Okay. Well, without discussing the merits of the case, I can say:
1) The service of process on a case is to be to the NM Attorney General. The office accepts summons, complaints, and other legal documents alleging civil causes of action against the state, a state agency, or a state official or employee acting in an official capacity. Service must be made pursuant to the Rules of Civil Procedure upon:
Office of the Attorney General
Santa Fe, NM 87504
2) One must file a notice claim against the state agency one wishes to sue within 90 days. See HERE. It is vitally important to do so, because missing that deadline can stop the suit before it even begins. The written notice must state the time, place, and events that occurred. NMSA 1987 Stat 41-4-16.
3) State agencies enjoy a very high level of immunity under the NM Tort Claims Act, and one must prove that the actions went below the standards of reasonable care, and possibly were grossly negligent and/or malicious. See HERE and review this carefully, especially part III (immunizes) and on.
4) Every complaint must be drafted from scratch, so this would have to be done by you or your attorney. You can likely find a number of complaints in the local law library.
I hope this helps and clarifies. Please use the SEND or REPLY button to keep chatting, or please RATE when finished. You may always ask follow ups at no charge after rating. Kindly rate my answer as one of TOP THREE FACES/STARS and then SUBMIT, as this is how experts get credit for our time. Rating my answer the bottom two faces/stars (or failing to submit the rating) does not give me credit and reflects poorly on me, even if my answer is correct. I work very hard to formulate an informative and honest answer for you; please reciprocate my good faith with a positive rating.