Arthur Provencher v. Buzzell-Plourde Associates & a.

Summary

The Supreme Court of New Hampshire affirmed the Superior Court’s dismissal of the plaintiff’s claims, holding that the trial court did not abuse its discretion in refusing a Rule 58 hearing, that absolute witness immunity shields the defendants’ pre‑litigation appraisals because eminent domain litigation was contemplated, and that the plaintiff’s conspiracy claim was waived because it was not raised below. The court emphasized the policy of encouraging free testimony and applied established New Hampshire precedent on absolute privilege.