Stephen Libby

THE STATE OF
NEW HAMPSHIRE
CARROLL COT]NTY, SS.
SUPERTOR COURT
C. FURLONG, rlr,
Route 3O2, pO Box 447
Bartlett , NH 03 B i_2
EDWARD
ptainti
v.
ff
].455
US
OF BARTLETT 56 Town HalI,

Road Bartlet,t,
NH 03912, and
TOWN
Case No.
2L2-201L-cv-00298
TIMOTHY CONNIFEY Bartlett

Police Chief RR1 Box 49 Town
HaI1 Road, fntervale,

and
NH 03g45,
Annette Libby Bart,Iett

Recreational Director i-5
Meadows Drive Madison, NH 03949
Defendants.
DEPosrrroN oF srEpHEN R. LrBBy, a deponent in the

above-mentioned matter, taken pursuant to ag.reement
by counsel, before Susan F. Lozzj-, Registered

Professional Reporter, License No. !4o, in ttre state
of New Hampshire, ert the Bartlett rown Hall, 5G Town
HaIl Road, Bartrett, New Hampstrire, orr Thursday,
October 18, 2OL2, commencing at, 9:03 a.m.
DUFFY & McKENNA REPORTING AssocTATEs
P. O. Box l_56g
Dover, NH 0382J_-l_G5g
(503) 743-4949
ToII Free: 1 (BOO) GOO-LOOO
Duffy & McKenna Court Reporters, LLC

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APPEARANCES:
I
C. FURLONG
P.O. Box 447
Bartlett,
New Hampshire 03gL2
(503 ) zz4_9257
For Edward C. Furlong, plaintiff.
BY: EDWARD C. FURLONG, PRO SE.
EDWARD
BOYNTON, WALDRON, DOLEAC, wooDl"IAN
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P.O. Box 4Ig, g2 Court, Street & scoTT, p.A.

Portsmouth, New Hampshire O3 g O2 _ 04 i_ g
(503 ) 436-4010
For the Defendants.
BY: WILLfAM G. SCOTT, ESe.
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INDEX
R. LIBBY
Direct Examination by Mr. Furlong
Cross-Examination by Mr. Scott
STEPHEN
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Page
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EXHIBITS
No.
No.
No.
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Description
One-page docrrment by Stephen R.

Libby, dated Decemblr 4, 2OOg.
Plaintiff,
Edward C. Furlong,s
First, Set of fnterrogatories to be

answered by Defendant Stephen Libby
and six colored photograpts
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*** Original exhibits retained

bY Mr. Furlong ***
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Steven Libby
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P-R-O-C-E-E-D- r -N-G-S
R. LIBBY, having been sworn to

testif ied as follows:
STEPHEN
telI
DTRECT EXAMINATION BY
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t,he truth,
a.
A.
MR.
FURLONG:
Would you please state your name.

Stephen Roger Libby.
And can you please state what town you

8 I reside in.
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a.
A.
Madison, New Hampshire.
A. How long have you resided in Madison, New

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A. Approximately 12 years.
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What is your relationsllip with Annette
a.
14 Libby?
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A.
She is my wife.
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a.
What is your relationship
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with Mr.
Garland?
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A.
f have none.
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O.
A.
Do you know Mr. Doug Garland?
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Doug
Yes, I do.
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A. You state that you know Mr. Doug Garland,
22 but you profess that you have no rerationship with
23 him, whether it be personal or business?
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Steven Libby
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A.
That's correct.
A.
December 4Lh, 2OO8r |ou submitted
document to the selectmenrs office
and r have it
right here- rs this document what you submitted to
the Selectmen,s Office?
A. Actually, I believe it,s probably
there
was one there with my letterhead on it that was a
rough draft, but
there was one with my letterhead
on it,
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but, ys, it,s the same context.

It's the sarne context as this
a.
(indicating) ?
A.
Yes
At whose request from the Selectmen,s

a.
office did you do the investigatory work at the
precinct field?
A.
There was no one from the Selectmenrs

Office that asked me to do it, do any investigative
work.
Why did you feel compelled then to
a.
investigate the precinct f ield through. the d.eed.s,
prats, Registry of Deeds in ossipee, New Hampshire,
i and do a thorough outline of the precinct field and

23i then submit this docrrment to the Selectmen,s office
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without their giving you

that?
A.
a.
A.
O.
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Which schools did you attend, Mr. Libby?

Lin-Wood High School and elementary school
and Berlin Tech.
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Because in 2008 the rec department
received a grant, to build dugouts and a stred on the

precinct field and although it was municipal
property and did not require to be
to fotrow the
normal setbacks, Director Annette Libby wanted to
make sure that all setbacks were adhered to and
since there were no boundaries, r offered to do the
researctr at the registry.
a.
tlrere?
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commissioning you to do
And how long did you go to Berlin Tech?
That was a two-year program.

And what was tlle courses that you studied
I majored in water, wastewat,er technology.
Have you ever studied land use, anything
a.
to do with portions of land, surveying, researching
deeds, perhaps, or anything of that nature that
would facilitate
you in this endeavor that you
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A.
WeIl, f took a half semester in high

school where we spent time at the Registry of Deed.s
in Grafton County, plus my former employer r did
research and sLuff for const,ruction and so on.
a.
A.
Have you ever been arrested?

Never.
Have you ever been ticketed?
a.
A.
O.
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A speeding ticket? Warning.

How long have you resided in Madisort,
New
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Hampshire?
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A.
f believe I just told you approximately
L2 years.
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And prior to that, you were in?

a.
A. Lincoln, New Hampshire, was my primdry,
although I served in the military.
Have you ever been to Mr. Furlong,s
a.
property near the cabin that you reported was once
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shed?
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A.
f have never st,epped onto Mr. Furlong,s
property.
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a.
You
ve never been on Mr. Furlong,
propert,y?
A.
f have never been on Mr. Fur1ong,s

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Steven Libby
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property-
r'|ve been behind on the forestry property

but never on Mr. Furlong,s property.
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What was your business with the U.S.

a.
Forest, Terry Miller, ts seen in a picture with you
standing on Mr- Furl0ng's property next to the cabin
and you stated it was a shed.?

MR. SCOTT: Do you have the picture?
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Do you know the picture?

THE WfTNESS:
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picLure.
A.
f believe I saw that
Oh, yeah.
Do you have that picture
to refresh my
memory of exactly where r was standing because
A. I need to refresh your memory?
A.
I never stepped foot on your property, so
if you have the picture showing where f was
standing', I could probably t,eII you where I was
standing in relation to your property.
Did you not converse with the forest

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service supervisor, Mr. Terrance Miller?
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A.
I most certainly did.
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So you were on my property?
a.
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A.
I was not on your property. I was on
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Steven Libby
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Why did the selectmen ask you to

a.
investigate the precinct fie1d, the boundaries and
markers and the pins?
A.
I believe I just, told you that we were
putting up the dugouts and the shed and Annette
wanted to make sure that we maintained proper
setbacks on your property.
And since there was no boundaries between
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yours and the precinct, I investigated wtrere the

boundaries were which led me to that missing
boundary behind your shed.
a.
asked your wife, Annette Libbyr --
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So you're saying perhaps the selectmen
Negative
to?
I just told you that the selectmen said it

was municipal property and she did not have to
adhere to setbacks. It was Annette that insisted on
adhering to setbacks.
A.
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O. WeII, municipal property is usually owned

by the town or a city.
I mean, I would
I was
assuming that ttre Bartlett Water Precinct property
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is a utiliLy?
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A.
It was a municipal property. Municipal

precinct.
A precinct is a government entity.
O. What kind of map did you produce f or t,he
Selectmenrs Office that mentioned a map? Do you
recall a map that you submitt,ed to ttre Selectmenrs
Office that showed the preeinct field?
A.
f
I rve looked at several maps, so
unless you can tell me which one it was I cannot
teII you which one I presented to them because I
don't recall which one it was.
MR. FURLONG: Ttris is of f the record.
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(Discussion off the record. )

MR. FURLONG: Can I get this as
Exhibit 1,? This was the docr-rment in t,tre beginning.
(Exhibit No . l; so marked. )
MR. SCOTT: Is that dated?
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(Reviewing document.
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MR. FURLONG: On December 4th,
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Stephen Libby submitted a document dated
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December' 4Eh, 2008, entered in as Exhibit
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O.
What type of relationstrip
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do you have with
the Waterr Precinct Cornmissioner, Mr. Bob BIake?

A. He and I volunteered with t he rec
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department. That,'s t,he only

he's done cookouts.
He's done work on the field and that's it.
Have you ever conversed with him about
a.
Mr. Furlong and his businesses?
A.
I don't recall.
Was he present wtrile you were taking
a.
pictures of the property, of Mr. Furlong?
A.
f don,t recall.
So how many pictures can you est,imate that
a.
you took of Mr. Furlong,s property?
A. Well, I know I submit,ted orte, two, three,
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four, five,
six all pertaining
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that were set.

MR. FURLONG: Can you enter that in,
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to the new boundaries
those pictures as Exhibit 2.

(Reviewing photographs.
A.
These are my copies, but these are the
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ones t,hat were submitted to you on my original

interrogatories,
Iisted as item five on your
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interrogatories
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(Exhibit No. 2; so marked.)

Some of these pictures reveal nothi ng to
a.
do with boundaries or set pins, markers for
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measuring or accurately detailing
a property Iine.
Can you explain that?
A.
I disagree. The first picture has ttre
garden tractor in the backg'round right behind the
new forestry marker. That was ttre pin No. 7 ttrat
was mentioned in that leLter dated from
December 2008; ttrat was the key forestry boundary
that I needed in order to get the baek property line
of the precinet ball field.
The second picture is just a closer
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picture of that, same corner. The third picture in

line there is showing the new graniLe monument to
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t,tre front of the property between the precinct and
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Mr. Furlongi's property with a string line running

from front to back.
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The fourth picture is showing the stake
standing up in the left corner is above the new rear

monument on that property line and ttre red blaze in
the tree on the two trees is part of the three tree
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blaze that ttre forestry marks for that corner.

just so happens that one of your buildings was
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between th"e two trees.
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It
picture is taken
standing in line with the new back property of the
The fifth

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ball field
taking a picture of ttre three trees with

the grade stake marking the new g'ranite monument to
the rear of the property, and the next picture in

line is just a close-up of that that shows two of
ttre blazed trees a little
more clearly with no
buildings in view.
According to your statement here that you
a.
submitted December 4Eh, 2008, to t,he Selectmenrs
Office, in the seventh paragraph, the last line you
state Although the photo
I t,ook a picture with

cellptrone. Although the photo reproduces very
grainy, the lighted cab of tlre pickup can be seen
parked between the motel and the telephone pole with

yellow tape. What was that comrnent in reference to
if you're just
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I believe that one picture there was the

day we were putt.ing up the gate on ttre property
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and
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my
A.
Excuse me. Wtrat property?
a.
A.
On the ball
a.
Property or front of a roadway?
field property, across the

front entrance to the property to keep vehicles out
during the winter season.
Duffy & McKenna Court Reporters, LLG

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Steven Libby
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A.
In front of the driveway.
a.
A.
Okay. A driveway?
A driveway.
O.
A.
Not a C1ass 5 roadway?

A driveway.
a.
A.
So it's
not a Class 5 roadway?

It is the precinct's driveway.
just, answer my question.
Yourre not
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it your opinion it's
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not a Class 6 roadway?
MR. SCOTT: Wait a minute-
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Wait a
minute.
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No.
MR. SCOTT: He has said
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it's
a driveway.
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opinions on anything.
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thinks it is
He is not rendering expert
He's telling
you what he
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he has said
That ' s fair
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enougrh.
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AIso in this letter you state as

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Mr. Furlong claims that he has no access to the back
of his property where the cabins are without
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utilizing
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November 22nd, T witnessed Mr. Furlong drive into
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the fieldrs
driveway.
On Saturday,

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his upper driveway and he and his vehicle reappeared

along the field's property line behind his motel
unit.
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Can you explain that?
A.
Yes. Ttrat gloes along with the very last

sentence you just read to me. You had been stating
tlrat because the driveway was now blocked and you
you claim you trad no access to the rear of
had no
your property, I was just taking a picture of how
you had just driven around your cabins and parked
behind those cabins.
So you obviously did have access to your
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back property wittrout having t,o use the driveway of

the ball fie1d, which is why I took t,Lre picture on
my cellphone, which was grainy that day-
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The driveway that entered my cabins from

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ttre ball field from that driveway, what, was placed
in front of the driveway to preclude :me from
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entering, do you reca1I?
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A.
I believe
initially
ttrere was a log placed
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across that driveway and then at some point
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the new chain-link
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stockade fence running down t,he new established
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property
line,
between
fence being put in and the
ttrere was a line
of boulders placed

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Steven Libby
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along that line and, also, if you happen to look at

that pict,ure showing the boulders, those boulders
were placed weII upon the precinct property nowhere
near the string line that was run from pin to pin.
Who placed the logs in front of the

a.
Mr. Furlong's driveway to keep him from entering
into his cabins? Do you recall
person?
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the narne of that
I do not recall who placed the logs there.

Maybe I can refresh your memory. Does Don
a.
Ryder ring a bell?
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I know Don Ryderr 1zs. He supplies

Christmas trees.
O. So yourre noL sure if it was him that
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placed those logs in front?
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I have no idea.
Who placed the rocks, the boulders?
a.
A. Ttre rocks were placed by
excuse me. I
cannot t,hink of that gentlemanrs name that owns the
Bartlett Service Center, the older gentleman. He
had the boulders on his property and he offered to
place them along the property wit,h his tractor.
He
bucketed them across 3O2 and plaeed them in line for
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us.
I believe his name is Mr. Gerry

f or t,he record.
O.
A.
McMannus,
Sr.
If there's a Sr.
A. Sr. And, also, I am to understand that
Mr. McMannus, Sr., was highly competitive with
Mr. Furlong in the snow remowal rental business?
MR. SCOTT: Wait a minute.
If you
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have questionsr folJ can ask questions, but you

shouldn't be testifying about, wtrat you want. If you
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have a question about what he did, thatrs fine,
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but
MR. FURLONG: It's
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record.
MR. SCOTT: It shouldn't be on the
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just for the
Really, yourre asking this witness

questions.
record.
MR. FURLONG: You can strike
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that.
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Are you aware if Mr. McMannus, Sr., was

compensated for the rocks or Lre just donated them?
A. He just donated ttrem. He wanted them off
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his property.
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do it, rxo cost.
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O.
We had
use for them. He offered to

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Steven Libby
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I believe it was a stopgap measure while

we were waiting for a permanent fence to be placed
to keep you from traveling wherever there was an
opening through the
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Why were such ugly boulders placed there

a.
on the property line? What was ttre purpose of that?
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A.
a.
A.
along the property.

Along the property. Along the driveway?
Along the property line.
O.
A.
Along the driveway there.

Along the driveway property line.
a.
A.
Yes.
Actua1ly, strike
that.
It's
not along the
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driveway because ttrere's approximately l-0 to 1-5 f eet

of separation between ttre driveway and the property
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over
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15 feet from the property line to the driveway?
A.
I'm just looking at this picture here, and
I am guesstimating approximately 1-0 to 15 feet of
separation between the property line and that pin
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over property; not driveway.

So you' re saying ttrere' s approximately
for that post for the gate, a seasonal gate.

Your wife, Ms. Annette Libby, who's
a.
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I have no reason to tike or distike you.

I mean, Irve never met you. As I said someplace I
think in one of my
one of my answers to you
and I'11 read it so I'm not taking it out of eontext
here. f will read it, to you. Let me just find the
right one, please.
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Revi ewing docrrment . )
A.
Since I spent all the time having to

answer these, I would like to
this is from page
five of my interrogatories.
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To the best of my knowledge, I have never

initiated any conversation with Mr. Furlong, never
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soughL him out and never crossed over his property
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line during any of my time working on B1ack FIy

Fie1d projects.
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I have never approached him in any other

and I was cordial to him wlren I served him
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setting,
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during the 4th of .IuIy celebrations.

O. Was there a time back around spring of
2008, could have been a little
later, that you were
putting up tape to mark your boundary line wtren
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Mr. Furlong and you exchanged words? And those

words were in pretty much a belligerent style,
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demeanor towards each other?
A.
I don,t recall that. I do have

sometime after the missing forest,ry corner boundary
had been replaeed and Black FIy Field had been
surveyed, I was running a string 1ine along the
recently surveyed property line and Mr. Furlong did
approach me. He accrrsed me of spying, to which f
replied I was simply marking property lines.
He then accused me of being orr his
property, to which I replied ttrat I was working we1l
within the confines of Black Fly property but that
ttre brush tre stacked was clearly on Black Fly
propert,y and needed to be removed.
One late faII
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day while a work party was
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installing
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stockade fence to the back granite
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Mr. Furlong' did approach us.
He questioned what
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were doing and who authorized
it.
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snow fence from the other end of the
He was holding
bound,
we
up a newspaper as though he
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was reading i t; t,hen he would bring out a camera,
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snap a pieture
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this several times, one of the individuals in ttre

work party suggested that he just put down his paper
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and hide t,he cErmera. Af ter doing

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since we all
he left
doing and then
us alone.
MR. FURLONG: Thank you.
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knew what he was reaIIy
Thank you.
Tlrere's no other questions.
MR. SCOTT: Okay.
THE WITNESS: I had one more there
that kind of related
to exaetly
I trave nothing.
what he said.
MR. FURLONG: No, that ' s it
MR. SCOTT: Hold on a second.

MR. FURLONG: Strike
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(Discussion
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CROSS-EXAMINATION BY
a.
MR.
off
that.
the record.
SCOTT:
Did you have any other confrontation
with
Mr. Furlong at the property?

A.
Yes, I did,
and this
actually
relates
to
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the sunrmer of 2008.
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encounter was during the summer of 2009 when r was

searchingi for the u.s. Forestry and Black Fty Fierd
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boundaries.
And as I wrote,
orte other
I was behind his property but well within

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the forestry land. He wanted me to identify mysetf
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because r courd be a pervert sneaking, around in t,he
23 woods behind his cabins, to which r repried that if
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he was concerned, he should call the police and f
would still be here working when they arrived.
MR. SCOTT: Okay.
We're done, Steve.
Thank you.
(Whereuporr, the deposition concluded.
at 9228 a-m.)
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ERRATA SHEET
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corrections:
PAGE/LrNE NO.
, wish to document the following

CORRECTION
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SUBSCRIPTION OF DEPONENT
State of
County of
I,
, do hereby cert,ify t,hat I have
read the foregoing transcripl of
and
further cerrify that said tianscriitmy testimony
(with/without)
suggested corrections on the Errat-a sheet is a trrr"
and accurate record of said testimony
taken at the
time and place designated..
Date
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Subscribed and sworn to before me this

of
, 2012.
day
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Notary Public
State of New Hampshire
Commission expires:
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CERTIFICATE
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F'nat i-i;? io::eqaii\g is a
hereby certifl'
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to l-he acLicn in whichi this
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The foreEoing
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Stephen Libby

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Stephen Libby

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THE STATE OF

CARROLL COT]NTY, SS.

OF BARTLETT 56 Town HalI,

TIMOTHY CONNIFEY Bartlett

HaI1 Road, fntervale,

Annette Libby Bart,Iett

DEPosrrroN oF srEpHEN R. LrBBy, a deponent in the

by counsel, before Susan F. Lozzj-, Registered

Duffy & McKenna Court Reporters, LLC

BOYNTON, WALDRON, DOLEAC, wooDl"IAN

P.O. Box 4Ig, g2 Court, Street & scoTT, p.A.

Duffy & McKenna Court Reporters, LLC

One-page docrrment by Stephen R.

First, Set of fnterrogatories to be

*** Original exhibits retained

Duffy & McKenna Court Reporters, LLC

R. LIBBY, having been sworn to

Would you please state your name.

And can you please state what town you

Madison, New Hampshire.

A. How long have you resided in Madison, New

What is your relationship

Do you know Mr. Doug Garland?

December 4Lh, 2OO8r |ou submitted

document to the selectmenrs office

but, ys, it,s the same context.

At whose request from the Selectmen,s

There was no one from the Selectmenrs

i and do a thorough outline of the precinct field and

Duffy & McKenna Court Reporters, LLC

without their giving you

Which schools did you attend, Mr. Libby?

and Berlin Tech.

Because in 2008 the rec department

received a grant, to build dugouts and a stred on the

And how long did you go to Berlin Tech?

That was a two-year program.

WeIl, f took a half semester in high

Have you ever been arrested?

A speeding ticket? Warning.

And prior to that, you were in?

ve never been on Mr. Furlong,

f have never been on Mr. Fur1ong,s

r'|ve been behind on the forestry property

What was your business with the U.S.

and you stated it was a shed.?

Do you know the picture?

f believe I saw that

Did you not converse with the forest

Duffy & McKenna Court Reporters, LLC

Why did the selectmen ask you to

And since there was no boundaries between

yours and the precinct, I investigated wtrere the

asked your wife, Annette Libbyr --

So you're saying perhaps the selectmen

I just told you that the selectmen said it

O. WeII, municipal property is usually owned

Duffy & McKenna Gourt Reporters, LLC