Conflict of Interest Affidavit: to go with my Victim Witness Statement

⚖️ Intro for Conflict of Interest Affidavit (Hampden/Worcester County Misconduct)

This affidavit is part of my public Memory Ark, an ongoing record of abuse, corruption, and neglect across Massachusetts courts, law enforcement, and legal services.

This sworn statement outlines more than a decade of direct, personal experiences with systemic obstruction of justice. From being denied medical care after being struck by a vehicle in 2013, to witnessing the abuse of disabled adults by state-approved caretakers, to the deeply compromised cases from 2021–2025—this is a record of failure at every level.

The agencies and individuals named here have either ignored or actively participated in the misconduct.

This is not just a personal complaint. It is a demand for an independent investigation. To explore other related events and documentation, use the sidebar to browse the Memory Ark, where more posts from 1994–2025 are cataloged by year and theme.

AFFIDAVIT REGARDING SYSTEMIC MISCONDUCT AND CONFLICTS OF INTEREST:

HAMPDEN COUNTY DISTRICT ATTORNEY'S OFFICE AND ASSOCIATED LAW ENFORCEMENT AGENCIES

I, Ricky Stebbins, being of sound mind and over the age of 18, under penalty of perjury, do hereby affirm the following:

INTRODUCTION: This affidavit is submitted to support my formal conflict of interest motion and to once again formally report sustained, systemic misconduct, conflicts of interest, and deliberate obstruction of justice involving the Hampden and Worcester County District Attorney’s Office, the Springfield and Warren Police Departments, court-appointed attorneys, and various state oversight agencies between 2013 and 2025. This affidavit reflects my lived experience as a criminal defendant who was repeatedly denied due process, medical care, and impartial representation while attempting to navigate a legal system I now believe is both structurally compromised and functionally hostile to accountability.

SECTION 1 – EARLY SYSTEMIC FAILURES (1994):

1. In 1994, when I was a child, I was taken out of school by Springfield Police without my parents’ permission by now Super Intendent Larry Akers. This removal violated both my rights and my parents' explicit objections. Despite this clear overreach, no legal action was taken against those responsible.

2. My friend Tammy was the victim of a serious and disturbing incident which remains unresolved to this day. The Springfield Police failed to pursue her case appropriately, and no accountability was enforced. This early failure by law enforcement set a precedent of neglect and inaction that would continue throughout my life.

SECTION 2 – UNDENIABLE ALLEGATIONS:

1. On January 16, 2013, I was struck by a vehicle while walking through a parking lot. When police arrived, I was arrested without being able to give a statement and denied medical attention by responding law enforcement (Springfield Police Officers Thomas Sheehan and Thomas Douglas). I wrote a statement in the hospital after leaving the police station and had it notarized before appearing at my first court appearance.

2. I was wrongfully charged with malicious damage to a motor vehicle and brought to trial without being provided all the relevant evidence in my case.

3. Before trial, I filed a complaint with what was supposed to be a civilian-oversight department on Maple Street, but it was run and staffed by Springfield police officers.

4. I agreed to go to trial without legal representation; ADA Katherine Johnston and Edward Kavari told me Judge Hadley denied me access to the driver's insurance information, claiming it was not relevant to the charges. I was found guilty in a process that later revealed prosecutorial misconduct.

5. I later discovered that the driver was uninsured, which I believe is why officers initially denied me medical attention.

6. ADA Katherine Johnston provided the court with a falsified window repair receipt and stated the driver paid for it out of her own pocket, all while trying to paint me as a monster. I was supposed to be provided a copy of this receipt by the court but I was not.

7. I discovered that the driver, Kishana Johnson, had family members working at the Hampden County Courthouse.

8. Attorney Randy Milo, Attorney Eric Applebaum, Attorney Anna Levine, Head Court Clerk Jon Gay, and then-DA Mark Mastroianni all failed to act on clear constitutional violations and did not pursue proper investigation into the driver’s car insurance or registration status.

9. Judge Hadley dismissed physical evidence supporting that Springfield police deleted information off of my police report and denied me medical attention because the driver was operating the vehicle illegally.

10. In 2014, I was physically attacked on Phillips Avenue while walking to court to extend a harassment prevention order I had filed against Kishana Johnson. I originally requested this order after noticing her repeatedly driving past my house, despite my police report at the time stating she lived in Chicopee. I believed she was stalking me. After the court date for the order was suddenly moved up, I was attacked on the very street where she actually lived—Phillips Avenue—while heading to the bus stop, as my license had been suspended as a result of the original incident. This timing and location were not coincidental. Despite this alarming escalation, Springfield Police falsely claimed they did not know she lived there and failed to investigate the attack. This event exemplifies the consistent pattern of retaliation, suppression of evidence, and refusal to act by local law enforcement and court officials who were already fully aware of the ongoing misconduct.

11. I was falsely charged with forgery after discovering my own notarized statement was illegally altered and entered into the docket. While I was preparing to defend myself, I became seriously ill, and Attorney Elaine Pourinski coerced me into pleading guilty on February 5, 2016. This occurred shortly after a traumatic psychiatric hospitalization (ending January 25, 2016), and after someone held a gun to my head in a hallway outside her office in Northampton. Despite these extreme events, no court-ordered competency evaluation was ever conducted. I tried reporting this to court and state officials, including Probation Officer Jen O.

12. I contacted multiple oversight and media outlets over the years—including Mayor Domenic Sarno, the ACLU, the Governor's Office, the Massachusetts State Police, the FBI, the Attorney General’s Office, the Board of Bar Overseers, and local news stations (Channel 3 and Channel 22)—providing detailed documentation of my case. Most failed to respond or declined to provide me with contact information for those who could and would investigate.

SECTION 3 – WITNESS TO ABUSE AND STATE NEGLECT (2016–2021):

1. I witnessed Massachusetts state investigators falsely accuse Beth Nichols of abandoning her son at a New Hampshire psychiatric facility, when in fact the state of Massachusetts had placed him there over two hours away.

2. I witnessed Stephen Nichols suffer abuse and neglect inside that psychiatric facility, at Crystal Springs in Fall River, MA, and while he lived in Uxbridge under the care of Kennedy Donovan Center (KDC) and Amigo.

3. I also witnessed his abuse and neglect at a group home run by Venture community services, whose president is Mike Hyland. This is the same location later mocked by Attorney Roger Banks.

4. Tammy Hyland, the wife of Mike Hyland, was hired as a Human Service Coordinator for the State of Massachusetts during this time, despite claims that she had no prior experience and behavior that clearly demonstrated her lack of experience. Tammy oversaw the care of Stephen Nichols and countless other disabled adults both for her husbands company and other companies in an area of central Massachusetts. Tammy ignored countless abuse reports that both Beth and I filed. Beth and I filed complaints against Tammy with the state of Massachusetts, but they were ignored.

5. The abuse was so extensive that we began documenting everything via email and discontinued all phone conversations.

6. We filed multiple abuse reports and contacted various organizations, including the Massachusetts Disabled Persons Protection Commission (DPPC), the Disability Law Center, the Massachusetts State Police, the Department of Children and Families (DCF) and the Department of Developmental Services (DDS). All our concerns were either ignored or dismissed, and to this day I have received no follow-up regarding the serious abuse allegations.

SECTION 4 – REPEATING TIMELINE (2021–2025):

1. October 2021: Assault charge filed. Attorney Roger Banks was appointed. He ignored allegations of abuse against me and laughed about abuse going on in a group home for disabled adults. He had a client in this household and stated he received body cam footage of my arrest, which he described in detail.

2. 2023: Attorney O'Doherty attempted a "trial by surprise," bypassing procedural protections and never informing me of what was going on in my case.

3. 2023: Attorney Bergo stalled my case after I drove to Worcester and spent hours explaining these issues to him.

4. 2024: Attorney Bergo attempted to mislead me about the existence of the body cam footage that Attorney Banks had previously acknowledged receiving. When I pointed out that Warren police vehicles are equipped with in-vehicle recording systems, something I knew firsthand from a prior ride to the emergency room in January 2016, he responded by ordering a competency evaluation. This was after I escaped the emergency room during my last suicide attempt, and shortly before I was coerced into pleading guilty after having a gun placed to my forehead in my lawyer’s office building.

5. 2025: ADA Lindsay White falsely claimed in open court that dash cam footage did not exist. She avoided discussing applicable department policies and procedures. Warren police were then forced to admit footage existed, but only provided recordings taken far from the actual event. Attorney Grady downplayed the severity of this misconduct and expressed zero concern for citizens’ safety and wellbeing, reflecting a broader pattern of disregard I’ve experienced from other legal representatives and officials I’ve contacted. The charges were ultimately dismissed because I spoke up, but no one was held accountable for the years of obstruction and harm.

SECTION 5 – REQUEST FOR ACTION:

I request that this affidavit be entered into official record with the appropriate oversight bodies, including:

• Office of the Massachusetts Attorney General- 6-11-2025 – Phone Call with AG's Office (Lisa Fenishell):

  On June 11th, I received a call from Lisa Fenishell of the Massachusetts Attorney General’s Office. The call lasted approximately five minutes. During this call, I attempted to discuss my unresolved legal concerns regarding Commonwealth Care Alliance and related systemic failures across multiple state agencies and legal representatives. Ms. Fenishell refused to assist, expressed anger at my questions, explicitly stated that she wanted no part in helping, and abruptly ended the call. This was not only dismissive but a clear example of institutional hostility when citizens request oversight or accountability. Screenshots of the call and its duration have been documented in the archive.

• Massachusetts Board of Bar Overseers

• United States Department of Justice (Civil Rights Division)

• Internal Affairs Division for Springfield, Warren, and Massachusetts State Police

Furthermore, I request that an independent review be initiated regarding the pattern of misconduct and collusion observed in Hampden County courts, with particular attention paid to the withholding of evidence, retaliatory legal strategies, and suppression of witness rights.

This affidavit represents only a summary of the issues at hand. Full evidence logs, complaint files, and recordings are maintained in a publicly accessible archive for transparency and corroboration.

Signed,

Ricky Stebbins
Date: _______________

Notarized by:

[Notary Public, if applicable]

Public Signatures: