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NOW COMES the defendant, Donald Laro, by his attorneys, Wiggin & Nourie, P.A., and files this objection to plaintiffs' motion to compel, and states as follows:

The parties are before the Court in a civil action concerning a telephone jamming operation said to have been engaged in by defendants during the November, 2002 elections. That jamming operation was intended to disrupt or frustrate a "Get Out The Vote" telephone effort on the part of the plaintiffs.

Plaintiffs Raymund Buckley, Jane Gremons, the New Hampshire Democratic Party and Jane Doe ("the plaintiffs") have brought a civil action against defendant New Hampshire Republican State Committee ("NHRSC"), Charles McGee, Milo Enterprises, Inc. Allen Raymond, Chris Cupit, and GOP Marketplace concerning an alleged telephone jamming scheme that is said to have taken place during the November, 2002 election. With respect to each defendant, the plaintiffs allege four counts, including: (1) interference with federal and state constitutional rights to vote and participate in elections; (2) interference with state and federal constitutional rights to free association; (3) civil conspiracy; (4) a request for preliminary and permanent injunctive relief.

Hearing was held on September 7, 1994 with regard to various pending motions. Present were Attorney Richard Inglis, representing the Estate of Infantine; Attorney Richard A. Mitchell, representing Fleet Bank of New Hampshire; Attorneys Emily G. Rice and John T. Broderick, representing Fleet Bank of New Hampshire; Attorney Charles Douglas, III, representing Robert Audley; Attorney Timothy Sheedy, representing Robert H. Brooks; Attorney William S. Gannon, representing Robert Brooks, R. Scott Brooks, HABS/CDM, Inc. and RSA Corp. and R. Scott Brooks, pro se, representing ABI Corp. The Court has reviewed and addressed the following pending motions.

The Court held a hearing on August 13, 1997, for continued argument on pending motions. The plaintiff, the intervenor, and the co-respondent were represented by counsel. The defendant appeared pro se.

At issue in plaintiffs' motion to compel are various documents that plaintiffs had sought from defendant New Hampshire Republican State Committee ("NHRSC") during discovery in this civil action. In earlier proceedings, the Court had entered various discovery orders. Plaintiffs assert that NHRSC has failed to comply with the discovery orders as entered by the Court. The items which presently appear to constitute the central focus of the plaintiffs' motion concern a report arising from an investigation of the underlying telephone jamming issues that had been conducted by legal counsel for defendant NHRSC, and its supporting documents. Counsel for NHRSC submits that the material at issue is protected by the attorney-client privilege as well as the attorney work-product privilege.

The Court has reviewed the transcript of plaintiffs deposition, submitted under Court order of January 31, 2005. By way of brief background, plaintiff claims defendant-decedent failed to stop at a red light on March 16, 2001, striking her vehicle and causing her personal injuries. Plaintiff also claims lost wages from April, 2003 forward. Before the Court is plaintiffs Motion to Appoint a Commissioner, following the abrupt termination of plaintiffs deposition.

Plaintiffs Chris Arnoldy and Rebecca Drummond have brought a civil action against defendants City of Manchester, Manchester Police Department and Stephen Coco concerning an alleged shooting of plaintiff's dog by defendant Stephen Coco. Mr. Coco is a police officer with the City of Manchester. He was on off-duty status when the events at bar are said to have taken place. Plaintiffs seek access to any internal affairs investigation file that may have been prepared by the City of Manchester or the Manchester Police Department concerning the alleged events.

The plaintiffs seek production of credentialing committee records regarding Dr. Day "to determine more precisely what the hospital had done to assure the competency of Dr. Day to perform stress tests before she was hired." See Plt. Motion at p. 5. The request is limited to documents produced before Dr. Day was hired. In addition, the plaintiffs seek an order requiring the hospital's executive director to answer specific questions related to Dr. Day's qualifications to perform stress tests. The defendants object arguing that the documents and related questions are protected from disclosure pursuant to RSA 151:13-a. After a review of the pleadings, related case law and exhibits attached to each pleading, the court grants the plaintiffs' requests.

On July 23, 2002, the defendant filed a motion for discovery. The defendant had requested inter alia that the state be required to produce certain records for a review by the court in camera. The state did not object to this portion of the defendant’s request and, accordingly, the court issued an order on August 14, 2002 granting that portion of the motion.