Check Number Date Amount Monthly Bills

5310 11/18/2010 $1,200.00 Nov-10 $3,975.00
5312 11/30/2010 $2,775.00 Dec-10 $4,448.75
5318 12/7/2010 $1,367.50 Jan-11 $14,577.00
5323 12/18/2010 $3,081.25 Feb-11 $4,216.25
5330 1/1/2011 $6,205.00 Mar-11 $13,812.50
5341 1/15/2011 $4,165.00 Apr-11 $6,077.00
5343 1/20/2011 $3,187.00 May-11 $8,096.25
5345 1/27/2011 $1,020.00 Jun-11 $9,372.50
5349 2/3/211 $3,166.25 Jul-11 $12,855.00
5351 2/10/2011 $1,050.00 Aug-11 $5,800.00
5357 3/1/2011 $3,655.00 Sep-11 $6,530.50
5364 3/8/2011 $3,145.00 Oct-11 $11,923.75
5367 3/17/2011 $4,080.00 Nov-11 $5,121.50
5370 3/27/2011 $1,020.00 Dec-11 $7,203.00
5373 3/31/2011 $1,912.50 Jan-12 $9,495.00
5376 4/7/2011 $1,062.00 $123,504.00
5384 4/17/2011 $3,017.50
5385 4/24/2011 $1,997.50 Average $8,233.60
5390 5/5/2011 $3,782.50 Median $7,203.00
5394 5/16/2011 $4,313.75 Lowest $3,975.00
5403 6/4/2011 $5,377.50 Highest $14,577.00
5406 6/14/2011 $3,017.50
5414 6/23/2011 $977.50
5422 7/14/2011 $8,160.00 Calendar Year 2011
5428 7/25/2011 $4,695.00 $105,585.25
5433 8/4/2011 $1,955.00
5443 8/24/2011 $3,845.00
5447 9/6/2011 $4,367.50 Summary Report
5464 9/22/2011 $2,163.00 Liora Farkovitz
5477 10/8/2011 $5,500.00 TechnologicalEvidence.com
5485 10/22/2011 $6,423.75 9-Mar-12
5507 11/15/2011 $4,101.50 liora@technologicalevidence.com
5511 11/24/2011 $1,020.00 Mobile: 212-470-5441
5515 12/1/2011 $4,228.00
5524 12/13/2011 $2,975.00
5535 1/10/2012 $4,547.50
5536 1/19/2012 $1,062.50
**** 1/1/2012 $3,885.00
$123,504.00
N. J. Sarno & Co., LLC Payments by Check Number Liberti v. Liberti
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To •
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT

NICHOLAS SICINOLFI and :
THE NICHOLAS-JAMES COMPANY :
Plaintiffs, :
:
v. :
: CIVIL ACTION NO.:
TOWN OF TRUMBULL, : 3:03 CV 929 (AWT)
MARLIN LIVELY, :
ANN MOORE, :
RICHARD BERNAUD and :
CHRISTOPHER PAOLETTI, :
Defendants. : December 3, 2004


DEFENDANTS’ MEMORANDUM OF LAW IN SUPPORT OF
MOTION FOR SUMMARY JUDGMENT

The Defendants, Ann Moore, M. James Lively, Richard Bernaud, Christopher Paoletti
and the Town of Trumbull, submit the following memorandum of law in support of their
motion for summary judgment.
I. FACTUAL AND PROCEDURAL BACKGROUND
The Plaintiffs are Nicholas Sicinolfi a/k/a Nick Sarno and the Nicholas-James
Company, LLC. On or about May 23, 2003, the Plaintiffs commenced the present action
against the Defendants Town of Trumbull, M. James Lively, Ann Moore, Richard Bernaud, and
Case 3:03-cv-00929-AWT Document 50 Filed 12/07/2004 Page 1 of 29
Christopher Paoletti. The Complaint was initially asserted in five counts.
1
Count One alleged
that the individual Defendants had violated the Plaintiffs’ “right to be free from false arrest,
detention and groundless interdiction under the Fourth and Fifth Amendments to the United
States Constitution, and plaintiffs’ right to due process of the laws under the Fourteenth
Amendment to the United States Constitution.” (Complaint, Count One, ¶ 22). Count One
sought redress under 42 U.S.C. §§ 1983, 1985 and 1988. (Complaint, Count One, ¶ 24). Count
Two alleged that the individual Defendants “violated plaintiffs’ right to equal protection of the
laws under the Fourteenth Amendment to the United States Constitution,” and sought redress
under 42 U.S.C. §§ 1983 and 1988. (Complaint, Count Two, ¶¶ 26 and 28). Count Three
alleged that the individual Defendants “violated plaintiffs’ rights to freedom of speech and
association under the First Amendment to the United States Constitution,” and sought redress
under 42 U.S.C. §§ 1983 and 1988. (Complaint, Count Three, ¶¶ 30 and 32). Count Four
alleged that the individual Defendants “conspired in violation of 42 U.S.C. § 1985 to violate
plaintiffs’ rights under the First and Fourteenth Amendments to the United States
Constitution,” and sought redress under 42 U.S.C. §§ 1983, 1985 and 1988. (Complaint, Count
Four, ¶¶ 34 and 36). Finally, Count Five alleged that the Town of Trumbull “violated the rights
to free speech and association, due process of the laws and equal protection of the laws
guaranteed plaintiffs by the First and Fourteenth Amendments to the United States

1
All citations to the original Complaint & Jury Trial Demand, dated May 22, 2003, will be simply “Complaint.”
Citations to the First Amended Complaint & Jury Trial Demand, dated October 16, 2003, will be “Amended
2
Case 3:03-cv-00929-AWT Document 50 Filed 12/07/2004 Page 2 of 29
Constitution,” and sought redress under 42 U.S.C. §§ 1983 and 1988. (Complaint, Count Five,
¶¶ 38 and 41).
On or about August 28, 2003, the Defendants filed a motion to dismiss pursuant to Rule
12(b)(6) of the Federal Rules of Civil Procedure asserting that the Court should dismiss Counts
One through Four as to several of the individual Defendants for the Plaintiffs’ failure to state
claims upon which relief could be granted. The Plaintiffs responded by filing an Amended
Complaint, dated October 16, 2003, which the Plaintiffs’ claimed added allegations sufficient
to require the denial of Defendants’ motion to dismiss. (Plaintiffs’ Memorandum, Oct. 16,
2003, p.2). The Defendants replied on or about October 22, 2003 to the Plaintiffs’ Amended
Complaint by noting that it did not cure the deficiencies in the initial Complaint, but merely
compounded them by adding personal attacks against the Defendants wholly unrelated to the
Plaintiffs’ causes of action.
The Court (Thompson, J.) issued its ruling upon the motion to dismiss on February 12,
2004. The Court granted the Defendants’ motion in part and denied it in part: Count One was
dismissed solely as to Moore; Count Two was dismissed as to Moore, Bernaud and Paoletti;
and Count Four was dismissed as to all Defendants. The Plaintiffs have not made any further
amendments to their complaint. The Defendants have answered the remaining allegations of
the Amended Complaint and asserted affirmative defenses in response.

Complaint.”
3
Case 3:03-cv-00929-AWT Document 50 Filed 12/07/2004 Page 3 of 29
The undisputed material facts of this case are as follows. Plaintiff Nicholas J. Sicinolfi
is also known by the name “Nick Sarno.” (See Amended Complaint, case caption). Sicinolfi
and Detective James DeSanty of the Trumbull Police Department were co-owners of Plaintiff
Nicholas-James Company, LLC since its organization in February, 1999. (Amended
Complaint, ¶ 14; Deposition of Nicholas Sicinolfi, attached hereto as Exhibit A, p. 19). On or
about February 20, 1999, Sicinolfi submitted an application for a license to carry pistols or
revolvers to the Town of Trumbull. (Affidavit of M. James Lively, attached hereto as Exhibit
B, ¶ 9; Exhibit B-3). Sicinolfi’s application was processed by his business partner James
DeSanty. (Exhibit A, p. 127; Exhibit B, ¶ 11; Exhibit C, ¶ 6).
The Plaintiffs’ business is self-described as “providing supervised visitation services.”
(Amended Complaint, ¶¶ 12-13). The Plaintiffs allege that their task is “to assure that no harm
comes to children or other parties in domestic cases during visitation.” (Amended Complaint, ¶
12). The Plaintiffs’ business has also been described more directly as providing “protection” to
children in such situations. (Exhibit A, pp. 22-24, 196-97).
Defendant M. James Lively served as the Town of Trumbull’s Acting Chief of Police in
2001. (Amended Complaint, ¶ 5; Exhibit B, ¶ 4). As part of his duties as Acting Chief of
Police, Lively conducted a department-wide review of two matters, which are related to the
Plaintiffs’ claims. First, Lively supervised the review of applications and procedures for the
4
Case 3:03-cv-00929-AWT Document 50 Filed 12/07/2004 Page 4 of 29
issuance of pistol permits in the Town of Trumbull for preceding years. (Exhibit B, ¶¶ 5-8).
2

Second, Lively conducted an investigation of the outside employment activities of all members
of the Trumbull Police Department. (Exhibit B, ¶¶ 12-13).
The investigation of pistol permit applications and officers’ employment activities
raised questions about the legality of Sicinolfi’s pistol permit application and the Plaintiffs’
business activities.
3
As to the investigation of his pistol permit application, it seemed that the
information Sicinolfi supplied was at times incomplete and at other points deliberately false.
For example, Sicinolfi did not list his alias “Nick Sarno” in his application when asked to “List
all other names by which you have been known.” (Exhibit A, pp. 104-105). Sicinolfi’s
application stated that he had served in the Armed Forces, but the Department of Defense had
no record of the Plaintiff serving in the military. (Exhibit B-3; Exhibit B-4; Affidavit of
Christopher Paoletti, attached hereto as Exhibit C, ¶ 6). Sicinolfi’s application stated that he
had experience with pistols and revolvers through his “military service;” (Exhibit B-3); but this
statement was completely false. (Exhibit A, pp. 17, 107-108).
The investigation of Plaintiffs’ business activities was the result of the department-wide
investigation of police officers’ outside employment. In his response to the questions posed to

2
Although she drafted the letter to Lively on behalf of the Trumbull Board of Police Commissioners which
initiated his investigation of the pistol permit applications, Defendant Ann Moore was not personally involved in
the investigation process, nor did she have any involvement in the resultant revocation of Sicinolfi’s permit.
(Affidavit of Ann Moore, attached hereto as Exhibit E, ¶¶ 5-6).
3
Although the report from Deputy Chief Edwards apparently did not include Sicinolfi’s application processed by
Det. James DeSanty, Lively learned of Sicinolfi’s application and reviewed it for accuracy. (Exhibit B, ¶ 9).

5
Case 3:03-cv-00929-AWT Document 50 Filed 12/07/2004 Page 5 of 29
all employees, Det. James DeSanty told Lively that he was employed by the Nicholas-James
Company, LLC and that this business involved working as a “Personal Security Consultant.”
(Exhibit B-6; Exhibit B-9).
4
When asked for more information, DeSanty informed Lively that
his business partner’s name was “Nicholas Sarno.” (Exhibit B-11). In the course of his
investigation, Lively learned that Nicholas Sicinolfi and “Nick Sarno” were the same person,
and that Sicinolfi had failed to include any reference to his business relationship with DeSanty
in his pistol permit application. (Exhibit A, p. 107). Concerned by DeSanty’s description of
the Plaintiffs’ business activities, Lively sent a letter to the State of Connecticut Department of
Public Safety to inquire, inter alia, as to the legality of providing the self-described “supervised
visitation services.” (Exhibit B-12). In response, Lively received a letter, dated June 28, 2001,
stating the Plaintiffs were violating Connecticut law by providing such security services
without a license. (Exhibit B-13).
Sicinolfi came to the parking lot of the Trumbull Police Department on or about August
2, 2001, while conducting “supervised visitation services.” (Amended Complaint, ¶ 31.d.;
Exhibit B, ¶ 16).
5
At that time, Lively noticed Sicinolfi’s presence and ordered Defendant
Paoletti, assisted by Bernaud, to seize the Plaintiff’s pistol permit, to determine if he was

4
The Court may note that in his deposition Plaintiff Sicinolfi denied that he worked as a security consultant,
despite his business partner’s characterization, and despite Sicinolfi having listed personal security consultant as
his occupation in his tax returns. (Exhibit A, pp. 45-49).
5
There is a discrepancy in the evidence as to whether the incident Plaintiff describes as an arrest occurred on
August 2
nd
or 3
rd
, but this discrepancy is of little moment inasmuch as the Plaintiff concedes that he was only
arrested on one occasion, and that the arrest was for his refusal to surrender his state pistol permit. (Exhibit A, pp.
133-34).
6
Case 3:03-cv-00929-AWT Document 50 Filed 12/07/2004 Page 6 of 29
carrying any firearms, and to investigate his presence in the parking lot. (Exhibit B, ¶ 16;
Exhibit C, ¶ 7; Affidavit of Richard Bernaud, attached hereto as Exhibit D, ¶ 5).
6
Sicinolfi’s
Town of Trumbull pistol permit was seized by the police officers, and Sicinolfi was given a
letter from Lively explaining the basis for the seizure of his pistol permit. (Exhibit A, p. 133;
Exhibit B, ¶ 15-16; Exhibit B-14; Exhibit C, ¶ 7). Sicinolfi refused on that date to produce his
State of Connecticut Pistol Permit when asked to do so by Trumbull police officers. (Exhibit
A, p. 134).
Ann Moore was not personally involved in any of the actions alleged to involve a
“campaign of harassment” against the Plaintiffs. (Affidavit of Ann Moore, attached hereto as
Exhibit E, ¶¶ 6-7). For their part, after having made scandalous and irrelevant accusations
against her and her family, the Plaintiffs have not come forward with any evidence that would
establish that Ann Moore was even aware of their existence or had any personal feelings one
way or another about them at the time of the incidents alleged in the Complaint. (See Exhibit
A, p. 63).
II. LAW AND ARGUMENT
A. Legal Standard for Motions for Summary Judgment
Federal Rule of Civil Procedure 56(c) provides, in part, that a motion for summary
judgment shall be granted when a review of the record demonstrates “that there is no genuine

6
In his deposition, Sicinolfi stated that there was a third police officer involved in the August, 2001 incident, but
he was unable to identify him and that officer has not been named as a defendant. (Exhibit A, p. 130-131).
7
Case 3:03-cv-00929-AWT Document 50 Filed 12/07/2004 Page 7 of 29
issue as to any material fact and that the moving party is entitled to a judgment as a matter of
law.” Fed. R. Civ. P. 56(c). The burden falls on the moving party to establish that no relevant,
material facts are in dispute. Heyman v. Commerce & Indus. Ins. Co., 524 F.2d 1317, 1320 (2d
Cir. 1975). In determining whether a genuine has been raised, a court must resolve all
ambiguities and draw all reasonable inferences against the moving party. See United States v.
Diebold, Inc., 369 U.S. 654, 655, 82 S. Ct. 993, 8 L. Ed. 2d 176 (1962) (per curiam); Quinn v.
Syracuse Model Neighborhood Corp., 613 F.2d 438, 445 (2d Cir. 1980).
The nonmoving party, however, cannot simply rest on the allegations in his pleadings
since the essence of summary judgment is to go beyond the pleadings to determine if a genuine
issue of material fact exists. See Celotex Corp. v. Catrett, 477 U.S. 317, 324, 106 S. Ct. 2548,
91 L. Ed. 2d 265 (1986). Federal Rule of Civil Procedure 56 (e) provides, in part:
When a motion for summary judgment is made and supported as provided in this rule,
an adverse party may not rest upon the mere allegations and denials of the adverse
party’s pleadings, but the adverse party’s response, by affidavits or as otherwise
provided in this rule, must set forth specific facts showing that there is a genuine issue
for trial. If the adverse party does not so respond, summary judgment if appropriate,
shall be entered against the adverse party.

If the movant demonstrates an absence of material issues of fact, a limited burden of production
shifts to the nonmovant, who must “demonstrate more than some metaphysical doubt as to the
material facts, . . . [and] must come forward with specific facts showing that there is a genuine
issue for trial.” (Emphasis in original; internal quotation marks omitted.) Aslanidis v. U.S.
Lines, Inc., 7 F.3d 1067, 1072 (2d Cir. 1993). “[P]roperly employed, summary judgment is a
8
Case 3:03-cv-00929-AWT Document 50 Filed 12/07/2004 Page 8 of 29
useful device for unmasking frivolous claims and putting a swift end to meritless litigation….
Thus, the mere possibility that a factual dispute may exist, without more, is not sufficient to
overcome a convincing presentation by the moving party.” (Citations omitted; emphasis in
original.) Quinn, supra, 613 F.2d 445; see also Donnelly v. Guion, 467 F.2d 290, 293 (2d Cir.
1972)(“[w]hen a party presents evidence on which, taken by itself, it would be entitled to a
directed verdict . . . it rests upon [the opposing ] party at least to specify some opposing
evidence which it can adduce and which will change the result”). If the nonmovant fails to
meet this burden, summary judgment should be granted. The question is whether there is
sufficient evidence to reasonably expect that a jury could return a verdict in favor of the
nonmoving party. See Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 106 S. Ct. 2505, 91
L. Ed. 2d 202 (1986).
B. Count One - § 1983 Unreasonable Seizure Claim
As set forth above, Count One originally was asserted against all four individual
Defendants, but this Count was dismissed as to Ann Moore due to the Plaintiffs failing to
adequately allege personal involvement by Moore in the alleged arrest or detention. The
remaining three individual Defendants assert that summary judgment should be granted as to
them. The Defendants assert that even if the Plaintiffs had been arrested as alleged in Count
One, summary judgment is appropriate because 1) any detention was properly related to the
investigation and revocation of Plaintiff Sicinolfi’s pistol permit; 2) the Defendants would have
9
Case 3:03-cv-00929-AWT Document 50 Filed 12/07/2004 Page 9 of 29
been justified in arresting Sicinolfi for violating Connecticut General Statutes § 53a-167a by
his conduct; and 3) the Defendants would have been justified in arresting Plaintiff Sicinolfi for
providing security services without a license, in violation of Connecticut General Statutes §§
29-153, et seq.
1. Seizure Related to Investigation and Revocation of Pistol Permit
Although there were no charges ever filed against the Plaintiffs by the Town of
Trumbull; (Exhibit A, p. 137; Exhibit B, ¶ 17); the Plaintiffs allege that Sicinolfi was detained
and arrested by Defendants Lively, Paoletti and Bernaud on August 2, 2001, at the Trumbull
Police Station. (Amended Complaint, ¶ 31.d.). Nevertheless, solely for the sake of the instant
motion, the Defendants will assume, arguendo, that the Plaintiff was seized on August 2, 2001
and that such seizure constitutes an “arrest” for purposes of the application of the Fourth
Amendment of the United States Constitution.
7
Whether or not Sicinolfi was “arrested,” it was
appropriate for the Defendants to conduct an investigation into his conduct on August 2, 2001.
This investigation was appropriate due, in part, to his false and misleading statements made in
his application for a pistol permit from the Town of Trumbull. In fact, the Defendants had

7
The Plaintiffs’ allegations of an arrest, however, are curious in light of the fact that Plaintiff Sicinolfi testified at
his deposition that he believed he was under arrest and not free to leave the police station on August 2, 2001, but
that he left regardless, without being given permission to do so. (Exhibit A, pp. 134-137). Indeed, Sicinolfi’s
conduct in leaving the Police Department would subject him to criminal prosecution for Escape from Custody,
pursuant to Connecticut General Statutes § 53a-171, had the events actually transpired as described by the
Plaintiffs. See, generally, State v. Laws, 37 Conn. App. 276, 280-85, 655 A.2d 1131 (discussing proof of escape
from custody), cert. denied, 234 Conn. 907, 659 A.2d 1210 (1995).
10
Case 3:03-cv-00929-AWT Document 50 Filed 12/07/2004 Page 10 of 29
probable cause to arrest Sicinolfi on August 2, 2001 for violating Connecticut General Statutes
§ 53a-157b.
The Fourth Amendment to the United States Constitution provides, in pertinent part:
“The right of the people to be secure in their persons, houses, papers, and effects, against
unreasonable searches and seizures, shall not be violated….” It is well-settled that a valid
arrest may be made without a warrant where the arrest is properly supported by probable cause.
“If an officer has probable cause to believe that an individual has committed even a very minor
criminal offense in his presence, he may, without violating the Fourth Amendment, arrest the
offender.” Atwater v. City of Lago Vista, 532 U.S. 318, 354, 121 S.Ct. 1536, 149 L.Ed.2d 549
(2001); see also Oliver v. Woods, 209 F.3d 1179, 1186 (10
th
Cir. 2000)(“An officer may make
an arrest without a warrant if the officer has probable cause to believe a crime has been
committed by the arrestee.”). “There is probable cause when the arresting officer has
knowledge or reasonably trustworthy information sufficient to warrant a person of reasonable
caution in the belief that an offense has been committed by the person to be arrested.” (Internal
quotation marks omitted.) O’Neill v. Town of Babylon, 986 F.2d 646, 650 (2d Cir. 1993).
“Of course, state law defines the authority of an officer to arrest for a given offense;
federal law only asks whether the officer had probable cause to believe that the predicate
offense had been committed. Michigan v. DeFillippo, 443 U.S. 31, 36, 99 S.Ct. 2627, 2631, 61
L.Ed.2d 343 (1979) (‘Whether an officer is authorized to make an arrest ordinarily depends, in
11
Case 3:03-cv-00929-AWT Document 50 Filed 12/07/2004 Page 11 of 29
the first instance, on state law.’).” Richardson v. Bonds, 860 F.2d 1427, 1342 n.4 (7
th
Cir.
1988).
In this regard, the Court should note, “[Connecticut] General Statutes [§ ]54-1f(a)
authorizes police officers to arrest an individual without a warrant, for any offense in their
jurisdiction, when the person is taken or apprehended in the act or on the speedy information of
others ... [A] warrantless misdemeanor arrest must be supported by probable cause.” (Internal
quotation marks omitted.) State v. Santiago, 224 Conn. 494, 498, 619 A.2d 1132 (1993).
Connecticut recognizes that “[p]robable cause to arrest exists if (1) there is probable
cause to believe a crime has been committed; and (2) there is probable cause to believe that the
person to be arrested committed that crime ... Probable cause exists when the facts and
circumstances within the knowledge of the officer and of which he has a reasonably
trustworthy information are sufficient in themselves to warrant a man of reasonable caution to
believe that a [crime] has been committed.” (Citations omitted.) State v. Trine, 236 Conn.
216,236, 673 A.2d 1098 (1996). The test for determining probable cause is objective, and
requires more than mere suspicion. Id., 237. “[T]he line between mere suspicion and probable
cause necessarily must be drawn by an act of judgment formed in light of the particular
situation and with account taken of all the circumstances ... In dealing with probable cause ... as
the very name implies, we deal with probabilities. These are not technical; they are factual and
practical considerations of everyday life on which reasonable and prudent men, are not legal
12
Case 3:03-cv-00929-AWT Document 50 Filed 12/07/2004 Page 12 of 29
technicians, act.” (Citations omitted; internal quotation marks omitted.) State v. Trine, supra,
236 Conn. 236-37.
The Plaintiffs state that Sicinolfi was arrested for refusing to surrender his state pistol
permit. (Exhibit A, pp. 133-34). There is no disagreement between the parties that the August
2, 2001 incident was connected with his pistol permit. The Defendants, however, assert that
the investigation into Sicinolfi’s conduct was appropriate in light of his false and misleading
responses given in his pistol permit application and due to the fact that his business partner
processed said application. There can be no legitimate dispute that it was inappropriate for
Sicinolfi’s friend and business partner, James DeSanty, to conduct the background
investigation for Sicinolfi’s pistol permit application. (See Exhibit B, ¶ 11; Exhibit B-13).
The application itself contained incomplete and inaccurate responses, which were only
disclosed once an independent investigation was conducted. (Exhibit B, ¶ 11; Exhibit C, ¶¶ 5-
6). Given these concerns, it was more than reasonable that the Defendants seize Sicinolfi’s
pistol permit.
Furthermore, the Defendants assert that the undisputed facts which were known to them
on August 2, 2001, provided probable cause to believe that Plaintiff Sicinolfi had committed
the crime of False Statement in the Second Degree, pursuant to Connecticut General Statutes §
53a-157b.
8
The Town of Trumbull pistol permit application signed by Sicinolfi and witnessed

8
Section 53-157b provides: “(a) A person is guilty of false statement in the second degree when he intentionally
makes a false written statement under oath or pursuant to a form bearing notice, authorized by law, to the effect
13
Case 3:03-cv-00929-AWT Document 50 Filed 12/07/2004 Page 13 of 29
by a notary public, bore the notice “I declare, under the penalties of False Statement, that the
answers to the above are true and correct.” (Exhibit B-3). The application contained
information which Sicinolfi knew to be false at the time the application was submitted,
including: 1) the failure to list his alias “Nick Sarno”; 2) stating he was “self-employed” rather
than listing the Nicholas-James Company as his business; and 3) stating he received training on
pistols and revolvers during military service. (Exhibit A, pp. 103, 105, 108; Exhibit B, ¶ 11;
Exhibit B-3; Exhibit C, ¶ 6). Where there is no genuine issue of material fact that Sicinolfi’s
pistol permit contained these falsehoods, it would have been appropriate for the Defendants to
arrest Sicinolfi on the spot for violating Connecticut General Statutes § 53a-157b.
2. Arrest for Interfering With an Officer; Conn. Gen. Stat. § 53a-167a;
Justified In Light of Sicinolfi’s Conduct

Plaintiff Sicinolfi testified that he was arrested on August 2, 2001 for refusing to
surrender his state pistol permit when asked to do so by police officers. (Exhibit A, pp. 133-
34). This refusal by the Plaintiff to cooperate in a lawful police investigation into his illegal
conduct was itself a violation of Connecticut law.
Connecticut General Statutes § 53a-167a provides:

that false statements made therein are punishable, which he does not believe to be true and which statement is
intended to mislead a public servant in the performance of his official function.
“(b) False statement in the second degree is a class A misdemeanor.”
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“(a) A person is guilty of interfering with an officer when such person obstructs, resists, hinders
or endangers any peace officer or firefighter in the performance of such peace officer's or
firefighter's duties.
“(b) Interfering with an officer is a class A misdemeanor.”
The Plaintiff had no right to retain possession of a state pistol permit which he had
gained by false and misleading information on his application to the Town of Trumbull. By
refusing to surrender his state pistol permit on August 2, 2001, Plaintiff Sicinolfi was
attempting to “hamper the activities of the police in the performance of their duties,” thus
violating Connecticut law. See White v. Wortz, 66 F. Supp. 2d 331, 334 (D.Conn. 1999);
State v. Biller, 5 Conn. App. 616, 621, 501 A.2d 1218 (1985) (upholding conviction for
interfering based upon arrestee’s refusal to surrender documents in his possession), cert.
denied, 199 Conn. 803, 506 A.2d 146, cert. denied, 478 U.S. 1005, 106 S.Ct. 3296, 92 L.Ed.2d
711 (1986).
Moreover, the United States Supreme Court has acknowledged the propriety of
allowing police officers a reasonable amount of discretion in conducting investigations into
suspected criminal activity. Recently, in Hiibel v. Sixth Judicial District Court of Nevada,
United States Supreme Court No. 03-5554 (June 21, 2004), the Court held that an arrest of a
Terry stop suspect for refusal to identify himself, in violation of Nevada law, did not violate the
Fourth Amendment prohibition against unreasonable searches and seizures, because the stop
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was reasonable and plaintiff did not claim that the statute was unconstitutionally vague. The
Court also concluded that the defendant’s conviction for refusal to identify himself did not
violate his Fifth Amendment right against self-incrimination because disclosure of his name
and identity presented no reasonable danger of incrimination. The principle set forth by the
majority in Hiibel supports a conclusion that there was no violation of the Plaintiffs’
constitutional rights under the circumstances.
Even if the August 2, 2001 incident occurred precisely as described by the Plaintiff in
his deposition, the police officers’ conduct was completely appropriate and supported by
Connecticut law. In spite of the lack of formal charges being filed against Plaintiff Sicinolfi, he
violated Connecticut law, and an arrest would have been proper under the circumstances.
3. Plaintiffs Providing Security Services Without License
The Plaintiffs’ Amended Complaint is nothing less than an admission of their own
violation of Connecticut law. The Plaintiffs are not entitled to continue providing “supervised
visitation services” in the guise of the unlicensed and unqualified Plaintiff Sicinolfi. The
Defendants would have been justified in arresting the Plaintiffs for violating Connecticut
General Statutes §§ 29-153, et seq.
The Plaintiffs’ business is self-described as “providing supervised visitation services.”
(Amended Complaint, ¶¶ 12-13). The Plaintiffs allege that their task is “to assure that no harm
comes to children or other parties in domestic cases during visitation.” (Amended Complaint, ¶
16
Case 3:03-cv-00929-AWT Document 50 Filed 12/07/2004 Page 16 of 29
12). The Plaintiffs’ business has also been described more directly as providing “protection” to
children in such situations. (Exhibit A, pp. 22-24, 196-97).
Connecticut General Statutes § 29-153 provides as follows:
No person shall engage in the business of, or solicit business as a private detective or
investigator or as a watchman, guard or patrol service or represent himself to be, hold
himself out as or advertise as a private detective or investigator or as furnishing
detective or investigating services or as a watchman, guard or patrol service without
first obtaining a license from the Commissioner of Public Safety.

In addition, Connecticut General Statutes § 29-161 provides:

Any person who violates any provision of sections 29-153 to 29-161, inclusive, shall be
fined not more than five thousand dollars or imprisoned not more than one year or both.

The Plaintiffs will no-doubt deny that they were violating Connecticut law each and
every time that they engaged in “supervised visitation services.” Nevertheless, the Plaintiffs’
description of “supervised visitation services” falls within the category of “watchman, guard or
patrol service” as those terms are used in the statute. Conn. Gen. Stat. § 29-153.
The terms “watchman, guard or patrol service” are not specifically defined in the statute
itself. Instead, the Court should consider the Opinion of the Attorney General, Opinion No. 86-
65 (August 26, 1986), in determining the scope of these terms. In that Opinion, former
Attorney General of the State of Connecticut Joseph Lieberman utilizes the method commonly
approved by Connecticut courts of looking to the standard dictionary definition of terms when
the terms are not specifically defined in statutes. The Attorney General’s opinion notes that
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“guard” is defined as “one that defends against injury danger or attack … a man or body of men
stationed to protect or control a person or position.”
The District Court may also consider the regulation promulgated by the Connecticut
Department of Revenue Services, Section 12-426-27, which defines “Private investigation,
protection, patrol, watchman and armored car services” as follows:
Such services mean and include providing personnel or canines to patrol or guard
property; engaging in detective or investigative duties; safeguarding or maintaining a
surveillance of an individual; maintaining and monitoring mechanical protective
devices, such as burglar and fire alarm systems; providing armored cars for the
transportation of valuables; wrapping coins; setting up a payroll; and the rendering of
police services by an off-duty policeman.

(Emphasis added.)
And, finally, the Court should consider the fact that Defendant Lively consulted the
Connecticut Department of Public Safety with regard to the legality of the Plaintiffs’ activities.
(Exhibit B, ¶ 14; Exhibit B-12). The Connecticut Department of Public Safety responded to
Defendant Lively’s inquiry by stating, “From the evidence presented by your investigator, the
Nicholas-James Company is more than a security consultant company; they are providing
security for which they must obtain a license. Our records indicate the Nicholas-James
Company is not a licensed security company and they are in violation of several sections of
chapter 534 of the Connecticut General Statutes” (Exhibit B-13).
The Defendants violated Connecticut General Statutes § 29-153 by providing what they
term “supervised visitation services.” If the Plaintiffs were arrested on August 2, 2001, that
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arrest was proper, and summary judgment should enter as to any claims based upon such an
arrest.
C. Count Two – § 1983 Equal Protection Claim
In Count Two, the Plaintiffs attempted to assert a claim under 42 U.S.C. § 1983 for
Defendants’ alleged violation of Plaintiffs’ rights under the Fourteenth Amendment equal
protection clause. The Court has dismissed Count Two as to all Defendants but Lively. In its
ruling on the Defendants’ motion to dismiss, the Court held that the Complaint alleges one
action by Lively that might qualify under this cause of action: revocation of pistol permit.
(Ruling on Motion to Dismiss, p.10).
In its Ruling, the Court noted that the United States Supreme Court has recognized
“class of one” equal protection claims in limited circumstances. See Village of Willowbrook v.
Olech, 528 U.S. 562, 564, 120 S.Ct. 1073, 145 L.Ed.2d 1060 (2000). As quoted by the District
Court here, to state a “class of one” claim, a plaintiff must allege that he or she “has been
intentionally treated differently from others similarly situated and that there is no rational basis
for the difference in treatment.” Id. The Plaintiffs’ claim cannot survive this analysis.
The Plaintiffs have not come forth with any evidence of other persons making false and
misleading statements in their pistol permit applications, whose permits were approved or
treated differently than Plaintiff Sicinolfi’s by Defendant Lively. In fact, Defendant Lively
conducted a review of all of the pistol permit applications over several previous years. (Exhibit
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B, ¶¶ 5-8). Furthermore, there was a rational basis for the revocation of Sicinolfi’s pistol
permit given the information available to Defendant Lively. (Exhibit B, ¶ 11; Exhibit B-13).
Wherefore, the Court should grant summary judgment as to Count Two of the
Complaint.
D. Count Three - § 1983 First Amendment Claim
In Count Three, the Plaintiffs attempt to assert that the individual Defendants violated
the Plaintiffs’ rights to freedom of speech and association under the First Amendment to the
United States Constitution. The Plaintiffs allege that the Defendants subjected the Plaintiffs to
“a campaign of harassment” as a consequence of the alleged relationship between the Plaintiffs
and certain disfavored members of the Trumbull Police Department and as a consequence of
the Plaintiff allegedly publicly criticizing the Defendants. (Amended Complaint, ¶¶ 31-35).
The Plaintiffs have produced no evidence to support such a claim, and the facts underlying the
so-called “campaign of harassment” demonstrate that there were legitimate reasons for each of
the actions taken.
First, as to Defendant Ann Moore, there is no connection between Ann Moore and the
Plaintiffs whatsoever. The Plaintiffs are not personally acquainted with Ann Moore. Despite
the Plaintiffs making numerous malicious allegations against Ann Moore and her family in the
body of their Amended Complaint; (see Amended Complaint, ¶¶ 18, 28); the Plaintiffs could
not state how many sons Ann Moore has or what their names are. (Exhibit A, pp. 76, 78). For
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her part, Defendant Moore was not even aware of the Plaintiffs’ existence at the time of the
incidents alleged in the Complaint. (Exhibit E, ¶¶ 6-7). The Plaintiffs have chosen to give vent
to their personal animosity towards Defendant Moore through the federal courts, but they have
failed to produce any evidence linking Defendant Moore to the actions taken against the
Plaintiffs. Defendant Moore has submitted an affidavit, which establishes that she was not
involved in the alleged “campaign of harassment.” (Exhibit E, ¶ 7). In light of this undisputed
evidence, the Court should grant summary judgment as to the sole remaining claim against Ann
Moore. As to the remaining Defendants, Lively, Bernaud and Paoletti, these Defendants’
actions were appropriate in light of the Plaintiffs’ illegal activities, despite the label “campaign
of harassment” given by the Plaintiffs.
The first incident described as part of the “campaign of harassment” involves police
cruisers being sent to Plaintiff Sicinolfi’s home in mid-April, 2001 with regard to a suspected
unregistered motor vehicle. (Amended Complaint, ¶ 31.a.). The Plaintiffs were not witnesses
to this portion of the “campaign,” but, from what Plaintiff Sicinolfi testified to in his
deposition, it is clear that the Defendants were not involved in any wrongdoing. (Exhibit A, pp.
139-42; Exhibit B, ¶ 18; Exhibit C, ¶ 8; Exhibit D, ¶ 6). Apparently, Plaintiff Sicinolfi had
done a “supervised visitation service” in the parking lot of the Trumbull Police Department
using a car that had either transferred plates or new plates. (Exhibit A, pp. 139-41). When a
question arose as to the registration, two police cruisers were sent to Plaintiff Sicinolfi’s house.
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(Exhibit A, pp. 139-140). Once Plaintiff Sicinolfi heard of the investigation, he went to the
Trumbull Police Department with documentation establishing the registration of the vehicle.
(Exhibit A, p. 142). The Defendants, however, were not involved with this investigation and
only learned about it after the fact. (Exhibit B, ¶ 18; Exhibit C, ¶ 8; Exhibit D, ¶ 6).
The second incident described involves Defendant Bernaud allegedly detaining one of
the Plaintiffs’ clients on May 21, 2001, in order to question the client about the Plaintiffs.
(Amended Complaint, ¶ 31.b.). Despite having made this allegation, the Plaintiffs have no
first-hand knowledge of this incident. (Exhibit A, pp. 61-62, 146). Moreover, Defendant
Bernaud has provided an affidavit that establishes he was not involved in any such incident.
(Exhibit D, ¶ 7).
The third and fifth incidents described as part of a “campaign of harassment” involve
Defendant Lively contacting Plaintiff Sicinolfi to make inquiries into his pistol permit
application and, ultimately, revoking the pistol permit. (Amended Complaint, ¶31.c.). Despite
the Plaintiffs’ conclusion in their Amended Complaint that “there was no legal ground to
revoke [the pistol permit],” the Defendants have shown that there existed ample, multiple
grounds upon which Plaintiff Sicinolfi’s pistol permit should be revoked. (See Exhibit A, pp.
105, 108; Exhibit B, ¶ 11; Exhibit C, ¶ 5-6). The Plaintiffs have no cause to complain against
the investigation which arose as the result of Sicinolfi’s own illegal conduct.
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The fourth incident has already been discussed in connection with the Defendant
argument as to Count One of the Amended Complaint. The Plaintiffs assert that Defendants
Lively, Paoletti and Bernaud falsely arrested Plaintiff Sicinolfi at the Trumbull Police
Department. (Amended Complaint, ¶ 31.d.). As noted in Part II.B. of this memorandum, there
were ample grounds to support an arrest of Sicinolfi in response to his illegal activities.
There is no genuine issue of material fact which would support a conclusion that the
Defendants engaged in a “campaign of harassment” as alleged in the Amended Complaint.
Wherefore, the Court should enter summary judgment as to Count Three of the Amended
Complaint.
E. Defendants Entitled to Qualified Immunity in Relation to the Incidents
Alleged as Campaign of Harassment

Although the Defendants have demonstrated the absence of any proof of wrongdoing on
their parts, they assert as an additional, alternative basis for granting summary judgment as to
Counts One, Two and Three that the doctrine of qualified immunity shields them from liability.
“The defense of qualified immunity shields government officials from civil liability if
the official's conduct did not violate constitutional rights that were clearly established at the
pertinent time or if it was objectively reasonable for the official to believe that the conduct did
not violate such rights.” Cecere v. City of New York, 967 F.2d 826, 829 (2d Cir. 1992).
Furthermore, “[e]ven defendants who violate constitutional rights enjoy a qualified immunity
that protects them from liability for damages unless it is further demonstrated that their conduct
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was unreasonable under the applicable standard.” Davis v. Scherer, 468 U.S. 183, 190, 104
S.Ct. 3012, 82 L.Ed.2d 139 (1984). A subjective inquiry into a government employee’s
motivations in acting or refusing to act has been rejected because it generally implicates
questions of fact and is therefore incompatible with the expressed policy that summary
judgment be readily available to protect government employees from suit. See Harlow v.
Fitzgerald, 457 U.S. 800, 815-19, 102 S.Ct. 2727, 73 L.Ed.2d 396 (1982). “Summary
judgment on the issue of objective reasonableness is appropriate where no reasonable jury
could conclude that it was objectively unreasonable for defendants to believe they were acting
in a manner that did not clearly violate an established federally protected right.” (Emphasis in
original.) Smart v. Morgillo, Docket No. 3:00cv1281, 2001 WL 802697, *2 (D. Conn. Jul. 10,
2001); see also Lennon v. Miller, 66 F.3d 416, 423-26 (2d Cir.1995) (finding qualified
immunity for false arrest, malicious prosecution and excessive force claims).
In the present case, the individual Defendants’ conduct was objectively reasonable.
First, as noted in Part II.D., there is not one iota of evidence which connects Defendant Moore
to the investigation or alleged arrest of the Plaintiffs. Even if there were such evidence,
however, the undisputed facts available to the Defendants at the time of the incidents alleged in
the Amended Complaint establish that their actions towards the Plaintiffs were objectively
reasonable. As noted in detail at Part II.B. of this memorandum, the Plaintiffs appear to have
committed at least three violations of Connecticut law for which the Defendants could have
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arrested Plaintiff Sicinolfi or fined Plaintiff Nicholas-James Company, LLC. The fact that the
Plaintiffs were never formally charged with a crime; (see Exhibit A, p. 137); does not change
the fact that there was an objective basis which would have supported such an arrest.
Therefore, the Defendants are shielded from liability by qualified immunity, and the Court may
grant summary judgment in favor of the Defendants on that ground in addition to those already
set forth herein.
In considering the applicability of the doctrine of qualified immunity to the present
case, the Defendants submit that the following cases may also provide insight for the Court’s
decision. “With respect to whether a wrongful arrest has occurred, considerable uncertainty
must be tolerated on occasion because of the need to allow the police to take immediate
affirmative action in ambiguous circumstances…. The Constitution therefore does not
guarantee that only guilty persons will be arrested.” (Citation omitted; internal quotation marks
omitted.) Lukos v. Bettencourt, 23 F. Supp. 2d 175, 177 (D. Conn. 1998); see also Krause v.
Bennett, 887 F.2d 362, 371 (2d Cir. 1989) (noting that probable cause does not require an
officer to be certain that subsequent prosecution of the arrestee will be successful); Mozzochi v.
Borden, 959 F.2d 1174, 1179-80 (2d Cir. 1992) (holding defendants qualifiedly immune from
liability under First Amendment claim where criminal prosecution was supported by probable
cause); Johnston v. City of Houston, 14 F.3d 1056, 1060-61 (5
th
Cir. 1994) (qualified immunity
where complaint failed to allege sufficient involvement on part of defendant).
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F. Count Five – §§ 1983 and 1988 Against Town of Trumbull
Count Five of the Amended Complaint incorporates all of the allegations set forth in
Counts One, Two and Three and brings a claim directed solely towards Defendant Town of
Trumbull. The Plaintiffs, however, have failed to demonstrate any violation of their rights.
Defendant Town of Trumbull is not liable where there has been no underlying violation of
Plaintiffs’ rights.
It cannot be disputed that the Plaintiffs’ failure to demonstrate the existence of evidence
in support of the alleged underlying violations must result in the Court granting summary
judgment as to the Plaintiffs’ claims against the Town of Trumbull. “It is clearly established
that a municipality cannot be held liable under § 1983, whether on a failure to train theory or
municipal custom and policy theory, unless the municipal/state employee is found liable on the
underlying substantive constitutional claim.” Friedman v. City of Overland, 935 F.Supp. 1015,
1018 (E.D.Mo. 1996); see also Los Angeles v. Heller, 475 U.S. 796, 799, 106 S. Ct. 1571, 89
L. Ed. 2d 806 (1986) (“If a person has suffered no constitutional injury at the hands of the
individual police officers, the fact that the departmental regulations might have authorized the
use of constitutionally excessive force is quite beside the point.”); Curley v. Village of Suffern,
268 F.3d 65, 71 (2d Cir. 2001) (“a municipality cannot be held liable for inadequate training or
supervision when the officers involved in making an arrest did not violate the plaintiff’s
constitutional rights”)..
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In the present case, the individual Defendants have set forth irrefutable evidence of the
Plaintiffs’ illegal conduct. There was no violation of the Plaintiffs’ rights where 1) Plaintiff
Sicinolfi had no right to retain a pistol permit gained by false and misleading answers in his
application and where the application was processed by his business partner, James DeSanty
(see Part II.B.1.); 2) Plaintiffs were engaged in providing security services without a license
(see Part II.B.3.); and 3) there was an objective, rational basis for each of the actions alleged to
involve a “campaign of harassment.” (See Part II.D.).
The Defendant Town of Trumbull has no liability to the Plaintiffs for any claimed
underlying violation of their rights, because the evidence is undisputed that the Plaintiffs’ rights
were never violated. The Court should enter summary judgment in favor of Defendant Town
of Trumbull as to Count Five.
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Case 3:03-cv-00929-AWT Document 50 Filed 12/07/2004 Page 27 of 29
III. CONCLUSION
The Plaintiffs have made scandalous, irrelevant and unsupported allegations against the
Defendants. The Plaintiffs have had more than enough opportunity to come forward with
evidence to support their claims against the Defendants. What the evidence has established,
however, is a clear pattern of wrongdoing on the part of the Plaintiffs, with no indications of
any wrongdoing or improper motives on the part of the Defendants.
WHEREFORE, the Court should enter summary judgment as to Counts One through
Three and Count Five.

DEFENDANTS,
TOWN OF TRUMBULL,
MARLIN LIVELY, ANN MOORE,
RICHARD BERNAUD and
CHRISTOPHER PAOLETTI


By:
Stuart E. Brown (ct 24659)
Hassett & George, P.C.
555 Franklin Avenue
Hartford, Connecticut 06114
(860) 296-2111


28
Case 3:03-cv-00929-AWT Document 50 Filed 12/07/2004 Page 28 of 29
29
CERTIFICATION

This is to certify that a copy of the foregoing has been mailed this ___ day of
December, 2004 to the following counsel and/or pro se parties of record:
William B. Barnes, Esq.
Rosenstein & Barnes
1100 Kings Highway East
Fairfield, CT 06825



Stuart E. Brown

















\\Sbs2k\shared\Northland Cases\Sicinolfi, Nicholas, et al v. Town of Trumbull, et al\Pleadings\Memo to support Motion for Summary
Judgment.doc
Case 3:03-cv-00929-AWT Document 50 Filed 12/07/2004 Page 29 of 29
2/28/12 1:22 AM
Page 1 of 8 file:///Users/sunnykelley/Desktop/liora%20docs/njsarnollc%20sms%20complete%20history.webarchive
SMS Messages
Sunday, February 27, 2011
Sunday, March 13, 2011
Sunday, March 27, 2011
Tuesday, March 29, 2011
Hi Sunny it's me Sarno. I
have Atty. Bordieri e-mail
nut sure if we have the
other atty's e-mail. Can
you please give it to
Allison with the check.
Thanks Sunny
10:37 AM
hi nick. please help me
figure out what's going on
with meeting rich
8:05 AM
hes not here and therefore
I'm late for picking max up
8:05 AM
no one is picking up the
phone so I've left
messages with him, you,
and allison
8:06 AM
I went to trader joes to use
the bathroom, if you arrive
soon. will be back out
shortly
8:43 AM
We're good to go Allison is
on her way. Max is still not
well but better then
yesterday so make sure
you have ever thing you
need at home. Once at
your house I think it would
be wise he stay inside
today thanks Sunny
7:28 AM
Good morning. Ron had
keep Max home from
school had little fever last
night no big deal. Pick up
will be at their house at
3:00 pm Allison will call
you
8:42 AM
2/28/12 1:22 AM
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Thursday, March 31, 2011
Tuesday, December 6, 2011
ok. thanks 8:42 AM
Welcome 8:43 AM
Max is home today so pick
up there at 3pm. Allison
will call to conferm Thanks
Sunny
9:22 AM
ok. thanks. will see allison
then
9:23 AM
Your welcome yes you will 9:24 AM
hi nick. there is no one
here at the meeting place.
please let me know who
was supposed to be here
and how I can contact
them. neither you nor
allison is picking up.
thanks.
3:28 PM
richie got here in time for
3:30 pickup. problem is
that pickup was supposed
to be at 3pm today but no
one notified me or richie
about it in time. this is
unacceptable. please
notify your staff when
there is a variation to the
schedule in time. thanks
3:46 PM
We found out last min.
You need to check that
sight for info also we can't
do it all
4:29 PM
12:30 isn't last minute. and
your staff has to ind out
when their visit starts.
thanks for working this out
today.
9:50 PM
It was last min. We did the
best we could all you lost
was 15 mins but you did
2/28/12 1:22 AM
Page 3 of 8 file:///Users/sunnykelley/Desktop/liora%20docs/njsarnollc%20sms%20complete%20history.webarchive
Thursday, December 22, 2011
was 15 mins but you did
get to visit with your son
as i said was the best we
could do . If Thats not
good enough please
contact your attys and Atty
Murphy
9:54 PM
I have done so. but let's be
clear that it was 30
minutes lost and that I am
entitled by court order to a
full visit, so let's not act like
I'd better be grateful for
anything I get no matter
how truncated it is. once
again thank you for your
efforts.
9:57 PM
Excuse me when was the
last time you went on that
sight to check what's going
we have to depend on Rob
for info by the time it filters
down to all partys it dosen'
t happen in mins. Plus
yours is not the only Case
we have. Once again we
did our best.Thank you
and good night.
10:02 PM
nick, I have no Internet so
I'm unable to check time
and location of pickup
today. is it at 3pm at robs
house? thnx
12:12 PM
Excuse me who is this ? I
don't know this number
12:14 PM
this is sunny 12:14 PM
Ohhhhh sorry 12:14 PM
Yes I belive so. If Max ins't
in school then yes it is
12:15 PM
ok. I'll be at meeting place
before 3. please make
sure mike knows as well.
thnx
12:16 PM
2/28/12 1:22 AM
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Wednesday, December 28, 2011
Sunday, January 1, 2012
Friday, January 6, 2012
Monday, January 9, 2012
Yes about 2:45 at
resturant
12:16 PM
great. thnx 12:18 PM
Sunny. We are going to
need a payment tomorrow
As of The Dec 23 visit your
balance is now $4845.
Last billing was $3910.
Therefore we will need last
billing of $3910 paid
please , if not I'll have to
cut your visits back to
Tusedays and Thursdays
till you catch up.Thank
you.
9:34 PM
hi nick. this is sunny.
there's no one here at the
meeting place yet
8:55 AM
I don't know who's on
today and so can't contact
anyone
8:55 AM
He's there 8:56 AM
no. here. there is no one
here
8:56 AM
that was: I'm here. there is
no one else here
8:57 AM
He should be pulling in 8:57 AM
ok. just saw him. thanks 8:57 AM
Sunny we have a
promblem. Your check for
$4000 bounced
3:46 PM
Sunny. I need to know
2/28/12 1:22 AM
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Tuesday, January 10, 2012
Tuesday, February 7, 2012
Sunny. I need to know
about payment today by
4pm or I have to reach out
to the Attys. Also email
was sent to your mother
about it. Please get back
to me. Thank you
11:12 AM
Sunny I spoke to my
admin Susan I will except
your check in the amount
of $4000. You will tender it
over to mike prior to the
start of the visit before pick
up.You check will once
again be deposited with
our bank tomorrow
morning. If no check is
received there will no visit.
Thank you.
12:24 PM
We will wait till 3:45 then
we are leaving will be no
visit
3:27 PM
I am here on time for
picking my son up at
school. after I arrived on
time I learned that my son
was not in school and my
parenting time should
have started at 3pm.
3:38 PM
Next time read your emails 3:39 PM
I check my email regularly
including just before I left
my house
3:39 PM
Hi Sunny. We will meet
you same time and place
as always but I'll need your
pass port in order to have
a visit today. Thanks
10:27 AM
Sunny will you get back to
me please
12:00 PM
did I miss a question? I'll
see mike? at 3:20.
12:07 PM
2/28/12 1:22 AM
Page 6 of 8 file:///Users/sunnykelley/Desktop/liora%20docs/njsarnollc%20sms%20complete%20history.webarchive
Thursday, February 9, 2012
Monday, February 13, 2012
see mike? at 3:20.
I need your passport or
visit will not take place
12:08 PM
Sorry but it's in the court
order
12:09 PM
yes, I'll bring the passport 12:10 PM
It can't be a expired one
must be the one that's
curent
12:12 PM
my passport is current 12:14 PM
Great see you later 12:14 PM
How long kiddo ? 3:26 PM
soon. traffic 3:26 PM
K 3:29 PM
Do you want to me same
place or Dr. Collins office?
2:57 PM
I'm sorry. I don't
understand what you
mean
2:57 PM
why are we meeting? 2:58 PM
Just checcjef with Collins
no need for us to be there
see you saturday
3:01 PM
ok 3:01 PM
got this from Rob. No visit
tomorrow. See attachment
I just took Max to the
doctor. He will take
antibiotics. He is to stay
home from school on
2/14/12.
6:08 PM
2/28/12 1:22 AM
Page 7 of 8 file:///Users/sunnykelley/Desktop/liora%20docs/njsarnollc%20sms%20complete%20history.webarchive
Thursday, February 16, 2012
Tuesday, February 21, 2012
Thursday, February 23, 2012
2/14/12.
There will be no visit with
his mom.
Doctor's note available
upon request.
Got e-mail Max is still not
feeling well no visit today.
11:58 AM
See you at 1:45 today also
you have to start CC Rob
on this. I did this time
11:53 AM
Chuck will meet you same
place and time you have
Dr Collins today. After
drop off at the house at
6pm please conferm.
Thanks
12:15 PM
I don't understand this 12:59 PM
You have Dr Collins today
at 4 you and chuck will
pick up at school ho to
Collons and drop off Max
at 6.
1:21 PM
ok. I'll meet chuck at 3:20.
thanks
1:21 PM
please see you email 2:27 PM
requires immediate
attention. thanks
2:28 PM
From understanding this is
fine for today
2:30 PM
I think you should spend a
little time with Max
2:31 PM
understanding by whom,
please
2:31 PM
2/28/12 1:22 AM
Page 8 of 8 file:///Users/sunnykelley/Desktop/liora%20docs/njsarnollc%20sms%20complete%20history.webarchive
Monday, February 27, 2012
Dr Collins 2:33 PM
Don't worry if problem I'll
take the heat on this
2:33 PM
You need to see. Max 2:34 PM
yes, my son needs his
mother as much as
possible and I would love
more than anything to see
him. but you and dr Collins
are not authorized to
violate court orders. the
consequences to max of
my doing so would far
outweigh the joy of seeing
him. it wouldn't be right for
you, as an agent of the
state, to encourage the
violations of my rights or
the violation of court
orders
2:38 PM
John Collins wants to see
you and Max. He knows
you Chuck are picking him
up nit a problem
2:58 PM
Read the order it's fine 2:58 PM
max is not in school today 3:03 PM
We send our billing to your
mom more then once via
email. When can we
expect payment please.
3:19 PM
Please respond 5:07 PM
Business Inquiry
Business Inquiry Details
Business Name: N.J. SARNO & CO., LLC Business Id: 0817403
Business Address:
89 WEST LAKE RD,
TRUMBULL, CT, 06611
Mailing Address: NONE
Citizenship/State Inc: Domestic/CT Last Report Year:
Business Type:
Domestic Limited Liability
Company
Business Status: Active
Date Inc/Register: Apr 06, 2005
Principals
Name/Title: Business Address: Residence Address:
NICHOLAS J.
SICONOLFI
MANAGER/MEMBER
89 WEST LAKE RD, TRUMBULL,
CT, 06611
89 WEST LAKE RD., TRUMBULL, CT, 06611
IMPORTANT: There are more principals for this business that are not shown here.
Business Summary
Agent Name: NICHOLAS J. SICONOLFI
Agent Business
Address:
89 WEST LAKE RD, TRUMBULL, CT, 06611
Agent Residence
Address:
89 WEST LAKE RD, TRUMBULL, CT, 06611
View Filing History View Name History View Shares
Back
Commercial Recording Division http://www.concord-sots.ct.gov/CONCORD/PublicInquiry?eid=9744&...
1 of 1 2/25/2012 12:58 PM
Business Inquiry
Filing History
Business Id Business Name
0817403 N.J. SARNO & CO., LLC
Filing
Number
Filing Date/Time
Effective
Date/Time
Filing Type
Volume
Type
Volume
Start
Page
Pages #
0002899658
Apr 06, 2005
8:30:00 AM
ORGANIZATION B 00745 1204 1
0003883310
Mar 11, 2009
8:30:00 AM
INTERIM
NOTICE
B 01260 1299 1
Back
Commercial Recording Division http://www.concord-sots.ct.gov/CONCORD/PublicInquiry?eid=9748&...
1 of 1 2/25/2012 1:13 PM
Business Inquiry
Business Inquiry Details
Business Name: N.J. SARNO & CO., LLC Business Id: 0817403
Business Address:
89 WEST LAKE RD,
TRUMBULL, CT, 06611
Mailing Address: NONE
Citizenship/State Inc: Domestic/CT Last Report Year:
Business Type:
Domestic Limited Liability
Company
Business Status: Active
Date Inc/Register: Apr 06, 2005
Principals
Name/Title: Business Address: Residence Address:
NICHOLAS J.
SICONOLFI
MANAGER/MEMBER
89 WEST LAKE RD, TRUMBULL,
CT, 06611
89 WEST LAKE RD., TRUMBULL, CT, 06611
IMPORTANT: There are more principals for this business that are not shown here.
Business Summary
Agent Name: NICHOLAS J. SICONOLFI
Agent Business
Address:
89 WEST LAKE RD, TRUMBULL, CT, 06611
Agent Residence
Address:
89 WEST LAKE RD, TRUMBULL, CT, 06611
View Filing History View Name History View Shares
Back
Commercial Recording Division http://www.concord-sots.ct.gov/CONCORD/PublicInquiry?eid=9744&...
1 of 1 2/25/2012 1:13 PM
Business Inquiry
Name Change History
Business Id Business Name
0817403 N.J. SARNO & CO., LLC
No Name Change Records found for Business with ID : 0817403
Back
Commercial Recording Division http://www.concord-sots.ct.gov/CONCORD/PublicInquiry?eid=9747&...
1 of 1 2/25/2012 1:16 PM
Business Inquiry
Business Inquiry Details
Business Name: N.J. SARNO & CO., LLC Business Id: 0817403
Business Address:
89 WEST LAKE RD,
TRUMBULL, CT, 06611
Mailing Address: NONE
Citizenship/State Inc: Domestic/CT Last Report Year:
Business Type:
Domestic Limited Liability
Company
Business Status: Active
Date Inc/Register: Apr 06, 2005
Principals
Name/Title: Business Address: Residence Address:
NICHOLAS J.
SICONOLFI
MANAGER/MEMBER
89 WEST LAKE RD, TRUMBULL,
CT, 06611
89 WEST LAKE RD., TRUMBULL, CT, 06611
IMPORTANT: There are more principals for this business that are not shown here.
Business Summary
Agent Name: NICHOLAS J. SICONOLFI
Agent Business
Address:
89 WEST LAKE RD, TRUMBULL, CT, 06611
Agent Residence
Address:
89 WEST LAKE RD, TRUMBULL, CT, 06611
View Filing History View Name History View Shares
Back
Commercial Recording Division http://www.concord-sots.ct.gov/CONCORD/PublicInquiry?eid=9744&...
1 of 1 2/25/2012 2:31 PM
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Nicholas
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Name Age Location
Possible
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Nicholas
Siconolfi
24 Brooklyn, NY  Annette P
Siconolfi,
Anthony V
Siconolfi I,
Anthony M
Siconolfi,
Chris C
Siconolfi 
Available  Available 
Nicholas
Siconolfi
Nicholas J Siconolfi
2 more
63 Trumbull, CT
Fairfield, CT
North
Hollywood,
CA
Los Angeles,
CA
Westport, CT
Stratford, CT
Milford, CT
Santa
Monica, CA
Burbank, CA 
Debra Ann
Siconolfi,
Jonathan M
Siconolfi,
Joseph
Siconolfi,
Margaret M
Siconolfi,
Salvatore
Siconolfi 
Available  Available 
Nicholas
Siconolfi
Nicholas A Siconolfi
Nicholis Siconolfi
90 Rochester,
NY
Hilton, NY
Westland, MI
Inkster, MI 
Anthony N
Siconolfi,
Edith M
Siconolfi,
Gerald R
Siconolfi Sr,
Janice Ann
Siconolfi,
Marci Lynn
Siconolfi 
  Available 
Nicholas A
Siconolfi
90 Rochester,
NY 
Edith M
Siconolfi,
Gerald R
Siconolfi Sr,
Nicholas A
Siconolfi 
Available  Available 
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Nicholas J Siconolfi
Age: 63
Trumbull, CT
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nicholas J siconolfi
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Personal Info
4 Daniels Farm Rd Apt, Trumbull, CT 06611
Previous Addresses
Aliases
Name: Nicholas J Siconolfi
Age: 63
Date of Birth: 04/28/1948
Address:
4 Daniels Farm Rd
Trumbull, CT 06611
Phone Numbers:
203-368-1964
203-394-2815
203-375-0333
203-375-8138
203-375-2888
203-380-2343
Address Last Seen
4 Daniels Farm Rd Apt, Trumbull, CT 06611 11/2006
128 Sterling St, Fairfield, CT 06825 11/1998
4445 Cartwright Ave Apt 308, North Hollywood, CA 91602 06/1990
10535 Wilshire Blvd # 14, Los Angeles, CA 90024 06/1990
89 W Lake Rd, Westport, CT 06880 02/1978
4A Pearl Hill St, Milford, CT 06460
2930 Colorado Ave, Santa Monica, CA 90404
1200 W Riverside Dr Apt 288, Burbank, CA 91506
89 W Lake Rd, Trumbull, CT 06611
2567 Broadbridge Ave, Stratford, CT 06614
44445 Cartwright Ave, North Hollywood, CA 91602
89 Weston Rd, Westport, CT 06880
Name Age DOB
Nicholas J Siconolfi Unavailable Unavailable
Nicholas J Siconolfi 63 04/28/1948
Nicholas Siconolfi 63 04/28/1948
Nicholas Siconolfi 63 04/1948
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Table of Contents Possible Relatives
Nicholasj J Siconolfi 63 04/28/1948
Nicholas Siconoffi 63 04/28/1948
N Siconolfi 63 04/28/1948
Nicholas Siconoffi 63 04/1948
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NJ SARNO & CO LLC | TRUMBULL, CT http://www.ishcc.org/CT/Trumbull/n-j-sarno-amp-co-llc
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Contact Information
89 West Lake Rd
Trumbull, CT 06611
Other Information
Entity Status: Active
Type of Entity: Domestic Limited Liability Company
Entity Creation Date: Apr 06, 2005
Days in Business: 2519 days
Employees
Nicholas J Siconolfi: Manager/member
Registered Agent
Nicholas J Siconolfi
Ct, CT NONE
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