Veteran Resort Chapel - case docket # 219-CV-00220

State of New Hampshire

Strafford, SS                                                                                  Superior court

                                                            Town of Lee


                                                  Veteran Resort-Chapel

Docket No. 219-CV-00220

                        Motion for court ruling in Veteran Resort-Chapel favor

            Now comes: The Defendant Veteran Resort-Chapel (VRC) in this case a Chapel know as the Veteran Resort-Chapel for Homeless US Military Veterans to find God with man’s help to try to come back from combat to the nation we gave our future for the United States of America.  We the VRC a NH registered Non-profit and a federal 501-c-3 church own the property at 101 Stepping Stone Rd Lee NH and built a church on it.  The God that the combat veteran found and follows may not meet the Lee town government standards but we found God in our own way and believe in.  Homeless Combat Veterans are by law RSA 165:5 must be taken care of by the town they reside in.  This law obligates the community to take care of Homeless US Military Combat Veterans.  The Law Religious Land Use institutionalized person’s act protect churches from exactly what the plaintiff in this case Town of Lee NH is doing to stop us.  Using the courts for such a frivolous case as so stated here in:

1.  The religious belief’s for any one person to freely believe in God as they choose is not a question for the Town of Lee NH to decide for their residents and land owners as is the case here.  The Lee town government and their attorney have stated that they do not recognize the church of the homeless US Military Veterans at 101 Stepping Stone Rd and as such use property tax to help them win this case by attrition   

            a. NH const Part First articles 4,5

            b. RLUIPA

2.  The right for any property owners to park a legally registered trailer on their own property that presents no hazards of safety dangers cannot be diminished by any town government for the sole purpose to find a court reason to inflict harm on such property owner is frivolous less.  The trailer in question is owned and legally registered to the property owner and defendant in this case VRC.

            a.  NH const. Part First articles 1, 2, 3,4,6,8,12, 14, 15, 22,28a, 28,30, 31, 37,

3.  Any property owner in the United States this including NH has the right to have a guest stay on their property with out the town government telling said property owner whom they may have as a guest or not have as a guest as in this case where a church member volunteered her time to stay in the back yard of the 11 acre property several days and nights a week to take care of the homeless veteran living above the chapel. 

            a.  NH const. Part First articles 1, 2,3,5,6,8,

4.  The right of the Defendant in this case VRC to have a sign not attached to any permanent part of the property but free standing leaning against a flagpole in the front yard constitutes personal property and cannot be regulated by the Town of Lee.  The property is a construction site as no certificate of occupancy has been issued.  The town government cannot dictate what toy a child may leave in their front yard or the parents can leave lawn furniture or a sign in the front yard.  The VRC has a sign telling the public what is being built on the property and as such as all other construction sights in Lee NH is allowed to have a sign so we must be allowed to also.

            A.  Children’s toys with words printed on them are in yards all over Lee NH and no court action is taken against them.  Discrimination to single out Homeless Combat Veterans cannot be tolerated by the town of Lee NH or any town.

            a.  NH Const. Part First articles 1, 2, 3, 4, 5, 6, 7, 8,

5.  The defendant VRC in this case is sited for having rented a portable toilet for a construction site at the demand of the Town of Lee NH in order for the VRC to get a building permit.  The portable toilet is maintained and properly cleaned weekly when in use.  The Plaintiff in this case is well aware as stated in court by the plaintiff that the toilet in question here has not been used since Dec. 22 2013 and is waiting for the owning company to pick it up.  Town governments cannot be allowed to dictate what a property owner can and cannot legally have in their yards.  The VRC has a portable toilet that is working in good order but the town of Lee required we rent one as one can reason to cost more money to win by attrition.   The Plaintiff in this case had no town ordinance to site to require the toilet be removed to give the court a reason so they used the Intentional Plumbers code to reach for a reason that does not exist to require a property owner to remove objects from their yard legally placed there by the property owner.  The town of Lee as well as many other property owners have just such toilets on their property which means that the Plaintiff in this case town of Lee NH is singling out the Homeless Combat Veterans because the plaintiff does not want us living in their town.  Discrimination cannot be tolerated.  

            a.  NH Const. Part First the entire Constitution. 

Where fore: The plaintiff in this case the Town of Lee NH brought a frivolous case to this court for the purpose to harass and intimidate the Plaintiff in this case.   Discrimination against the Homeless Combat US Military Veteran as is the clear object of the plaintiff in this case cannot be tolerated.  Discrimination is against the law and this court cannot accept these discriminating actions of the Town of Lee NH against the defendants’ the VRC as so documented in this case.  To use the courts in what appears to defeat a property owner into the dominating use of power by a town government to win by costing the propertyowner excess cost (or win by attrition) cannot be tolerated.   The Religious Land Use Institutionalized Act of 2000 is a law created to stop just such discrimination actions against a religion that a town does not want to recognize.  The VRC is a 501-c-3 Federally recognized non-profit church and in good standing registered with the State of NH as a non-profit church.  We the Religious group of homeless US Military Combat Veterans known as the VRC so pray that this court grants

1.  That the Town of Lee must recognize the fact that the VRC is a church, Religious organization, non-profit and as such is protected by our laws and Constitution.

2.  That the Plaintiff in this case used the law RSA 165:17,15 as a means to intimidate the defendants in this case.  The town was warned in our court papers that we were asking 5 million dollars in damage and costs and since they choose to use frivolous court actions must be held to pay the entire amount.

3.  That the court set a precedence that the law written over 100 years ago RSA 165.5 and revived by the NH government in 2012 is a law to protect and care for Homeless US Military Combat Veterans for with out these men and women this nation the United States of America would not exist as a free Nation.

A copy of this Motion is delivered to the Plaintiff in this case town of Lee NH

Respectfully submitted this 16 Day of September 2014