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COMMONWEALTH OF MASSACHUSETTS 1THE TRIAL COURTSuffolk, ss. Superior Court Dept.Suffolk Division
)
FATHERS AND FAMILIES, INC.
,)
TODD W. SANDAHL,
)
MICHAEL T. FOGG
)
DAVID SATLOFF
)
DAVID LITTLE
)
ROBERT THOMPSON
)
PAUL DIONNE
)
RICHARD DiPALMA
)
BOBBIE FEUERSTEIN
)
SHAWN GLIKLICH,
)
JOHN RICE,
)
STEVEN MAYNARD,
)Plaintiffs,))vs.)
CIVIL ACTION No
.
09-1069-E
)
Hon. ROBERT A. MULLIGAN,
)
In His Official Capacity, and
)
THE JUSTICES OF THE TRIAL
)
COURT OF MASSACHUSETTS,
)
In Their Official Capacity,
)Defendants.))
COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEFIntroduction
1.
This complaint seeks declaratory and injunctive relief against Robert A. Mulligan, in hisofficial capacity as Chief Justice for Administration and Management of the MassachusettsTrial Court, and the Justices of The Trial Court of Massachusetts, in their official capacities,to enjoin the mandatory use of new Child Support Guidelines (“New Guidelines”), whichwere effective after January 1, 2009, until the defendants comply with the laws andConstitution of the United States and Massachusetts.
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Parties
2.
Plaintiff
Fathers And Families, Inc.
(“Fathers and Families”) is a Massachusetts non-profitcorporation, with a principal place of business at 20 Park Plaza, Suite 628, Boston,Massachusetts. Fathers and Families has thousands of members, many of whom aredivorced, re-married, or never-married fathers who seek reform of child custody and childsupport policies. The majority of its members pay child support and are subject to theMassachusetts child support guidelines. Some members are women who are second wives or partners, with or without children, whose families and children are negatively impacted by payment of inequitable and excessive amounts of child support to first families.
3.
Plaintiff
Todd W. Sandahl
, is a natural person residing in Walpole, Massachusetts, and hasone child for whom he pays child support. He will be directly and negatively affected by theimplementation of the New Guidelines. He is not a member of Fathers and Families.
4.
Plaintiff
Michael T. Fogg
, is a natural person residing in Holyoke, Massachusetts, and theadoptive father of five children for whom he is paying child support. He will be directly andnegatively affected by the implementation of the New Guidelines. He is not a member of Fathers and Families.
5.
Plaintiff
David Satloff
, is a natural person residing in the state of Rhode Island, and the father of one son for whom he is paying child support. He will be directly and negatively affected by the implementation of the New Guidelines. He is not a member of Fathers and Families.
6.
Plaintiff
David Little
, is a natural person residing in New Ashford, Massachusetts, and thefather of four children for whom he is paying child support. He will be directly andnegatively affected by the implementation of the New Guidelines.
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7.
Plaintiff
Robert Thompson
, is a natural person residing in Bradford, Massachusetts, and thefather of two children for whom he is paying child support. He will be directly andnegatively affected by the implementation of the New Guidelines.
8.
Plaintiff
Paul Dionne
, is a natural person residing in Danvers, Massachusetts, and the father of two children for whom he is paying child support. He will be directly and negativelyaffected by the implementation of the New Guidelines.
9.
Plaintiff
Richard DiPalma,
is a natural person residing in Brookline, New Hampshire, andthe father of three children for whom he is paying child support, and one child with plaintiff Bobbie Feuerstein. He and the new child will be directly and negatively affected by theimplementation of the New Guidelines. He is a member of Fathers and Families.
10.
Plaintiff
Bobbie Feuerstein
, is a natural person residing in Brookline, New Hampshire, andthe fiancé of Plaintiff Richard DiPalma, with whom she has one child. She and her new childwill be directly and negatively affected by the implementation of the New Guidelines.
11.
Plaintiff
Shawn Gliklich
,
is a natural person residing in Boxford, Massachusetts, and thefather of two children for whom he is paying child support. He will be directly andnegatively affected by the implementation of the New Guidelines.
12.
Plaintiff
John Rice
, is a natural person residing in Waltham, Massachusetts, and the father of two children for whom he is paying child support. He will be directly and negativelyaffected by the implementation of the New Guidelines.
13.
Plaintiff
Steven Maynard
, is a natural person residing in Washington, D.C., and the father of one child for whom he is paying child support. He will be directly and negatively affected bythe implementation of the New Guidelines. He is a member of Fathers and Families.
14.
Defendant
Robert A. Mulligan
, is the Chief Justice for Administration and Management(“CJAM” or “Justice Mulligan”) for the department of the Trial Court of the Commonwealth
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