RETURN DATE: MARCH 9,2010 SUPERIOR COURT

VINCENT A. VIZZO, JR. J.D. OF ANSONIA-MILFORD

VS. AT MILFORD

TOWN OF OXFORD FEBRUARY 4,2O1O

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COMPLAINT
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{ FIRST COUNT
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1. The defendant, The Town of Oxford, is a municipal corporation organized
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4a under and existing pursuant to the laws of the State of Connecticut.
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y6 2. At all times mentioned herein, the plaintiff, Vincenl A. Vizzo, Jr., was the
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with inter alia overseeing and regulating land use and development in the Town of Oxford
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and, as such, was a municipal officer of the Town of Oxford.
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3. As a member of said Commission the plaintiff was duly elected by the voters of
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a said Town in or about November, 1995 to serve on said Commission.
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4. lri or about November, 2003 the plaintiff was further elected by the members of

the Commission to serve as its Chairman.

5. On or about July 2,2009 the plaintiff was named as a respondent in an ethics

complaint made to the Town of Oxford's Ethics Commission in which the plaintiff was alleged
 to have willfully committed a wide variety of ethics violations, occurring in the course of

discharging his duties as Chairman of the Oxford Planning and Zoning Commission.

6. When the ethics complaint was filed the town attorney for the Town of Oxford

authorized the plaintiff to hire an attomey to represent his interests as the town attorney could
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not represent his interests due to a conflict of interest.
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:iH plaintffi in the defense of his interests would be paid by and be the responsibility of the Town
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2a 8. Based upon that advice given to the plaintiff by the town attomey, the plaintiff
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9. After a hearing before the Ethics Commission the Commission decided that of
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the numerous charges initially brought against the plaintiff, that he had comrnitted a technical
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o 10. ln doing so, the Ethics Commission rejected numerous other charges brought
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against the plaintiff.
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11. ln defending the Ethics Complaint the plaintiff has incurred attorney's fees and

expenses.
 12. Despite demand, the defendant, the Town of Oxford, has failed, neglected and

refused to pay the plaintiffs legalfees and expenses.

SECOND COUNT
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1-11. Paragraphs one through eleven of the First Count are hereby incorporated and
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; made paragraphs one through eleven of this, the Second Count as if more fully set forth
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qn 12. The defendant, the Town of Oxford, has been unjustly enriched to the extent
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that the plaintiff has incurred attorney's fees and expenses in representing himself which fees
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l-l o and expenses are more properly those of the Town of Oxford and which fees and expenses
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woutd have been born by the Town but for the conflict with the Town Attorney.
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13. As such, the Town of Oxford has been unjustly enriched'
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14. Despite demand, the defendant, the Town of Oxford, has failed, neglected and
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 THIRD COUNT

1-11. Paragraphs one through eleven of the First Count are hereby incorporated and

made paragraphs one through eleven of this, the Third Count as if more fully set forth herein.

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12. Pursuant to Conn. Gen. Stat. $ 7-101a the defendant, the Town of Oxford, is
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-$ cornplaints filed against him while acting in the discharge of his duties as Chairman of the
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ets Planning and Zoning Commission.
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13. Pursuant to statute, the plaintiff issued notice to the defendant on January 13,
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14. Despite demand and issuance of notice to the Town, the defendant, the Town
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of Oxford, has failed, neglected and refused to pay the plaintiffls legal fees and expenses as
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aforesaid.
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 WHEREFORE, the plaintiff claims:

1. Money damages;

2. Attorneys' fees in the prosecution of this action;

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3. Costs;
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4. lnterest;

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+ 5. Such other and further relief as the court deems equitable and just.
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<h THE PLAINTIFF
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ON J. TREMBICKI
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3q 225 Main Street
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Suite 103
Am Westport, CT 06880
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Juris No.: 034874
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a Phone No.: 203.227.6808
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PLEASE ENTER AN APPEARANCE FOR:

ALEXANDER J. TREMBICKI
Lynch, Trembicki & Boynton
225 Main Street, Suite 103, Westport, CT 06880
1 .203.227.6808/Juris No. 03487 4
 RETURN DATE: MARCH 9,2010 SUPERIOR COURT

VINCENT A. VIZZO, JR. J.D. OF ANSONIA.MILFORD

VS. AT MILFORD

TOWN OF OXFORD FEBRUARY 4,2O1O

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6l AMOUNT IN DEMAND
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tf The amount in demand is more than $15,000.00 exclusive of interest and costs.
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AL . TREMBICKI
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Juris No.: 034874
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