Shelton Scanlon Docs

DOCKET NO.: CITY OF SHELTON, BY AND THROUGH ITS MAYOR, MARK A. LAURETTI v. SHARON A.
SCANLON
SUPERIOR COURT
JUDICIAL DISTRICT OF ANSONIA/MILFORD AT MILFORD SEPTEMBER 5, 2012
APPLICATION FOR PREJUDGMENT REMEDY
The Plaintiff, CITY OF SHELTON, by and through its Mayor, MARK A.

LAURETTI (hereinafter "Plaintiff SHELTON"), hereby represents as follows:
1.
That Plaintiff SHELTON is about to commence an action against
Defendant SHARON
A.
SCANLON (hereinafter "Defendant SCANLON")
having an address at 23 Crescent Drive, in the City
of Shelton, County
of
Fairfield and State of Connecticut pursuant to the attached proposed unsigned

Writ, Summons, Complaint and Affidavits'
2.
That there is probable cause that a judgment will be rendered
in
such matter in favor of the Plaintiff SHELTON and, to secure such judgment, the
plaintiff SHELTON seeks an order from this Court directing that the following
prejudgment remedy be issued as to the Defendant SGANLON to secure the
sum of THREE HUNDRED FORTY EIGHT THOUSAND FOUR HUNDRED

STXTEEN
and NO/100 ($348,416.00) DOLLARS to attach the following
real
property of the Defendant SCANLON located in the City of Shelton, County of Fairfield and State of Connecticut and furlher described in Volume 844 at Page
LAW OFFICES OF RAMON S. SOUS

Telephone: (203) 888-0557. Facsimile: (203) 888-5819
70 and Volume 938 at Page 222 of the shelton Land Records, which is more
particularly bounded and described in Schedule
and made a Part hereof.
"A" which is attached
hereto
3.
The prejudgment remedy requested is for an attachment
of
property of the Defendant SCANLON in the amount of THREE HUNDRED
FORTY EIGHT THOUSAND FOUR HUNDRED SIXTEEN ANd

($348,41 6.00) DoLLARS.
NO/1OO
4.
The Plaintiff SHELTON seeks a hearing on said application'
Dated at Seymour, Connecticut this sth day of September,2012'
PLAINTIFF, CITY OF SHELTON, BY AND THROUGH ITS MAYOR, MARK A. LAURETTI
159 Main Street Seymour, Connecticut 06483 Tel: (203) 888-0557 Fax: (203) 888-5819 Juris No.: 060150
2
Telephone: (203) 888-0557' Facsimile: (203) 888-5819
Schedule "A" Legal DescriPtion

All that certain piece or parcel of land with the buildings there,on standing situated in the Town of Shelton, County of Fairfield and State of Connecticut, bounded and described as follows: Being known and designated as Lot No. 3 (including Parcel B) as shown Joan on a certain map entifled "Property Line Revisions Plan Between Louis and carpenter and the Town of'shelton, shelton conn., "Made by L. Edwards Associates, and filed for record on April 7, 1988 in the Shelton Town Clerk's Office as Map No. 24348 and bounded:
Northerly: By land now or formerly

said map, 344.66 feet:
of Keller as shown on
Easterly:
southerly:
By Crescent Drive as shown on said map, 174.84feet; By Lot No. 2 as shown on said map 243.52feet; By Lot No. 2 as shown on said map 150.72feet:
westerly:
Also, all that tract or parcel of land described by a deed from Michael E. pacowta to Robert Scanlon, Jr. and Sharon A. Carpenter filed in Shelton Land Records on December 29, 1989 in Liber 938, Page 222'

Telephone: (203) S88-0557' Facsimile: (203) 888-5819
DOCKET NO.: CITY OF SHELTON, BY AND THROUGH IT'S MAYOR, MARK A. LAURETTI
SUPERIOR COURT
v.
SHARON A. SCANLON
WHEREAS, the ptaintiff CITY OF SHELTON in the above-entitled action
has made application for a prejudgment remedy to attach the propefi of the
Defendant, SCANLON; and (AFTER HEARING
- APPEARING DEFENDANT)
at which the Plaintiff and
Defendant
WHEREAS, after due hearing,
judgment appeared and were fully heard, it is found that there is probable that a
in the amount of the 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
plaintiff
clw
oF SHELTON, and that the supplication for prejudgment remedy
should be granted; or
(AFTER HEARING
- NON'APPEARING DEFENDANT)
is
WHEREAS, after due hearing, at which the Plaintiff appeared and was
fully heard, but the Defendant, SGANLON made default of appearance, it
LAW OFFICES OF
MMON S. SOUS
found that copies of the application for prejudgment remedy, accompanying

affidavit, proposed order for prejudgment remedy, unsigned writ, summons and complaint, notice and claim form, order for hearing and notice, and summons for
hearing were duly serviced on the Defendant, SCANLON as appears from the
certification of service on file, and it is also found that there is probable cause
that a judgment in the amount of the 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 Plaintiff CITY OF SHELTON, and that the application for
prejudgment remedy should be granted.
NOW, THEREFORE, it is herby ordered that the following prejudgment

remedy be ordered in favor of the Plaintiff CITY OF SHELTON against the
Defendant, SCANLON, and that the Plaintiff may attach property referenced in
Schedule
"A"
attached hereto, to the value of THREE HUNDRED FORTY
EIGHT THOUSAND FOUR HUNDRED SIXTEEN and NO/100 ($g+8,416.00)

DOLLARS. Dated at Milford this day of 2012.
BY THE COURT
By:
Asst Clerk/Clerk
2
Schedule "A" Leqal DescriPtion

All that certain piece or parcel of land with the buildings thereon standing situated in the Town of Shelton, County of Fairfield and State of Connecticut, bounded and described as follows: Being known and designated as Lot No. 3 (inctuding Parcel B) as shown on a certain map entitted "Property Line Revisions Plan Between Louis and Joan Carpenter and the Town of Shelton, Shelton Conn., "Made by L. Edwards Associates, and filed for record on April 7, 1988 in the Shelton Town Clerk's Office as Map No. 24348 and bounded:
Northerly:
By land now or formerly of Keller as shown on said map, 344.66 feet: By Crescent Drive as shown on said map, 174'84 feet;
Easterly:
Southerly:
By Lot No. 2 as shown on said map 243.52 feet; By Lot No. 2 as shown on said map 150.72 feet:
Westerly:
Also, all that tract or parcel of land described by a deed from Michael E. Paco6a to Robert Scanlon, Jr. and Sharon A. Carpenter filed in Shelton Land Records on December 29, 1989 in Liber 938, Page 222.
LAW OFFICES OF
MMON S. SOUS
DOGKET NO.: CITY OF SHELTON, BY AND THROUGH ITS MAYOR, MARK A. LAURETTI
V.
SUPERIOR COURT
SHARON A. SCANLON
ECTI
NOTICE TO THE DEFENDANTS PURSUANT TO UT GENERAL STAT -278c
YOU HAVE RIGHTS SPECIFTED IN THE CONNECTICUT GENERAL STATUTES, INCLUDING CHAPTER 903A, THAT YOU MAY WISH TO
EXERCISE CONCERNING THIS APPLICATION FOR PREJUDGMENT

REMEDY. THESE RIGHTS INCLUDE THE RIGHT TO A HEARING: (1) TO
OBJECT TO THE PROPOSED PREJUDGMENT REMEDY BECAUSE YOU
HAVE
DEFENSE TO OR SET.OFF AGAINST THE ACTION OR A
COUNTERCLAIM AGAINST THE PLAINTIFF OR BECAUSE THE AMOUNT
SOUGHT IN THE APPLICATION FOR THE PREJUDGMENT REMEDY IS

UNREASONABLY HIGH OR BECAUSE PAYMENTOF ANY JUDGMENT THAT
MAY BE RENDERED AGAINST YOU IS COVERED BY ANY INSURANCE
THAT MAY BE AVAILABLE TO YOU; (21 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 MY RESULT FROM THE PREJUDGMENT REMEDY; (3) TO REQEUST

Telephone: (203) 888-0557' Facsimile: (203) 888'5819
THAT YOU
BE
ALLOWED
TO SUBSTIfiUE A BOND FOR THE

AND (4} TO SHOW THAT
THE
PREJUDGMENT REMEDY SOUGHT;
PROPERTY SOUGHT TO BE SUBJECTED TO THE PREJUDGMENT IS

EXEMPT FROM SUCH A PREJUDGMENT REMEDY.
THE PLAINTIFF, CITY OF SHELTON, BY AND THROUGH ITS MAYOR, MARK A. LAURETTI
By:
159 Main Street Seymour, Connecticut 06483 Tel: (203) 888-0557 Fax: (203) 888-5819 Juris No.: 060150
2
tAW OFFICES OF RAMON S. SOUS
Telephone: (203) 8S8-0557' Facsimile: (203) 888-5819
To Any proper Officer:
By authority of the State of Connecticut, you are hereby commanded, in

accordance with the accompanying order, to attach to the value of THREE HUNDRED FORTY EIGHT THOUSAND FOUR HUNDRED SIXTEEN and NO/100 ($3+g'416'00)
DOLLARS the goods or estate of SHARON A. SCANLON, 23 Crescent Drive, Shelton, Connecticut and summon her to appear before the Superior Court for the Judicial
District of Ansonia/Milford at Milford on 2012 such appearance to be made by the Defendant or her attorney by filing written statement of appearance with the clerk of the court on or before the second day following the return date, then and
there to answer unto the City of Shelton, 54 Hill Street, Shelton, Connecticut, in a civil action wherein the Plaintiff comptains and alleges as set forth in the accompanying
complaint.
DOCKET NO.: CITY OF SHELTON, BY AND THROUGH ITS MAYOR, MARK A. LAURETTI
SUPERIOR COURT
v.
SHARON A. SCANLON
COMPLAINT
1.
The
Clw oF
SHELTON
is a duly incorporated municipal
corporation within the State of Connecticut, and as such is authorized by the Connecticut General Statues (CGS) to assess certain property within its borders and/or owned by its residents, to levy taxes on such property and to collect said
taxes and to establish and maintain a budget system.
2.
responsibility
The office of the Assistant Finance Director is charged with the
of reconciliation, cash management, accounting for various City
funds, monthly financial reports, year-end reports, bank reconciliation, financial

analysis and internal audit and further has the responsibility for making difficult
accounting technical decisions.
3.
From 1996 until August 23, 2012 the Defendant SHARON A.
SCANLON (hereinafter "Defendant SCANLON") who resides at 23 Crescent

Drive, in the City of Shelton, County of Fairfield and State of Connecticut (See

Schedule "A" hereto attached and herein incorporated Finance Director of the City of Shelton'
) was the
Assistant
4.
The Defendant SCANLON as Assistant Finance Director was
responsible for or had the final responsibility for: (1) reconciling bank statements;
(2) monthly financial reports; and (3) originating and tracking each check issued
by the City of Shelton.
S.
On July 25,2A12, the Office of the Shelton Mayor Mary A. Lauretti
was advised that there were discrepancies and irregularities involving, but not
limited to, City checks being deposited into the personal account of Defendant,
SCAN LON without authoritY.
O. ln response to the above notification, Mayor Mark A. Lauretti

directed that an investigation be conducted by the City's auditors and on July 26, ZA12 and at other times thereafter the City auditors met with other employees and consultants of the City of Shelton to discuss irregularities.
7. L
Thereafter, the Defendant, SCANLON resigned from the Office of
the Assistant Finance Director on August 23,2012.
The City auditors determined that there was
sufficient
documentation or lack thereof to indicate that the Defendant SCANLON had

taken for her own benefit Shelton monies.
g.
The City auditors estimated that for the period between July 2009
and July 2012 the Defendant, SCANLON had taken at least the amount of
2
LAW OFFICES OF
MMON S, SOUS
THREE HUNDRED FORTY EIGHT THOUSAND FOUR HUNDRED SIXTEEN and NOllO0 ($348,416.00) DOLLARS for her own benefit'
10. 11.
That the monies estimated by the City's auditors that were taken by
Defendant, SCANLON are owned by the City of Shelton and should be returned.
ln accordance with CGS 52-564, the Plaintiff CITY OF SHELTON
is entitled to receive treble damages for all monies taken.
WHEREFORE, Plaintiff claims:
1.
Money damages
2.
3.
4.
lnterest
Late fees.
Attorney's Fees.
of Suit
5. Costs 6.
Such other and further relief as in law or equity may appertain.
By: Ramon S. Sous, its Attorney 159 Main Street Seymour, Connecticut 06483 Tel: (203) 888-0557 Fax: (203) 888-5819 Juris No.: 060150
3

All that certain piece or parcel of land with the buildings thereon standing situated in the Town of Shelton, County of Fairfield and State of Connecticut, bounded and described as follows: Being known and designated as Lot No. 3 (including Parcel B) as shown on a certain map entitled "Property Line Revisions Plan Between Louis and Joan Carpenter and the Town of Shelton, Shelton Conn', "Made by L. Edwards Associates, and filed for record on April 7, 1988 in the Shelton Town Clerk's Office as Map No. 24348 and bounded:
Northerly: By land now or formerly of Keller as shown

said map, 344.66 feet:
on
Easterly:
Westerly:
By Crescent Drive as shown on said map, 174.84feet;
Southerly: By Lot No. 2 as shown on said map 243'52
feet;
By Lot No. 2 as shown on said map 150'72 feet:
Also, all that tract or parcel of land described by a deed from Michael E. pacoqa to Robert Scanlon, Jr. and Sharon A. Carpenter filed in Shelton Land Records on December 29, 1989 in Liber 938, Page 222'
LAW OFFICES OF
MMON S. SOUS
DOCKET NO.: CITY OF SHELTON, BY AND THROUGH ITS MAYOR, MARK A. LAURETTI v. SHARON A. SCANLON
SUPERIOR COURT
AD DAMNUM
The amount in demand is greater than FIFTEEN THOUSAND and

NO/l00 ($15,000.00) DoLLARS, exclusive of interest and costs.
By:
Ramon S. Sous, its Attorney 159 Main Street Seymour, Connecticut 06483 Tel: (203) 888-0557 Fax: (203) 888-5819 Juris No.: 060150
IJW
OFFICES OF RAMON S. SOUS

with the buildings thereon standing All that certain piece or parcel of land co*tv of Fairfield and state of connecticut' situated in the roiun lisnertdn, bounded and described as follows:
BeingknownanddesignatedasLotNo.3(includingParcelB)asshown finl Cevisions Flan Between Louis and Joan on a certain map ;;titl"d;FrJperty "Made by L' Edwards and tn-e'-iown ot'snb*onl sn"non-99nn', Shelton Town Clerk's Carpenter in the and iir"O io1. record on-n'ptir 7-, 1988
Associates,
ofd;;t
MaP No. 24348 and bounded:
Northerly:Bylandnowor-formerlyofKellerasshownon
said maP, 344.66 feet:
Easterly:ByCrescentDriveasshownonsaidmap,lT4.S4feet;
Southerly:
243'52 feet; By Lot No' 2 as shown on said map
Westerly:
l S0'72feel. By Lot No' 2 as shown on said map
Also,allthattractorparceloflanddescribedbyadeedfromMichaelE. sr'"'on A' Carpenter filed in shelton Land Pacowta to Robert scanlon, tr. ano Liber 938'Page222' Records on o"cemoli zg, tbag in
r.r.pnin"i tiosl
IAW OFFICES OF RAMON S. SOUS s8a-ossz ' Facsimile: (203) 888-s81s
SUPERIOR COURT
JUDICIAL DISTRICT OF ANSONIA/MILFORD
v.
SHARON A. SCANLON
AT MILFORD SEPTEMBER5,2012
ORDER FOR HEARING AND NOTICE
The above application having been presented to the Court, it is hereby ordered,
that a hearing thereon be held at the Superior Court, Judicial District of Ansonia-Milford,
at Milford (14 West River Street, Milford, Connecticut 06460), on

2Q12 at
amftA(anO that the Plaintiff CITY OF SHELTON give notice to
the Defendant, SCANLON in accordance with Section 52-278c of the General Statues
of the pendency of the application and of the time and place it will be heard by causing a
true and attested copy of the application, the proposed unsigned Writ, Summons,
Compliant, Affidavit and of this order, together with such notice as is required under Subsection (e) of Section 52-278c, to be served upon the Defendant by some proper
officer or indifferent person on or befor
"
tryan
ot
4"n
2a,
2012, and that due
return of service be made to this Court Dated at Milford
tni"
,f4ry
2012.
BY THE COURT
By:
Telephone: (203) 888-0557 . Facsimile: (203) 888-5819
v.
SUPERIOR COURT
SHARON A. SCANLON
SUMMONS
TO ANY PROPER OFFICER:
BY AUTHORITY OF THE STATE OF CONNECTICUT, you are hereby

cornmanded to serve a true and attested copy of the above Notice of Application
for Prejudgment Remedy/Claim for Hearing to Contest Application or
Claim
Exemption, Application for Prejudgment Remedy, Affidavits, Order for Hearing
and Notice, unsigned Proposed Writ, Summons and Complaint and Order for
Prejudgment Remedy, upon SHARON A. SGANLON having an address at 23
Crescent Drive
in the City of Shelton, County of Fairfield and State of

20 ,2012.
Connecticut, in the manner prescribed by law on or before Septembe, Hereof fail not but due service and return make. Dated at
,
this
SrH
day of September,2012.
RamOn S. SOUS Commissioner
of the Superior Court
I.AW OFFICES OF
MMON S. SOUS
Telephone: (203) 88&0557' Facsimile: (203) 888-5819
DOGKET NO.: CITY OF SHELTON, BY AND THROUGH ITS MAYOR, MARK A. LAURETTI
v.
SUPERIOR COURT
SHARON A. SCANLON
AFFIDAVIT
STATE OF CONNECTICUT
)
couNTY OF FAIRFIELD
)
)
ss: Shelton
The undersigned DAVID CAPPELLETTI being duly sworn does depose

and say:
1. 2.
That he is over the age of eighteen (18) years and believes in the
obligations of an oath.
That he is a Certified Public Accountant and is employed
by
Levitsky & Berney, an accounting firm, Shelton's City auditors since 2008.
3. On or about July 25, 2012 there was discovered certain

irregularities in the City's financial records as it pertained to the City's Assistant
Finance Director, SHARON A. SCANLON.
4.
That on or about July 26, 2012, MAYOR MARK A. LAURETTI
asked him to further review and investigate the records of the City's Assistant

Finance Director and in particular those records pertaining to monies written by

check from the City's account to SHARON A. SCANLON'
S.
That he, after reviewing in detail the records of the
Shelton
Assistant Finance Director and other City records concluded that there was
sufficient information to indicate that between the dates of July 2009 and July
2O1Z Defendant, SHARON
IEAST
A. SCANLON took for her own benefit funds in at
thE
AMOUNT Of
THREE HUNDRED FORTY EIGHT THOUSAND FOUR
HUNDRED SIXTEEN and NO/100 ($348,416.00) DOLLARS owned by the Citv of Shelton. Dated at Seymour, Connecticut this sth day of September,2012.
CITY OF SHELTON
SUBSCRTB
ED AND St/yORN fO, before me this 5th day of September,
2012.
nS.
of the Superior Court
2
SUPERIOR COURT JUDTCIAL DISTRICT OF ANSONIA/MILFORD
v.
SHARON A. SCANLON
AT MILFORD SEPTEMBER 5, 2012
AFFIDAVIT
STATE OF CONNECTICUT
)
couNTY OF FAIRFIELD
) ss: Shelton
)
The undersigned MARK A. LAURETTI being duly sworn does depose

and say:
1. 2.
since 1991
.
That he is overthe age of eighteen (18) years and believes in the
obligations of an oath.
That he is the MAYOR of the CITY OF SHELTON and has been
3.
That the CITY OF SHELTON is a duly incorporated municipal
corporation within the State of Connecticut, and as such is authorized by the

Connecticut General Statutes (CGS) to assess certain property within its borders
and/or owned by its residents, to levy taxes on such property and to collect said
taxes and to establish and maintain a budget system'
TAW OFFICES OF RAMON S. SOUS

Telephone: (203) 88S-0557' Facsimile: (203) 888-5819
4.
responsibility
That the office of the Assistant Finance Director is charged with the
of reconciliation, cash management, accounting for various City
funds, monthly financial reports, year-end reports, bank reconciliation, financial

analysis and internal audit and further has the responsibility for making difficult
accounting technical decisions-
5.
From 1996 until August 23,2012, the Defendant, SHARON A.
SCANLON of 23 Crescent Drive, City of Shelton, County of Fairfield and State of

Connecticut had been the Assistant Finance Director of the City of Shelton
6.
That the Defendant, SHARON A. SCANLON as Assistant Finance
Director was responsible for or had the final responsibility for: (a) reconciling bank statements; (b) monthly financial reports; and (c) origination and tracking
each check issued by the City of Shelton'
7.
That on July 25, 2012, the office of the shelton Mayor, Mark A.
Lauretti was advised that in the Office of the Assistant Finance Director there were discrepancies and irregularities involving: (a) City checks being deposited
into the personal accounts of SHARON A. SCANLON without authority.
8..
That in response to the above notification, Mayor Mark A. Lauretti
directed that an investigation be conducted by the City's auditing firm of Levitsky & Berney, PC. That on or about July 26, 2A12, Mayor Mark A. Lauretti met with
the City's auditors and other employees and consultants of the City of Shelton to
discuss the investigation and irregularities'
2
I.AW OFFICES OF
MMON S, SOUS
9. 10.
That thereafter, the Defendant, SHARON A. SCANLON resigned
from the Office of the Assistant Finance Director on August 23,2012'
That the City auditors determined that there was
sufficient
documentation
or lack thereof to indicate that the Defendant, SHARON A.
SCANLON had taken for her own benefit shelton monies.
11.
thE
That the City auditors estimated that for the period between July of
2009 and July, ZO12 the Defendant, SHARON A. SCANLON had taken at least
AMOUNT
Of THREE HUNDRED FORTY EIGHT THOUSAND
FOUR
HUNDRED slxTEEN and No/l00 ($348,416'00) DOLLARS'
12. That the monies estimated taken by the City auditors are owned by
the City of Shelton and should be returned'
13.
ThAt ON bChAIf Of thc CITY OF SHELTON, MAYOR MARK A.
LAURETTI seeks
SCANLON iN thc
to
attach real estate
of the Defendant,
SHARON A.
AMOUNT Of
THREE HUNDRED FORTY EIGHT THOUSAND
FOUR HUNDRED SIXTEEN and NO/100 ($g+g,416'00) DOLLARS' to wit 23 Crescent Drive, Shelton, Connecticut, which is more particularly bounded and
described in Schedule "A" which is attached hereto and made a part hereof'
14.
SCANLON.
That there is probable cause for a judgment entering in favor of the
Plaintiff, CITY OF SHELTON and against the Defendant, SHARON A'
3
Dated at Seymour, Connecticut this
Sth
day of September,2O12. CITY OF SHELTON
By:
Mark A. Lauretti, lts MaYor
SUBSCR 2012.
ED AND SWORN IO, before me this
5th day
of September,
4
Telephone: (203) 8SS-0557' Facsimile: (203) 888-5819
tAW OFFICES OF RAMON S. SOUS

All that certain piece or parcel of land with the buildings thereon standing situated in the Town of Shelton, County of Fairfield and State of Connecticut, bounded and described as follows: Being known and designated as Lot No. 3 (including Parcel B) as shown on a certain map entifled "Property Line Revisions Plan Between Louis and Joan
Office as MaP No. 24348 and bounded:
carpenter and the Town of shelton, shelton conn., "Made by L. Edwards Associates, and filed for record on April 7, 1988 in the Shelton Town Clerk's
Northerly:
By land now or formerly of Keller as shown on said map, 344.66 feet: By Crescent Drive as shown on said map,174.84 feet; By Lot No. 2 as shown on said map 243.52 feet; By Lot No. 2 as shown on said map 150.72 feet:
Easterly:
southerly:
westerly:
Also, all that tract or parcel of land described by a deed from Michael E. pacowta to Robert Scanlon, Jr. and Sharon A. Carpenter filed in Shelton Land Records on December 29, 1989 in Liber 938, Page 222'


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DOCKET NO.: CITY OF SHELTON, BY AND THROUGH ITS MAYOR, MARK A. LAURETTI v. SHARON A.

JUDICIAL DISTRICT OF ANSONIA/MILFORD AT MILFORD SEPTEMBER 5, 2012

APPLICATION FOR PREJUDGMENT REMEDY

The Plaintiff, CITY OF SHELTON, by and through its Mayor, MARK A.

That Plaintiff SHELTON is about to commence an action against

SCANLON (hereinafter "Defendant SCANLON")

having an address at 23 Crescent Drive, in the City

Fairfield and State of Connecticut pursuant to the attached proposed unsigned

That there is probable cause that a judgment will be rendered

sum of THREE HUNDRED FORTY EIGHT THOUSAND FOUR HUNDRED

and NO/100 ($348,416.00) DOLLARS to attach the following

LAW OFFICES OF RAMON S. SOUS

"A" which is attached

The prejudgment remedy requested is for an attachment

property of the Defendant SCANLON in the amount of THREE HUNDRED

FORTY EIGHT THOUSAND FOUR HUNDRED SIXTEEN ANd

The Plaintiff SHELTON seeks a hearing on said application'

Dated at Seymour, Connecticut this sth day of September,2012'

PLAINTIFF, CITY OF SHELTON, BY AND THROUGH ITS MAYOR, MARK A. LAURETTI

Schedule "A" Legal DescriPtion

Northerly: By land now or formerly

LAW OFFICES OF RAMON S. SOUS

JUDICIAL DISTRICT OF ANSONIA/MILFORD AT MILFORD SEPTEMBER 5, 2412

WHEREAS, the ptaintiff CITY OF SHELTON in the above-entitled action

WHEREAS, after due hearing,

in the amount of the prejudgment remedy sought, or in an amount greater than

oF SHELTON, and that the supplication for prejudgment remedy

fully heard, but the Defendant, SGANLON made default of appearance, it

Telephone: (203) 888-0557' Facsimile: (203) 888-5819

found that copies of the application for prejudgment remedy, accompanying

that a judgment in the amount of the prejudgment remedy sought, or in an

NOW, THEREFORE, it is herby ordered that the following prejudgment

attached hereto, to the value of THREE HUNDRED FORTY

EIGHT THOUSAND FOUR HUNDRED SIXTEEN and NO/100 ($g+8,416.00)

Schedule "A" Leqal DescriPtion

Telephone: (203) 888-0557' Facsimile: (203) 888-5819

JUDICIAL DISTRICT OF ANSONIA/MILFORD AT MILFORD SEPTEMBER 5, 2012

NOTICE TO THE DEFENDANTS PURSUANT TO UT GENERAL STAT -278c

EXERCISE CONCERNING THIS APPLICATION FOR PREJUDGMENT

DEFENSE TO OR SET.OFF AGAINST THE ACTION OR A

COUNTERCLAIM AGAINST THE PLAINTIFF OR BECAUSE THE AMOUNT

SOUGHT IN THE APPLICATION FOR THE PREJUDGMENT REMEDY IS

MAY BE RENDERED AGAINST YOU IS COVERED BY ANY INSURANCE

THAT MAY BE AVAILABLE TO YOU; (21 TO REQUEST THAT THE

A BOND IN ACCORDANCE WITH SECTION 52.278d

THE GENERAL STATUTES TO SECURE YOU AGAINST ANY DAMAGES

LAW OFFICES OF RAMON S. SOUS

TO SUBSTIfiUE A BOND FOR THE

PREJUDGMENT REMEDY SOUGHT;

PROPERTY SOUGHT TO BE SUBJECTED TO THE PREJUDGMENT IS

To Any proper Officer:

By authority of the State of Connecticut, you are hereby commanded, in

JUDICIAL DISTRICT OF ANSONIA/MILFORD AT MILFORD SEPTEMBER 5, 2012

is a duly incorporated municipal

The office of the Assistant Finance Director is charged with the

of reconciliation, cash management, accounting for various City

funds, monthly financial reports, year-end reports, bank reconciliation, financial

From 1996 until August 23, 2012 the Defendant SHARON A.

SCANLON (hereinafter "Defendant SCANLON") who resides at 23 Crescent

LAW OFFICES OF RAMON S. SOUS

The Defendant SCANLON as Assistant Finance Director was

On July 25,2A12, the Office of the Shelton Mayor Mary A. Lauretti

O. ln response to the above notification, Mayor Mark A. Lauretti