Professional Documents
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Town of Oxford, by and'through its First Selectman, Mary Ann Drayton-Rogers, 486 Oxford Road, Oxford, Connecticut 06478
NAME(S), ADDRESS(ES) AND'TELEPHoNE NO(S). oF DEFENDANT(S) AGAINST WHOM PREJUDGMENT REMEDY lS SOUGHT (rvo., sbeet, town and zip code) (Attach
.
addilidnat sh,eet if n ecessary)
GUillet, Karen M., 2 Dou las
g Oxford, Gonnecticut 06478 (Telephone: 203-888-9787)
AND ADDRESS OF ANY THIRD PERSON HOLDING PROPERW OF DEFENDANT WHO IS TO BE MADE A GARNISHEE BY PROCESS PREVENTING
DISSIPATION
NAME AND ADDRESS OF ATTORNEY, LAW FIRM OR PIAINTIFF lF PRO SE (No., skeet and zip code)
FOR THE PLAtNTtFF(S) Ffancis A- Teodosio, Welch, Teodosio, Stanek & Blake,
ENTER THE
APPEARANCEOF: DATE SIGNED
12J912910
You have rights specified in the Connecticut General Statutes, 9Q3a, that you may wish to exercise concerning
this application for a prejudgment remedy. These rights incl a neannq:
(1) to object to the proposed prejudgment remedy a defense to or set-off against the action or a'codnterclaim
against the plaintiff or because the amount sought in the application for the prejudgment remedy is unreasonably high or
because payment of any judgment that may be rendered against you is covered by any irisurance that rnay be available to you;
(2) to request that the plaintiff post a bond in accordance with section 52-278d of the General Statutes to secure you against
any damages that may result from the prejudgment remedy;
(3) to request that you be allowed to substitute a bond for the prejudgment remedy sought; and
: (4) to show that the property sought to be subjected to the prejudgment remedy is exempt from such a prejudgment remedy.
You may request a hearing to contest the application for a prejudgment remedy, assert any exemption or make a request concerning
the posting or substitution of a bond in connection with the prejudgment remedy. The hearing may be requested by any proper motion
pr by completing section lll below and returning this form to the superior court at the Court Address listed above.
You have a right to appear and be heard at the hearing on the application to be held at the above court location on:
DATE COURTROOM
l, the defendant named below, request a hearing to contest the application for prejudgment remedy, claim an exemption or
request the posting or substitution of a bond. I claim: ('X" the appropriate boxes)
ll tnat the amount souoht in the aoolication'ior l-l a defense. counterclaim. I ilffil iltilt tilil tilt iltilt til llil til fiil
- prejudgment remedy-is unreasdriably high. - set-off, or'exemption. CLPJRH
FOR COURT USE ANLY
I tnat any judgment that may be rendered is [-] tnat I be allowed to substitute a
aoequatety secured Dy tnsurance. - bond for the prejudgment remedy. s{.JFtrR-IOR. C(}[J}.T'
DISTRICT OF AT{SOI{IA/I}4IT,FORD
l-l tnat the plaintiff be reouired to oost a bond to secure me aqainst
any daniages that ma! result fiom the prejudgment remed!.
I certify that a copy of the above claim was mailed/delivered to the Plaintiff
DEC 0I 2010
or the Plaintiffs aftornev on the Date,Mailed/Delivered shown below. I .'
'.' oere coevfiesy ue lEbEEltveneo
JAM]ES F. Q[JnnW
ctruEF cLERt(
PJR cv t o.-
NAME OF EACH PARTY SERVED' ADDRESS AT W|IICH SERVICE WAS MADE'
'lf necessary, attach additional sheet with names of each party served and the address at which service was made.
V.,
:
AT }ULFORD
i
, Affidavits. .
To attach the following real pioperty of the Defendant GUILLET located in the
'Towu of Oxford, County of New Hav1, and Stato of Connecticut and frrther described
bounded and described in Schedule A which is atlached hereto and made a part hereof,
Defendant GUILLET in the amorrnt of Six Hundred Seventy One Thousand Seven
i€ub'i.eq!,'19,'q+!; 4lld
iBirri{c.i or
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lqn r.
. ranf, .'lngnlh I"pritr+tc
;I ordlh.an ce4;
"V.. , AIISONIA.MILF'ORD
i AT MILF,ORD
: KARIN M. GTIILLET AND DECEMBER 9,2010
IIARTF.OT{ TTnn INSURANCE COMPAI\iY
made application for a prej+dgnent remedy to attach the property of the Defendant . .
' were fully heard, it is found that there is probable that a judgment in the amount of the
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prejudgment remedy sought, or in an'amount greater than the amount of the prejudgment
remedy sought;taking into account any known defenses, counterclaims or setoffs, will be
' .rendered in this matter in favor of the Plainfiff TOWN OF OXFORD, and that the
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l|aHERE/lS, after due hearing, at which the Plaintiff appeared and was.firlly
heard, but th,e Defendant KAREN M.. GIIILLET made default'of appearance, it is
found that copies of the application for prejudgment remedy, accompanying affidavit,
' proposed order for prejudgment remedy,. unsigned writ, summbns and compliant, notice
and claim form,.order for hearing and riotice, and summons.for hearing were duly served
file, and it'is also fotrnd that there is probable cause that.a judgment in the amount cif tlie
Defendant KAREN M. GIIILLET, and that the Plaintiff may attach property to.the
value of Six Hundred Seventy One thousand Seven Hundred Sixty Eight alid 771100'
($671,768.77) Dollars
: . BY THE COIIRT
Clerk
,! ,i'
,ti
wEL.CH. TEODOSIO, STANEK & BLAKE, LLG - 4TTqRNEYS AT LAW ' 068220
. 3?5 BRIDGEPORT AVENUE -SHELTON, CT 0648',+ - 203-925-3000
' 4Sl OXFoRO RoAD - oxFoRD, cT 05478 -.203-881-3600
., .t
-.DOCKNT
':
NO.
v. : ANSONTA-MI]LFORD
..
. AT MILF'ORD ' .
COMPLAINT
with the
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'ieceived; (2). depositslips made; and (3) deposits presented to the local bank in which:the
.:
Officp of the Tar Collector deposited ta,x payment$ she received.
the final resp'onsibilify for: (1) receiving tan payments; (2) preparing deposit sipj.for such
taken the
directed
or:1a9k thereof to,indicate that the'Defendant GUILLET had taken other amounts' Qf ,;
' ,l
12. .The ad hoc committee'estimated that for the period between July of 2003
.' ' . . '14. The Harrford Fire Insurance Company, a.Connecticutbased insurance
:'
I
'':
' ..' :' 15,' Inaccoidance'with:Ccs'52:564, the Plainfiff ToYvN oF oxFoRD is. .
.a
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BYJ.
FRANCIS A. TEODOSIO
Juris #102585
Welch, Teodosib, Stanek &
48l Oxford Road
Oxford, Connectic ut 0 647 8
Teleohone: 203-881-3600
F dcsimile: 203-881-3606
i:-
wELcH, TEoOosIo, STA.NEK & BLAKE, L.LC - arrbn.ueYs AT LAw - 0682.2'0
, jzs B'Rr,DGEpoRT AvENUE. - sHELToN, cT 06484 .* 203-92s-3000 '
. ,,. : .:.
'
.;rowN.oroxroRDByANDTHRoucH . s[rpERroRCpunr
-ITS,FIRST SELECTMAN,
. .
AT MILF'ORD .
"
. XANNX M. GUII,LET NTVO .
DECEMBER 9, 20,10
T.IRTTORD F'IRE.INSURAI\CE COMPANY
':. AD DAMNUM
- THE PLAINTTFN
BY:
RANCIS A. TEODOSIO
Juris #102585 . :. "
Welch, Teodosio, Stanek &:tsfake, LiC
481 Oxford Road
" Oxford, Connecticut 06478
Telephone: 203-881-3600,,'
f,'acsimile: 203-881-3606
)
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..subJecg. tp: auclr ,f,act8 |s, cn 1Bscffttd :*'urire11:, d6.q7.sf '*n+fe.Ctde+ of tt*fr,.prilq*Fni
p+l'ilClsclnrsi '
A}[SONIA-MILFORD
AT MILFORD
: rnnnN M. GUILLET AND DECEMtsER 9,2010
: HARTtr'ONU TTNN INSURANCE COMPAI{Y
:
AF'F'IDAVIT
STATE OF CONNECTTCUT )
i ss:
Otford
) --^ ^'
o---t
: .
The undersigned JOIIN P. Kil,EY, JR. being duly swom, does depose und say: ..
' 1. dhat he is over the age of eighteen (18) years and believes'in the
obligations of an oath.
"2. Thal on gr. about.June 17, 201A, First Selectman Maqy Am Drayton=
Rogers appointed him to a three-member ad hoc committee to review and investigate the
recoids of the Oxford Tax Collector and in particular thosb records pertaining to monies
' . received,.deposit slips made and deposits made by Ms. Karen Guillet.
:STATE OF COII{NECTICUT )
recotds of the Oxford,Tax Collector and in p'articular those records pertainng to monies
. recbived, deposit slips made ald deposits made by Ms. Karen Guiltet.
' -I
-.i
'
wEr-,cu., .trEoDos.lo, srAN.EK e elake, . LLc - ''ntf o.aHeYs AT tAlv.. 068220
, 3T5 BRIDGEPOR.T AVENUE - SHEL.TOt'l' CT 06484 - 203'92s'3000
481,'OXFORD 804D - 'oxF0R.D, CT. 06478 - 203-881'3600
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. 3. That he, {ong with the other two members, after reviewing in detail the
'records of the Oxford Tax Collector concluded that there was sufficient infomration to
indicate that between the dates of July of 2003 and December of 2009 Ms.'Karen Guitlet
took for her own benefit funds in the amount of Six Hundred Seventy One Thousand
TOWN OF OXFORD
JAMES IILWA
Finance Director
NOTARY PIJBLIC
W A;;il;;;;nires: ?/a/+u,,
v., AIISOIIIA-MILtr'ORI)
AT MILFORD
AX'F'IDAVIT
STATE OF CONNECTICUT )
) ss: Oxford
couNTY oF NEW TTAVEN )
The urdersigned JOSEPH CALABRESE being duly swom, does depose and
say:
1.. That he is over the. age of eighteen (18) years and believes in the
obligations of an oath.
2. That on or about June 17, 2010, First Selectrnan Mary Ann Drayton-
Rogefs appointed him to a three-member ad hoc committee to review and investigate the
.received, deposit slips made and deposits made by Ms. Karen Guillet.
: ' 3. That he,.along;with the other two members, after reviewing:in detail,'the
:
'rbcord.d of the Oxford Ttx Collector concluded that there was lufficient informhtion to
..
lindigate that between the dafes of July of
2003 and December of 2009 Ms. Karen Guillet
'.:
for her own benefit funds in thd amount of Six Hundred Swenty. One Thousahd
toqk '3
TOWN OF OXFORD
CALABRESE
NOTARY PT]BLIC
My Commission Expires: 1/S/aary
,I
".AT LAw'.oogzzlo
WELCH, TEODOSIO, STANEK & BLAKE,' LLC - ATToRNEYs
izs sRtoeEPoRT AvENUE - sHELroN' CT 06484 - 203'925i3000
': 'os4za
481 OXFoRD ROAD' - OxFORD; GT - zos-aai-seoo' .
.:
' DOCTqT NO.
..TOWN.ON SUPERIOR CO{'RT
OXX'ORD BY AND THROUGH J
,ITS..FIRST
SEI.ECTMAN,,
"
MARY ANN DRAYTON.ROGERS JUDICIAL DISTRICT OF
.:
lV. ANSONIA..MILtr'ORD ..
AT MILF'ORD
KARENM.GU&LETAND ; .
DECEMBER 9,201.0
IrARTfOnn rrnn TNSURAIICE COMPANY
. ,. NoTicn Tg rIru DEEENL$IS=ITIBSUANT T,9
s4c=S9N sz-zz8c ',
Oxfordr'Connectiqut 06478 .
Telebhone: 203-881-3600
X'acsimile: 203-881.3606,
- .order, which has been signed by the judge or a clerk of fte court. You must eoine to c-ourt, or
,ygyr attoiney mu'st Comeito cgqrt, on the'date and time shown in the order if
you want to b.
lfrebrU in this matter. ' : ' :
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;l 'O[r the flrst hearing date, the Court will condubt a status/settlement conference. The : .' "
, , : r'
l: ,
. ., Court will not take evidence'at this first hearing date. lf .the case is not:resolv'ed at the.' -
fL;l
.ri
a ,i .
;
DOCKETNO. : i ,
: TO}YN oF oxF.onn
': ny.Iwn THROUGII .SUPERIOR COIIRT,. :
V. ANSONIA.MILFORD
'i'
AT MILFORI)
. :. ...
that a hearing thereon be held at the Superior Court, Judicial Diitrict of Ansonia-Milford,
thai. ttre Ptaintiff. TOWN Of O>ffO$,D give noticelto the Defendant fAnnN fVf.
GpIf,LET in accord'ance with Section 52-278c of tfe General Statutps of.the pend.ency
;-..
irf ttre:apptication'and of the time and place it will bg heard by causing q true and.attestgd
copy of thl vpplic:ation, the proposed unsigned Writ, Sumxlons, Complain! Affidavit and'
gf tlUs Q{dgr, together wittr sucn notice as is,.required. irndef Spction'.(3I of.
': :
made to this'Court.
BY TIIE COIIRT
l ln
. , ' ... 1
AT IYIILF.ORD
j"
AF'FIDAVIT..
STATN OX'CONNECTICUT )
) ss: Oxford
'goLr.r..ruy oF NEw rr,wnrr )
1 'That she is ove4 the age of eighteen" (18) years and believes in the.
.
j ' ,
:obiigdtions of an oath.
:
Geneial Statutes (CGS) to assess certain properff siitbin its bordbrs and/or owned by'its'
:'r-9!idg4t,.to
leyy taxes on such properly and to collqct said taxes., "'
: ,. Thatthe elective office of the Oxford Tax Collector is charged with the
:rgsponsibility.of levying agd collecting personal, motor Vehicle, and real prope{i taxes. .
(b)
into
" ernployees and conSultants of the Town of Oxford'to discuss the'investigation and.
inegularities "
':That :
directed that the Defendant KAREN M. GUILLET leave Oxfor.d Town Hatrl.
:.
wELcH, tEoDo'slo,. STANEK .&'.B.LAKE, LLc -. ATTORNEYS 'AT LAW . A6A22A
' 375 ARIDGEPORT AyENUE - SHEITON, CT 06484 - 203'925:3000
48t OXFO.RD RoAD -' oxFoRD, cT 06478 -.203-881-3600
the 3d hoc bo"mmittee are owned by
jl
ANN D
'Its First Selec an
': . scrlT,.DIILE A
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'. gri'blgcfi: t-o,:.aqqfi .f'qcts '"n *
I 'Fry',dd*clnqei..'
:.
V. AIISONIA.MILFORD
AT MILFORD
ST'MMONS
F'RA}\CIS A..TEODOSIO
WEI,CH, TEODOSIO, STANEK & BLAKE, LLC '