STATE OF NEW HAMPSHIRE

CARROLL, SS SUPERIOR COURT

Case No: 212-2015-CV-000 I 0

Starbrite Leasing, Inc., and Edward C. Furlong III

v.

Town of Bartlett, et al., and Bartlett Water Precinct, et al.

MOTION TO OBJECT/STRIKE DEFENDANT'S AMENDED ''ANSWER''

NOW COMES , Edward Charles Furlong III, (Individually), by andthrough, as President, for Starbrite Leasing, Inc., and Pro Se Counsel, forPlaintiffs, (hereinafter, "Plaintiffs").

Defendants.' Town of Bartlett, (Selectmen, Chandler, Selectman, Garland),employee, Bartlett recreation department, Annette Libby; The Bartlett WaterPrecinct, employees, Bob Blake and David Ainsworth, (hereinafteqDefendants) and in furtherance states the following:

SLMMARY OF FACTS

1. On March 20,2015 Attorney for the Bartlett Water Precinct, MathewCairns, and counsel for the Defendant, Bartlett Water Precinct, has submittedto the "Clerk" his "Answers" to the Plaintiff's Petition before this HonorableCourt titled: "Petition for Injunctive and Declaratory Relief and Damages."Exhibit 1 attached.

2. Exhibit 3 attached, Attorney for the Barllett Water Precinct, # 2, A PeterMalia, had showed an appearance for the Bartlett Water Precinct on February27,2014 and actually appeared at the hearing on March 4,2015 before this

Honorable Court, as well. The Plaintiff and counsel for the Bartlett TownSelectman, were also present at the hearing.

3. I received the Bartlett Water Precinct "Answers" through attorney Cairnson March 20th,2015.

4. On April 7th,2015, Plaintiff's receive an "Amended Answers" fromattorney, 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 WhiteMountain National Forest." Exhibit 2 attached

5. That statement is a "matter of substance,"(Superior Court rule:12)t, andshould be submitted bv motion to this Honorable Court by Defendant'scounsel.

6. Exhibit 4 attached, is a memo from Annette Libby, Bartlett recreationemployee to Defendant, former selectman, Doug Garland. This letter impliesmany different senerios that Plaintiff's feel that this Honorable Court shouldconsider 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." Thisinformation, or change in testimony is most substantial, in that it continues toshow the "profound deceit" by Defendants, and Defendant's counsel throughthis entire litigation.

7. Only after Plaintiff's counsel, Edward Furlong, highlighted this hugerevelation by attorney Cairns, to this Honorable Court, does attorney Cairnswant to "completely change his testimony "and now states: it "is not in fact aright of way." Does he want to change or modifu his testimony in his"Amended Answer" and submit it to the Superior Court Clerk, circumventingthe presiding Justice, or Honorable Judge, is Plaintiff's question. That,perhaps, Defendant's counsel Cairns talked with the other counsel involved inthis case; and the testimony that attorney, Cairns, wishes to change in an"Amended Answer" is submitted, by him, through the clerks office, is an error.Superior Court Rule 12.

8. Plaintiff is really "fed up" with this proliferation of a bunch of changed

I Rule l2 states: "Amendments may be made to Complaint or Answer upon the order of the court..."

testimony, lies under deposition, lies under affidavit andlor interrogatories.The general consensus by the two selectman, Chandler and Garland, is thatcross country skiers/activist will not co-exist with snowmobilers. 'So lets getrid of all the snowmobile businesses, or we'll die trying in our officialcapacities, attitude. That sounds very one sided by selectman Candler andGarland. They should not be hanging their hats at the Selectmen's office then.Plaintiff submits Exhibit 6 p.6 attached .

9. Letter to Investigator, Mr. Casey and Mr.Vara, Assistant AttorneyGeneral, at the New Hampshire Attomey General's office, they are currentlyworking on this problem I have. Exhibit 5 attached

10. Exhibit 6 attached, is a yet another suspect document concerning thelink between Annette Libbv's malfeasance, and former Selectman, Garlandmalfeasance.

WHEREFORE, Plaintiff, Edward C. Furlong III, and Starbrite Leasing,Inc., prays that this Honorable Court deny Defendants'Counsel submission ofa certain legal document, to the "Clerk of Court," titled: "Amended Answer ofBartlett Village Water Precinct" in reply to the within Complaint titled:Petition for Injunctive and Declaratory Relief and Damages, and

1. Order any further relief this Honorable Court deems just and proper.

Respectfully submittedStarbrite Leasing, Inc.,By and through it's Counsel,and it's President

Edward C. Furlong III, Pro SePO Box 447Bartlett, NH 03812

Certificate of Service

I herby certifr that a copy of the foregoing Motion has this 14 day of April, 2015, beenforwarded hrst class mail, postage prepaid, Chris Hilson, Bill Scott, Peter Maila andMathew Cairns, Esquire.

Edward C. Furlong 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

April, 2015, in North Conway, Canoll County, New Hampshire'

Edward C. Furlong III, Individually and,as President of: Starbrite Leasing, Inc.

STATE OF NEW HAMPSHIRECARROLL, SS

personally appeared before me, on this day of April 14th,2015, Edward C. Furlong, III,

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.

Notary Public/Justice of the Peace