STATE OF NEW HAMPSHIRE

CARROLL, SS SUPERIOR COURT

Case No: 212-201 5-CV-00032

Starbrite Leasing, Inc., and Edward C. Furlong III

V.

Gene Chandler. Selectman

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OBJECTION TO DEFENDANT'S EMERGENCY MOTION TO ORDER PRODUCTION OFEXHIBITS AND PLAINTIFF''S MOTION TO SANCTION ATTORNEY CHRIS HILSON

NOW COMES , Starbrite Leasing, Inc, and Edward Charles Furlong III, by andthrough, as President, for Starbrite Leasing, Inc., and Pro Se Counsel for Petitioners,(hereafter, Petitioners) and in his Pro Se capacity request this Honorable Court DenyDefendant's Emergency Motion to Order Production of Documents, Order, and insupport of Plaintiffls OBJECTION; Plaintiff's states the following herein,

Verified Statement of Facts

1. On or about May 3Oth,2015 I received a motion from attorney ChrisHawkins who is representing Plaintiff's former attorney Randall Cooper regarding an

ongoing litigation (Legal Malpractice) and separate Supreme Court case no. 2014-0113.See Exhibit no.1 attached: "Motion to Clarify Plaintiff's Supreme Court filings."

2. Exhibit no. 1a sttached Carroll County Superior Court's Order, is an orderissued out of this Honorable Court dated Mav 1 Lth.2015. this Court Order dissolvinsPetitioner's TRO.

3. On June 3rd,201 5 a status hearing was held to determine the specifics andparameters 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 ChrisHilson after the hearing was adjourned if it was he who sent attorney Chris Hawkins theMay 1lth Order Denying Petitioner's TRO and Petition no. 212-2015-cv-00010 to useagainst Petitioners. Attorney Chris Hilson confirmed it was he who sent this to ChrisHawkins. He then stated he didn't think there was any harm done "since it's publicrecord." 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 caseand co-defendant (beside Petitioner) in another case, complexing for this HonorableCourt,...Petitioner realizes, and Petitioner Furlong wants to thank this Honorable Courtfor it's invaluable time to this matter.

5. Petitioner's are still litigating against Plaintiffs former attorney, RandallCoopeq for his malpractice; against his attorney, Chris Hawkins, of Nelson Kinder +Mosseau, PA. This lawyer, Hawkins, has been conversing and exchanging verysensitive/private documents with Chris Hilson. Chris Hawkin's client Randal Cooper, isa Trustee Defendant in this case here in this Honorable Court, case no. 212-2013-cv-097;but it's Chris Hilson, the defendant's (Bartlett Selectmen) attorney in this case thathas been soliciting Chris Hawkins , not Chris Hawkins soliciting Chris Hilson; this trialCourt's Order dated May I 1,2015 denying Petitioner's TRO, now in the hands of thisattorney Chris Hawkins, now turns the tables adversely for Petitioners because hegained a legal document that in it's very essence is adverse to Petitioners. Thisprofessional misconduct could potential torpedo Petitioner's case in the Supreme Courtin favor of Randall Cooper, under their rule 1 1, Petition For Original Jurisdiction thatPetitioners have docketed there.

6. For attorney Hilson to take the Superior Court Order dated May 1 |th,2015that's unequivocally, adverse to Petitioners, and hand delivering it to an attorney (ChrisHawkins) on no less a silver platter, who is a co-defendant along side Petitioners in onecase involving an attachment on Petitioner's cabin rental business, and defendant's sitopposite to Plaintiff's in the malpractice case. Hawkins will no doubt use that SuperiorCourt 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, vicariouslythrough their attorney. Suffice it to say not as what tort is the most caustic. This act hasthe potential to seriously cripple Petitioners financially. Petitioners stand to lose I .6million dollars if when the Supreme Court Justices review/rule that that Court Orderfrom Hilson to Hawkins might very well be the straw that broke the camels back. Thishas seriously injured Petitioners chances at the Supreme Court referencing the Rule l1Petitioners have docketed. Chris Hawkins and Plaintiff Furlong are curently battling fora 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 professionalconduct flying the coop.

7. This is a direct violation of the rules governing professional conduct pursuantto rule r.7 and 4.1; see conflicts in litigation Exhibit no. 2, pase 6 paragraph 24.

8. This is just another occurrence of total disregard by attorney Hilson to theprofessional ethics that guides attorney's towards the correct judicial path. Seems likeattorney Hilson gets enjoyment with his flirtations with a contempt of court sanction,and always getting away with it, because he retards the deception with a professionalclean-cut appearance. That does not cut it with this Petitioner. Petitioners are asking thisHonorable Court to see the seriousness of this last episode of deceit here in thisHonorable Court and sanction attorney Hilson with an appropriate fine. Petitioner's planon filing ethic charges against attorney Hilson at their earliest opportunity, for whatevergood that it will do, is highly debatable.

9. Plaintiffs are litigating a major case up in New Hampshire Supreme Courtagainst their former attorney, Randall Cooper and Cooper Cargill and Chant, PA.; andPlaintiff's have a huge financial interest in that case's outcome, of course. The Orderdated May I lth,2015 is technically still an open case with several motions entered forthis Honorable Court's review (Motion for Reconsideration, and others). Petitioners areplanning to file a Supplement to the Motion to Reconsider the Courts ruling on Mayllth,2015. Petitioner would like to submit THEE SMOKING GLrN of all smokingguns; enter Exhibit no. 7 attached: selectmen meeting minutes where selectman GeneChandler steps down when a comment about snowmobiling: that [chandler] he "can'tbelieve that this snowmobile business is going to lower the values in the area..."2

a. Please see exhibit no. 3 attsched

10. According to the NH Bar Rules of Professional Ethics attorney Chris Hilsonwas prohibited from divulging this Court Order to a defendant attorney; that severeinformation in the Court Order, dated May 1 I, 2015 now prejudices petitioners case in

' Petitioner's just uncovered this huge smoking gun (selectmen meeting minutes); Petitioners will be requesting this Court totoss 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 thisreconsideration on all the incomingmaterial facts and exhibits to case number 212-2015-cv-000t0. There is no res judicatahere 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 litigatingagainst 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 Hilsonand ask that he be sanctioned earlier. Now is the time. Your Honorable Court.

I l. By attorney Hilson faxing, emailing or sendin gthat Superior Court Order toattorney Chris Hawkins, to fortiSr his defenses in his appellate case, attorney ChrisHilson, defendant's attorney, instantly injured Petitioners. That is a huge defensemechanism for Hawkins to show the Supreme Court, the Order Denying Plaintiff s TRObecause the whole case against Cooper is whether or not he should of filed andemergency TRO for his then client, Edward Furlong: that is the " case within the case."But for Cooper's negligence. Plaintiffs are hoping this Honorable Court is seeing thehuge adverse implications of this violation of professional misconduct by attorney ChrisHilson.

12. Attorney Cooper, represented by Chris Hawkins, are "Trusty Defendants" inthe "Cabin Case" that Plaintiffls are also litigating in the Supreme court under case no.2014-0063. Please see Exhibit no. 4 attsched : Standards for imposing Law:lerSanctions.

answer to motion

13. Selectmen Defendant's counsel Chris Hilson is "playing the court " right here,again, by purposely filing this frivolous motion, because clearly discovery has beentendered 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 alignarguments 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 tobe brought to bear for this unethical behavior.

14. Petitioner's are very busy putting on an offense, but told Mr. Hilson he couldbring his own copy machine (because of the voluminous pleadings) and come toPetitioner's office in Bartlett and he could copy all the files.

15. Attorney Hilson is spending most all of his client's billable hours degrading andtrying to demoralize Petitioners through innuendo and direct insult to Petitioner's legalexpertise, or lack thereof. But he has not offered any rebuttal evidence to the seriousallegations introduced by Petitioners. please see Exhibit no. 5 attsched: Conway DailySun article where attorney Hilson states: " I need to build a case for him and defend

against him because I can't forthrightly understand what he's getting at.',

PRAYERS

WHERBFORE, Petitioner's pray that this Honorable Court Deny Defendant'smotion to order production of exhibits and to "STAY" case no. 212-201 5-cv-0001 0 untilfinal hearing on the last motion; request to Stay Order dated May l lth, 2015, pendingruling to the class vi roadway and the ruling on Doug Garland's Disqualification orremoval and

a. GRANT Plaintiff s Motion to sanction attorne), Chris Hilson for violatingrule 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. Deny Defendant's motion to compel production of documents.

c. Order such other and further relief as this Court deems just and proper.

Respectful ly submitted,Dated: June 1 6th,2015

Edward C. Furlong III, Pro Se

by and through, as Counsel,and as it's President for: StarbriteLeasing, Inc.,PO Box 447 BartleIt" NH 03812

Certificate of Service

I herby certifu that a copy of the foregoing Motion has this 16th day of .Iune, 2015, beenforwarded 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

information and belief; as to those matters, I believe them to be true.

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.

Edward C. Furlong III, Pro Se

STATE OF NEW HAMPSHIRECARROLL, SS

Personally appeared before me, on this day of June 16th,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 of my knowledse and belief.

Notary Public/Justice of the Peace

My Commission Expires: