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STATE OF NEW HAMPSHIRTI

CARROLI, COLIN'TY.

SS

STJI'I]RIOR COUR'f
March 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' Man


Snowmobile Rentals, INC., (hereafter, Plaintiffs) in his PRo SE Capacity,
and Counsel for Plaintiff, Lil' Man Snowmobile Rentals in the above
captioned 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 the

office of Randal Cooper, (fbrmer attorney lbr plairrtifl).


2. Defendant's, selectmen, Doug Garland and Gene Chandler (fbr "-l'he'fown") signed
a dift-erent

a1

location with their attorney, Douglas Mansfield, Esq.

3. I'}laintiff's counsel, Randal Cooper, since the signing of thc TAA on 02-13-2009.had
been sued by this

Plaintiff for not providing

a duty of care that meets certain cthical

standards; and as provided in the New l{ampshire's Bar Prolessional Conduct and Ethics

Ruels. Randal Cooper, Esq., was fbund by a Strafford County "Jury. Verdict" to be guilty
o1-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 no

strangers to corruption; Mr. Tanquay.iust recently was removcd from his selectman chair
because 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 rax
evasion see Plainti-f-f's exhibit 2.
5. Gene Chandler and Garland. are the sclectman that originally had their hands in the

drafting 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. They
ordered the town's attorney to "pick up the fight" where Garland turned thc volume down
a few years ago when

Plaintiffs burden was reversed with police intimidation.

so

Plaintiffs, again, were le1lto back out, fighting. Plaintifls have been arrested twice since
the order dated February l3 th, 2015 was Ordered, as a standing order; but was denied by
Def-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. Plaintilfs
showed 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 own

infbrmation on "a history" of Plaintiffs behavior, to determine that "probable cause


existed 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 to
abide by the Court order from JD, (Temple, C), to ol'fer as more evidencc to this

Honorable Court that Doug Garland will not stop, at violating Superior Court Orders,

violating plaintiffs fundamental rights, because Garland uses the police to enforce noncompliance of the Superior Court Order fiom the t-lonorable.ludge Temple. (Garland's
private police fbrce); (Chief Champlin) lbund notes fiom out going (Chief T. Conify) in
his frle cabinet, that elicited a non-compliance "stance" fiorn Del'cndant's police force,

acting chief Janet Hadley Champlin.


7.

Plaintiff s are not going to expand anymore on the corruption of the temporary

access

agreement, selectman Doug Garland, the history of corruption that has plagued the

Bartlett Town Hall for years; ever since fbrmer police chief Bob Snow was indicted fbr
stealing money from the "Dare Program," and subsequently "pleading out" ancl receiving
2 years in the DOC.
8. I base the revisiting of the vacating of

of

o'new,

the "temporary

access agreemenl" on a plethora

"conclusive," hard evidence, (including but cerlainly not limited to Garland's

two 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 who

patronize 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,

Grant

Plaintiff s Motion to Vacate the Temporary Access Agrecment dated February 13th,
2009, and moves this Court to:

Enioin the Defendsnt (sI, and the Bartlett PD from harassing Plaintiffs,
Plaintiff's customers, from there ingress or egress, to aforernentioned class
vi roadway, that parallels Plaintifft property on the "east side,"as recorded at
book 2121, page 708, Carroll County Registry of deeds, and identified as
Parcel 023L00, until a hearing on the merits, which has been scheduled
already by this Honorable Court for March 4,2015, at 9:00 am.
a.

b. Order Defendants to unlock gate, this is in violation of lr{.H. RSA229:5


and IY.H.RSA 23 L'21.Order gate unlocked, pending hearing on the merits.
c. Order Defendants to remove the unsightly logs and Boulder/rocks
placed in roadway contrary to IY.H.RSA 476: I .
d. Order Defendants to remove what is known as the "Revenge
Fence"(wooden fence over 7'high in places and approxirnately 200' in
length. lY.H. RSA 236:16

e. In the second Alternative: Order The

7'high fence located "across" entry


to cabins (approximately 20 'feet wide) between the two very large twin
pines as seen in exhibit 12 and attached hereto removed. also see(Bruce
Bamum 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.

Respectf ul

Date: March 4th,2015

ly submitted,

Starbritc I-easing. Inc..


81' and thnrogh it')1f'ounsel.
and

ivsFicsidrnti/-

/.,, ,//V,'t

*?,iqfr
Pro Se

Bartlett, NH 03812
ecturlong I 95 8@gmail.com
603-3 87-90 1 4

VERIFICATION
I, Edward C. Furlong, III, individually and as President of Starbrite Leasing, Inc., do
hereby 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 Access
Agreement

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

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 of
March, 2015. in North Conway, Carroll County, New Hampshire.

Irdward C. Furlong III, Individually and.


as President of : Starbrite Leasins. Inc.

STATE OF NEW HAMPSHIRE

CARROLL,

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 oath

affirmed that the above was the truth to the best o1-my knowledge and belief.

Notary Public/.lustice

o1'

the Peace

My Clommission Expires: