OF THE STATE NEW HAMPSHIRE CARROLL COUNTY.

SS COURT SUPERIOR zT, December zort

il"'a a*r""r,,,,
1455 Route 3oz US PO Box 447 Bartlett, NH o38rz Plaintiff CaseNo.:

Town of Bartlett 56 Town Hall Road Bartlett, NH o38rz,and Timothy Connifey Bartlett Police Chief RRr Box 49 Town Hall Road Intervale,NH o3845,and Annette Libby Bartlett RecreationalDirector r5 Meadows Drive Madison, NH %B49 Defendants

AND DEMAND FOR A IURY TRIAL COMPI"A.INT and for this proceeding his Pro Secapacity, in EdwardC Furlong, NOW COMES, as and states follows: alleges against Defendants, Complaint

Plaintiff hereby files his claim for Defamation Per Se against the Town of Bartlett, Timothy Connifey and Annette Libby and his claim for FalseArrest against the Town of Bartlett and Timothv Connifev. PARTIES r. Plaintiff Edward CharlesFurlong, III is a resident of the State of New Hampshire and a citizen of the United Statesof America. Plaintiff Edward Furlong residesat 1455US Route 3oz, Bartlett, New Hampshire o38rzand may be servedpleadingsat that addressor by mail serviceaddressed Edward Furlong PO Box 447,Bartlett, to NH o38rz. 2. Defendant Town of Bartlett receivesmail and may be servedpleadingsat 56 Town Hall Road, Bartlett, New Hampshire o38n. 3. Defendant Timothy Connifey is the Chief of Police for the Town of Bartlett and can receivemail and be servedpleadingsat the Bartlett Police Station located at RRr Box 49 Town Hall Road, Intervale, New Hampshire %84... 4. DefendantAnnette Libby is the RecreationalDirector for the Town of Bartlett and residesat 15Meadows Drive, Madison, New Hampshire %84g where she may receivepleadingsby serviceor mail. JURISDICTION AND VENUE 5. Personaljurisdiction is proper over Defendant Town of Bartlett becauseit is a town in the State of New Hampshire

Personaljurisdiction is proper over Defendant Timothy Connifey becausehe residesin the State of New Hampshire and works for the Town of Bartlett, located in the State of New Hampshire 7. Personaljurisdiction is proper over Defendant Annette Libby becauseshe resides in the State of New Hampshire and works for the Town of Bartlett, located in the Stateof New Hampshire.

8 . Venue is proper in this Court becauseDefendantsTown of Bartlett, Timothy

Connifey and Annette Libby work and reside in Carroll County, State of New Hampshire and Plaintiffs causeof action for defamation and falsearrest arosein Carroll County. STATEMENT OF FACTS 9 . Plaintiff Edward C Furlong was a homelessalcoholic from1976 until 1996.
to.

Plaintiff Edward C Furlong got clean and sober in 1996and moved to 1455US Route 3ozin Bartlett, New Hampshire.

lt.

Plaintiff Edward C Furlong has worked from 1996until the present to maintain good standing in his community as a businessmanand as a taxpaying citizen in the town of Bartlett, New Hampshire.

t2.

Plaintiff Edward C Furlong started renting snowmobilesto the public in the winter of ry97-t998 from his property at451; US Route 3ozin Bartlett, New Hampshire and incorporated Lil'Man Snowmobile Rentalsin 1998.

13. Plaintiff Edward C Furlong operatesa lodging business, Abenaki Inn & Cabins,

LLC, from his property at455 US Route 3oz in Bartlett, New Hampshire.

r4. Defendant Timothy Connifey becameDefendant Town of Bartlett's Chief of Police in the end ofJanuary in 2ooz. r5. Bartlett Police Chief, Defendant Timothy Connifey,visited Plaintiff Edward C Furlong at his home located at 455 US Route 3oz in Bartlett, New Hampshire in or around the spring of zoo3 to question Mr. Furlong about his arrest record in the Stateof Florida. 16. Bartlett Police Chief, Defendant Timothy Connifey, pulled Plaintiff Edward C Furlong out of the voting line for the presidentialelectionsof zoo4, accusingMr. Furlong of having a warrant out for his arrest in front of all the other Bartlett residentswaiting to vote. r7. DefendantAnnette Libby was hired by Defendant Town of Bartlett to be the Bartlett RecreationalDirector sometime prior to the summer of zoo8. r8. Sometimeafter being hired as the Bartlett RecreationalDirector, Defendant Annette Libby began work on Black Fly Ball Field, located on the Bartlett Water Precinct property located to the east of Plaintiff Edward C Furlong'sproperry. 19. Defendant Annette Libby spied on Plaintiff Edward C Furlong'sproperty and the work being done on his property. zo. DefendantAnnette Libby and her husband sneakedaround in the woods behind Plaintiff Edward C Furlong'sproperty and took pictures of renovations being done to a cabin on Mr. Furlong's property in an attempt to cite Mr. Furlong for building code violations.

2r. There is a roadway between Plaintiff Edward C Furlong's propeffy located at 455 US Route 3oz in Bartlett, New Hampshire and the Bartlett Water Precinct land locatedto the east of Mr. Furlong'sproperty that leadsto the White Mountain National Forest. zz. Plaintiff Edward C Furlong'sproperty located at455 US Route 3oz in Bartlett, New Hampshire has been in the hospitality businessfor at least r33yearsand its owners. staff and customers have accessed the forest floor via the roadwav between his property and the Bartlett Water Precinct properry. Lil'Man Snowmobile Rentals,Inc. and 23. Plaintiff Edward C Furlong'sbusinesses, Abenaki Inn & Cabins,have used this roadway for its staff, its customersand the public to access the New Hampshire Bureau of Trail's snowmobile and hiking trails have used systemsince 1997.The public and other snowmobile rental businesses the snowmobile trails since at least 1988.The public and this roadway to access located at 1455US Route 3ozin Bartlett, New patrons of the lodging businesses the hiking trails since at least 1876. Hampshire have used this roadway to access 24.A Complaint for a ClassB Misdemeanorwas filed against Plaintiff Edward C violation of NH RSA 635:2,by Defendant Timothy Furlong for Criminal Trespass, Connifey on January23,2oog for driving his Sno-Coachon the public roadway east of his property. 25. The Bartlett RecreationalDepartment has baseballgamesand allows other towns to have baseball games on Black Fly Ball Field located on Bartlett Water Precinct property directly to the east of the public roadway and Plaintiff Edward C

Furlong'sproperty and has never provided the players,coaches,families and fans with any sort of restroom facilities. 26. During the times that the Bartlett RecreationalDepartment has baseballgameson Black Fly Ball Field, located on Bartlett Water Precinct property directly to the east of the public roadway and Plaintiff Edward C Furlong'sproperty, the public drove, parked, sat and urinated on the public roadway between the Bartlett Water Precinct land and Mr. Furlong'sland. 27. Plaintiff Edward C Furlong routinely documented the fact that there were no sanitary restroom facilities provided by the Town of Bartlett or the Bartlett RecreationalDepartment using his video camerabecausethe public used Mr. Furlong'swooded acreageto urinate and defecateon. 28. On June r5, zorr Plaintiff Edward C Furlong was recording the eventsat Black Fly Ball Field with his video camera.Mr. Furlong recorded cars parking on the public roadway east of his property, cars parking on US Route 3oz and cars parking on Mr. Furlong'sproperty. Mr. Furlong recorded fans at the ballgame holding up a blanket for privacy as other people went to the bathroom near the wood fence separatingMr. Furlong's property from the public roadway. 29. On June 16,2or1an old Ford pickup truck with its licenseplates coveredwith plastic bags was seen on Plaintiff Edward C Furlong's property. 3o. Plaintiff Edward C Furlong chasedthis truck and made numerous phone callsto 9tr.

3r, Plaintiff Edward C Furlong pulled into Grant's Supermarket parking lot in Intervale,New Hampshire and the driver of the Ford truck entered the parking lot behind Mr. Furlong. The driver of the truck got out of his truck and came after Mr. Furlong in a physically aggressive manner, screamingand cursing that Mr. Furlong was a pedophile and that he was going to kill Mr. Furlong. 32. On Junezz, zou Plaintiff Edward C Furlong was recording the eventsat Black Fly Ball Field with his video camera.Mr. Furlong recorded Bartlett Police Officer Ed Conley stop in his cruiser and speakwith Defendant Annette Libby on US Route 3oz. Ed Conley then drove to where Plaintiff Edward C Furlong was standing with his video camera and yelled at him not to "talk to the kids". 33. DefendantAnnette Libby told Bartlett police officer Ed Conley that Plaintiff Edward C Furlong was a pedophile and that he was taking pictures of children at Black Fly Ball Field. 34. DefendantAnnette Libby told at leastthree $) other people that Plaintiff Edward C Furlong was a pedophile and was using his video and still camerasto take pictures of children at Black Fly Ball Field. Two (z) of these people called the Bartlett Police Department and one (r) went to Plaintiff Edward C Furlong'shome to causehim harm on June 16,zol. 35. On April 26, zol Erin Myatt, girlfriend to Plaintiff Edward C Furlong, had a court date in Carroll County for a driving infraction and Bartlett Police Chief, Defendant Timothy Connifey, was the prosecutorin the case.

36. On April 26, zott Defendant Timothy Connifey asked Erin Myatt where Plaintiff Edward C Furlong got his discretionaryincome. 3T.OnApril 26, zol Defendant Timothy Connifey asked Erin Myatt if Plaintiff Edward C Furlong was involved in a pyramid schemein the state of Florida. 38. On April 26, zorl Defendant Timothy Connift told Erin Myatt that Plaintiff Edward C Furlong was involved in a pyramid schemein the state of Florida, he just couldn't prove it. 39. On April 26, zon Defendant Timothy Connifey told Erin Myatt that Plaintiff Edward C Furlong was easierto deal with when he had a young woman around and there had been a string of young women around Mr. Furlong before she moved to his property. COUNT r - Against Town of Bartlett, Timothy Connifey and Annette Libby DEFAMATION paragraphsr-37,as if set forth fully herein. 4c. Plaintiff repeatsand re-alleges 4r. Defendant Timothy Connifey and Defendant Annette Libby are employed by Defendant Town of Bartlett. 42. New Hampshire R.S.A.$ 644:rrdefinescommitting defamation as, "purposely communicat[ing] to any person,orally or in writing, any information which he knows to be falseand knows will tend to exposeany other living person to public hatred, contempt or ridicule". 43. Defendant Timothy Connifey made the following untrue statements regarding Plaintiff Edward C Furlong: a. There was a warrant out for Mr. Furlong's arrest; and

b. Mr. Furlong was engaging in criminal activity, being involved in a pyramid schemein the state of Florida. 44.As a direct and proximate result of Defendant Timothy Connifey making these untrue statements, Plaintiff Edward C Furlong has suffered substantial damagesto his reputation as a good, upstanding businessmanand citizen of Bartlett, New Hampshire. 45. As a direct and proximate result of Defendant Timothy Connifey making these untrue statements,Plaintiff Edward C Furlong has been subjectedto hatred, contempt and ridicule within his community and his personal life. 46. DefendantAnnette Libby made the following untrue statementsregarding Plaintiff Edward C Furlong: a. Mr. Furlong was at Black Fly Ball Field taking pictures and videos of children; and b. Mr. Furlong is a pedophile. +2.As a direct and proximate result of DefendantAnnette Libby making these untrue statements, Plaintiff Edward C Furlong has suffered substantial damages to his reputation as a good, upstanding businessmanand citizen of Bartlett, New Hampshire. 48. As a direct and proximate result of Defendant Annette Libby making these untrue statements,Plaintiff Edward C Furlong has been subjectedto hatred, contempt and ridicule within his community and personallife.

Count z - Against Town of Bartlett and Timothy Connifey False Arrest paragraphsr-37,as if set forth fully herein. 49. Plaintiff repeatsand re-alleges 5o. Defendant Timothy Connifey is employed by Defendant Town of Bartlett. 5r. The Complaint against Plaintiff Edward C Furlong by Defendant Timothy Connifeywas issuedmaliciously and without probable cause. 52. Plaintiff Edward C Furlong (or a member of his staff) drove his Sno-Coachon the public roadway to the east of his property only and did not drive on the Bartlett Water Precinct properry known as Black Fly Ball Field. 53. Defendant Timothy Connifey told Plaintiff Edward C Furlong if Mr. Furlong d.id charge,Mr. Furlong would go to jail. not plead guilry to the Criminal Trespass 54. Plaintiff Edward C Furlong asked Defendant Timothy Connifey if Mr. Furlong could enter a guilty plea under the Alfred Doctrine. Defendant Timothy Connifey told Plaintiff Edward C Furlong that he could not plead guilty under the Alfred Doctrine. 55. Plaintiff Edward C Furlong pled guilry to the Complaint of Criminal Trespass becausehe was scaredthat Defendant Timothy Connifey was going to place him in iail. 56. Defendant Timothy Connifey used Plaintiff Edward C Furlong's past as a homeless alcoholic with a long rap sheet to coerceMr. Furlong into entering a guilty plea to the charge of criminal trespass. 57. Defendant Timothy Connifey knew or should have known that the roadway was a public right of way and Plaintiff Edward C Furlong could not be arrestedfor 10

trespassing a right of way belonging to his property and the general public on under current prescriptive easementlaw.

WHEREFORE,Plaintiff respectfullydemandsjudgment againstthe Defendants,jointly and severally,as follows: a. Compensatorydamagesin an amount within the jurisdictional limits of this Court and to be determined by the jury trying this action; b. Punitive damagesto the fullest extent permitted by the laws of the State of New Hampshire; c. All attorneys' feesand costs incurred by the Plaintiff in connection with prosecutingthis action; and d. Such other and further relief as this Court deems just and proper.

lly Respectfu Submitted,

Dated: December

. zorz Edward C Furlong, III 1455US Route 3oz P.O. Box 447 Bartlett, NH o38rz (6o:) 387.9or4 ecfurlongproadrunner.com

, Pro Se

TT