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CARROLI, COLIN'TY.
SS
STJI'I]RIOR COUR'f
March 4, 2015
e1 al
ano
a1
3. I'}laintiff's counsel, Randal Cooper, since the signing of thc TAA on 02-13-2009.had
been sued by this
standards; and as provided in the New l{ampshire's Bar Prolessional Conduct and Ethics
Ruels. Randal Cooper, Esq., was fbund by a Strafford County "Jury. Verdict" to be guilty
o1-Breach of Fiduciary Duty or conf'lict of lnterest. see cxhihir r.
+.
Defendant's Doug Garland and Gene Chandler and Jon 'fanquay. all Selectmen. are no
strangers to corruption; Mr. Tanquay.iust recently was removcd from his selectman chair
because of his conviction
"Deposition", and Chandler was indicted, by the New Hampshire t,egislature House for
(campaign fraud), but later settled the case with the United States tRS fbr income rax
evasion see Plainti-f-f's exhibit 2.
5. Gene Chandler and Garland. are the sclectman that originally had their hands in the
drafting of the "temporary access agreement" or (T'AA). And they are back at it again.
They're not budging. they're back at trying to take away what belongs to Plaintiffs. They
ordered the town's attorney to "pick up the fight" where Garland turned thc volume down
a few years ago when
so
Plaintiffs, again, were le1lto back out, fighting. Plaintifls have been arrested twice since
the order dated February l3 th, 2015 was Ordered, as a standing order; but was denied by
Def-endants as a non-authentic order by the court. Plaintifl-s had to post a cash bond
of
$4,000.00 before being released from the Ossippee, Ilouse of Corrections. Plaintilfs
showed the "acting chiel'', .lanet Hadley Champlin. the Courl Order datcd February 13.
and she simply disregarded the Ilonorable Judge Templc's Orders, based on her own
Honorable Court that Doug Garland will not stop, at violating Superior Court Orders,
violating plaintiffs fundamental rights, because Garland uses the police to enforce noncompliance of the Superior Court Order fiom the t-lonorable.ludge Temple. (Garland's
private police fbrce); (Chief Champlin) lbund notes fiom out going (Chief T. Conify) in
his frle cabinet, that elicited a non-compliance "stance" fiorn Del'cndant's police force,
Plaintiff s are not going to expand anymore on the corruption of the temporary
access
agreement, selectman Doug Garland, the history of corruption that has plagued the
Bartlett Town Hall for years; ever since fbrmer police chief Bob Snow was indicted fbr
stealing money from the "Dare Program," and subsequently "pleading out" ancl receiving
2 years in the DOC.
8. I base the revisiting of the vacating of
of
o'new,
the "temporary
two lies to cover up the "intentional" tort against Plaintifl-s). implicating the Def-endant;
and the serious off'enses against the Plaintiffs. their businesses and the general pr-rblic who
patronize those businesses. This serious problem was perpetrated by Doug Garland.
Selectman/Representative Ex ofTicio to the Bartlett plannins Iloard.
Grant
Plaintiff s Motion to Vacate the Temporary Access Agrecment dated February 13th,
2009, and moves this Court to:
Enioin the Defendsnt (sI, and the Bartlett PD from harassing Plaintiffs,
Plaintiff's customers, from there ingress or egress, to aforernentioned class
vi roadway, that parallels Plaintifft property on the "east side,"as recorded at
book 2121, page 708, Carroll County Registry of deeds, and identified as
Parcel 023L00, until a hearing on the merits, which has been scheduled
already by this Honorable Court for March 4,2015, at 9:00 am.
a.
Respectf ul
ly submitted,
ivsFicsidrnti/-
/.,, ,//V,'t
*?,iqfr
Pro Se
Bartlett, NH 03812
ecturlong I 95 8@gmail.com
603-3 87-90 1 4
VERIFICATION
I, Edward C. Furlong, III, individually and as President of Starbrite Leasing, Inc., do
hereby declare that I have read the forgoing Motion and know of the contents thereof.
With respect to the matters regarding Starbrite Leasing: the "T'entporary Access
Agreement
or (TAA),"
Garland, and, the same is true to my knowledge except to those mattcrs that are alleged
CARROLL,
SS
Personally appeared betbre me, orl this day of March 4th.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 o1-my knowledge and belief.
Notary Public/.lustice
o1'
the Peace
My Clommission Expires: