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STATE OF NE,W HAMPSHIRE

CARROLL.

SUPEzuOR COURT

SS

Case

No: 212-201 5-CV-0001

Starbrite Leasing,Inc., and Edward C. Furlong III


V,

Town of Barllett, et al
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REPLY TO DEFENDANT'S MOTION TO OBJECT TO MOTION TO STAY

11" 2015

ORDER

NOW COMES , Starbrite Leasing, Inc, and Edward Charles Furlong III, by and
through, as President, for Starbrite Leasing, Inc., and Pro Se Counsel for Petitioners,
(hereafter, Petitioners) and in his Pro Se capacity request this Honorable Court Deny
Defendant's Motion to Object to Motion to Stay May 11,2015 Order, and in support of
Plaintiffs Reply Motion Plaintiff's states the following herein,

Verified Statement of Facts


This corruption case is very intricate and complicated on it's face; but at it's
core is a percolating pestilence that Petitioner's are calling official corruption. The facts
(see Exhibit no. I attacheA remain undisputed so far by defendants because
defendant's counsel is spending more time on undermining Petitioner's Complaint by
hearsay and innuendo,..than actually offering any exculpatory evidence to refute
Petitioner's very serious allegations against his clients, Chandler and Garland.

1.

2.

Petitioner's have these two selectmen violating their oaths of office


conspicuously, conspiratorially, and sometimes blatantly so. Point Blank; Petitioner's are
again asserting for the record that these two Bartlett selectmen have dirty hands on
Petitioner's Procedural Due Process, first (stomping on U.S.C. 42 1983 and it's sub-

chapters), and second, committed acts outside their official capacities to injure
Petitioners violating State RSA law. They had Petitioner Furlong alrested with a
convoluted probable cause. Petitioner should not have had to secure a TRO in the first
place. Simply put, Petitioners would not risk filing a frivolous lawsuit, or spend the
huge amounts of money they have, hitherto; for the sake of some type of "hidden agenda
or vendetta by Petitioners." This is not the case here. Of course Petitioner's are angry,
who wouldn't be (and mental anguish has manifested itself to Petitioner Furlong) but
Petitioner Furlong is solely motivated by material facts and"injuries sustained" "
regarding these two rogue selectmen and their malicious acts. And the all conclusive
compelling evidence that Petitioner's are in possession of.

3. Petitioner's submit Exhibit no. I attached: "Constitutional" claims and


protections that has been litigated in State Court by other Plaintiff s in the same area of
conflict of law as it pertains to res judicata; Petitioner wishes to incorporate the
language, controlling authorities and citations in that exhibit I into this Motion to
reflect Petitioner's unwavering stance on this matter of violation of procedural due
process; as it pertains to Bartlett selectmen Gene Chandler and former selectman Doug
Garland, and their wanton, conspiratorial violations against Petitioners fundamental
procedural due process rights while perpetrating an intentional tort (s)-two). This
motion, and all the motions entered into the record since this case's inception dated
February 2,2015. There needs to be a time, a day, when at some point that this tortious
behavior by the two defendant selectman ceases to hurt Plaintiffs, and that can only
happen with money damages to Petitioners in an amount that will exceed the coverage
available.

4.

Exhibit no. la sttsched is a list of items that can be found in the huge appendix
attached to the within case 212-201 5-cv-00010 and other (appendixes) exhibits attached
to this huge case that support every allegation Petitioners entered into the record by
Petitioners; for selectman Doug Garland's disqualification or removal from Official
Office of Bartlett Selectman and selectman Chandler. Just looking at this ample list and
verifuing it's existence through the appendixes is huge and beyond compelling. This
evidence must be brought to a jrrry.

5.

This Honorable Court must address these serious constitutional issues. this can
not be ignored by oversight. There is no res judicata or estoppel. And Petitioners have
cited many case law to support a class vi roadway under existing RSA law. And in
furtherance, to support disqualification at the very least of these two rogue Bartlett
selectmen, to support claims of constitutional protections to procedural due process that
were summarily denied. Petitioners have enough proof to put three of the five

Defendant's exceeding the 5l % culpable "defendant share" and thus meaning


Petitioners "pray" to see these money damages to compensate Petitioners for these
protracted injuries committed by the two Bartlett selectmen.

Exhibit no. 2 attached This list includes persons from the general public who
wished to travel the class vi road, and were denied access through the Bartlett
6.

selectmen, Chandler and Garland, and now these people are irreparably harmed through
this method; the Gateway Inn of 1896 (see exhibit no. 3 attached, "Latchstrings Always
Out" Eileen Carole). This is a Historical Lodging Property (see www.Abenaki-Inn.com)
; by having to find other resources to enter into a National Park (White Mountain
National Forest) is preposterous, and tortious, and a violation under federal statute,
violation under the ADA, violations under procedural due processed--denied these fine
folks. They too are very angry over this municipal slight by these two rogue Bartlett
selectmen.

7.

Petitioners intend to file a motion before this Honorable Court's deadline for
pre trial motions on or before July 3, 2015; to Consolidate case: 212-2015-cv-00032 to
case: 212-201 5-cv-00053.

8. Timothv G Morsles v. The Psrish of Jefferson 54 So. 3d 669 (2010) is an


"exception to the res judicata preclusion is found in many case law when it is preceded
by violations of "eminent" Constitutional Protections:

9.

Petitioner's have a case up in the Supreme Court regarding a separate


intentional tort committed by these two rogue selectmen that selectman Gene Chandler
and former selectman Doug Garland, unequivocally, have their dirty hands on this
Petitioner. This is a serious case Your Honor. Petitioner needs this Court to allow this
Petitioner his day in Court on this official corruption in the Bartlett selectmen's office.
Jurisdiction is proper here, in Superior Court and not the Supreme Court. This is real
corruption that's been meticulously documented by Petitioners.

10.

Petitioner's realize that the State Court Judiciary does not see many cases that
rest on a U.S.C. 42 (1983) platform; this is one such case. Petitioners again will assert
that they are ready to "show proof'to these serious civil rights violations and Petitioner
will start this process, and will prevail in every aspect of this case by this conclusive
evidence.

11.

Defendant counsel Mathew Cairns states that Petitioner's do not "cite any"
controlling authorities, no citations, etcetera; This is again an attempt to capitalize on

the court's inability to control this type of defense. Defendant counsel Mathew Cairns
adopts the same defenses as Chris Hilson; rather insert some real defenses in their briefs
they constantly insinuating Petitioners of not having a case; this is simply troubling, and
diversionary tactic to confuse this Honorable Court.

no 3 attsched. Front cover to "the book" (Latchstring is Always Out


by ) Petitioner's are highlighted as one of a handful of historical lodging properties here
in our the Mount Washington valley.

12. Exhibit

13. Exhibit no. 4 attached "1933 NHDOT" highway plan depicts a "drive to" ball
field or class vi road.

14. Exhibit no. 5 attached Deed

and Plat dated October 29,1898 show's the


right of way through "southeast corner of the field." (Plaintiff's Request Hearing) on
This Document, this document can also be found in the Alfano "Expert Report" attached
as

Exhibit 1a of the 357 page appendix to case 212-2015-cv-00010.

15. Exhibit no. 6 attached Assorted pictures to help this Honorable Court see
more clearly, the facts.

PRAYERS

WHEREFORE, Petitioner's pray that this Honorable Court Deny Defendant's


ccSft{" case no. 212-2015-cv-00010 until final hearing on the
motion to objection to
last motion; request to Stay Order dated May 1 Lth,2015, pending ruling to the class vi
roadway and the ruling on Doug Garland's Disqualification or removal, based on the
Petition and 357 page appendix, attached to the former case with no. 212-2015-cv00010. Plaintiff's hereby request this Honorable Court Grant Plaintiff's relief sought
and

a.

GRANT MOTION for class vi roadway based on the merits of pending


motions and materiol facts attached to case no: 212-201 5-cv-00010 and case no: 2122015-cv-00032 and case no:212-cv-2015-00053 Furlong v. Town of Bartlett, et al.

b.

Grant all of Petitioner's pending motions in favor of Petitioners

STATE OF NEW HAMPSHIRE


CARROLL, SS
Personally appeared before me, on this day of June l0th, 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 of my knowledge and belief.

Notary Public/Justice of the peace


My Commission Expires:

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