STATE OF NEW HAMPSHIRE

CARROLL COTINRY" SS. SUPERIOR COURT

Edward C. Furlons III

Town of Bartlett, et al

Docket No.: 212-20 I l -CV-00298

PLAINTIFF. EDWARD C. FURLONG'S FIRST SET OF INTERROGATORIESTO BE ANSWERED BY DEFENDANT TIMOTHY CONNIFEY

NOW COMES the Plaintiff, Edward C. Furlong, and submits the followinginterrogatories to Defendant, Timothy, to be answered under oath pursuant to Rule 36 ofthe New Hampshire Superior Court Rules within thirty (30) days from the date of servicehereof.

These interrogatories are propounded in accordance with Superior Court Rule 36.You, Timothy Connifey, must answer each question separately and fully in writing andunder oath. You, Timothy Connifey, must return the original and one (1) copy of youranswers within thirty (30) days of the date you receive them to the party (Edward Furlongat PO Box 477 Bartlett, NH 03812) that served them upon you. If you object to anyquestions, you must note your objection and state the reason. if you fail to retum youranswers within the allotted thirty (30) days, the party who served them upon you mayinform the court, and the court shall make such orders as justice requires, including theentry of a conditional default against you.

INSTRUCTIONS

t. "ldentify" shall mean:

o With reference to a document you shall specifically designate the type ofdocument (such as a letter, interoffice memorandum, report, drawing,agreement, cpmputer printout, etc.), its date, and such additionalinformation as will permit the Plaintiff to identify the document, such as

its addressee, its author, its approximate number of pages and its title. Ifthese interrogatories require you to i{entify a document not in yourcustody or possession, please identify any person (pursuant to thefollowing paragraph) to whom copies of such document have been sentand the present last known location or possessor of the original document.

2.

with reference to a person, you shall furnish information sufficient toenable the Plaintiff to locate that person (their name, present address,telephone number and place of employment).

with reference to a corporation, company, business, joint venture,partnership, not-for-profit corporation or other business entity, state its fullname, its last known address, the nature of its business, its relationship toyou and the name of its last known chief executive officer.

In answering these interrogatories, you shall fumish all information which isavailable to you including information in the possession of your officers,employees, attorneys, investigators, agents, or anyone acting on your behalf, andnot merely such information known to your personal knowledge.

These interrogatories are continuing in nature with regard to these matters, asspecified in New Hampshire Court Rule 36 and pAD Rule 4.

In accordance with New Hampshire Superior Court Rule 36, each objection tothese interrogatories shall be forwarded with a statement of reason therefore.When an objection is made to any part of an interrogatory, the remainder of theseinterrogatories shall be answered at the time the obiection is made unless theperiod to answer has been extended.

If after exercising due diligence to secure the information necessary to answer thefollowing interrogatories in fulI you cannot answer them, state the answer to theextent possible, specifying the reason or reasons for your inability to answer theremainder and stating whatever information is available to you concernins theunanswered portion.

DEFINITIONS

l. "Documents" - means any written or other recorded, graphic or photographicmatter of any kind or character, however produced or reproduced, andincludes, without limiting the generality of the foregoing, all notes,transmittals, mail grams, letters, envelopes, tele grams, teletypes,correspondences, contracts, agreements, drafts, work papers, advertisements,editorial creditors, news stories, promotional pieces, notes to file, shopnotebooks, reports, memorandum, market surveys, mechanical and electricalsound recordings or transcripts thereof, surveys, blueprints, formal or informaldrawings or diagrams, calendar ordinary entries, memorandum or telephone orpersonal conversations or meetings or conferences or any event or activity,telephone bulletins, statements, manuals, summaries, minutes or meetings,maps, charts, graphs, order papers, articles, announcements, books, catalogs,records, tables, invoices, bills, checks, promissory notes, trial balancecomputation, data processing, materials or analysis or other statistical data

3.

4.

5.

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aJ.

including originals and all non-identical copies of any of the foregoing,whether types, printed, handwritten or on tape or other recordings, und unymaterial underlining, supporting or used in the preparation of any suchdocument.

"You or your" - means the party upon whom these interrogatories are served,Timothy connifey, and includes your affiliates, divisions, subsidiaries,officers, directors, managers, representatives, agents, attorneys, employees orinvestigators.

"communication" - means any transfer of information, ideas, opinions orthoughts by any means, any time or place, under any circumstances and is notlimited to transfers between persons, but in cases other transfers, such asrecords and memorandum to file.

4. "Plaintiff'- means and shall refer to Edward C. Furlong III.

5. "Defendant" - means Timothy Connifey.

6. "other Defendants" - means one or all of the following: Town of Bartlett,Annette Libby, Stephen Libby and/or the Bartlett Recreation Department.

7. "Bartlett Selectmen" - means one or all of the following: Douglas Garland,Gene Chandler, Jon Tanguay and/or David Patch

8. "Bartlett village water Precinct" - means one or all of the following: BobBlake, Matt Howard, Don Mayer, David Ainsworth and/or Bert George.

9. "Bartlett Village Water Precinct Property" - means the property containingBlack Fly ball field in Bartlett, New Hampshire and located directly to the eastof Mr. Edward Furlong's property.

10. "Mr. Edward Furlong's Property" - means the property belonging to Mr.Edward Furlong located at 1455 US Route 302 in Bartlett, New Hampshireand located directly to the west of the Bartlett village Water PrecinctPropertv.

INTERROGATORIES

1' Set forth the full name, address, occupation and official capacity of the personanswering these interro gatories.

ANSWER:

Timothy connifey, chief of porice of the Town of Bartrettc/o Bartlett Police Department56 Town Hall RoadBartlett, NH

2. Set forth the position, if any, you hold with the Town of Bartlett, Carroll County orthe State of New Hampshire.

ANSWER:

See Answer to Interrogatory No. 1.

3. Set forth the dates, times and substance qf each and every encounter you have hadwith the Plaintifl Mr. Edward C. Furlonq.

ANSWER:

I do not recall each and every encountgrl however,I have attached to theseAnswers the reports of the Police Department with respect to encounters with thePlaintiff. In addition , in 2002 or 2003 I had an encounter with the Plaintiff at thepoles.

In addition, I was present at Selectmen's meetings attended by the Plaintiff. Iwas there at the request of the Selectmen 4lthough I do not recall any particularinteraction with the Plaintiff.

4' Detail each and every verbal or written discussior/correspondence you had with theBartlett Selectmeh, individually or as a group that related to Mr. Edward Furlong, hisbusiness or his property.

ANSWER:

I was notified by the Selectmen about issues regarding use of snowmobiles on theball field and damage to shrubs by the snow machines. I do not recall any otherdiscussions with the Selectmen relating to the Plaintiff, his business or prlperty.

5' Detail each and every verbal or written discussion/correspondence you have had withthe Bartlett Village Water Precinct, individually or as a whole, relating to Mr. EdwardFurlong, his businesses or his property.

ANSWER:

The only communication I might have had or received from anyone with theBartlett Village Water Precinct was when the Plaintiff fited a suit regarding his useof the accessway on the batl field. At that time I may have received an email or twobut had no real involvement.

6. Attach any and all documents you have regarding any encounter with Mr. EdwardFurlong or any documents or coruespondences regarding any discussion or encounteryou had with anyone else regarding Mr. Furlong, his businesses or his property.

ANSWER:

See prior Answers.

7. When and how did you come to find out that Mr. Edward Furlong had a criminal pastin the state of Florida?

ANSWER:

I do not recall whether I requested a criminal history from the State of Floridabased upon customers of the Plaintiff s business alleging fraud or whether it wasdone when the Plaintiff was charged with trespassing in late 2008 or early 2009.

8. Attach any and all documents you obtained regarding Mr. Edward Furlong from anyindividual or agency.

ANSWER:

I do not believe I have that copy of the criminal record. If it is obtained it will beprovided.

9. Identify all persons who have worked as Bartlett Police Officers in the last ten yearsand the reason for their leavins.

ANSWER:

Objection as it is not likely to lead to admissible evidence.

10. Detail your experience with Mr. Edward Furlong in2002 regarding an incident withJohn Garland (brother to Bartlett Selectman, Douglas Garland) chaining 3

snowmobiles belons to Lil' Man Snowmobile Rentals.

ANSWER:

Objection as it is not likely to lead to admissible evidence and is unrelated toanything in this case.

11. In your answer to the Complaint filed by Mr. Edward Furlong, you admit to pullinghim out of the presidential election voting line in 2004. Set forth the reasons fbr thisaction.

ANSWER:

Objection as it not likely to lead to admissible evidencel however, withoutwaiving that objection, the Defendant states that I thought Furlong might besomeone named Sprague.

l2' On April26,201l you had a conversation with Erin Myatt at the Carroll Countycourthouse in North conway, New Hampshire. with iegards to Mr. EdwardFurlong, his business and his properly, detail your discussion,

ANSWER:

My discussion with Erin Myatt related to the fact that she was an asset being theout-front person for your business and that it appeared that her residing at yourproperty was not necessarily good for her problems.

13. Who contacted you or what prompted you when you came to Mr. Edward Furlong'sproperty on January 23,2009 to serve him an arrest warrant for criminal trespass?

ANSWER:

It is not clear to me that there was ever an arrest warrant served on the plaintiffand that it was done through a Complaint. In addition, I do not believe this wasserved on January 23r2009. Nevertheless, it related to the Plaintiff s use of asnowmobile on property under the control of the Town which was not permitted.The Plaintiff pled guitfy to a violation.

l4' Detail each and every contact the Bartlett Police Department has received regardingMr. Edward Furlong, his business or his propefiy.

ANSWER:

See prior Answers.

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I5. Anach aly and a-ll documents the Bartlett Police Departmot has regerding Mr,

Edward Furlong, his business or his poperty.

ANSWER:

See prior Answers.

16, Whar were you moljvations or what did you hope to gain when you came to Mr.Edward Furlong's property on or about May 1, 2003 to question him about his pist inFlorida?

ANSWER:

Objection as.this is not likely to lead to sdmissible evidencel however, withoutwaiving that objection I do not recall that meeting.

I hereby certifyand belief,

of my knowledge

rHE SrATE O9+iEW HAMPSHIRECOUNTY OF \ o rrsll -, SS

Pc-rsonally appeared Timothy Connifey and acknowledgcd the forcgoing

$atemenrs made by him are rue and accurate to the best of his knowledgc and belie f,