Linda Hamilton, Plaintiff

Attorney General Thomas Riley, Defendant

1. This is a complaint seeking judicial review pursuant to G.L. 30 sect. 30A.
2. The plaintiff is a resident of the Commonwealth and resides at Nine Wilde Rd., Shelburne Falls, Ma.
3. The Defendant is the Attorney General of Massachusetts.
4. The plaintiff is aggrieved by the decision of the Defendant, declining to investigate the conduct of state and local police officers on March 1, 2000.
5. The Defendant's decision is contrary to constitutional standards because Article IX of the Massachusetts State Constitution guarantees that every subject of the Commonswealth ought to find a certain rememdy, by having recourse to the laws, for all injuries or wrongs that he may receive in his person, property or character.
6. The Attorney General's has four broad missions: investigate and prosecute violations of state criminal law, promote effective law enforcement and criminal justice, crime prevention and provide assistance to crime victims.
7. The criminal bureau within the office of the Attorney General investigates and prosecutes crimes that compromise the public's confidence in the government or harm public agencies. These include crimes committed against state and local public agencies and government employees, agents, and contractors. Specifically the Attorney General is charged with investigating and prosecuting the crimes of perjury, tax evasion, larceny, bribery, accepting unlawful gratuities, identity fraud, comspiracy, and procurement fraud.
8. The Defendant's decision is contrary to law because MGL 12: Section 11H guarantees the citizen appropriate equitable relief when the constitutional rights of the citizen have been violated.
9. There is a presumption that public officials perform their duties in an honest and impartial manner. LaPoint v. License Bd. of Worcester, 389 Mass. 545, 459 (1983); see also Konover Mgt. Corp. v. Planning Bd. of Auburn 32 Mass App. Ct. 319, 326 (1922)

Wherefore plaintiff requests the following relief:

1. This Honorable court compel Attorney General Thomas Riley to conduct his ministerial duty and to protect the Constitutional rights of the plaintiff.
2. This Honorable court compel Attorney General Thomas Riley to thoroughly investigate any person involved as a public official or government employee concerning an illegal stop of the plaintiff by Mass. State Police on March 1, 2000 and continuing until the present.
3. This Honorable Court compel Attorney General Thomas Riley to prosecute fully any individual determined to have committed unlawful acts and violated the Civil rights of the plaintiff.

Respectfully Submitted,
Linda Hamilton, pro se

[signature]

February 1,2005