UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE ______________________________________ ) Leisha Tringali, ) ) Plaintiff ) ) vs. ) ) ) Department of Transitional Assistance, ) ) Department of Revenue / CSE, ) ) Doug Comfort ) ) Registry of Motor Vehicles / RMV, )
)

Civil Action No.: 1:12-cv-00124PB

Petition for Temporary Protective Order and Petition and Motion for Preliminary Injunction Hearing

Defendants ) ____________________________________ )

UNDER OATH, I PETITION THE COURT for a temporary protective order and a preliminary injunction against the defendants based on the following:
1.

As part of this petition is a statement of facts indicating that defendants has engaged in conduct which is believed to be criminal in nature and would cause harm to the petitioner. The petitioner is aggrieved by the defendant's prior unlawful criminal acts under the color of law by creating and using a synthetic identity without the express authorization of the petitioner. The defendants transferred petitioners personal identifying information onto a synthetic identity to intercept petitioners property and to deny her due process. Without a modification the defendants altered a temporary order. The petitioner alleges that any continued conduct by the defendants that is the same as or similar to conduct that is prohibited by both Federal and State Laws would harm petitioner.

2.

3.

4.

The petitioner would face a substantial threat of irreparable damage or injury if the injunction is not granted. The balance of harms weighs in favor of the petitioner seeking the preliminary injunction

5.

Conclusion

For the reasons set forth herein, the Petitioner respectfully requests that this Court grant her emergency motion for a protective order and prohibit the defendants from continuing through with interceptions of finances, levies on accounts and suspension of her right to drive.

______________________________ Leisha Tringali, Petitioner

REQUEST THE COURT: 1. Issue a temporary protective order requiring the defendants to cease or avoid any liens, levies and suspensions against the Petitioner until the case is briefed and considered, an administrative closing of the child support case is appropriate. 2. Set a time for a hearing on the petition for an injunction requiring the defendants to cease and / or avoid any leins, levies and suspensions until the case has been briefed and considered . 3. If the temporary protective order is denied, Petitioner moves the court to schedule an injunction hearing. 4. Issue an injunction against the defendants from going forward with a course of conduct ( ie: liens, levies, and suspensions ) or compelling a party to continue with a course of conduct until the case has been decided. 5. Direct the sheriff to assist in executing or serving this petition for temporary restraining order and/or injunction and notice of injunction hearing, if requested. 6. Grant an award in a reasonable amount for the costs of maintaining this action, if deemed appropriate, and such other relief as may be just and equitable.

State of_______________________ County of __________________________ Subscribed and sworn to before me On ________________________________ ___________________________________ Notary Public, Court Official My commission/term expires: Date ____________________________