THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEW HAMPSHIRE

REVEREND ZACHARIAH TRINGALI,

Plaintiff,

v.

KELLY AYOTTE, in her official capacity as Governor of the State of New Hampshire;

JOHN M. FORMELLA, in his official capacity as Attorney General of the State of New Hampshire;

and DOES 1–10,

Defendants.

Civil Action No. __________________

FORMAL NOTICE OF GOVERNMENTAL RESPONSIBILITY,

DISPLACEMENT, RISK OF SERIOUS HARM, AND POTENTIAL LOSS OF LIFE

TO:

THE HONORABLE KELLY AYOTTE

Governor of the State of New Hampshire

JOHN M. FORMELLA

Attorney General of the State of New Hampshire

PLEASE TAKE FORMAL NOTICE:

Plaintiff Reverend Zachariah Tringali hereby places the Governor of New Hampshire and the Attorney General of New Hampshire on formal notice concerning alleged governmental practices that may contribute to the displacement, destabilization, loss of shelter, loss of essential property, loss of service-provider contact, exposure to environmental dangers, and increased risk of serious injury or death among persons experiencing homelessness.

This Notice is intended to create a clear administrative and evidentiary record.

It is not an accusation that either named official personally caused a particular person's death. Rather, it places the appropriate state officials on notice of alleged systemic conditions and demands that those conditions be investigated, documented, and addressed.

I. THE CENTRAL ISSUE

1. Human beings do not cease to possess constitutional protections because they lack permanent housing.

2. Removal from an encampment does not, by itself, constitute placement into permanent housing.

3. Displacement is not the same thing as resolution.

4. A government may remove tents from a particular location while leaving the underlying homelessness crisis untouched.

5. When an encampment is cleared without a realistic and accessible alternative, the individual may simply be moved from one location to another.

6. The resulting displacement may interrupt relationships with outreach workers, medical providers, family members, shelters, treatment programs, and other service providers.

7. Recent research examining encampment clearances has reported that displaced individuals may remain unsheltered and may lose contact with service providers following clearance operations.

8. Plaintiff therefore demands that governmental decision-making concerning encampment enforcement be evaluated not merely according to whether an area has been cleared, but according to what happens to the human beings who were living there afterward.

II. NOTICE TO THE GOVERNOR

9. Governor Kelly Ayotte is hereby placed on notice that state-level policies, funding decisions, executive coordination, agency directives, and oversight decisions may affect the conditions under which municipalities and state agencies respond to homelessness.

10. Plaintiff recognizes that municipalities possess their own governmental authority and that the Governor does not personally control every municipal enforcement action.

11. Nevertheless, where state agencies, state funding, state law-enforcement resources, state policies, or executive-branch decisions materially affect the governmental response to homelessness, those actions may be relevant to determining governmental responsibility.

12. Plaintiff therefore requests preservation and production of records sufficient to determine:

a. what state policies govern encampment enforcement;

b. what state agencies participate in such operations;

c. what state funding supports enforcement or displacement;

d. what state funding supports shelter and permanent housing;

e. what alternatives are available before an encampment is cleared;

f. how displaced individuals are tracked or referred to services;

g. whether mortality, hospitalization, exposure, or other adverse outcomes are monitored;

h. whether state officials receive reports concerning deaths or serious injuries following displacement; and

i. what corrective measures have been considered.

III. NOTICE TO THE ATTORNEY GENERAL

13. Attorney General John M. Formella is separately placed on notice because the New Hampshire Department of Justice represents and advises state governmental interests and participates in matters involving state law, constitutional questions, governmental liability, and law-enforcement interests.

14. Plaintiff does not contend that the Attorney General personally directed every encampment operation.

15. Plaintiff does contend that the Attorney General's office should be placed on formal notice of the constitutional, evidentiary, and public-safety issues raised by the alleged governmental practices.

16. Plaintiff requests that the Attorney General's Office preserve records reasonably related to these matters and ensure that relevant governmental custodians are advised of applicable preservation obligations.

IV. DISPLACEMENT IS NOT A PUBLIC-SAFETY METRIC BY ITSELF

17. Plaintiff challenges the assumption that eliminating the visible presence of an encampment necessarily demonstrates that homelessness has been successfully addressed.

18. The relevant question is what happens to the displaced individual.

19. If a person loses a tent, medication, identification, clothing, bedding, transportation, documents, or contact with service providers, the person's vulnerability may increase rather than decrease.

20. If a person is moved into a more isolated or dangerous location, the government's numerical reduction of an encampment population does not necessarily represent an improvement in the person's living conditions.

21. Plaintiff therefore requests that Defendants preserve records capable of establishing the actual outcomes of displacement operations.

V. NOTICE CONCERNING DEATH AND SERIOUS INJURY

22. Plaintiff is specifically concerned about the possibility that displacement may expose vulnerable individuals to increased risk of hypothermia, heat exposure, untreated medical conditions, violence, overdose, accidental injury, or other life-threatening circumstances.

23. Plaintiff is not presently asserting that any particular death was caused by any particular Defendant.

24. Plaintiff is demanding that the governmental record be preserved so that causation, foreseeability, governmental knowledge, available alternatives, and actual outcomes can be determined through evidence rather than speculation.

25. Where a death or serious injury occurs following a governmental displacement operation, Plaintiff requests preservation of records sufficient to determine:

a. the date and location of the displacement;

b. the agencies and personnel involved;

c. the notice provided to affected persons;

d. the property removed or destroyed;

e. shelter or housing alternatives offered;

f. transportation offered;

g. referrals to services;

h. known medical or safety concerns;

i. subsequent governmental contacts;

j. emergency calls or dispatch records;

k. surveillance records;

l. communications among involved agencies; and

m. any governmental after-action review.

VI. RECORDS TO BE PRESERVED

26. Plaintiff demands preservation of all records reasonably related to these issues, including:

a. encampment-enforcement plans;

b. operational orders;

c. photographs and video;

d. body-camera footage;

e. drone footage;

f. dispatch records;

g. incident reports;

h. property inventories;

i. property-disposal records;

j. shelter-placement records;

k. transportation records;

l. outreach referrals;

m. mortality and serious-injury reports;

n. communications concerning deaths following displacement;

o. Flock Safety and ALPR records where legally relevant;

p. surveillance policies;

q. interagency agreements;

r. contractor records;

s. contracts;

t. invoices;

u. grants;

v. training materials;

w. communications among state and municipal agencies;

x. communications concerning Plaintiff or House of Mercy Ministry; and

y. other electronically stored information reasonably related to the issues identified herein.

VII. DEMAND FOR ACCOUNTABILITY

27. Plaintiff demands that the State distinguish between:

(1) clearing an encampment;

(2) relocating a person;

(3) providing emergency shelter;

(4) providing transitional housing;

(5) providing permanent housing; and

(6) actually resolving the individual's homelessness.

28. These outcomes are not interchangeable.

29. A policy that measures only the disappearance of tents, vehicles, or people from a particular location may conceal rather than resolve the underlying humanitarian condition.

30. Plaintiff therefore demands transparency concerning the actual outcomes experienced by persons affected by governmental displacement.

VIII. REQUEST FOR STATE ACTION

31. Plaintiff requests that the Governor and Attorney General undertake or facilitate an appropriate review of:

a. encampment-clearance practices;

b. property-seizure and disposal procedures;

c. notice procedures;

d. shelter availability;

e. housing availability;

f. outreach continuity;

g. mortality and serious-injury outcomes;

h. surveillance practices;

i. interagency coordination;

j. records-retention practices; and

k. constitutional compliance.

32. Plaintiff further requests identification of the state official or agency responsible for receiving and investigating complaints concerning alleged unconstitutional treatment of unhoused persons.

IX. FEDERAL LITIGATION NOTICE

33. Plaintiff is pursuing federal civil-rights claims concerning governmental conduct affecting unhoused persons and Plaintiff's protected religious, expressive, observational, and advocacy activities.

34. This Notice therefore places Defendants on actual notice that records concerning displacement, enforcement, surveillance, property removal, governmental knowledge, and resulting harm may become relevant to federal litigation.

35. Plaintiff reserves the right to seek appropriate discovery, preservation orders, declaratory relief, injunctive relief, damages where legally available, and other remedies authorized by law.

X. FINAL NOTICE

36. This is a notice of accountability, not a declaration of guilt.

37. Plaintiff is demanding that the State preserve the evidence necessary to determine what happened, who knew what, what alternatives existed, what decisions were made, and what consequences followed.

38. If the evidence ultimately establishes that governmental policies or actions materially contributed to displacement, serious injury, or death, Plaintiff reserves the right to present that evidence to the appropriate judicial or governmental authority.

39. If the evidence establishes that governmental officials acted lawfully and that alleged harms were caused by independent circumstances, that evidence should likewise be preserved and examined.

40. The issue must therefore be decided by evidence.

41. Plaintiff demands that the record be preserved.

42. Plaintiff demands transparency.

43. Plaintiff demands accountability.

44. Above all, Plaintiff demands that the lives of unhoused people be treated as human lives rather than as statistics, obstacles, or problems to be moved from one public space to another.

TAKE NOTICE ACCORDINGLY.

DATED: August 17, 2026

REVEREND ZACHARIAH TRINGALI

Plaintiff, Pro Se

House of Mercy Ministry

Cambridge, Massachusetts

Telephone: 603-661-9745

Email: zachariahtringali@gmail.com

X____________________________________

DATE_______________________

RECORDS PRESERVATION AND LITIGATION HOLD / “BURN NOTICE”

New Hampshire Homeless Encampment Enforcement, Property Removal, Surveillance, Grants Pass Implementation, and Low-Income Property-Line Enforcement

Date: August 13, 2026

TO:

Office of the Governor of New Hampshire

State House

107 North Main Street

Concord, New Hampshire 03301

New Hampshire Department of Justice

Office of the Attorney General

Attorney General John M. Formella

1 Granite Place South

Concord, New Hampshire 03301

RE: FORMAL NOTICE TO PRESERVE RECORDS AND ELECTRONICALLY STORED INFORMATION

From:

Reverend Zachariah Tringali

House of Mercy Ministry

Cambridge, Massachusetts

I. FORMAL PRESERVATION NOTICE

This correspondence constitutes formal notice that all records, electronically stored information, communications, photographs, video, audio, policies, directives, memoranda, grant records, enforcement records, training materials, legal memoranda, contracts, surveillance records, and other potentially relevant evidence concerning the State of New Hampshire’s treatment of unhoused persons, homeless encampments, temporary outdoor shelters, personal property, and low-income residential or property-line disputes must be preserved.

This preservation obligation applies immediately and extends to records maintained by the Governor’s Office, New Hampshire Department of Justice, state agencies, law-enforcement agencies, municipalities, counties, contractors, consultants, grant recipients, and other governmental or quasi-governmental entities acting on behalf of the State.

No potentially responsive record should be deleted, destroyed, altered, overwritten, concealed, discarded, or otherwise rendered inaccessible.

II. SUBJECT MATTER OF THE PRESERVATION HOLD

The preservation hold specifically includes records concerning:

1. Homeless encampment removals, sweeps, closures, abatements, evictions, cleanups, seizures, impoundments, destruction, disposal, or relocation of personal property.

2. Policies or operational protocols adopted after or in response to City of Grants Pass v. Johnson, 603 U.S. ___ (2024).

3. State or municipal interpretations of Grants Pass, including legal opinions concerning the Eighth Amendment, Fourth Amendment, Fourteenth Amendment, First Amendment, due process, equal protection, property rights, and enforcement against unhoused persons.

4. State or municipal enforcement of camping, lodging, loitering, trespass, disorderly conduct, obstruction, nuisance, public-health, sanitation, zoning, or similar laws against unhoused persons.

5. Any policy, directive, training material, memorandum, email, text message, presentation, briefing, or legal guidance instructing officers or municipal employees how to enforce such laws against unhoused individuals.

6. Any protocol concerning advance notice before an encampment removal.

7. Any protocol concerning identification, inventory, tagging, storage, retrieval, destruction, disposal, or return of property belonging to unhoused individuals.

8. Records concerning claims that property was “abandoned,” “discarded,” “unclaimed,” “unsafe,” “unsanitary,” or otherwise subject to removal.

9. Records concerning tents, tarps, carts, bicycles, backpacks, clothing, medications, identification documents, religious property, ministry materials, electronic equipment, computers, communications equipment, food, documents, and other personal effects belonging to unhoused individuals.

10. Surveillance or monitoring used in connection with encampment enforcement, including drones, cameras, automated license-plate readers, body-worn cameras, fixed cameras, mobile cameras, geolocation technology, electronic tracking, photographs, video surveillance, or other electronic monitoring.

11. Contracts or agreements with private removal companies, towing companies, sanitation contractors, security companies, technology companies, surveillance vendors, or property-disposal contractors.

12. Federal, state, county, or municipal grants used to finance homeless-encampment enforcement, policing, surveillance, property removal, sanitation operations, or related activities.

13. Grant applications, grant awards, grant conditions, reimbursement requests, invoices, expenditure reports, performance reports, audits, monitoring reports, and communications concerning such funding.

14. Communications between New Hampshire governmental entities and federal agencies concerning enforcement against unhoused individuals.

15. Communications with the United States Department of Justice, Department of Housing and Urban Development, Department of Homeland Security, Department of Transportation, or other federal agencies concerning homeless encampment enforcement.

16. Complaints, internal investigations, use-of-force reports, incident reports, arrest reports, citations, warnings, photographs, body-camera footage, dispatch records, and after-action reports involving encampment enforcement.

17. Records concerning enforcement actions occurring on or adjacent to private property, public property, sidewalks, parks, transportation facilities, libraries, schools, churches, ministries, shelters, or other locations used by low-income or unhoused persons.

18. Policies or practices concerning property lines, easements, rights-of-way, public/private boundaries, trespass enforcement, zoning enforcement, nuisance enforcement, or other mechanisms allegedly used to remove or displace low-income households or unhoused persons.

19. Communications concerning complaints from property owners, businesses, residents, municipalities, law enforcement, social-service organizations, religious organizations, or advocacy organizations concerning homeless encampments.

20. Records identifying the officials responsible for authorizing, directing, supervising, funding, reviewing, or approving encampment-removal operations.

III. GRANTS PASS DOES NOT ELIMINATE CONSTITUTIONAL LIMITATIONS

The Supreme Court's decision in City of Grants Pass v. Johnson addressed a specific Eighth Amendment question concerning enforcement of public-camping laws.

The decision did not create an unrestricted governmental power to seize property, destroy personal possessions, conduct unreasonable searches or seizures, deny procedural due process, retaliate against protected speech or religious activity, discriminate against protected classes, or employ unreasonable enforcement practices.

Accordingly, this preservation demand includes all records reflecting how New Hampshire officials interpreted the scope and limitations of Grants Pass.

Particular attention should be given to records addressing the distinction between:

- lawful enforcement of a generally applicable ordinance;

- seizure or destruction of personal property;

- criminal prosecution;

- civil enforcement;

- administrative abatement;

- emergency public-health measures;

- trespass enforcement;

- displacement from public property; and

- enforcement actions directed at a person's status, circumstances, speech, religious activity, or exercise of constitutional rights.

IV. PROPERTY AND DUE-PROCESS RECORDS

The preservation hold specifically encompasses evidence concerning what happens to personal property after an encampment operation.

This includes:

- property inventories;

- photographs before removal;

- photographs after removal;

- property tags;

- chain-of-custody documentation;

- storage logs;

- retrieval records;

- disposal authorizations;

- destruction records;

- landfill or transfer-station records;

- contractor invoices;

- employee time records;

- body-camera footage;

- dispatch recordings;

- radio traffic;

- written warnings;

- notices of removal;

- receipts;

- property-release forms;

- complaints concerning missing or destroyed property; and

- communications regarding whether property was considered abandoned.

Any assertion that property was abandoned should be supported by the contemporaneous records establishing the factual and legal basis for that determination.

V. SURVEILLANCE AND ELECTRONIC INFORMATION

Preservation must include electronically stored information concerning surveillance or monitoring of unhoused persons and encampments.

This includes, without limitation:

- body-worn-camera recordings;

- dash-camera recordings;

- drone footage;

- fixed-camera footage;

- photographs;

- automatic license-plate-reader data;

- location data;

- GPS information;

- dispatch data;

- CAD records;

- radio recordings;

- email;

- text messages;

- instant messages;

- Microsoft Teams or similar communications;

- cellular-device records maintained by governmental entities;

- cloud-stored records;

- photographs containing metadata;

- audit logs;

- access logs;

- database searches;

- search histories;

- vendor-generated reports; and

- contracts or technical documentation describing surveillance capabilities.

No automatic deletion schedule should be permitted to destroy potentially relevant information after receipt of this notice.

VI. FEDERAL FUNDING AND GRANT RECORDS

Preserve all records concerning federal or state financial assistance connected to:

- homelessness enforcement;

- encampment removal;

- public safety;

- policing;

- surveillance;

- sanitation;

- property removal;

- public-space enforcement;

- transportation enforcement;

- municipal enforcement initiatives; and

- programs affecting unhoused or extremely low-income persons.

This includes applications, award documents, grant conditions, subawards, invoices, reimbursement records, audits, monitoring reports, performance measurements, correspondence, and communications concerning compliance with federal funding requirements.

The federal Department of Justice maintains grant programs supporting law enforcement and public-safety activities, making grant-related records potentially relevant where federal funds are connected to enforcement activities.

VII. RSA 91-A RIGHT-TO-KNOW NOTICE

This preservation notice is also intended to identify categories of governmental records that may subsequently be requested pursuant to New Hampshire RSA Chapter 91-A.

RSA 91-A:4 provides a right to inspect governmental records subject to statutory exemptions and requires a public body unable to immediately produce requested records to respond within five business days by producing the record, denying the request, or providing a written statement explaining the reasonably necessary delay.

Any withholding should identify the specific statutory exemption relied upon and explain its application.

This notice does not concede that any particular category of records is exempt from disclosure.

VIII. PRESERVATION OF RECORDS DURING DISPUTES

New Hampshire RSA 91-A:9 specifically prohibits knowing destruction of information for the purpose of preventing inspection or disclosure and requires preservation of requested material for 90 days, or while litigation under RSA 91-A:7-8 remains pending, when a request is denied on exemption grounds.

Accordingly, the State and any agency receiving this notice should implement an appropriate litigation hold and suspend ordinary document-destruction practices applicable to potentially responsive information.

IX. REQUEST FOR IDENTIFICATION OF RESPONSIBLE OFFICIALS

Please identify the governmental official or office responsible for maintaining and preserving records responsive to this notice.

Please also identify:

1. The State agency responsible for homeless-encampment policy.

2. The State agency responsible for coordinating municipal enforcement guidance.

3. The State official responsible for legal guidance concerning Grants Pass.

4. The officials responsible for federal grant oversight.

5. The officials responsible for records retention.

6. The officials responsible for responding to RSA 91-A requests concerning these subjects.

X. NO WAIVER OF RIGHTS

Nothing in this notice waives any constitutional, statutory, administrative, common-law, or equitable claim or remedy.

Nothing herein constitutes an admission concerning the legality of any particular enforcement action.

The preservation request is intended to protect evidence while the underlying legal and factual questions are investigated.

Potential claims may include, depending upon the facts established by the preserved records:

- Fourth Amendment unreasonable search and seizure;

- Fourteenth Amendment procedural due process;

- Fourteenth Amendment equal protection;

- First Amendment retaliation or interference with protected expression;

- First Amendment religious-exercise protections where applicable;

- unlawful deprivation or destruction of property;

- state-law claims;

- municipal-liability claims;

- statutory violations;

- records-access violations; and

- other remedies available under federal or New Hampshire law.

XI. DEMAND

Effective immediately upon receipt of this notice, all recipients and persons acting under their authority are requested to:

PRESERVE ALL POTENTIALLY RELEVANT RECORDS.

Do not delete, destroy, overwrite, alter, conceal, dispose of, or materially modify potentially relevant information.

Preserve the information in its native electronic form where reasonably practicable, together with available metadata and audit information.

Preserve physical evidence and property records in substantially the condition in which they presently exist.

Preserve communications between governmental officials and outside contractors, vendors, municipalities, law-enforcement agencies, grant administrators, and federal agencies.

This notice should be distributed to all personnel reasonably likely to possess responsive information.

XII. FINAL NOTICE

The State of New Hampshire and its agencies are placed on formal notice that records concerning homeless encampment enforcement, property removal, surveillance, low-income property enforcement, federal funding, and implementation of Grants Pass may become material evidence in administrative proceedings, public-records proceedings, civil-rights litigation, or other judicial proceedings.

The preservation of evidence is therefore mandatory as a matter of prudent governmental recordkeeping and litigation management.

Please treat this correspondence as a formal litigation hold and preservation demand.

ADDENDUM TO RECORDS PRESERVATION AND LITIGATION HOLD

Flock Safety, Ford Police Cruisers, Automated License-Plate Recognition, Vehicle Technology, and Electronic Tracking

XIII. FLOCK SAFETY AND AUTOMATED LICENSE-PLATE RECOGNITION

The preservation demand is expressly expanded to include all records concerning the acquisition, installation, operation, maintenance, use, sharing, retention, querying, auditing, or disposal of data generated by Flock Safety or any Flock-related automated license-plate-recognition (“ALPR”) system.

Preserve, without limitation:

1. All contracts, purchase orders, invoices, renewals, subscriptions, memoranda of understanding, and licensing agreements involving Flock Safety.

2. All communications between the State of New Hampshire, Governor's Office, New Hampshire Department of Justice, State Police, county law-enforcement agencies, municipalities, and Flock Safety.

3. All policies, directives, training materials, standard operating procedures, legal opinions, and memoranda governing Flock use.

4. All ALPR photographs, plate-read records, vehicle detections, timestamps, GPS/location information, confidence scores, vehicle characteristics, and associated metadata.

5. All searches, queries, alerts, hot lists, watch lists, investigative searches, and historical-location searches conducted through Flock systems.

6. All records identifying which personnel accessed or queried Flock systems.

7. All audit logs showing searches, data access, downloads, exports, sharing, modification, or deletion.

8. All records concerning retention periods and automatic deletion schedules.

9. All records concerning sharing of Flock data with other governmental agencies, federal agencies, fusion centers, task forces, private entities, or law-enforcement partners.

10. All records concerning requests for Flock data involving unhoused persons, homeless encampments, outreach workers, clergy, activists, journalists, political candidates, demonstrations, ministries, shelters, or organizations providing services to low-income individuals.

11. All records concerning the use of Flock technology to identify vehicles associated with particular individuals, locations, encampments, shelters, ministries, outreach operations, or political activity.

12. All records concerning Flock alerts generated from vehicles entering or leaving areas associated with homeless encampment operations.

XIV. FORD POLICE CRUISERS AND VEHICLE-BASED DATA

The preservation hold further includes all records concerning Ford Motor Company vehicles used as police cruisers or government enforcement vehicles, including Ford Police Interceptor Utility vehicles and other Ford vehicles equipped with governmental, law-enforcement, telematics, camera, communications, GPS, diagnostic, or data-collection systems.

Preserve all records concerning:

- Ford police-cruiser specifications;

- vehicle identification numbers where legally maintainable;

- vehicle procurement;

- fleet contracts;

- purchase and lease agreements;

- maintenance contracts;

- onboard computers;

- vehicle telematics;

- GPS/location systems;

- cellular communications;

- vehicle diagnostic systems;

- onboard cameras;

- dash cameras;

- cruiser-mounted surveillance equipment;

- emergency-light systems;

- mobile data terminals;

- wireless networking;

- Bluetooth or wireless-device connectivity;

- vehicle access logs;

- vehicle-location records;

- software systems;

- firmware;

- remote-access capabilities;

- data retention;

- data transmission;

- cloud services;

- vendor access;

- law-enforcement integrations; and

- records concerning extraction or disclosure of vehicle-generated information.

XV. INTEGRATION BETWEEN FORD CRUISERS AND FLOCK SYSTEMS

Particular preservation is demanded concerning any technological or operational connection between Ford police cruisers and Flock Safety systems.

This includes any system through which a cruiser may:

1. Receive Flock alerts;

2. Transmit ALPR information;

3. Access Flock databases;

4. Query vehicle-location information;

5. Receive information regarding a vehicle detected by Flock;

6. Display Flock information on a mobile data terminal;

7. Upload photographs or vehicle information;

8. Connect Flock equipment to cruiser computers;

9. Connect ALPR equipment to cruiser cameras;

10. Exchange information with dispatch or CAD systems; or

11. Share information with other law-enforcement databases.

Preserve all technical documentation identifying the systems, interfaces, APIs, network connections, software applications, data flows, and vendors involved.

XVI. CRUISER USE DURING ENCAMPMENT OPERATIONS

The preservation requirement specifically covers Ford cruisers and other enforcement vehicles deployed during homeless-encampment sweeps, property-removal operations, trespass enforcement, public-space enforcement, surveillance operations, or interactions with unhoused persons.

Preserve:

- dash-camera recordings;

- cruiser GPS/location data;

- CAD records;

- dispatch communications;

- radio transmissions;

- mobile-data-terminal activity;

- ALPR detections;

- Flock alerts;

- officer activity logs;

- vehicle deployment records;

- photographs;

- video;

- incident reports;

- enforcement reports;

- vehicle inspection records; and

- communications concerning deployment of specific cruisers.

XVII. FLOCK DATA AND INDIVIDUALIZED SURVEILLANCE

Preserve records sufficient to determine whether ALPR or Flock technology was used to develop information concerning the movements of particular individuals or vehicles.

This includes records concerning:

- repeated vehicle detections;

- historical vehicle searches;

- pattern-of-life analysis;

- location-based searches;

- searches surrounding encampments;

- searches surrounding shelters;

- searches surrounding outreach locations;

- searches surrounding government buildings;

- searches surrounding demonstrations;

- searches involving clergy or ministry vehicles;

- searches involving journalists or activists; and

- searches conducted at the request of another governmental agency.

The preservation requirement applies regardless of whether the resulting information was subsequently used in an arrest, citation, investigation, encampment operation, property seizure, or other enforcement action.

XVIII. FEDERAL AND INTERAGENCY DATA SHARING

Preserve all records showing whether Flock, Ford vehicle systems, ALPR information, cruiser data, or related surveillance information was transmitted to or received from:

- federal law-enforcement agencies;

- Department of Homeland Security;

- Department of Justice;

- FBI;

- U.S. Marshals Service;

- federal task forces;

- regional intelligence centers;

- fusion centers;

- neighboring states;

- county governments;

- municipal police departments;

- sheriffs' offices; or

- private contractors.

Preserve records identifying the legal authority, policy, contract, memorandum, or other authorization relied upon for such sharing.

XIX. LEGAL AUTHORITY AND POLICY REVIEW

Preserve all legal memoranda and communications addressing whether Flock Safety, ALPR, Ford cruiser technology, GPS information, vehicle telematics, or other electronic tracking may constitutionally or statutorily be used to monitor persons or vehicles associated with homeless encampments, outreach ministries, political activity, demonstrations, or protected expression.

This includes analyses concerning the:

- Fourth Amendment;

- First Amendment;

- Fourteenth Amendment;

- New Hampshire Constitution;

- RSA Chapter 91-A;

- state privacy laws;

- public-records obligations;

- search-and-seizure law;

- reasonable-expectation-of-privacy doctrine;

- warrant requirements;

- data-retention requirements; and

- restrictions on governmental surveillance.

XX. NO DELETION OR AUTOMATIC PURGING

Upon receipt of this addendum, all potentially relevant Flock, Ford, cruiser, ALPR, GPS, telematics, camera, CAD, dispatch, and electronic-surveillance information should be preserved notwithstanding ordinary retention or automatic-deletion schedules.

This includes information maintained by governmental entities as well as information maintained on their behalf by contractors or technology vendors.

The State should issue appropriate preservation instructions to personnel, agencies, contractors, technology vendors, and other custodians possessing potentially responsive information.

XXI. EXPANDED SCOPE OF PRESERVATION

This Addendum is incorporated into the August 13, 2026 Records Preservation and Litigation Hold and should be treated as part of the same preservation demand.

Nothing in this Addendum waives any federal or state constitutional claim, statutory claim, public-records right, discovery right, or other legal remedy.

The purpose of this Addendum is to ensure that potentially material evidence concerning government surveillance, Flock Safety ALPR systems, Ford police cruisers, vehicle technology, and electronic monitoring is preserved before routine deletion, overwriting, replacement, or contract termination can make such evidence unavailable.

Respectfully,

Reverend Zachariah Tringali

House of Mercy Ministry

362 Green Street

Cambridge, Massachusetts 02139

603-661-9745

zacharytringali@gmail.com

X______________________________________

DATE_________________

END OF PRESERVATION NOTICE

PLAINTIFF'S EVIDENTIARY OBJECTION AND REQUEST FOR JUDICIAL REVIEW OF THE SEPTEMBER 26, 2025 “NOTICE TO VACATE PROPERTY”

UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Tringali v. Hillsborough County Sheriff's Department, et al.

Civil Action No. 1:26-cv-00350-SM

PLAINTIFF'S NOTICE OF MATERIAL EVIDENCE CONCERNING THE SEPTEMBER 26, 2025 “NOTICE TO VACATE PROPERTY” USED IN CONNECTION WITH THE NOVEMBER 4, 2025 ENCAMPMENT OPERATION

Plaintiff respectfully submits the attached photograph of a document entitled “NOTICE TO VACATE PROPERTY”, dated September 26, 2025, as material evidence concerning the governmental authority, notice, authorization, and procedures relied upon in connection with the November 4, 2025 operation at or concerning the Stark Park encampment.

I. THE DOCUMENT DOES NOT IDENTIFY PLAINTIFF OR HIS ORGANIZATION

The document is addressed generically to:

“All individuals camping on State property”

It does not identify Plaintiff by name.

It does not identify Reverend Zachariah Tringali.

It does not identify House of Mercy Ministries.

It does not identify any particular occupant, ministry, organization, property owner, or property custodian.

Accordingly, Defendants should be required to establish whether this generic notice was actually intended to provide legally sufficient notice to Plaintiff personally or to any property belonging to Plaintiff or House of Mercy Ministries.

II. THE DOCUMENT DOES NOT IDENTIFY THE GOVERNMENTAL OFFICIAL WHO ISSUED OR AUTHORIZED IT

The document concludes only:

“Posted by the State of New Hampshire, September 26, 2025.”

It does not identify:

the State agency;

the State official;

the official's title;

the governmental board allegedly exercising jurisdiction;

the person who physically posted the notice;

the law-enforcement agency requested to enforce it;

the legal instrument authorizing the posting; or

any court proceeding associated with the notice.

This is significant because RSA 236:58 does not simply authorize any governmental actor to prohibit camping on any property. The statute refers to permission from the governing board of the governmental authority having jurisdiction over the property. 

General Court of New Hampshire

Therefore, the identity and legal authority of the entity that issued the September 26 notice are material facts.

III. THE NOTICE DOES NOT APPEAR TO BE A JUDICIAL ORDER

The document is not captioned as a court order.

It contains no court name.

It contains no docket number.

It contains no case number.

It contains no judge's name.

It contains no judicial signature.

It contains no clerk certification.

It contains no judicial seal.

Plaintiff does not contend that every administrative notice necessarily requires a judge's signature. Rather, Plaintiff submits that Defendants should not characterize this document as a judicial authorization for the November 4 operation unless they can produce competent evidence establishing that such judicial authorization existed.

That distinction is critical.

A notice posted by an executive or administrative governmental entity is not automatically equivalent to a judicial warrant, judicial eviction order, or judicial authorization to seize and destroy personal property.

IV. THE DOCUMENT EXPRESSLY CLAIMS THAT THE PROPERTY IS OWNED BY THE STATE

The notice expressly states:

“This property is owned by the State of New Hampshire.”

This statement creates a material factual issue if the notice was posted at Stark Park.

The City of Manchester identifies Stark Park as a City park under its Parks and Recreation Department and describes it as a historic asset of the City of Manchester. 

City of Manchester

Consequently, Defendants should be required to establish through competent property records:

Who owned the precise parcel where the September 26 notice was posted on September 26, 2025?

That question should not be resolved merely by the language printed on the notice.

Plaintiff therefore requests production of the deed, parcel identification, property map, State ownership record, City ownership record, easement documents, or other documentary evidence establishing the governmental entity possessing jurisdiction over the precise location.

V. RSA 236:58 DOES NOT ITSELF ESTABLISH AUTHORITY TO SEIZE AND DESTROY PERSONAL PROPERTY

RSA 236:58 prohibits camping on public property without permission from the governmental authority having jurisdiction. 

General Court of New Hampshire

RSA 236:59 establishes penalties for violations of RSA 236:58. 

General Court of New Hampshire

But Defendants should be required to identify the separate legal authority they contend permitted them, on November 4, 2025, to:

enter the encampment;

remove individuals;

seize personal property;

remove Plaintiff's ministry property;

destroy or dispose of property;

transport property away from the site;

prevent Plaintiff from retrieving property; or

authorize a private contractor to destroy or dispose of property.

The existence of a camping prohibition does not, standing alone, answer those separate constitutional questions.

VI. THE TIMELINE REQUIRES PARTICULARIZED EXPLANATION

The notice is dated September 26, 2025 and establishes October 6, 2025 as the stated deadline.

The challenged operation occurred on November 4, 2025, approximately four weeks after that deadline.

Accordingly, Defendants should be required to produce the documents demonstrating what occurred between October 6 and November 4, including:

enforcement referrals;

Sheriff's Department communications;

Manchester Police communications;

State agency communications;

City communications;

property inventories;

photographs;

body-camera footage;

dispatch records;

emails;

memoranda;

operational plans;

instructions concerning personal property;

authorization for disposal;

contractor instructions;

evidence-retention records; and

any warrant, court order, administrative order, or other legal process relied upon.

VII. AUTHENTICITY AND AUTHORITY OF THE DOCUMENT SHOULD BE ESTABLISHED THROUGH THE GOVERNMENT'S OWN RECORDS

Plaintiff does not ask the Court to assume that the document is fraudulent merely because it lacks a signature.

Rather, Plaintiff requests that Defendants be required to establish the document's provenance.

Specifically:

Who created it?

Who authorized it?

What agency created it?

Where was it posted?

Who posted it?

What property parcel was involved?

What governmental entity had jurisdiction?

Was it intended to provide notice to Plaintiff?

What authority allegedly permitted law enforcement to enforce it?

What authority allegedly permitted seizure or destruction of personal property?

These are factual questions directly relevant to the legality of the November 4 operation.

VIII. THE DOCUMENT SHOULD NOT BE TREATED AS A SUBSTITUTE FOR WARRANT OR JUDICIAL PROCESS

Plaintiff respectfully submits that Defendants should not be permitted to use the September 26 notice as a substitute for whatever constitutional or statutory authority was required for the subsequent governmental seizure and destruction of property.

The Court should distinguish between:

(1) a general administrative notice prohibiting camping;

(2) authority to enforce a violation of RSA 236:58;

(3) authority to remove persons from property;

(4) authority to seize personal property;

(5) authority to permanently deprive persons of their property; and

(6) authority to destroy or dispose of property.

Those are not necessarily the same legal question.

REQUEST FOR RELIEF

Plaintiff respectfully requests that the Court:

Accept the attached September 26, 2025 “Notice to Vacate Property” as an exhibit;

Require Defendants to identify the governmental entity and individual official who issued and/or authorized the notice;

Require Defendants to establish the ownership and governmental jurisdiction of the precise property where the notice was posted;

Require Defendants to produce the original or official copy of the notice and records establishing its provenance;

Require Defendants to identify the legal authority relied upon for the November 4, 2025 operation;

Require Defendants to identify the separate legal authority relied upon for the seizure, removal, destruction, or disposal of personal property;

Require production of all communications between the State of New Hampshire, City of Manchester, Manchester Police Department, Hillsborough County Sheriff's Department, contractors, and other governmental actors concerning the notice and subsequent operation; and

Consider the absence of individualized notice, issuing-official identification, judicial process, and documented authority as relevant evidence when determining whether the November 4, 2025 operation violated Plaintiff's constitutional rights.

Respectfully submitted,

Reverend Zachariah Tringali

Plaintiff, Pro Se

House of Mercy Ministries

362 Green Street

Cambridge, MA 02129

603-661-9745

zacharytringali@gmail.com

Name \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

X\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Date\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Witness \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

X\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Date\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

ADRESS\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_



EXHIBIT FOR NOTICE TO VACATE PROPERTY POSTED AT DIFFERENT LOCATIONS NOT ONE IN AREA OF PARK FOR THIS NOTICE BACKSIDE PARK NEAR TRACKS HALF WAY UP ON LEFT TRAIL SECTOR OUR ENCAMPMENT WAS SEE PHOTOS OF CLEAN ENCAMPMENT OTHER ONE WAS OLD OR OTHER INDIVIDUALS LIVED THERE.

MINE HAD 

Jen Kulgowaski 

Dyral F

Jamie Levine 

And person staying for day or two until bed available at Gateway rehab Nashua 

Other residents in or around locations throughout the park.

This notification was given by George Thonburg as evidence

The Watchers and the Watched: Reverend Zachariah Tringali’s Fight Against the Modern Panopticon

By Storytelling Adventures Studio Inc.

There is an old question at the heart of every struggle between the individual and the institution:

Who watches the watchers?

For Reverend Zachariah Tringali, that question has become more than a philosophical exercise. It has become a framework for examining the collision of municipal surveillance, technology, homelessness policy, civil-rights litigation, and the machinery of modern government.

Tringali's approach is unconventional. He does not separate these issues into neat political categories. Instead, he sees them as pieces of a larger technological and institutional architecture—one in which cameras, databases, automated identification systems, public-records processes, police operations, municipal policies, and private technology companies can interact in ways that ordinary citizens may struggle to see.

His inspiration is unmistakably Orwellian.

George Orwell's 1984 imagined a society in which surveillance was not merely a police technique but a governing philosophy. The telescreen watched citizens. The Ministry of Truth controlled historical narratives. The Memory Hole erased inconvenient records. Doublethink allowed contradictory realities to coexist.

Tringali argues that the modern world does not need to reproduce Orwell's fictional state literally for some of its underlying warnings to become relevant.

The contemporary version may be quieter.

It may arrive through software contracts rather than secret police.

Through automated license-plate readers rather than telescreens.

Through databases rather than paper dossiers.

Through administrative decisions rather than public declarations.

And through the disappearance of records rather than the burning of books.

Breaking the Doublethink

One of Tringali's central arguments concerns what might be called institutional doublethink.

A municipality can describe an operation as outreach while simultaneously conducting enforcement.

A government can describe surveillance technology as a public-safety tool while citizens remain uncertain about how information is collected, retained, searched, shared, or deleted.

An encampment operation can be described as a humanitarian intervention while the people affected experience displacement, loss of property, or disruption of essential services.

The question is therefore not simply what government officials call an operation.

The question is what actually happened.

That distinction is crucial.

Tringali's strategy has increasingly focused on creating an evidentiary record through public-records requests, court filings, discovery, documentation, photographs, communications, and public advocacy.

The objective is straightforward: place official statements and underlying records next to one another and allow the evidence to speak.

That is where rhetoric becomes accountability.

Defeating the Memory Hole

Orwell understood that controlling history is a form of controlling power.

If yesterday's records can disappear, tomorrow's public has no reliable way to determine what actually happened.

Modern public-records laws exist in part to prevent precisely that problem.

Tringali's approach treats the public record as a form of institutional memory.

A request is filed.

A response arrives.

A deadline passes.

A document is withheld.

An exemption is asserted.

A lawsuit follows.

Each event becomes part of a chronological record.

Social media can amplify that record, but the deeper strategy is documentary. Court dockets, authenticated records, contracts, policies, emails, photographs, dispatch logs, surveillance policies, and discovery responses possess a significance that an ordinary online argument does not.

The philosophy is simple:

Document before the institution can redefine the event.

That principle extends beyond any individual dispute. It is a model of citizen oversight in an era when government decisions increasingly depend upon digital systems that most citizens never see.

Turning the Panopticon Around

The most provocative element of Tringali's philosophy is the concept of reciprocal surveillance.

The traditional Panopticon works because one side observes while the other side remains uncertain about who is watching, what is being recorded, and how the information will be used.

Tringali seeks to reverse that relationship.

If government deploys cameras, citizens should be able to ask what those cameras collect.

If automated systems identify vehicles, citizens should be able to ask what happens to the resulting data.

If private technology companies process governmental information, citizens should be able to ask what contractual and legal authorities govern that relationship.

If information is shared between agencies, citizens should be able to ask who authorized the sharing.

If surveillance information influences enforcement decisions, citizens should be able to ask what safeguards exist against error, misuse, or discriminatory application.

These questions do not require unauthorized access to computer systems.

They can be pursued through lawful discovery, public-records statutes, subpoenas, litigation, technical analysis of publicly available information, and democratic oversight.

That distinction matters.

The goal is not to “hack” a government network.

The goal is to make the architecture accountable.

Technology Does Not Eliminate Constitutional Rights

Modern technology creates an additional danger: the illusion that because something can be technologically measured, it can automatically be treated as administratively legitimate.

But constitutional rights do not disappear because information has been converted into data.

A person walking down a public street remains a person.

A person living without permanent housing remains a person.

A person whose vehicle is captured by an automated camera remains a person.

A person's movements do not become morally insignificant merely because a computer can record them.

Technology can identify.

Technology can categorize.

Technology can predict.

Technology can store.

Technology can correlate.

But technology cannot determine human dignity.

That remains a question of law, ethics, and public responsibility.

Homelessness and the Datafied Human Being

This issue becomes particularly stark in the context of homelessness.

When people without permanent housing are discussed exclusively through statistics, enforcement maps, incident reports, sanitation records, calls for service, and geographic databases, there is a danger that the human being disappears behind the dataset.

The individual becomes an “encampment.”

A “service call.”

A “nuisance.”

A “public-safety concern.”

A “case number.”

A “displacement.”

Tringali's ministry challenges that abstraction by putting the human being back into the story.

His work as an ordained minister and outreach worker places him directly in environments where policy becomes reality.

That creates an unusual position.

He is not simply observing homelessness from a conference room.

He is approaching the issue through ministry, advocacy, documentation, political participation, media, and litigation.

The message is deliberately confrontational:

A human being cannot be administratively reduced to a problem merely because the person is inconvenient to the system.

The Courtroom as a Transparency Engine

For Tringali, litigation is therefore not merely a mechanism for seeking damages.

It can also function as a transparency engine.

Discovery can demand records.

Depositions can establish who knew what and when.

Requests for production can identify contracts, policies, communications, technical documentation, and operational procedures.

Requests for admission can force parties to accept or deny specific factual propositions.

Public-records litigation can challenge governmental withholding.

And the resulting filings become part of a permanent public record.

The courtroom consequently becomes another arena in the struggle over information.

The institution has records.

The citizen demands the records.

The government provides an explanation.

The citizen tests that explanation against the evidence.

The court determines what the law permits.

That process is not anarchy.

It is adversarial democracy.

From Fiction to Reality

Storytelling has always served as a rehearsal space for society's fears.

That is why dystopian fiction remains powerful.

1984 was not simply a story about surveillance cameras. It was a warning about what happens when institutions acquire the ability to control information, language, memory, and individual identity.

Tringali's own creative work operates in a different medium but explores related questions: authority, fear, morality, survival, identity, redemption, and the struggle of individuals against forces larger than themselves.

Through Storytelling Adventures Studio Inc., those themes can exist simultaneously in fiction and nonfiction.

The fictional world can ask:

What happens when the system becomes all-powerful?

The real world can ask:

What safeguards prevent it from becoming so?

Those are different questions.

But they belong to the same conversation.

The New Citizen's Role

The traditional model of citizenship often assumes a relatively simple relationship.

Government governs.

Citizens vote.

Courts resolve disputes.

Journalists investigate.

Today that division is increasingly blurred.

A citizen can document an encounter with a smartphone.

A researcher can analyze public databases.

A journalist can publish records within minutes.

A litigant can use discovery to expose institutional practices.

A community can collectively preserve evidence.

Technology has therefore created a paradox.

The same digital infrastructure that makes surveillance more powerful can also make government more observable.

The same internet that allows institutions to distribute information can allow citizens to challenge institutional narratives.

The same database that categorizes human beings can become evidence in a courtroom.

The same camera that watches the public can become the subject of public scrutiny.

The Panopticon may therefore have acquired a new vulnerability:

The watchers themselves can be watched.

A Different Kind of Resistance

Tringali's approach is deliberately uncomfortable.

It rejects the idea that citizens must always communicate with institutions in the language institutions prefer.

It challenges bureaucratic euphemisms.

It documents contradictions.

It files records requests.

It asks technical questions.

It enters courtrooms.

It uses media.

It invokes constitutional principles.

And it places homelessness, surveillance, technology, and civil rights into the same conversation.

Whether every legal theory ultimately succeeds is a question for courts and evidence.

Whether every allegation is ultimately substantiated is likewise a question for the record.

But the larger question is already here.

How much power should a modern government possess to observe its citizens?

How much information should private technology companies possess about ordinary people?

What happens when government enforcement becomes dependent upon automated systems?

Who audits the algorithms?

Who audits the databases?

Who audits the contractors?

Who audits the police?

And, ultimately:

Who watches the watchers?

Perhaps the most important lesson of Orwell's 1984 was never that the future would look exactly like Oceania.

It was that freedom can disappear gradually when people stop asking questions about power.

Tringali's campaign, viewed through that lens, is fundamentally an argument for asking those questions loudly, repeatedly, and on the record.

Not because every camera is tyranny.

Not because every government employee is corrupt.

Not because every technology company is malicious.

But because concentrated power requires scrutiny.

Technology requires accountability.

Government requires transparency.

And human beings—especially those who possess the least institutional power—remain entitled to dignity.

The ultimate rebellion against the dystopian imagination is therefore not chaos.

It is accountability.

**Watch the watchers.

Preserve the record.

Challenge the narrative.

Defend human dignity.**

That is where the story leaves the page and enters the street.

REVEREND ZACHARIAH TRINGALI

House of Mercy Ministries

362 Green Street

Cambridge, Massachusetts 02129

603-661-9745

zacharytringali@gmail.com

August 8, 2026

VIA ELECTRONIC DELIVERY

TO: Public Records Officer / Legal Counsel

MANCHESTER POLICE DEPARTMENT

Manchester, New Hampshire

RE: RSA 91-A RIGHT-TO-KNOW REQUEST — MANCHESTER POLICE DEPARTMENT FLOCK/ALPR SURVEILLANCE, VEHICLE TRACKING, HOTLISTS, AUDIO, DATA SHARING, AND FIRST AMENDMENT ACTIVITY

Dear Public Records Officer:

Pursuant to RSA Chapter 91-A, I request copies of all public records concerning the Manchester Police Department's use, access, acquisition, deployment, operation, and sharing of automated license plate reader and vehicle-surveillance information.

The requested period is January 1, 2020 through August 8, 2026.

Please produce:

1. All Flock Safety contracts, agreements, renewals, amendments, invoices, purchase orders, proposals, and related records.

2. All contracts involving any ALPR, automated vehicle-surveillance, AI, predictive-policing, tracking, audio-surveillance, or related vendor.

3. All Flock/ALPR policies, procedures, training documents, manuals, general orders, directives, and retention policies.

4. All Flock/ALPR database search and access logs.

5. All audit trails identifying users who searched, viewed, exported, copied, or disseminated surveillance information.

6. All searches involving Reverend Zachariah Tringali, his vehicles, license plates, House of Mercy Ministries, ministry activities, religious gatherings, outreach activities, demonstrations, political activity, civil-rights advocacy, protests, or public assemblies.

7. All records identifying the reason, authorization, officer, supervisor, or governmental entity associated with each such search.

8. All warrants, subpoenas, court orders, exigent-circumstance requests, or other legal authority associated with searches of Flock/ALPR information.

9. All hotlist records, watchlists, BOLO records, automated alerts, vehicle fingerprints, and alert criteria.

10. All records concerning false-positive alerts, mistaken license-plate identification, mistaken vehicle identification, or erroneous surveillance information.

11. All records concerning sharing of Flock/ALPR data with federal agencies, New Hampshire agencies, other municipalities, counties, out-of-state agencies, or private entities.

12. All records concerning searches of Manchester surveillance data performed by outside agencies.

13. All records concerning Manchester Police searches of surveillance information collected outside Manchester.

14. All records concerning integration of Flock/ALPR systems with CAD, RMS, dispatch, NCIC, facial-recognition, predictive-policing, automated-alert, or other systems.

15. All records concerning audio capture, audio processing, microphones, listening functionality, recordings, or audio metadata associated with any surveillance system.

16. All records concerning any technology, system, vendor, or integration capable of communicating with or affecting the operation of a motor vehicle, including stopping, disabling, immobilizing, detaining, or generating an automated vehicle intervention.

17. All records concerning surveillance of churches, ministries, religious organizations, public worship, religious outreach, political demonstrations, civil-rights organizations, journalists, or other protected First Amendment activity.

18. All complaints, internal investigations, disciplinary records, audits, corrective actions, or misconduct findings concerning Flock/ALPR misuse.

19. All correspondence between Manchester Police and Flock Safety concerning constitutional rights, religious activity, First Amendment activity, protests, demonstrations, civil-rights activity, warrants, privacy, data retention, data sharing, or improper searches.

20. All records establishing how long Flock/ALPR data is retained and when it is deleted.

21. All records concerning requests by prosecutors, federal agencies, other police departments, or other governmental entities for Manchester Flock/ALPR information.

22. All records concerning Manchester Police requests for surveillance information maintained by other jurisdictions.

23. All training materials addressing constitutional limitations on ALPR searches, prolonged movement tracking, religious activity, protected association, political activity, and First Amendment rights.

24. All policies establishing whether an automated Flock alert must be independently verified before an officer conducts a vehicle stop or other enforcement action.

25. All records concerning any vehicle stop, detention, search, seizure, or investigation initiated, influenced, or supported by a Flock/ALPR alert involving Plaintiff.

If any portion is withheld or redacted, please identify the specific statutory exemption and provide the statutory citation and legal basis for withholding the material. Please release all reasonably segregable non-exempt portions.

Please provide electronic records electronically, preferably in native format where reasonably practicable.

Please preserve all responsive electronic records, including emails, text messages, database records, audit logs, access histories, metadata, search histories, system records, and surveillance records.

This request includes equivalent or successor systems even when the records do not use the word “Flock.”

Please provide the response required by RSA Chapter 91-A.

Sincerely,

REVEREND ZACHARIAH TRINGALI

House of Mercy Ministries

603-661-9745

zacharytringali@gmail.com

362 Green Street

Cambridge, Massachusetts 02129

REVEREND ZACHARIAH TRINGALI

House of Mercy Ministries

362 Green Street

Cambridge, Massachusetts 02129

603-661-9745

zacharytringali@gmail.com

August 8, 2026

VIA ELECTRONIC DELIVERY

TO: Public Records Officer / City Clerk / Legal Counsel

CITY OF MANCHESTER, NEW HAMPSHIRE

RE: RSA 91-A RIGHT-TO-KNOW REQUEST — CITYWIDE FLOCK SAFETY, ALPR, VEHICLE SURVEILLANCE, DATA SHARING, AUDIO, HOTLISTS, AND SURVEILLANCE TECHNOLOGY

Dear Public Records Officer:

Pursuant to RSA Chapter 91-A, I request copies of all public records concerning the City of Manchester's acquisition, deployment, operation, funding, use, access, sharing, and oversight of Flock Safety, automated license plate readers, vehicle-surveillance systems, AI surveillance, automated alerts, and related technologies.

This request covers January 1, 2020 through August 8, 2026.

This request is directed to the City of Manchester and includes all departments, divisions, offices, boards, commissions, contractors, and other municipal entities possessing responsive records, including but not limited to:

Manchester Police Department;

Manchester Fire Department;

Department of Information Technology;

Office of the Mayor;

City Solicitor's Office;

City Clerk;

Emergency Communications/Dispatch;

Code Enforcement;

Public Works;

Parking;

Transportation;

and any other municipal department or office possessing responsive records.

I request all records described in the attached/requested categories, including contracts, policies, training materials, data-sharing agreements, search logs, audit logs, hotlist criteria, warrants, subpoenas, technical documentation, camera deployment records, privacy policies, complaints, investigations, and communications.

I specifically request records concerning:

1. Flock Safety and every other ALPR vendor.

2. Automated vehicle identification and tracking.

3. Historical vehicle-location searches.

4. Hotlists and automated alerts.

5. Data sharing with federal, state, county, municipal, and out-of-state agencies.

6. Access to Flock databases by outside agencies.

7. Searches conducted by Manchester personnel through databases maintained by other agencies.

8. Searches concerning Reverend Zachariah Tringali, his vehicles, House of Mercy Ministries, ministry locations, public outreach, religious activity, demonstrations, protests, political activity, civil-rights activity, or public assemblies.

9. Any surveillance or database search undertaken because of protected First Amendment activity.

10. Any audio capability associated with surveillance technology.

11. Any integration between surveillance technology and dispatch, CAD, RMS, NCIC, facial-recognition, predictive-policing, or other governmental databases.

12. Any technology capable of communicating with or affecting a vehicle's operation, including systems capable of stopping, disabling, immobilizing, or generating an automated intervention concerning a vehicle.

13. Any documented malfunction, false positive, erroneous identification, or mistaken alert.

14. Any complaint, investigation, audit, disciplinary proceeding, or corrective action involving misuse of ALPR/Flock information.

15. All municipal policies concerning constitutional restrictions on surveillance of religious organizations, religious activity, political activity, journalists, protesters, civil-rights organizations, and protected assemblies.

If any responsive record is withheld, please identify the specific statutory exemption and provide the statutory basis for withholding it. Please release all reasonably segregable portions of otherwise responsive records.

Please provide electronic records electronically and in their native format where reasonably practicable.

Please preserve all responsive records, including electronically stored information, audit trails, metadata, access logs, search histories, database records, emails, text messages, contracts, and system records.

This request is intended to encompass records regardless of whether the City's records use the term “Flock.” Records concerning equivalent or successor ALPR, automated vehicle-surveillance, AI, tracking, alert, audio, or database systems are included.

Please provide the response required by RSA Chapter 91-A.

Sincerely,

REVEREND ZACHARIAH TRINGALI

House of Mercy Ministries

603-661-9745

zacharytringali@gmail.com

362 Green Street

Cambridge, Massachusetts 02129

REVEREND ZACHARIAH TRINGALI House of Mercy Ministries 362 Green Street Cambridge, Massachusetts 02129 603-661-9745 zacharytringali@gmail.com

August 8, 2026

VIA ELECTRONIC DELIVERY

TO: Public Records Officer / Legal Counsel MANCHESTER POLICE DEPARTMENT Manchester, New Hampshire

RE: RSA 91-A RIGHT-TO-KNOW REQUEST — MANCHESTER POLICE DEPARTMENT FLOCK/ALPR SURVEILLANCE, VEHICLE TRACKING, HOTLISTS, AUDIO, DATA SHARING, AND FIRST AMENDMENT ACTIVITY

Dear Public Records Officer:

Pursuant to RSA Chapter 91-A, I request copies of all public records concerning the Manchester Police Department's use, access, acquisition, deployment, operation, and sharing of automated license plate reader and vehicle-surveillance information.

The requested period is January 1, 2020 through August 8, 2026.

Please produce:

All Flock Safety contracts, agreements, renewals, amendments, invoices, purchase orders, proposals, and related records.

All contracts involving any ALPR, automated vehicle-surveillance, AI, predictive-policing, tracking, audio-surveillance, or related vendor.

All Flock/ALPR policies, procedures, training documents, manuals, general orders, directives, and retention policies.

All Flock/ALPR database search and access logs.

All audit trails identifying users who searched, viewed, exported, copied, or disseminated surveillance information.

All searches involving Reverend Zachariah Tringali, his vehicles, license plates, House of Mercy Ministries, ministry activities, religious gatherings, outreach activities, demonstrations, political activity, civil-rights advocacy, protests, or public assemblies.

All records identifying the reason, authorization, officer, supervisor, or governmental entity associated with each such search.

All warrants, subpoenas, court orders, exigent-circumstance requests, or other legal authority associated with searches of Flock/ALPR information.

All hotlist records, watchlists, BOLO records, automated alerts, vehicle fingerprints, and alert criteria.

All records concerning false-positive alerts, mistaken license-plate identification, mistaken vehicle identification, or erroneous surveillance information.

All records concerning sharing of Flock/ALPR data with federal agencies, New Hampshire agencies, other municipalities, counties, out-of-state agencies, or private entities.

All records concerning searches of Manchester surveillance data performed by outside agencies.

All records concerning Manchester Police searches of surveillance information collected outside Manchester.

All records concerning integration of Flock/ALPR systems with CAD, RMS, dispatch, NCIC, facial-recognition, predictive-policing, automated-alert, or other systems.

All records concerning audio capture, audio processing, microphones, listening functionality, recordings, or audio metadata associated with any surveillance system.

All records concerning any technology, system, vendor, or integration capable of communicating with or affecting the operation of a motor vehicle, including stopping, disabling, immobilizing, detaining, or generating an automated vehicle intervention.

All records concerning surveillance of churches, ministries, religious organizations, public worship, religious outreach, political demonstrations, civil-rights organizations, journalists, or other protected First Amendment activity.

All complaints, internal investigations, disciplinary records, audits, corrective actions, or misconduct findings concerning Flock/ALPR misuse.

All correspondence between Manchester Police and Flock Safety concerning constitutional rights, religious activity, First Amendment activity, protests, demonstrations, civil-rights activity, warrants, privacy, data retention, data sharing, or improper searches.

All records establishing how long Flock/ALPR data is retained and when it is deleted.

All records concerning requests by prosecutors, federal agencies, other police departments, or other governmental entities for Manchester Flock/ALPR information.

All records concerning Manchester Police requests for surveillance information maintained by other jurisdictions.

All training materials addressing constitutional limitations on ALPR searches, prolonged movement tracking, religious activity, protected association, political activity, and First Amendment rights.

All policies establishing whether an automated Flock alert must be independently verified before an officer conducts a vehicle stop or other enforcement action.

All records concerning any vehicle stop, detention, search, seizure, or investigation initiated, influenced, or supported by a Flock/ALPR alert involving Plaintiff.

If any portion is withheld or redacted, please identify the specific statutory exemption and provide the statutory citation and legal basis for withholding the material. Please release all reasonably segregable non-exempt portions.

Please provide electronic records electronically, preferably in native format where reasonably practicable.

Please preserve all responsive electronic records, including emails, text messages, database records, audit logs, access histories, metadata, search histories, system records, and surveillance records.

This request includes equivalent or successor systems even when the records do not use the word “Flock.”

Please provide the response required by RSA Chapter 91-A.

Sincerely,

REVEREND ZACHARIAH TRINGALI House of Mercy Ministries 603-661-9745 zacharytringali@gmail.com 362 Green Street Cambridge, Massachusetts 02129

“City Officials Sleep in Comfort While Others Sleep on Concrete”

A Signature Expression of Reverend Zachariah Tringali’s Homelessness Advocacy

Written by Storytelling Adventures Studio Inc.

“City officials sleep in comfort while others sleep on concrete.”

The sentence is deliberately stark. It is not bureaucratic language, and it is not intended to be. It is a rhetorical expression used by Reverend Zachariah Tringali to draw attention to what he describes as the profound distance between municipal decision-making and the lived reality of people experiencing homelessness.

At the heart of the phrase is a physical contrast: comfort versus concrete.

One represents security, shelter, privacy, warmth, and the ability to close a door at the end of the day. The other represents exposure, uncertainty, weather, police enforcement, displacement, and the absence of a secure place to sleep.

For Tringali, that contrast becomes a lens through which he examines municipal policy.

When a city closes a shelter, restricts public camping, conducts an encampment removal, or adopts policies affecting where unhoused people may sleep, the language of government can become highly technical: ordinance enforcement, public-space management, relocation, compliance, public safety, or encampment abatement.

Tringali's rhetoric deliberately moves in the opposite direction.

He brings the discussion back to the human being sleeping on the ground.

The question becomes simple:

Where is that person supposed to sleep tonight?

That is the force behind the phrase.

From City Hall to the Sidewalk

Tringali's advocacy frequently places municipal authority in direct conversation with street-level experience. His work through street ministry and homelessness advocacy emphasizes that policies affecting unhoused people are not merely administrative decisions. They determine where people can sleep, store possessions, seek safety, maintain community, and survive.

The phrase therefore functions as a challenge to institutional distance.

It asks elected officials, administrators, attorneys, police departments, and municipal policymakers to consider the practical consequences of decisions made inside government buildings.

A city council vote may take minutes.

An ordinance may occupy several pages.

A municipal memorandum may contain carefully constructed legal terminology.

But for someone living outside, the consequence may be immediate:

Tonight, there may be nowhere to go.

That is the rhetorical collision Tringali seeks to create.

“Comfort” and “Concrete”

The power of the expression comes from its simplicity.

“Comfort” symbolizes institutional security.

“Concrete” symbolizes exposure and vulnerability.

The phrase does not attempt to explain homelessness through statistics alone. It makes an argument through imagery. It asks the audience to visualize the difference between making policy from a protected office and experiencing that policy from a sidewalk, park, tent, doorway, or other exposed environment.

This is characteristic of Tringali's broader advocacy style: reducing complicated institutional questions to tangible human consequences.

Instead of asking only whether a municipal action is technically authorized, his rhetoric asks whether the action is humane, proportionate, and consistent with the dignity of the people affected.

The Street-Ministry Perspective

As a minister and outreach advocate, Tringali approaches homelessness not simply as a housing-policy question but as a question of human dignity.

The person sleeping outside is not merely an “encampment resident,” “unauthorized camper,” “transient,” or statistical category.

The person has a name.

The person has a history.

The person possesses belongings, relationships, beliefs, memories, and human dignity.

That perspective is central to the phrase.

“City officials sleep in comfort while others sleep on concrete” is therefore less a literal description of where individual officials sleep than a rhetorical indictment of the distance between governmental power and human vulnerability.

It is a demand that policymakers confront the consequences of their decisions at street level.

A Challenge to Bureaucratic Language

Municipal government necessarily operates through laws, regulations, budgets, procedures, and administrative terminology.

But Tringali's argument is that bureaucratic language can sometimes obscure the human consequences behind a policy.

“Encampment removal” can sound administrative.

“Relocation” can sound neutral.

“Ordinance enforcement” can sound procedural.

But the person affected may experience the same event as the loss of a sleeping place, the destruction or removal of possessions, separation from a community, or another night without shelter.

His rhetoric therefore attempts to translate government terminology into human terms.

What does this policy mean when experienced by the person standing on the sidewalk?

That is the question beneath the slogan.

A Broader Moral Argument

The expression ultimately represents a larger philosophy within Tringali's advocacy:

A government should be judged not only by how efficiently it manages public space, but also by how it treats people who have the least power within that space.

The phrase challenges the assumption that homelessness can be solved simply by moving homeless people somewhere else.

It asks what happens after the police leave.

Where does the person go?

Where are their belongings?

Where will they sleep?

Where will they obtain food, medication, identification, employment, transportation, or social services?

And, perhaps most importantly:

What happens when there is nowhere else to go?

That is where “comfort versus concrete” becomes more than a slogan.

It becomes a framework for examining public policy.

The Storytelling Adventures Studio Perspective

Storytelling Adventures Studio Inc. presents this expression as part of the evolving public voice of Reverend Zachariah Tringali and his homelessness advocacy.

Its strength lies in its accessibility.

A person does not need a law degree to understand the difference between sleeping safely indoors and sleeping on concrete.

They do not need to understand municipal budgeting to understand what it means to have nowhere to sleep.

They do not need to study administrative law to understand the fear of losing the only place where they can keep their belongings.

The phrase takes a complicated political and social debate and reduces it to a fundamental human question:

If those with power have a safe place to sleep, why should the people without power be expected to accept concrete as their bed?

That question is the heart of the rhetoric.

And that is why the phrase endures as a defining expression within Tringali's public advocacy: it forces the conversation away from paperwork, terminology, and political abstraction—and back toward the human being lying on the ground.

**City officials sleep in comfort.

Others sleep on concrete.

The distance between those two realities is where the homelessness debate begins.**

“City Officials Sleep in Comfort While Others Sleep on Concrete”

A Signature Expression of Reverend Zachariah Tringali’s Homelessness Advocacy

Written by Storytelling Adventures Studio Inc.

“City officials sleep in comfort while others sleep on concrete.”

The sentence is deliberately stark. It is not bureaucratic language, and it is not intended to be. It is a rhetorical expression used by Reverend Zachariah Tringali to draw attention to what he describes as the profound distance between municipal decision-making and the lived reality of people experiencing homelessness.

At the heart of the phrase is a physical contrast: comfort versus concrete.

One represents security, shelter, privacy, warmth, and the ability to close a door at the end of the day. The other represents exposure, uncertainty, weather, police enforcement, displacement, and the absence of a secure place to sleep.

For Tringali, that contrast becomes a lens through which he examines municipal policy.

When a city closes a shelter, restricts public camping, conducts an encampment removal, or adopts policies affecting where unhoused people may sleep, the language of government can become highly technical: ordinance enforcement, public-space management, relocation, compliance, public safety, or encampment abatement.

Tringali's rhetoric deliberately moves in the opposite direction.

He brings the discussion back to the human being sleeping on the ground.

The question becomes simple:

Where is that person supposed to sleep tonight?

That is the force behind the phrase.

From City Hall to the Sidewalk

Tringali's advocacy frequently places municipal authority in direct conversation with street-level experience. His work through street ministry and homelessness advocacy emphasizes that policies affecting unhoused people are not merely administrative decisions. They determine where people can sleep, store possessions, seek safety, maintain community, and survive.

The phrase therefore functions as a challenge to institutional distance.

It asks elected officials, administrators, attorneys, police departments, and municipal policymakers to consider the practical consequences of decisions made inside government buildings.

A city council vote may take minutes.

An ordinance may occupy several pages.

A municipal memorandum may contain carefully constructed legal terminology.

But for someone living outside, the consequence may be immediate:

Tonight, there may be nowhere to go.

That is the rhetorical collision Tringali seeks to create.

“Comfort” and “Concrete”

The power of the expression comes from its simplicity.

“Comfort” symbolizes institutional security.

“Concrete” symbolizes exposure and vulnerability.

The phrase does not attempt to explain homelessness through statistics alone. It makes an argument through imagery. It asks the audience to visualize the difference between making policy from a protected office and experiencing that policy from a sidewalk, park, tent, doorway, or other exposed environment.

This is characteristic of Tringali's broader advocacy style: reducing complicated institutional questions to tangible human consequences.

Instead of asking only whether a municipal action is technically authorized, his rhetoric asks whether the action is humane, proportionate, and consistent with the dignity of the people affected.

The Street-Ministry Perspective

As a minister and outreach advocate, Tringali approaches homelessness not simply as a housing-policy question but as a question of human dignity.

The person sleeping outside is not merely an “encampment resident,” “unauthorized camper,” “transient,” or statistical category.

The person has a name.

The person has a history.

The person possesses belongings, relationships, beliefs, memories, and human dignity.

That perspective is central to the phrase.

“City officials sleep in comfort while others sleep on concrete” is therefore less a literal description of where individual officials sleep than a rhetorical indictment of the distance between governmental power and human vulnerability.

It is a demand that policymakers confront the consequences of their decisions at street level.

A Challenge to Bureaucratic Language

Municipal government necessarily operates through laws, regulations, budgets, procedures, and administrative terminology.

But Tringali's argument is that bureaucratic language can sometimes obscure the human consequences behind a policy.

“Encampment removal” can sound administrative.

“Relocation” can sound neutral.

“Ordinance enforcement” can sound procedural.

But the person affected may experience the same event as the loss of a sleeping place, the destruction or removal of possessions, separation from a community, or another night without shelter.

His rhetoric therefore attempts to translate government terminology into human terms.

What does this policy mean when experienced by the person standing on the sidewalk?

That is the question beneath the slogan.

A Broader Moral Argument

The expression ultimately represents a larger philosophy within Tringali's advocacy:

A government should be judged not only by how efficiently it manages public space, but also by how it treats people who have the least power within that space.

The phrase challenges the assumption that homelessness can be solved simply by moving homeless people somewhere else.

It asks what happens after the police leave.

Where does the person go?

Where are their belongings?

Where will they sleep?

Where will they obtain food, medication, identification, employment, transportation, or social services?

And, perhaps most importantly:

What happens when there is nowhere else to go?

That is where “comfort versus concrete” becomes more than a slogan.

It becomes a framework for examining public policy.

The Storytelling Adventures Studio Perspective

Storytelling Adventures Studio Inc. presents this expression as part of the evolving public voice of Reverend Zachariah Tringali and his homelessness advocacy.

Its strength lies in its accessibility.

A person does not need a law degree to understand the difference between sleeping safely indoors and sleeping on concrete.

They do not need to understand municipal budgeting to understand what it means to have nowhere to sleep.

They do not need to study administrative law to understand the fear of losing the only place where they can keep their belongings.

The phrase takes a complicated political and social debate and reduces it to a fundamental human question:

If those with power have a safe place to sleep, why should the people without power be expected to accept concrete as their bed?

That question is the heart of the rhetoric.

And that is why the phrase endures as a defining expression within Tringali's public advocacy: it forces the conversation away from paperwork, terminology, and political abstraction—and back toward the human being lying on the ground.

**City officials sleep in comfort.

Others sleep on concrete.

The distance between those two realities is where the homelessness debate begins.**

My name is Reverend Zachariah Tringali I am currently running for alderman Ward 6

A Call from the Rubble: The Closing of 39 Beach Street

Delivered in Manchester, New Hampshire

Ladies and gentlemen, neighbors, watchmen of this weary city—

Tonight, I do not come bearing niceties nor muttered apologies for discomfort. I come, rather, to strike a match of reckoning upon the damp parchment of political negligence. For we stand now at the unmarked funeral of 39 Beach Street—another shelter closed, another threshold swept away by the cold hand of austerity, another home turned into absence.

Yes—closed, not for the safety of its residents, nor for better prospects, but as a casualty of “cost-cutting,” that sterile euphemism for gutting the bones of human need. We are told it is due to the burdens of infrastructure, that funding must be diverted—a word far too polite for what is plainly abandonment.

But I ask you: what costlier infrastructure exists than a city’s own people strewn beneath bridges, wrapped in blue tarps, whispering prayers not to God but to frostbite?

How dare we speak of budgets when tents multiply like tombstones? When every eviction echoes like thunder in the alleyways? How can a city call itself civilized when it slashes shelter and then turns its eyes away from the rising tide of human despair?

No. This is not prudence. This is malevolence disguised in municipal protocol.

And yet—I do not come bearing only lamentation. I bring solution.

Rooming houses. Yes, rooming houses—an age-old remedy for those in need of dignity without decadence. Affordable, sustainable, community-rooted. We have the blueprint in hand, a plan designed not for the proud pockets of developers, but for the common man: veterans, single mothers, those cast aside by the tempest of circumstance. These structures are not castles, but sanctuaries—stepping stones, not tombstones.

But we must act, and we must act now. The closure of Beach Street must be the last of its kind, not the herald of many. For every tent we ignore, a city soul is forgotten. For every shelter shuttered, a future is forfeited.

And let us speak, plainly, of the other cancers within our civic body:

Our sidewalks—cracked like forgotten promises, treacherous to the elderly, cruel to the disabled.

Our public trash houses—monuments to our own neglect, breeding grounds for vermin and contempt.

And our neighborhoods, afflicted with the tinnitus of unceasing exhaust and music weaponized into violence—where bass and bravado replace peace and safety. This is not vibrancy; this is vulgarity made ambient.

Where is enforcement? Where is respect? Where is the civic spine?

The soul of a city is not measured by her skyline or her festivals, but by the state of her forgotten corners. And Manchester, I say this with righteous indignation, is decaying in silence while pretending to smile.

Let no one mistake our tone tonight. This is not anger without purpose. This is not protest without plan. This is a call to conscience. We are not asking—we are demanding that human dignity be restored to the ledger of city priorities.

Build the rooming houses. Fix the sidewalks. Enforce the noise laws. Clean the filth. Reclaim our streets.

If we fail to act, we will not merely have homelessness. We will have hopelessness—and that, my friends, is far more dangerous.

Let 39 Beach Street be the line in the sand. Let it be the final insult that awakens our collective will. If the city won’t listen to compassion, then let it tremble before our conviction.

Because if we don’t stand now, soon there will be no place left to stand.

Thank you.

PLAINTIFF'S EVIDENTIARY OBJECTION AND REQUEST FOR JUDICIAL REVIEW OF THE SEPTEMBER 26, 2025 “NOTICE TO VACATE PROPERTY”

UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Tringali v. Hillsborough County Sheriff's Department, et al.

Civil Action No. 1:26-cv-00350-SM

PLAINTIFF'S NOTICE OF MATERIAL EVIDENCE CONCERNING THE SEPTEMBER 26, 2025 “NOTICE TO VACATE PROPERTY” USED IN CONNECTION WITH THE NOVEMBER 4, 2025 ENCAMPMENT OPERATION

Plaintiff respectfully submits the attached photograph of a document entitled “NOTICE TO VACATE PROPERTY”, dated September 26, 2025, as material evidence concerning the governmental authority, notice, authorization, and procedures relied upon in connection with the November 4, 2025 operation at or concerning the Stark Park encampment.

I. THE DOCUMENT DOES NOT IDENTIFY PLAINTIFF OR HIS ORGANIZATION

The document is addressed generically to:

“All individuals camping on State property”

It does not identify Plaintiff by name.

It does not identify Reverend Zachariah Tringali.

It does not identify House of Mercy Ministries.

It does not identify any particular occupant, ministry, organization, property owner, or property custodian.

Accordingly, Defendants should be required to establish whether this generic notice was actually intended to provide legally sufficient notice to Plaintiff personally or to any property belonging to Plaintiff or House of Mercy Ministries.

II. THE DOCUMENT DOES NOT IDENTIFY THE GOVERNMENTAL OFFICIAL WHO ISSUED OR AUTHORIZED IT

The document concludes only:

“Posted by the State of New Hampshire, September 26, 2025.”

It does not identify:

the State agency;

the State official;

the official's title;

the governmental board allegedly exercising jurisdiction;

the person who physically posted the notice;

the law-enforcement agency requested to enforce it;

the legal instrument authorizing the posting; or

any court proceeding associated with the notice.

This is significant because RSA 236:58 does not simply authorize any governmental actor to prohibit camping on any property. The statute refers to permission from the governing board of the governmental authority having jurisdiction over the property.

General Court of New Hampshire

Therefore, the identity and legal authority of the entity that issued the September 26 notice are material facts.

III. THE NOTICE DOES NOT APPEAR TO BE A JUDICIAL ORDER

The document is not captioned as a court order.

It contains no court name.

It contains no docket number.

It contains no case number.

It contains no judge's name.

It contains no judicial signature.

It contains no clerk certification.

It contains no judicial seal.

Plaintiff does not contend that every administrative notice necessarily requires a judge's signature. Rather, Plaintiff submits that Defendants should not characterize this document as a judicial authorization for the November 4 operation unless they can produce competent evidence establishing that such judicial authorization existed.

That distinction is critical.

A notice posted by an executive or administrative governmental entity is not automatically equivalent to a judicial warrant, judicial eviction order, or judicial authorization to seize and destroy personal property.

IV. THE DOCUMENT EXPRESSLY CLAIMS THAT THE PROPERTY IS OWNED BY THE STATE

The notice expressly states:

“This property is owned by the State of New Hampshire.”

This statement creates a material factual issue if the notice was posted at Stark Park.

The City of Manchester identifies Stark Park as a City park under its Parks and Recreation Department and describes it as a historic asset of the City of Manchester.

City of Manchester

Consequently, Defendants should be required to establish through competent property records:

Who owned the precise parcel where the September 26 notice was posted on September 26, 2025?

That question should not be resolved merely by the language printed on the notice.

Plaintiff therefore requests production of the deed, parcel identification, property map, State ownership record, City ownership record, easement documents, or other documentary evidence establishing the governmental entity possessing jurisdiction over the precise location.

V. RSA 236:58 DOES NOT ITSELF ESTABLISH AUTHORITY TO SEIZE AND DESTROY PERSONAL PROPERTY

RSA 236:58 prohibits camping on public property without permission from the governmental authority having jurisdiction.

General Court of New Hampshire

RSA 236:59 establishes penalties for violations of RSA 236:58.

General Court of New Hampshire

But Defendants should be required to identify the separate legal authority they contend permitted them, on November 4, 2025, to:

enter the encampment;

remove individuals;

seize personal property;

remove Plaintiff's ministry property;

destroy or dispose of property;

transport property away from the site;

prevent Plaintiff from retrieving property; or

authorize a private contractor to destroy or dispose of property.

The existence of a camping prohibition does not, standing alone, answer those separate constitutional questions.

VI. THE TIMELINE REQUIRES PARTICULARIZED EXPLANATION

The notice is dated September 26, 2025 and establishes October 6, 2025 as the stated deadline.

The challenged operation occurred on November 4, 2025, approximately four weeks after that deadline.

Accordingly, Defendants should be required to produce the documents demonstrating what occurred between October 6 and November 4, including:

enforcement referrals;

Sheriff's Department communications;

Manchester Police communications;

State agency communications;

City communications;

property inventories;

photographs;

body-camera footage;

dispatch records;

emails;

memoranda;

operational plans;

instructions concerning personal property;

authorization for disposal;

contractor instructions;

evidence-retention records; and

any warrant, court order, administrative order, or other legal process relied upon.

VII. AUTHENTICITY AND AUTHORITY OF THE DOCUMENT SHOULD BE ESTABLISHED THROUGH THE GOVERNMENT'S OWN RECORDS

Plaintiff does not ask the Court to assume that the document is fraudulent merely because it lacks a signature.

Rather, Plaintiff requests that Defendants be required to establish the document's provenance.

Specifically:

Who created it?

Who authorized it?

What agency created it?

Where was it posted?

Who posted it?

What property parcel was involved?

What governmental entity had jurisdiction?

Was it intended to provide notice to Plaintiff?

What authority allegedly permitted law enforcement to enforce it?

What authority allegedly permitted seizure or destruction of personal property?

These are factual questions directly relevant to the legality of the November 4 operation.

VIII. THE DOCUMENT SHOULD NOT BE TREATED AS A SUBSTITUTE FOR WARRANT OR JUDICIAL PROCESS

Plaintiff respectfully submits that Defendants should not be permitted to use the September 26 notice as a substitute for whatever constitutional or statutory authority was required for the subsequent governmental seizure and destruction of property.

The Court should distinguish between:

(1) a general administrative notice prohibiting camping;

(2) authority to enforce a violation of RSA 236:58;

(3) authority to remove persons from property;

(4) authority to seize personal property;

(5) authority to permanently deprive persons of their property; and

(6) authority to destroy or dispose of property.

Those are not necessarily the same legal question.

REQUEST FOR RELIEF

Plaintiff respectfully requests that the Court:

Accept the attached September 26, 2025 “Notice to Vacate Property” as an exhibit;

Require Defendants to identify the governmental entity and individual official who issued and/or authorized the notice;

Require Defendants to establish the ownership and governmental jurisdiction of the precise property where the notice was posted;

Require Defendants to produce the original or official copy of the notice and records establishing its provenance;

Require Defendants to identify the legal authority relied upon for the November 4, 2025 operation;

Require Defendants to identify the separate legal authority relied upon for the seizure, removal, destruction, or disposal of personal property;

Require production of all communications between the State of New Hampshire, City of Manchester, Manchester Police Department, Hillsborough County Sheriff's Department, contractors, and other governmental actors concerning the notice and subsequent operation; and

Consider the absence of individualized notice, issuing-official identification, judicial process, and documented authority as relevant evidence when determining whether the November 4, 2025 operation violated Plaintiff's constitutional rights.

Respectfully submitted,

Reverend Zachariah Tringali

Plaintiff, Pro Se

House of Mercy Ministries

362 Green Street

Cambridge, MA 02129

603-661-9745

zacharytringali@gmail.com

Name ____________________________

X_________________________________

Date_________________

Witness ____________________________

X__________________________________

Date_______________

ADRESS___________________________

EXHIBIT FOR NOTICE TO VACATE PROPERTY POSTED AT DIFFERENT LOCATIONS NOT ONE IN AREA OF PARK FOR THIS NOTICE BACKSIDE PARK NEAR TRACKS HALF WAY UP ON LEFT TRAIL SECTOR OUR ENCAMPMENT WAS SEE PHOTOS OF CLEAN ENCAMPMENT OTHER ONE WAS OLD OR OTHER INDIVIDUALS LIVED THERE.

MINE HAD

Jen Kulgowaski

Dyral F

Jamie Levine

And person staying for day or two until bed available at Gateway rehab Nashua

Other residents in or around locations throughout the park.

This notification was given by George Thonburg as evidence

​

--- Please respond above this line ---

RE: Public Records Request of July 27, 2026, Reference # P261936-072726.

Dear Reverend Zachariah Tringali,

I write in response to your request:

 "I request that the Cambridge Police Department conduct a thorough internal review to determine:

Whether repeated reports concerning Avery White and Michael Potter were knowingly false or lacked a factual basis.

Which officers responded to each incident.

Whether departmental policies regarding investigation and documentation were followed.

Whether any individual knowingly made repeated false reports to law enforcement.

I am prepared to provide testimony regarding my observations if this matter proceeds through administrative proceedings or litigation.

Pursuant to the Massachusetts Public Records Law, I also request copies of all records relating to these incidents, including but not limited to:

All incident reports.

All police call logs and CAD dispatch records.

All responding officers' body-worn camera footage.

Cruiser camera footage, if available.

Officer notes and supplemental reports.

Audio recordings of 911 and non-emergency calls, where releasable.

Any photographs or evidence collected.

The names and badge numbers of all responding officers.

Any internal communications relating to these incidents.

Please provide these records electronically by email whenever possible.

This letter also serves as notice that these records should be preserved. I request that no responsive evidence be destroyed or altered while these matters remain under review or while legal claims are being evaluated.

LEGAL LITIGATION HOLD NOTICE AND DEMAND TO PRESERVE EVIDENCE

This letter serves as a formal Litigation Hold Notice. Because litigation is reasonably anticipated, the Cambridge Police Department, the City of Cambridge, all responding officers, supervisors, dispatch personnel, and any other custodians of records are directed to immediately preserve all potentially relevant evidence.

This preservation demand includes, but is not limited to:

All body-worn camera recordings.

Cruiser camera video.

911 and non-emergency call recordings.

CAD dispatch logs.

Incident reports and supplemental reports.

Officer notes, field interview cards, and investigative files.

Emails, text messages, and internal communications.

Computer-aided dispatch data.

GPS and AVL vehicle location records.

Radio transmissions.

Digital photographs and video.

Any records concerning complaints made by or attributed to Dennis Coleman regarding Avery White or Michael Potter.

Any Child Protective Services communications or referrals, to the extent maintained by the department.

Any electronically stored information (ESI), including metadata and archived or deleted records.

The intentional destruction, alteration, deletion, or failure to preserve relevant evidence after notice of anticipated litigation may constitute spoliation of evidence and may subject the responsible parties to sanctions or other remedies under Massachusetts law and applicable court rules.

Massachusetts Public Records Request

This request is made pursuant to the Massachusetts Public Records Law, Massachusetts General Laws Chapter 66, Section 10, together with the definition of public records contained in Massachusetts General Laws Chapter 4, Section 7, Clause 26.

I request that all responsive records be produced electronically via email whenever possible. If any portion of a record is withheld, I request a written explanation identifying the specific statutory exemption relied upon for each withheld record or redaction."

The City is treating your inquiry as a public records request pursuant to G.L. c. 66, § 10.

The City has located four sets of records which may be responsive to your request.  These incidents took place on May 31, 2026, June 30, 2026, July 3, 2026, and July 25,2026.  If you are aware of additional sets of records that I should be searching for, please update me with further information so that I may assist you.

The City is denying your request, as this information is exempt from disclosure, specifically for the following reasons:

G. L. c. 4 § 7(26)(f): Records which pertain to an active investigation.

You have a right to appeal these redactions to the Supervisor of Public Records under 950 CMR § 32.08(1) and have a right to seek judicial review of an unfavorable decision by commencing a civil action in the superior court.

Because providing the requested records took less than two hours of staff time, and the records are being produced electronically, pursuant to 950 CMR § 32.07(2)(m) there will be no charge for responding to this public records request.

Sincerely,



Seah Levy

Public Records Access Officer

Law Department

Cambridge City Hall

795 Massachusetts Avenue

Cambridge, MA 02139

publicrecords@cambridgema.gov

Submit a Public Records Request ●  Public Records Center



COMMONWEALTH OF MASSACHUSETTS

MIDDLESEX, ss.

SUPERIOR COURT DEPARTMENT

___________________________________

REVEREND ZACHARIAH TRINGALI,

Plaintiff,

v.

CITY OF CAMBRIDGE, through its

Records Access Officer and appropriate municipal officials,

Defendant.

---

CIVIL ACTION #______________

COMPLAINT FOR JUDICIAL REVIEW AND ENFORCEMENT OF THE MASSACHUSETTS PUBLIC RECORDS LAW

G.L. c. 66, §§ 10 and 10A

---

INTRODUCTION

1. This action seeks judicial enforcement of the Massachusetts Public Records Law, G.L. c. 66, §§ 10 and 10A.

2. Plaintiff Reverend Zachariah Tringali submitted a written public-records request to the City of Cambridge concerning police incidents involving Avery White and Michael Potter and records concerning reports attributed to Dennis Coleman.

3. The request sought existing governmental records, including incident reports, CAD and dispatch records, body-worn-camera recordings, cruiser-camera recordings, 911 and non-emergency call recordings, officer notes and supplemental reports, photographs, evidence records, identifying information concerning responding officers, and related communications.

4. Plaintiff also requested preservation of potentially relevant evidence because litigation was reasonably anticipated.

5. The City assigned the request Reference No. P261936-072726.

6. In its response, the City identified four sets of potentially responsive records concerning incidents occurring on May 31, 2026, June 30, 2026, July 3, 2026, and July 25, 2026.

7. The City nevertheless denied the requested records by relying generally upon G.L. c. 4, § 7(26)(f), characterizing the records as pertaining to an active investigation.

8. The City's response does not adequately identify which specific records or portions of records are being withheld, does not sufficiently explain the factual basis for applying the investigatory exemption to each category of requested records, and does not establish that all reasonably segregable non-exempt material has been released.

9. Plaintiff therefore seeks judicial review and enforcement under G.L. c. 66, § 10A(c).

JURISDICTION AND VENUE

10. This Court has jurisdiction pursuant to G.L. c. 66, § 10A(c).

11. G.L. c. 66, § 10A(c) expressly authorizes a requester to initiate a civil action to enforce the requirements of the Public Records Law.

12. Because Defendant is a municipality, this action is properly brought in the Superior Court in the county in which the municipality is located.

13. The City of Cambridge is located in Middlesex County.

THE PUBLIC RECORDS REQUEST

14. On July 27, 2026, Plaintiff submitted a written request to the City of Cambridge pursuant to G.L. c. 66, § 10.

15. Plaintiff's request reasonably described the governmental records sought.

16. Plaintiff requested records relating to identified police incidents and requested electronic production where reasonably available.

17. The request included, among other things:

a. incident reports;

b. police call logs;

c. CAD dispatch records;

d. body-worn-camera recordings;

e. cruiser-camera recordings;

f. officer notes and supplemental reports;

g. 911 and non-emergency call recordings;

h. photographs and evidence records;

i. names and badge numbers of responding officers;

j. internal communications relating to the incidents;

k. radio transmissions;

l. GPS and AVL records where maintained and responsive;

m. digital photographs and video;

n. records concerning complaints made by or attributed to Dennis Coleman regarding Avery White or Michael Potter; and

o. other electronically stored information relating to the identified incidents.

18. Plaintiff's request also expressly requested that responsive evidence be preserved.

THE CITY'S RESPONSE

19. The City treated Plaintiff's submission as a public-records request under G.L. c. 66, § 10.

20. The City subsequently identified four sets of potentially responsive records concerning May 31, 2026, June 30, 2026, July 3, 2026, and July 25, 2026.

21. The City stated that it was denying the request because the information was allegedly exempt under G.L. c. 4, § 7(26)(f), relating to records pertaining to an active investigation.

22. The City's response did not provide Plaintiff with the requested records.

23. The response did not identify each individual record being withheld.

24. The response did not identify whether CAD records, call logs, officer-identification information, incident reports, recordings, photographs, or other categories were being withheld in their entirety or only in part.

25. The response did not adequately explain why disclosure of each withheld record or portion thereof would prejudice effective law enforcement.

26. The response did not establish that reasonably segregable non-exempt portions of the requested records had been released.

27. Plaintiff contends that the City's categorical denial is inconsistent with the requirements of the Massachusetts Public Records Law.

COUNT I

VIOLATION OF G.L. c. 66, § 10

28. Plaintiff incorporates paragraphs 1 through 27 as though fully set forth herein.

29. G.L. c. 66, § 10 requires a records access officer, without unreasonable delay, to permit inspection or furnish copies of public records or any segregable portion of a public record, subject to applicable statutory exemptions.

30. The statute requires an agency or municipality that intends to withhold records to identify the records or categories of records being withheld and provide the specific reasons for withholding them, including the specific exemption or exemptions relied upon.

31. The City has identified four sets of potentially responsive records but has not sufficiently particularized the records or portions of records being withheld.

32. The City's response therefore fails to provide Plaintiff with a sufficiently particularized basis for determining what records have been withheld and why.

33. Plaintiff is entitled to production of all responsive records that are not exempt from disclosure.

COUNT II

IMPROPER APPLICATION OF THE INVESTIGATORY EXEMPTION

34. Plaintiff incorporates paragraphs 1 through 33.

35. The City relies upon G.L. c. 4, § 7(26)(f).

36. Plaintiff does not contend that every investigative record must necessarily be disclosed.

37. Plaintiff contends, however, that the City cannot establish that every category of requested record is exempt merely by characterizing the records generally as relating to an active investigation.

38. The City must establish the applicability of the claimed exemption to the records or portions of records withheld.

39. The City has not sufficiently demonstrated that disclosure of each withheld record would prejudice effective law enforcement.

40. The City has also failed to demonstrate that non-exempt and reasonably segregable portions of the records cannot be produced.

41. The Court should therefore require the City to conduct a record-by-record review and produce all records or portions of records that are not lawfully exempt.

COUNT III

FAILURE TO PRODUCE SEGREGABLE RECORDS

42. Plaintiff incorporates paragraphs 1 through 41.

43. Massachusetts Public Records Law requires disclosure of public records and segregable portions of records unless a valid statutory exemption applies.

44. The City's response does not establish that it conducted an adequate segregation analysis.

45. Even if portions of particular investigative records are legitimately exempt, factual and administrative portions that can be segregated must be produced unless independently exempt.

46. Plaintiff therefore requests that the Court order the City to produce all reasonably segregable portions of responsive records.

COUNT IV

REQUEST FOR IN CAMERA REVIEW

47. Plaintiff incorporates paragraphs 1 through 46.

48. If Defendant maintains that particular records are exempt under G.L. c. 4, § 7(26)(f), Plaintiff requests that the Court conduct an in camera review of the withheld records as necessary to determine whether the claimed exemption applies.

49. Plaintiff further requests that the Court determine whether redaction and segregation can permit disclosure of portions of records while protecting any legitimately exempt information.

COUNT V

JUDICIAL ENFORCEMENT UNDER G.L. c. 66, § 10A(c)

50. Plaintiff incorporates paragraphs 1 through 49.

51. G.L. c. 66, § 10A(c) authorizes a requester to bring a civil action to enforce the requirements of the Public Records Law.

52. The Superior Court has authority to provide remedies at law or in equity and to enjoin unlawful municipal action.

53. The statute further provides that the Court shall determine the propriety of the agency or municipal action de novo.

54. The statute provides a presumption that each requested record is public and places upon the municipality the burden of proving, by a preponderance of the evidence, that a record or portion of a record may lawfully be withheld.

55. Plaintiff seeks enforcement of those statutory rights.

REQUEST FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that this Court:

A. Assume jurisdiction over this action pursuant to G.L. c. 66, § 10A(c);

B. Determine de novo whether Defendant's withholding of the requested records complies with the Massachusetts Public Records Law;

C. Declare that Defendant has not adequately established that all requested records or portions thereof are exempt from disclosure;

D. Order Defendant to produce all responsive public records that are not exempt from disclosure;

E. Order Defendant to produce reasonably segregable portions of any records containing both exempt and non-exempt information;

F. Require Defendant to identify with reasonable specificity each record or category of record withheld and the statutory exemption relied upon;

G. Require Defendant, where necessary, to submit withheld records for in camera review;

H. Order Defendant to preserve all potentially responsive records, recordings, electronically stored information, metadata, CAD data, dispatch records, body-worn-camera footage, cruiser-camera footage, radio transmissions, photographs, reports, notes, and related records pending resolution of this action;

I. Expedite this proceeding to the extent permitted by G.L. c. 66, § 10A(d);

J. Award Plaintiff reasonable attorney's fees and litigation costs to the extent authorized by G.L. c. 66, § 10A(d);

K. Award such other relief as the Court considers just and proper.

Respectfully submitted,

REVEREND ZACHARIAH TRINGALI

Plaintiff, Pro Se

House of Mercy Ministries

Outreach Director

(603) 661-9745

zacharytringali@gmail.com

362 Green Street

Cambridge, MA 02129

Date: ______________________

VERIFICATION

I, Reverend Zachariah Tringali, declare under the pains and penalties of perjury that I have read the foregoing Complaint and that the factual allegations contained therein are true and accurate to the best of my knowledge, information, and belief.

Signed under the pains and penalties of perjury.

Reverend Zachariah Tringali

X_______________________________

Date: ___________________________

ADRESS__________________________

Hide quoted text

On Mon, Aug 10, 2026, 12:24 PM City of Cambridge Law Department <cambridgema@mycusthelp.net> wrote:

--- Please respond above this line ---

RE: Public Records Request of July 27, 2026, Reference # P261936-072726.

Dear Reverend Zachariah Tringali,

I write in response to your request:

 "I request that the Cambridge Police Department conduct a thorough internal review to determine:

Whether repeated reports concerning Avery White and Michael Potter were knowingly false or lacked a factual basis.

Which officers responded to each incident.

Whether departmental policies regarding investigation and documentation were followed.

Whether any individual knowingly made repeated false reports to law enforcement.

I am prepared to provide testimony regarding my observations if this matter proceeds through administrative proceedings or litigation.

Pursuant to the Massachusetts Public Records Law, I also request copies of all records relating to these incidents, including but not limited to:

All incident reports.

All police call logs and CAD dispatch records.

All responding officers' body-worn camera footage.

Cruiser camera footage, if available.

Officer notes and supplemental reports.

Audio recordings of 911 and non-emergency calls, where releasable.

Any photographs or evidence collected.

The names and badge numbers of all responding officers.

Any internal communications relating to these incidents.

Please provide these records electronically by email whenever possible.

This letter also serves as notice that these records should be preserved. I request that no responsive evidence be destroyed or altered while these matters remain under review or while legal claims are being evaluated.

LEGAL LITIGATION HOLD NOTICE AND DEMAND TO PRESERVE EVIDENCE

This letter serves as a formal Litigation Hold Notice. Because litigation is reasonably anticipated, the Cambridge Police Department, the City of Cambridge, all responding officers, supervisors, dispatch personnel, and any other custodians of records are directed to immediately preserve all potentially relevant evidence.

This preservation demand includes, but is not limited to:

All body-worn camera recordings.

Cruiser camera video.

911 and non-emergency call recordings.

CAD dispatch logs.

Incident reports and supplemental reports.

Officer notes, field interview cards, and investigative files.

Emails, text messages, and internal communications.

Computer-aided dispatch data.

GPS and AVL vehicle location records.

Radio transmissions.

Digital photographs and video.

Any records concerning complaints made by or attributed to Dennis Coleman regarding Avery White or Michael Potter.

Any Child Protective Services communications or referrals, to the extent maintained by the department.

Any electronically stored information (ESI), including metadata and archived or deleted records.

The intentional destruction, alteration, deletion, or failure to preserve relevant evidence after notice of anticipated litigation may constitute spoliation of evidence and may subject the responsible parties to sanctions or other remedies under Massachusetts law and applicable court rules.

Massachusetts Public Records Request

This request is made pursuant to the Massachusetts Public Records Law, Massachusetts General Laws Chapter 66, Section 10, together with the definition of public records contained in Massachusetts General Laws Chapter 4, Section 7, Clause 26.

I request that all responsive records be produced electronically via email whenever possible. If any portion of a record is withheld, I request a written explanation identifying the specific statutory exemption relied upon for each withheld record or redaction."

The City is treating your inquiry as a public records request pursuant to G.L. c. 66, § 10.

The City has located four sets of records which may be responsive to your request.  These incidents took place on May 31, 2026, June 30, 2026, July 3, 2026, and July 25,2026.  If you are aware of additional sets of records that I should be searching for, please update me with further information so that I may assist you.

The City is denying your request, as this information is exempt from disclosure, specifically for the following reasons:

G. L. c. 4 § 7(26)(f): Records which pertain to an active investigation.

You have a right to appeal these redactions to the Supervisor of Public Records under 950 CMR § 32.08(1) and have a right to seek judicial review of an unfavorable decision by commencing a civil action in the superior court.

Because providing the requested records took less than two hours of staff time, and the records are being produced electronically, pursuant to 950 CMR § 32.07(2)(m) there will be no charge for responding to this public records request.

Sincerely,



Seah Levy

Public Records Access Officer

Law Department

Cambridge City Hall

795 Massachusetts Avenue

Cambridge, MA 02139

publicrecords@cambridgema.gov

Submit a Public Records Request ●  Public Records Center



THE ENGINEER OF HUMAN SYSTEMS

Zachariah Tringali and the Architecture of Purpose

By Storytelling Adventures Studio Inc.

Editorial Feature

There are engineers who build bridges, engineers who write software, and engineers who design machines capable of operating under extraordinary pressure.

Then there are people who approach society itself as an engineering problem.

Zachariah Tringali represents a particularly unconventional version of that mindset: an ordained minister, outreach worker, writer, activist, and systems-oriented thinker whose attention repeatedly returns to the same fundamental question:

How does a system work—and what happens when someone learns how to take it apart?

Through that lens, the conflicts that have shaped Tringali's public life can be interpreted not simply as a collection of disconnected confrontations, but as manifestations of a broader philosophy. His arena is not a factory floor or a conventional engineering laboratory. It is the intersection of law, government, technology, homelessness, ministry, civil rights, and community organizing.

His preferred vocabulary may be different from that of a conventional engineer, but the underlying process is recognizable: observe the system, identify its architecture, locate its points of failure, understand its governing rules, and construct an alternative pathway.

This is the engineering of human systems.

THE LEGAL SYSTEM AS SOURCE CODE

For Tringali, law can be understood as a form of institutional source code.

Municipal ordinances, administrative regulations, constitutional protections, public-records statutes, procedural rules, and federal civil-rights statutes collectively form the operating architecture of government. Every agency operates within defined authorities and limitations. Every official action has a procedural context. Every government record creates another potential data point.

The systems-engineering approach is therefore straightforward:

What is the rule?

Who has authority?

What procedure is required?

What documentation exists?

What happened in practice?

Where does the documented process diverge from the legally required process?

This approach explains his interest in mechanisms such as New Hampshire's Right-to-Know Law, RSA 91-A, federal civil-rights litigation, municipal records, discovery, and constitutional procedure.

Rather than treating these mechanisms as isolated legal technicalities, the engineering perspective treats them as components in a larger architecture.

A public-records request becomes a diagnostic instrument.

A deposition becomes an information-gathering mechanism.

Discovery becomes system mapping.

A motion becomes an attempt to alter the operating conditions of a dispute.

A federal lawsuit becomes a formal challenge to the architecture itself.

There is, however, an important distinction between engineering metaphor and actual legal strategy. Administrative requests cannot lawfully be used as an attack designed merely to overwhelm a government office, and procedural deadlines do not automatically create a successful civil-rights claim. The strongest version of this philosophy therefore depends upon precision rather than volume: every request must have a legitimate purpose, every allegation must be supported by evidence, and every legal argument must connect to an actionable constitutional or statutory violation.

The engineer's greatest weapon is not chaos.

It is documentation.

BUILDING HUMAN FIREWALLS

The second component of Tringali's philosophy concerns vulnerable communities.

Traditional engineering attempts to protect physical or digital infrastructure. Cybersecurity engineers build firewalls. Structural engineers calculate load limits. Safety engineers identify failure points before catastrophic events occur.

Tringali's community-oriented model applies a comparable concept to human vulnerability.

Through House of Mercy Ministries and his outreach work, the objective becomes what might be described as a human firewall: a network of people, information, documentation, advocacy, and legal knowledge designed to reduce the vulnerability of individuals who possess little institutional power.

The central premise is simple.

A person sleeping outside generally does not possess the same resources as a municipality, police department, property owner, or government agency.

There is an asymmetry of power.

The engineering response is therefore to reduce the asymmetry through information.

Know the rules.

Document encounters.

Preserve evidence.

Identify decision-makers.

Track policies.

Understand available legal remedies.

Build relationships.

Create institutional accountability.

This does not eliminate conflict. It changes the conditions under which conflict occurs.

Instead of an individual confronting a government institution with nothing more than an accusation, the individual can potentially bring photographs, dates, witnesses, public records, policies, correspondence, video, receipts, court filings, and documented chronology.

The result is a transformation from anecdote to evidence.

That transformation is fundamental to systems thinking.

PREDICTIVE DEFENSE

Another characteristic of the engineering mindset is anticipation.

An engineer does not wait for a bridge to collapse before examining its load-bearing structure.

A cybersecurity professional does not wait for a breach before thinking about vulnerabilities.

Likewise, Tringali's approach to community defense attempts to anticipate institutional behavior before a confrontation occurs.

Government agencies operate according to policies, budgets, personnel structures, contracts, calendars, enforcement priorities, and established procedures. Those patterns can sometimes be reconstructed from public information.

The objective is not necessarily to predict an individual officer's behavior with certainty.

It is to understand the system's likely decision tree.

If an encampment is targeted, what agency has authority?

Who issued the order?

What notice was required?

What property procedures apply?

What records were created?

What contractors were involved?

What surveillance technology was deployed?

Who authorized it?

What policy governed its use?

What constitutional interests are implicated?

Each question becomes another node in the system map.

The result is a defensive architecture based on preparation rather than reaction.

FICTION AS A SYSTEM SIMULATOR

Tringali's creative work provides another window into this worldview.

Storytelling Adventures Studio Inc. approaches fiction not merely as entertainment, but as a laboratory for ideas.

A novel can function like a simulation.

Characters become variables.

Institutions become systems.

Conflicts become stress tests.

The protagonist becomes an agent introduced into the system to determine how that system responds.

In thrillers and institutional dramas, a protagonist confronting a powerful organization provides an opportunity to examine hierarchy, corruption, loyalty, bureaucracy, secrecy, and institutional failure.

The story can then ask a question that resembles an engineering problem:

What happens when an individual understands the rules of a powerful system better than the people who operate it?

That is where the underdog archetype becomes particularly important.

The protagonist does not necessarily possess greater physical power.

He possesses information.

He recognizes relationships others overlook.

He identifies contradictions.

He understands institutional incentives.

He knows where pressure can be applied.

Fiction becomes a controlled environment in which those variables can be explored without requiring the real-world consequences of experimentation.

In that sense, storytelling becomes another form of systems analysis.

THE BARABBAS PARADIGM

The theological component of this philosophy introduces an entirely different dimension.

The story of Barabbas presents an extraordinary inversion of justice: a condemned prisoner is released while another person takes the punishment associated with his case.

For Tringali, the story can be interpreted symbolically as an architecture of substitution, mercy, guilt, and redemption.

The Barabbas Paradigm therefore becomes less about a literal legal loophole and more about a theological proposition:

Grace can interrupt the expected mechanics of judgment.

This distinction matters.

Grace is not a mechanism for making unlawful conduct lawful.

It is a theological concept concerning forgiveness, redemption, and the transformation of guilt.

Within the metaphorical framework developed around Tringali's philosophy, however, grace functions almost like an operating-system reset.

The individual is not required to remain permanently defined by his failures.

The past does not have absolute authority over the future.

The condemned person can become the redeemed person.

The broken system does not necessarily have the final word.

That is the deeper power of the Barabbas metaphor.

FROM CHAOS TO ARCHITECTURE

Viewed individually, Tringali's interests can appear disconnected.

Ministry.

Homelessness outreach.

Civil-rights advocacy.

Public-records research.

Cybersecurity education.

Writing.

Film.

Political activism.

Legal research.

Community defense.

But viewed through a systems-engineering framework, a common pattern emerges.

He repeatedly seeks to understand structures of power.

He studies how information moves.

He identifies institutional vulnerabilities.

He documents failures.

He builds alternative networks.

He uses storytelling to model conflicts.

And he searches for a philosophical framework capable of explaining why the struggle matters.

That does not mean every tactic is legally effective, every interpretation is correct, or every institutional conflict validates his conclusions.

Engineering requires testing.

A theory must survive contact with evidence.

A design must withstand stress.

A system must produce measurable results.

That same standard can be applied to Tringali's philosophy.

The question is not simply whether he believes he is an engineer of human systems.

The more important question is whether his methods actually produce durable structures capable of protecting the people he seeks to serve.

THE PURPOSE OF CREATION

At the center of this philosophy is an unusual interpretation of purpose.

Creation, in this framework, is not merely about constructing physical objects.

It is about constructing possibilities.

A ministry can become infrastructure.

A public-records archive can become institutional memory.

A lawsuit can become a mechanism for accountability.

A book can become a simulation.

A classroom can become a technical laboratory.

A community can become a protective network.

And an individual who has experienced institutional vulnerability can attempt to transform that experience into a blueprint for others.

The engineer, therefore, is not defined by a drafting table, computer terminal, welding station, or laboratory.

The engineer is defined by the instinct to ask:

How does this system work?

Why was it designed this way?

Where does it fail?

Who bears the cost of that failure?

Can the architecture be redesigned?

For Zachariah Tringali, those questions have become intertwined with ministry, advocacy, technology, law, and storytelling.

His purpose of creation, as expressed through this philosophy, is ultimately not destruction.

It is redesign.

The objective is to take systems that appear permanent and demonstrate that they are constructed.

And if they were constructed, they can be examined.

If they can be examined, they can be challenged.

And if they can be challenged, they can potentially be rebuilt.

That is the central idea behind the engineer of human systems.

Not simply fighting the machine.

Learning how the machine works—and then designing something better.

STORYTELLING ADVENTURES STUDIO INC.

Stories. Systems. Ideas. The architecture behind the narrative.

UNITED STATES DISTRICT COURT

DISTRICT OF MASSACHUSETTS

REVEREND ZACHARIAH TRINGALI,

Plaintiff,

v.

FLOCK GROUP, INC., d/b/a FLOCK SAFETY;

FLOCK SAFETY OFFICERS, EMPLOYEES, AGENTS,

AND CONTRACTORS, JOHN/JANE DOES 1–20;

MUNICIPALITIES, LAW-ENFORCEMENT AGENCIES,

AND GOVERNMENT OFFICIALS THAT AUTHORIZED,

OPERATED, ACCESSED, SEARCHED, OR SHARED

FLOCK SURVEILLANCE DATA, JOHN/JANE DOES 21–50;

and

DOES 51–100,

Defendants.

Civil Action No. __________

COMPLAINT FOR DECLARATORY, INJUNCTIVE,

AND MONETARY RELIEF

42 U.S.C. §§ 1983 AND 1988;

UNITED STATES CONSTITUTION,

FIRST, FOURTH, FIFTH, AND FOURTEENTH AMENDMENTS;

AND APPLICABLE FEDERAL AND STATE PRIVACY LAWS

Plaintiff Reverend Zachariah Tringali, proceeding pro se, brings this civil-rights and privacy action against Flock Group, Inc., doing business as Flock Safety, together with governmental entities and unidentified officials who participated in the acquisition, deployment, operation, access, search, retention, dissemination, or misuse of Flock surveillance information.

Plaintiff alleges that the defendants have created, operated, facilitated, or participated in a system of pervasive vehicle surveillance capable of recording and retaining information concerning the movements of ordinary Americans, including Plaintiff, without constitutionally sufficient safeguards, individualized suspicion, judicial authorization, meaningful notice, or adequate limitations on governmental access.

Plaintiff further alleges that discovery is necessary to determine the full technological capabilities of the Flock system, including whether particular devices or connected systems capture, process, transmit, retain, or permit access to audio; whether Flock data has been combined with other governmental databases or surveillance systems; whether information has been used to identify individuals associated with particular locations, religious activities, political activities, demonstrations, ministries, journalists, or protected speech; and whether any connected technology has ever been used or capable of being used to initiate, facilitate, request, or communicate a vehicle immobilization or other intervention.

Plaintiff does not presently allege, as an established fact, that every Flock camera can directly disable a vehicle. Plaintiff specifically seeks discovery, forensic examination, technical documentation, contracts, system architecture, access logs, audit records, communications, and other evidence necessary to determine whether Flock technology has been connected to or integrated with systems capable of affecting vehicle operation or generating governmental interventions affecting a vehicle's operation.

I. PARTIES

1. Plaintiff is Reverend Zachariah Tringali, an ordained minister, outreach worker, author, activist, and civil-rights advocate.

2. Plaintiff's address is 362 Green Street, Cambridge, Massachusetts 02129.

3. Plaintiff's telephone number is 603-661-9745.

4. Plaintiff's email address is zacharytringali@gmail.com.

5. Defendant Flock Group, Inc., doing business as Flock Safety, is a private corporation engaged in the development, deployment, sale, leasing, operation, maintenance, and support of automated license-plate reader and vehicle-surveillance technology.

6. Defendants John/Jane Does 1–20 are Flock officers, employees, agents, contractors, engineers, administrators, or other persons whose identities and specific involvement will be determined through discovery.

7. Defendants John/Jane Does 21–50 include governmental officials and employees who authorized, operated, accessed, searched, retained, disseminated, or otherwise used Flock surveillance information concerning Plaintiff or members of the public.

8. Defendants Does 51–100 include municipalities, agencies, private contractors, technology providers, and other entities that participated in the alleged surveillance system or its integration with other databases, communications systems, or governmental functions.

II. JURISDICTION

9. This action arises under the Constitution and laws of the United States, including the First, Fourth, Fifth, and Fourteenth Amendments and 42 U.S.C. §§ 1983 and 1988.

10. This Court has federal-question jurisdiction pursuant to 28 U.S.C. § 1331.

11. Plaintiff seeks declaratory and injunctive relief pursuant to applicable federal law.

12. Plaintiff further invokes supplemental jurisdiction over related state-law privacy claims pursuant to 28 U.S.C. § 1367 where appropriate.

III. FACTUAL ALLEGATIONS

13. Flock's technology is designed to identify and record vehicles and license plates passing designated cameras.

14. Flock's published materials acknowledge that LPR information can include license-plate images, vehicle images, vehicle characteristics, license-plate numbers, state information, dates, times, and camera locations.

15. Flock's published privacy policy also acknowledges that certain Flock products may process video and/or audio signals and data, depending upon the particular product.

16. Plaintiff alleges that the widespread deployment of automated vehicle surveillance creates a substantial risk that the government can reconstruct a person's movements over time.

17. A vehicle is frequently associated with a particular person, household, ministry, workplace, residence, religious organization, political activity, medical facility, attorney, journalist, or other constitutionally protected association.

18. Consequently, systematic collection and retrospective searching of vehicle-location information can reveal highly sensitive information about a person's private life, associations, movements, and activities.

19. Plaintiff alleges that the defendants have participated in or facilitated surveillance occurring from approximately 2020 to the present, although the precise date, geographic scope, equipment, contracts, agencies, retention periods, and individual searches are presently unknown.

20. Plaintiff therefore seeks discovery concerning the entire period beginning January 1, 2020.

21. Plaintiff alleges that government agencies have been able to search or obtain surveillance information concerning vehicles without obtaining a traditional judicial warrant in circumstances where the aggregate information effectively permits reconstruction of a person's movements.

22. Plaintiff alleges that the absence of meaningful judicial oversight creates a substantial risk of arbitrary governmental surveillance.

23. Plaintiff further alleges that Flock's system may be capable of integration with other governmental databases, hotlists, dispatch systems, investigative systems, or other technologies.

24. Plaintiff seeks discovery concerning every such integration.

25. Plaintiff further alleges that law-enforcement searches of the system may reveal where an individual traveled, when the individual traveled, which locations the individual visited, and potentially which people or organizations the individual associated with.

26. Plaintiff alleges that such information is particularly sensitive when used to identify persons attending churches, ministries, political meetings, protests, demonstrations, shelters, outreach operations, civil-rights activities, or other protected gatherings.

27. Plaintiff alleges that surveillance of protected activity can have a chilling effect upon speech, religion, assembly, association, journalism, political participation, and petitioning of government.

28. Plaintiff further alleges that surveillance data can be misused by individual officers or officials for personal, retaliatory, discriminatory, harassing, or investigatory purposes unrelated to legitimate law-enforcement objectives.

29. Plaintiff seeks all access logs, search histories, audit trails, account records, search justifications, warrants, subpoenas, administrative requests, hotlist records, data-sharing records, and dissemination records concerning Plaintiff.

30. Plaintiff further seeks records identifying every governmental entity that has possessed, accessed, searched, queried, received, copied, exported, or disseminated information capable of identifying Plaintiff's vehicle or movements.

31. Plaintiff alleges that defendants have failed to provide constitutionally adequate safeguards against unreasonable governmental searches and seizures of such information.

32. Plaintiff further alleges that the defendants' policies, practices, customs, training, supervision, retention policies, and technological architecture permitted or facilitated unconstitutional surveillance.

33. Plaintiff alleges that any governmental access to prolonged, comprehensive historical location information concerning an identifiable individual constitutes a materially greater intrusion than merely observing a vehicle on a single public roadway.

34. Plaintiff further alleges that the aggregation of individual observations creates a substantially different privacy intrusion from isolated visual observation.

35. Plaintiff also seeks discovery concerning whether Flock surveillance information has been used to generate automated alerts or governmental interventions affecting vehicles.

36. Plaintiff is particularly concerned with whether any Flock-connected technology, third-party integration, governmental system, communications interface, or automated alert has ever been used to initiate or facilitate the stopping, disabling, immobilization, detention, or other interference with a motor vehicle.

37. Plaintiff alleges that if any such technology exists or has been deployed without adequate safeguards, an erroneous identification, defective database entry, software malfunction, communications error, or mistaken hotlist match could create a serious physical safety hazard.

38. A technological error resulting in a vehicle being stopped, disabled, immobilized, or subjected to an emergency governmental intervention while traveling on a highway could create a foreseeable risk of serious injury or death.

39. Plaintiff therefore seeks technical discovery sufficient to determine whether such functionality exists, whether it has ever been deployed, what safeguards exist, who controls it, and what procedures are followed before any intervention affecting a vehicle is initiated.

40. Plaintiff further seeks discovery concerning whether Flock or governmental customers have installed, operated, or authorized microphones, audio capture, audio processing, or other listening functionality in locations where individuals could reasonably expect that private conversations would not be technologically intercepted or recorded.

41. If audio surveillance occurred without lawful authority, consent, or compliance with applicable federal and state wiretap and privacy laws, Plaintiff alleges that such conduct constitutes an independent violation of law.

42. Plaintiff alleges that the defendants' conduct has caused actual and threatened injury to Plaintiff's constitutional rights, privacy interests, liberty interests, freedom of movement, freedom of speech, freedom of religion, freedom of association, and right to be free from unreasonable governmental searches and seizures.

COUNT I

42 U.S.C. § 1983 — FOURTH AMENDMENT

UNREASONABLE SEARCHES AND SEIZURES

43. Plaintiff incorporates all preceding allegations.

44. The Fourth Amendment protects persons against unreasonable searches and seizures.

45. The Supreme Court has recognized that prolonged governmental tracking of a person's movements can implicate Fourth Amendment protections.

46. Defendants' collection, aggregation, retention, searching, and disclosure of vehicle-location information concerning Plaintiff, particularly when performed over extended periods, constitutes a search where the circumstances invade Plaintiff's reasonable expectation of privacy or otherwise constitute a constitutionally significant intrusion.

47. Government defendants cannot evade constitutional limitations merely by outsourcing surveillance infrastructure to a private corporation.

48. Plaintiff alleges that defendants conducted or facilitated searches without warrants, probable cause, individualized suspicion, or constitutionally adequate safeguards.

49. Plaintiff seeks declaratory relief, injunctive relief, damages where legally available, and all other appropriate remedies.

COUNT II

FOURTH AMENDMENT — DIGITAL MOVEMENT SURVEILLANCE

50. Plaintiff incorporates all preceding allegations.

51. Aggregated vehicle-location data can reveal a person's movements over days, weeks, months, or years.

52. Such information can expose intimate details concerning a person's associations, religious activities, political activities, professional activities, medical activities, family relationships, and private life.

53. Plaintiff alleges that defendants' prolonged collection and retrospective searching of such information constitutes a constitutionally significant search when performed without adequate judicial authorization.

54. Plaintiff seeks an order requiring constitutionally sufficient standards governing collection, retention, querying, dissemination, and destruction of such information.

COUNT III

FIRST AMENDMENT — FREEDOM OF SPEECH, RELIGION,

ASSEMBLY, ASSOCIATION, AND PETITION

55. Plaintiff incorporates all preceding allegations.

56. The First Amendment protects freedom of speech, religion, peaceful assembly, association, journalism, and petitioning government.

57. Government surveillance that identifies or monitors individuals because of their protected speech, religious activities, political activities, civil-rights advocacy, ministry work, or association may violate the First Amendment.

58. Plaintiff alleges that vehicle surveillance can reveal attendance at religious services, ministry locations, political events, protests, civil-rights activities, public meetings, and other protected activities.

59. Plaintiff further alleges that surveillance of protected activities can chill participation because individuals may reasonably fear that their movements and associations are being recorded and made available to law enforcement.

60. To the extent defendants targeted Plaintiff or his protected activities because of his speech, religious ministry, civil-rights advocacy, political activity, or criticism of government, Plaintiff alleges an independent First Amendment violation.

61. Plaintiff seeks declaratory, injunctive, and monetary relief as permitted by law.

COUNT IV

FOURTEENTH AMENDMENT — DUE PROCESS

62. Plaintiff incorporates all preceding allegations.

63. Government defendants may not deprive persons of protected liberty or property interests through arbitrary governmental action without constitutionally adequate process.

64. Plaintiff alleges that secret surveillance systems, undisclosed data collection, erroneous watchlist information, arbitrary searches, and governmental interventions based upon inaccurate or incomplete information can deprive individuals of protected interests without meaningful notice or opportunity to challenge the underlying information.

65. Plaintiff further alleges that if an automated or semi-automated surveillance system produces consequences affecting an individual's liberty, property, freedom of movement, or safety, constitutionally adequate procedural safeguards may be required.

66. Plaintiff seeks disclosure of the procedures by which individuals can challenge inaccurate records, erroneous vehicle identification, false alerts, mistaken hotlist matches, and improper governmental searches.

COUNT V

FOURTEENTH AMENDMENT — EQUAL PROTECTION

67. Plaintiff incorporates all preceding allegations.

68. Government officials may not intentionally administer surveillance programs in a discriminatory manner or selectively target individuals based upon protected classifications or constitutionally protected conduct.

69. Plaintiff alleges that discovery is required to determine whether Flock surveillance was selectively deployed, searched, or used against particular individuals, neighborhoods, religious groups, political organizations, civil-rights activists, homeless persons, minorities, or other protected classes or groups.

70. If discovery establishes discriminatory enforcement or selective governmental surveillance, Plaintiff seeks appropriate relief under the Equal Protection Clause.

COUNT VI

FIFTH AMENDMENT — DUE PROCESS AND PROPERTY RIGHTS

TO THE EXTENT APPLICABLE TO FEDERAL ACTORS

71. Plaintiff incorporates all preceding allegations.

72. To the extent federal governmental actors or agencies participated in the conduct alleged herein, Plaintiff invokes applicable Fifth Amendment protections against deprivation of life, liberty, or property without due process of law.

73. Plaintiff further seeks investigation into whether governmental surveillance systems have resulted in deprivation or interference with protected property interests without adequate notice or process.

74. Plaintiff expressly pleads this claim only to the extent applicable under federal law and against defendants subject to the Fifth Amendment.

COUNT VII

FIRST AND FOURTEENTH AMENDMENTS — RETALIATION

75. Plaintiff incorporates all preceding allegations.

76. Government officials may not use governmental power to retaliate against a person for exercising constitutionally protected speech, petition, religious activity, association, journalism, or civil-rights advocacy.

77. Plaintiff alleges that if surveillance searches, alerts, database queries, or governmental interventions were initiated because Plaintiff criticized government officials, reported governmental misconduct, engaged in ministry, participated in political activity, or exercised other protected rights, such conduct constitutes unconstitutional retaliation.

COUNT VIII

UNLAWFUL AUDIO SURVEILLANCE / STATE AND FEDERAL PRIVACY LAWS

78. Plaintiff incorporates all preceding allegations.

79. To the extent defendants captured, intercepted, recorded, transmitted, stored, or disclosed private audio communications, Plaintiff alleges violations of applicable federal and state wiretap, electronic surveillance, and privacy laws.

80. Plaintiff seeks production of technical specifications identifying every Flock product capable of capturing audio, every location where such products were deployed, the dates of activation, audio-storage policies, audio-retention policies, access logs, recordings, metadata, and every governmental entity that received or accessed such information.

81. Plaintiff reserves the right to amend this count after discovery identifies the precise statutory violations and jurisdictions involved.

COUNT IX

MONELL LIABILITY — MUNICIPAL POLICIES, CUSTOMS,

FAILURE TO TRAIN, SUPERVISE, AND CONTROL

82. Plaintiff incorporates all preceding allegations.

83. Government entities are responsible under 42 U.S.C. § 1983 where an unconstitutional deprivation results from an official policy, widespread custom, deliberately indifferent failure to train or supervise, or decision by an official possessing final policymaking authority.

84. Plaintiff alleges that governmental entities adopted, approved, funded, or continued surveillance programs without constitutionally adequate safeguards.

85. Plaintiff further alleges inadequate training concerning warrants, constitutional searches, First Amendment activity, religious association, data retention, database searches, discriminatory use, and protection against misuse.

86. Plaintiff seeks discovery concerning contracts, policies, training materials, memoranda, standard operating procedures, audit reports, complaints, disciplinary records, search logs, and governmental oversight of Flock systems.

COUNT X

DECLARATORY AND INJUNCTIVE RELIEF

87. Plaintiff incorporates all preceding allegations.

88. An actual controversy exists concerning the constitutionality and legality of the defendants' surveillance practices.

89. Plaintiff requests a declaration that defendants may not conduct prolonged or otherwise constitutionally unreasonable surveillance of Plaintiff through automated vehicle-location systems.

90. Plaintiff requests appropriate injunctive relief requiring constitutional safeguards, judicial authorization where required, limitations on data retention, access controls, audit mechanisms, correction procedures, and restrictions upon surveillance of protected First Amendment activity.

91. Plaintiff further requests an injunction preventing defendants from using inaccurate or unlawfully obtained surveillance information against Plaintiff.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that this Court:

A. Declare that defendants' unlawful surveillance practices violate Plaintiff's constitutional rights;

B. Declare that government defendants may not evade constitutional requirements by outsourcing surveillance functions to a private corporation;

C. Enjoin defendants from conducting unconstitutional searches of Plaintiff's vehicle-location information;

D. Require defendants to preserve all data concerning Plaintiff and his vehicle pending final resolution of this action;

E. Order defendants to identify every governmental agency, official, employee, contractor, or private entity that has accessed, searched, received, copied, exported, or disseminated Plaintiff's surveillance information;

F. Order production of all records concerning Plaintiff's vehicle, license plate, vehicle characteristics, locations, timestamps, alerts, searches, queries, hotlist matches, audio recordings, video recordings, metadata, audit logs, and dissemination records;

G. Order defendants to disclose every Flock product deployed during the relevant period and its technical capabilities;

H. Order defendants to disclose whether any Flock system has ever been integrated with a system capable of communicating with, stopping, disabling, immobilizing, or otherwise affecting the operation of a motor vehicle;

I. Order defendants to disclose every governmental contract, purchase order, subscription, data-sharing agreement, memorandum of understanding, policy, and technical integration concerning Flock surveillance from January 1, 2020, to the present;

J. Order appropriate deletion or restriction of unlawfully collected information concerning Plaintiff;

K. Award compensatory damages in an amount to be established at trial;

L. Award punitive damages against individual defendants where permitted by law;

M. Award nominal damages where appropriate;

N. Award reasonable costs and attorney's fees pursuant to 42 U.S.C. § 1988 where legally available;

O. Grant such other and further relief as this Court determines to be just and proper.

JURY DEMAND

Plaintiff demands trial by jury on all issues so triable.

Respectfully submitted,

REVEREND ZACHARIAH TRINGALI

Plaintiff, Pro Se

House of Mercy Ministries

362 Green Street

Cambridge, Massachusetts 02129

603-661-9745

zacharytringali@gmail.com

Date: __________________

ADDITIONAL COUNTS AND JURISDICTIONAL ALLEGATIONS

COUNT XI

FIRST AMENDMENT — FREEDOM OF RELIGION,

FREE EXERCISE, SPEECH, ASSEMBLY, ASSOCIATION,

AND PETITION

92. Plaintiff incorporates every preceding allegation.

93. Plaintiff is an ordained minister who engages in public religious ministry, outreach, speech, assembly, advocacy, and charitable activity.

94. Plaintiff's public ministry constitutes protected religious exercise, speech, assembly, association, and petitioning activity.

95. The First Amendment protects the free exercise of religion and prohibits government from abridging speech, peaceful assembly, association, and the right to petition government for redress of grievances.

96. Government surveillance of a religious minister, congregation, ministry participants, volunteers, donors, supporters, or persons attending religious activities can burden the exercise of religion and chill protected association.

97. Plaintiff alleges that governmental defendants used, accessed, searched, retained, or disseminated Flock surveillance information in a manner that monitored, identified, mapped, or otherwise subjected Plaintiff's religious ministry and public activities to governmental surveillance.

98. Plaintiff further alleges that surveillance of Plaintiff's ministry locations, religious gatherings, public outreach, church-related activities, demonstrations, meetings, and associated persons interferes with the constitutional right to engage in religious exercise without governmental intimidation or unjustified surveillance.

99. If governmental defendants selected, searched, or used surveillance information because of Plaintiff's religious ministry, criticism of government, civil-rights advocacy, political activity, or public speech, such conduct constitutes unconstitutional viewpoint discrimination and retaliation.

100. Plaintiff seeks declaratory, injunctive, compensatory, nominal, and other relief permitted by law.

COUNT XII

RELIGIOUS FREEDOM — GOVERNMENTAL BURDEN

ON PUBLIC MINISTRY

101. Plaintiff incorporates every preceding allegation.

102. Plaintiff's ministry involves religious expression and exercise conducted in public spaces.

103. Government may regulate conduct in public spaces through legitimate, neutral laws, but it may not use surveillance technology as a pretext to suppress, intimidate, discriminate against, or substantially burden religious exercise.

104. Plaintiff alleges that surveillance, monitoring, identification, tracking, or governmental intervention directed at his ministry or persons participating in his ministry substantially interfered with protected religious activity.

105. Plaintiff seeks an adjudication of whether the government's surveillance practices are neutral and generally applicable or instead selectively burden Plaintiff's religious exercise.

106. Where strict scrutiny applies, Plaintiff alleges that defendants must establish a compelling governmental interest and use means narrowly tailored to accomplish that interest.

COUNT XIII

MASSACHUSETTS CONSTITUTION

ARTICLE II AND ARTICLE XLVI

FREEDOM OF RELIGION

107. Plaintiff incorporates every preceding allegation.

108. Article II of the Massachusetts Declaration of Rights protects religious worship and religious profession from governmental restraint, subject to the constitutional limitation concerning public peace and interference with others' worship.

109. Article XLVI, §1 provides that no law shall be passed prohibiting the free exercise of religion.

110. Plaintiff alleges that governmental surveillance and interference with his public religious ministry, when undertaken because of or in retaliation for his religious activities, constitutes governmental restraint upon religious exercise.

111. Plaintiff further alleges that governmental officials cannot use surveillance technology to accomplish indirectly what the government could not lawfully accomplish directly—namely, suppressing or intimidating protected religious ministry.

112. Plaintiff seeks all remedies available under Massachusetts law.

COUNT XIV

MASSACHUSETTS CONSTITUTION

RELIGIOUS EQUALITY AND PROTECTION

113. Plaintiff incorporates every preceding allegation.

114. The Massachusetts Constitution protects religious exercise and provides constitutional protection for religious activity within the Commonwealth.

115. Plaintiff alleges that governmental defendants selectively surveilled, investigated, monitored, restricted, or interfered with Plaintiff's religious ministry or associated persons.

116. Plaintiff alleges that unequal governmental treatment based upon religion, religious activity, religious association, or religious viewpoint violates applicable Massachusetts constitutional protections.

117. Plaintiff requests declaratory and injunctive relief and any damages remedy recognized under Massachusetts law.

COUNT XV

FIRST AMENDMENT — FREEDOM OF PEACEFUL ASSEMBLY

118. Plaintiff incorporates every preceding allegation.

119. Public religious ministry necessarily involves the gathering of people for worship, prayer, charitable outreach, speech, discussion, education, and community assistance.

120. The First Amendment protects peaceful assembly.

121. Government surveillance capable of identifying attendees, participants, vehicles, volunteers, supporters, and associates may chill participation in Plaintiff's public ministry.

122. Plaintiff alleges that defendants' surveillance practices have the effect, purpose, or foreseeable consequence of discouraging persons from attending or participating in Plaintiff's ministry.

123. Plaintiff seeks an injunction prohibiting surveillance practices that target protected assembly without lawful constitutional justification.

COUNT XVI

FIRST AMENDMENT — RETALIATION AGAINST

RELIGIOUS AND CIVIC ACTIVITY

124. Plaintiff incorporates every preceding allegation.

125. Plaintiff has engaged in public speech, religious ministry, civil-rights advocacy, political activity, and criticism of governmental conduct.

126. Those activities constitute protected First Amendment activity.

127. Government officials may not use governmental surveillance systems to retaliate against an individual for exercising constitutional rights.

128. Plaintiff alleges that any Flock searches, surveillance queries, alerts, investigations, vehicle monitoring, database searches, or governmental interventions undertaken because of Plaintiff's protected activity constitute retaliation.

129. Plaintiff seeks discovery identifying the officials who initiated or approved any surveillance concerning Plaintiff and the reasons for each search or query.

COUNT XVII

CHURCH-STATE SEPARATION

AND GOVERNMENTAL RELIGIOUS ENTANGLEMENT

130. Plaintiff incorporates every preceding allegation.

131. The First Amendment contains both the Establishment Clause and Free Exercise Clause.

132. Government must not use its regulatory or surveillance authority to favor, disfavor, suppress, monitor, or discriminate against religious activity because of its religious character.

133. Plaintiff alleges that governmental surveillance of religious ministry, if motivated by religious viewpoint or religious identity, creates unconstitutional governmental interference with protected religious activity.

134. Plaintiff further alleges that governmental officials must maintain constitutional neutrality rather than using governmental surveillance infrastructure to monitor or control religious ministry.

135. Plaintiff seeks a judicial declaration defining the constitutional limits applicable to governmental surveillance of Plaintiff's religious ministry.

COUNT XVIII

FOURTH AMENDMENT — RELIGIOUS ASSOCIATION

AND MOVEMENT SURVEILLANCE

136. Plaintiff incorporates every preceding allegation.

137. Government surveillance of vehicles traveling to churches, ministries, religious gatherings, shelters, outreach locations, or other religious activities can reveal constitutionally protected associations.

138. Aggregated surveillance can reveal substantially more information than a single observation in a public place.

139. Plaintiff alleges that defendants used or facilitated prolonged surveillance capable of reconstructing Plaintiff's movements and religious associations.

140. Plaintiff alleges that searches of such information were conducted without constitutionally sufficient judicial authorization or individualized suspicion.

141. Plaintiff requests disclosure of all searches involving Plaintiff's vehicle, locations associated with Plaintiff, and known ministry locations.

COUNT XIX

MASSACHUSETTS GENERAL LAWS

CHAPTER 272, §99 — UNLAWFUL

INTERCEPTION OF ORAL COMMUNICATIONS

142. Plaintiff incorporates every preceding allegation.

143. Plaintiff alleges, upon information and belief and subject to discovery, that certain surveillance technology may possess audio-recording, audio-processing, or listening capabilities.

144. Plaintiff specifically seeks discovery establishing which products deployed in Massachusetts were capable of capturing or processing audio.

145. Plaintiff further seeks the identity and location of every such device, activation dates, recordings, metadata, retention records, access logs, governmental requests, and disclosures.

146. If defendants intentionally intercepted oral communications in violation of Massachusetts law, Plaintiff alleges an independent statutory violation.

147. Massachusetts law provides a civil cause of action for an aggrieved person whose oral or wire communications or privacy interests were unlawfully intercepted, disclosed, or used. Mass. Gen. Laws ch. 272, §99.

148. Plaintiff seeks all damages, statutory remedies, costs, and other relief available under §99.

COUNT XX

42 U.S.C. §1983 — GOVERNMENTAL

JOINT ACTION WITH PRIVATE SURVEILLANCE COMPANY

149. Plaintiff incorporates every preceding allegation.

150. Plaintiff alleges that governmental defendants contracted with, purchased services from, directed, authorized, or otherwise jointly participated with Flock in the surveillance activities challenged herein.

151. Plaintiff further alleges that Flock's involvement was not merely an independent commercial relationship where discovery establishes that governmental defendants directed, controlled, requested, or substantially participated in the challenged searches.

152. To the extent discovery establishes joint action, conspiracy, governmental direction, coercion, or substantial governmental entwinement, Plaintiff seeks relief under 42 U.S.C. §1983.

153. Plaintiff requests discovery sufficient to determine the relationship between Flock and each governmental defendant.

COUNT XXI

MONELL LIABILITY — GOVERNMENTAL SURVEILLANCE

POLICY, CUSTOM, TRAINING, AND SUPERVISION

154. Plaintiff incorporates every preceding allegation.

155. Governmental entities adopted, purchased, authorized, funded, maintained, or continued automated vehicle-surveillance systems.

156. Plaintiff alleges that governmental entities failed to establish constitutionally adequate policies concerning:

a. First Amendment-protected religious activity;

b. public ministry;

c. peaceful assembly;

d. religious association;

e. political speech;

f. civil-rights advocacy;

g. warrant requirements;

h. prolonged movement tracking;

i. database searches;

j. retention of surveillance information;

k. dissemination of surveillance information;

l. erroneous vehicle identification;

m. false alerts;

n. audio surveillance;

o. correction of inaccurate information;

p. discriminatory surveillance; and

q. retaliation against protected activity.

157. Plaintiff alleges that these failures constitute policies, customs, practices, or deliberate indifference sufficient to support municipal liability where the required elements are established.

COUNT XXII

RELIGIOUS FREEDOM RESTORATION ACT

TO THE EXTENT FEDERAL GOVERNMENT ACTORS ARE INVOLVED

158. Plaintiff incorporates every preceding allegation.

159. To the extent federal governmental defendants participated in the challenged conduct, Plaintiff invokes the Religious Freedom Restoration Act, 42 U.S.C. §§2000bb et seq.

160. Plaintiff alleges that federal governmental action substantially burdened his exercise of religion.

161. Plaintiff alleges that any such burden must satisfy the statutory compelling-interest and least-restrictive-means standards applicable to the challenged federal action.

162. Plaintiff reserves all remedies available under RFRA.

163. Plaintiff recognizes that RFRA's applicability differs depending upon whether the challenged governmental conduct is federal, state, or local. The Supreme Court's decision in City of Boerne v. Flores limits Congress's ability to apply RFRA to state and local governments, making the First Amendment and applicable state constitutional protections particularly important for state and municipal defendants.

COUNT XXIII

DECLARATORY JUDGMENT — CONSTITUTIONAL

LIMITS ON SURVEILLANCE OF RELIGIOUS MINISTRY

164. Plaintiff incorporates every preceding allegation.

165. Plaintiff seeks a declaration establishing that governmental defendants may not use automated vehicle-surveillance technology to target, suppress, intimidate, retaliate against, or substantially burden Plaintiff's protected religious ministry or peaceful assembly without lawful constitutional justification.

166. Plaintiff further seeks a declaration that governmental surveillance of religious association must comply with the First and Fourth Amendments and applicable Massachusetts constitutional and statutory protections.

COUNT XXIV

INJUNCTIVE RELIEF — PROTECTION OF

RELIGIOUS MINISTRY AND ASSEMBLY

167. Plaintiff incorporates every preceding allegation.

168. Plaintiff requests preliminary and permanent injunctive relief prohibiting governmental defendants from:

a. targeting Plaintiff because he conducts religious ministry;

b. monitoring religious gatherings solely because they are religious gatherings;

c. identifying participants in Plaintiff's ministry without lawful constitutional justification;

d. searching vehicle-location data for the purpose of identifying religious associates;

e. using surveillance to retaliate against protected speech or religious activity;

f. using unlawfully obtained audio or surveillance information;

g. disseminating unlawfully obtained information concerning Plaintiff's ministry;

h. using false or inaccurate surveillance information against Plaintiff; and

i. interfering with lawful public religious assembly.

169. Plaintiff further requests preservation of all potentially relevant surveillance evidence pending resolution of this action.

ADDITIONAL JURISDICTIONAL BASIS

170. This Court has jurisdiction over federal constitutional claims pursuant to 28 U.S.C. §1331 and 42 U.S.C. §1983.

171. This Court has jurisdiction over claims arising under federal civil-rights statutes pursuant to 28 U.S.C. §1343.

172. This Court may exercise supplemental jurisdiction over related Massachusetts constitutional and statutory claims pursuant to 28 U.S.C. §1367 when those claims form part of the same case or controversy.

173. Plaintiff reserves all claims arising under applicable Massachusetts privacy, wiretap, civil-rights, tort, and constitutional law.

174. Plaintiff further reserves claims arising under federal privacy, electronic surveillance, civil-rights, and religious-liberty statutes when discovery establishes the factual and statutory basis for such claims.

175. Plaintiff seeks relief against governmental defendants in their official capacities where prospective declaratory or injunctive relief is legally available and against individual defendants where the applicable law permits personal liability.

176. Plaintiff seeks appropriate relief against private defendants only to the extent their conduct is independently actionable or their conduct is sufficiently connected to governmental action to establish liability under the applicable law.

177. Plaintiff expressly requests that the Court permit amendment of this Complaint after discovery identifies additional defendants, governmental entities, surveillance products, technical capabilities, searches, communications, audio interceptions, contracts, and constitutional violations.

Plaintiff’s Argument Regarding Public Records Obstruction and Need for Complete Records Production

Your Honor,

Plaintiff respectfully submits that the City of Manchester’s handling of Plaintiff’s RSA 91-A Right-to-Know requests has created substantial concerns regarding delay, lack of transparency, and potential withholding of relevant evidence necessary to establish Plaintiff’s civil rights claims.

Plaintiff submitted lawful public records requests seeking records directly related to issues at the center of this matter, including government actions affecting unhoused individuals, enforcement decisions, communications, policies, and records concerning the treatment of Plaintiff and others engaged in protected speech and outreach activities.

Despite the importance of these records, Plaintiff has experienced significant delays and responses that have limited meaningful access to information needed to investigate and present claims. The requested records are not merely administrative documents; they may contain evidence regarding policies, procedures, decision-making processes, communications among officials, and whether actions were carried out pursuant to established practices or customs.

Plaintiff respectfully requests that the Court consider the pattern of delay and incomplete disclosure as relevant to the need for judicial oversight, preservation of evidence, and appropriate discovery orders.

The requested records are necessary to determine:

Whether municipal policies, customs, or practices contributed to alleged constitutional violations;

Whether officials acted consistently with established procedures or outside those procedures;

Whether Plaintiff’s protected speech, advocacy, religious activities, or public criticism played any role in government actions;

Whether records exist that corroborate Plaintiff’s allegations regarding displacement, property loss, enforcement actions, and treatment of unhoused persons.

Plaintiff further states that access to these records is essential for presenting the full factual record to the Court. The absence of timely disclosure prevents Plaintiff from obtaining evidence that may be material to claims under federal civil rights law, including 42 U.S.C. §1983.

Plaintiff therefore respectfully requests appropriate relief requiring preservation and production of relevant records and allowing full discovery into the policies, communications, and actions at issue.

Respectfully submitted,

Reverend Zachariah Tringali

Plaintiff

X_____________________________________

DATE________________________

ADDRESS_____________________________________

________________________________________________

PHONE NUMBER____________________________

 

Category

Alleged Wrong / Issue

Evidence Needed

Legal Theory / Claim

Potential Damages

Homeless deaths

Deaths among unhoused residents linked to lack of shelter, medical access, addiction services, or displacement

Medical examiner records, death certificates, EMS records, shelter records

Negligence theories (where applicable), civil rights policy/custom claims if government action contributed

Survival damages, wrongful death damages where legally available, emotional distress

Overdose deaths

Failure to provide adequate prevention, treatment access, outreach, or emergency response

EMS overdose calls, Narcan deployments, public health reports

Monell policy/custom claim requires proof of municipal policy or deliberate indifference

Compensatory damages, policy remedies

Forced displacement

Removal of homeless encampments or displacement without adequate alternative placement

Police reports, DPW records, notices, body camera footage, property inventories

Fourth Amendment seizure claims, Fourteenth Amendment due process claims

Property loss, emotional distress, constitutional damages

Destruction/loss of property

Confiscation, disposal, or destruction of personal belongings

Inventory logs, photographs, contractor records, chain-of-custody documents

Unreasonable seizure / deprivation of property

Replacement value, punitive damages against individuals if applicable

Religious property interference

Loss or damage of ministry items, religious materials, clergy equipment

Photos, receipts, witness statements

First Amendment Free Exercise claim

Emotional distress, constitutional damages

Speech retaliation

Alleged retaliation for criticizing city actions or reporting homeless conditions

Social media records, account restrictions, communications, city policies

First Amendment retaliation claim

Compensatory damages, injunctive relief

Public records obstruction

Delays or refusal involving RSA 91-A requests

Request dates, responses, fee demands, withheld records

New Hampshire Right-to-Know enforcement

Court orders, attorney fees where authorized

Failure to protect vulnerable population

Policies that allegedly increased risks for unhoused individuals

Shelter capacity reports, city policies, contracts, meeting minutes

Civil rights policy/custom analysis

Damages depend on proof of constitutional violation

Political retaliation

Alleged targeting connected to activism or political speech

Election records, communications, enforcement patterns

First Amendment retaliation

Compensatory damages

Damage Type

Formula

Property loss

Fair market replacement value + documented losses

Lost ministry equipment

Inventory value + replacement costs

Lost income/opportunity

Past losses + projected losses supported by records

Emotional distress

Jury-determined based on severity and evidence

Constitutional injury

Nominal damages + compensatory damages if proven

Punitive damages

Only against individual defendants for reckless/intentional misconduct

Attorney costs

Statutory or court-authorized recovery

Evidence Collection Matrix (RSA 91-A / Discovery)

Request:

All homeless death records from 2019–2025:

Names (subject to privacy laws)

Date/location of death

Cause and manner of death

Medical examiner communications

Police reports

EMS reports

All encampment enforcement records:

Notices

Orders

Photos/videos

Contractor agreements

Property seizure logs

Disposal records

All communications regarding homelessness:

Mayor’s office

Board of Aldermen

Police Department

Public Works

Health Department

City Solicitor

All policies:

Encampment removal policy

Property storage policy

Homeless outreach policy

First Amendment social media policy

All training records:

Police training

Code enforcement training

Homeless outreach training

Plus all FOIA req.

Below is a §1983 / Monell-style fact matrix framework. It separates established facts, allegations, evidence needed, potential constitutional theories, and damages categories. Items in the “alleged misconduct” column must be proven through discovery.

Column A — Proven Facts / Known Events

Column B — Alleged Misconduct (Requires Proof)

Column C — Supporting Evidence Needed / Discovery Targets

Column D — Potential Constitutional Violation

Column E — Potential Monetary Damages

Plaintiff submitted RSA 91-A Right-to-Know requests to Manchester officials seeking public records

City officials allegedly delayed, restricted, or improperly withheld responsive records

RSA 91-A requests, dates submitted, city responses, emails, clerk logs, withholding letters, privilege claims

New Hampshire Right-to-Know enforcement; possible due process concerns if records obstruction affects litigation rights

Court costs, statutory remedies where available, attorney fees if awarded

Plaintiff engaged in public advocacy regarding homelessness, encampments, and government actions

Officials allegedly retaliated against protected speech or criticism

Social media records, public statements, meeting records, city communications, enforcement timelines

First Amendment retaliation under 42 U.S.C. §1983

Compensatory damages, nominal damages, injunctive relief

Plaintiff operated or participated in homeless outreach/ministry activities

Officials allegedly targeted religious or outreach activity because of viewpoint or identity

Ministry records, photographs, witness statements, communications with officials

First Amendment speech/free exercise claims

Emotional distress, constitutional damages, possible punitive damages against individuals if proven

Homeless encampment removals occurred in Manchester during the relevant period

City allegedly removed persons/property without adequate notice, process, or lawful procedures

Notices, police reports, DPW records, contractor contracts, body camera footage, property inventories

Fourth Amendment unreasonable seizure; Fourteenth Amendment due process

Property replacement costs, emotional distress, constitutional damages

Personal belongings of unhoused individuals were affected during enforcement actions

Officials allegedly failed to protect, inventory, store, or return property

Property seizure logs, disposal records, photographs, contractor records, witness testimony

Fourth Amendment seizure/deprivation of property; Fourteenth Amendment procedural due process

Value of lost property, replacement expenses, related losses

Plaintiff alleges ministry/religious items were affected during enforcement activity

Officials allegedly interfered with religious exercise or religious expression

Receipts, photographs, clergy items inventory, witness statements

First Amendment Free Exercise Clause

Compensatory damages, emotional distress

Plaintiff reported concerns about homeless deaths, overdoses, and displacement

Officials allegedly ignored known risks or failed to address systemic problems

Public health reports, EMS data, meeting minutes, policy documents, budgets, outreach records

Possible Monell claim if a municipal policy/custom caused a constitutional injury

Damages depend on proof of direct causation

Manchester has experienced homelessness and overdose-related deaths during the period reviewed

City policies allegedly contributed to unsafe conditions through inadequate practices or deliberate indifference

Shelter capacity records, contracts, public health data, city council records, internal communications

Fourteenth Amendment substantive due process theories are difficult and require specific proof; Monell requires policy/custom evidence

Compensatory damages only if legal causation is established

Plaintiff participated in public meetings, political activity, or community advocacy

Officials allegedly treated Plaintiff differently because of political viewpoint or criticism

Meeting videos, agendas, emails, witness statements, enforcement comparisons

First Amendment viewpoint discrimination/retaliation

Compensatory damages, injunctive relief

City departments made decisions affecting homeless services and enforcement

Officials allegedly acted pursuant to an unofficial policy, custom, or practice

Department policies, training manuals, disciplinary records, prior incidents, supervisor communications

Monell municipal liability under 42 U.S.C. §1983

Compensatory damages against municipality if policy/custom caused violation

Plaintiff alleges inability to obtain records needed to present claims

Government agencies allegedly created barriers preventing access to evidence

Complete RSA 91-A correspondence, production logs, court filings, discovery history

Discovery issues; possible sanctions depending on court findings

Litigation costs, possible sanctions or fees where authorized

Monell Discovery Targets (Municipal Liability)

Issue

Records Requested

Policy/custom

Written and unwritten policies regarding homelessness, encampments, public demonstrations, and outreach

Training

Police, code enforcement, DPW, and contractor training materials

Supervisory knowledge

Emails, reports, complaints, internal reviews

Prior incidents

Similar complaints involving homeless individuals, property loss, arrests, or speech issues

Decision-making

Mayor, Board of Aldermen, department head communications

Contractors

Contracts, instructions, supervision records, disposal procedures

Risk management

Insurance claims, Primex communications, prior settlements

Damages Categories to Develop Through Evidence

Economic damages

Lost property value

Replacement costs

Lost income or opportunities

Costs caused by alleged government actions

Non-economic damages

Emotional distress

Loss of dignity

Harm to reputation

Interference with ministry/community work

Constitutional damages

First Amendment injury

Unreasonable seizure injury

Due process injury

Municipal liability damages

Only if evidence establishes that a City policy, custom, or failure to train/supervise caused the constitutional violation.

UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Plaintiff’s Notice Regarding Settlement Communications and Request for Clarification of Representation

Your Honor,

Plaintiff Reverend Zachariah Tringali respectfully submits this notice regarding unsuccessful efforts to resolve this matter outside of court and requests clarification regarding the participation and authority of Matthew V. Burrows in settlement communications involving this case.

Plaintiff has attempted to engage in good-faith discussions to explore a possible resolution without unnecessary additional litigation costs. Despite those efforts, the parties have not reached a resolution.

Plaintiff respectfully requests clarification regarding:

Whether Matthew V. Burrows is acting as legal counsel, claims representative, risk management representative, or another authorized representative for any defendant or interested party;

Whether Mr. Burrows has settlement authority or authority to engage in meaningful resolution discussions;

Whether the opposing parties intend to participate in good-faith settlement negotiations before further litigation expenses are incurred.

Plaintiff believes that meaningful settlement discussions require transparency regarding who represents the interests of each party and whether those individuals have authority to negotiate a resolution.

Plaintiff remains willing to participate in reasonable settlement discussions. However, if settlement efforts cannot proceed in good faith, Plaintiff respectfully requests that the matter continue through the normal litigation process, including discovery necessary to develop the factual record.

Plaintiff further requests that all parties preserve relevant records, communications, and documents related to the issues raised in this action.

Respectfully submitted,

Reverend Zachariah Tringali

Plaintiff

X_____________________________________

ADDRESS _____________________________

_____________________________________

PHONE NUMBER___________________________

Case Summary: Reverend Zachariah Tringali v. Hillsborough County Sheriff’s Department, et al.

United States District Court — District of New Hampshire

Civil Action No. 1:26-cv-00350

Overview

Plaintiff Reverend Zachariah Tringali filed a federal civil rights action pursuant to 42 U.S.C. § 1983, proceeding pro se, alleging that government entities and officials violated his constitutional rights through actions connected to homelessness enforcement, property seizures, public advocacy, and religious outreach activities.

The complaint alleges violations of rights protected under the First, Fourth, Eighth, and Fourteenth Amendments of the United States Constitution.

Defendants Identified

The complaint names governmental entities and officials associated with:

City of Manchester, New Hampshire

Manchester municipal officials

Manchester Police Department

Hillsborough County Sheriff’s Department

Core Constitutional Claims Alleged

1. First Amendment — Speech, Assembly, and Religious Exercise

Plaintiff alleges that his public advocacy, criticism of government actions, and activities through House of Mercy Ministries constituted protected speech and religious outreach.

The complaint alleges that government actions interfered with:

Distribution of aid and supplies

Religious outreach activities

Public advocacy concerning homelessness

Expression of criticism regarding municipal policies

Evidence relevant to this claim may include:

Public statements

Social media records

Ministry records

Witness statements

Communications between officials

2. Fourth Amendment — Search, Seizure, and Property Rights

Plaintiff alleges that during homeless encampment enforcement activities, government actors unlawfully seized, damaged, or disposed of personal property.

Relevant discovery may include:

Police reports

Body camera footage

Property inventories

Contractor records

Disposal documentation

Photographs and videos

3. Eighth Amendment — Punishment Related to Homelessness

Plaintiff alleges that enforcement actions against unhoused individuals amounted to unconstitutional punishment of the status of homelessness.

This claim would require analysis of:

Specific enforcement actions

The circumstances of each incident

Available shelter alternatives

Applicable Supreme Court and First Circuit precedent

4. Fourteenth Amendment — Due Process and Equal Protection

Plaintiff alleges deprivation of property and unequal treatment without adequate legal process.

Relevant evidence may include:

Notice procedures

City policies

Training materials

Prior complaints

Comparable enforcement actions

Municipal Liability (Monell) Theory

Plaintiff’s municipal liability claims require evidence showing that alleged constitutional violations resulted from:

An official policy;

A widespread custom or practice;

Failure to train or supervise;

Deliberate indifference by policymakers.

Potential discovery areas include:

City policies regarding encampments

Police training materials

Internal communications

Prior complaints

Risk management records

Communications with insurers or municipal defense organizations

Litigation Preservation Issues

Plaintiff has requested preservation of potentially relevant evidence, including records relating to:

Reverend Zachariah Tringali;

House of Mercy Ministries;

Homeless outreach activities;

Encampment enforcement operations;

Property removal procedures;

Communications among involved departments.

A litigation hold is intended to preserve potentially relevant information while litigation proceeds.

Requested Relief

Plaintiff seeks relief available under federal civil rights law, which may include:

Compensatory damages;

Nominal damages;

Injunctive or declaratory relief;

Recovery of allowable costs and fees where authorized by law.

Plaintiff,

REV. Zachariah Tringali 

X______________________________________________

ADDRESS_______________________________________

_______________________________________________

PHONE NUMBER_______________________

UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Zachariah Tringali, Plaintiff

v.

CITY OF MANCHESTER, NEW HAMPSHIRE;
BOARD OF MAYOR AND ALDERMEN;
CITY OFFICIALS;
MANCHESTER POLICE DEPARTMENT;
HILLSBOROUGH COUNTY SHERIFF’S DEPARTMENT;
JOHN DOES 1–20, Defendants

Civil Action No. _______

AMENDED COMPLAINT FOR VIOLATIONS OF CIVIL RIGHTS

42 U.S.C. § 1983

JURY TRIAL DEMANDED

I. INTRODUCTION

1. Plaintiff Reverend Zachariah Tringali brings this action seeking protection of constitutional rights guaranteed under the First, Fourth, Eighth, and Fourteenth Amendments to the United States Constitution.
2. This case challenges government practices that Plaintiff alleges have targeted unhoused persons, individuals exercising religious ministry, and vulnerable residents through enforcement policies that punish the condition of homelessness rather than address the underlying housing crisis.
3. Plaintiff alleges that Defendants implemented, enforced, or participated in policies resulting in displacement, deprivation of personal property, interference with religious outreach, and unequal treatment.

II. JURISDICTION

1. This Court has jurisdiction under:

• 28 U.S.C. §1331 (Federal Question Jurisdiction)
• 42 U.S.C. §1983 (Civil Rights Act)
• 28 U.S.C. §1343 (Civil Rights Jurisdiction)

III. PARTIES

Plaintiff

1. Plaintiff Zachariah Tringali is a resident of New Hampshire and a licensed/ordained minister conducting outreach work among unhoused individuals.
2. Plaintiff has provided humanitarian services including food assistance, outreach, religious support, and advocacy.

Defendants

1. Defendant City of Manchester is a municipal corporation responsible for policies, ordinances, and actions of its departments.
2. Defendant Manchester Police Department is responsible for enforcement actions.
3. Defendant Hillsborough County Sheriff’s Department is responsible for actions taken by its officers.
4. Individual defendants acted under color of state law.

IV. FACTUAL ALLEGATIONS

A. Enforcement Against Unhoused Residents

1. Manchester adopted and enforced ordinances restricting camping and use of public spaces.
2. Plaintiff alleges these policies have resulted in displacement of unhoused residents without adequate alternatives.
3. Plaintiff alleges enforcement actions have caused loss of personal belongings, disruption of survival necessities, and increased vulnerability.

B. Property Seizure and Destruction

1. Plaintiff alleges government actors removed, seized, or failed to properly preserve personal property belonging to Plaintiff and other unhoused individuals.
2. Plaintiff alleges property included:

• personal belongings
• religious materials
• ministry equipment
• clothing
• essential survival items

1. Plaintiff alleges Defendants failed to provide adequate notice, inventory, storage, or meaningful opportunity to recover property.

C. Religious Freedom Claims

1. Plaintiff conducted religious outreach protected by the First Amendment.
2. Plaintiff alleges government actions interfered with his ability to practice religion and provide ministry services.
3. Plaintiff alleges religious materials were treated as ordinary disposable property despite their protected nature.

D. Disability Discrimination

1. Plaintiff has mobility limitations requiring use of a cane.
2. Plaintiff alleges Defendants failed to reasonably accommodate disability-related needs during enforcement actions.
3. Plaintiff alleges policies created additional barriers for disabled unhoused persons.

V. CLAIMS FOR RELIEF

COUNT I

Fourth Amendment — Unreasonable Seizure of Property

1. Plaintiff incorporates prior paragraphs.
2. Defendants seized and/or deprived Plaintiff of property without lawful process.
3. Such conduct violated Plaintiff’s Fourth Amendment rights.

COUNT II

Fourteenth Amendment — Procedural Due Process

1. Plaintiff had protected property interests.
2. Defendants deprived Plaintiff of property without adequate notice or opportunity to be heard.
3. Defendants violated Plaintiff’s Fourteenth Amendment rights.

COUNT III

First Amendment — Free Exercise of Religion

1. Plaintiff’s ministry and religious activities constitute protected expression and religious exercise.
2. Defendants interfered with Plaintiff’s religious activities.
3. Defendants violated the First Amendment.

COUNT IV

First Amendment — Speech and Assembly

1. Plaintiff engaged in advocacy regarding homelessness and government policy.

COUNT V

Fourteenth Amendment — Equal Protection

1. Defendants applied policies that disproportionately affected unhoused individuals.
2. Plaintiff alleges enforcement was based on housing status and economic condition.

COUNT VI

Municipal Liability — Monell Claim

1. Defendant City of Manchester maintained policies, customs, or practices that caused constitutional violations.
2. These included:

• inadequate property protection procedures
• enforcement practices against unhoused residents
• failure to train personnel
• failure to supervise officers

1. The City’s policies were a moving force behind Plaintiff’s injuries.

VI. DAMAGES

Plaintiff seeks:

• compensatory damages
• damages for lost property
• emotional distress damages where permitted
• punitive damages against individual defendants where allowed
• attorney fees under 42 U.S.C. §1988
• costs
• declaratory relief
• injunctive relief

VII. REQUEST FOR RELIEF

Plaintiff respectfully requests that this Court:

A. Declare unconstitutional actions unlawful;

B. Order Defendants to establish lawful procedures for property removal;

C. Require adequate notice and recovery procedures;

D. Require disability accommodation policies;

E. Award damages;

F. Grant any additional relief deemed appropriate.

Respectfully submitted,

Zachariah Tringali
Plaintiff, Pro Se

Date: ___________