Preview
DOCKET NO.;: HHD-CV18-6104443-S : SUPERIOR COURT
DOMINIC W, PAPA TRUSTEE, ET AL. : JUDICIAL DISTRICT OF HARTFORD
VS. : AT HARTFORD
OLD LYME ZONING COMMISSION,
ET AL, : MARCH 13, 2019
JOINT MOTION TO SUPPLEMENT RECORD
The Defendants, Neck Road Hope Housing LLC and Old Lyme Housing LLC (“Applicant
Defendants”) and the Plaintiffs Dominic W. Papa Trustee, William Francis Fitzgerald and Patricia
Fitzgerald (“Plaintiffs”) jointly move, pursuant to C.G.S. § 8-8(k), that the following documents be
entered into evidence in this appeal:
1 Exhibit A: Correspondence from Robert Staab, Chairperson, Old Lyme Ethics
Commission, to Peter Thomas, dated September 10, 2018.
2. Exhibit B: Correspondence from Robert Staab, Chairperson, Old Lyme Ethics
Commission to Peter Thomas, David M. Royston and Sylvia K. Rutkowski dated December 3, 2018.
These documents concern the Plaintiff’s allegation that the approval was “tainted” by a conflict
of interest on the part of the applicant’s attorney, David Royston. Exhibits A and B are notices of action
taken by the Old Lyme Ethics Commission concerning the involvement of Attomey Royston as counsel
for the applicant in this matter. The Plaintiffs wish to offer Exhibit A. The Applicant-Defendants wish
NAL itigation\Genera\Women's Instilute\Old Lyme Zoning Appealijoint m-supp record.docxto offer Exhibit B. Both movants reserve all rights with respect to argument concerning the significance
of the document offered by the other party.
THE PLAINTIFFS,
DOMINIC W. PAPA TRUSTEE,
WILLIAM FRANCES FITZGERALD
AND PATRICIA FITZGERALD
By: /s/ David S. Hoopes
Lewis Wise, Esq.
Rogin Nassau LLC
185 Asylum Street, 22" Floor
Hartford, CT 06103
Telephone: (860) 256-6300
Juris No, 050793
Its Attorneys
THE DEFENDANTS,
NECK ROAD HOPE HOUSING LLC
OLD LYME HOUSING LLC
By: /s/ David S. Hoopes
David S. Hoopes
Hoopes Morganthaler Rausch & Scaramozza LLC
CityPlace II—185 Asylum Street
Hartford, CT 06103-3426
Telephone: (860) 275-6800
Juris No. 423839
Its Attorneys
Ni\Litigation\GeneraltWomen's Institute\Old Lyme Zoning Appealoint m-supp record.docx 2CERTIFICATION
Thereby certify that a copy of the foregoing was mailed, postage prepaid, or emailed to all
counsel and pro se parties of record on this 13th day of March, 2019, as follows:
Lewis Wise, Esq.
Rogin Nassau LLC
185 Asylum Street, 22"! Floor
Hartford, CT 06103
Matthew J. Willis, Esq.
Halloran & Sage LLP
One Goodwin Square
225 Asylum Street
Hartford, CT 06103
willis@halloransage.com
/s/ David S. Hoopes
David 8. Hoopes
NALitigation\General\Women's Institute\Old Lyme Zoning Appealjoint m-supp record.docx.EXHIBIT
Sepiember 10, 2018
Robert Staab, Chairperson
Old Lyme Bthies Commission
Memorial Town Hall
52 Lyme St.
Old Lyme, CT 06371
To: Peter Thomas
clo 17 Gould Lane
Old Lyme Ct 06371
Dear Mr. Thomas:
The Old Lyme Ethies Commission has reviewed the Complaint (Appendix A) you submitted
alleging a conflict of interest exists for the attorney David Royston of Dzialo, Pickett & Allen,
PLC, (“the Firm”). Below is our decision regarding this Complaint
Facts
The Firm is counsel to the Old Lyme Board of Appeals. Mr, Royston is a member of the Hope
Partnership Properties Committee, Hope Partnership is seeking approval from the Town of Old
Lyme Zoning Commission for an affordable housing development in Old Lyme,
On June 5, 2018, ata Public Hearing regarding the affordable housing application, Attomey
Lewis Wiso entered into the record a statement that Mr. Royston has a conflict of interest
because of his involvement in Hope Partnership while “he regularly represents Old Lyme land
use agencies.” (See Appendix B),
Sylvia Rutkowska, partner at the Firm, responded in writing to the conflict of Interest allegation
on behalf of the Firm and Mr. Royston, Her response was sent to the Old Lyme Zontng Board of
Appeals with copies to the Old Lyme Zoning Commission, Lewis Wise, Hope Partnership, and
the First Selectman's Office. In brief, Ms, Rutkowska explained the extent of the firm’s
representation of the town and that no conflict of interest existed under the Connecticut Code of
Professional Conduct which governs licensed attorneys in Connecticut. {See Appendix B),
ethics Commission Analysis
The Town of Old Lyme has enacted a Code of Ethics (see the Code text at: 2
hitpsevode360;comn/38 O26 87h uhlight=of/20code%20a/20qthbios cade M200t%420ethies,eth
ies¥o20code%20olrol20ethies.cthles,code,of#8840268). Under Section 43-3 of the Code a -
- “paid consullant” defined as “{a] person, firm or corporation hired by the Town to provide
services to the Town for a fee.” Under Section 43-5 of the Code, “[nJo paid consultant of the
Town shat! represent a private party in any action or proceeding against the Town,” The Code
also provides that this “restriclion may be waived by the Ethics Commission,”The Firm is a paid consultant for purposes of the Code. Neither the firm nor Mr. Royston has
appeared before the Ethics Commission to seek a waiver in this matter pursuant to Section 43-5
of the Code. We therefore determine that the Firm failed to adhere to the procedural
requirements of Section 43-5 of the Code. Note, the Commission fs nor at this time making a
finding on the merits of whether a waiver is warranted. If the Firm wishes to contact the
Commission so that it can appear and request a waiver, the Commission will consider and
respond to its request.
This letter is submitted on behalf of the Town of Old Lyme Ethics Coramisston,
Sincerely,
a B)
Cc eackall ee,
‘Old Lyme Ethics Commission
ce: David Royston. Esq.
Sylvia Rutkowska, Esq.
Old Lyme Bthics CommissionEXHIBIT.
December 3, 2018
Peter Thomas
17 Gould Lane
Old Lyme Ct 06371
David M. Royston
Dzialo, Pickett & Allen, P.C,
15 Elm Street
Old Saybrook, CT 06475
Sylvia K Rutkowska
Dzialo, Pickett & Allen, P.C,
15 Elm Street
Old Saybrook, CT 06475
Re: Ethics Complaint dated 7/17/18
Dear Messrs, Thomas and Royston and Ms, Rutkowska:
I write on behalf and at the direction of the Old Lyme Bthics Commission in
connection with the complaint by Mr. Thomas dated 7/17/18, a copy of
which is attached hereto, In short, the complainant alleged a violation of the
Ethics Code by Attorney Royston and his firm because the firm represented
a private party at Zoning Commissions meetings without requesting a waiver
from the Ethics Commission,
The complaint was accepted on September 4, 2018. Our Code Section 43-8
A (2) provides that “If it accepts the complaint, acknowledgment of receipt
shall be sent to the complainant within five (5) days thereafter, and a copy of
the complaint furnished the respondent, The respondent shall be notified that
he/ she is affotded at least ten (10) business days to submit any response
{101701520,DOCX; v,}he/she wishes the Commission to consider before it decides to open a
hearing”.
As previously noted, we failed to provide the respondents with the above *
referenced due process notice as required, Accordingly, our letter dated
September 10, 2018, was thereby withdrawn and vacated by. way of
correspondence to you dated November 8, 2018, and proper notice was
therefor sent to the respondents on November 8, 2018, as well,
The Commission acknowledged the respondents! letter of October 19, 2018
and November 27, 2018, with attachments theieto, and in response the
Commission scheduled a meeting to discuss the issue once again, That
meeting was held on November 28, 2018. The complainant and the
respondents chose to attend that meeting, and in particular, Mr, Thomas and
Mr. Royston chose to submit their comments in person during the
confidential session, Said confidential session was held pursuant Code
section 43-8 A(L), The respondents exercised their right to keep the entire
record and entire hearing confidential while the Commission determined
whether there was probable cause to proceed, The Commission took great
strides to meet that request. The input of both Mr, Thomas and Royston to
the Commission is greatly appreciated, as is the interest from the town at
large. We acknowledge public comments to make this matter public but we
are unable to do so absent a finding of probable canse pursuant to Code
section 43-8 A(4) & (5), or absent a request by the respondents to do so
During this entire process of review and review of the Code, the
Commission found provisions in our Code that could be considered
ambiguous, As such, the Commission intends to propose clarifying
language to the Code in the near future. We insist that this be done to be fair
to all concerned, now and in the future, However, at this time, we are bound
to rule on the complaint with the Code as currently written, not as we may
wish for it to be written at some point in the future,
The initial complaint of Mr. Thomas dated 7/17/18 alleged that David
Royston, ef al was a paid consultant and represented a private party without
an Ethics Commission waiver, After reviewing this matter and taking the
oral and doghmentary evidence into consideration, the Commission
examinedfelovant Code provisions,
{101701520.DOCX; v.}Based on our review, we find, as Mr. Royston and his firm candidly
acknowledged, that he is a Paid Consultant, as that term is defined by Code
section 43-3, In this regard, we find further that the relevant Code section
43-5A provides that “no paid consultant of the Town shall represent a
private party in any action or proceeding against the Town. This restriction
may be waived by the Ethics Commission.” The clear language of the Code,
as presently written, indicates that a paid consultant, absent a waiver, may
not represent a private party in an action against the Town.
In this matter, the evidence reflect'that the representation by Mr. Royston on
behalf of a private party or parties before the Zoning Commission was not in
connection with “an action or proceeding against the Town.” Accordingly,
we find that no violation occurred, and since there was no representation by
him in any action against the town, it was not necessary to apply for a
waiver.
We further note that the evidence reflected that Mr. Royston, requested and
received written permission from the then chair of the ZBA to represent the
private party in the action before the zoning Commission, While not binding
upon us, and while future Code changes may include directives to
Commission chairs to refer such requests to the Ethics Commission for its
consideration, it is evidence of intent by Royston to avoid the appearance of
impropriety as that term is commonly defined. We note, parenthetically,
that the term “appearance of impropriety” is not defined and is found in two
Code sections , 43-1 (A) and 43-3 (Conflict of Interest). In particular, the
definitional section of conilict of interest limits appearance of impropriety to
the specific issues cited in the Conflict of Interest section, Finally, we note
that while a paid consultant may request a waiver of a conflict of interest
pursuant to Code section 43-5, this waiver is permissive in nature and not
mandatory, imposes no requirement on a paid consultant to seek a waiver,
and, in this case, was not applicable due to our finding that Mr. Royston’s
representation was not adverse to the Town, Clearly, albeit not before.us,
had Mr. Royston’s client lost the underlying application before the Zoning
Commission, any subsequent appeal by that client by Royston would be in
violation of the Code because that matter, at that point, would be considered
to be an action or proceeding against the Town, and its Zoning Commission
{101701520.DOCX; v.}The Commission, after reviewing all comments and documents in
connection with the complaint, has conducted its investigation as provided
by the Code and C.G.S. sections 7-148h and 1-82a, We find ne probable
cause that Royston, ef al has violated the Code and, accordingly, there is no
need for further public hearings as envisioned by Code section 43-8, Our
investigation is complete and the matter is dismissed with a finding of no
probable cause. Pursuant to statute and our Code section 43-8.A(5) the
complaint and the record of investigation shall remain confidential.
We thank you for your interest and consideration,
Very truly yours,
ee sh
Chairperson
Old Lyme Ethics Commission
Memorial Town all
52 Lyme Street
Old Lyme, Ct 06371
{104701520 DOCX; v.}TOWN OF OLD LYME CODE OF ETHICS
EEHICS COMPLAINT | .
TAwe, the undersigned hereby allege a violation of the Town of
Old Lyme Code of Ethics
A, Name of Public Official, Officer or Public employee whether
olected and/or appointed, paid or unpaid
Arrenney David Royston s Pzialo, Plecew & Mes wt al.
B. _ Cite the specific section(s) of the Code of Ethics thathas been =~
-* violated in this matter © 43-8 ‘Pain Consultants ¢
C. The specific acts’ which constitute the violation and when they
occurred are as follows (attach additional pages if necessary);
Attorsey/fam Represented Private. panty ‘ar S/t4 Zodserg ©
mrq. 2k Slow Ewe mrqg. witoor aw tételes waiver? (
D. Have you presented these allegations to any other administrative or ‘
judicial authorities?
NAtsed conceans AT OL Zoning Commission Public Heb
Sez
CERTIFICATION arn
Thwe declare undex penalty of false statement that the above complaint and
any attachments thereto, is/are true to the best of my knowledge. I *
understand thet until the Ethics Commission has made a finding of probable
cause, I am forbidden from disclosing to any third party that I have filed an
Ethics Complaint.
Signed: mak (4
Print name ° Address Propeury on net
Reve Thomas P Goud Url, O10
iT PAI IGS cr 06
Date 2 (17/(% Work/cell Phone Home Phone a- :
E-mail address(optional)
petethomss @ATI NET
Completed form should be mailed to
Chair of Ethics Commission
C/O The Town Clerk
52 Lyine Street
Old Lyme, CT 06371
Dated January 24, 2009
Preview
DOCKET NO.;: HHD-CV18-6104443-S : SUPERIOR COURT DOMINIC W, PAPA TRUSTEE, ET AL. : JUDICIAL DISTRICT OF HARTFORD VS. : AT HARTFORD OLD LYME ZONING COMMISSION, ET AL, : MARCH 13, 2019 JOINT MOTION TO SUPPLEMENT RECORD The Defendants, Neck Road Hope Housing LLC and Old Lyme Housing LLC (“Applicant Defendants”) and the Plaintiffs Dominic W. Papa Trustee, William Francis Fitzgerald and Patricia Fitzgerald (“Plaintiffs”) jointly move, pursuant to C.G.S. § 8-8(k), that the following documents be entered into evidence in this appeal: 1 Exhibit A: Correspondence from Robert Staab, Chairperson, Old Lyme Ethics Commission, to Peter Thomas, dated September 10, 2018. 2. Exhibit B: Correspondence from Robert Staab, Chairperson, Old Lyme Ethics Commission to Peter Thomas, David M. Royston and Sylvia K. Rutkowski dated December 3, 2018. These documents concern the Plaintiff’s allegation that the approval was “tainted” by a conflict of interest on the part of the applicant’s attorney, David Royston. Exhibits A and B are notices of action taken by the Old Lyme Ethics Commission concerning the involvement of Attomey Royston as counsel for the applicant in this matter. The Plaintiffs wish to offer Exhibit A. The Applicant-Defendants wish NAL itigation\Genera\Women's Instilute\Old Lyme Zoning Appealijoint m-supp record.docxto offer Exhibit B. Both movants reserve all rights with respect to argument concerning the significance of the document offered by the other party. THE PLAINTIFFS, DOMINIC W. PAPA TRUSTEE, WILLIAM FRANCES FITZGERALD AND PATRICIA FITZGERALD By: /s/ David S. Hoopes Lewis Wise, Esq. Rogin Nassau LLC 185 Asylum Street, 22" Floor Hartford, CT 06103 Telephone: (860) 256-6300 Juris No, 050793 Its Attorneys THE DEFENDANTS, NECK ROAD HOPE HOUSING LLC OLD LYME HOUSING LLC By: /s/ David S. Hoopes David S. Hoopes Hoopes Morganthaler Rausch & Scaramozza LLC CityPlace II—185 Asylum Street Hartford, CT 06103-3426 Telephone: (860) 275-6800 Juris No. 423839 Its Attorneys Ni\Litigation\GeneraltWomen's Institute\Old Lyme Zoning Appealoint m-supp record.docx 2CERTIFICATION Thereby certify that a copy of the foregoing was mailed, postage prepaid, or emailed to all counsel and pro se parties of record on this 13th day of March, 2019, as follows: Lewis Wise, Esq. Rogin Nassau LLC 185 Asylum Street, 22"! Floor Hartford, CT 06103 Matthew J. Willis, Esq. Halloran & Sage LLP One Goodwin Square 225 Asylum Street Hartford, CT 06103 willis@halloransage.com /s/ David S. Hoopes David 8. Hoopes NALitigation\General\Women's Institute\Old Lyme Zoning Appealjoint m-supp record.docx.EXHIBIT Sepiember 10, 2018 Robert Staab, Chairperson Old Lyme Bthies Commission Memorial Town Hall 52 Lyme St. Old Lyme, CT 06371 To: Peter Thomas clo 17 Gould Lane Old Lyme Ct 06371 Dear Mr. Thomas: The Old Lyme Ethies Commission has reviewed the Complaint (Appendix A) you submitted alleging a conflict of interest exists for the attorney David Royston of Dzialo, Pickett & Allen, PLC, (“the Firm”). Below is our decision regarding this Complaint Facts The Firm is counsel to the Old Lyme Board of Appeals. Mr, Royston is a member of the Hope Partnership Properties Committee, Hope Partnership is seeking approval from the Town of Old Lyme Zoning Commission for an affordable housing development in Old Lyme, On June 5, 2018, ata Public Hearing regarding the affordable housing application, Attomey Lewis Wiso entered into the record a statement that Mr. Royston has a conflict of interest because of his involvement in Hope Partnership while “he regularly represents Old Lyme land use agencies.” (See Appendix B), Sylvia Rutkowska, partner at the Firm, responded in writing to the conflict of Interest allegation on behalf of the Firm and Mr. Royston, Her response was sent to the Old Lyme Zontng Board of Appeals with copies to the Old Lyme Zoning Commission, Lewis Wise, Hope Partnership, and the First Selectman's Office. In brief, Ms, Rutkowska explained the extent of the firm’s representation of the town and that no conflict of interest existed under the Connecticut Code of Professional Conduct which governs licensed attorneys in Connecticut. {See Appendix B), ethics Commission Analysis The Town of Old Lyme has enacted a Code of Ethics (see the Code text at: 2 hitpsevode360;comn/38 O26 87h uhlight=of/20code%20a/20qthbios cade M200t%420ethies,eth ies¥o20code%20olrol20ethies.cthles,code,of#8840268). Under Section 43-3 of the Code a - - “paid consullant” defined as “{a] person, firm or corporation hired by the Town to provide services to the Town for a fee.” Under Section 43-5 of the Code, “[nJo paid consultant of the Town shat! represent a private party in any action or proceeding against the Town,” The Code also provides that this “restriclion may be waived by the Ethics Commission,”The Firm is a paid consultant for purposes of the Code. Neither the firm nor Mr. Royston has appeared before the Ethics Commission to seek a waiver in this matter pursuant to Section 43-5 of the Code. We therefore determine that the Firm failed to adhere to the procedural requirements of Section 43-5 of the Code. Note, the Commission fs nor at this time making a finding on the merits of whether a waiver is warranted. If the Firm wishes to contact the Commission so that it can appear and request a waiver, the Commission will consider and respond to its request. This letter is submitted on behalf of the Town of Old Lyme Ethics Coramisston, Sincerely, a B) Cc eackall ee, ‘Old Lyme Ethics Commission ce: David Royston. Esq. Sylvia Rutkowska, Esq. Old Lyme Bthics CommissionEXHIBIT. December 3, 2018 Peter Thomas 17 Gould Lane Old Lyme Ct 06371 David M. Royston Dzialo, Pickett & Allen, P.C, 15 Elm Street Old Saybrook, CT 06475 Sylvia K Rutkowska Dzialo, Pickett & Allen, P.C, 15 Elm Street Old Saybrook, CT 06475 Re: Ethics Complaint dated 7/17/18 Dear Messrs, Thomas and Royston and Ms, Rutkowska: I write on behalf and at the direction of the Old Lyme Bthics Commission in connection with the complaint by Mr. Thomas dated 7/17/18, a copy of which is attached hereto, In short, the complainant alleged a violation of the Ethics Code by Attorney Royston and his firm because the firm represented a private party at Zoning Commissions meetings without requesting a waiver from the Ethics Commission, The complaint was accepted on September 4, 2018. Our Code Section 43-8 A (2) provides that “If it accepts the complaint, acknowledgment of receipt shall be sent to the complainant within five (5) days thereafter, and a copy of the complaint furnished the respondent, The respondent shall be notified that he/ she is affotded at least ten (10) business days to submit any response {101701520,DOCX; v,}he/she wishes the Commission to consider before it decides to open a hearing”. As previously noted, we failed to provide the respondents with the above * referenced due process notice as required, Accordingly, our letter dated September 10, 2018, was thereby withdrawn and vacated by. way of correspondence to you dated November 8, 2018, and proper notice was therefor sent to the respondents on November 8, 2018, as well, The Commission acknowledged the respondents! letter of October 19, 2018 and November 27, 2018, with attachments theieto, and in response the Commission scheduled a meeting to discuss the issue once again, That meeting was held on November 28, 2018. The complainant and the respondents chose to attend that meeting, and in particular, Mr, Thomas and Mr. Royston chose to submit their comments in person during the confidential session, Said confidential session was held pursuant Code section 43-8 A(L), The respondents exercised their right to keep the entire record and entire hearing confidential while the Commission determined whether there was probable cause to proceed, The Commission took great strides to meet that request. The input of both Mr, Thomas and Royston to the Commission is greatly appreciated, as is the interest from the town at large. We acknowledge public comments to make this matter public but we are unable to do so absent a finding of probable canse pursuant to Code section 43-8 A(4) & (5), or absent a request by the respondents to do so During this entire process of review and review of the Code, the Commission found provisions in our Code that could be considered ambiguous, As such, the Commission intends to propose clarifying language to the Code in the near future. We insist that this be done to be fair to all concerned, now and in the future, However, at this time, we are bound to rule on the complaint with the Code as currently written, not as we may wish for it to be written at some point in the future, The initial complaint of Mr. Thomas dated 7/17/18 alleged that David Royston, ef al was a paid consultant and represented a private party without an Ethics Commission waiver, After reviewing this matter and taking the oral and doghmentary evidence into consideration, the Commission examinedfelovant Code provisions, {101701520.DOCX; v.}Based on our review, we find, as Mr. Royston and his firm candidly acknowledged, that he is a Paid Consultant, as that term is defined by Code section 43-3, In this regard, we find further that the relevant Code section 43-5A provides that “no paid consultant of the Town shall represent a private party in any action or proceeding against the Town. This restriction may be waived by the Ethics Commission.” The clear language of the Code, as presently written, indicates that a paid consultant, absent a waiver, may not represent a private party in an action against the Town. In this matter, the evidence reflect'that the representation by Mr. Royston on behalf of a private party or parties before the Zoning Commission was not in connection with “an action or proceeding against the Town.” Accordingly, we find that no violation occurred, and since there was no representation by him in any action against the town, it was not necessary to apply for a waiver. We further note that the evidence reflected that Mr. Royston, requested and received written permission from the then chair of the ZBA to represent the private party in the action before the zoning Commission, While not binding upon us, and while future Code changes may include directives to Commission chairs to refer such requests to the Ethics Commission for its consideration, it is evidence of intent by Royston to avoid the appearance of impropriety as that term is commonly defined. We note, parenthetically, that the term “appearance of impropriety” is not defined and is found in two Code sections , 43-1 (A) and 43-3 (Conflict of Interest). In particular, the definitional section of conilict of interest limits appearance of impropriety to the specific issues cited in the Conflict of Interest section, Finally, we note that while a paid consultant may request a waiver of a conflict of interest pursuant to Code section 43-5, this waiver is permissive in nature and not mandatory, imposes no requirement on a paid consultant to seek a waiver, and, in this case, was not applicable due to our finding that Mr. Royston’s representation was not adverse to the Town, Clearly, albeit not before.us, had Mr. Royston’s client lost the underlying application before the Zoning Commission, any subsequent appeal by that client by Royston would be in violation of the Code because that matter, at that point, would be considered to be an action or proceeding against the Town, and its Zoning Commission {101701520.DOCX; v.}The Commission, after reviewing all comments and documents in connection with the complaint, has conducted its investigation as provided by the Code and C.G.S. sections 7-148h and 1-82a, We find ne probable cause that Royston, ef al has violated the Code and, accordingly, there is no need for further public hearings as envisioned by Code section 43-8, Our investigation is complete and the matter is dismissed with a finding of no probable cause. Pursuant to statute and our Code section 43-8.A(5) the complaint and the record of investigation shall remain confidential. We thank you for your interest and consideration, Very truly yours, ee sh Chairperson Old Lyme Ethics Commission Memorial Town all 52 Lyme Street Old Lyme, Ct 06371 {104701520 DOCX; v.}TOWN OF OLD LYME CODE OF ETHICS EEHICS COMPLAINT | . TAwe, the undersigned hereby allege a violation of the Town of Old Lyme Code of Ethics A, Name of Public Official, Officer or Public employee whether olected and/or appointed, paid or unpaid Arrenney David Royston s Pzialo, Plecew & Mes wt al. B. _ Cite the specific section(s) of the Code of Ethics thathas been =~ -* violated in this matter © 43-8 ‘Pain Consultants ¢ C. The specific acts’ which constitute the violation and when they occurred are as follows (attach additional pages if necessary); Attorsey/fam Represented Private. panty ‘ar S/t4 Zodserg © mrq. 2k Slow Ewe mrqg. witoor aw tételes waiver? ( D. Have you presented these allegations to any other administrative or ‘ judicial authorities? NAtsed conceans AT OL Zoning Commission Public Heb Sez CERTIFICATION arn Thwe declare undex penalty of false statement that the above complaint and any attachments thereto, is/are true to the best of my knowledge. I * understand thet until the Ethics Commission has made a finding of probable cause, I am forbidden from disclosing to any third party that I have filed an Ethics Complaint. Signed: mak (4 Print name ° Address Propeury on net Reve Thomas P Goud Url, O10 iT PAI IGS cr 06 Date 2 (17/(% Work/cell Phone Home Phone a- : E-mail address(optional) petethomss @ATI NET Completed form should be mailed to Chair of Ethics Commission C/O The Town Clerk 52 Lyine Street Old Lyme, CT 06371 Dated January 24, 2009