STATE OF NEW HAMPSHIRE

CARROLL,

SUPERIOR COURT

SS

Case

No: 212-201 5-CV-00032

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

V.

Gene Chandler. Selectman

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OBJECTION TO DEFENDANT'S EMERGENCY MOTION TO ORDER PRODUCTION OF

EXHIBITS AND PLAINTIFF''S MOTION TO SANCTION ATTORNEY CHRIS HILSON

NOW COMES , Starbrite Leasing, Inc, and Edward Charles Furlong III, by and
through, as President, for Starbrite Leasing, Inc., and Pro Se Counsel for Petitioners,
(hereafter, Petitioners) and in his Pro Se capacity request this Honorable Court Deny
Defendant's Emergency Motion to Order Production of Documents, Order, and in
support of Plaintiffls OBJECTION; Plaintiff's states the following herein,

Verified Statement of Facts

1.

On or about May 3Oth,2015 I received a motion from attorney Chris

Hawkins who is representing Plaintiff's former attorney Randall Cooper regarding an
ongoing litigation (Legal Malpractice) and separate Supreme Court case no. 2014-0113.
See Exhibit no.1 attached: "Motion to Clarify Plaintiff's Supreme Court filings."

2.

Exhibit no. 1a sttached Carroll County Superior Court's Order, is an order

issued out of this Honorable Court dated Mav 1 Lth.2015. this Court Order dissolvins
Petitioner's TRO.

3.

On June 3rd,201 5 a status hearing was held to determine the specifics and
parameters of case no.212-2015-cv-00032,Edward C. Furlong et al v. Gene Chandler.

4.

On this day of June 3rd,2015 at this status hearing, Plaintiff's ask Chris
Hilson after the hearing was adjourned if it was he who sent attorney Chris Hawkins the
May 1lth Order Denying Petitioner's TRO and Petition no. 212-2015-cv-00010 to use
against Petitioners. Attorney Chris Hilson confirmed it was he who sent this to Chris
Hawkins. He then stated he didn't think there was any harm done "since it's public
record." Well it's not public record until the last motion that was entered by Petitioner
(motion to reconsider) is ruled on. Attorney Randall Cooper, is a defendant in one case
and co-defendant (beside Petitioner) in another case, complexing for this Honorable
Court,...Petitioner realizes, and Petitioner Furlong wants to thank this Honorable Court
for it's invaluable time to this matter.

5.

Petitioner's are still litigating against Plaintiffs former attorney, Randall

Coopeq for his malpractice; against his attorney, Chris Hawkins, of Nelson Kinder +
Mosseau, PA. This lawyer, Hawkins, has been conversing and exchanging very
sensitive/private documents with Chris Hilson. Chris Hawkin's client Randal Cooper, is
a Trustee Defendant in this case here in this Honorable Court, case no. 212-2013-cv097;but it's Chris Hilson, the defendant's (Bartlett Selectmen) attorney in this case that
has been soliciting Chris Hawkins , not Chris Hawkins soliciting Chris Hilson; this trial
Court's Order dated May I 1,2015 denying Petitioner's TRO, now in the hands of this
attorney Chris Hawkins, now turns the tables adversely for Petitioners because he
gained a legal document that in it's very essence is adverse to Petitioners. This
professional misconduct could potential torpedo Petitioner's case in the Supreme Court
in favor of Randall Cooper, under their rule 1 1, Petition For Original Jurisdiction that
Petitioners have docketed there.

6.

For attorney Hilson to take the Superior Court Order dated May 1 |th,2015
that's unequivocally, adverse to Petitioners, and hand delivering it to an attorney (Chris
Hawkins) on no less a silver platter, who is a co-defendant along side Petitioners in one
case involving an attachment on Petitioner's cabin rental business, and defendant's sit
opposite to Plaintiff's in the malpractice case. Hawkins will no doubt use that Superior
Court Order as seen in Exhibit no 1a attached against Petitioners in there appellate brief.
This is yet a third tort against Petitioners from the Bartlett selectmen, vicariously
through their attorney. Suffice it to say not as what tort is the most caustic. This act has
the potential to seriously cripple Petitioners financially. Petitioners stand to lose I .6
million dollars if when the Supreme Court Justices review/rule that that Court Order
from Hilson to Hawkins might very well be the straw that broke the camels back. This
has seriously injured Petitioners chances at the Supreme Court referencing the Rule l1
Petitioners have docketed. Chris Hawkins and Plaintiff Furlong are curently battling for
a elevated position with this case,..to it's finish; but now Defendant's counsel Chris

Hilson is working tangent (helping) with this other attorney's case to hurt Petitioner,
this is some serious ethic violations here. This is wrong as a matter of professional
conduct flying the coop.

7.

This is a direct violation of the rules governing professional conduct pursuant

to rule r.7 and 4.1; see conflicts in litigation Exhibit no. 2, pase 6 paragraph 24.

8.

This is just another occurrence of total disregard by attorney Hilson to the

professional ethics that guides attorney's towards the correct judicial path. Seems like
attorney Hilson gets enjoyment with his flirtations with a contempt of court sanction,
and always getting away with it, because he retards the deception with a professional
clean-cut appearance. That does not cut it with this Petitioner. Petitioners are asking this
Honorable Court to see the seriousness of this last episode of deceit here in this
Honorable Court and sanction attorney Hilson with an appropriate fine. Petitioner's plan
on filing ethic charges against attorney Hilson at their earliest opportunity, for whatever
good that it will do, is highly debatable.

9.

Plaintiffs are litigating

a major case up in New Hampshire Supreme Court

against their former attorney, Randall Cooper and Cooper Cargill and Chant, PA.; and
Plaintiff's have a huge financial interest in that case's outcome, of course. The Order
dated May I lth,2015 is technically still an open case with several motions entered for
this Honorable Court's review (Motion for Reconsideration, and others). Petitioners are
planning to file a Supplement to the Motion to Reconsider the Courts ruling on May
llth,2015. Petitioner would like to submit THEE SMOKING GLrN of all smoking
guns; enter Exhibit no. 7 attached: selectmen meeting minutes where selectman Gene
Chandler steps down when a comment about snowmobiling: that [chandler] he "can't
believe that this snowmobile business is going to lower the values in the area..."2
a. Please see exhibit no. 3 attsched

10.

According to the NH Bar Rules of Professional Ethics attorney Chris Hilson

was prohibited from divulging this Court Order to a defendant attorney; that severe
information in the Court Order, dated May 1 I, 2015 now prejudices petitioners case in

'

Petitioner's just uncovered this huge smoking gun (selectmen meeting minutes); Petitioners will be requesting this Court to
toss the TAA, Crant the Roadway, Remove the unsightly Fence; RECONSIDER this Courts ruling dated May I lth, 2015,
quashing movant's Petition for "lnjunctive and Declaratory Relief and Damages,"....now, this Honorable Court can base this
reconsideration on all the incomingmaterial facts and exhibits to case number 212-2015-cv-000t0. There is no res judicata
here but a heap of constitutional violations taking over the stage, with acts committed intentionally to commit murder by tort.
Order Statutory Damages to Petitioners.

the New Hampshire Supreme Court, to an attorney who Petitioners are still litigating
against by fault of the Bartlett selectmen. This has gone too far. This needs to stop.
Petitioner's have stated to this Court several times about half-truths by attorney Hilson
and ask that he be sanctioned earlier. Now is the time. Your Honorable Court.

l.

By attorney Hilson faxing, emailing or sendin gthat Superior Court Order to

attorney Chris Hawkins, to fortiSr his defenses in his appellate case, attorney Chris
Hilson, defendant's attorney, instantly injured Petitioners. That is a huge defense
mechanism for Hawkins to show the Supreme Court, the Order Denying Plaintiff s TRO
because the whole case against Cooper is whether or not he should of filed and
emergency TRO for his then client, Edward Furlong: that is the " case within the case."
But for Cooper's negligence. Plaintiffs are hoping this Honorable Court is seeing the
huge adverse implications of this violation of professional misconduct by attorney Chris
Hilson.
I

12.

Attorney Cooper, represented by Chris Hawkins, are "Trusty Defendants" in

the "Cabin Case" that Plaintiffls are also litigating in the Supreme court under case no.
2014-0063. Please see Exhibit no. 4 attsched : Standards for imposing Law:ler
Sanctions.
answer to motion

13.

Selectmen Defendant's counsel Chris Hilson is "playing the court " right here,
again, by purposely filing this frivolous motion, because clearly discovery has been
tendered to the defendants by the Plaintiffs. please see Exhibit no. 6 attsched.ly'rr.
Hilson is clearly just trying to do what most smart lawyers do, think ahead and align
arguments now for grounds for an appeal. This is waisting Plaintiff's time and money,
and the courts invaluable time. This is just another reason why attorney Hilson needs to
be brought to bear for this unethical behavior.
14. Petitioner's are very busy putting on an offense, but told Mr. Hilson he could
bring his own copy machine (because of the voluminous pleadings) and come to

Petitioner's office in Bartlett and he could copy all the files.

Attorney Hilson is spending most all of his client's billable hours degrading and
trying to demoralize Petitioners through innuendo and direct insult to Petitioner's legal
expertise, or lack thereof. But he has not offered any rebuttal evidence to the serious
allegations introduced by Petitioners. please see Exhibit no. 5 attsched: Conway Daily
Sun article where attorney Hilson states: " I need to build a case for him and defend
15.

against him because

I can't forthrightly understand what he's getting

at.',

PRAYERS

WHERBFORE, Petitioner's pray that this Honorable Court Deny Defendant's

motion to order production of exhibits and to "STAY" case no. 212-201 5-cv-0001 0 until
final hearing on the last motion; request to Stay Order dated May l lth, 2015, pending
ruling to the class vi roadway and the ruling on Doug Garland's Disqualification or
removal and

a.

GRANT Plaintiff s Motion to sanction attorne), Chris Hilson for violating

rule 7.1 and 4.1 of the New Hampshire Rules of Professional Conduct, and other
.....rules as scribed in the American BarAssociation Professional Rules of Conduct.

b.

Deny Defendant's motion to compel production of documents.

c.

Order such other and further relief as this Court deems just and proper.
Respectful ly submitted,

Dated: June 1 6th,2015

Edward C. Furlong III, Pro Se
by and through, as Counsel,
and as it's President for: Starbrite
Leasing, Inc.,
PO Box 447 BartleIt" NH 03812

Certificate of Service
I herby certifu that a copy of the foregoing Motion has this 16th day of .Iune, 2015, been
forwarded first class mail, postage prepaid to Chris Hilson, Matt Cairns, Bill Scott and Peter Malia,
counsel for the Defendants.

Edward C. Furlong

III, Pro Se

VERIFICATION
I, Edward C. Furlong, III, individually, and as President for Starbrite Leasing, Inc., do hereby
declare that I have read the forgoing "Objection to to Order Production of Document of Exhibits" and

know of the contents thereof. With respect to the matters regarding Plaintifl-s, Edward C. Furlong III,
Starbrite Leasing, 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 l6th, day of June. 2015. in North
Conway, Canoll County, New Hampshire.

Edward C. Furlong III, Pro Se

STATE OF NEW HAMPSHIRE

CARROLL, SS
Personally appeared before me, on this day of June 16th,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 knowledse and belief.

Notary Public/Justice of the Peace

My Commission Expires: