COMPLAINT AGAINST ATTORNEY

(GRIEVANCE COMPLAINT)

ADA NOTICE
The Judicial Branch of the State of Connecticut complies
with the Americans with Disabilities Act (ADA). If you need a
reasonable accommodation in accordance with the ADA,
contact a court clerk or an ADA contact person listed at
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JD-GC-6 Rev. 9-12

P.B. 2-32(a)

Read the Instructions for this complaint before

filling it out. Complaints that are not filled out
correctly will be returned to you.

1.

STATE OF CONNECTICUT
JUDICIAL BRANCH
www.jud.ct.gov

After filling out this complaint, mail the original and 6 copies of it to:

Statewide Bar Counsel

Statewide Grievance Committee
287 Main Street, 2nd Floor, Suite 2
East Hartford, CT 06118-1885
Complainant's (person making complaint against attorney) Information. A separate complaint form must be
filled out for each Complainant.
Name (First, Middle, Last)

Mr.

Mrs.

Ms.

Edward F Taupier

(Other)

Address

6 Douglas Drive, Cromwell, CT 06416

2.

Telephone number

Email address (optional)

860-807-2263

ted.taupier@sbdllc.net

Information about the attorney you are making a complaint against. Do not name a law firm. A separate
complaint form must be filled out for each attorney you are complaining about.
Name (First, Middle, Last)

Geraldine Ficarra
Address

3 Scholes Lane

3.

Telephone number

Attorney's juris number (if known)

Email address (if known)

860.767.8300

102516

geraldineficarra@aol.com

Explain how you are connected to the attorney.

to

I hired/retained the attorney. Dates of representation:

The court appointed the attorney to represent me. Date attorney was appointed by the court:
The court appointed the attorney to represent my children. Date attorney was appointed by the court:

The attorney represented the other side against me in a matter.

The attorney was the prosecutor in my criminal case.
Other. Explain:

4.

Have you ever filed a complaint against this attorney with the Statewide Grievance Committee?
Yes. Give the name and grievance number of each complaint that you have filed:

5.

No

Please give the information asked for below if your complaint is about the attorney's conduct in a lawsuit or a
criminal case.
Name of lawsuit or criminal case

Docket number

Courthouse location

Your connection to the lawsuit or criminal case (for example: plaintiff, defendant, witness)

Hartford CT - Family Superior Court

Defendant and My Children's liberty interests

Do Not Write in This Area For Statewide Bar Counsel Use Only
File Date:
Complaint number:
Referred to:

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6.

Please explain the type of legal work done by the attorney in the matter that led to this complaint. Check all that
apply.

Criminal law

Family law/Divorce

Personal injury/Wrongful death/Malpractice

Personal real estate matter

Business or corporate matter

Estate planning/Elder law/Probate

Workers' compensation

General civil claims

Immigration matter

Arbitration or mediation

Collection matter

Other. (Explain)
7.

Please explain what kind of complaint this is. Check all that apply. You must still explain your complaint in
detail in question 10.

Neglect, diligence or competence issues

Misused funds or other property

Charged too high a fee

Did not safeguard money or property

Did not return records

Fraud or misrepresentation issues

Conflict of interest

Communication issues

Did not obey a court order

Improper withdrawal

Did not pay a judgment

8.

Confidentiality issues

Harassment

Other. (Explain)

conduct that is prejudicial to justice

Have you paid the attorney any legal fees for the matter complained about or has any other person paid the
attorney any legal fees for the matter for you?
Yes. Amount the attorney charged you:
Amount paid to the attorney by you or by another person for you:
The matter involved a contingency fee that has not been paid.

No.
Attach a copy of the fee agreement to this complaint.

9.

Give a list of all witnesses that have information about your complaint. Attach additional sheets if necessary.
Name (First, Middle, Last)

Telephone number

Alisha Mathers - Attorney

860-817-3837

Address

Telephone number

Name (First, Middle, Last)

Address

Telephone number

Name (First, Middle, Last)

Address

JD-GC-6 Rev. 9-12

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10. Give the details of your complaint in the order that they happened. Attach additional sheets if necessary.
ISSUE #1 ( AGAINST Geraldine Ficarra ) PB Rule 1.6 VIOLATIONS:
1A) - PB Rule 1.6 VIOLATIONS: I filed Pro-Se on 11 August 2014, all documented information was served to the interested parties.
My Lawyers ( #415813 ) knew they were now requesting addition funds to represent me and so was GERALDINE FICARRA - ( Jurist
# 102516 ) on my Ex-Wife. I filed Pro-Se due to the depletion of all life savings and cash savings (~$90,000.00). The divorce has
been dragging out form more than 22 months.
1B)- Money depleted) I was out of money and optioned to become Pro-se ( My life savings/college funds for children and my
retirement was all gone $90k+ ) I had no more money to pay lawyers to drag out my divorce case and drain my financial status, THE
DIVORCE HAD LASTED 2 + YEARS AND WAS NOT PROGRESSING. I filed for a Special Master and Pro-se on 11 Aug. 2014.
1C) After notification Geri continued to contact my old lawyers for several weeks : and discuss the case. Lobo and Associates
with Geri were colluding to drag out the case for billable hours. Derrick Oatis continued to speak about the case. Lobo and
Associates were not party too the case as of 11 Aug. 2014. Geri continued to discuss the case instead of contacting me as a duly
noted Pro-Se litigant despite her notice, as a result of this, I am now being charged additional costs by Lobo and Associates = ~
$4110.00 for having to take and field her calls to and with Geraldine Ficarra . ( See attached documentation - package #1 )
>> (a) A lawyer shall not reveal information relating to representation of a client unless the client gives informed consent, the

disclosure is implied authorized in order to carry out the representation, or the disclosure is permitted by subsection (b), (c), or (d
(e) A lawyer shall make reasonable efforts to prevent the inadvertent or unauthorized disclosure of, or unauthorized access to,
information relating to the representation of a client.
ISSUE #2 ( AGAINST Geraldine Ficarra ) Rule 3.1. Meritorious Claims and Contentions : A lawyer shall not bring or defend a

proceeding, or assert or controvert an issue therein, unless there is a basis in law and fact for doing so that is not frivolous, which
includes a good faith argument for an extension, modification or reversal of existing law.
2A) - On 22 August 2014 Geri and Tanya continue to file meritless claims and useless motions of contempt 7-12 depending on you
view of the attached (22 Aug. contempt motion), which was eventually denied by Judge Bozzuto, however the case detail originally
slated the motion to be heard on 02 Sept. 2014. As you can see from the case detail 32% of the motions filed are contempt motions
in this divorce case. Judge Simon used the children and their removal from their fathers life as punishment for accusations of the
meritless claims including the violation of a court order for children's school assignment, Failure to fully participate in a Family
Services assessment, neglecting the children's health - " Father caused cavities " ; Father has girl friend living in home : after he hired
a nanny:
2B) Mr Taupier was ordered by Judge Elizabeth Bozzutto, to never participate in legislative and representative government. The
Motion of contempt dated 22 Aug. 2014 filed by Geri and Tanya her client was denied by Judge Elizabeth Bozzuto.

ISSUE #3 : Rule 3.3. Candor toward the Tribunal ( Fraud upon the Court )
3A) - (a) A lawyer shall not knowingly: (1) Make a false statement of fact or law to a tribunal or fail to correct a false statement of
material fact or law previously made to the tribunal by the lawyer;
A) Geri Ficarra and Judge Bozzuto colluded to make a false claim of Imminent and emergency claim that the children are in
danger of psychosocial abuse, The claim was signed in an ex-parte motion :

B) Children attending public schools is not causing psychological harm to children. No Public school is
causing arbitrary harm to children. This ex-parte order is a declaration of emergency and immediate danger
C) Tanya removed the children the morning of their first day of school 27 Aug 2014 with the assistance of attorney Geri

Ficarra & Cromwell Police. The children were escorted by the police from their classroom to the parking lot experiencing
embarrassment and humiliation, and likely fear. Mother chose to remove the child during school hours rather than
waiting for the children to complete the day . Clearly a decision contrary to the best interests of the children
http://youtu.be/JMDdceGIbrM << Mother kidnapping children against family orders >>
The first day of school fell during the fathers parenting week as approved and ordered by Judge Bozzuto
Children have had significant psychological issues confirmed by the therapist since the removal from the school by
Cromwell Police and such issue are further exasperated by the deprivation of the fathers parenting time

I note that you ( Geri) lack 'clean hands' to proceed in a court of equity. You cannot establish that your
hands are clean after the events of this week. Please note in Pappas v. Pappas, 164 Conn. 242, 246:
"It is a fundamental principle of equity jurisprudence that for a complainant to show that he is entitled to the
benefit of equity he must establish that he comes into court with 'clean hands'.....The clean hands doctrine is
applied not for the protection of the parties but for the protection of the court."
In your ex parte action, you failed to make full and frank/fair disclosure to the court relating to the June '14
parenting plan. The application you submitted lacked disclosure of Judge Bozutto's direction from the bench
JD-GC-6 Rev. 9-12

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upon entering said plan. You are in possession of the transcript and you were present when she stated her lack
of understanding of the plan but trusts its meaning to the parties. Your ex parte representation that the August
'13 plan had not been disturbed was recklessly and intentionally misleading as it was replaced in June and
effectively expired this week.
Please note the case law on such fair disclosure in Billington v Billington, 220 Conn. 212, citing Monroe v.
Monroe 177 Conn. 173. You have duty to ensure that all information is provided to the court so that fair and
equitable orders can be made. In the instant matter, you withheld information thereby eliminating the court's
ability to enter proper orders. You have a professional duty to inform Bozutto, J. immediately of your
shortcoming. As for the affidavit of your client, you had duty to execute a 'searching dialogue, about all of the
facts' that affect your client's interests. As she swore to psychological harm as the basis of the 'emergency ex
parte' action, you had legal cause to understand the underlying evidence of her first hand knowledge of such
claim of harm. It is obvious to the most casual observer that there is no underlying facts, evidence, qualified
medical opinion or any iota of reality that such harm existed to meet the 'emergency' threshold for the ex parte
action. It is your and Judge Bozzutto's impossible burden to prove that Cromwell schools cause psychological
harm. Again, you have failed your obligations as a lawyer so specified in the noted case law. To wit:
"Lawyers who represent clients in matrimonial dissolutions have a special responsibility for full and fair
disclosure, for a searching dialogue, about all of the facts that materially affect the client's rights and
interests.....It is a logical extension...to require such full and frank disclosure...between marital litigants
themselves." (Billington, 220)
It appears that you have failed duty under Monroe/Billington by not disclosing such facts underlying the
psychological harm either to the court or to me. As it is your duty to do so, please immediately provide such
underlying facts, your client's first hand knowledge of same or a statement that the affidavit filed with the
court is false. I make the assumption that you and your client did intentionally provide such misleading
information to the court to obtain your 'emergency' order. As you chose not to advise me of such action, your
efforts were fraud upon the court. See fraud by non-disclosure as there was duty to speak; Reville v. Reville,
SC18452.
Perhaps you would care to ponder the opinion in Mitchell v. Mitchell, 194 Conn. 312, 322. To wit:
"...the spirit of our rules which requires full disclosure of all material facts, the obligation of an attorney to be
candid with the court as provided by the Code of Professional responsibility."
Given said case law, I will also assume that you instructed your client to remove the children from E.C.
Stevens Elementary School with the aid of the Cromwell Police to carry out your fraudulently obtained
'emergency ex parte' order. I remain available throughout the weekend for discussions to put an end to your
malicious drama.
ISSUE #4 ( AGAINST Geraldine Ficarra ) Rule 8.4. Misconduct :

4A) - Geri continues to file and act in the most inappropriate way. The direct results of these maliciouse actions are now being defined
by the AFCC Therapist for the children; Nancy Eiswirth has issued an alarming e-mail concerning the mental and health status of the
children. See attached : This direct disregard to the administration of justice and the misconduct for creating a private high conflict for
the divorce ahs placed the children at risk for PTSD and daily/hourly stress. The high conflict divorce has now damaged the children
with stress and mental block affecting their learning and development. School records show clear disciplinary problems and out bursts
from both children. There is PTSD clearly noted in my son and my son has no short term memory. The children are in distress and are
suffering from this lawyer Misconduct looking to escalate the conflict to fill her pockets. Clearly Geri with Tanya stating that Cromwell
Schools are causing psychological harm was a meritless claim and the Judge Bozzuto signed it with no factual basis or medical report.
this is clear misconduct on the Jurris and the Judge. Geri and Tanya also served the "ex parte" motions to the school to threaten and
cause legal concerns on a party/persons not party to the divorce action. Geri also called the Cromwell Police to escalate the mid
morning school raid and extraction under armed guard. This action severely traumatized the children and was actually
kidnapping the children - see YOUTUBE : http://youtu.be/JMDdceGIbrM

>> The CROMWELL school Asst. Superintendent verified educational neglect and endangerment on video
>> Cromwell schools legal team reviewed the orders and registered the children base on no clear orders of
educational motions, again this was misrepresented to Judge Bozzuto who again issued an illegal JD-GC-6 Rev. 9-12

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EMERGENCY EX-PARTE ORDER.

(3) Engage in conduct involving dishonesty, fraud, deceit or misrepresentation;
(4) Engage in conduct that is prejudicial to the administration of justice;
(5) State or imply an ability to influence improperly a government agency or official or to achieve results by means that violate
the Rules of Professional Conduct or other law; or
(6) Knowingly assist a judge or judicial officer in conduct that is a violation of applicable rules of judicial conduct or other law.
ISSUE #5 ( AGAINST Geraldine Ficarra ) Vexatious Litigation Chapter 15 pg 239-290:
4A) Lastly the culminating of all this false litigation, actions, and frivolous motions filing on my person and against the best
interests of the children: my children: has caused irrevocable harm to my persons and my two children. These destructive
actions by Geri and her law firm in the name of creating a high conflict divorce and creating instability for " billing the client
" is what is being reflected onto my children and their future. Judge Bozzutto's active participation, knowing and aiding
abetting this activity is but another concern to be investigated in future civil actions. Judicial misconduct once discovered
is to be investigated by all lawyers ( section 8.4 CT PB )

(3) Engage in conduct involving dishonesty, fraud, deceit or misrepresentation; Geri clearly violated this PB rule and CT statute
by stating that the children were being subject to psychological harm caused by the Cromwell Public School System and to
other students ). The Assistant Superintendent of Cromwell schools even said this is educational neglect and a very bad
situation caused by Geri telling Tanya to get police and extract the children @ 10 am in the morning on their first day of
second grade. The police had no authority to call the school and insert themselves into a civil case and family matter.
(4) Engage in conduct that is prejudicial to the administration of justice;
>> Geri is clearly executing a divorce war plan and billing hours scheme to fit her own agenda and not that of the court or
aligned with the administration of justice, there by engaging in this conduct that is clearly prejudicial to the administration
of justice and more a tune to anarchy on and of the court.
(5) State or imply an ability to influence improperly a government agency or official or to achieve results by means that violate
the Rules of Professional Conduct or other law; or
>> By Geri contacting the Cromwell Police - this is a clear indication and violation of professional conduct - There are now
subpeona's for the phone records for Cromwell Police Dept, and Geri's phone records. This will be brought out in the next few
months as part of a criminal trial
(6) Knowingly assist a judge or judicial officer in conduct that is a violation of applicable rules of judicial conduct or other law.
(P.B. 1978-1997, Rule 8.4.) (Amended June 26, 2006, to take effect Jan. 1, 2007.)

>>Geri knowingly and willingly filed a false affidavits, she has been filing random vexatious civil court filings to cause a high
billing record official or t
11. Sign and date this complaint below. Please use blue ink.
Signature of Complainant

Date signed

Signed under penalties

of false statement,

Be sure to read paragraph 11 of the Instructions before copying and filing your complaint.

JD-GC-6 Rev. 9-12

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