THE STATE OF NE,W HAMPSHIRE

CARROLL COUNTY.
SUPERIOR COURT

SS

Februar)' 9. 2015

Case No:212-201 5-CV-0001 0

Edward C. Irurlong III

1455 rte 302 (Box 447)
Bartlett, NH 03812
Starbrite l,easing, Inc1455 Rte 302 (Box 447)
Bartlett, NH 03812
Petitioners

COMPLAINT
MOTION FOR LEAVE TO FILE FIRST AM-MPNDED
TO A CLASS VT
AND To ADD I\{cFT] EVIDENCE PERTAINI-NG
RO;D AND RbMOVAL OF SELECTMAN
NowCOMES,E,dwardC.FurlongIII,(PresidentofStarbrite Starbrite

Counsel for Petitioner'

Leasing, INC), in his PRO SE Capacity, ;nd

Leasing,Inc.,aNewHampshireCorporationingoodstandingand located
it's cotporate headquarters
established and residing (since 2003i at

at !455route 302,Bai.tt,

N.* Hampshire. Petitioner seeks Declaratory

of Mr. Douglas Garland'

Judgment in the Disqualification or Rlmoval
Officio to the Bartlett Planning
Bartlett Selectman's R.p.esentative, and E'x
now please'
Board. Retief from this Honorable Court
Statement of Facts

court
I keep finding more evidence for this Honorable
has hurt me really bad' This
to hasten it's de;sion p.or.rs. ThiJSelectman
in deposition and on video' and
Selectman is caught lying under oath twice
Act" to hurt Plaintiff'
were to cover up an "lntentional Tortious
1. I keep digging and

both lies
financial hurt is befallen on
financially. But we know as a society that when
un-!t and their physical health fails
someone they become psychologicaily
hetp from this court right now' I
and this is what happened to me.. I need

and rule on the Selectman' Mr'

am Moving this Court to see the evidence
because redress cannot get
Garland, within *.uronuble amount of time
here sooner.

to
the people get to deliver a corrupt Offlcial
(expletive 's') to the curb'
the lectern fbr u.r upology before we kick their

2. It's not everyday that "we"

is a Selectman meeting
3. Enclosed as exhibit No. 1, attached hereto,
(water precinct
minutes from June 1 7 ,2005, where Berl George
a town selectman meeting'"'
commissioner) is talking to Doug Garland at
think I might be running out
about shutting my ATV business down; they
the summer time on the forest
back where atu use is prohibited (illegal) in
where I took clients up the
trails; that's not the case h"re; f nad iusinets

',MountWashingtonAutoRoad''ontoursofthatMountain.
corroborates Plaintiff
4. Exhibit No. 2 (a flyer from Plaintiffs company

between George and

claim, not breaking the law like the conversation
to show the Honorable Court
Garland is suggesiing. The Plaintiff is trying
towards Plaintiff s businesses'
the mind-set of Oouf Garland back in 2005
5.

where I state: Garland is

Exhibit No. 3; Meeting minutes fiom 12-0l-06
Step Down'
with me and my businesses and he needs to

personally involved
won't impede the roadway'
Then Gene Chandler states the "snow fence"
then, Jon Tanquay' Selectman (
But
exist.
roadway
the
that
admits
Here,...he
pornography) is heard saying that he
who just received seven years for child
thought it was a "dead end road" '

5.YourHonor,youhaveenoughevidencetoremoveGarland.
to RSA statute to declare the
6. You have enough evidence pursuant
roadwaY.

I'm not right' This has hurt me,

7. Sir, Your Honor, I need this to stop now,
PsychologicallY!
this rogue
g. I,ve lost millions, my retirement, everything, because of
selectman.
now'
9. I need redress from this Honorable Court

But WHEREFORE

tfullv Petition this Honorable Court to Grant Plaintifl's

bv
Motion For LEAVE TO FILE FIRST AMMENDED COMPLAINI

Leasing, Inc.

March 1st,2015 and,

Disqualify in Perpetuity, or Disrniss and RE,MOVE

Board' Doug
Selectman/Representative, Ex Officio to the Barllett Planning
a. Permanently

in a quaisiGarland, Permanently, and enioin Mr. Garland from ever sitting

judicial, or non-quaisi-judicial setting in which Mr. Garland would be a

Mr' Garland
normal parlicipant as a Selectmen sitting a Meeting; where
Edward
MUST STEP DOWN regarding Petitioner or Petitioner's counsel,

c. Furlong III or any other matter that presents itself in the Barllett,
property or
Selectmen's office regarding the undersigned, Petitioner's
businesses. Additionally,

GRANT and Make Null and Void anvthins with

or
Mr. Garland's name and signature on itl that has hurt Petitioner'
tenor of
Petitioner's counsel, Edward c. Furlong III within the official
Selectman, Doug Garland's Official Office'

b.Grantanystatutoryfines(now,perRSA.,231.4gandStevensv.
to hire an
Town of Goshen , l4I X.rr. 219 (1996) that can allow Plaintiff
put on a better prosecution than I, as a Pro Se litigant
the1r

"tt"*.y
would.

*h"

"un

Revenge Fencing RSA 476:1, ordered taken down'

c.ordera.fRoontheroadpendinghearingonthemerits.
deems just and
d. Order any further relief that this Honorable Court
e.

fit'

time to this
Plaintiffs, profoundly, thank this Honorable Courl for it's

matter.
Edward C. Furlong and

Starbrite Leasing, Inc.

Petitioners

By it's Counscl:

Respectfully submitted,
Date: FebruarY 9,2015

Edward C. Furlong

lll,

Pro Se

PO Box 447

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

VERIFICATION
of Starbrite Leasing' Inc'' do
I, Edward C. Furlong, IlI, individually and as President
the contents thereof'
that I have read the forgoing Petition and know-of

hereby declare

with

more evidence to corroborate

respect to the matters regarding the submittal of
VI
(Selectman) Huge Conflict of Interest;the Class

Plaintiffs claims: Doug Garland's

Report, and the same is true to my

Roadway that is outlined in Paul Alfano's Expert
on information and beliefl as to those
knowledge except to those matters that are alleged
matters, I believe them to be true'

the foregoing is true and correct

I declare under the pains and penalties of periury that
Febrary' 2015' in North
this declaration was executed on this 9th, day of

and that

Conwav. Carroll County, New Hampshire'

Edward C. Furlong III.

as President: Starbrite Leasing, Inc.

STATE, OF NEW

CARROLL

HAMPSHIRE

SS

Personally appeared before me, on this day of January 28th, 2015, Edward C.
Furlong, III, individually and as Pre siclent of Starbrite Leasing, Inc', and under oath

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

Notary Public/.lustice of the Peacc

My Commission ExPires: