Beruflich Dokumente
Kultur Dokumente
CARROLL,
SS
SUPERIOR COURT
Case
No: 212-2015-CV-000
I0
SLMMARY OF FACTS
Cairns, and counsel for the Defendant, Bartlett Water Precinct, has submitted
to the "Clerk" his "Answers" to the Plaintiff's Petition before this Honorable
Court titled: "Petition for Injunctive and Declaratory Relief and Damages."
Exhibit 1 attached.
2. Exhibit 3 attached, Attorney for the Barllett Water Precinct, # 2, A Peter
Malia, had showed an appearance for the Bartlett Water Precinct on February
27,2014 and actually appeared at the hearing on March 4,2015 before this
Honorable Court, as well. The Plaintiff and counsel for the Bartlett Town
Selectman, were also present at the hearing.
3. I received the Bartlett Water Precinct "Answers" through attorney Cairns
on March 20th,2015.
4. On April 7th,2015, Plaintiff's receive an "Amended Answers" from
attorney, Cairns, to amend line number 7 and contrary to his first answer,
states: "It denies that the right of way starts at route 302 and ends at the White
Mountain National Forest." Exhibit 2 attached
5. That statement is a "matter of substance,"(Superior Court rule:12)t, and
should be submitted bv motion to this Honorable Court by Defendant's
counsel.
6. Exhibit 4 attached, is a memo from Annette Libby, Bartlett recreation
employee to Defendant, former selectman, Doug Garland. This letter implies
many different senerios that Plaintiff's feel that this Honorable Court should
consider in a "certain light";....of the change of heart by Defendant counsel,
Cairns, stating in his first Answer, "that there is in fact, a right of way." This
information, or change in testimony is most substantial, in that it continues to
show the "profound deceit" by Defendants, and Defendant's counsel through
I Rule l2 states: "Amendments may be made to Complaint or Answer upon the order of the court..."
malfeasance.
1. Order any
Respectfully submitted
Starbrite Leasing, Inc.,
By and through it's Counsel,
and it's President
Edward C. Furlong
PO Box 447
Bartlett, NH 03812
III,
Pro Se
Certificate of Service
Motion has this 14 day of April, 2015, been
forwarded hrst class mail, postage prepaid, Chris Hilson, Bill Scott, Peter Maila and
I herby
certifr that
III,
Pro Se
VBRIFICATION
I, Edward C. Furlong, III, individually and as President of Starbrite Leasing, Inc., do
hereby declare that I have read the forgoing motion to Amend, and know of the contents
thereof. With respect to the matters regarding Starbrite Leasing, Inc.,, Libby's memo, the
above captioned case no. 212-2011-CV-00061, docketed in Carroll County Superior Court,
New Hampshire, the same is true to my knowledge except to those matters that are alleged
on information and belief; as to those matters, I believe them to be true.
I, Edward C. Furlong III, declare under the pains and penalties of perjury that the
foregoing is true and correct and that this declaration was executed on this l4th, day of
of April 14th,2015,
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.