Professional Documents
Culture Documents
CARROLL,
SUPERIOR COURT
SS
Case
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 Emergency Motion to Order Production of Documents, Order, and in
support of Plaintiffls OBJECTION; Plaintiff's states the following herein,
1.
2.
3.
On June 3rd,201 5 a status hearing was held to determine the specifics and
parameters of case no.212-2015-cv-00032,Edward C. Furlong et al v. Gene Chandler.
4.
On this day of June 3rd,2015 at this status hearing, Plaintiff's ask Chris
Hilson after the hearing was adjourned if it was he who sent attorney Chris Hawkins the
May 1lth Order Denying Petitioner's TRO and Petition no. 212-2015-cv-00010 to use
against Petitioners. Attorney Chris Hilson confirmed it was he who sent this to Chris
Hawkins. He then stated he didn't think there was any harm done "since it's public
record." Well it's not public record until the last motion that was entered by Petitioner
(motion to reconsider) is ruled on. Attorney Randall Cooper, is a defendant in one case
and co-defendant (beside Petitioner) in another case, complexing for this Honorable
Court,...Petitioner realizes, and Petitioner Furlong wants to thank this Honorable Court
for it's invaluable time to this matter.
5.
6.
For attorney Hilson to take the Superior Court Order dated May 1 |th,2015
that's unequivocally, adverse to Petitioners, and hand delivering it to an attorney (Chris
Hawkins) on no less a silver platter, who is a co-defendant along side Petitioners in one
case involving an attachment on Petitioner's cabin rental business, and defendant's sit
opposite to Plaintiff's in the malpractice case. Hawkins will no doubt use that Superior
Court Order as seen in Exhibit no 1a attached against Petitioners in there appellate brief.
This is yet a third tort against Petitioners from the Bartlett selectmen, vicariously
through their attorney. Suffice it to say not as what tort is the most caustic. This act has
the potential to seriously cripple Petitioners financially. Petitioners stand to lose I .6
million dollars if when the Supreme Court Justices review/rule that that Court Order
from Hilson to Hawkins might very well be the straw that broke the camels back. This
has seriously injured Petitioners chances at the Supreme Court referencing the Rule l1
Petitioners have docketed. Chris Hawkins and Plaintiff Furlong are curently battling for
a elevated position with this case,..to it's finish; but now Defendant's counsel Chris
Hilson is working tangent (helping) with this other attorney's case to hurt Petitioner,
this is some serious ethic violations here. This is wrong as a matter of professional
conduct flying the coop.
7.
8.
9.
10.
'
Petitioner's just uncovered this huge smoking gun (selectmen meeting minutes); Petitioners will be requesting this Court to
toss the TAA, Crant the Roadway, Remove the unsightly Fence; RECONSIDER this Courts ruling dated May I lth, 2015,
quashing movant's Petition for "lnjunctive and Declaratory Relief and Damages,"....now, this Honorable Court can base this
reconsideration on all the incomingmaterial facts and exhibits to case number 212-2015-cv-000t0. There is no res judicata
here but a heap of constitutional violations taking over the stage, with acts committed intentionally to commit murder by tort.
Order Statutory Damages to Petitioners.
the New Hampshire Supreme Court, to an attorney who Petitioners are still litigating
against by fault of the Bartlett selectmen. This has gone too far. This needs to stop.
Petitioner's have stated to this Court several times about half-truths by attorney Hilson
and ask that he be sanctioned earlier. Now is the time. Your Honorable Court.
l.
12.
13.
Selectmen Defendant's counsel Chris Hilson is "playing the court " right here,
again, by purposely filing this frivolous motion, because clearly discovery has been
tendered to the defendants by the Plaintiffs. please see Exhibit no. 6 attsched.ly'rr.
Hilson is clearly just trying to do what most smart lawyers do, think ahead and align
arguments now for grounds for an appeal. This is waisting Plaintiff's time and money,
and the courts invaluable time. This is just another reason why attorney Hilson needs to
be brought to bear for this unethical behavior.
14. Petitioner's are very busy putting on an offense, but told Mr. Hilson he could
bring his own copy machine (because of the voluminous pleadings) and come to
Attorney Hilson is spending most all of his client's billable hours degrading and
trying to demoralize Petitioners through innuendo and direct insult to Petitioner's legal
expertise, or lack thereof. But he has not offered any rebuttal evidence to the serious
allegations introduced by Petitioners. please see Exhibit no. 5 attsched: Conway Daily
Sun article where attorney Hilson states: " I need to build a case for him and defend
15.
at.',
PRAYERS
a.
rule 7.1 and 4.1 of the New Hampshire Rules of Professional Conduct, and other
.....rules as scribed in the American BarAssociation Professional Rules of Conduct.
b.
c.
Order such other and further relief as this Court deems just and proper.
Respectful ly submitted,
Certificate of Service
I herby certifu that a copy of the foregoing Motion has this 16th day of .Iune, 2015, been
forwarded first class mail, postage prepaid to Chris Hilson, Matt Cairns, Bill Scott and Peter Malia,
counsel for the Defendants.
Edward C. Furlong
III, Pro Se
VERIFICATION
I, Edward C. Furlong, III, individually, and as President for Starbrite Leasing, Inc., do hereby
declare that I have read the forgoing "Objection to to Order Production of Document of Exhibits" and
know of the contents thereof. With respect to the matters regarding Plaintifl-s, Edward C. Furlong III,
Starbrite Leasing, the same is true to my knowledge except to those matters that are alleged on
I, Edward C. Furlong III, declare under the pains and penalties of perjury that the foregoing is
true and correct and that this declaration was executed on this l6th, 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
truth to the best of my knowledse and belief.