STATE OF NE,W HAMPSHIRE

CARROLL. SS SUPEzuOR COURT

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

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

V,

Town of Barllett, et al

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REPLY TO DEFENDANT'S MOTION TO OBJECT TO MOTION TO STAY 11" 2015 ORDER

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 Motion to Object to Motion to Stay May 11,2015 Order, and in support ofPlaintiffs Reply Motion Plaintiff's states the following herein,

Verified Statement of Facts

1. This corruption case is very intricate and complicated on it's face; but at it's

core is a percolating pestilence that Petitioner's are calling official corruption. The facts

(see Exhibit no. I attacheA remain undisputed so far by defendants because

defendant's counsel is spending more time on undermining Petitioner's Complaint by

hearsay and innuendo,..than actually offering any exculpatory evidence to refute

Petitioner's very serious allegations against his clients, Chandler and Garland.

2. Petitioner's have these two selectmen violating their oaths of office

conspicuously, conspiratorially, and sometimes blatantly so. Point Blank; Petitioner's are

again asserting for the record that these two Bartlett selectmen have dirty hands on

Petitioner's Procedural Due Process, first (stomping on U.S.C. 42 1983 and it's sub-

chapters), and second, committed acts outside their official capacities to injurePetitioners violating State RSA law. They had Petitioner Furlong alrested with a

convoluted probable cause. Petitioner should not have had to secure a TRO in the firstplace. Simply put, Petitioners would not risk filing a frivolous lawsuit, or spend thehuge amounts of money they have, hitherto; for the sake of some type of "hidden agendaor vendetta by Petitioners." This is not the case here. Of course Petitioner's are angry,who wouldn't be (and mental anguish has manifested itself to Petitioner Furlong) butPetitioner Furlong is solely motivated by material facts and"injuries sustained" "regarding these two rogue selectmen and their malicious acts. And the all conclusivecompelling evidence that Petitioner's are in possession of.

3. Petitioner's submit Exhibit no. I attached: "Constitutional" claims andprotections that has been litigated in State Court by other Plaintiff s in the same area ofconflict of law as it pertains to res judicata; Petitioner wishes to incorporate thelanguage, controlling authorities and citations in that exhibit I into this Motion toreflect Petitioner's unwavering stance on this matter of violation of procedural dueprocess; as it pertains to Bartlett selectmen Gene Chandler and former selectman DougGarland, and their wanton, conspiratorial violations against Petitioners fundamentalprocedural due process rights while perpetrating an intentional tort (s)-two). Thismotion, and all the motions entered into the record since this case's inception datedFebruary 2,2015. There needs to be a time, a day, when at some point that this tortiousbehavior by the two defendant selectman ceases to hurt Plaintiffs, and that can onlyhappen with money damages to Petitioners in an amount that will exceed the coverageavailable.

4. Exhibit no. la sttsched is a list of items that can be found in the huge appendixattached to the within case 212-201 5-cv-00010 and other (appendixes) exhibits attached

to this huge case that support every allegation Petitioners entered into the record byPetitioners; for selectman Doug Garland's disqualification or removal from OfficialOffice of Bartlett Selectman and selectman Chandler. Just looking at this ample list and

verifuing it's existence through the appendixes is huge and beyond compelling. Thisevidence must be brought to a jrrry.

5. This Honorable Court must address these serious constitutional issues. this can

not be ignored by oversight. There is no res judicata or estoppel. And Petitioners have

cited many case law to support a class vi roadway under existing RSA law. And infurtherance, to support disqualification at the very least of these two rogue Bartlettselectmen, to support claims of constitutional protections to procedural due process thatwere summarily denied. Petitioners have enough proof to put three of the five

Defendant's exceeding the 5l % culpable "defendant share" and thus meaningPetitioners "pray" to see these money damages to compensate Petitioners for theseprotracted injuries committed by the two Bartlett selectmen.

6. Exhibit no. 2 attached This list includes persons from the general public whowished to travel the class vi road, and were denied access through the Bartlettselectmen, Chandler and Garland, and now these people are irreparably harmed throughthis method; the Gateway Inn of 1896 (see exhibit no. 3 attached, "Latchstrings AlwaysOut" Eileen Carole). This is a Historical Lodging Property (see www.Abenaki-Inn.com); by having to find other resources to enter into a National Park (White MountainNational Forest) is preposterous, and tortious, and a violation under federal statute,violation under the ADA, violations under procedural due processed--denied these finefolks. They too are very angry over this municipal slight by these two rogue Bartlettselectmen.

7. Petitioners intend to file a motion before this Honorable Court's deadline forpre trial motions on or before July 3, 2015; to Consolidate case: 212-2015-cv-00032 tocase: 212-201 5-cv-00053.

8. Timothv G Morsles v. The Psrish of Jefferson 54 So. 3d 669 (2010) is an"exception to the res judicata preclusion is found in many case law when it is precededby violations of "eminent" Constitutional Protections:

9. Petitioner's have a case up in the Supreme Court regarding a separateintentional tort committed by these two rogue selectmen that selectman Gene Chandlerand former selectman Doug Garland, unequivocally, have their dirty hands on thisPetitioner. This is a serious case Your Honor. Petitioner needs this Court to allow thisPetitioner his day in Court on this official corruption in the Bartlett selectmen's office.Jurisdiction is proper here, in Superior Court and not the Supreme Court. This is realcorruption that's been meticulously documented by Petitioners.

10. Petitioner's realize that the State Court Judiciary does not see many cases thatrest on a U.S.C. 42 (1983) platform; this is one such case. Petitioners again will assertthat they are ready to "show proof'to these serious civil rights violations and Petitionerwill start this process, and will prevail in every aspect of this case by this conclusiveevidence.

11. Defendant counsel Mathew Cairns states that Petitioner's do not "cite any"controlling authorities, no citations, etcetera; This is again an attempt to capitalize on

the court's inability to control this type of defense. Defendant counsel Mathew Cairns

adopts the same defenses as Chris Hilson; rather insert some real defenses in their briefs

they constantly insinuating Petitioners of not having a case; this is simply troubling, and

diversionary tactic to confuse this Honorable Court.

12. Exhibit no 3 attsched. Front cover to "the book" (Latchstring is Always Out

by ) Petitioner's are highlighted as one of a handful of historical lodging properties here

in our the Mount Washington valley.

13. Exhibit no. 4 attached "1933 NHDOT" highway plan depicts a "drive to" ball

field or class vi road.

14. Exhibit no. 5 attached Deed and Plat dated October 29,1898 show's the

right of way through "southeast corner of the field." (Plaintiff's Request Hearing) on

This Document, this document can also be found in the Alfano "Expert Report" attached

as Exhibit 1a of the 357 page appendix to case 212-2015-cv-00010.

15. Exhibit no. 6 attached Assorted pictures to help this Honorable Court see

more clearly, the facts.

PRAYERS

WHEREFORE, Petitioner's pray that this Honorable Court Deny Defendant's

motion to objection to ccSft{" case no. 212-2015-cv-00010 until final hearing on the

last motion; request to Stay Order dated May 1 Lth,2015, 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. 212-2015-cv-

00010. Plaintiff's hereby request this Honorable Court Grant Plaintiff's relief sought

and

a. GRANT MOTION for class vi roadway based on the merits of pending

motions and materiol facts attached to case no: 212-201 5-cv-00010 and case no: 212-

2015-cv-00032 and case no:212-cv-2015-00053 Furlong v. Town of Bartlett, et al.

b. Grant all of Petitioner's pending motions in favor of Petitioners

STATE OF NEW HAMPSHIRECARROLL, SS

Personally appeared before me, on this day of June l0th, 2015, Edward C. Furlong, III,individually and, as President of Starbrite Leasing, Inc., and under oath affirmed that the above was thetruth to the best of my knowledge and belief.

Notary Public/Justice of the peace

My Commission Expires: