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 Se

1455 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 OF

BARTLETT 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 for
Co-Petitioner, Starbrite Leasing, Inc., a New Hampshire Corporation, and in
good standing, and established, and residing (since 2003), at it's corporate
headquarters located at 1455 route 302,Bartlett, New Hampshire. Petitioner
seeks Declaratory Judgment in the Disqualification or Removal of, Gene
Chandler, Bartlett Selectman/Chair. Retieffrom this Honoruble Court now
please.

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

disqualification or removal, only; and facilitate this Honorable Court to

ascertain the truth regarding Selectman Chandler's malfeasance and to rule on a
"Disqualification" retro to 2008, and "going forward," in perpetuity; and, to
make invalid all documents that Selectman Gene Chandler has signed, with his
name "Selectman Gene Chandler" on the document's face, and in Selectman
Chandler's Official Capacity as Selectman, that had a negative or adverse
impact on Petitioner and to Disqualify Selectman, Chandler,...for his
malfeasance associated with the case no., 212-201 5-CV-000 1 0. Selectman
Chandler made ajudicial decision regarding Petitioner's (access) property
rights and therefore RSA laws governing a disqualification of a public official
to 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.

judicially when it decides matters that

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

b. "...The Court

has said that a municipality body is acting

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

d.

RSA 673:14

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

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

as "SBL" or "Petitioners").

a mailing address

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 above

captioned case, and Counsel for Co-Petitioner, Starbrite Leasing, Inc., both
move this Honorable Court on this day to Disqualify or Remove from Office,
Mr. Gene Chandler, Selectman/Chairman and Representative to the House of
Representatives, 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 beyond
compelling, 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 tacit

concuffence 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 & 0829-09, 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 lie
further, ond abetted by Selectmen, Chandler Petitioner submit, Exhibit no. 2f
Depositionr 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's
property 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,...
Selectman Chandler knew, or should have known, that Lil'Man
Snowmobile Rental was significant, in that people would travel from Europe
and Asia to patronize the conceffI. Lil' Man was the Highlight of their

7.

petitioner would like to apprise this Honorable Court that on the day of Travis Chick taking of his
' This
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 front
restaurant 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 financially
injure Petitioners'businesses from prospering; these two Bartlett selectmen
stepped outside the protection of "discretionary function immunity" "New
Acts" of Oppression and Deprivation have occurred since then; j ust up to only
a 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 of
Doug 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
oxicallv enough. are
the two Selectmen
Plaintiffs. But these acti
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 arrest

Petitioner. 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's
mother statute: U.S.C. 42 (1983): and as it pertains to,"Coercion and Official
Oppression (thru police arrest and detention ).1 hope this Honorable Court is
sensing 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 Exhibit
no. 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 monolithic
proportion. 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.

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 212-2015CV-000 10, Exhibit no, 8, "Petition For Injunction and Declaratory Relief and

13.

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
even if it
states: that "it doesn't matter the length or width of a class vi road,
only gets used, periodically and, " it doesn't matter who owns underneath the
road."

private easements accrue and attach onto "Real Property" through

and'
the years, and can not be extinguished, they are eminent over any authority
vi
the abutter exercises that authority as it pertains to his right of way, or class
road, and has all rights reserved and, guaranteed by our Constitution, and

14.

numerous N H., RSA law. N.H. RSA 43:6 and Article 35 of Part
H amps h ire C o nstit utio n.

of the New

It

15.

Exhibit no.

16.

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

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 will
present 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.

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.

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

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

Bztlar,

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 of

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.l3
page 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. 5
page 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
question 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 of
Petitioner'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 3rd

Exhibit back, no. 5c: letters and minutes to corroborate the Petitioners claim of
conspiracy 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 controlling
authority 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 what
Petitionerrs 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
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
RSA

"...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 of

Bartlett, 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 "Master
plan" 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 affront
to the ethics that have been carved in stone for centuries, but are certainly
lacking within the halls of the Bartlett selectman board. This is official
transgression 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,"to
include 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 it
hard 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 Snowmobile
Rentals, 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 to
recreate, should not suffer this. Theoretically speaking, if the cross country ski
trails would include the trails in Bartlett, that Garland calls his own trails, to
connect 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 would
preclude 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 :
verntn
shall
to be iven lo a
proceeding..... "

6.

int a time and

hearins. und rtrdar nttticc

rishts mav be directlv affected

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 know
Law." 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, while
in official capacity.

of.
There are no statute of limitations here, because "new acts" of
Deprivation lo Plaintiff's property rights have continually occurred since 2008.
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 Exhibit
no 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.
7

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 ballfield
and"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. Exhibit
no.

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 not
suffice as authorization, to delegate such authority, "a letter." To establish a
legal transfer of authority from the Bartlett Water Precinct to the Town of
Bartlett, there must be a legal document involved and a town vote. This type of
behavior 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 Court
is familiar with these types of laws; requiring these types of legal delegation of
authority, 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, or
private 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, "inhercnt
dislike" 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.

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,

If the lies that

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'Man
Snowmobile Rentals, Inc., up to the Instant, )"lntentional Tort, of barricading
Petitioner'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. Now
Petitioner'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 a
criminal nature, of collusion, conspiracy to coerce, "conspiracy" to defame,
defamation, invasion of privacy, just to name a few. This is a profound injury to
Petitioners. Petitioner Furlong has suffered psychological impairment from this
dirty deed. Petitioner Furlong is very, very angry at this huge slight. But
Petitioner 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 town
police 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 all
marked "elements" directed at supporting a conspiracy charge. Under U.S.C.
42 (1983), a person is guilty when they conspire together "acting under color

law"...ExhibL

16.

of

AQ,fl!,

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's
Watch.

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

SelectmanlChair, Gene Chandler, Petitioner re-alleges all the facts, here, and
circumstances detailed above. and states in furtherance. the followine:
That the duty of care owed Plaintiffs, by an Official (s): Selectman Chandler
and Selectman Garland, to Petitioner and, who is a citizen of the United States
of America and residing at 1455 route 302, Bartlett, New Hampshire: "The
Petitioner," 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. Garland
denying he blocked access to Petitioners two businesses and Exhibit no. 2
(two) page 9 line 20-23 (two years later, while under oath, Garland's
Deposition) where Selectman Garland states, emphatically, that he "yes" he did
throw or place the Boulders down, or had them thrown down, to blockade
Petitioners 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" Exhibit
no. 1a where Gene Chandler knows of the Boulders.
Selectman, Representative Chandler, knew his actions with Doug
Garland, 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 Rental
company in the entire United States takes a lot of guts.
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:
A

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 the
Selectman and Petitioner, Edward Furlong, around July 24th 2009; show the
Petitioner filing a civil complaint, regarding fighting for his Propefty's Access
Rights, 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 is
a license" between the Town of Bartlett and the Bartlett Water Precinct , to
support what we know as a, "Temporary Access Agreement", (here after
referred to as the, TAA), and offered by Selectman, Chandler, to support their
legal authority. To who's authority did they have in drafting the TAA in the first
place, 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 Exhibit
no;!, 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 the

Town Selectman/Representative to the House, State of New Hampshire, "Gene
Chandler." 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 the
Petitioner's Property, owned by the Bartlett Water Precinct. Here Chandler,
unequivocally, deposes and states: "None of the Selectmen" requested Stephen
Libby, to do research. Now if you please, see Exhibit no.Sa, letter from
Stephen Libbv, where Stephen Libbv states that it wss the Board of Selectmen
who 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. This
letter speaks volumes that Chandler ask the Libby's to join the conspiracy: to
do 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, in
furtherance of the Tortious Interference. And in furtherance, conspired to
oppress Petitioner and his businesses. Petitioner has two like-in-kind
businesses; 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's
deposition) page no., I6 line 1-23. By Selectman Garland conspiring with
Annette Libby, (Bartlett recreation director) and, Stephen Libby, and
SelectmanlChair,, Representative to the House, Gene Chandler, involving in
violating Petitioners property rights and the rights of Mr. Furlong, specifically
those 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 in

Bartlett, as a class vi road, or right of way (ROW), separating Petitioner's
property and the property, that of the Barllett Water Precinct; is malfeasance by
Representative, 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 the
defendants "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 the
authority to gate and bar a class vi road. Or authorize him to order his
employees to block Petition's access to his property. Attorney Cairns is only
stepping forward now with the truth because of the law suit that was just filed
via Petitioner's Temporary Retraining (TRO) Order, that issued out of Superior
Court 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 Process
Rights, as they pertain to that class vi road, or easement/ROW, or as the
violation of due process and, conspiracy to oppression, to false arest to assist
in the Tortious Interference, or the Violation of Constitutionally Protected, Due
Process, as it pertains to conspiracy or Oppression that is the Proximate Cause
for 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 the
Bartlett Water Precinct, Mathew Cairns, Deposes and States, "unequivocally,"
that there is a "Right of Way...." separating the Petitioner's Property, and
property that of the Bartlett Water Precinct. This is unconscionable, and
deliberate. This is now being asserted by the Barllett Water Precinct's attorney
because of the liability concern, I'm certain, after referencing Petitioner's
current "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 of
Law." This is wanton and Deliberate Act (s), Malicious, in its deepest roots,
and a slight by Representative, Gene Chandler, and this must be remedied by
this, Honorable "High" Court. Bill of Rights, defined, Article 2:
ooAll

men have certain

and 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 bv
the state on account, of race, creed. color, sex, or national origin."

COLINT V

5. COLTNT V RSA 629:3, "CONSPIRACY/DEPRIVATION" while acting

under color of Law: RSA 640 2 Conspiracy: purportedly acting under color of
Gene Chandler's Official Office, as Selectman, and Representative to the
House, "Did Conspire to Hurt" Petitioner, Edward C. Furlong, and his
businesses with co-conspirator, Annette Libby (Bartlett Recreation Director),
her husband Stephen Libby, Selectman, Doug Garland and Bartlett Police
Department's Acting Chief, Janet Champlin, to Conspire together, acting under
color of their Official, respective, Duties to Serve, not Take, to Damage
Petitioners Good Reputation and "Depriving" Petitioner their Fundamental Due
Process, under U.S.C. 42 (1983). Doug Garland, while perpetrating the
aforementioned offenses, Gene Chandler benefited by association, and is the
Proximate Cause to Petitioner's Injuries. When Representative Chandler
Perjured Himself, while under oath of Office, to Conspire, aiding Selectman
Garland's Intentional Tort, the lie to cover it up, against Petitioner, and their
Property Rights, as they pertain to the Constitution, as defined:

I. A person

guilty of conspiracy tf, with a purpose that a crime deJined by statute

be committed, he agrees with one or more persons to committ or cause the commision of
such crime, and an overt act is committed by one of the conspirators in furtherance of the
is

conspiracy.

Representativel Selectman Gene Chandler has Abetted and Conspired to

Abet, with Annette Libby, her husband, Stephen Libby, Bartlett police
Department, Acting Chief, Janet Champlin, and Doug Garland, to blockade
Petitioner's two businesses, that was Petitioner's Life Line on "The" class vi
Road, and the Ingress/Egress from the Petitioner's Property, as it relates to its
east side boundary, and the class vi roadway. See Exhibit no. le. This shows
selectmen Meeting Minutes, Memorializes, that the Bartlett Police Department
take 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 Prescribed
Easement, corroborate a charge of ConspiracylDeprivation, that have been
annexed to this case through the many legal briefs, Petitioners has filed
regarding, 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, to
Illegally Harass Petitioner, and "Detain" Petitioner to perform certain duties
against his will and denied any contact with the outside world. Gene Chandler,
Representative to the House, State of New Hampshire, and is the Proximate
Causation to Hurt Petitioner. The Police, Janet Champlin and
Representative/Selectman, Gene Chandler, Coerced and Defamed Petitioner
through intimidation, in the Presence of a Crowd of People, at Petitioners place
of Business and Home. Petitioner was coerced to abide by a differant law, not
the laws of New Hampshire, when Selectman Chandler told the Police to
Falsely Arrest Petitioneq Ed Furlong. These Deliberate Acts Defamed
Petitioner. Defendant (s) used Coercion to make Petitioner do things he did not
want to do; like getting in the back seat of a squad car to be transported to the
County Jail, where there are Real Criminals. Coerced to do things that are
contrary to things of Pleasure and life's Enjoyments. Instead the Defendant
Chandler was relaxed in his own home enjoying Life's Pleasures, and denied
Petitioner his. see Exhibit no. 4 page 2 line 5 Gene Chandler deposes and
states: ..." the Town could protect the Town's significant investment in the base
ball recreation park from damage by snowmobiles." These accusatory remarks
have no merit, they are used to make Petitioner look like a bad person. These
wonton, "Malicious Acts" by Gene Chandler, Representative, has Precipitated
huge amounts of mental anguish on Petitioner Furlong, and this is detrimental
and debilitating to Petitioners Health, Financial Welfare and Life in general,
and this has denied the Petitioner's Inherent Property Rights guaranteed
Petitioner, through the United States and New Hampshire Constitution, as far
back as the winter of 2008.

CONCLUSION

1.

On yet another "Instant/Intentional Tort," that Defendant

Representative, Gene Chandler, and Selectman, Garland, Annette Libby and her
husband, Stephen Libby, Perpetrated, against Petitioneq to collude to cause
Petitioner untold Harm, can be seen through a web-site Petitioners were
compelled to build, to fight this Malicious, Blatant,..Official Corruption:

w ww. b artlettc o ru upt io ns

uit.

w e b s. co

2.

A separate Memorandum of Law has not been filed because the

relevant 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 Selectman
Chair.

4.

Permanentlv Disqualifv in Perpetuitv, or Dismiss Selectman

(chairman) Gene Chandler, and enioin Bartlett Selectman Gene Chandler
from ever sitting in a Quaisi-Judicial or legislative setting in which Mr.
Chandler would be a normal Official-Participant, as a Selectmen, sitting a
meeting; where Mr. Chandler MIJST STEP DOWN regarding petitioner, or
Petitioner's Counsel, Edward C. Furlong III, or any other matter that presents
itself in the Bartlett, Selectmen's office regarding the undersigned, Petitioner's
Property or Businesses. Additionally, GRANT and Make Null and Void
anvthing with Selectman Chandler's name and signature on it; that has hurt
Petitioneg or Petitioner's Counsel, Edward C. Furlong III, within the Official
Tenor 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 Se

Box 447
Bartlett, NH 03812
ecfurlon 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, been
properly served through the Sheriffs Office, to Bartlett Selectman Gene Chandler at 56 Town
Hall 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., do

hereby declare that I have read the forgoing Petition and know of the contents thereof. With
respect to the matters regarding Starbrite Leasing; Gene Chandler's (Selectman) abetment to a
tortious lie, and dirty hands, to Selectman Gene Chandler and Representative to the House of
Representatives, State of New Hampshire. (Tortfeasor) Gene Chandler, lie to cover up the
Intentional Tort perpetrated against Petitioner, that are outlined in many, many legal briefs
before this Honorable Court; the video, submitted as Exhibit no. l, and 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 declare under the Pains and penalties of perjury that the foregoing is true and correct
and 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 HAMPSHIRE

CARROLL, 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 the
above was the truth to the best of my knowledge and belief.
i.

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