Timothy Connifey

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 INTERROGATORIES

TO BE ANSWERED BY DEFENDANT TIMOTHY CONNIFEY
NOW COMES the Plaintiff, Edward C. Furlong, and submits the following
interrogatories to Defendant, Timothy, to be answered under oath pursuant to Rule 36 of
the New Hampshire Superior Court Rules within thirty (30) days from the date of service
hereof.
These interrogatories are propounded in accordance with Superior Court Rule 36.
You, Timothy Connifey, must answer each question separately and fully in writing and
under oath. You, Timothy Connifey, must return the original and one (1) copy of your
answers within thirty (30) days of the date you receive them to the party (Edward Furlong
at PO Box 477 Bartlett, NH 03812) that served them upon you. If you object to any
questions, you must note your objection and state the reason. if you fail to retum your
answers within the allotted thirty (30) days, the party who served them upon you may
inform the court, and the court shall make such orders as justice requires, including the
entry of a conditional default against you.
INSTRUCTIONS
t.
"ldentify" shall
mean:
With reference to a document you shall specifically designate the type of

document (such as a letter, interoffice memorandum, report, drawing,
agreement, cpmputer printout, etc.), its date, and such additional
information as will permit the Plaintiff to identify the document, such as
its addressee, its author, its approximate number of pages and its title. If
these interrogatories require you to i{entify a document not in your
custody or possession, please identify any person (pursuant to the
following paragraph) to whom copies of such document have been sent
and the present last known location or possessor of the original document.
with reference to a person, you shall furnish information sufficient to
enable 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 full
name, its last known address, the nature of its business, its relationship to
you and the name of its last known chief executive officer.
2.
In answering these interrogatories, you shall fumish all information which is

available to you including information in the possession of your officers,
employees, attorneys, investigators, agents, or anyone acting on your behalf, and
not merely such information known to your personal knowledge.
3.
These interrogatories are continuing in nature with regard to these matters, as

specified in New Hampshire Court Rule 36 and pAD Rule 4.
4.
In accordance with New Hampshire Superior Court Rule 36, each objection to
these interrogatories shall be forwarded with a statement of reason therefore.
When an objection is made to any part of an interrogatory, the remainder of these
interrogatories shall be answered at the time the obiection is made unless the
period to answer has been extended.
5.
If after exercising due diligence to
secure the information necessary to answer the

following interrogatories in fulI you cannot answer them, state the answer to the
extent possible, specifying the reason or reasons for your inability to answer the
remainder and stating whatever information is available to you concernins the
unanswered portion.
DEFINITIONS
l.
"Documents" - means any written or other recorded, graphic or photographic

matter of any kind or character, however produced or reproduced, and
includes, 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, shop
notebooks, reports, memorandum, market surveys, mechanical and electrical
sound recordings or transcripts thereof, surveys, blueprints, formal or informal
drawings or diagrams, calendar ordinary entries, memorandum or telephone or
personal 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 balance
computation, data processing, materials or analysis or other statistical data
including originals and all non-identical copies of any of the foregoing,

whether types, printed, handwritten or on tape or other recordings, und uny
material underlining, supporting or used in the preparation of any such
document.
2.
"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 or
investigators.
J.
"communication" - means any transfer of information, ideas, opinions or

thoughts by any means, any time or place, under any circumstances and is not
limited to transfers between persons, but in cases other transfers, such as
records and memorandum to file.
4. "Plaintiff'- means and shall refer to Edward
C. Furlong III.
5.
"Defendant"
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"
8.
"Bartlett village water Precinct" - means one or all of the following: Bob
Blake, Matt Howard, Don Mayer, David Ainsworth and/or Bert George.
9.
"Bartlett Village Water Precinct Property" - means the property containing

Black Fly ball field in Bartlett, New Hampshire and located directly to the east
of Mr. Edward Furlong's property.
10.
"Mr. Edward Furlong's Property"
means Timothy Connifey.
- means one or all of the following: Douglas Garland,

Gene Chandler, Jon Tanguay and/or David Patch
- means the property belonging to Mr.

Edward Furlong located at 1455 US Route 302 in Bartlett, New Hampshire
and located directly to the west of the Bartlett village Water Precinct
Propertv.
INTERROGATORIES
1'
Set forth the full name, address, occupation and official capacity
of the person
answering these interro gatories.
ANSWER:
Timothy connifey, chief of porice of the Town of Bartrett

c/o Bartlett Police Department
56 Town Hall Road
Bartlett, NH
2.
Set forth the position, if any, you hold with the Town of Bartlett, Carroll
County or
the State of New Hampshire.
ANSWER:
See
3.
Answer to Interrogatory No.
1.
Set forth the dates, times and substance qf each and every encounter you have had
with the Plaintifl Mr. Edward C. Furlonq.
ANSWER:
I do not recall each and every encountgrl however,I have attached to these
Answers the reports of the Police Department with respect to encounters with the
Plaintiff. In addition , in 2002 or 2003 I had an encounter with the Plaintiff at the
poles.
In addition, I was present at Selectmen's meetings attended by the Plaintiff. I

was there at the request of the Selectmen 4lthough I do not recall any particular
interaction with the Plaintiff.
4'
Detail each and every verbal or written discussior/correspondence you had with the
Bartlett Selectmeh, individually or as a group that related to Mr. Edward Furlong, his
business or his property.
ANSWER:
I was notified by the Selectmen about issues regarding use of snowmobiles on the
ball field and damage to shrubs by the snow machines. I do not recall any other
discussions with the Selectmen relating to the Plaintiff, his business or prlperty.
5'
Detail each and every verbal or written discussion/correspondence you have had with
the Bartlett Village Water Precinct, individually or as a whole, relating to Mr. Edward
Furlong, his businesses or his property.
ANSWER:
The only communication I might have had or received from anyone with the
Bartlett Village Water Precinct was when the Plaintiff fited a suit regarding his use
of the accessway on the batl field. At that time I may have received an email or two
but had no real involvement.
6. Attach any and all documents you have regarding
any encounter with Mr. Edward

Furlong or any documents or coruespondences regarding any discussion or encounter
you 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
past
in the state of Florida?
ANSWER:
I do not recall whether I requested a criminal history from the State of Florida
based upon customers of the Plaintiff s business alleging fraud or whether it was
done 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 any
individual or agency.
ANSWER:
I do not believe I have that copy of the criminal record.

provided.
If it is obtained it will be
9. Identify all persons who have worked as Bartlett Police Officers
in the last ten years
and 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 with

John 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
to
anything in this case.
11. In your answer to the Complaint
filed by Mr. Edward Furlong, you admit to pulling

him out of the presidential election voting line in 2004. Set forth the reasons
fbr this
action.
ANSWER:
Objection as it not likely to lead to admissible evidencel however, without
waiving that objection, the Defendant states that I thought Furlong might
be
someone named Sprague.
l2' On April26,201l you had a conversation with Erin Myatt at the Carroll County
courthouse in North conway, New Hampshire. with iegards to Mr. Edward
Furlong, his business and his properly, detail your discussion,
ANSWER:
My discussion with Erin Myatt related to the fact that she was an asset being the
out-front person for your business and that it appeared that her residing at your
property was not necessarily good for her problems.
13. Who contacted you or what prompted you when you came to
Mr. Edward Furlong's

property 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 plaintiff
and that it was done through a Complaint. In addition, I do not believe this was
served on January 23r2009. Nevertheless, it related to the Plaintiff s use of
a
snowmobile 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 regarding
Mr. Edward Furlong, his business or his propefiy.
ANSWER:
See
prior Answers.
rJQt.aV/ tVL/
t1; UA f A-6. OVOdOg / 4Ag
D..!.J\LL-qI r
ruLJ,vD
w)vut
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.
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 in
Florida?
16, Whar were
ANSWER:
Objection as.this is not likely to lead to sdmissible evidencel however, without

waiving that objection I do not recall that meeting.
***'r*********
of my knowledge
hereby certify
and belief,
rHE SrATE O9+iEW HAMPSHIRE

COUNTY
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,

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STATE OF NEW HAMPSHIRE

PLAINTIFF. EDWARD C. FURLONG'S FIRST SET OF INTERROGATORIES

With reference to a document you shall specifically designate the type of

with reference to a person, you shall furnish information sufficient to

with reference to a corporation, company, business, joint venture,

In answering these interrogatories, you shall fumish all information which is

These interrogatories are continuing in nature with regard to these matters, as

If after exercising due diligence to

secure the information necessary to answer the

"Documents" - means any written or other recorded, graphic or photographic

including originals and all non-identical copies of any of the foregoing,

"communication" - means any transfer of information, ideas, opinions or

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

"other Defendants" - means one or all of the following: Town of Bartlett,

"Bartlett Village Water Precinct Property" - means the property containing

"Mr. Edward Furlong's Property"

means Timothy Connifey.

- means one or all of the following: Douglas Garland,

- means the property belonging to Mr.

Timothy connifey, chief of porice of the Town of Bartrett

Answer to Interrogatory No.

In addition, I was present at Selectmen's meetings attended by the Plaintiff. I

6. Attach any and all documents you have regarding

any encounter with Mr. Edward

in the state of Florida?

I do not believe I have that copy of the criminal record.

9. Identify all persons who have worked as Bartlett Police Officers

in the last ten years

and the reason for their leavins.

with Mr. Edward Furlong in2002 regarding an incident with

filed by Mr. Edward Furlong, you admit to pulling

Mr. Edward Furlong's

t1; UA f A-6. OVOdOg / 4Ag

or what did you hope to gain when you came to Mr.

16, Whar were

Objection as.this is not likely to lead to sdmissible evidencel however, without

rHE SrATE O9+iEW HAMPSHIRE

Pc-rsonally appeared Timothy Connifey and acknowledgcd the forcgoing

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