I, Edward Furlong, do respectfully submit this addendum to the Petition to Reopen Case

No.: 08-E-0160 to this court. I would like to apologize to the court for submitting
information in two installments. I am overwhelmed with all the evidence and issues going
on in this case and I overlooked an incredibly important piece of information that I
believe the court will be able to use to see more clearly why this Petition and Motion
should be granted. I submit the following document to show this court how Doug
Garland’s behavior as a Bartlett Selectman has been biased and unfair towards me and
my businesses and how his conflict of interest should have precluded him from making
any decisions regarding me, my property and my businesses. Especially, this conflict of
interest and extreme bias towards me should have precluded him from not only taking
part in the TAA but from the design of the TAA. Doug Garland has used his position as
Selectman to further his financial and business interests and not the best interest of the
Town of Bartlett. Doug Garland has further used his position as Selectman to single out
Edward Furlong and LilÕ Man Snowmobile Rentals for abuse and has been working to
shut me down.

1. I spent 24 years completely secluded from normal society due to my inability to

function as a productive member of society while I was dealing with a prolonged bout of
alcoholism. I inherited alcoholism from my father and fought with the disease for many
years before I found my way back to society. For 24 years I remained disconnected from
society unable to achieve any level of success in life or with life. I was finally y parking
for the cabins located to the rear of my property, as seen in Exhibit 2. The GBR is the
only access to my cabins. Beginning as early as 1896 when the Sweets took title to the
property and through November 2008, member of the general public have accessed and
recreated on the forest floor (and after its creation in 1920, the White Mountain National
Forest) exiting at the rear of my property at the southeast corner by use of this public
roadway, the GBR. At the time I opened Lil Man Snowmobile Rentals in 1997 the GBR
was a part of the statewide snowmobile trail system. The snowmobile trails ran across
Route 302 and along the GBR and into the White Mountain National Forest following
what I submit is the right of way (GBR) referred to and in use since the conveyance of
the property from Alfred Stillings to Frank George dated October 12, 1878, as seen in
Exhibit 3. The plat states right on it, with right of way across said Stillings land through
the pasture at the southeast corner of my field. The public has been accessing the
multiuse trail system in the National Forest, via the GBR along the east side of my
property for as long as I’ve been in business. In the case of Breakers Motel Inc. et al v.
sun beach Montauk Two Inc. et al NY Supreme Court 2/13/1996 it was found that an
easement was created by a 1897 deed and a 1904 map that included language granting an
easement for access to a beach over the Defendant’s property. The Court further found
that since this easement was created it would remain forever and nothing that happened
subsequent would warrant the extinguishment of said easement. I too have a deed and a
map explicitly giving a right of way along the west side of the Water Precinct’s property
from the year 1878 included as Exhibit 3. Snowmobilers who are using the trails as well
as cross country skiers and snowshoers have stopped in to Lil’ Man to purchase gasoline,
candy, soda, water and maps. I have had many people over the years park in my front
public parking area and access the trails via the GBR for many purposes other than
snowmobiling such as walking their dogs, hiking, snowshoeing, exploring the White
Mountain National Forest and just for a picnic. I also have a lodging business on my
property located at 1455 US Route 302 in Bartlett New Hampshire, Abenaki Inn &
Cabins. Part of the rental units I use are the cabins located at the rear of my property.
These customers used this access to get to their rented/leased cabins by using the GBR,
with that access gone my customers are forced to park their cars in my front parking area
and hike in approximately 150 feet to their cabins with luggage and groceries. As Lil’
Man Snowmobile Rentals grew in fleet and reputation as a family friendly destination for
lodging and snowmobile rentals. I have employed more and more people, starting with 1
or 2 in 1997 to as many as 8 to 10 employees in previous years.

3. At the same time I began Lil’ Man Snowmobile Rentals, in the year 1997, a man down
the street, Doug Garland, opened a cross country ski business, Bear Notch Cross Country
Ski Touring Center, from his own cabin rental business, Mountain Home Cabin Rentals,
on his property. Doug Garland’s business mirrors mine with the one exception being that
he rents cross country skis and I rent snowmobiles. This competing business that is
owned and operated by Doug Garland (and his brother, John Garland) is located just ¼
mile from my property and shares the same trail system that Lil’ Man Snowmobile
Rentals uses but uses the direct access from his property to access the trails.

4. It was early in the winter of 1999 when Doug Garland made his first phone call to my
snowmobile rental office complaining that some trails in this multiuse trail system that
we both use are exclusive to his cross country skiers and I should keep my snowmobilers
off them. Doug Garland was referring to the spur trails that run from his property to the
New Hampshire Bureau of Trails primary multiuse trail system. I explained to Mr.
Garland that our current trail map we supply to our customers explicitly shows these
cross country ski only trails in question and these problems should not present
themselves. I even suggested that we put signs where these cross country ski only trails
leave the main trail system that prohibit snowmobile use so as snowmobilers would not
be confused. Customers will hopefully abide by these signs and these problems will not
occur in the future. Mr. Garland agreed with me and signs were posted on trees at the
point where Mr. Garland’s spur trails leave the multiuse trail system. Not long after this,
in March of 1999, another minor altercation occurred between Mr. Garland and me over
the phone regarding the cross country skiers clashing with snowmobilers on the trail
system. I am not even sure that the snowmobilers in question were even my customers
and we give very detailed directions regarding the map we provide and there are other
public points of access to this trail system. When he called me, Mr. Garland was furious
and extremely agitated that his cross country skiers were being annoyed by the noise and
smell on the trails created by snowmobiles. I assured him that it was not only my
customers using snowmobiles on these trails and that people wanting to snowmobile had
just as much of a right to use the multiuse trail system as cross country skiers but Mr.
Garland did not want to hear it. Mr. Garland would not share the White Mountain
National Forest trails with any snowmobilers if he had his druthers. It was at this early
juncture that I began to feel uneasy about the inability to share these trails with Doug
Garland’s cross country ski business after seeing his demeanor towards me and my
business and his apparent animosity towards snowmobiling in general. There did not
seem to be the healthy competitive relationship here, just a very angry man calling and
berating me and my snowmobile business. It seemed to me that Doug Garland considered
himself to be at war with Edward Furlong, Lil’ Man Snowmobile Rentals and
snowmobiles in general. “It’s only friendly competition” I would say to him but Mr.
Garland was not thinking in a business sense and was just so angry about the sharing of
trails. Mr. Garland just cannot bring himself to accept that these are multiuse trails which
means that everybody can use them. It is sad to think that cross country skiers and
snowmobilers can not coexist and enjoy the same beautiful trail system. Every year
thousands of bicyclists come to the White Mountains and bike the roadways in the area,
they get along fine with the motorists who come to see the same beautiful sights. If
everyone is respectful to the rules of the road/trail there is no reason that motorized and
non-motorized recreation enthusiasts cannot get along and enjoy the beauty of the area
and share the same space.

5. Doug Garland ran for and was elected to the Town of Bartlett Selectman’s Office in
March of 2000. Since that time he has also been the Selectman’s representative to the
Planning Board. While serving in that capacity as representative to the Planning Board
Doug Garland has used his influence to the favor of his own business interests, in
particular having the expansion of the trail system for the Bear Notch Ski Touring Center,
that Doug Garland owns, to be linked with those in the towns of Jackson and Intervale to
provide a larger regional trail network included within the “Master Plan” for the Town of
Bartlett. Another important item that was on Doug Garland’s agenda when he first took
office was a drafted piece of legislation for an ordinance to keep all new snowmobile
rental businesses who come to Bartlett from operating and denying an occupational
license without first going through the rigors of the ZBA (Zoning Board of Adjustment).
All other types of businesses can just seek the approval of the Selectman’s Office. Since
becoming a Selectman in March of 2000, Doug Garland has also used his position and
influence to issue me violation after violation for my property and business and has
illegally used his office to pass ordinances and make deals that benefit his businesses and
hinder or shadow mine.

6. Doug Garland has always shown at the very least a conflict of interest but it is more
than that. Mr. Garland has never entertained stepping down at Selectman meetings when
issues were brought up regarding me, my property or my businesses (Lil’ Man
Snowmobile Rentals and Abenaki Inn & Cabins) even though we were having personal
problems with our businesses and that we were in direct competition and obvious conflict
with one another. Mr. Garland’s decisions through the Bartlett Selectman’s Office have
been clearly biased against me. For example, in 2008 I applied for what they said was the
wrong type of permit to paint, shingle and replace rotten wood on one of my cabins. The
Selectmen, fueled by Mr. Garland’s conflict of interest, found fault with the type of
permit and the drawing I supplied for the work to be done. At Doug Garland’s insistence
this violation was pursued through the local state court system, see Exhibit 4, the
violation issued to me by the Bartlett selectmen regarding my cabin. The Judge in this
case found in my favor at the first hearing and when Doug Garland still found it
necessary to pursue this matter, at the added expense to the taxpayers of Bartlett, further,
Judge Albee ruled in my favor a second time on this matter. As seen in Exhibit 5, Judge
Albee’s Order on the Motion to Reconsider her first ruling, which was in my favor. To
further show that Doug Garland was singling me out for abuse, I submit Exhibits 6 and 7.
Exhibit 6 is a permit application submitted by Doug Garland’s mother in 2004 to rebuild
and expand one of his rental cabins that had burnt completely to the ground and Exhibit 7
is my permit application. Of course his permit was approved by the same Selectmen that
he sits with in the Selectman’s Office even though his drawing was poor to say the least
and he was rebuilding and expanding an entire burnt cabin and not fixing one up like I
was. Although our applications are almost identical, the inequity lies in the way these
applications were received by the Selectman’s Office. The Garland application was
approved without question and the Selectmen took my lack of proper application twice to
state court and finally to the Supreme Court where it ultimately rests, this matter alone
has exhausted my legal fund. This is more corroboration to the fact that Mr. Garland is
using his office for his betterment and to the detriment of my businesses. I would
frequently request that Mr. Garland step down when issues involving Edward Furlong or
Lil’ Man Snowmobile Rentals arose, I would ask him why he wasn’t stepping down but
never received a satisfactory response. Doug Garland has stepped down as a selectman
for other issues dealing with snowmobiles as seen in Exhibits 21, 22 and 23, but never for
me or Lil’ Man Snowmobile Rentals as seen in Exhibit 27. Exhibit 21 is the selectman
meeting’s minutes dated January 16, 2004 and describe Doug Garland stepping down as
selectman to address the meeting as the owner of Bear Notch Ski Touring Center. Exhibit
22 is the selectman meeting’s minutes dated February 6, 2009 and describe Doug Garland
stepping down as selectman to address the meeting as owner of Bear Notch Ski Touring
Center. Exhibit 23 is the selectman meeting’s minutes dated January 8, 2010 and describe
Doug Garland stepping down as selectman to address the meeting as owner of Bear
Notch Ski Touring Center. Exhibit 27 is the selectman meeting’s minutes dated
November 7, 2008 and describe me explaining that Doug Garland has a conflict of
interest with his cross country ski business and yet Mr. Garland still does not step down.
As these exhibits show Doug Garland is more than willing to step down and address
issues that he feels are of concern to his business and his own financial interest, yet he
has never stepped down with regards to me, Lil’ Man Snowmobile Rentals or Abenaki
Inn & Cabins. Mr. Garland feels that he can endeavor in his capacity as selectman to shut
me down with no consequences and as shown with these exhibits is not treating me fairly
or as he treats other competing businesses. This conflict of interest alone makes me feel
slighted by the Selectmen and the Town of Bartlett. In 2010 Mr. Garland recused himself
from a highly publicized Selectman’s meeting regarding snowmobile issues, see Exhibit
8, a computer printout of a Conway Daily Sun article detailing Doug Garland stepping
down from a Selectman’s meeting. This meeting was regarding a new snowmobile rental
company, a competitors of mine, Northern Extremes run by Peter Gagne who had just
moved to town in 2005. I felt a slap in the face by Mr. Garland as this action because I
had been asking him for years to recuse himself and now he recuses himself for my
competitor but not for my business that has suffered tremendous damage from having
frivolous violations sent to my home and my business. Not to mention the detriment to
come in regards to litigating to “save myself” and my businesses. This was a huge blow
to my own integrity and my self-worth as a resident of Bartlett, a businessman in Bartlett,
a citizen of the United States of America and as a human being.
7. In February 2002 I received a frantic phone call from one of my customers. These
particular customers were not on designated cross country ski only trails but rather they
were on railroad bed tracks up towards Bartlett Village proper and are part of the New
Hampshire Bureau of Trail’s snowmobile trail system zoned as multiuse trails. My
customers were agitated and distraught and told me that someone in a groomer (it was
John Garland, Doug Garland’s brother) had stopped them on their snowmobiles and
became belligerent and abusive towards them telling them that, “you don’t belong here,
I’m chaining these sleds up and you can walk back to Lil’ Man and tell Ed Furlong to
keep his sleds off our land”. John Garland literally made my customers get off their
machines and he used a length of chain he pulled from his Sno-Cat to chain my
snowmobiles together so that they could not be driven. I know that the Garlands do own
large tracts of land in Bartlett and that trails on this land are off limits to snowmobilers
but these railroad tracks that John Garland detained my customers on are actually part of
the New Hampshire Bureau of Trails snowmobile trail system and not on Garland land. I
know this because I had to go unchain my sleds and pick them up, so I know exactly
where they were. The location of the chained snowmobiles is seen on Exhibit 25, the
White Mountain Trail Club’s snowmobile trail map. I did call the police and stated that I
wanted to have John and Doug Garland arrested for whatever charge was applicable for
what he did. The chief of police in Bartlett, Tim Connifey, called me about 2 hours later
telling me that he was going to do nothing and no crime took place. I was not only totally
livid at this point but was taken aback as what to do or what recourse was available to me
to have this situation remedied. I asked Tim Connifey to at least file a report so there
would be some evidence of what John Garland did. I have been trying repeatedly to
obtain this document from the police department with no results to date. Exhibit 9 is a
copy of 2 emails that I sent to Police Chief Tim Connifey on October 17 and November
13 of 2010 where after repeatedly trying to get him to return my phone call I ask him
again to try and find the information regarding John Garland chaining my snowmobiles
up.

8. Another example of Mr. Garland’s bias towards me is shown in the setback violations I
started receiving in the summer of 2005, see Exhibit 10. These setback violations show
interesting and compelling evidence of Mr. Garland’s bias towards me and anything I
own. In 2005 I purchased the property (1467 US Route 302 in Bartlett, New Hampshire)
directly to the west of my existing property at 1455 US Route 302 in Bartlett, New
Hampshire that had previously belonged to Mr. Don Ryder. The Town allows for a 25
foot setback from every property line as green space, there is nothing to be placed in this
green space set back. Mr. Ryder had for many years stored junk VW busses directly
along the property line between his property and mine and received no setback violations
from the Selectman’s Office, see Exhibit 11, a picture showing Mr. Ryder’s VW busses
right on the property line between his property and mine. I purchased the property at
1467 US Route 302 in 2005 and almost immediately began receiving setback violations
for storing my snowmobiles along the line separating my two properties. Please allow me
to point out that Mr. Ryder was storing equipment along the property line for many years
when I and the previous owner of this property owned it and received no violations but
when I stored equipment along the property line when I owned the property on both sides
I received numerous setback violations. These violations were all signed by Doug
Garland, the same man who has been verbally abusive towards me over the phone and in
person regarding his problems with my businesses, my customers and me as an
individual. I would also like to point out that Doug Garland and the Town of Bartlett had
no qualms about violating their own setback ordinances by placing rocks, logs, boulders
and fences along the property line between my property and the Water Precinct property.
They placed these unsightly barriers directly along the property line with no thought to
their own setback and green space rules.

9. Mr. Garland has also been working with Terry Miller, District Ranger for the USDA
Forest Service on a land exchange deal that encompasses all the bias and conflict of
interest that I have been showing. In 2004 Doug Garland came up with the idea of this
land exchange between the Town of Bartlett and the USDA Forest Service, see Exhibit
12, Bartlett Selectman minutes from October 19, 2004. This land exchange would entail
the swapping of land directly behind my property (south side) owned by the USDA
White Mountain National Forest for some land owned by the Town of Bartlett up off
Allen Road. This land exchange would benefit Mr. Garland by giving him complete
control over the back of my property and with no other meritorious reason for this
exchange to either party, I have to conclude that this deal was to give Mr. Garland further
means to oppress me and Lil’ Man. An acquisition of such peculiarity only illicit
suspension in my mind that Mr. Garland has no reason to pursue this deal other than
another attempt to shut Lil’ Man down for good. This deal would deprive me of my
freedom to even enter the National Forest again from the rear of my historical property. I
find this land exchange to be one of the most blatant and transparent attempts by Mr.
Garland to shut me down and one of the most obvious examples of Mr. Garland’s
complete bias against me and my businesses. Doug Garland wants this land exchange to
go through so he can permanently shut down my access along the GBR and also leave the
GBR closed forever to the public. To further show the mindset of Doug Garland and the
Bartlett Selectmen regarding the land surrounding my property I submit Exhibit 13,
Selectman meeting minutes from June 17, 2005. In these minutes Bert George,
commissioner at the time for the Bartlett Water Precinct, states that there is very little
interest in the ball field anymore. In fact, there was nothing on this field except a pitchers
mound and baseball diamond, there were no fences, no sheds, no anything. This opened
the door for Selectman Chandler to suggest that the Water Precinct just give it (the ball
field) to the Town of Bartlett. I submit that this was the idea all along, for the Town to be
in control of all the land surrounding my property so they could shut down Lil’ Man
Snowmobile Rentals for good. There are plenty of existing fields and a baseball field at
Josiah Bartlett Elementary and Middle School, the Town did not need another field. If the
Town were to gain control of the ball field through the Water Precinct and the land
behind my property in the land exchange deal with the USDA Forest Service they would
have complete control over my property and my access to the White Mountain National
Forest, including the New Hampshire Bureau of Trail’s snowmobile trail system.
Shutting down Lil’ Man did not happen exactly this way but the land exchange deal and
the minutes from June 17, 2005 show the mentality of the Selectmen, mainly Doug
Garland, as they attempt to “gain control” of my access to my property and the
snowmobile trails.
10. Mr. Garland has used his position as Selectman to collude with the Bartlett Water
Precinct to shut down my access to the GBR. The Bartlett Water Precinct has an
agreement with the Bartlett Recreation Department to use and maintain (i.e. sow, seed,
erect fences and mow when necessary) the Baseball Field and the Selectman’s Office
controls the Recreation Department. Doug Garland was strategic in bringing in a new
Recreation Director, Annette Libby, from out of town (Madison, New Hampshire) who
before I even met her had already been poisoned by Doug Garland against Edward
Furlong and Lil’ Man Snowmobile Rentals. Annette Libby and her husband Stephan
Libby have been documented sneaking around my property near dark and taking pictures
of my property. Stephan and Annette Libby submitted these pictures to Doug Garland in
the Selectman’s Office and said pictures were used against me in the cabin case that
Judge Albee found in my favor referenced previously. Please see Exhibits 14 and 15.
Exhibit 14 is 2 letters from Annette and Stephan Libby in which they detail exactly what
I am accusing them of, sneaking around my property and taking pictures. Stephan even
says in his letter that he is writing it at the request of the Bartlett Selectmen. As seen in
Exhibit 16, a listing of the licensed appraisers and surveyors for the state of New
Hampshire, Stephen Libby is not on either list. Mr. Libby had absolutely no business or
legitimate reason to be observing my property or walking the boundary lines and the
Bartlett Selectmen had absolutely no right to ask him to do so. Doug Garland recruited
the Libby’s to do his dirty work and they willingly went along with him and violated my
right to privacy. The Recreation Director and her husband, who holds no position with
the Town of Bartlett or relevant position with the State of New Hampshire, have
absolutely no legitimate interest or business in building permits, researching titles and
deeds, and work being done to a cabin on my property. The only possible reason that they
would sneak around and take pictures of such work would be at the bequest of Mr.
Garland since Annette Libby can pretend that she is in the Ball Field on legitimate
business. I had never met this woman when she was taking these pictures and she had
absolutely no reason to dislike me as we had had no interaction as of yet. This situation
involving Annette Libby is just another example of how Doug Garland used his position
as Selectman to not only influence others to dislike me and work against me but to
actually bring individuals in from out of town who he could indoctrinate or proselytize to
work with him on these matters. Doug Garland even brought Stephan Libby onto my
property to do what appears to be taking measurements but since Stephan Libby is not
licensed in the State of New Hampshire for such duties I am unsure as to what exactly he
was doing on my property as seen in Exhibit 24. Mr. Garland actually persuaded the
Recreation Director to break the law under 18 U.S.C. section 241 which states, Òif two or
more persons conspire to injure, oppress, threaten, or intimidate any person in any State,
Territory, Commonwealth, Possession, or District in the free exercise or enjoyment of
any right or privilege secured to him by the Constitution or laws of the United States and
under color of law as defined by 18 U.S.C. section 242, “include acts not only done by
federal, state, or local officials within the bounds or limits of their lawful authority, but
also acts done without and beyond the bounds of their lawful authority, provided that, in
order for unlawful acts of any official to be done under color of law, the unlawful acts
must be done while such official is purporting or pretending to act in the performance of
his/her official duties”. Doug Garland and Annette Libby broke both of these laws while
working together to spy on my property and my actions.
11. Mr. Garland has used his influence over the Recreation Department and in turn the
Bartlett Water Precinct to seek out a solution to the obstacle of Lil’ Man Snowmobile
Rentals that is hurting both his cross country ski business and his cabin rental business.
The Bartlett Water Precinct has gone against its own ordinances regarding right of ways
in shutting down the GBR and performed acts that are not normal or standard procedure
and deny both me and the public due process. Doug Garland influenced the Bartlett
Water Precinct to close the GBR without public comment or forum to be heard. Due
process, proper procedure and the public’s interest were totally ignored by Doug Garland
and the Bartlett Water Precinct and left me with no recourse or viable remedies. The right
of way over the GBR was a perfect example of the Water Precinct’s own definition of a
right of way as seen in Exhibit 17, until Doug Garland orchestrated the change of the
definition of a right of way in the ordinances in 2008 to diminish my asserted rights over
the GBR as seen in Exhibit 18. Doug Garland has deleted language, namely deleting the
description of a right of way as ‘any private way used as a means of access to two or
more residential, institutional or commercial buildings’ in the 2008 amended ordinances
to better his position against me because this definition clearly describes the access to my
4 cabins at the rear of my property. Doug Garland and the Water Precinct disregarded this
ordinance by closing off the GBR first with rocks, boulders, logs and finally a 6 foot
wood fence, leaving no doubt about the detriment that would befall me and my
businesses. There is no useful purpose in fencing off the GBR, nobody is benefited by
this fence except Mr. Garland for whom this is just another step in the total annihilation
of Lil’ Man Snowmobile Rentals and Edward Furlong. This is an unnecessary fence and
costs the taxpayers, of which I am one, money that could be used for other productive
items not just Mr. Garlands benefit. Doug GarlandÕs conflict of interest with me and his
actions through the Selectman’s Office have resulted in unfair treatment of me and my
businesses. The Town of Bartlett and Bartlett Water Precinct have bowed to Doug
Garland and allowed this conspicuous and wanton behavior to continue unabated.
Richard v. Good Luck Trailer Court, Inc., 157 NH 65,70 (2008) says that in every
agreement there exists an implied covenant that each of the parties will act in good faith
and deal fairly with each other. That covenant is breached if the defendant behaved
inconsistently with common standards of decency, fairness and reasonableness and with
the parties’ agreed upon purposes and justified expectations. The defendants in this
matter have never acted fairy with me or treated me with any level of decency or good
faith. As this document lays out, Doug Garland has actually done the opposite, he has
purposefully and knowingly been indecent, unfair and unreasonable with me.

12. Doug Garland has a clear pecuniary interest is closing down Edward Furlong and Lil’
Man Snowmobile Rentals and Abenaki Inn & Cabins. Not only does closing the GBR
hurt me financially, the placing of boulders and fences along the GBR benefits Doug
Garland, Bear Notch Ski Touring Center and Mountain Home Cabins with financial
prosperity in the instant. The moment access to Abenaki Inn & Cabin’s cabins was
blocked Doug Garland must have seen an increase in revenue from his cabin rentals.
With Lil’ Man Snowmobile Rentals access blocked there are less snowmobiles on the
multiuse trails and Doug Garland can use that in his advertising for Bear Notch Ski
Touring Center and increase business by telling people that the snowmobilers will be less
of a bother to the cross country skiers. Doug Garland has used his position not only to
shut Lil’ Man down but to increase or augment the cross country ski trail system
experience in the area to financially benefit himself and his business, this is shown in
Preston v. Gillian, 104 N.H. 261 which states a public officer is disqualified if he has a
“direct personal and pecuniary interest” and the interest must be “immediate, definite and
capable of demonstration; not remote, uncertain, contingent and speculative, that is such
men of ordinary capacity and intelligence would not be influenced by it” as seen in
Atherton v. Concord. Mr. Garland should not and can not be allowed to continue to break
the rules and maliciously manipulate the Town and Water Precinct and Recreation
Department to his own financial betterment.

13. Based on all these documented incidences of Doug Garland’s bias towards me and
Lil’ Man Snowmobile Rentals and his clear conflict of interest with his businesses I beg
this court to allow this Petition to Reopen Case No.: 08-E-0160 and grant the Motion to
Vacate the Temporary Access Agreement. For Mr. Garland to have a hand in the
architecture of the TAA only allows him to continue to perpetrate his intense dislike of
me and snowmobilers. As long as this TAA remains in place my hands are bound to
pursue to what rightfully belongs to both me and the public. Mr. Garland has repeatedly
shown that he can not deal with me in a fair and impartial manner. Mr. Garland has acted
in such a manner as to not allow me any due process in the closing off of the GBR. I find
it reprehensible that a Selectman working in his official capacity would act in such a
corrupt manner as to further his own personal interests and vendettas and financial gain.
Doug Garland has abused his official position as Selectman and I am appalled by his
actions against me. I believe that he should be held to a higher standard than ordinary
citizens because he is in a position of authority. Were Doug Garland just a businessman
in the town of Bartlett I would have no recourse against him other than to do legitimate
business maneuvers to try and outwit him; however, Mr. Garland has chosen to be in a
position of authority and he has chosen to use that position for the betterment of his
businesses and he must be held accountable for those actions. I have actually done
nothing to Mr. Garland or any of the other individuals named in this document,
absolutely nothing to deserve this treatment I am receiving. Mr. Garland has his opinions
about me and he is entitled to them, however when these opinions spill over into his
official duties and he uses his position to advance these opinions to others and use these
opinions to manipulate procedures and ordinances, that is misconduct and conflict of
interest and contrary to the common law of the land and common decency.

14. To show the caliber of Selectman sitting with Doug Garland of the Board of
Selectmen, I submit Exhibits 19 and 20. The other 2 selectmen are Jon Tanguay and
Gene Chandler. Exhibit 19 is an article from the Conway Daily Sun detailing Jon
Tanguay’s arrest for child pornography, his previous settlement with another boy for
sexual abuse and his current romantic relationship on MySpace with a local high school
boy. Exhibit 20 is a Special Report to the Speaker of the House of Representatives
Regarding Complaint #2004-2 in which Gene Chandler is recommended to be expelled
from the House of Representatives for his Ethics Guidelines violations. These 2 men and
Doug Garland are the people who constructed the TAA and over the last decade have put
me in the position I am currently in, complete financial ruin and on death’s doorstep from
the stress. These are the men, unethical as they are, who have forced me out of business
and taken almost everything that I value from my life. These men should not be sitting in
the Selectman’s Office, they have proven themselves unworthy and unfit for public office
through each of their own despicable actions. I urge this Court to see the intricacies of
this case, to see how this has all played out, and override these unethical, illegal men and
grant this Petition to Reopen Case # 08-E-0160 and grant this Motion to Vacate the
Temporary Access Agreement.

15. I also submit to this Court that I have filed a civil rights complaint with the United
States District Court, District for New Hampshire naming Doug Garland, Annette Libby,
Terry Miller, the Town of Bartlett and the Bartlett Water Precinct as defendants. This
case was filed October 5, 2010 and has been given Case No.: 1:10-cv-453-JD and is
available to view on ECF through the Federal Court’s website.

16. I also submit to this Court Exhibit 26, a letter from Attorney Cooper to me dated
December 11, 2009 in which he declines my request to file a Motion to Reconsider with
this court and appeal to the Supreme Court. I asked Mr. Cooper to do both of these things
and even though he remained my attorney, he would not comply with my request. I
submit that this is another example of how Mr. Cooper let me down as an attorney. In
order to continue with this case the proper procedures must be followed and the next step
for an appeal to the Supreme Court is a Motion to Reconsider. I wanted very much to
proceed with this case and as this document proves, I have a plethora of evidence to back
up my allegations. Mr. Cooper denied me a chance to fight for my rights by refusing to
file a Motion to Reconsider and although I subsequently filed the motion pro se, due to
my lack of experience it was unsurprisingly denied. Mr. Cooper basically gives up and
refuses to move forward with my case.

I would like to reiterate my apologies to this Honorable Court for failing to file all
relevant information together in the initial pleading. I also would like to again tell this
Court that I am not grandstanding with this case, I believe very strongly that I have been
mistreated and that Doug Garland and the other Selectmen and individuals named in this
document are all responsible for their actions and should be held accountable for their
malfeasance. If it were not for the actions of these individuals I would not be in the
financial position I am now and would have funds available to retain proper counsel for
this matter. I apologize for any deviations from proper procedure with this document and
ask this Court’s forgiveness for any mistakes made herein.

Respectfully Submitted,

___________________________, Pro Se
Edward C Furlong III, Pro Se
1455 US Route 302
Bartlett, NH 03812
(603) 387 9014
EXHIBIT LIST
1. Front cover and relevant page from Aileen M Carroll’s The Latchstring Was Always
Out: A History of Lodging Hospitality and Tourism in Bartlett, New Hampshire.

2. Cesspool sketch dating 1926.

3. Plat of my property located at 1455 US Route 302 Bartlett, New Hampshire showing
the right of way.

4. Violation issued from Bartlett Selectmen for cabin work I did.

5. Judge Albee’s order on the violation for cabin work I did.

6. Jean Garland’s permit application for Doug Garland’s cabin that burnt to the ground.

7. My permit application for the cabin work I did.

8. Article from the Conway Daily Sun describing Doug Garland stepping down as
Selectman for snowmobile meeting regarding Peter Gagne.

9. My emails to Tim Connifey attempting to get information regarding John Garland

chaining my snowmobiles up.

10. Setback violations from the Bartlett Selectmen for having snowmobiles on my
property line.

11. Picture of Don Ryder’s VW busses on the property line.

12. Minutes from Bartlett Selectman’s meeting dated October 19, 2004 regarding the land
exchange.

13. Minutes from Bartlett Selectman’s meeting dated June 17, 2005 regarding the
Baseball field.

14. Letters from Annette and Stephan Libby.

15. Pictures of my cabin that Annette Libby took through the trees.

16. Computer printouts from the databases containing all licensed appraisers and
surveyors for the state of New Hampshire.

17. Bartlett ordinances predating 2008.

18. Bartlett ordinances dating after 2008.

19. Article from Conway Daily Sun regarding Jon Tanguay’s arrest for child
pornography.

20. Special Report to the Speaker of the House of Representatives Regarding Complaint
#2004-2, Gene Chandler’s charges from violating the Ethics Guidelines.

21. Bartlett Selectman meeting minutes dated 1/16/04.

22. Bartlett Selectman meeting minutes dated 2/6/09.

23. Bartlett Selectman meeting minutes dated 1/8/10.

24. Picture of Doug Garland, Stephan Libby and Bert George on my property.

25. White Mountain Trail Club’s snowmobile trail map.

26. Letter from Attorney Cooper dated December 11, 2009.

27. Bartlett Selectman meeting minutes dated 11/7/08.

Also included with document are Exhibits 28-32, 5 pictures of the GBR and its relation to
my property for the benefit of this Court as it may be unfamiliar with the layout of the
land in these issues. These pictures have all been sent to the defense attached with
previously submitted documents and are not included with this document.

28. Picture taken from US Route 302 of the GBR.

29. Picture of the GBR with gate.

30. Picture of rocks, boulders and logs blocking my cabin access from the GBR.

31. Picture of the log blocking access to my cabins from the GBR.

32. Picture of the front of my property, the Abenaki Inn with the ball field in the
background.

NEW HAMPSHIRE SUPERIOR COURT

CERTIFICATE OF SERVICE
I, Edward Furlong do hereby certify that this document was served to Attorneys Cairns
and Scott and Douglas Mansfield via certified USPS mail on December 20, 2010.

_____________________________, Pro Se
Edward C Furlong III, Pro Se
1455 US Route 302
PO Box 447
Bartlett, NH 03812
(603) 387 9014