STATE OF RHODE ISLAND KENT, SC.

Girard Bouchard, in his capacity as President of the Board of Directors of The Central Coventry Fire District, Plaintiff, v. Central Coventry Fire District, Defendant : : : : : : :

SUPERIOR COURT

K.B. No. 12-1150

OBJECTION OF RAYMOND J. ANGELL III TO THE CCFD BOARD OF DIRECTORS PETITION TO CLOSE AND LIQUIDATE THE CENTRAL COVENTRY FIRE DISTRICT Now comes Raymond J. Angell III (hereinafter Angell) and hereby objects to the CCFD Board of Directors (hereinafter Board) Petition to Recommend the Court Authorize the Special Master Close and Liquidate the Central Coventry Fire District (hereinafter District). In support thereof, Angell states the CCFD Board has failed to undertake the necessary and proper due diligence that would lead to a well- reasoned and sound business judgment decision to make such a drastic and dangerous recommendation. Angell has reason to believe and does believe that the vote taken to seek liquidation authorization is based on false and/or misleading information designed to color the judgment of the Board and ultimately the residents of the District. The actions of the Board are not in the best interest of Angell or the District residents as a whole, and I respectfully request that this Honorable Court decline to authorize the Special Master to liquidate the District order and the matter be held for further hearing, debate, review, and analysis to ensure that the safety and welfare of the affected parties is safeguarded. The actions of the CCFD Board and their deficient due diligence will negatively affect the safety and well-being of district residents and businesses, detrimentally alter insurance classifications, and further negatively impact the operation of the District, thus depriving residents of their expectation of adequate and proper fire safety services.

In support of this Objection, Angell provides the following information to this Honorable Court:

1. Angell is a resident of the Central Coventry Fire District (hereinafter District), residing for more than twenty-one years on Station Street in the Town of Coventry. 2. Angell has taken an active interest in the status and direction of the District and has attended meetings, sought clarification, and has provided input whenever possible. 3. Upon information and belief, the Board has undertaken a strategy of misrepresentation and falsehoods designed to prevent transparency and the accurate dissemination of information that would allow residents/taxpayers an opportunity to make a well informed and reasoned decision related to the operation of the District. 4. Illustrative of the above-referenced information, I offer that on September 11, 2013, I made an Open Meetings/Open Records request pursuant to RIGL 38-2-1 et seq. of the Board and/or its representatives to inspect and obtain copies of various public records. (See attached Exhibit 1) 5. The purpose of the request was to obtain information that would allow me as a taxpayer, and/or others I represent, an opportunity to review and provide comment at/during public forums intended to inform the public of the necessary facts prior to voting on decisions impacting the District. 6. The initial response of the Board by/through its agent, Attorney DAgostino, was a nonsubstantive response seeking additional time. 7. Prior to the request for additional time, Angell was publicly chastised by Chairman Gralinski for requesting the information contained in Exhibit 1 and was publicly informed that my request was considered harassment of the Board and as such monetary charges would be imposed to offset the fees the Board would be charged by the Special Master to supply the requested information. The Chairman indicated the request would likely cost the District hundreds of dollars due to the hourly rate of the Special Master. 8. Subsequent to Chairman Gralinskis statements, I spoke with the Special Master to ensure the referenced fees were not going to in any way penalize the District and I was informed by the Special Master that he was not aware of any request made by me and had expended no time to comply with said request, thus causing no cost to the District.
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9. On or about October 24, 2013 I received a Supplemental Response from Attorney DAgostino which is attached hereto as Exhibit 2. 10. Said response indicates in part that no sub-committee meetings dealing with various issues have EVER taken place in direct contradiction to what has been stated/implied at District meetings; the Board has stated that providing documents related to the budget process are voluminous and will cost in excess of $100.00 to reproduce; and additional requests made in and part of Exhibit 1 have not been adequately and properly responded to in violation of the applicable RI General Laws. 11. Upon information and belief, the Board, by and through its agents, have denied Angell access to public records in violation of the RI General Laws for the purpose of depriving a resident/taxpayer of information necessary to form a well-reasoned decision, as well as for punitive reasons. 12. As evidence of the punitive nature of the Boards actions, Angell was intentionally ignored as he attempted to offer public comment at a District meeting, as well as being publicly chastised and insulted at the previously mentioned meeting dealing with the referenced public records request. 13. In an attempt to keep the within Objection as brief as possible, Angell, as an officer of the court and duly licensed attorney of the State of RI, states upon information and belief, the Board has made repeated and numerous statements that misrepresent, mis-state, and misinterpret the nature of the status of the District and the planned resolution of the issues facing the District. 14. The Board has made assertions to this Honorable Court that are intentionally and willfully misleading. Upon information and belief, various statements are simply lies and in direct contradiction to information available to the Board through the proper exercise of their sound business judgment. 15. As but one example of the many disingenuous statements purported to this Honorable Court, Angell cites Chief Baynes statement that he at no time offered a budget request of 7.2 million dollars-a direct contradiction of the lie often cited publicly by the Board and/or its agents.

16. Angell attended the October 21, 2013 Special Meeting and listened to the statements made by the Board and/or its agents and upon information and belief, many statements and positions taken were misrepresentations, mis-statements, and lies including, but not limited to, the Board, by and through its Attorney, indicating the Court and/or the Election Board had issued an order intended to keep non-resident parties from attending the meeting in violation of RI Open Meetings Laws. 17. The referenced apparent violation of RI Open Meetings Laws is not the first time the Board has committed violations of this nature and on more than one occasion the Board has adjourned to secret Executive Session improperly. 18. Based on the above-referenced information, Angell has reason to believe and does believe that the actions of the Board as outlined, are not in the best interest of Angell or the District residents as a whole, and respectfully requests that this Honorable Court deny the Boards Petition to Authorize Liquidation and order the matter be held for further hearing, debate, review, and analysis to ensure that the safety and welfare of the affected parties is safeguarded. 19. Furthermore, Angell requests this Honorable Court authorize the Special Master and/or his designee to attend and participate in all meetings and proceedings held by the Board to ensure that proper and accurate information is considered and/or disseminated so residents/taxpayers can be assured they are supplied with the necessary information to make sound decisions in the near future. Respectfully submitted, RAYMOND J. ANGELL III /s/ Raymond J. Angell III Raymond J. Angell III, Esq. #6291 CASSEL & ANGELL, LLP PO Box 489, Hope RI 02831 401-383-7177-office 401-821-3348-fax 401-413-0972-cell casselangell@cox.net and rja260@gmail.com October 29, 2013

CERTIFICATION A true copy of the foregoing was served on the following via email on October 29, 2013. kmiley@courts.ri.gov, bstern@courts.ri.gov, rland@crfllp.com, jgauthier@crfllp.com, mrobinson@shslawfirm.com, jgatchison@shslawtirm.com; jmccann@shslawfirm.com; Parchambault@BeaconMutual.com; imccoy@benjestlaw.com; jfleming@sos.ri.gov; mary.kay@dem.ri.gov; David.Sullivan@tax.ri.gov; amr@amresq.com; fred@fgtesq.com; WJichardson@centrevillebank.com; lreid@centrevillebank.com; kgrande@edwardswildrnan.com; lholley@risp.dps.ri.gov; wconley@wjclaw.com; mgursky@rilaborlaw.com; torson@orsonandbrusini.com; president@local3372.org; peopleplaces@hotmail.com; carmine@assalone.com; ljones@appeallaw.com; jsmallridge@itwlaw.com; sen-raptakis@rilin.state.ri.us; Nkettle10@gmail.com; repchippendale@rilin.state.ri.us; rep-tomasso@rilin.state.ri.us; rep-nunes@rilin.state.ri.Us; rep-8morgan@rilin.state.ri.us; rep-guthrie@rilin.state.ri.us; joeyb331@verizon.net; alapinski@verizon.net; Bbman1@cox.net; CcfdtaxcollectorO1@firehousemail.com; bcbavnes@yahoo.com; thoover@coventryri.org; nickgorham@gorhamlaw.com; Daviddagostino@gorhamlaw.com; Steve.morris@health.ri.gov; ratherholt@lleaseserv.com; agc@cblaw.necoxmail.com; fredccfd@gmail.com; casselangell@cox.net; rja260@gmail.com /s/ Raymond J. Angell III