Professional Documents
Culture Documents
CARROLI,.
SUPERIOR COURT
SS
lll
V.
th,oug@rStarbriteLeasing,Inc.,andProSeCounsel,forPetitionerS:,
enter a
(hereifter, Petitioners) and in his Pro Se capacity request this Honorable Court
regarding a
default judgment against Defendant Barllett Selectman, Gene Chandler,
DISeUAt-iptCATlON and rule on Petition to Disqualiff former Bartlett selectman,
Doug Garland, with case number 212-2015-cv-0001 0'
for
From the outset, Plaintiffs want to thank this Honorable Courl profusely,
Evidence'
taking the time out to "Read Plaintiff's many Briefs," and Volume's of
1. This is the second time selectman Gene Chandler has failed to show for a
Superior
hearing. Quite franky Petitioners believe selectman Chandler is avoiding
and no career
Court because there might be adverse media attention to his person,
politician,, such as Gene Chandler, would hurt his chances to get re-elected'
2.
3.
of Representatives, Concord).
4.
5.
justice.
Petitioner could end up in jail for a long time over this municipal corruption,
for criminal trespassing on a class vi road if Petitioners can not get relief here in this
Honorable Court, with this rogue selectman, Gene Chandler, who ordered the arrest
while Petitioner's were merely trying to enjoy their lives. This is some very serious
violations of petitioners basic, fundamental, common sense civil rights. 18 U.S.C. 241
snd 18 U.S.C. 242.
6.
see
Exhibit no 4 attached.
Even in 2008 former atty Randall Cooper new something was amiss. please see
Exhibit no. S attached. Even Cooper new they were corrupt but did nothing about it.
8.
g.
petitioner's prepared for the last 6 years for this day and Bartlett selectman
Chandler has not a leg to stand on; why wouldn't he want to exonerate himself today
petition" on
one must ask; he had almost 60 days from the first filing of the "original
April 7th,2015 to prepare his defenses. The agenda for today's House (of
Representatives) session is seen in Exhibit no. 2 and clearly there are no pressing
issues in this weeks representative session's agenda that would "outweigh" a hearing in
New Hampshire Superior Court to be disquailified or removed with aggravating-rortious incriminations against selectman Chandler. Is he (Chandler) calculating
perhaps, worried that Petitioners have the evidence, and his political career is over, this
would be a correct answer.
10. Defendant Chandler: It's not judicially acceptable to admit contempt of court by
acknowledging the June 3rd court date just 24 hours before said courl date is to happen
and ask for a continuance without proper motion or statutory time constraints; Chandler
"knew" 3 and a half weeks ago about this June 3rd hearing,...and the weekly
representative meeting was known by him, it's a regular occuffence.
1.
PRAYERS
defendant Bartlett selectman Gene Chandler and Stay of the Order dated May 1 l, 2075
to case no. 212-201 5-cv-00010; request to Stay Order 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. 212-201 5-cv00010. Plaintiff's hereby request this Honorable Court Grant Plaintiff's relief sought
and
a. GRANT MOTION FOR DEFAULT based on the merits of pending motions and
material facts attached to case no: 212-2015-cv-00010 and case no: 212-2015-cv00032 and case no 2l2-cv-2015-00053 Furlong v. Chandler.
b.
c.
d.
Order such other and further relief as this Court deems just and proper.
Respectfully submitted,
Dated: June 3rd. 2015
Certificate of Service
I herby certifu that a copy of the foregoing Motion has this 3rd day of June, 2015, been
forwarded first class mail, postage prepaid to Chris Hilson, counsel for the Defendant.
Edward C. Furlong
III,
Pro Se
VERIFICATION
as President
lll,
true to my knowledge except to those matters that are alleged on information and belief; as to those
matters, I believe them to be true.
I, Edward C. Furlong
Ill,
declare under the pains and penalties of perjury that the foregoing is
true and correct and that this declaration was executed on this 3rd, day of June, 2015, in North
Conway, Canoll County, New Hampshire.
individually and,
as president
of Starbrite Leasing, Inc., and under oath affirmed that the above was the
Peace
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the use of the indivdual or entity named abov lf ytu are nol the Intonded rscrpEnt b aware that any drsclGure copyrng distnbutron or us of the @ntmts rs prchibited lf yoe
r@rve thrs transmrsspn rn eror. pleas rctfy us by telephm
so that we n take approprtate sleps to prctect ofidentrality and/or atlomey{irent psvrleg of thrs
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The Intomatpn In this transmlssron contarns rnfomalron from the lil fim of DONAHUE TUCKER & CIANDELLA PLLC whrch is pflvrleged
fortheU5eol|i]elndiv|dUalorent|tynamedabovel'yearenotthelntendedreop|entbeewarethatanydlsclosUey|n9dlstr!bU|on
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Tue Jun
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Selectman ChandJef has a brgger obligation to the pople of Bartlett to fa6 thse charges of @rrptron by myself and the other Pebtioner Starbnte Leasing So there rs no way for
Chandle/s absse a
time Chandler has to be there tomorow B thers at I am'
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lawrd rd \rodf
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To Edward <duflong1gs8@gmarl @m>
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rh Intomaton
In this transmrssron
ontarns rrdomalon from the law frm ol DONAHUE TUCKER & CIANDELLA PLLC whrch
rs pflvrleged and
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rs
rntended to be used
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Selsdman Chandlerhas e brgger obtigatrof to the people ot Eart,ett to fae these charges of orruohon by mysetl and the olher Petrtjoner Slarbnte Leasrng So lhere s no way for
Chandlels absen a s$nd tim Chandler has to be there tomoffow B th.e at I am
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271 3661
61212015
5:58 PM
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Court Name:
Case Name:
n h.
us
Ll1'
]4an Snowmobil,
Rentals
Case Number
f
ii known
OF
Barrlet t ,
Nil
o'clock AM on 0Il13l2Ott9
L-jYouDoNoTHAVEToCoMEToCoURTbutmustanSWerthiscitationby-o,c|ockAM/PM
Follow the instructions on page 2 of this Summons.
County of
Carro I 1
Court
District
P0 Box
94C
NH
03BlB
rTown/City)
r,Zip)
(State)
THE UNDERSIGNED COMPLAINS THAT CONTRARY TO RSA 676 THE DEFENDANT: (Prease Prrnt)
furlong
Erl (d/b/a Li1' l{an Snowmobile Rentals)
(rrrst Name)
(Last Name)
PO
iMl)
C3812
i,Zip)
(CrtytTown)
(Address)
on
Bartlett, \.TI
rll0T lzoo1
10 /18
/2008
(narrative to include the circumstances of the violation and place the violation occurred)
renovationand.ConStructionworkcontinr:edonthecabi
X\rIf-R Adnr-i-nistration, Enforcement and PenalLies which
rpnrli rps A hrri I d-i ns nprmi t for internal or external modifications if it vil1 change the
ue.
r /08 / 2008
at 10:00 AM/PM
Afrei
rce, tne vtolat n was again witnessed
Zon-i-ng Ordinance
Article
Signature)
(TitleiAU
Maxrmurn $225 per citation for the first cffense and $550 per cltatror
for- subsequent offenses for eacb Cay tne violattor contlnues
Pur-suant to RSA 676 17
l
Personally appeared the above named complainant and made oath that the above citation by him/her
subscribed is, in his/her belief, true.
12lr2l2008
Date
Date
(
r-.
NHJB-2332-D
(47 t26t2041)
,)
E*/r, /, /
r,u?)
Court
Name.
Name:
n h.
us
Tonn of Bartlctt r. Edn'ard Furlong d/bia Li'l -\Ian Snoumobile Rentals. Trustce
Case Number, Defendant Randall Cooper. Esq.. & Trustee Defendant Cooper. Cargill & Clhant. P.-{.
Case
'xnow't
PP.CC;S
The Plaintiff petitions for permtssion to make the followrng attachments in the abovereferenced Civil Action.
Category of Property to be attached
(lf real estate provloe adoress o. DooK & oage referencer
Real Estate Other I Descriotion
Name of Defendant
Edu'ard Furlong
l-l
See
Edn'ard Furlong
SeeCbelou
Amount of attachment
i See .{ trelou
$ 362.000.00
B belol
362.000.00
s362.000.0t)
2 uury
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State
of iiei.r
l"f31P5fti1e
County of
06/1trl?.ql3
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1 4 //ro
Carroll
i 'y
/a 11.r
by
Gene
c. iha;r.tl:.
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case Name: Tonn of Bartlett r, Ednard Furlong d'b a l.i'l \lan Snonmobile Rentals.-l'rusree
case Number: Defendant Randall Cooper. Esq,.& Trustee
Detendant f'ooper. f'argill & C,hant. p.A..
, r-:
XAT^--AT-n-
L' -:DtFFlll-\-
THE PLAINTIFF INTENDS TO ATTACH YCUR PR]PERTY AS SET FCRTH IN TI-1= ABCVE
PE-i-I'I'ICN FCR PERN4ISSICN TO DO SO TC SECURE ANY JUDGMENT CR DECREE THE
PLAINT Ftr'MAY CBTAIN IN THIS ACTION YOU HAVE THE RIGHT TO OBJECT TC THE
ATTACHMENT AND TO HAVE A HEARING AS TO WHETHER IT SHCULD BE IMADE IF YOU DO
WISH TC OBJECT AND HAVE A HEARING YOU SHCULD trILE A \A/R]TTEN CBJECTION
DETAILING THE REASONS THEREFOR -l-CGETHER WITH A R=QUEST FCR A H=ARING Vr,rlTH
THE CLERKCF CCURT NOT LATER'iHAN 3O DAYS AFTER YOU I-1A\/= SEEN SER'/ED \^/ITH
THE PETITICN TC ATTACH
IF YCU FAIL TC CBJECT BY THAT DATE YCT, WILL BE DEEIr/ED TO HAVE \^iAIVED ANY
CBJECTICN
IF YOU TRANSFER
EVEN lF YCU DO NO-r OBJECT -l-O Tri= ATTACHI/ENT YOU SIOULD FILE AN APPEARANCE
AND ANSWER WITH THE CLERK CF COURT BY 30 DAYS AFTER YCU I-]AVE BEEN SERVED
UNLESS YOU ARE WILLING THAT THE PLAINTIFF HAVE JUDGMENT BY DEFAUI--|
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ORDER
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96 : rupn: Dr:;e
::r.lrbL.roasil. ),IE :.r0 rJ
N'laine Flealth C
anliolos\
DATE
DOB: 1/2/1958
1t21 t20'15
Srncerely
SarnrpC Vasarwata MD
SV11d 12.1 i2015
recrro,rrcarry S
g";-n
4C
*"
/1r'r,4, /ru?
JET
Plarntrffs
CASE
\O. L'lE-l-,i
NO\\'C'ON'lES l-rl l'vlan Snorirnobile.let Ski Rentals. Inc, and Eduarcl C. FLrrlong Iil
sr,rbrnits
tlie follou jng cer-trtlcatron re-earding llie eftbrrs tlrat hare been made
to gtre notice and the reasons tltat supponrng the clarrr thtrt noilce siroLrld not be required:
l.
On tirat sarne date. I \\fote a lctter to lite C'omrlissioner of the []artlett \\'atcr Precinct
ri hich included:
larn cerlainlr interested rn learntng uhat pr-ecipitared tlrrs lction on vour pan. for
if \\as rn reactron t0 thrnss ilv clicnt i.rr hrs cr:stollers rna\ ltare done. tiien rie
slrould address those rssues in a rnannel that does ncrt torliousir rnterfere uith hrs
tbr clarnaces Iarl also interested in
learnrng rf this roadriav and trarl to the lbrest is being closed to all traffic. or tust
to rrv client's traffic. It does not seerrr at all iogrcal to me. that land being held
for recreation use is berng restncted tiorn allouins the pLrblrc to access the )1.H.
snori rnobile trail svstem. u lrich rs a sisnitlcant u inte fiime recreational amenitr.
br-rsiness and erpose the Precinct to ltabrilrtr
'l-here
Rule
6-rt b ) C
ertifi catron
Page
of
-1
c.
Iu,gsid appreciate y'oll getlrng back tcr nre at vollr earl rest conrenience provrdine
nre r.iith an oppoftunitr to dtscuss sor-ne otirer altematires to address an\ lssue
volr rra\ irare. other tlran thr,s aclron Snou should be flving shorrl.,. and I need
to knou tf I rnust go to Court to protect rnv clients' interests.
i.
A copy c,f that letter uas sent to Terr-r Nliller. the Drstrict Ranser of the Saco River
Drstnct of tlre \\ihite \'1or-intain \ational Ft)reSt,
.{pproxirnatelr a ueek later Irecerr.ed a pirone call lrorr Robert Lpton. ll. Esq.. uho
tnfbnred nre he \\'as representrns the Barrlett \\
On or about
ater- Precrnct.
in
uhrch he erplained that he \\'as not pennltted to allori a priratc acce\s onto t1'rr'\\'\1\F.
uith the
6.
ln follo*'ine un on that drscussron. Imet on Decernber 9. l0()E on site riith Ranger Nliller
and tire C'hief of the N.H. Br"rreau of
-frails
providing parkrng lot and the like tbr the pubrlrc. drrectlr fi'rrrr m)'clrent's land onto the
di5cu5,sion.
solution (albeir not a -erren uith rlultrpie issLrcs to be explor-ed and resolred)uhrch could
take as rnuclt as a \eAr to L.,ring to tlLritron. it tL'rnpLrrzrr\ solultrrn \\ as prr)posed u hrch
required cooperation from the Bartlett \\'ater Precrnct
On that same date. thrs fact and proposal uas corlrnunicated to.Attornev Upton. whcr
8.
On December
C]t.'nt
i2. 2008. the Chief of the -\.H. Bureau of T:-ails cornrnunicated bv e-rnail
tirat tirere lvas on-going dlscussron and rerte,,i at DRED. ri'hich coLrld take a u'eek or
,fD
17
http://en.wikipedia.org/wiki/Gene G. Chandler
Gene G. Chandler
From Wikipedia. the liee encyclopedia
Gene G' Chandler (bom June 28, 1947) is a Republicm politician in the U.S. stare of New Hampshire.Ul Chandler, who is
from Bartlett, representing Canoll County Distnct I (Bartlett, Hart's Location and Jackson) in the New Hampshire House
of Representatives
(lhandler
Gene G.
Repr6ent!tiv6
from the I district
Contents
I
I
!
I
Incumbent
Nw
982
Personal L.ile
Incum bent
7 Extemal links
Assumed oflice
Assumed office
2012
Speaker PrGTempore ofthe New Hampshire
House of Repr6entativ6
In office
20t0 20t2
Chandler was Deputy Majority l,eader ofthe New Hampshire House ofRepresentatives fiom 1997 to 1998i Majority
Leader ofthe Nerv Hampshire House ofRepresentatives from 1998 to 2000; and Speaker ofthe House from 2000 to 2004
He served as House Speaker Pro-Tempore from 2010-2012 and was elected House Republican Leader follo*ing the 2012
Senior
ln office
election. I2l
2008 20r0
In addition to his House dulies, Chandler has served on the Bartlett Board of Selectmen since I 974 and has been chair
the Board for the last 19.
t:l
of
Hous of Repr6entstives
t+J IsJ
In office
2010 Election
?006 2008
On October 6, 20 I 0, the ( 'onwuv l)uil.y Sun reported that Chandler would run for Speaker again rf the Republicans retook
the House ofRepresentattves in the 2010 elections. Chandler said, ""First, I have to win reelection in my district and as you
knorv it's a crowded field. Secondly we rvould need to see the Republicans get back the majoriry in the House. Ifthat all
happens rhen I will run for Speaker" Republicans currently need fourteen seats to retake the House. Chandler easily rook
the number one GOP slol in the primaries earlier in the yer, and received more votes than any other candidate in his
district.[6] [{e won re-election and the Republican Party took control ofthe House on November
2,2010.
Trvo weeks iater, on November I 8, 20 | 0, Chandler was del'eated | 42- I 33 in his run for the Speakership. Chandler yielded
to Representative Wrlliam O'Brien, saying he would not ask House Democrats 10 support him.
Repr*entativs
In office
20ol
by
Succeded bv
Prceded
2004
Doma Sytek
Doucl* scmmtr,
O'Brien appointed Chandler Speaker Pro-'l'empore, which he sewed as durrng the 2011-2012 tem.
1998 2000
2012 Election
House of Repr6entstives
ln oflice
ln December 20 I 2, Chandler rvm m elected as the Minoritv leader in the House, defeating lbrmer Deputy House Speaker
Pam Tuclcr t R-Lireenlandt hv a \otc ol'gl-7q [7]
t996
1998
Pe.sonal details
Personal Life
Bon
Rep. Chandler attended Olivet College and New Hampshire College and is in the real estate, land and timber business. He
and his late wil'e, Nancy. rvere married for more than 30 years. He is the father oftwo grown sons and grandf'ather to four
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until2004,whenhechosenottoseekre-eiectionasSpeakeramidallegationsthathefailedtoreportapproximately
$64,000 he received in gifts over a six-year period. ln 2004, it came to light that Chandler fhiled to report money he received from the group "Friends ofGene Chandlcr
rvhich held an annual "Old-Fashioned Com Roast" for the preceding ten years.
Chandler argued that he had been misinlomed by the State Secretary of State's oflce, since the mony was raised by a "Friends committee." Under New Hampshire State
Larv. money raised by such an organization cannol be used for election purposes, but is instead used to cover other expenses. However, the money must still be reported.
Acknowledgrng he made a mistake, Chandler pled guilty to a single misdemeanor for violating RSA 640:5 Gifs to Public Servants (http://wwwgencourt.state.nh.us/rsa,/html
'rLXIV640/640-5.htm), for t'ailure to file financial information with the State. He was forced to pay the maximum fine of $2,000 and perfom 100 hours of communrty senrce
Chandler did not run for a third term as speaker and received a censure from the House for violating House Ethics Rules bu1 was allowed to keep his seat, although the Ethics
Committee recommended expulsion. Chandler was reelected amidst the Attomey General's investigation. He had the confidence of Speaker W. Douglas Scamman and serued
as Chaiman of the House Public Works and Highways Committee
On September 9, 2005, I he ( ttnwuy I)uily Sun ran an article announcing that the com roasts, now "Gene's Fall Family Fun Picnic", would continue as nomal on September
I l,2005, with lhe cost still $10 to attend, and Rep. Chandler asserted it was "200 percent legal." The event has continued since then.
In the 2007-2008 biennium, House Republican Leader Michael Whalley appointed Chandler as Republican Policy Leader, the number 3 person in the Republican Caucus.
Ilouse Republican Leader Sherman Packard appointed Chandler as Senior Assistant Republican Leader in the 2009-2010 legislative brennrum.
References
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