape (M. GL. 265 §22) and a concurrent rm of five years for indecent assault and batiory on a person fourtsen or older (M.GIL.C. 265 § 13 H) ‘ut of Woreester Superior Court. ‘28, Plant isserving a reformatory (“Concord”) sentence which requires the Pant to serve 1/10 or 10% of ‘rventy years to be parole eligible, Two years is 1/10 of twenty years. 29. On March 20" 1992 the Parole Board issued the Pant «parole pemitto Georgia after having served to years or 1/10" of his twonty years sentence. See Exhibit I, section “H’ 30, On May 25" 1992 Georgia Parole and Pardons (“GPP”) approved supervision ofthe Paints residence at 5419 Iroquois Trail a sub-division in Duluth Georgia. Soe Exhibit. 51. OnJune 12* 1992 Plants was released from the Massachusetts Deparment of Corestion (“DOC”) on parole to Atlanta, Georgia. See Exhibit 1, Section “H. 32, On December 10" 1995 Plaintf's parle was provisionally revoked for arrest and conviction of robbery and

    Anda mungkin juga menyukai