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CARROLL.
SUPEzuOR COURT
SS
Case
Town of Barllett, et al
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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,
1.
2.
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.
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
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.
9.
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.
12. Exhibit
13. Exhibit no. 4 attached "1933 NHDOT" highway plan depicts a "drive to" ball
field or class vi road.
15. Exhibit no. 6 attached Assorted pictures to help this Honorable Court see
more clearly, the facts.
PRAYERS
a.
b.