CARROLL COUNTY. SS

SUPERIOR COURT

THE STATE OF NE,W HAMPSHIRE

Februar)' 9. 2015

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

Edward C. Irurlong III1455 rte 302 (Box 447)

Bartlett, NH 03812

Starbrite l,easing, Inc-

1455 Rte 302 (Box 447)

Bartlett, NH 03812

Petitioners

MOTION FOR LEAVE TO FILE FIRST AM-MPNDED COMPLAINT

AND To ADD I\{cFT] EVIDENCE PERTAINI-NG TO A CLASS VT

RO;D AND RbMOVAL OF SELECTMAN

NowCOMES,E,dwardC.FurlongIII,(PresidentofStarbriteLeasing, INC), in his PRO SE Capacity, ;nd Counsel for Petitioner' Starbrite

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

at !455route 302,Bai.tt, N.* Hampshire. Petitioner seeks Declaratory

Judgment in the Disqualification or Rlmoval of Mr. Douglas Garland'

Bartlett Selectman's R.p.esentative, and E'x Officio to the Bartlett Planning

Board. Retief from this Honorable Court now please'

Statement of Facts

1. I keep digging and I keep finding more evidence for this Honorable court

to hasten it's de;sion p.or.rs. ThiJSelectman has hurt me really bad' This

Selectman is caught lying under oath twice in deposition and on video' and

both lies were to cover up an "lntentional Tortious Act" to hurt Plaintiff'

financially. But we know as a society that when financial hurt is befallen on

someone they become psychologicaily un-!t and their physical health fails

and this is what happened to me.. I need hetp from this court right now' I

am Moving this Court to see the evidence and rule on the Selectman' Mr'

Garland, within *.uronuble amount of time because redress cannot get

here sooner.

2. It's not everyday that "we" the people get to deliver a corrupt Offlcial to

the lectern fbr u.r upology before we kick their (expletive 's') to the curb'

3. Enclosed as exhibit No. 1, attached hereto, is a Selectman meeting

minutes from June 1 7 ,2005, where Berl George (water precinct

commissioner) is talking to Doug Garland at a town selectman meeting'"'

about shutting my ATV business down; they think I might be running out

back where atu use is prohibited (illegal) in the summer time on the forest

trails; that's not the case h"re; f nad iusinets where I took clients up the

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

claim, not breaking the law like the conversation between George and

Garland is suggesiing. The Plaintiff is trying to show the Honorable Court

the mind-set of Oouf Garland back in 2005 towards Plaintiff s businesses'

5. Exhibit No. 3; Meeting minutes fiom 12-0l-06 where I state: Garland is

personally involved with me and my businesses and he needs to Step Down'

Then Gene Chandler states the "snow fence" won't impede the roadway'

Here,...he admits that the roadway exist. But then, Jon Tanquay' Selectman (

who just received seven years for child pornography) is heard saying that he

thought it was a "dead end road" '

5.YourHonor,youhaveenoughevidencetoremoveGarland.

6. You have enough evidence pursuant to RSA statute to declare the

roadwaY.

7. Sir, Your Honor, I need this to stop now, I'm not right' This has hurt me,

PsychologicallY!

g. I,ve lost millions, my retirement, everything, because of this rogue

selectman.

9. I need redress from this Honorable Court now'

But WHEREFORE

Leasing, Inc. tfullv Petition this Honorable Court to Grant Plaintifl's

Motion For LEAVE TO FILE FIRST AMMENDED COMPLAINI bv

March 1st,2015 and,

a. Permanently Disqualify in Perpetuity, or Disrniss and RE,MOVE

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

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

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

normal parlicipant as a Selectmen sitting a Meeting; where Mr' Garland

MUST STEP DOWN regarding Petitioner or Petitioner's counsel, Edward

c. Furlong III or any other matter that presents itself in the Barllett,

Selectmen's office regarding the undersigned, Petitioner's property or

businesses. Additionally, GRANT and Make Null and Void anvthins with

Mr. Garland's name and signature on itl that has hurt Petitioner' or

Petitioner's counsel, Edward c. Furlong III within the official tenor of

Selectman, Doug Garland's Official Office'

b.Grantanystatutoryfines(now,perRSA.,231.4gandStevensv.Town of Goshen , l4I X.rr. 219 (1996) that can allow Plaintiff to hire an

"tt"*.y *h" the1r

"un put on a better prosecution than I, as a Pro Se litigant

would.Revenge Fencing RSA 476:1, ordered taken down'

c.ordera.fRoontheroadpendinghearingonthemerits.

d. Order any further relief that this Honorable Court deems just and fit'

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

matter.

Edward C. Furlong and

Date: FebruarY 9,2015

Starbrite Leasing, Inc.

Petitioners

By it's Counscl:

Respectfully submitted,

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

I, Edward C. Furlong, IlI, individually and as President of Starbrite Leasing' Inc'' do

hereby declare that I have read the forgoing Petition and know-of the contents thereof'

with respect to the matters regarding the submittal of more evidence to corroborate

Plaintiffs claims: Doug Garland's (Selectman) Huge Conflict of Interest;the Class VI

Roadway that is outlined in Paul Alfano's Expert Report, and the same is true to my

knowledge except to those matters that are alleged on information and beliefl as to those

matters, I believe them to be true'

I declare under the pains and penalties of periury that the foregoing is true and correct

and that this declaration was executed on this 9th, day of Febrary' 2015' in North

Conwav. Carroll County, New Hampshire'

Edward C. Furlong III.

as President: Starbrite Leasing, Inc.

STATE, OF NEW HAMPSHIRE

CARROLL 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: