THE STATE OF NEW HAMPSHIRE

CARROLL, SS. SUPERIOR COURT

Starbrite Leasing, Inc., Lil'Man Snowmobile Rentals, lnc.and Edward C. Furlonq lll

V.

Town of Bartlett, et al., Bartlett Police Department, et al.,Bartlett Village Water Precinct, et al., Bartlett Recreation Department, et al.,

and Carroll County Sheriffs Department, et al.

Docket No. 212-20 1 5-CV-00053

BARTLETT VILLAGE WATER PRECINCT. DAVID AINSWORTHAND BOB BLAKE'S OBJECTION TO MOTION TO CONSOLIDATE

The Bartlett Water Precinct, David Ainsworth and Bob Blake (collectively referred

to as the "Precinct") object to plaintiffs' motion to consolidate and say:

1. Plaintiffs seek to consolidate this matter with another of their cases, No.212-215-CV-032.

2. The Precinct is not a party to No. -032 which is focused on allegedmisdeeds by the Town of Bartlett and Gene Chandler.

3. This matter deals only with the arrest of Mr. Furlong and alleged, butdenied, physical contact between Mr. Furlong and Mr. Ainsworth.

4. While the "ball field" dispute is a common fact, the legal theories in thecases are sufficiently dissimilar as to make consolidation inappropriate. Further, tocompel the Precinct to participate in discovery as relates to -032 and Mr. Chandlerwould be unduly burdensome and be a waste of resources the Precinct cannot afford.

5. Contrary to Plaintiffs' conclusory statements, judicial economy andefficiency would not be served by consolidation.

WHEREFORE, the Precinct respectfully requests that the Honorable Court:

A. Deny this motion to consolidate; and

B. Grant such other relief as may be just.

Respectfu lly Subm itted

BARTLETT VILLAGE WATER PRECINCT,DAVID AINSWORTH and BOB BLAKE

By Their Attorneyst & GARTRELL, PC

Dated: July 9 2015R. Matthew , Esq. (#411)PO Box 1415Concord, NH 03302-1415(603) 228-1181

CERTIFICATE OF SERVICE(,n.'l t n ,\

I hereby certify that I have this date fonruarded via U. S. mail, postage prepaid, acopy of the foregoing to Edward C. Furlong, lll, Pro Se Piaintiff, William G. Scott,Esquire and Corey Belobrow, Esquire.

Dated: July 9, 2015R. Matthew Cairns, Esq. (ffa11)