KEENE, N.H. (MyKeeneNow)  The former owner of a Keene property is pushing back against a buyer’s effort to keep a civil conspiracy claim alive in a $1.6 million lawsuit over alleged misrepresentations surrounding the sale of a 10-unit apartment property.

Jared Goodell, representing himself in Cheshire County Superior Court, filed a reply Aug. 28 asking the court to reject Tatro Road Realty LLC’s arguments and dismiss Count VI of the lawsuit, which accuses Goodell, former Keene Mayor George Hansel and H.G. Johnson LLC of conspiring in connection with the sale of the property at 7–15 Aliber Place.

The latest filing follows Tatro’s objection to Goodell’s Aug. 21 motion to dismiss. Tatro argues that its complaint contains enough factual allegations to support an inference that the defendants acted together, while Goodell maintains that the allegations show, at most, a business relationship and an opportunity to coordinate — not an actual agreement to commit fraud.

Goodell Challenges Conspiracy Allegations

Goodell argues that Tatro has not identified an agreement or “meeting of the minds” between him, Hansel and H.G. Johnson to engage in unlawful conduct.

In his reply, Goodell takes particular issue with representations cited by Tatro concerning the property’s tenants, financial performance and other aspects of the sale. He argues that the complaint itself attributes those representations to Hansel and H.G. Johnson, who were acting as the listing agents, rather than to Goodell personally.

Goodell also disputes Tatro’s reliance on the timing of a $100,000 loan he made to Hansel shortly after the property was listed for sale. He argues that the loan, along with the parties’ business relationships and Hansel’s earlier involvement with the development, does not establish that the defendants agreed to misrepresent the property.

The reply also argues that simply knowing facts about a property does not constitute an unlawful overt act required to establish civil conspiracy.

Tatro’s objection takes a different view, arguing that the complaint lays out a series of connected events involving the defendants’ respective roles in developing, managing, marketing and selling the property, as well as their financial relationships. Tatro argues those allegations are sufficient at the pleading stage for the court to infer concerted action.

Dispute Began With $1.6 Million Sale

Tatro Road Realty, a Bedford-based investment firm, sued Goodell, Hansel and H.G. Johnson in June, seeking to rescind its July 2025 purchase of the apartment complex.

Tatro paid $1.6 million for the property, which Goodell had developed before it was placed on the market in May 2025.

The buyer alleges it was misled about several aspects of the property, including the stability of its tenants, operating finances and construction.

One central allegation concerns the property’s occupancy. Tatro claims that roughly 60 percent of the occupied units were being used to house residents temporarily displaced by a flood at another senior housing property, rather than representing ordinary long-term tenancy.

Tatro also alleges that financial information provided before the sale failed to disclose recurring expenses, resulting in an inaccurate picture of the property’s cash flow.

The lawsuit further alleges that post-purchase engineering testing raised questions about required steel reinforcement in portions of the building’s foundations. Tatro claims the issue was not disclosed before the purchase.

Goodell Seeks Protection From Potential Liability

Goodell’s latest filing is separate from another legal maneuver he made Aug. 21: a cross-claim against Hansel and H.G. Johnson seeking contribution and indemnification.

While denying that he is liable to Tatro, Goodell argues that if the court ultimately finds him responsible for damages, the real estate professionals should bear some or all of that financial responsibility.

Goodell contends that Hansel and H.G. Johnson prepared and transmitted the marketing materials and property information provided to Tatro, including statements concerning tenant occupancy.

He says he did not make the allegedly misleading representations directly to Tatro.

Hansel, a former Keene mayor and licensed real estate salesperson, had been involved with the property during its development and permitting process before later serving as a listing agent. H.G. Johnson was the brokerage involved in the sale.

Tatro is asking the court to unwind the transaction, return ownership of the property to Goodell and recover the purchase price and damages.

Goodell has requested oral arguments on his motion to dismiss and a jury trial on his cross-claims if the case proceeds.

The court had not ruled on the pending motions as of the latest filings.