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JJT&M v. Oxford

JJT&M v. Oxford

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Published by ValleyIndyDotOrg
JJT&M v. Oxford
JJT&M v. Oxford

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Published by: ValleyIndyDotOrg on Jul 26, 2013
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05/09/2014

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Willcutts Law Group, LLC • Attorneys at Law • 285 Farmington Avenue • Hartford, CT 06105 • (860) 524-6800 • Juris # 412755
RET. DATE JULY 16, 2013
JJT & M, INC. : SUPERIOR COURTv. : J. D. at MILFORDTOWN OF OXFORD : JUNE 20, 2013
COMPLAINTCOUNT ONE (Slander of Title Town of Oxford)
1. The plaintiff, JJT & M, Inc., is a Connecticut corporation that, for all timesrelevant hereto, was and is the rightful owner of a parcel of commercial real estatelocated at 66 Hawley Road, Oxford, CT (the “property”).2. Said property includes a commercial building that was designed andconstructed for the purpose of supporting satellite telecommunication operations, andthe plaintiff purchased the property with the intention of using it for such businesspurposes.3. For all relevant times set forth herein, Karen Guillet was the Tax Collector for the defendant Town of Oxford (the “Town”), and in said position she was an officer,employee and/or agent of the Town with respect to the assessment and collection of real estate property taxes on real property situated in the Town, including the plaintiff’sproperty, and the Town authorized Guillet to act on its behalf in collecting real estatetaxes on Town property4. For all relevant times set forth herein, the Town benefitted financially fromTown property owners complying with the directives and instructions issued by Guilletas to the payment of real estate taxes on their properties and the Town actively
 
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Willcutts Law Group, LLC • Attorneys at Law • 285 Farmington Avenue • Hartford, CT 06105 • (860) 524-6800 • Juris # 412755
encouraged its property owners to comply with said directives and instructions issuedby Guillet.5. For all relevant times set forth herein, Guillet engaged in a scheme todefraud various Town property owners by manipulating and altering real estate taxassessments, by failing to credit property owners for payments submitted in payment of their real estate tax bills, and/or by stealing taxpayer funds (hereinafter “the tax fraudscheme”).6. As a direct consequence of Guillet’s tax fraud scheme, numerous Townresidents were issued real estate tax bills by the Town that were inflated, false andfraudulent.7. The plaintiff was a victim of Guillet’s tax fraud scheme, and as a directconsequence of said tax fraud scheme, the Town issued real estate tax bills to theplaintiff that were inflated, false and fraudulent.8. When the plaintiff began protesting and resisting its real estate tax billsthat it perceived to be inflated and erroneous, the Town caused tax liens to be recordedagainst the plaintiff’s property on the Town land records, and said tax lien recordingswere false and fraudulent, as they were based upon inflated, false and fraudulent taxbills, and they were derogatory to the plaintiff’s title to the property. The Town, actingthrough the office of Tax Collector, knew that said tax liens were false and fraudulent or caused them to be recorded with a reckless disregard as to whether they were false,and the Town thereby acted with malice towards the plaintiff in recording false tax liensagainst the plaintiff’s property.9. When the plaintiff continued to protest and resist its real estate tax billsthat it perceived to be inflated and erroneous, the Town further caused a lis pendens of a foreclosure action to be recorded on the Town land records, and said lis pendens wasfalse and fraudulent, as it was based upon enforcement of the Town’s false and
 
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Willcutts Law Group, LLC • Attorneys at Law • 285 Farmington Avenue • Hartford, CT 06105 • (860) 524-6800 • Juris # 412755
fraudulent tax liens, and it was derogatory to the plaintiff’s title to the property. TheTown, acting through the office of Tax Collector, knew that said lis pendens was falseand fraudulent or caused it to be recorded with a reckless disregard as to whether it wasfalse, and the Town thereby acted with malice towards the plaintiff in recording said lispendens against the plaintiff’s property.10. In June 2010, Guillet resigned her position as Tax Collector for the Townunder suspicion that she had engaged in illegal activities in connection with the taxfraud scheme.11. In November 2011, Guillet was arrested on charges of larceny and forgeryin connection with the tax fraud scheme, and sometime prior thereto, Guillet’s successor as Tax Collector became informed as to the nature of the tax fraud scheme, includingthe Town’s issuing false and fraudulent real estate tax bills in reliance upon said taxfraud scheme.12. Notwithstanding Guillet’s successor becoming informed of the tax fraudscheme, the Town ratified the inflated, false and fraudulent real estate tax bills issued tothe plaintiff pursuant to said scheme, as well as the tax liens and lis pendens recordedagainst the plaintiff’s property pursuant to said scheme, by its continuing efforts tocollect upon said inflated, false and fraudulent real estate tax bills, which effortsculminated in the Town conducting a tax sale auction of the property on June 28, 2012and the Town accepting a bid of $600,000 for the property by defendant Angelo Melisi(“Melisi”).13. In conducting said tax sale auction of the property, the Town failed toinform Melisi that the plaintiff disputed the Town’s real estate tax bill on the property, asbeing the product of the Guillet tax fraud scheme, and the Town further failed to informMelisi that the plaintiff disputed the Town’s right to transfer title to the property by meansof a tax sale auction, as these were based upon the tax fraud scheme. When Melisi

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