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STATE OF NEW HAMPSHIRTI
CARROLI, COLIN'TY. SS STJI'I]RIOR COUR'fMarch 4, 2015
Case No: 2 I 2-20 I 5-CV-000 I 0
Starbrite I-easing, Inc., and Edward C. Furlong III
v-
'l'own of' Bartlett. e1 al
ano
Bartlett Water l)recinct
MOTION TO VACATE ''TEMPORARY ACCESS AGREEMENT'" A.K.A.(TAA) BASED ON NEW PHYSICAL EVIDENCT'
NOW COMES, Edward C. Furlong III, (President of Lil' ManSnowmobile Rentals, INC., (hereafter, Plaintiffs) in his PRo SE Capacity,and Counsel for Plaintiff, Lil' Man Snowmobile Rentals in the abovecaptioned case, sets forth and states the following:
l.'fhe agreement "Temporary Access Agreement" hereafter (1'AA) between the "Plaintiffs and Defbndants, Doug Garland and Gene Chandler (Rartlett Selectmen) fbr"'l'he Town" was signed by Plaintiff, Edward Cl. F'urlong III, February 13, 2009 at theoffice of Randal Cooper, (fbrmer attorney lbr plairrtifl).2. Defendant's, selectmen, Doug Garland and Gene Chandler (fbr "-l'he'fown") signed a1a dift-erent location with their attorney, Douglas Mansfield, Esq.3. I'}laintiff's counsel, Randal Cooper, since the signing of thc TAA on 02-13-2009.hadbeen sued by this Plaintiff for not providing a duty of care that meets certain cthical
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standards; and as provided in the New l{ampshire's Bar Prolessional Conduct and EthicsRuels. Randal Cooper, Esq., was fbund by a Strafford County "Jury. Verdict" to be guiltyo1-Breach of Fiduciary Duty or conf'lict of lnterest. see cxhihir r.+. Defendant's Doug Garland and Gene Chandler and Jon 'fanquay. all Selectmen. are nostrangers to corruption; Mr. Tanquay.iust recently was removcd from his selectman chairbecause of his conviction of child pornography. Garland's been arrested as seen in his"Deposition", and Chandler was indicted, by the New Hampshire t,egislature House for(campaign fraud), but later settled the case with the United States tRS fbr income raxevasion see Plainti-f-f's exhibit 2.5. Gene Chandler and Garland. are the sclectman that originally had their hands in thedrafting of the "temporary access agreement" or (T'AA). And they are back at it again.They're not budging. they're back at trying to take away what belongs to Plaintiffs. Theyordered the town's attorney to "pick up the fight" where Garland turned thc volume downa few years ago when Plaintiffs burden was reversed with police intimidation. soPlaintiffs, again, were le1lto back out, fighting. Plaintifls have been arrested twice sincethe order dated February l3 th, 2015 was Ordered, as a standing order; but was denied byDef-endants as a non-authentic order by the court. Plaintifl-s had to post a cash bond of$4,000.00 before being released from the Ossippee, Ilouse of Corrections. Plaintilfsshowed the "acting chiel'', .lanet Hadley Champlin. the Courl Order datcd February 13.and she simply disregarded the Ilonorable Judge Templc's Orders, based on her owninfbrmation on "a history" of Plaintiffs behavior, to determine that "probable causeexisted to arrest," Mr. Furlong, Business owneriPlaintiff , and Counsel fbr Plaintiff,Starbrite Leasing, Inc.
6. Plaintiffs have an "authorized" recording of acting Chief .lanet Champlin's refusal toabide by the Court order from JD, (Temple, C), to ol'fer as more evidencc to thisHonorable Court that Doug Garland will not stop, at violating Superior Court Orders,violating plaintiffs fundamental rights, because Garland uses the police to enforce non-compliance of the Superior Court Order fiom the t-lonorable.ludge Temple. (Garland'sprivate police fbrce); (Chief Champlin) lbund notes fiom out going (Chief T. Conify) inhis frle cabinet, that elicited a non-compliance "stance" fiorn Del'cndant's police force,
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acting chief Janet Hadley Champlin.7. Plaintiff s are not going to expand anymore on the corruption of the temporary accessagreement, selectman Doug Garland, the history of corruption that has plagued theBartlett Town Hall for years; ever since fbrmer police chief Bob Snow was indicted fbrstealing money from the "Dare Program," and subsequently "pleading out" ancl receiving2 years in the DOC.
8. I base the revisiting of the vacating of the "temporary access agreemenl" on a plethoraof o'new, "conclusive," hard evidence, (including but cerlainly not limited to Garland'stwo lies to cover up the "intentional" tort against Plaintifl-s). implicating the Def-endant;and the serious off'enses against the Plaintiffs. their businesses and the general pr-rblic whopatronize those businesses. This serious problem was perpetrated by Doug Garland.Selectman/Representative Ex ofTicio to the Bartlett plannins Iloard.
WHEREFORE, Plaintiffs respectfully request this Ilonorable Courl, GrantPlaintiff s Motion to Vacate the Temporary Access Agrecment dated February 13th,2009, and moves this Court to:
a. Enioin the Defendsnt (sI, and the Bartlett PD from harassing Plaintiffs,Plaintiff's customers, from there ingress or egress, to aforernentioned classvi roadway, that parallels Plaintifft property on the "east side,"as recorded atbook 2121, page 708, Carroll County Registry of deeds, and identified asParcel 023L00, until a hearing on the merits, which has been scheduledalready by this Honorable Court for March 4,2015, at 9:00 am.
b. Order Defendants to unlock gate, this isand IY.H.RSA 23 L'21.Order gate unlocked,
in violation of lr{.H. RSA229:5pending hearing on the merits.
c. Order Defendants to remove the unsightly logs and Boulder/rocksplaced in roadway contrary to IY.H.RSA 476: I .
d. Order Defendants to remove whatFence"(wooden fence over 7'high inlength. lY.H. RSA 236:16
is known as the "Revengeplaces and approxirnately 200' in
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e. In the second Alternative: Order The 7'high fence located "across" entryto cabins (approximately 20 'feet wide) between the two very large twinpines as seen in exhibit 12 and attached hereto removed. also see(BruceBamum Report) Exhibit 1 in the Alfano Report submitted with the original,within complaint.
f. Order any other further relief that this Honorable Court deems iust and
fit.
Date: March 4th,2015Respectf ul ly submitted,Starbritc I-easing. Inc..
*?,iqfrPro Se
Bartlett, NH 03812
ecturlong I 95 [email protected]
603-3 87-90 1 4
VERIFICATION
I, Edward C. Furlong, III, individually and as President of Starbrite Leasing, Inc., dohereby declare that I have read the forgoing Motion and know of the contents thereof.With respect to the matters regarding Starbrite Leasing: the "T'entporary AccessAgreement or (TAA)," the class vi roadway, Planning Roard Member, Ex officio, D.Garland, and, the same is true to my knowledge except to those mattcrs that are alleged
81' and thnrogh it')1f'ounsel.and ivsFicsidrnti/- i. /.,, ,//V,'t
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on information and belief; as to those matters. I believe then-r to be true.I. Edward C. Furlong III. declare under the pains and penaltics of per.jr-rry that the
foregoing is true and correct and that this declaration was executed on this 4th. dav ofMarch, 2015. in North Conway, Carroll County, New Hampshire.
Irdward C. Furlong III, Individually and.as President of : Starbrite Leasins. Inc.
STATE OF NEW HAMPSHIRECARROLL, SS
Personally appeared betbre me, orl this day of March 4th.2015, Edward C.Furlong, III, individually and as President of Starbrite Leasing, Inc., and under oathaffirmed that the above was the truth to the best o1-my knowledge and belief.
Notary Public/.lustice o1' the Peace
My Clommission Expires:
