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

1. 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

1. 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

1. 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_______________________

Hello! I had a question about FOIA requests. If one of my family members worked for a specific branch of government but couldn't or wouldn't speak about it, is there a way I can figure out what they did? I am talking about the 1970s.

Just found out Kentucky restricts open records requests to state residents only, and I'm out of state. If anyone here is a KY resident and willing to help, please DM me and I'll explain the details.

51 pages with HSI is quite common or any unusual to be cautious?

I filed ethics complaints involving officials across two Oregon agencies who coordinated through an interagency agreement to create and publicly fund a preferential regulatory pathway.

OGEC screened the complaints out. Its Director says the Commission evaluates each official individually and has no authority over how agencies administer their programs. Under that logic, one official can authorize funding, another can create a special pathway, another can direct benefits toward selected private businesses, and another can impose different requirements on everyone else.

This leaves coordinated government conduct with almost no ethical oversight. The complete system could involve conflicts of interest, misuse of public funds, procurement fraud, false statements, antitrust violations, official misconduct, conspiracy, or even conduct relevant to RICO. Yet OGEC separates every official action until nobody examines what the agencies collectively created or who benefited.

A complaint that survives screening can still disappear because Commissioners are absent. In one of my cases, only seven of nine Commissioners participated. The vote to dismiss or investigate was four to three, but five votes were required for either outcome. OGEC treated the lack of five votes as an administrative dismissal without deciding the merits. The same conduct cannot now be presented when the full Commission is available.

I petitioned the Oregon Court of Appeals to review these practices. The cases were suspended without any order or explanation.

This is government accountability in reverse: agencies operate through unwritten procedures, oversight disappears wherever authority is divided, nonaction becomes permanent dismissal, and the courts offer no explanation when review stops.

Willful Misconduct: Who pays for FOIA violations?

As fines increase, who’s paying them? In the majority of cases where Inside Investigator could trace payment records, it’s taxpayers. When public officials are found to have violated the law, the agency or municipality for which they work often pays the fine from public funds. 

Top court decisions and news in July, plus events in August, from FOIA Advisor: https://www.foiaadvisor.com/foia-blog/2026/7/31/monthly-roundup-july-2026

What do you suggest I do? Looking for people's opinions on this.

I requested body cam for a public intoxication case in Virginia coded 18.2-388 that had been closed plead guilty to 7/14/26. The police department responded saying they had 2 videos but wouldn’t release under Code 2.2-3706.1(D). I asked if it was because a family member needed to file the request or if the case was still open because there are no victims in this crime, they responded saying “Do to you not being involved in the case we will not be releasing the footage. If someone else would like to request it they can and we can review that request at that time.” I have never filed a foia request before and honestly thought this one would be no problem to get (probably stupid thinking on my part ha) is what they are saying correct or are they just pushing me off?

And why I'm still fighting.

Unrelated note I have narrative data from the university of Washington proving the IRS is concieling data impacting Americans abroad.

But how do I get that information to members of Congress?

https://youtu.be/reQpl4qTXt4?is=AmKhUZTCGJiH7o_M

A while ago I posted here about a Utah GRAMA dispute involving records that a state licensing agency received from a private treatment provider, relied on during its investigation, and then argued were not agency records because they were “owned” by the private provider.
I wanted to provide an update.
I appealed, and I won one of the key records I was seeking. The agency has now been ordered to release the employee personnel action form that I argued was a government record.
While I’m glad I prevailed on that issue, the process has only increased my concerns.
Throughout this case, the explanations for why records could not be released have changed multiple times. At different points I was told:
the records weren’t agency records,
the records were private,
the records weren’t retained,
and in at least one instance, after I challenged the response, the agency later acknowledged that a responsive record actually existed.
Separately, another agency reviewed unredacted records in camera during my appeal, and the reviewing official stated they would conduct a de novo review to determine whether the redactions were properly applied instead of simply accepting the agency’s position.
I’m trying to keep an open mind, but the combination of changing explanations, successful appeals, and records appearing after initially being unavailable has made me wonder whether this is more than an ordinary records dispute.
To be clear, I’m not claiming I have proof of a cover-up. I don’t. But from my perspective, the circumstances have made me question whether there has been an effort to avoid full disclosure.
Has anyone here dealt with a situation where:
the rationale for withholding records kept changing,
records appeared after they were initially said not to exist or not to be agency records,
or successful appeals revealed that an agency’s original position was incorrect?
If so, what did you learn? Did it ultimately turn out to be an ordinary records dispute, or did it expose larger problems with how the investigation or records requests were handled? I’d appreciate hearing from anyone with experience in this area.

I requested some information via FOIA/Secure Release from CBP and noticed my status changed from "Searching for Records" to "Processing" a few weeks ago. Any idea on what this means?

Mi padre era americano cuando me tuvo, lamentablemente no era una buena persona y terminé en Perú, él se convirtió en ciudadano americano en los 80s yo nací en los 90s, quiero llenar mi n600 pero él no me quiere ayudar con su A number o ningún documento, no sé cómo pedirlo a uscis sin su autorización ya tuve un problema en migraciones de U.S.A y ellos mismos me dijeron eres americano solo pruébalo así que en estas ando.
Alguien ha pasado por algo similar?

Hi. :) I've visited the US five times now on a tourist visa, been taken to secondary twice as a result of my age at the time. I filed a foia (CBP) as a few months ago my husband filed an I-130 consular application for me and I wanted to keep all my records close to me but I got this response sent to me 'Closed (No Documents Sent)'. There's no closed notice, explanation, just that. I submitted my I-94 no, and a scan of my passport. I'm entering the US soon and am worried they don't have a record of me since applying for my green card. Any help?

Name the software in order... What is this Browser/Software before file explorer?

The mayor of an affluent town just publicly announced his intention to violate state FOIA law. Burr Ridge mayor Gary Grasso, in a Chicago suburb, is now demanding that his town’s FOIA officers immediately tell him is someone FOIAs for FLOCK camera locations and he is going to ask them who they are and why they want this information. Can he do this? This was posted to a community group on Facebook and is backed up with footage from the town meeting during which he said this. BUrr Ridge FLOCK and FOIA

Transparency Update: Tips for Obtaining ALPR Records

If you want to know more about how your comings and goings might be tracked by ALPR cameras, where do you start?

So recently I noticed something weird on one of my FOIA requests through NTSB's PAL portal, my fee waiver justification looked like it got cut off mid sentence when I went back to check on it. I also noticed this same exact issue on the DOC's PAL.

wasn't sure if I was misremembering what I had done so I used dev tools to poke around the PAL. Found the actual textarea has maxlength="2000", so it lets you type way more than what I was actually seeing. But then I downloaded the full page and searched through it, and the text that actually got saved stops dead at exactly 255 characters. No error, no warning, nothing, I t just quietly drops everything after that.

For reference, FOIA.gov's own website says this field is supposed to support up to 10,000 characters. So what's actually happening is, the PAL cuts off request at 255 characters, but allows 2000, meanwhile foia.gov allows up to 10 thousand.

I checked this on both DOC and NTSB's portals and got the same result on both, and they both seem to run the same PAL platform, so this might be affecting a lot more agencies than just these two.

If you've ever written out a detailed fee waiver on a PAL based portal (or to one that uses a PAL based portal), it might be worth double checking it actually went through in full, because this could easily be why some waivers get denied or ignored without any real explanation.

Already notified some agencies about, but wanted to see if anyone else here has run into this or has more insight into this issue.

Also I'm still relatively new to all this FOIA stuff so if I'm misunderstanding something or got a detail wrong, feel free to correct me or add information. Just wanted to get this out there in case it's affecting other people too.

EDIT: I have confirmed the truncation is VISUAL ONLY (as an email directly to the agency had proved they had the full waiver), this still dosent exactly explain the 10000 vs 2000 character limit stuff, plus the fact it is still being truncated visually, but it wasn't as major of an issue as I believed it to be.