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CARROLL,
SUPERIOR COURT
SS.
2-2015-CV-00032
1.
of
The Town respectfully requests that this Honorable Court excuse the presence
at 1 :30 p'm' as he
Gene Chandler fiom the hearing currently scheduled for August 14,2015
be unavailable on that date. In the altemative,
will
2.
p.m' to
This Honorable Court scheduled a hearing for August 74,2015 at 1:30
ATTORNEYS
AT
I,AW
oFFIcEsTNEXETER,PORTSMOL'THNDMEREDITH,NEwWPSHIRESoo.565'0506www'DTCnWYERS'CoM
3.
In the past, this Courl has commentcd that it would like to sec Mr. Chandler
4.
The matters to be heard at the hearing of August 14, 2015 do not appear to
Dismiss, which focuses on the application of res judicata and collateral estoppel; the Motion to
Compel Appearance of Counsel, which takes up the nature of the Plaintiff s self-representation
and advisability to compelling counsel to appear on behalf of the
Motion to Sanction, which deals with certain actions undersigned counsel is taking in this matter.
None of these issues irnplicate the need for Mr. chandlcr to appear.
5.
6.
To the extent thc Courl will find it helpful, however, Mr. Chandler is more than
August
wiliing to appear for the hearing. Mr. Chandler and undersigned oounsel are available on
1
i.
The Town sought the concurence of the Piaintiffs in this matter, but as of the
by the aftemoon of
Furlong on the momtng of August 3,2015, and has not heard a response
Ausust 3. 20 i 5.
DONAHUE, TUCKER & CIA}iIDELLA, PLLC OFFICES IN EXETER, PORTSMOMH A{D MEREDITH, NEW WPSHIRE
ATTORNEYS
8OO-566'0506
AT
LAW
WM'DTCCWYERS'COM
A.
Excuse the presence of Gene Chandler at the upcorning hearing on August 14,
201 5, or,
Dated
B.
In the altemative, move the hearing to any one of the afbren-ientioned dates; and,
C.
f /
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CERTIFICATION
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S: BA-BD,Banlcn. Town ol',Ftulong & Starbrite Leasing r,. (lhan4lcr-SC 2015',Pioadings\2015 08 03 Tou'n's Motion to Excrlsc the Presctrce ol
Gcne Chandler.docx
DONAHUE, TUCKER
OFFICES
IN
ATTORNEYS
AT
tAW
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