STATE OF NEW HAMPSHIRE

CARROLL,

SS

SUPERIOR COURT
Starbrite Leasing, Inc.,

Lil' Man Snowmobile

Rentals Inc.,

and

Edward C.-Furlong, III

v.

Town of Bartlett, Bartlett Police Department, Bartlett Water

Precinct, Bartlett Recreation Department
ano

Carroll County Sheriff s Department

Docket #: 212-2015-CV-53

OBJECTION TO PLAINTIFF'S MOTION TO CONSOLIDATE

Defendant, Canoll County Sheriff s Department, obiects to

Plaintiff s Motionto Consolidate

fbr reasons set forth below.

l.

Plaintiff's have moved to consolidate this case with Furlong v. Chandler, Docket #

212-2015-cv-32. 1'hey asserts in conclusory fashion that the two cases are "connected throush
the
defendants, respective to their malicious acts ....,,

2'

As to the Sheriff's Department, the above-captioned case concerns plaintiffs'

allegation that he was wrongfully anested in March 20l5.

3

'

Defcndant's counsel does not har,'e a cop}, of the pleadings in Furlong v. Chandler.

However, it appears to counsel that the case relates to Plaintiffs' ongoing dispute with the Town of

Barllett and others regarding his illegal use of the Town's ball field and/or other land for the
snowmobile business run from plaintiffs, property.

4.

l'he two cases do not "arise out of the same transaction" per Superior Court Rule

8.

The Sheriff s Deparlment has nothing to do with the long history relating to Plaintiffs' land - which

history apparently dates back to 2006.

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I of

5'

It would be highly inefficient to have claims against the Sheriff

s Department

consolidated with the other claims since the Sheriff

s Department has no role in the prior matters.

6'

'fhe Sheriff
s Department has kept this Objection brief, as it has pending
a
Motion

to Dismiss' In the unlikely event that its Motion is not granted,

the Department reserves the rieht
to supplement this Objection.
7

'

The

Sherifls Department further

at the time of the hearing on the

notes that the parties had a colloquy with the Court

Motion to Dismiss (july 6) for the purpose of avoiding unnecessary

work while that rnotion is pending.

WHEREFORE, Def.endant Carroll County Sheriff s Department
requests the Court deny

Plaintifls Motion to Consolidate.

Respectfully submitted
\-arrotLL?unty Sheriff s Department
Canollepunty
By its at|6rneys

Date:

717l15

Corey
Esquire
- - -J Ap{o@w.
-/--",7
Maggiotd& Belobrow, pLLC
58 Pleasant Street
Concord, N.H. 03301
(603) 22s-s1s2
NH Bar #: 534
EmaiI : Core),b(-dusa.net

CERTIFICATE OF SERVICE
I hereby certi$ that a copy of the foregoing has this date been fbrwarded via
first class
mail, postage prepaid to Edward C. Furlong, III, pro se, ancl via electronic
mail to William Scott,
Esquire and R. Matthew Cairns.

Date:

717115

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