TFIE STATE OF NEW HAMPSHIRE

CARROLL COT'NTY. SS SUPERIOR COLJRT

May 51h.2015

Case No: 2 I 2-20 I 5-CV-00032

Edward C. Furlong III, Pro Se1455 rte 302 (Box 447)Bartlett, NH 03812

Starbrite Leasing, Inc.1455 Rte 302 (Box 447)Bartlett. NH 03812

PETITIONERS

PETITION FOR DISOUALIFICATION OR REMOVAL OF OFFICIAL OFFICE OFBARTLETT SELECTMAN & CHAIRMAN.GENE CHANDLER

Now coMES, Petitioner, Edward c. Furlong III, Individually and(President of Starbrite Leasing, INC), in his PRO SE Capacity, and Counsel forCo-Petitioner, Starbrite Leasing, Inc., a New Hampshire Corporation, and ingood standing, and established, and residing (since 2003), at it's corporateheadquarters located at 1455 route 302,Bartlett, New Hampshire. Petitionerseeks Declaratory Judgment in the Disqualification or Removal of, GeneChandler, Bartlett Selectman/Chair. Retieffrom this Honoruble Court nowplease.

INTRODUCTION

This is an action to Disqualif.v Selectman. Gene Chandler. pursuant to RSA.The COLINTS and allegations by Petitioner within this Petition are criminaland are being investigated by, James Yara,Assistant Attomey General of theNew Hampshire Attorney General's Office. Petition submitted to thisHonorable Court is to enlighten or to apprise and offer evidence to support this

disqualification or removal, only; and facilitate this Honorable Court toascertain the truth regarding Selectman Chandler's malfeasance and to rule on a"Disqualification" retro to 2008, and "going forward," in perpetuity; and, tomake invalid all documents that Selectman Gene Chandler has signed, with hisname "Selectman Gene Chandler" on the document's face, and in SelectmanChandler's Official Capacity as Selectman, that had a negative or adverseimpact on Petitioner and to Disqualify Selectman, Chandler,...for hismalfeasance associated with the case no., 212-201 5-CV-000 1 0. SelectmanChandler made ajudicial decision regarding Petitioner's (access) propertyrights and therefore RSA laws governing a disqualification of a public officialto the "Jrrry Standard," by a local municipality, applies here.

a. "..Justice Souter said that the rule of legislative functions is that a conflict invalidates a vote

improperly cast determined the outcome, ie., if it's the deciding vote." Dictum Chenev, 130 N.H. 589,

594 (19881.

b. "...The Court has said that a municipality body is acting judicially when it decides matters that

affectstherightsofaspecificpetitionerwithrespecttoaspecificparcel of land." Ehrenherev.Citvof Concord, 120 N.H. 656 (19801.

c. "... If (the municipality official) are bound to notify, and to hear the parties, and can only

decide after weighing and considering such evidence and auguments as the parties choose to lay

before them, thier action is judicial." llinslow v. Holderness Plannine Board, 125 N.H. 262 (19841.

d. RSA 673:14 and RSA 43:6 both require officials to be as impartial as a juror. This'Jurystandard" was also cited in the lVinslow case (supra) even hefbre 614: I4 applied to planning

boards.

PARTIES

1. Starbrite Leasing, Inc., is a New Hampshire corporation, incorporated on

January 2,2003, with a place of business at 1455 Route 302,Bartlett, N.H. and

a mailing address of P.O. Box 447 Bartlett, N.H. 03812 (hereinafter referred to

as "SBL" or "Petitioners").

2. Edward C. Furlong III resides at 1455 Route 302, Bartlett, N.H., and has

a mailing address of P.O. Box 447, Bartlett N.H. 03812 (hereinafter referred to

as Petitioner Furlong or "Petitioners").

3. Bartlett Selectman Gene Chandler, Individually and selectman for the

Town of Bartlett, NH, (hereinafter referred to as "Selectman Chandler."), a

municipality, with an address of 56 Town Hall Road, Baftlett, N.H. 03845 and,

selectman Chandler can be served processing at that address.

AFFIDAVIT OF FACTS BY: EDWARD C. F{.JRLONG III

1. As a citizen of Bartlett, New Hampshire, and Petitioner, in the abovecaptioned case, and Counsel for Co-Petitioner, Starbrite Leasing, Inc., bothmove this Honorable Court on this day to Disqualify or Remove from Office,Mr. Gene Chandler, Selectman/Chairman and Representative to the House ofRepresentatives, State of New Hampshire.

2. Petitioners have irrefutable proof that Gene Chandler is a liar.Petitioners have attached a 357 page Appendix to corroborate the Petitioners

Complaint; the evidence against, Representative Gene Chandler, is beyondcompelling, that this Honorable Court will Grant Petitioner's deepest wishes:

To Remove Selectman Chandler from Official Office.

3. Mr. Chandler has abetted a lie that facilitated an "Intentional Tort,"perpetrated by associate Selectman, Doug Garland. This Intention Tort, and the

current litigation, is still ripe, and before the Trial Court at Carroll County,

Superior Court, New Hampshire. A petition to remove Doug Garland is before

this Honorable Court and attached to case no. 212-2015-CV-00010 .

Update: Selectman, Doug Garland, was removed from his selectman chair by

town vote, March, 11,2015. see Exhibit no 2c (Conway Daily Sun article).

4. Exhibit no.l is a (video #1) that shows Gene Chandler's tacitconcuffence to Selectman Garland's lie, Garland stating: "that [he] did not

throw boulders down" to Blockade Plaintiffs Businesses, and that he, "doesn't

know who did." Exhibit no. 2 Selectman, Garland's D@20l2,taken by Petitioners, where he "emphatically" states: "that [he] ordered,

or placed the Rocks or Boulders to Block Plaintiff's Property." Contrary to the

video. Exhibit no. 1d: Selectman Meetins Minutes dated. 10-23-2009 & 08-

29-09, show, Selectman Chandler, was cognizant about the Boulders, where he

comments, " [he] doesn't believe they will ever look good..." See Exhibit no.

11 , assorted pictures of the Boulders and Logs, before and after, being placed

to blockade Petitioner's then, two flourishing business' ingress/egress,

(Starbrite Leasing, Inc) d.b.a., (Abenaki Inn and Cabin Rentals). Website:

www.abenaki-inn.com & (Lil' Man Snowmobile Rentals, Inc.) Website:

www.lilmsnsnowmobilerentals.com . Then,..to corroborate this egregious liefurther, ond abetted by Selectmen, Chandler Petitioner submit, Exhibit no. 2fDepositionr of Travis Chick (Bartlett, Supervisor "Road Agent") where, Mr.

Chick, deposes and states: [he] "got his orders" to place the boulders

blockading Petitioner's business access, from the east side of Petitioner'sproperty along the class vi roadway, "from the Selectmen." Mr. Chick was

extremely evasive under questioning as the reading of the deposition suggest.

5. Because these lies are deep rooted, and the case intricate, and

there are Several "Players" involving "Official Oppression," with an

enhancement to conspiracy, to prove beyond any doubt, is perplex; the problem

of Petitioner to eradicate the truth that's buried somewhere under (Chandler's

Stonewall) is next to impossible. No "Discovery" opportunity, for the truth, via

Chandler, Garland, Annette Libby or Stephen Libby can be had. Their careers

might be at stake,...Petitioner is guessing. No one is talking. Petitioner has

relied on the "right to know law" to get this far. Representative Chandler is

trying to keep the culpability of the selectmen's tortious action, on his

subordinates, Annette and Stephen Libby. And this is not right. Chandler is,

"Let them take the blame". stance.

6. Blockading a business competitor to help his friend Doug out, is

reprehensible and morally indefensible. Both selectman Garland's businesses

compete directly and adversely with Petitioners'businesses. Selectman Doug

Garland and Gene Chandler have a documented dislike for snowmobiles. That

fact has been memorialized through news print and selectmen meeting minutes;

they have a bad attitude toward snowmobile rental companies, or snowmobiles

in general. When the heat was turned on by Selectmen Chandler, to blockade

Petitioner from life's pleasures, and conducting his business without municipal

interferenco,...

7. Selectman Chandler knew, or should have known, that Lil'ManSnowmobile Rental was significant, in that people would travel from Europe

and Asia to patronize the conceffI. Lil' Man was the Highlight of their

' This petitioner would like to apprise this Honorable Court that on the day of Travis Chick taking of his

deposition, by the Petitioner, Mi. Chick denied that the selectmen ordered him to do so up until the last page of

the tating ofihe deposition. That period was approximately 40 minutes. also see Exhibit no. 6 where Chandler,

fnterrogaiories:p.6 q. 12,14,15. Chandler avoids the question on the rocks; states it was not the town backhoe'

vacations: snowmobiling the white mountains, bringing their little ones to "Lil'Man Snowmobile." This allowed the owner a 6 figure "upper end" income, and

comfortable lifestyle, with a second home in Florida, and a fancy water frontrestaurant in Cocoa Beach, called Captain Ed's Tiki Bar & Grill. Then

Selectman Garland, in the fall of 2008, when the Boulders were placed to

Block Petitioner's ingress, Chandler & Garland were intent, to financiallyinjure Petitioners'businesses from prospering; these two Bartlett selectmen

stepped outside the protection of "discretionary function immunity" "NewActs" of Oppression and Deprivation have occurred since then; j ust up to onlya few months ago, when Selectman Chandler had Petitioner Furlong arrested

for criminal trespassing on what is the class vi roadway. This roadway is

attached" to Petitioner's property, next to Petitioner's two businesses, next to

the "Field," to it's east boundury. But for this one atrocious act against

Petitioners'businesses, the proximate cause to Petitioners' injuries are

substantiated here, against SelectmanlChair Gene Chandler, within this /ie ofDoug Garland, and aided, and abetted by associate selectman Chandler. Please

enter as Exhibit no. I (Wdeo showing Gsrland's lie supported by deposition)

this was an instant and, "Intentional Tort," perpetrated by the two Selectmen,

and they are liable, and the town; but moreover. their violations to Petitioner's

DueProcessProtections, guaranteedby our Constitution, were not qfforded to

Plaintiffs. But these acti the two Selectmen oxicallv enough. are

mor e perv erted tn refer encing Ihe D e-fendant's own v io I at ion s t o t he ir.respective. Oaths of Office. This must be remedied by this, Honorable Court.

8. When a corrupt offlrcial steps out of his shoes, and steps into the

shoes, that of another, to commit a criminal act, or even an act contrary to their

official ethics, we have some serious issues. Official Oppression, contrary to

the fourteenth amendment to our Constitution, is life's blood. This is what's

happened to Petitioners: no due process protection, loss of life's blood. This is

where I seek redress,...here, in the New Hampshire State Courts. I have not

gotten due process protections from Selectman Gene Chandler, at Town Hall.

There are no armed security guards out on the streets of America, to protect it's

businesses, like a policeman protecting it's citizens. The irony here is, that's

exactly what happened to Petitioner; the police got involved by order of the

Selectmen,( to falsely arrest, enhanced) with Petitioners'businesses, by

arresting him. They arrested him less than 30 feet from his office door,

defaming him, in front of his patrons and staff; that damaged his character and

reputation, and simultaneously, elevating Defendant Chandler and Garland's

own reputation and character. This is horrendous. And this begs the question:

by what authority did defendant's rely on to find probable cause to arrestPetitioner. What type of malice are we talking about here, that Defendants go

to such length to impede Lil'Man Snowmobile Rentals from prospering. The

Selectmen reverse the burden of proof regarding the traveling on a public way,

contrary to Blagbrough Familv Trust v. A & T Forest Products, Inc 155 N.H.

29,917 A.2d 1221 (20071; at the Federal level, this invokes, yet again, the

constitution protections guaranteed, under sub-chapters, that rely solely on it'smother statute: U.S.C. 42 (1983): and as it pertains to,"Coercion and OfficialOppression (thru police arrest and detention ).1 hope this Honorable Court issensing the seriousness, of Chandler's own involvement with this case.

Businesses, who suffer this type of corruption, are rare, indeed, and very hard

to prosecute when there is a cover-up. More reason, that this Petitioner seeks

redress here in State Court. This is not a stick up at the local grocery store or a

conspiracy to assassinate the president by the Defendants. This is murder by

tort.

9. This one multi minded form of machination, perpetrated by a few

rogue men, with a hidden agenda. Selectman Chandler has played this out to

help his friend, selectman Garland. But the money Petitioner's have lost, is in

the (millions of dollars) and the health problems Petitioner Ed Furlong has

continues unabated, and continues to debilitate him; no bank robbery here, but

tort murder, by and through it's own right. Chandler and Doug Garland,

vicariously, used the Libby's to commit their Tbrtious Act, against Petitioner;

whether the selectmen Chandler or Garland actually picked up the Boulders

themselves, and dropped them down to Block, makes no difference, whether

one Selectman ordered it and not the other, makes no difference, whether

walking in someone else's shoes, while (colluding with other"s"),committing

"a Tortious Act ",... while purporling to be at the office, makes all the

difference in the world.

10. To the Honorable Court: what we have here, encumbering this

petition, is perhaps, I truly believe,...because of the number of "Players"

involved, one for the books; one of the most dynamically malicious colruption

cases, that the New Hampshire Judiciary will ever bear witness to. Selectman

Chandler, walking around in someone else's shoes;...that happens all the time

(It's called deception); committing these acts of duplicity , while walking

around in someone else's shoes, through the office of Bartlett Selectmen, with

associate Selectman Doug Garland, tugging at Chandler's leash, with the intent

to injure Plaintiffs two businesses, is culpable; and the two other

conspirators/tortfeasors, (Annette & Stephen Libby), are guilty of oppression

through deception. Then,...vicariously, through their subordinates, (see Exhibitno. 2e)Annette and Stephen Libby and Gene, to facilitate to cover up, are

liable, both criminally and civilly. And a crime, pursuant to RSA 643:l

"Official Oppression" has been committed. These acts, while committed acting

under "color of law"; (U.S.C. 42 (1983),...an official is guilty, of stepping

outside his shoes, when a tie (s) to cover up a tortious act precludes the victim

from due process than a crime has been committed; this gives rise to enhanced

penalties, (no immunity exist). Whether or not, through a "subordinate" or

associate, or whoever, the Selectmen purports to be at the office, whether or

not they are walking in someone else's shoes (Libbys), makes no difference.

This is a libelous, and an aberration by theses selectmen of monolithicproportion. What the Selectmen (Chandler and Garland, Tbrtfeasors) did to

Petitioners, was deliberate and wanton, and so detrimental to Petitioner's

livelihood, and health. Petitioner had to have open hearl quintuple by-pass

surgery to bandage that problem; "part of the problem" anyways, from all the

stress Petitioner Furlong; stress caused Petitioner to lose his fianc6. She had

had enough, as the many documents submitted and enclosed will shedlight on

the collateral damage to Petitioner's life. see Exhibit no. 3b, Affidavit of Erin

Myatt. The other half of the problem /ies within the Selectmen's office, and the

lies thatemanate from there, are very serious, and can be corroborated as they

pertain to Chandler and Garland's malfeasance and Ethic Violation(s), and as

they will pertain to the void, in Discretionary Function ImmuniQ, at the Town

Hall, in the Selectmen's office. Violation of their Ethics,...this wont be the first

time for Representative, Gene Chandler." see Exhibit no. 3. Ethic charges filed

against Representative, Chandler.

11. I was under huge amounts of stress going forward, from the winter

of 2008, when this "Intentional Tbrt" consumed Petitioner. Petitioner's had to

hire a lawyer then,...to fight this wrong, by Selectman Chandler. The lawyer did

not do a good job for Petitioners, as this Honorable can see here. The collateral

damage has been profound. This tortious act, (to augment Garland's reputation

and cabin rental business and ski business, at the cost of Petitioners, has

"oppressef' Petitioners, tortiously so), and perpetrated by Chandler and

Garland, has left an indelible scar on Petitioner, for life. Then to lie to cover up

the intentional tort, or distort and confuse the facts under, (he said she said),petitioner's right to "Discovery" is Stonewalled. 'Discovery Rule" applies to

attempting to ascertain the truth. In this case, the Selectmen have

"intentionally," distorted the facts to keep Petitioner away from the truth. This

is abominable, and a violation of Petitioner's constitutional protections,

guaranteed by same; and the numerous other laws that are annexed to a U.S'C.

+Z 1t983). But for Chandler's indiscretions, Petitioner is left despondent and

lacking life's normal pleasures. Petitioner needs this Honorable Court now, to

remedy Petition's injuries.

12. A class vi roadway can not be discontinued "subject to Gates and

Bars" pursuant to RSA 231:43 and RSA 231:45 without warrunt article and/or

Tbwn Vote. Selectman/Chairman deliberalely, and maliciously, with reckless

indiff.r.nce, permitted the Boulders to be placed to block Petitioner's

ingress/egress to Petitioner's respective businesses, and Selectman Chandler,,installed" a locked highway gate, to it's Petitioner's"ingress" to Petitioner's

property, contrary to: RSA 231: 43 snd RSA 231:45; see pictures E@i1: assorted pictures to help this Honorable Court, see more clearly- Note:

pirtut. with iocked gate. Petitioner had a temporary restraining order from the

Superior Court at Osippee, New Hampshire, "ordering" that Defendant,

Chandler and others, leave Petitioner alone to conduct his business, and

Chandler was ordered to remove the boulders, to no avail. see Exhibit no.Lc,

Representstive Chandler, bucking the Order.

13. Exhibit no. 7: Attorney for the Barllett Water Precinct, Mathew

Cairns, his "Rep-y Brief," to answer the current case before the Superior Court'

Canoll County, that Petitioner's currently have docketed, as case no 212-2015-

CV-000 10, Exhibit no, 8, "Petition For Injunction and Declaratory Relief and

Damages"..-in uttor*Vt Cairn's reply brief, he states on page 1 line 7: "It is in

fact, a right of way...." Blogbrough FamilV Realtv Trust v. A & T Forest

proiduci, Inc (2007' I55 N.H. 29, 917 A.2d 1221 and Cheshire Turnpike v.

Stnrrrt OtSgt iO N.n. tSS. Class vi road are defined: see Exhibit no. 1Ia,

p"g. ft"- "

"Hard Road to Travel"; published by the University of New

ilampshire, cooperative Extension. Exhibit no. 11b, a letter dated 02-22-12,

from Bob Talo", (N.U.O.O.T., Right of Way/Roadway, AuthoriQ) where he

states: that "it doesn't matter the length or width of a class vi road, even if it

only gets used, periodically and, " it doesn't matter who owns underneath the

road."

14. private easements accrue and attach onto "Real Property" through

the years, and can not be extinguished, they are eminent over any authority and'

the abutter exercises that authority as it pertains to his right of way, or class vi

road, and has all rights reserved and, guaranteed by our Constitution, and

numerous N H., RSA law. N.H. RSA 43:6 and Article 35 of Part I of the New

H amps h ire C o nstit utio n.

15. Exhibit no. It assorted photos, before and after blockade.

Selectmen Meeting Minutes, Exhibit no. 2d dated, 12-01-06, where Selectman

Chandler states: " there was no fence going across road." Chandler admits there

is a road, right there, in that selectmen meeting minutes. Now if you please,

see Exhibit no. 5, page 6 question 14. Chandler's Interrogatories, he "passes"

the question about the boulders. Now if I may, I would present all the

selectmen Meeting Minutes, that are too numerous to mention, that would say

Annette Libby does nothing without the authorization of the Selectman. I willpresent this Honorable Court one Exhibit no. 2e. This Meeting Minutes shows

Bartlett Recreation Director, Annette Libby reporting to her bosses (The

Bartlett, Selectmen, Chandler and Selectman Garland). The third selectman,

David Patch, is inconsequential, Garland and Chandler are the 213's vote.

16. Exhibit no.2s dated March 22,2012,is Petitioner, Ed Furlong's

Complaint to the "General Court," Legislative Ethics Committee, against

Selectman Doug Garland and the reply letter addressing my complaint against

Selectman Garland; now please see Exhibit no. 2e letter from an anonymous

person who heard about Petitioner's plight through Petitioners website:

www. b artlettco rr uptio ns uit. w e b s, c o m

17. Exhibit no. 12s December 14,2001; letter Selectman served

Petitioner with no "hearing date."

18. Selectman Chandler is no exception to the rule, when it comes to

Official Corruption as seen in exhibit no. 3 .

19. Mr. Chandler is selectman-chair, he presides over the other two

selectmen, it is Chandler's expected duty, by the Citizens of Bartlett, that he be

held to a higher degree of astuteness, and authoritative control, in all issues

during these quaisi-judicial selectmen meetings. This did not happen with

Plaintiffs, and Selectman Chandler was silent, and indifferent, and did not

contest Selectman Garland's lie" that [he] "did not order the Boulders/Rocks"

placed to Block Plaintiff's businesses, and "does not know who did."

20. Bztlar, Selectman Chandler's silence. and (abetting Garland's lie),

Petitioners have suffered great financial losses. Not to mention health injuries.

The video suggest Selectman Chandler played along with Garland's lie; all the

while when Selectman Garland was lying through his teeth to cover up the

Intention Tort committed against Plaintiff's businesses vicariously through

Annette and Stephen Libby. Petitioner now will invoke the conspiracy charges,

and bring Selectman Chandler into the mix. His own 2 lies, and the abetting ofa third lie, to corroborate Petitioner's within Petition for Chandler's Removal,

from Official Office.

21. Exhibit no. 6a Letter dated, December 4th 2008, Stephen Libby to

the Bartlett Selectmen, reporting to them on his investigation into the

Petitioner's property. Now please see, Stephens Intemogatories, Exhibit no.l3page I line T,where Stephen Libby perjures himself, yet again, and he states:

[he] "is not spying on Petitioner's property" or he isn't performing any duties

for Selectman Chandler or Selectman Garland. Now please see Exhibit no. 5page 6 line 14. Chandler's Interrogatory; where Selectman Chandler denies

that the selectmen commissioned Stephen Libby to hurt Petitioners' businesses

with acts to injure Petitioner. Exhibit no. 15 August 21,2009, shows the

Selectman John Tanquay, (since then, Selectman Tanquay was sentenced to 7

years for child pornography) where he thanks Stephen Libby for the good work

he did to survey Plaintiffs Property and ball field. Exhibit no.ld is yet another

selectman meeting minutes where Annette Libby states; her husband "has done

a lot of research into the history of the field" all the while Gene Chandler states

that the Selectman did not commission Stephen Libby (husband to Bartlett

recreation director, Annette Libby) to research Petitioner's property or the field.

Yet in Chandler's interrogatory, Exhibit no. 5, Ouestion no. 13, Selectman

Chandler states: "none of the selectman hired Stephen Libby." Now to bolster

Libby's perjured statements in his Interrogatory, is further supported by this

letter Exhibit no. 5a where a letter dated December 4th,2008 by Stephen

Libby states: that he did submit the material relating to the Petitioner's property

and "field" at the "request from the selectman." now see Exhibit no. 13 paee Iquestion lT lnterrogatories answered by Stephen Libby, dated, October 18,

2012, where he, "emph atically," perjures himself stating: "neither the Bartlett

Board of Selectmen" requested him to do research regarding the field or

Petitioner's property. Now please see, Exhibit no. 5c Annette Libby's letter

where she outlines in detail, that she is "acting under color of law" purportedly,

as recreation director, but instead, she's reporting work being done on one ofPetitioner's rental cabins. now please see Exhibit no. 13 page question (st 4,

ancl 8: 14 and 20Interrogatories, answered by, Stephen Libby, and deposes and

states: "...two pictures were taken on August l3th, 2008." Exhibit no. 13a

question lT lnterrogatories answered by, Annette Libby, October 18 2012,deposes and states: [she] "has no conversations with, Selectman Doug

Garland, either before, or after her hire..." This is yet another perjured

Defendant, Petitioner would refer this Honorable Court's attention to the 3rdExhibit back, no. 5c: letters and minutes to corroborate the Petitioners claim ofconspiracy to commit certain "Intentional Tortious Acts."

22. On February 12,2015, Petitioner was arrested on the roadway next

to his property. This, reverses the burden of proof to prove the roadway exist

through police coercion and false imprisonment, contrary to the controllingauthority on who has the burden of proof: Blagbrough Familv Reoltv Trust v.

A & T Forest Products, Inc (2007t 15 5 IY.H. 29, 91 7 A2d 1221. This is a

serious violation under U.S.C. 42 (19831regarding property rights.

Barden of Proof: Discontinuunce of a public highway is a fact thut must be proved, und the hurden is

upon the party who ssserts cliscontinusnce to prove it by a clear and satisfuclory evidence.

23. This man, SelectmanlChair, has injured Petitioner's health and

Petitioner's businesses beyond what can be considered acts normal in a city

hall. This selectman needs to be brought to justice, to answer to these serious

allegations. You can't facilitate a lie by an associate selectman to help cover up

his "Intention Tort." It is just not going to happen here today. See Exhibit no.

8, complaint titled "Petition for Injunctive and Declaratory Relief and

Damages." Selectman Chandler has a quiet pestilence about his person that

belies his reserved behavior. He's cunning and smart. Petitioners will give him

that. He also has destroyed what Petitioners have worked so hard to build for

l8 years, and this has financially crippled Petitioner's "once",...two flourishing

businesses. The Indisputable Facts Remain though: Petitioners have

Selectman Gene Chandler compromising his oath of office with whatPetitionerrs have submitted to this Honorable Court for Ifte Recard

Abetting a lie in his Offlrcial Capacity as Selectman/Chair while acting under

color of law in his official capacity, to employ subterfuge to hurl Petitioners.

Controlling Authority, as defined:

OFFICIAL OPPRESSION

RSA 643:t: Officiat Oppression: Witliams v. Dover, 130 N.H. 527 (1988t ond RSA 673:13,,for iniffiiiencv, neglect of tlutv. or malfeasance in office" For Selectmen RSA:42:I:RSA

Chapter 43 Removsl from Office RSA42:la

"...0 public servant, is guilQ of fficial oppression f, with a purpose to

benifit himself or another, he knowingly commits an unauthorized act which

purports to be an act of his ffice; or knowing refrains fro* performing a duQ

imposed on him by law or clearly inherent in the nature of his ffice. "

MOTIVE / MODUS OF OPERANDI

l. Selectman/Chair, Gene Chandler, and Selectman Doug Garland, are

two associate Selectmen of three, who have worked together since Selectman

Garland was voted into the selectman's chair in the spring of 199912000. There

are just 3 selectmen here in Bartlett, New Hampshire, minimizing Petitioner's

odds at getting fair treatment from this "corrupt tribunal" at the Bartlett

selectmen town office. Selectman Chandler and Selectman Garland, have

- grown up together, as childhood buddies. I can't compete for my propefty

iightr, ui th.y pertain to the due process violations, against this corrupt and

impenetrable force, (Gene & Doug) at the selectman's office, at Bartlett, New

Hampshire. The two Selectmen, Doug Garland and Gene Chandler; they are the

213's vote.

2. Exhibit no. 12, osee 5 and 7, "Master Plan" for the Town ofBartlett, infers,...and shows, amending, in around, 2001; referencing the

"language in the letter's body, at page 1, paragraph 1. Soon after Doug Garland

was elected selectman in 2000, Selectman Garland began his private campaign

to suppress snowmobiling in Bartlett, and augment his cross county ski

business, Bear Notch Ski Touring, LLC. Petitioner has to give selectman

garland a slap on the back though, because he has always had a hidden agenda

as soon as he found his "seat". Selectman garland amended the towns "Masterplan" right after taking his chair, and had the audacity to incorporate into the

Town's "Master Plan," his business (Bear Notch Ski Touring, LLC) in 2001 ,

not even ayear right after he took Office. This in itself is suspect, if not

outright self-seeking for a pecuniary purpose. Advertising his business through

the Town's Master Plan, is a serious impropriety, considering the other

elements to this profound story, of Tortious Proportion, to the other

snowmobile rental companies who also operate in this small hamlet/town, and

can't expand because Selectman Garland possesses all the cards as Selectman,

Ex Officio to the Bartlett Planning Board. see Exhibit no. I2e :news print;where Garland states, " they can yell conflict all they want..." This is an affrontto the ethics that have been carved in stone for centuries, but are certainlylacking within the halls of the Bartlett selectman board. This is officialtransgression in its finest platform, by Defendants, with Intent to Oppress.

What's disturbing about this "Inclusion to the Bartlett's Master Plan" by

Selectman Doug Garland, to rewrite the Town of Barllett's "Master Plan,"toinclude his business, Bear Notch Ski Touring, LLC., in it's language, is a

conflict of Interest and an impropriety, or perhaps, malfeasance. Period. Hoping

this Honorable Court is sensing a pattern here. A Master Plan, that has

incorporated the Selectman's business, speaks volumes to what Petitioner has

been dealing with. A selectmen board that has been running amuck to

fundamental due process deprivation, resulting in financial hann to the

Petitioner's snowmobile business, (Lil'Man Snowmobile Rentals, Inc.) and the

"Tortious Interference" with a legitimate business enterprise. To blockade

Plaintiff's snowmobile business to access the national forest trails, is an

abomination to all the citizens of Bartlett, New Hampshire. This behavior is

status quo at the Town Hall, at the Selectmen's office, here in Bartlett. On the

part of Selectman Garland, he represents the "adversarial" mind set, of the

other two selectmen, towards the snowmobiling industry here in Bartlett. But I

would correct that statement, to just include Gene Chandler and Doug Garland.

David Patch, the 3rd selectman, seems an affable sort. But that's all it takes is

213's of the vote: Gene and Doug. Bartlett has only 3 selectmen, which makes ithard for fair play to begin with.

3. Snowmobiling in New Hampshire is the largest economical engine

in the winter months. It's beneficial to the town of Bartlett's economy. The

economical fortune offered by the snowmobilers, paradoxically, is contrary to

Doug Garland's needs as they would pertain to his "quaint" cross country ski

business. His proposed "dream" through the town's "Master Plan" is to have

his x-country trails connect with those up in the town of Jackson. His skiers

clash with the Petitioner's snowmobilers. enter Exhibit no 3e (two letters from

Joe Gill. Eastern Mountain Ski Team, USDA affiliate. This is the final chapter

in Garlands memoirs to the conclusion chapter that this Petitioner will never

see equity in anything involving Selectman Gene Chandler and Selectman

Garland. This Master Plan editing, by Selectman Garland, and approved by

Chandler, is outright tortious to Plaintiff s business Lil' Man SnowmobileRentals, and to the general public, who are suffering and the snowmobile rental

businesses in general, who outfit the hordes of tourist who come to Bartlett torecreate, should not suffer this. Theoretically speaking, if the cross country ski

trails would include the trails in Bartlett, that Garland calls his own trails, toconnect to the town of Jackson ski trails, this would mean less business for the

snowmobile rental businesses, specifically (Lil' Man), because

typically,...cross-country ski trails are exclusive to that sport and not to be used

by snowmobiles. see Exhibit no. 5b: (Selectman Garland's trail map regarding

his business). Snowmobiles leave marks and grooves in the snow that wouldpreclude a cross-country skier from enjoying the trails used by snowmobilers.

End result, would be the Bartlett snowmobile industry would be monetarily

suppressedfrom prospering, while the cross-country ski business Garland

owns, would flourish. Is this Honorable Court sensing a pattern yet? Garland or

Chandler, have yet to volunteered to step down while making "tribunal like"orders pertaining to Petitioner's businesses, but have started just recently

stepping down because of Petitioner's law suit.

4. "Jury Standard" pursuantto RSA43:6,"a person shall not sit...",

andAtherton v. Concord 109 N.H. 164 (19681: Ehrenbure v. Citv of Concord,

120 N.H. 656 (1980t Winslow v. Holderness Plannine Bosrd 125 N.H. 262

(1984t: Tbttv v. Grantham Plannine Board, 120 N.H. 390 (19801

5. Notice of Hearing: Section 43'2 as it pertains to the New

Hampshire Constitution states :

shall verntn int a time and hearins. und rtrdar nttticc

to be iven lo a rishts mav be directlv affected

proceeding..... "

6. Petitioner never received a hearing date, just a letter as seen in

Exhibit no. 12a. Petitioner had to go to Selectmen and Plea For His Rights,

but no formal hearing was set for petitioner. and no rights had; incidentally,

to corroborate these allegations by Petitioners; Petitioner's submit Exhibit no.

l@_ this Meeting Minutes show Petitioner "Invoking and Establishing" a

Constitutional "Due Process'o Violation bv f)efendant. Selectman. Gene

Chandler. on l0-7-2008. The Statute of limitation only starts running when the

victim, in light of the violation, finds out about the act. That just happened

recently to Petitioner, after learning through the Selectmen Meeting Minutes,and acquiring the Selectmen Meeting Minutes, through the "right to knowLaw." Petitioner Furlong had ask for 30 days to research the roadway, and

Petitioner was denied, summarily. This is a Huge violation of due process.

Selectman Gene Chandler, must be held accountable for this deliberate and

wonton violation of due process, by this Honorable Court. These acts were

perpetrated by Gene Chandler, to facilitate the end product, augmenting his

childhood buddy, Doug Garland's ski business and cabin rental business, whilein official capacity.

7 . There are no statute of limitations here, because "new acts" of.

Deprivation lo Plaintiff's property rights have continually occurred since 2008.acts" of

The latest: Petitioner being arrested (by order of the Barllett Selectman,

Chandler) on the class vi road, on March 19,2015, contravening a Court Order,

by issue of the Carroll County Superior Court; please enter Petitioner's Exhibitno 1c (Tbmple. Cl. A COURT ORDER, explicitly allowing, Petitioner's access

through the class vi roadway as it pertains to it's east side boundary.

Petitioners rights are rock solid, as the granite this wonderful State was named

after. Petitioner needs justice. The Judge, (Temple, C) Order was issued on an

"Exparte " basis; however, Petitioner immediately hand delivered this order to

"Acting" Chief, Janet Champlin, on February l3th,2075, at the Bartlett Town

Hall and police station. Chief Champlin told Petitioner that "[she] has her own

Court, at the 3rd District Couft, in Conway," and disregarded the Honorable

Judge, (Temple, C.) order, from Superior Court.

8. False arrest, defamation of character by action or association to

Garland, Libbys, or the Chief of Police, Janet Champlin. But the selectmen use

the Chief of police to execute their own, "In House" justice. see Exhibit no. le,former police Chief Tim Connifey..."takes his orders right from the selectmen,

regarding Petitioners property rights."

9. Exhibit no. 12a, Petitioner submits to this Honorable Court, a

letter dated December 14,2007; this was the only notification (no hearing). The

Town of Bartlett, through the selectmen's office, take control of the ballfieldand"related proper\t," which abuts Petitioner's property; ..."the field area is

not to be used by (Petitioner) or anyone else..." I guess Chandler takes what he

wants; see Exhibit no. 12d. Now see where Chandler states in so many words,

that there is no outhority for the Bartlett selectmen to control the field. Exhibitno. 5, (Chandler's Interrogatories) page 5 line 8, where Chandler deposes and

states: that "there is a letter to Annette Libby." but no "License." This will notsuffice as authorization, to delegate such authority, "a letter." To establish a

legal transfer of authority from the Bartlett Water Precinct to the Town ofBartlett, there must be a legal document involved and a town vote. This type ofbehavior has been going on too long. There has to be a lease, license or some

semblance of a contract agreement. A transfer of authority must be through a

warrant article, and subsequent town vote. I am assuming this Honorable Courtis familiar with these types of laws; requiring these types of legal delegation ofauthority, fiom one municipality, to a municipal entity (Bartlett Water Precinct).But it makes no difference, ...in that, we are dealing with a class vi roadway, orprivate easement, that the selectmen closed without warrant article.

10. Exhibit no. 12c , A must read. Is a letter dated, January 12, 2004,

where a seperate business owner, Mrs. Lynn Wilczek, who rents snowmobiles,

and who has a cabin rental business, as wel[, competing against Selectman

Garland's two competing cabin rental and ski businesses. She, Mrs. Wilczek,nearly got the same identical treatment as Petitioners, but certainly not as

Tbrtious. Against this backdrop, and that letter, is this Honorable Court sensing

a pattern, yet.

11. Exhibit no. 15b Numerous selectmen meeting minutes showing the

"mind set" of the Selectmen, Chandler and Garland which support the

Petitioner's allegations that the two Selectman have an unshakable, "inhercntdislike" for the snowmobile rental industry and, specifically, towards the

snowmobile rental business that Petitioner Ed Furlong owns; and Garland's

self-induced conflict with other cabin rental businesses, that are in close

proximity to selectman Garland's own cabin rental business. The Selectman,

Gene Chandler, is a close childhood friend to Selectman Garland.

12. Petitioner, Ed Furlong, called Chandler a "Dick Head" back in 2007 ,

at the local post office, when Ed Furlong was presented with this opportunity.

Petitioner Furlong, since regrets his verbal insult at Selectman Chandler;

however, this perhaps, was the impetus that started Chandler's own campaign

against Petitioners, Ed believes. Coupled with that, Gene, is Doug's good old

friend, from their childhood.

13. If the lies that are outlined in this complaint, under couNT, I, II,and III weren't directed at covering up an Intentional Tort, Petitioner's might

think that they could be argued by Selectman Gene Chandler, as an oversight,

but that's not the case here. Clearly Selectman Chandler was excercising his

rights under what we know as a "good old boy" network.

14. Exhibit no. 1(Video #2) shows Lil' man "sold out" video; Lil'ManSnowmobile Rentals, Inc., up to the Instant, )"lntentional Tort, of barricadingPetitioner's businesses, was the Largest Snowmobile Rental Company in the

United States. At Lil'Man's peak, before the violation (s) of Petitioner's Due

Process and Tortious Interference with a corporation; Lil'Man had a rental fleet

of over 80 Snowmobiles; and it's own Snow-Cat. see Exhibit no. lIc. NowPetitioner's have 20 snowmobiles. This is the biggest Intentional Torl I have

ever heard of, involving a Selectmen Board, here in New Hampshire. There are

numerous, serious, constitution due process issues here. I am suggesting of acriminal nature, of collusion, conspiracy to coerce, "conspiracy" to defame,

defamation, invasion of privacy, just to name a few. This is a profound injury toPetitioners. Petitioner Furlong has suffered psychological impairment from this

dirty deed. Petitioner Furlong is very, very angry at this huge slight. ButPetitioner continues to hold on, waiting for justice to deliver. But to no avail,

hitherto. Petitioner Furlong had to have emergency open heart by-pass surgery,

due to the stress manifested by Defendant's tortious acts, deliberately targeting

Petitioners two competing businesses, to financially cripple through subterfuge,

to shut Petitioners down by blockade. And to perpetrate that act with a townpolice authoriQ usedfor unlawful purposes.

15. Selectman Chandler, Selectman Doug Garland, Annette Libby,

Stephen Libby, Bartlett police chief Janet Champlin, David Ainsworth of the

BWP, conspirators, collectively and individually. Selectman/ Representative,

Chandler, colluded with the others to pull it off. see Exhibit no. 11d. This

needs to be remedied, now by this Honorable Court. Because of the "special

circumstances" of the number of "Players" (Annette Libby, her Husband,

Stephen Libby, Selectman/Representative, Chandler, and Garland, are allmarked "elements" directed at supporting a conspiracy charge. Under U.S.C.

42 (1983), a person is guilty when they conspire together "acting under color oflaw"...ExhibL AQ,fl!,

16. I will direct this Honorable Court's attention back to Exhibit no. 3

Ethic Charges,lodged against Representative, Gene Chandler. These were

some very serious charges, indicting him. Lucky for Gene, he had friends in

"high places." This is not going to happen this time. Not on this Petitioner'sWatch.

BUT FOR, the Defendant, Representative to the House, and

SelectmanlChair, Gene Chandler, Petitioner re-alleges all the facts, here, andcircumstances detailed above. and states in furtherance. the followine:

That the duty of care owed Plaintiffs, by an Official (s): Selectman Chandlerand Selectman Garland, to Petitioner and, who is a citizen of the United States

of America and residing at 1455 route 302, Bartlett, New Hampshire: "ThePetitioner," Edward C. Furlong III, was denied that duty of care.

COIJNT I

l. BUT FOR, Abuse of Office, Chandler obettins a Lie, "PERIURY"pursuant to 643, RSA:2; as seen through Exhibit no. I (video).Mr. Garlanddenying he blocked access to Petitioners two businesses and Exhibit no. 2(two) page 9 line 20-23 (two years later, while under oath, Garland'sDeposition) where Selectman Garland states, emphatically, that he "yes" he didthrow or place the Boulders down, or had them thrown down, to blockadePetitioners from conducting their, respective businesses, is tortious, and

Representative/Selectman Chandler tacitly offers a concumence to Selectman

Doug Garland's lie. see "selectmen Wdeo # I and meeting minutes" Exhibitno. 1a where Gene Chandler knows of the Boulders.

Selectman, Representative Chandler, knew his actions with DougGarland, blockading the roadway that was in current use by the abutter was

risky. But Representative Chandler felt complaisant enough to threshold the

tortious act. Plaintiff submits 4 lie with corroboration through deposition.Huston we have a problem. Blockading the largest Snowmobile Rentalcompany in the entire United States takes a lot of guts.

A public servant, as defined [hereinJ RSA 610:2, is guilty of a misdemeanor if, knowing thal

fficial aclion is contemplated or in reliance on information which he has acquired by virtue o/'his

ffice orfrom unother public servant, he:

I. Acquires or divest himself of a pecuniary interest in any property,

transaction or enterprise, which may be affected by such action or information;or

II. Speculates or wagers on the basis of such action or information; or

III. Knowingllz aids another to anlz of the forgoing.

COIJNT II

2. BUT FOR, RSA 643; Chqndler's lie # l. "PERJIJRY" RSA 641:l;as seen through Exhibit no. 4a. During heated litigation between theSelectman and Petitioner, Edward Furlong, around July 24th 2009; show the

Petitioner filing a civil complaint, regarding fighting for his Propefty's AccessRights, through his, then attorney, Randal Cooper. Now if you please, see

Exhibit no. 4,3rd parssraph dated Julv 28th 2009, (Affidavit of Gene

Chandler), while under oath, and Chandler states, emphatically, that- "There isa license" between the Town of Bartlett and the Bartlett Water Precinct , tosupport what we know as a, "Temporary Access Agreement", (here afterreferred to as the, TAA), and offered by Selectman, Chandler, to support theirlegal authority. To who's authority did they have in drafting the TAA in the firstplace, between the Bartlett Water Precinct and the Town of Bartlett (Selectmen)

to "legally" encumber that (TAA). But after the heated litigation ended, almost

3 years later, Representative Chandler undoes his lie, Chandler deposes and

states, under oath, through Interrogatories, on the same case, as seen in Exhibitno;!, Tbwn of Bartlettt, Interrogatories, question 8, Answered by

Representative,GeneChandler,SayS'emphatically,thatthereiS''@''Lease, no Contractual Agreement, but maybe a letter. This is Gross Negligence

and Tortious Interference with Plaintiff's Concerns. Defendant Representative,

Gene Chandler is wanton and malicious in his official capacity and, is the

"proximate cause" of Petitioner's Injuries, and contrary to Petitioner's health,

welfare, enjoyment, prosperity and the pursuit of happiness. Petitioner's will be

seeking redress for mone)t damages, under new, Separate "Action".

COUNT III

3. BUT FOR, 642, RSA 641 1, Chsndler lie # 2 "PERJURY" as seen

through Exhibit no. 5, Town of Bartlett Interrogatories, to be answered by theTown Selectman/Representative to the House, State of New Hampshire, "GeneChandler." Here, Representative Chandler, while under oath of Official Office,is ask which "Bartlett Selectman" requested that the (Town Defendant),Stephen Libby, research Petitioners Property, and the Field area, east of thePetitioner's Property, owned by the Bartlett Water Precinct. Here Chandler,unequivocally, deposes and states: "None of the Selectmen" requested StephenLibby, to do research. Now if you please, see Exhibit no.Sa, letter fromStephen Libbv, where Stephen Libbv states that it wss the Board of Selectmenwho requested him to research Petitioner's propefty. And in furtherance of this,perjured his testimony by Defendant, Representative Chandler; Exhibit no. 5c,more corroboration through letter of Annette Libby, Chandler's employee. Thisletter speaks volumes that Chandler ask the Libby's to join the conspiracy: todo reseach regarding the private matters of Mr. Furlong, the Petitioner.

COUNT IV

4. COUNT IV RSA 6431 "Official Oppression/Conspiracy" RSA 640:2

Representative Gene Chandler, in violating Petitioner's constitutional rights.Selectman, Gene Chandler, facilitated Selectman Doug Garland, in that, when

Representative Chandler tacitly concumed with Selectman Garland's"documented " lie, Selectman Chandler actions "conspired to increase"

Selectman Garland's Cabin and X-Cross Country Ski Rental Business, infurtherance of the Tortious Interference. And in furtherance, conspired tooppress Petitioner and his businesses. Petitioner has two like-in-kindbusinesses; these competing businesses between Petitioner and Selectman,Doug Garland businesses, are less than ll4 mile apart. These two businesses

have documented adverse history. please see, Exhibit noZ. (Garland'sdeposition) page no., I6 line 1-23. By Selectman Garland conspiring withAnnette Libby, (Bartlett recreation director) and, Stephen Libby, and

SelectmanlChair,, Representative to the House, Gene Chandler, involving inviolating Petitioners property rights and the rights of Mr. Furlong, specificallythose rights guaranteed by our constitution, to conspire to hurt Petitioner, and

in furtherance of that crime employed or commissioned, Mr. Stephen Libby, a

private cilizen, (Stephen Libby) to research Petitioner's property in furtherance

to hurt Petitioner. The Libbys or Selectman Chandler, in blockading Petitioner's

Ingress/Egress, down, what is "conspicuously known by all who live inBartlett, as a class vi road, or right of way (ROW), separating Petitioner'sproperty and the property, that of the Barllett Water Precinct; is malfeasance byRepresentative, Chandler, from the outset . see Exhibit no. 5c page 2,line 12. v.Exhibit no.7 page l.line 7. Now to corroborate even more see: Exhibit no.5 paee 6line 13 now please see: Exhibit no.2b. The Town Selectmen,(Through their pseudo authority, that they invented through the TAA ) that thedefendants "thought" they might of had authority, but that's not the case here.These were deliberate acts to hurt Petitioner. That Chandler, did not have theauthority to gate and bar a class vi road. Or authorize him to order hisemployees to block Petition's access to his property. Attorney Cairns is onlystepping forward now with the truth because of the law suit that was just filedvia Petitioner's Temporary Retraining (TRO) Order, that issued out of SuperiorCourt on February 13, 2015. Please see Exhibit no.6, page 2: porograph I2 a(ROW) Where Petitioner's have been embroiled fighting for their Due ProcessRights, as they pertain to that class vi road, or easement/ROW, or as theviolation of due process and, conspiracy to oppression, to false arest to assist

in the Tortious Interference, or the Violation of Constitutionally Protected, DueProcess, as it pertains to conspiracy or Oppression that is the Proximate Causefor Petitioner's Injuries. All perpetrated by Representative, Chandler, and

others. see Exhibit no. 9 poge 3 "Res Judicata Preclusion". No% as seen

through, Exhibit no. 7. Legal Brief, dated March 20, 2015; by attorney for theBartlett Water Precinct, Mathew Cairns, Deposes and States, "unequivocally,"that there is a "Right of Way...." separating the Petitioner's Property, andproperty that of the Bartlett Water Precinct. This is unconscionable, and

deliberate. This is now being asserted by the Barllett Water Precinct's attorneybecause of the liability concern, I'm certain, after referencing Petitioner'scurrent "Petition for Declaratory Relief and Damages".Pursuant to Title 18

U.S.C. Section 241: Title 18 U.S.C., Section 242: "Deprivation under color ofLaw." This is wanton and Deliberate Act (s), Malicious, in its deepest roots,and a slight by Representative, Gene Chandler, and this must be remedied bythis, Honorable "High" Court. Bill of Rights, defined, Article 2:

ooAll men have certainand defending, Iife and libertv, acquiring nossessins, and protecting. propertv, and, in a word.seekine and obtaing happiness. Equitv of riehts under the law shall not be denied or ahridged bvthe state on account, of race, creed. color, sex, or national origin."

COLINT V

5. COLTNT V RSA 629:3, "CONSPIRACY/DEPRIVATION" while actingunder color of Law: RSA 640 2 Conspiracy: purportedly acting under color ofGene Chandler's Official Office, as Selectman, and Representative to theHouse, "Did Conspire to Hurt" Petitioner, Edward C. Furlong, and hisbusinesses with co-conspirator, Annette Libby (Bartlett Recreation Director),her husband Stephen Libby, Selectman, Doug Garland and Bartlett PoliceDepartment's Acting Chief, Janet Champlin, to Conspire together, acting undercolor of their Official, respective, Duties to Serve, not Take, to DamagePetitioners Good Reputation and "Depriving" Petitioner their Fundamental DueProcess, under U.S.C. 42 (1983). Doug Garland, while perpetrating theaforementioned offenses, Gene Chandler benefited by association, and is theProximate Cause to Petitioner's Injuries. When Representative ChandlerPerjured Himself, while under oath of Office, to Conspire, aiding SelectmanGarland's Intentional Tort, the lie to cover it up, against Petitioner, and theirProperty Rights, as they pertain to the Constitution, as defined:

I. A person is guilty of conspiracy tf, with a purpose that a crime deJined by statutebe committed, he agrees with one or more persons to committ or cause the commision ofsuch crime, and an overt act is committed by one of the conspirators in furtherance of the

conspiracy.

Representativel Selectman Gene Chandler has Abetted and Conspired toAbet, with Annette Libby, her husband, Stephen Libby, Bartlett policeDepartment, Acting Chief, Janet Champlin, and Doug Garland, to blockadePetitioner's two businesses, that was Petitioner's Life Line on "The" class viRoad, and the Ingress/Egress from the Petitioner's Property, as it relates to itseast side boundary, and the class vi roadway. See Exhibit no. le. This shows

selectmen Meeting Minutes, Memorializes, that the Bartlett Police Departmenttake their Direction from the Selectman, in regards to Petitioner, Mr. Furlong,and his Property/Fluman Rights, as they pertain to the Constitution of the[Jnited States of America. Representative Gene Chandler had Petitioner,Edward Furlong, Arrested; on what is a Class VI Road, andlor PrescribedEasement, corroborate a charge of ConspiracylDeprivation, that have been

annexed to this case through the many legal briefs, Petitioners has filedregarding, case: 212-2015-CV-00010; to the laws of New Hampshire.

COLJNT VI

6. COLINT VI, RSA23 I : I "INTERFERANCE/COERCION" Intimidation.Representative, Gene Chandler used Threat of Arrest; Police Coercion, toIllegally Harass Petitioner, and "Detain" Petitioner to perform certain dutiesagainst his will and denied any contact with the outside world. Gene Chandler,Representative to the House, State of New Hampshire, and is the ProximateCausation to Hurt Petitioner. The Police, Janet Champlin andRepresentative/Selectman, Gene Chandler, Coerced and Defamed Petitionerthrough intimidation, in the Presence of a Crowd of People, at Petitioners placeof Business and Home. Petitioner was coerced to abide by a differant law, notthe laws of New Hampshire, when Selectman Chandler told the Police toFalsely Arrest Petitioneq Ed Furlong. These Deliberate Acts DefamedPetitioner. Defendant (s) used Coercion to make Petitioner do things he did notwant to do; like getting in the back seat of a squad car to be transported to theCounty Jail, where there are Real Criminals. Coerced to do things that arecontrary to things of Pleasure and life's Enjoyments. Instead the DefendantChandler was relaxed in his own home enjoying Life's Pleasures, and deniedPetitioner his. see Exhibit no. 4 page 2 line 5 Gene Chandler deposes andstates: ..." the Town could protect the Town's significant investment in the baseball recreation park from damage by snowmobiles." These accusatory remarkshave no merit, they are used to make Petitioner look like a bad person. Thesewonton, "Malicious Acts" by Gene Chandler, Representative, has Precipitatedhuge amounts of mental anguish on Petitioner Furlong, and this is detrimentaland debilitating to Petitioners Health, Financial Welfare and Life in general,and this has denied the Petitioner's Inherent Property Rights guaranteedPetitioner, through the United States and New Hampshire Constitution, as farback as the winter of 2008.

CONCLUSION

1. On yet another "Instant/Intentional Tort," that DefendantRepresentative, Gene Chandler, and Selectman, Garland, Annette Libby and herhusband, Stephen Libby, Perpetrated, against Petitioneq to collude to causePetitioner untold Harm, can be seen through a web-site Petitioners werecompelled to build, to fight this Malicious, Blatant,..Official Corruption:

w ww. b artlettc o ru upt io ns uit. w e b s. co m

2. A separate Memorandum of Law has not been filed because therelevant authorities have been included within this petition.

3. Disqualification/Remove Selectman/Representative to the House,State of New Hampshire, Gene Chandler. This petition Must prevail.

PRAYERS

WHEREFORE, Petitioner. Edward C. Furlong III. and Starbrite Leasing.tfull ition this H ble Courl to Disqualifu or Remove. Gene

Chandler. from his Official Position with the Town of Bartlett. as SelectmanChair.

4. Permanentlv Disqualifv in Perpetuitv, or Dismiss Selectman(chairman) Gene Chandler, and enioin Bartlett Selectman Gene Chandlerfrom ever sitting in a Quaisi-Judicial or legislative setting in which Mr.Chandler would be a normal Official-Participant, as a Selectmen, sitting ameeting; where Mr. Chandler MIJST STEP DOWN regarding petitioner, orPetitioner's Counsel, Edward C. Furlong III, or any other matter that presentsitself in the Bartlett, Selectmen's office regarding the undersigned, Petitioner'sProperty or Businesses. Additionally, GRANT and Make Null and Voidanvthing with Selectman Chandler's name and signature on it; that has hurtPetitioneg or Petitioner's Counsel, Edward C. Furlong III, within the OfficialTenor of Bartlett Selectman, Gene chandler's official office, and

a. Disqualify or Remove from Official Office, Barllett Selectman,

Gene Chandler.

b. Make Null and Void any Legal Document with Bartlett Selectman

Gene Chandler's name and/or signature on it, specifically, a document titled

Temporary Access Agreement or TAA dated February 13,2009.

c. Order any further relief that this Honorable Court deems iust and fit.

Date: May 51h.2015

Edward C. Furfong III, Pro SeBox 447Bartlett, NH 03812ecfurlon g 1 9 5 8 @gmall. com

Certificate of Service/Process

I herby certifr that a copy of the foregoing Motion has this 5th day of May, 2015, beenproperly served through the Sheriffs Office, to Bartlett Selectman Gene Chandler at 56 TownHall Road, Bartlett, New Hampshire 03812.

Edward C. Furlong III, Pro Se

VERIFICATION

I Edward C. Furlong, III, individually and as President of Starbrite Leasing, Inc., dohereby declare that I have read the forgoing Petition and know of the contents thereof. Withrespect to the matters regarding Starbrite Leasing; Gene Chandler's (Selectman) abetment to atortious lie, and dirty hands, to Selectman Gene Chandler and Representative to the House ofRepresentatives, State of New Hampshire. (Tortfeasor) Gene Chandler, lie to cover up theIntentional Tort perpetrated against Petitioner, that are outlined in many, many legal briefsbefore this Honorable Court; the video, submitted as Exhibit no. l, and the same is true to myknowledge except to those matters that are alleged on information and belief; as to thosematters, I believe them to be true.

I declare under the Pains and penalties of perjury that the foregoing is true and correctand that this declaration was executed on this 4th, day of May, 201.5, in North Conway,Canoll County, New Hampshire.

Edward C. Furl.cing III,as President: Starbrite Leasing, Inc,

STAfE OF NEW HAMPSHIRECARROLL, SS

Personally appeared before me, on this day of May 4th,2015, Edward C. Furlong, IIl,individually and as President of Starbrite Leasing, Inc., and under oath affirmed that theabove was the truth to the best of my knowledge and belief.

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