The State of New Hampshire objects to Richard Bergeron's amended motion for sanctions on the grounds that the issue is moot. The State argues that Bergeron had previously filed a motion for sanctions in July 2020, which was denied in an order issued in October 2020. As the original motion was already decided, Bergeron's amended motion is untimely and should be dismissed. Alternatively, the State requests a 10 day extension to file a substantive response if the Court does not dismiss the motion as moot or untimely.

1. STATE OF NEW HAMPSHIRE
Grafton, SS. Superior Court
State of New Hampshire
v.
Richard Bergeron
Superior Court Case: 211-2019-CR-0163
Charge ID: 1602978C, 1602979C, 1602980C, 1602981C, 1602995C, 1602996C
STATE'S OBJECTION TO AMENDED MOTION FOR SANCTIONS
NOW COMES the State of New Hampshire, by and through the Office of the
Grafton County Attorney, Tara J. Heater, Deputy County Attorney and states as follows:
1. The State is in receipt of Defendant’s Amended Motion for Court Ordered
Sanctions. It was received on or about February 1, 2021.
2. The State objects as the issue is Moot.
3. The defendant filed a Motion for Sanctions on or about July 20, 2020. There was
a hearing on the Motion held on September 9, 2020. An Order on the Motion
was issued October 23, 2020 denying the defendant’s Motion.
4. As the Motion was decided and an Order was entered, the defendant’s Motion to
Amend is untimely and should be dismissed as Moot.
5. If the defendant was attempting to file a Motion to Reconsider, it is untimely and
should be denied. See N.H.R.Cr.P. 43(a).
6. If the Court finds that the Motion is neither Moot nor Untimely, the State would
request an extension of the filing deadline to 10 days after the Order to file a
substantive response on the matter. If the Court denies the extension request,
the State would incorporate the Objection as previously filed on July 27, 2020 as
if more fully set forth herein and ask that those arguments be extended to cover
the undersigned and County Attorney Hornick.
WHEREFORE, the State requests that this Honorable Court:
A. DENY the Defendant's Motion without a hearing; or
B. HOLD a hearing on the matter; or
Filed
File Date: 2/9/2021 10:46 AM
Belknap Superior Court
E-Filed Document

2. C. Grant any other relief deemed proper and just.
Respectfully Submitted,
STATE OF NEW HAMPSHIRE
February 9, 2021
/s/Tara J. Heater
_______________________
Tara J. Heater, Esq.
Deputy County Attorney
NH Bar # 265655
Grafton County Attorney's Office
Office of the Grafton County Attorney,
3785 Dartmouth College Highway
North Haverhill, NH 03774
(603) 787-6968
CERTIFICATE OF SERVICE
I hereby certify that I, or my representative, have served a copy of the foregoing
through the New Hampshire Judicial Branch eCourt System on Richard Bergeron,
counsel for the defendant.
Respectfully Submitted,
STATE OF NEW HAMPSHIRE
February 9, 2021
/s/Tara J. Heater
_______________________
Tara J. Heater, Esq.
Grafton County Attorney's Office