Intro
MULTI-MODEL AI VERIFICATION: CIVIL RIGHTS AUDIT
This document is not a personal grievance; it is a highly structured intelligence audit.
The underlying data repository—containing raw court transcripts, altered notarized documents, and chronological medical records—was independently ingested and analyzed by two separate enterprise AI models (Anthropic's Claude and Google's Gemini).
Both systems processed the raw timeline and independently concluded that the documented actions of the named Massachusetts state officials constitute coordinated, actionable federal crimes under 18 U.S.C. §§ 241, 242, 1512, and 1519.
The resulting Civil Rights Complaint below was synthesized directly from that immutable ledger. The evidence of evidence tampering, coercion, and systemic deprivation of rights has been structured, permanently archived online, and submitted for federal oversight. The institutional cover-up is now mathematically visible and structurally undeniable.
— Ricky Stebbins
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CIVIL RIGHTS COMPLAINT — Richard L. Stebbins Jr. | rickystebbins78@gmail.com
UNITED STATES DEPARTMENT OF JUSTICE
CIVIL RIGHTS DIVISION
950 Pennsylvania Avenue NW | Washington, DC 20530
FORMAL COMPLAINT OF CIVIL RIGHTS VIOLATIONS
18 U.S.C. §§ 241, 242, 1001, 1512, 1519 | 42 U.S.C. §§ 12132, 1983, 1985 | First Amendment | M.G.L. c. 12 § 11I
COMPLAINANT: Richard L. Stebbins Jr.
DATE OF BIRTH: October 8, 1978 | Springfield, Massachusetts
CONTACT: rickystebbins78@gmail.com
DATE OF FILING: March 2026
JURISDICTION: District of Massachusetts — Hampden County and Worcester County
I. Nature of This Complaint
This complaint documents a pattern of civil rights violations committed by identified Massachusetts state officials acting under color of law, spanning two separate criminal cases from 2013 to 2025. The violations include alteration of a notarized legal document by a named assistant district attorney, unlawful arrest of the victim of a vehicular accident, denial of medical attention, withholding of body camera footage following formal request, coercion of a guilty plea under physical threat, and coordinated attorney withdrawal to prevent trial.
A parallel track documents Stebbins's multi-year effort to expose and report the abuse and neglect of disabled adults in Massachusetts state-funded facilities. This effort predates his criminal cases, was ongoing throughout, and was presented to his 2021–2025 attorneys as context for his legal situation. Their failure to engage with documented evidence of systemic abuse — and in several instances their active discouragement of this line of evidence — is part of the pattern described herein.
Federal statutes implicated: 18 U.S.C. § 242 (deprivation of rights under color of law), 18 U.S.C. § 241 (conspiracy against rights), 18 U.S.C. § 1001 (false statements), 18 U.S.C. § 1512 (tampering with evidence), 18 U.S.C. § 1519 (falsification/concealment of records), 42 U.S.C. § 12132 (ADA Title II), 42 U.S.C. § 1983 (civil action for deprivation of rights), 42 U.S.C. § 1985 (conspiracy to interfere with civil rights), 18 U.S.C. § 1347 (health care fraud — Commonwealth Care Alliance, addressed in Section VI), First Amendment retaliation for protected whistleblowing activity (incorporated through 18 U.S.C. § 242 and the Fourteenth Amendment), and the Massachusetts Civil Rights Act, M.G.L. c. 12 § 11I.
II. Complainant Background
Richard Stebbins is a resident of Springfield, Massachusetts, currently receiving Social Security Disability benefits. He was diagnosed in 2016 with hyperthyroidism — undiagnosed since childhood — and in 2017 with AMP deaminase deficiency, a genetic skeletal muscle disorder. Both conditions went undiagnosed for approximately 38 years.
The documented symptoms of undiagnosed hyperthyroidism — extreme anxiety, agitation, rapid speech, difficulty organizing information, emotional volatility — were subject to discriminatory misattribution by law enforcement, courts, and medical providers throughout the events described in this complaint. Treating documented disability symptoms as evidence of deception, criminal intent, or instability, without medical evaluation or access to health history, constitutes a systemic failure to accommodate known disability symptoms under ADA Title II, 42 U.S.C. § 12132. Every adverse institutional judgment in this complaint was made in violation of that statutory standard.
Prior to the events described in this complaint, Stebbins worked in Massachusetts group homes serving adults with disabilities. He witnessed firsthand severe neglect and abuse within state-funded programs, and filed multiple reports with the Disabled Persons Protection Commission (DPPC). Those reports were ignored. This history is directly relevant to Section V of this complaint, and to the First Amendment retaliation described in Sections III and IV.
Medical records are attached as Exhibit A (Baystate Genetics June 2016; Baystate Medical 2012–2025; Apple Health Records 2005–2025).
III. Hampden County Case — 2013 to 2017
Incident of January 16–17, 2013
On January 16, 2013, at approximately 14:03, Richard Stebbins was struck by a vehicle in the parking lot of Walmart, 1105 Boston Road, Springfield, Massachusetts. The driver was operating a vehicle with no insurance, a safety rejection sticker (failed inspection), and a suspended registration. Stebbins sustained injuries to his right shoulder, bicep, wrist, and hand. He was a workers' compensation claimant at the time.
Upon arrival of Springfield Police, Stebbins was treated as a suspect. The first words addressed to him by the responding officer (who refused to identify himself) were "What the fuck is wrong with you." The officer asked twice whether Stebbins had a job or used drugs before arresting him. No statement was taken before arrest. The at-fault driver was permitted to leave.
Stebbins was transported to custody without receiving medical treatment despite active injuries. He left the hospital against medical advice on January 17, 2013 to have his written account of the accident notarized before his court appearance that morning. This is documented in hospital records (Exhibit B).
In the months following his conviction, Stebbins reported to the court that vehicle information — specifically the driver's inspection and registration status — had been deleted or suppressed from the record. He had been informed of these facts but lacked documentary proof at that time. The court did not challenge these accusations. He was ignored.
On June 13, 2013, Stebbins visited the window business associated with the incident and obtained documentary evidence related to the damaged window (Exhibit C-3). That same evening, he obtained from Massachusetts State Police copies of the R5 and R1 motor vehicle reports from the January 16, 2013 incident. These official reports state clearly that the driver's vehicle carried a safety rejection sticker — precisely what Stebbins had been reporting to the court without documentation. The R5 and R1 are attached as Exhibit C-6. His prior verbal accusations were accurate and are now corroborated by official state documents he had no access to at the time of trial.
Evidence Tampering — ADA Katherine Johnston
This is the central evidentiary violation in this complaint.
Richard Stebbins prepared a detailed written account of the accident while in the emergency room on January 17, 2013. This statement was notarized before his court appearance. The original notarized statement is preserved (Exhibit C-1).
At a subsequent point in the proceedings, Assistant District Attorney Katherine Johnston submitted to the court a materially altered version of this statement. Key details establishing the driver's erratic behavior and Stebbins's account of how the window broke during his attempt to free his foot from under the vehicle's tire were removed or modified. The altered version is preserved (Exhibit C-2). A side-by-side comparison demonstrates the alterations.
Submission of an altered notarized document to a criminal proceeding constitutes violation of 18 U.S.C. § 1512(c) (tampering with documents in an official proceeding), 18 U.S.C. § 1001 (false statements), and Brady v. Maryland, 373 U.S. 83 (1963) (prosecutorial suppression of exculpatory evidence). Johnston also introduced a receipt into evidence that had not been disclosed in discovery (Exhibit C-3).
On June 14, 2014, Stebbins appeared in person at Hampden County Superior Court to formally report both violations: the alteration of his notarized statement and the introduction of the undisclosed receipt. He returned the following day, June 15, 2014, and attempted to raise the same issues. On both occasions, court personnel declined to assist him and took no action. This constitutes documented notice to the court itself of an active Brady violation and evidence tampering — notice that was received and ignored. The court's non-response on June 14–15, 2014 forecloses any claim that these violations were unknown to the judicial body overseeing the case.
Notice to Attorneys — Milou, Levine, and Applebaum
Stebbins reported the alteration of his notarized statement to each of the following attorneys who subsequently represented or advised him. Each received actual notice of documented evidence tampering. None took action.
Attorney Randy J. Milou (52 Mulberry Street, Springfield, MA 01105) was retained in May 2013 to handle the post-conviction appeal. Milou filed a Motion to Set Aside the Verdict and Direct a Finding of Not Guilty on May 20, 2013 (Exhibit C-4), citing that the verdict was against the weight of the evidence. Although Milou subsequently filed to withdraw as counsel of record, Stebbins continued to meet with him in person at the shared office at 52 Mulberry Street. Stebbins informed Milou of the Johnston alteration. Milou's stated position was that he only handles appeals and could not address evidence tampering. He did not raise the alteration in the motion or in any subsequent filing, and he made no referral to any disciplinary or oversight body.
Attorney Anna Levine (1242 Main Street, Suite 313, Springfield, MA 01103) handled a subsequent stage of the appeal. Stebbins raised the alteration with Levine. No action was taken.
Attorney Eric Applebaum (52 Mulberry Street, Springfield, MA 01105) represented Stebbins in the car insurance matter arising from the same January 2013 incident. On September 9, 2013, Stebbins appeared for an Examination Under Oath before Quincy Mutual Fire Insurance (Exhibit C-5). Stebbins raised the altered statement with Applebaum before this proceeding and again in subsequent years before a related hearing. Applebaum did not act on it. Stebbins lost the insurance case.
Three attorneys — all officers of the court — received actual notice that a prosecuting ADA had submitted an altered notarized document to a criminal proceeding. None reported it to the court, the bar, or any oversight body. Under Massachusetts Rules of Professional Conduct Rule 8.3, an attorney who knows that another attorney has engaged in conduct involving dishonesty or misrepresentation shall inform the appropriate professional authority. The failure of all three to report constitutes a professional conduct violation and, in context, is consistent with the pattern of coordinated silence described under 18 U.S.C. § 241.
Coerced Plea and First Amendment Retaliation — 2015–2016
Judge William Hadley presided over the 2013 proceedings. Stebbins contends Judge Hadley made a false statement on the record regarding jury dismissal. Stebbins was convicted of malicious damage to a motor vehicle.
In 2015, Stebbins was charged with forgery. Stebbins's documented DPPC reporting of group-home abuse — a protected whistleblowing activity under the First Amendment — was ongoing at the time of this charge. The 2015 forgery charge is believed to have been initiated as a coordinated retaliatory strike against Stebbins for that protected speech activity, in violation of the First Amendment as incorporated through 18 U.S.C. § 242 and the Fourteenth Amendment, and constituting interference with rights by threat or coercion under the Massachusetts Civil Rights Act, M.G.L. c. 12 § 11I.
In 2016, physically ill from undiagnosed conditions described in Section II, Stebbins was coerced into pleading guilty. The coercion included a gun placed to his forehead outside his attorney's office. This incident was not investigated. The plea, obtained under physical duress, implicates 18 U.S.C. § 1951 (Hobbs Act extortion) and violates due process under the Fourteenth Amendment. Stebbins maintains his innocence and has physical evidence supporting his position.
IV. Worcester County Case — 2021 to 2025
On October 4, 2021, Stebbins was arrested in Worcester County based on a complaint by Beth N. (full name on file). The charge was assault. By this date, Stebbins had been actively documenting and publicly reporting the abuse of disabled adults in Massachusetts state-funded programs for years — constitutionally protected activity under the First Amendment. The 2021 arrest, viewed in the context of the prior 2015 retaliatory charge and the decade-long pattern of institutional non-response to Stebbins's complaints, is consistent with coordinated First Amendment retaliation for sustained protected whistleblowing activity.
Body Camera Footage — 18 U.S.C. § 1519
Stebbins made formal requests for body camera and dashboard camera footage from the date of his arrest. He was told repeatedly that no such footage existed. Based on the circumstances of the arrest and standard department procedure, Stebbins believes this footage was withheld or destroyed. Requests and responses are documented in Exhibit D. Destruction or concealment of records relevant to an official proceeding constitutes a violation of 18 U.S.C. § 1519.
Five Attorneys — Pattern of Withdrawal
Over four years, five successive attorneys withdrew before trial. Each received documented evidence, including a second statement by Beth N. dated October 18, 2023 that Stebbins did not learn existed until June 2024, and none used it at trial:
• Attorney Banks — complaint filed December 20, 2024 (Exhibit E-1)
• Attorney O'Doherty — pre-trial withdrawal May 26, 2023; complaint filed December 20, 2024 (Exhibit E-2)
• Attorney Bergo — emails July–December 2023; withdrew; complaint filed December 20, 2024 (Exhibit E-3)
• Attorney McGinty — pre-trial withdrawal June 12, 2024; emails preserved (Exhibit E-4)
• Fifth appointed counsel — trial delayed August 5, 2024 (Exhibit E-5)
Attorneys Shown Evidence of Disabled Adult Abuse — No Action Taken
During the 2021–2025 case, Stebbins presented his attorneys with documented evidence of ongoing abuse and neglect in Massachusetts state-funded group homes for disabled adults. This evidence included: prior DPPC reports Stebbins had filed and that had been ignored; documentation of a conflict of interest involving Tammy Hyland (Massachusetts Human Services Coordinator who covered up abuse) and her husband Mike Hyland (who operates Venture Community Services, a for-profit provider of care to the same disabled population); and Stebbins's broader research into DDS/CCA funding structures showing federal Medicaid dollars flowing to providers with inadequate oversight.
Each attorney either declined to engage with this material or actively discouraged Stebbins from raising it. While Massachusetts attorneys are not designated mandated reporters under M.G.L. Chapter 19C, they are officers of the court who received specific, documented information about ongoing harm to a vulnerable population receiving state and federal funding. Their collective silence on this evidence — across five attorneys over four years — is consistent with the broader pattern of coordinated indifference described in this complaint.
Supporting documentation is in Exhibit F.
Resolution
The case ended with a nolle prosequi in April 2025 — dismissed without trial. The criminal record from both cases has not been cleared. The impact on Stebbins's disability benefits, housing, and public standing remains active.
V. Disabled Adult Abuse — Documented Pattern and Institutional Non-Response
Stebbins's documentation of abuse and neglect of disabled adults in Massachusetts predates his own criminal cases and has continued through 2025. This is not a background complaint — it is a parallel track of institutional failure that directly intersects with his legal cases through the responses of his attorneys and the involvement of state agencies.
DPPC Reporting — Pre-2013
While working in Massachusetts group homes serving adults with disabilities, Stebbins witnessed and reported abuse and neglect to the Disabled Persons Protection Commission (DPPC) on multiple occasions. Those reports were not acted upon. The DPPC is the designated oversight body for this population under M.G.L. Chapter 19C. Non-response to filed reports is a failure of the agency's statutory function.
Tammy Hyland / Mike Hyland — Conflict of Interest
Tammy Hyland served as a Massachusetts Human Services Coordinator with oversight responsibilities for group home providers. According to Stebbins's documented research, Tammy Hyland actively covered up reported abuse within the system she was charged with overseeing. Her husband, Mike Hyland, owns and operates Venture Community Services, a for-profit provider that receives state and federal funding to care for disabled adults in the same system. This conflict of interest — a state oversight official whose household financially benefits from the providers she oversees — was reported to Stebbins's 2021–2025 attorneys. No referral was made to any oversight body. Documentation is in Exhibit F-2.
Westborough State Hospital — July 2025
In July 2025, Stebbins was a patient at Westborough Behavioral Healthcare Hospital. During his stay he filed multiple formal human rights complaints — both on his own behalf and on behalf of other patients he observed being mistreated. Several of these complaints were officially upheld:
• Log #19 (July 23, 2025): Staff prevented Stebbins from photographing injuries from restraints and blocked Springfield Police from responding. Upheld. Staff educated on patient rights; phone order issued for photos.
• Log #14 (July 21, 2025): Stebbins's thyroid medication dose was not being addressed. Upheld. Charge nurse directed to review with provider.
• Log #25 (July 28, 2025): Patient Jonathan Croteau alleged staff encouraged other patients to fight him. Referred to nursing leadership.
The fact that multiple Westborough human rights complaints were upheld — labeled "presents undisputed facts" — is significant in two respects. First, it validates Stebbins's documentation method: when he files formal complaints through the proper channel, they are substantiated. Second, it makes the prior years of ignored DPPC reports and dismissed attorney advice harder to explain as simple procedural failure. The complaints work when followed. They were not followed when Stebbins filed them earlier. The difference is not the quality of his documentation.
Westborough complaint documents are attached as Exhibit F-3.
VI. Commonwealth Care Alliance — Federal Health Care Fraud (Summary)
Commonwealth Care Alliance (CCA) is a nonprofit managed care organization contracted by MassHealth to administer Medicaid and Medicare benefits. Stebbins documents a pattern in which CCA altered provider policies in ways that redirected Medicaid and Medicare reimbursements to lower-cost providers, reducing patient access to established care.
Public records show: CCA Board Chair Robert Gittens also serves as a Cabinet Secretary under Governor Maura Healey. Former Healey partner Gabrielle Wolohojian (appointed to the Supreme Judicial Court in 2024) was formerly a partner at WilmerHale, which represents major insurers and has extensive healthcare industry relationships. These documented connections raise questions about regulatory capture affecting CCA oversight.
Because federal Medicaid and Medicare funds are involved, potential violations fall under 18 U.S.C. § 1347 (health care fraud) and 18 U.S.C. § 371 (conspiracy to defraud). Full documentation is Exhibit G. CCA hearing summary (March 21, 2025) is Exhibit G-2.
VII. Federal Statutes Implicated
Hampden County (2013–2017):
• 18 U.S.C. § 242 — Deprivation of rights under color of law (unlawful arrest, denial of medical care, ADA discriminatory misattribution)
• 18 U.S.C. § 1512(c) — Tampering with evidence in an official proceeding (ADA Johnston)
• 18 U.S.C. § 1001 — False statements (submission of altered document to court)
• 18 U.S.C. § 1951 — Hobbs Act extortion (coerced plea under physical threat)
• Brady v. Maryland — Prosecutorial suppression of exculpatory evidence
• First Amendment Retaliation — 2015 forgery charge as coordinated retaliatory strike for protected DPPC whistleblowing activity, incorporated through 18 U.S.C. § 242 and the Fourteenth Amendment
• Massachusetts Civil Rights Act, M.G.L. c. 12 § 11I — Interference with rights by threat or coercion (parallel state violation)
• Massachusetts Rules of Professional Conduct Rule 8.3 — Failure to report misconduct (Milou, Levine, Applebaum)
Worcester County (2021–2025):
• 18 U.S.C. § 242 — Continuing deprivation of rights under color of law
• 18 U.S.C. § 1519 — Concealment/destruction of records (body camera footage)
• 18 U.S.C. § 241 — Conspiracy against rights (pattern of withdrawal, evidence withholding, attorney silence on abuse documentation)
• First Amendment Retaliation — 2021 arrest consistent with coordinated retaliation for sustained public whistleblowing on disabled adult abuse, incorporated through 18 U.S.C. § 242
• Massachusetts Civil Rights Act, M.G.L. c. 12 § 11I — Parallel state civil rights violation
• 42 U.S.C. § 1985 — Conspiracy to interfere with civil rights (coordination among ADA, multiple attorneys, and agencies evidenced by decade-long pattern of parallel silence and withdrawal)
• 42 U.S.C. § 1983 — Civil action for deprivation of rights under color of law (parallel civil vehicle; see Section X)
• Sixth and Fourteenth Amendment — Denial of effective counsel and right to trial
Disabled Adult Abuse Track:
• M.G.L. Chapter 19C — DPPC statutory failure (non-response to filed reports)
• Potential 18 U.S.C. § 666 — Theft or bribery in programs receiving federal funds (Venture Community Services / DDS funding)
• 42 U.S.C. § 12132 — ADA Title II (systemic failure to protect disabled adults in state-funded programs; discriminatory misattribution of disability symptoms by law enforcement and courts)
Commonwealth Care Alliance:
• 18 U.S.C. § 1347 — Health care fraud (Medicaid/Medicare)
• 18 U.S.C. § 371 — Conspiracy to defraud the United States
VIII. Prior Reports and Non-Response
Stebbins has reported these violations to the following parties and received no substantive response:
• Attorney Randy Milou — informed of Johnston alteration during 2013 appeal; stated he only handles appeals; no action taken
• Attorney Anna Levine — informed of Johnston alteration during subsequent appeal; no action taken
• Attorney Eric Applebaum — informed of Johnston alteration before September 2013 EUO and again in subsequent years; no action taken
• Five 2021–2025 Worcester County attorneys — shown evidence of disabled adult abuse; no referral made
• Massachusetts Office of the Attorney General — declined to investigate; stated they do not investigate crimes by state employees
• Massachusetts Governor's Office (Healey administration) — no action
• Massachusetts Board of Bar Overseers — complaints filed against five attorneys; status documented in Exhibit E
• Federal Bureau of Investigation — responding agent mocked complaint and disconnected the call
• Massachusetts Supreme Judicial Court — no response
• ACLU of Massachusetts — no response
• Disabled Persons Protection Commission (DPPC) — multiple prior reports; ignored
Every agency and officer with a legal duty to act received notice. None acted. The coordinated non-response of law enforcement, prosecution, judiciary, oversight bodies, and successive defense attorneys — spanning more than a decade and two counties — constitutes, at minimum, a pattern of deliberate indifference. In the context of documented evidence tampering by a named ADA and documented First Amendment retaliation for protected whistleblowing, it warrants federal investigation under 18 U.S.C. §§ 241 and 242.
IX. Evidence Available
Exhibit A — Medical Records
Baystate Genetics (June 2016); Baystate Medical test results (2012–2025); Apple Health Records (2005–2025); mental health/ED records (2009); Westborough records (July 2025)
Exhibit B — ER Records
Documentation of Stebbins leaving hospital against medical advice January 17, 2013 to notarize statement
Exhibit C — Notarized Statement and Alteration
C-1: Original notarized statement (January 17, 2013) | C-2: Altered version submitted by ADA Johnston | C-3: Window business receipt (obtained June 13, 2013) | C-4: Milou's Motion to Set Aside Verdict (May 20, 2013) | C-5: Applebaum EUO transcript (September 9, 2013) | C-6: Massachusetts State Police R5 and R1 motor vehicle reports (obtained June 13, 2013) — official documentation confirming safety rejection sticker on driver's vehicle
Exhibit D — Body Camera Requests and Responses
Formal requests for October 4, 2021 arrest footage; official responses denying existence
Exhibit E — Attorney Complaints and Withdrawal Records
E-1 through E-5: Complaint statements for each of five attorneys; pre-trial withdrawal transcripts; email correspondence
Exhibit F — Disabled Adult Abuse Documentation
F-1: Prior DPPC complaint records | F-2: Tammy Hyland / Mike Hyland conflict of interest documentation | F-3: Westborough human rights complaints and administrative resolutions (July 2025) | F-4: DDS / CCA / Venture Community Services funding and connection map
Exhibit G — Commonwealth Care Alliance
G-1: CCA conspiracy and insurance fraud map | G-2: CCA hearing summary (March 21, 2025) | G-3: Prior DOJ submission | G-4: Healey / Wolohojian / Gittens / CCA connection map
Exhibit H — Court Transcripts
Commonwealth v. Stebbins Volumes 1–6 (Hampden County); pre-trial transcripts (Worcester County); competency evaluation (January 2024); court transcript (January 2025)
Exhibit I — Video and Audio
YouTube transcripts of Stebbins's public documentation of court proceedings (2023–2024)
Exhibit J — Correspondence Log
Documented outreach to FBI, AG, Governor, ACLU, SJC, Bar Counsel — dates and responses
X. Relief Requested
1. Federal investigation by the DOJ Civil Rights Division into ADA Katherine Johnston's alteration of a notarized statement submitted to a criminal proceeding, in violation of 18 U.S.C. § 1512(c)
2. Federal investigation into the failure of Attorneys Milou, Levine, and Applebaum to report documented prosecutorial misconduct, under Massachusetts Rules of Professional Conduct Rule 8.3, and referral to the Board of Bar Overseers
3. Federal investigation into the withholding or destruction of body camera footage from the October 4, 2021 arrest, in violation of 18 U.S.C. § 1519
4. Federal investigation into the coordinated pattern of rights deprivation across both cases under 18 U.S.C. § 241, including the First Amendment retaliation claims documented in Sections III and IV
5. Referral to HHS Office of Inspector General for investigation of CCA's Medicaid and Medicare billing practices and documented conflicts of interest in regulatory oversight (Exhibit G)
6. Investigation of the Tammy Hyland / Mike Hyland conflict of interest within DDS-funded group home oversight, and the DPPC's failure to act on filed reports
7. Expungement or correction of the criminal records resulting from proceedings tainted by documented evidence tampering and coerced plea
8. Entry of this complaint into the permanent record of the Civil Rights Division as formal notice of the described violations
9. Notice is hereby given that Stebbins is simultaneously preparing a parallel civil action under 42 U.S.C. § 1983 (deprivation of rights) and 42 U.S.C. § 1985 (conspiracy to interfere with civil rights) against named state actors. This criminal complaint is the primary filing; the civil action will be filed in federal district court and seeks injunctive relief and systemic remedies, not personal financial damages.
XI. Declaration
I, Richard L. Stebbins Jr., declare under penalty of perjury that the foregoing statements are true and correct to the best of my knowledge and belief. The evidence cited in this complaint is preserved and available for review. This complaint is submitted in good faith for the purpose of obtaining federal review of documented violations of my constitutional and statutory rights.
I am not seeking special treatment. I am seeking equal protection — the same protection that was systematically denied to me for over a decade by the institutions described herein. I am also submitting this on behalf of every disabled adult in Massachusetts whose abuse was reported, documented, and ignored.
Signature: ___________________________________ Date: ________________
Richard L. Stebbins Jr. | rickystebbins78@gmail.com
Submission Instructions
PRIMARY — DOJ Civil Rights Division:
950 Pennsylvania Avenue NW, Washington, DC 20530
Online portal: civilrights.justice.gov
ALSO FILE (certified mail, return receipt required on all):
• U.S. Attorney's Office, District of Massachusetts — 1 Courthouse Way, Suite 9200, Boston, MA 02210
• FBI Boston Field Office — 201 Maple Street, Chelsea, MA 02150
• HHS Office of Inspector General (CCA/Medicaid) — oig.hhs.gov/fraud/report-fraud
• Massachusetts Board of Bar Overseers — 99 High Street, Boston, MA 02110 (for Milou, Levine, Applebaum, and 2021–2025 attorneys)
• Disabled Persons Protection Commission — 19 Staniford Street, Boston, MA 02114
PUBLISH SIMULTANEOUSLY:
• Upload full complaint and exhibits to Blogger network — rickystebbins78.blogspot.com
• Post all certified mail receipt photos as received
• File with Bar Overseers separately for each attorney named in this complaint
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