NO. HHD CV 16-6071180-S SUPERIOR COURT INDEPENDENT PARTY OF CT- STATE CENTRAL, ET AL. J.D. OF HARTFORD VS. AT HARTFORD DENISE MERRILL, AS CONNECTICUT SECRETARY OF THE MICHAEL ROCCO FRANK, JR. AUGUST 21, 2018 MEMORANDUM OF DECISION This case arises out of a longstanding dispute between two factions of the Connecticut Independent Party, namely, the Independent Party of CT-State Central (IPCT- SC), based in Danbury, and the Independent Party of Connecticut (IP-CT), based in Waterbury.l The action was commenced in September 2016 seeking declaratory and injunctive relief against Denise Merrill, State of Connecticut Secretary of the State (SOTS), in an effort to require her to place the names of the nominated candidates of IPCT-SC on a separate line for the Independent Party on the ballot for the general election held on November 8, 2016.2 The parties are the plaintiffs, 1 The plaintiff is variously referred to herein as the Independent Party of Connecticut State Central, the IPCT-SC, the Danbury IP, the and the Danbury faction. The is sometimes referred to herein as the Waterbury IP or the Waterbury Faction. After the election of 2008, as further detailed 1n this memorandum, the minor party claimed by the parties [to this case became known as the Independent Party and was of?cially recognized as such by thei SOTS. See Defendants? Exhibit Z. This case initially arose when the two factions nominated competing candidates for several state of?ces. On September 2, 2016, the SOTSnotn?iedlboth factions that, in accordance with existing policy and General Statutes 9? ?1151th am?%uld be placed on the ballot under the Independent Party line unless one hahdrdate iwlitl?ilclregv9 S??iion 9- 250 provides 1n relevant part as follows: ?No column, under the name [of an?politicgleaarty or independent inJ i . 3/ 53:111. Cd" Gamay 03113 A515 37/ 91/ 1&3 IPCT-SC, Michael Duff, Donna LaFrance, and Roger Palanzo.3 The defendants are the SOTS, Michael Telesca and Rocco Frank, Jr.4 The plaintiffs ?led an amended complaint on March 3, 2017 seeking a declaratory judgment ordering the SOTS to recognize the individual plaintiffs as the duly authorized of?cers of the and an injunction prohibiting the defendants from acting directly or indirectly on behalf of the IPCT-SC. The defendants ?led with permission of the court an answer with special defenses and a counterclaim on October 10, 2017. In the counterclaim, Telesca and Frank seek a judgment declaring that they are the rightful of?cers of the statewide Independent Party of Connecticut, and that the individual plaintiffs are not. A court trial was held on October 11, 17 and 18, 2017. The trial witnesses were Roger Palanzo, Sr., the secretary and deputy treasurer of the IPCT-SC since 2013; Michael Duff, chair of the since 2016; Michael Telesca, a founding member of the Mary Iorio, a witness and a participant in a meeting with Telesca and Dr. Robert Fand,5 in 2010; John Mertens, a professor of engineering and chair of engineering at Trinity College and former IP-CT candidate for United States Senate in 2006; Rocco Frank, an IT consultant and former IP-CT organization, shall be printed on any of?cial ballot, which contains more candidates for any of?ce than the number for which an elector may vote for that of?ce.? 3 All three named plaintiffs are of?cers of the IPCT-SC. Michael Duff becanfe chair upon the death of John L. Dietter in 2016, former chair and original plaintiff in this aetion, Donna L. LaFrance is the treasurer, and Roger Palanzo is the secretary/deputy treasurer, who replaced Dr. Robert Fand upon his death in 2013. 4 All references to the defendants In this memorandum, unless otherwise speci?ed, are to Telesca and Frank. 5 Fand was a founding member of the Central, who is now deceased. 2 candidate and creator of the Milford Independent Party; Lawrence DePillo, a computer consultant and founding member of the Waterbury Independent Party in 2003; Richard Wick, an executive and founding member of the Watertown Independent Party; and David LaPointe, a former state corrections of?cer, union president, and founding member of the Winsted Independent Party. Closing argument was held on March 23, 2018 and August 3, 2018. This lawsuit is one of several wherein the individual parties have challenged the actions of the other in an effort-to have their respective factions declared the true Independent Party of the State of Connecticut. See Price v. Independent Party of CT - State Central, 323 Conn. 529, 147 A.3d 1032 (2016); Independent Party of Connecticut State Central v. Telesca, Superior Court, judicial district of Danbury, Docket No. and Independent Party of CT v. Dietter, Superior Court, judicial district of Waterbury, Docket No. CV-12-5 0163 87-3 (September 28, 2012, Taylor, J.). In the present case, the plaintiffs seek the following declaratory and injunctive relief: A Declaratory Judgment that: a. the Bylaws as amended September 27, 2006 are the validly adopted and currently effective party rules of the Plaintiff Independent Party of CT - State Central Within the meaning of party rules set forth in Connecticut [General] Statute[s] 9-3 74; b. Individual Plaintiffs Duff, LaFrance, and Palanzo constitute the entirety of the duly elected board of Plaintiff Independent Party of CT - State Central; 0. Plaintiff Duff is the Chairman of the Plaintiff Independent Party of CT. - State Central; (1. Plaintiff LaFrance is the Treeisurer of the Plaintiff Independent Party of CT - State Central; e. Plaintiff Palanzo is the Secretary and Deputy Treasurer of the Plaintiff Independent Party of CT - State Central. 3 2. An immediate injunction restraining and prohibiting Defendants Telesca and Frank, jointly and severally, from directly and/or indirectly: a. Purporting to act on behalf of Plaintiff Independent Party of CT State Central; b. Making ?lings on behalf of Plaintiff Independent Party of CT - State Central with the State of Connecticut and/or any agency and/or political subdivision thereof; c. Representing to any person or entity in any form of communication or technology that they are of?cers of the Plaintiff Independent Party of CT - State Central; d. Taking any action which serves to contradict or is otherwise inconsistent with the lawful incumbency of the individual Plaintiffs in their respective capacities with the Plaintiff Independent Party of CT State Centra Plaintiffs? Second Amended Complaint, dated March 3, 2017. In their answer to the plaintiffs? complaint, the defendants have asserted the following special defenses: 1) the plaintiffs lack standing to ?le and prosecute this case; 2) the plaintiffs have rati?ed the actions by the defendants in ?ling bylaws for the Independent Party in 2010 or have waived any right to challenge the 2010 bylaws; 3) the purported bylaws of 1987 and 2006 Violate rights of free of association of members of the Independent Party guaranteed to them by the ?rst amendment of the United States Constitution and Article First, 14 of the Connecticut Constitution; and 4) the purported 2006 amendment to the 1987 bylaws, dated September 27, 2006, ?led with the SOTS is invalid in that it was adopted without authority. As previously stated, the defendants, Telesca and Frank, ?led a counterclaim seeking a declaratory judgment that they are the rightful of?cers of the Independent Party of Connecticut, and that the individual plaintiffs are not. In a ?ling on July 18, 2018, in response to an order of the court, the defendants 4 further specified the relief they are seeking by way of declaratory judgment. Speci?cally, the defendants request the following relief: The by-laws adopted by the Independent Party of Connecticut in 2010 after it became a statewide minor party as a result of the 2008 presidential election are the valid by?laws of the statewide Independent Party of Connecticut pursuant to Conn. Gen. Stat. 9?374. 2. Michael Telesca as chairman and Rocco Frank, Jr. as treasurer are the rightful of?cers of the statewide Independent Party of Connecticut. 3. The individual plaintiffs are not the rightful of?cers of the statewide Independent Party of Connecticut, and they are entitled to no relief. 4. The by?laws adopted in 2006, prior to the existence of a statewide Independent Party, by the Danbury faction calling itself Independent Party of CT State Central apply only to that local committee of the Independent Party. Accordingly, the Independent Party of CT State Central is entitled to no relief. 5. The Secretary of the State is ordered to recognize the above and to treat nominations and endorsements made pursuant to its 2010 by?laws as nominations and endorsements of the Independent Party of Connecticut.? Defendants? Counterclaim Prayer for Relief, dated July 18, 2018. The central issue in this case is whether the bylaws adopted by the 2006 (2006 bylaws), by a three-member central committee, two years before the Independent Party gained statewide status, remain the operative bylaws of the Independent Party in Connecticut or whether the operative bylaws are those adopted at a caucus held in 2010 (2010 bylaws), after the 5 Independent Party gained minor party status in 2008 by attaining 1 percent of the vote in a statewide election. At the heart of the dispute is the question of who is to control the Independent Party line in the November 2018 general election and whether the bylaws formed by a group of three individuals local to Danbury two years before the Independent Party achieved statewide status are the only legitimate bylaws which control the statewide Independent Party now that it has become a statewide minor party. I I. SUBJECT MATTER JURISDICTION As a threshold matter, the court must determine whether it has subject matter jurisdiction over the present action. ?Subject matter jurisdiction involves the authority of the court to adjudicate the type of controversy presented by the action before it. . . . court lacks discretion to consider the merits of a case over which it is without jurisdiction. . . . The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings . . . (Internal quotation marks omitted.) Keller v. Beckenstein, 305 Conn. 523, 531?32, 46 A.3d 102 (2012). ?Moreover, [t]he parties cannot confer subject matter jurisdiction on the court, either by waiver or by consent?? (Internal quotation marks omitted.) New Hartford v. Connecticut Resources Recovery Authority, 291 Conn. 511, 518, 970 A.2d 583 (2009). ?[J]usticiability comprises several related doctrines, namely, standing, ripeness, mootness and the political question doctrine, that implicate a court?s subject matter jurisdiction and its competency to adjudicate a particular matter. . . . A case that is nonjusticiable must be dismissed for lack of subject matter jurisdiction.? (Internal quotation 6 marks omitted.) Janulawicz V. Commissioner of Correction, 310 Conn. 265, 270, 77 A.3d 113 (201 3). Given the circumstances of this case, the court raised the issue of whether the dispute between the parties was nonjusticiable and more properly committed to the legislature or to the parties themselves for resolution. As such, in an order dated July 19, 2018, the court directed the parties to submit briefs and attend a hearing to address the question of whether the pending. controversy was properly within the subject matter jurisdiction of the court. In furtherance of that order, the parties filed supplemental memoranda, and a hearing was held on August 3, 2018. Both parties argued that the court did have subject matter jurisdiction over the matter; They contended that the dispute did not involve a political question, and they maintained that the dispute could not be resolved by the parties internally due to a fundamental disagreement over which bylaws controlled. The defendants also argued that the dispute required the court to interpret General Statutes 9-3 74 and related provisions, and that the need for such interpretation brought the case within this court?s jurisdiction. Accordingly, the court ?rst addresses whether the current dispute involves a political question. ?It is well settled that certain political questions cannot be resolved by judicial authority without violating the constitutional principle of separation of powers.? Nielsen v. Kezer, 232 Conn. 65, 74, 652 A.2d 1013 (1995). ?The ?mdamental characteristic of a political question . . . is that its adjudication would place the court in con?ict with a coequal biranch of government in violation of the primary authority of that coordinate branch.? Id. ?In deciding whether an action is nonjusticiable under the political question doctrine, we are to be guided by 7 several formulations which vary according to the settings in which the [question] arise[s] . . . . Prominent on the surface of any case held to involve a political question is found a textually demonstrable constitutional commitment of the issue to a coordinate political department; or a lack of judicially discoverable and manageable standards for resolving it; or the impossibility of deciding without an initial policy determination of a kind clearly for nonjudicial discretion; or the impossibility of a court?s undertaking independent resolution without expressing lack of the respect due coordinate branches of government; or an unusual need for unquestioning adherence to a political decision already made; or the potentiality of embarrassment from multifarious pronouncements by various departments on one question. Unless one of these formulations is inextricable from the case at bar, there should be no dismissal for nonjusticiability on the ground of a political question?s presence.? (Internal quotation marks omitted.) Id., 75. In the present case, the core principles underlying the political question doctrine are not implicated in the dispute between the parties, and judicial resolution may readily be accomplished without expressing lack of the respect due coordinate branches of government. See id., 76. There is no indication that the legislature sought to exclude courts completely from the adjudication of controversies relating to the type of intraparty dispute involved in {the present case, and no executive or legislative branch agency has plenary authority to consider 1such disputes. See id. Moreover, the Supreme Court has expressed its doubt that the political question doctrine was intended to apply to the intraparty disputes of a political party. See id., 75 - 76; see also Nielsen v. Kezer, Superior Court, judicial district of Hartford?New Britain at Hartford, Docket No. (September 8, 1994, Corradz'no, J) (12 Conn. L. Rptr. 8 419, 421) (declining to ?nd that it lacked subject matter jurisdiction under the political question doctrine because the executive committee or the executive committee of any other party is most assuredly not a coordinate branch of government to which the . . . courts owe deference within the meaning of the separation of powers or the political question doctrine?) Because the current dispute between the parties does not violate the constitutional principle of separation of powers and a resolution may be accomplished without expressing ailack of respect to the coequal branches of government, the court concludes that the present action does not raise a nonjusticiable political question. The court next examines the question of whether it lacks subject matter jurisdiction because the parties themselves are better suited to resolving the current dispute between them. ?Political parties generally are free to conduct their internal affairs free from judicial supervision. . . . This common law principle of udicial restraint, rooted in the constitutionally protected right of free association, serves the public interest by allowing the political processes to operate without undue interference. . . . Because the nomination and endorsement of candidates for elective of?ce are among the primary functions of political parties, [i]udicial intervention in [the selection of convention delegates] traditionally has been approached with great caution and restrain (Citations omitted; footnote omitted; internal quotation marks omitted.) Nielsen v. I Kezer, supra, 232 Conn. 78-79. ?The rule appears to be that in factional controversies within a political party where there is no controlling statute or clear legal right involved, the court will not assume jurisdiction, but will leave the matter for determination by the proper tribunals of the party itself, or by the electors at the polls.? Nielsen v. Kezer, supra, 12 Conn. L. Rptr. 420. 9 The Supreme Court has recognized, nevertheless, that ?the judiciary has a role to play in promoting fair play even within the nomination process.? Price V. Independent Party of State Central, 323 Conn. 529, 543, 147 A.3d 1032 (2016). Moreover, even when the action before the court involves an intraparty dispute, the court has jurisdiction to hear the matter when ?the controversy raises issues of constitutional and statutory interpretation of the kind regularly 9? entertained by courts. Nielsen v. Kezer, supra, 232 Conn. 76; see also Nielsen v. Kezer, supra 12 Conn. L. Rptr. 420 (concluding it had subject matter jurisdiction because clear legal right of the plaintiff was involved because he read the statutory scheme in a different way from defendant and court must have jurisdiction to resolve such claims.) In the present action, the court is required to interpret 9-3; 74 and related provisions to determine which bylaws govern the Independent Party?s nomination procedures for candidates for public of?ce, which is the central dispute between the parties. As the Nielsen court noted, such issues of statutory interpretation are regularly entertained by the courts and are well within its jurisdiction. As a result, the court concludes that it has subject matter jurisdiction over the dispute, and therefore, herein decides the case on the merits. II. FINDINGS OF FACT Based on the testimony and full exhibits in the case, the court finds the following facts. The Connecticut Independent Party was ?rst established as a minor party statewide in Connecticut when it gathered signatures and nominated Ralph Nader for president in 2008, and .he garnered 1 percent of the vote. General Statutes 9-372 (6) defines ?Minor party? as ?a 10 political party or organization which is not a major party and whose candidate for the of?ce in question received at the last?preceding regular election for such of?ce, under the designation of that political party or organization, at least one percent of the whole number of votes cast for all candidates for such of?ce at such election.?6 Thus, the ?rst step to establish a minor party for any particular of?ce is to run a candidate using a nominating petition with a party designation. If that candidate earns at least 1 percent of the votes cast for that of?ce, a minor party for that particular of?ce is recognized for the next election. Attaining minor party status affords the minor party the ability to nominate a candidate without having to gather signatures at the next election for that particular of?ce. The second step to establish a minor party is to ?le a ?copy of the party rules regulating the manner of nominating a candidate for such of?ce,? with the SOTS ?at least sixty days before the nomination of such candidate.? General Statutes 9-3 74. To maintain minor party status, a minor party must continually run candidates for the of?ce in question and retain at least 1 percent of the vote for that of?ce. In 2003, Telesca, DePillo, and others formed the Waterbury Independent Party (Waterbury IP), to run candidates for local of?ce as an alternative to the major parties. To do so, the Waterbury IP ?led a Form 601, Application for Reservation of Party Designation with the of?ce and gathered petition signatures to run candidates for municipal of?ce. A Form 601 is required to be ?led with the SOTS to reserve a party designation in any race where a candidate must petition to get on the ballot. See General Statutes 9?3 53b and 9-3'453u. A 6 In addition to?? 9-3 72 (6), there are essentially four statutes that speci?cally govern minor parties in Connecticut: General Statutes 9-374, 9-451, 9-452 and 9-452a. 11 reservation of party designation may only be ?led for a race in which another similarly named party has not already ?led such a form. Telesca reserved the name ?Independent Party? with the SOTS in 2003 for Waterbury races. That year, the Waterbury IP endorsed a full slate of candidates for municipal elections in Waterbury and elected eight people to of?ce, each of whom received more than 1 percent of the vote in their individual races. Because the candidates received at least 1 percent of the vote in each of those races, the Waterbury IP was eligible for minor party status for those of?ces. Thereafter, Waterbury electors could register as Independent Party members for local elections. After the 2003 Waterbury municipal elections, the SOTS sent a letter to the Waterbury IP requesting that it submit party rules. In 2004, the Waterbury IP drafted bylaws on how to conduct caucuses and created a nominating process for future races, Telesca?s goal was to build a new statewide third party to help people get ballot access around the state. The Waterbury IP bylaws were ?led with the Waterbury town clerk and the SOTS. In 2004, there were about 450 registered members of the Independent Party in the state. In 2004, the Waterbury IP decided to run candidates in races for state representative and state senate in the Waterbury area. In May 2004, it ?led a Form 601 for those General Assembly races and for registrar of voters, nominated candidates for most of the of?ces and sent a letter of its endorsements to the SOTS. Around this time, Telesca learned about a separate Independent Party that had been formed in Danbury headed by Fand that had reserved the name Inhependent Party for the 30th Senate District. Because the Danbury IP had already reserved the party designation of Independent Party for the 30th Senate District, the Waterbury IP was not allowed to nominate a candidate for that election. In 2004, Telesca and Fand reached an agreement that 12 the Waterbury IP would not operate in Danbury and the Danbury IP would not operate in Waterbury. On August 12, 2004, Telesca and others ?led a Form ED-48, a party committee registration form registering the name ?Independent Party Waterbury Town Committee,? which the SOTS accepted. In 2004, all of the Waterbury IP state representative and state senate candidates received over 1 percent of the vote. The Danbury IP also ran some candidates in 2004, some of whom received over 1 percent of the vote and some of whom did not. No party reservation form for any statewide of?ces was ?led by either the Danbury IP or the Waterbury IP in 2004. The Waterbury IP ran a ?ll slate of candidates for municipal of?ces in 2005. That year, Telesca also helped town committees in other municipalities run municipal candidates. In 2006, the Waterbury IP attempted to reserve the name ?Independent Party? statewide but was not able to do so because there were local parties using the name ?Independent? in both Danbury and Waterbury. The SOTS would not allow two different parties with any part of the same name on the ballot at the same time. In 2006, Telesca and Mertens learned from the SOTS that they needed to get the local independent parties to come together in order to get a petition for statewide of?ces. In 2006, Telesca and Fand joined together and signed and ?led a Eorm 601 as members of the Independent Party Designation Committee, but they failed to obtain dnough signatures to get ballot access for any statewide of?ce. As a result, there was no statewide minor party established in that year. Also in 2006, Fand and other members of the Danbury IP ?led bylaws for the Danbury IP. At the time the 2006 bylaws were ?led, the Danbury IP was a 13 recognized local party, as was the Waterbury IP. Neither the Danbury IP nor the Waterbury IP ran statewide candidates in 2006. The Waterbury IP ran candidates for General Assembly races in the Waterbury area in 2006. In September 2006, Fand, Dietter, and LaFrance ?led a form ED-48 with the SOTS designating themselves as the three members of the party committee for the ?Independent Party of CT - (State Central).? See Defendants?s Exhibit At the same time, these individuals ?led the 2006 bylaws, which consisted of one page called ?Party Rules Amended.? See Plaintiffs Exhibit 1. The introductory paragraph of those rules states that the committee ?adopts the following rules for the establishment of local committees and nomination of candidates.? The ?rst paragraph is set forth as Local Committees? and states that ?[l]ocal committees may be organized for any region containing at least one municipality.? It also states that each local committee must send its proposed rules to the for approval; that approval requires the vote of at least two-thirds of the three members of the two?thirds of the could also vote to dissolve a local committee ?for actions contrary to the principles of the and the has the power ?to resolve jurisdictional disputes between local committees by at least a two?thirds vote.? Paragraph 2 of the is designated as ?Nominations? and consists of subparagraphs A-G as follows: Pm Candidates? provides that no member shall seek ballot status in a general election as a candidate of the without ?rst being nbminated? under the provisions of the party rules. Local Committees? states that local icommittee of the may nominate candidates for any of?ce whose electoral district falls within its jurisdiction? but such nominations ?shall be subject to a veto by at leas[t] a two-thirds vote of the 14 Special Pam Meetings? states that special meeting called for that purpose by the may nominate any candidates for any of?ce for which no candidate has been nominated by a local committee and to conduct any other Party business.? State Central Committee of the Independent Party of Ct? states that ?[t]he may, by at least a two-thirds vote, nominate candidates for any of?ce for which no nomination has been made under A. B. or C. and for any State or Federal Office.? Presidential Campaigns? provides that by at least a two-thirds vote, the may ?nominate candidates of the for President and Vice President of the Caucuses? provides as follows: ?[t]hose eligible to make nominations and to vote for nominees for political of?ce at State of Ct?State Statute-required caucuses are those who [are] registered to vote under the Party designation Independent, and those who are registered other than Independent whose campaigns are being and/or have been funded solely by, and reported for, on required Ct. State B4 forms by the for State and/or Municipal Elections and are being/or have been on Municipal and/or State election ballot of the since 2006 under the designation Independent.? 7 (Emphasis in original.) Party Rules Changes? 7 Because the language in Subparagraph is so puzzling, at a hearing held on August 3, 2018, the court requested an explanation of it for two reasons: ?rst, there are no state of Connecticut caucuses required to be held by a minor party. Rather, there are only party meetings. See General Statutes 9?3 72(1) and 9-452a. Second, the court could not make sense out of this provision as written. There was no clear explanation of why the term ?caucus? is used as opposed to the term ?meeting? and the remainder of the paragraph was taken to mean that persons eligible to make nominations and vote for nominees for political of?ce under the IPCT - State Central party rules are those persons who are registered to vote as ?under the party designation Independent? and other persons not so registered but who have been ?mded by or who have been reported as being funded by the for State and/or Municipal Elections? or who are ?being/or have been on such ballots since 2006 ?under the designation ?Independent.? This seems to be a pretty convoluted way of saying that certain persons who have had a 15 provides that party rules can be amended at a special meeting or by ?at least a two-thirds vote of the The ?nal paragraph of the 2006 bylaws (Plaintiff?s Exhibit 1) indicates that the rules were passed unanimously at the meeting of the ?State Central Committee of the Independent Party of CT on 09/27/06,? and is signed by John L. Dietter, Chairman, Donna LaFrance, Treasurer and Robert Fand, Deputy Treasurer. No evidence was introduced at trial indicating that the IPCT-SC took any of the actions toward local committees outlined in the 2006 bylaws; nor was there any evidence that any local committee acknowledged or adhered to the 2006 bylaws of the IPCT-SC in any way. There is no provision in the 2006 bylaws for the replacement of the three original State Central Committee members, although two of the original members are now deceased and have been replaced with others, nor is there any provision at all regarding the election of party leaders. Under the 2006 bylaws, two of the three members of the IPCT-SC have the authority to override local committee bylaws. Two of the three members of the State Central Committee also purportedly control amendment of the rules, the calling of special meetings, have veto power over other local committee nominations, approval or rejection of other local committee rules, dissolution of local committees, nominations for the of?ce of president and vice president of the United States, and nominations for any of?ce where no other nomination has been made. Finally, there is no provision for membership extending beyond the State Central Committee. connection to the IPCT-SC and who are not registered to vote as ?Independent,? are eligible to make nominations and vote for nominees at ?caucuses? ?or meetings.? 16 In 2008, Fand and Telesca joined together to create a statewide Independent Party. There were other Independent Party chapters in the state at this time, including ones in Winsted and Milford. Telesca assisted those chapters by providing information regarding the election process. The immediate goal in 2008 was to run Ralph Nader as a candidate for president as an Independent and achieve 1 percent of the vote which would establish the Independent Party as a statewide minor party. See General Statutes 9?372 (6). In a joint effort to accomplish this goal, Telesca and and both signed and ?led the Form ED-601 Reservation of Party Designation form as the designated agents of the Independent Party. The form designated the name Independent Party not only for president, vice president and electors, but also for state senate districts 24, 28 and 11, state assembly districts 110 and 96, United States congressmen for the third and ?fth districts, and for several registrar of voters and probate judge races. See Defendants? Exhibit U. Telesca testi?ed that because there were different rules for the various local parties in the state who controlled the Independent Party line for their localities, he and Fand agreed that they would need to create a new set of bylaws to accomplish their joint goal of creating a statewide minor party. Without a statewide party, a local Independent Party could oppose a statewide candidate for any of?ce by reserving the same or a similar party designation for their towns. Running Ralph Nader for president provided a clear path toward garnering 1 percent of the vote and establishing a statewide minor party. Once Nader achieved over 1 percent of thelvote in the 2008 presidential election, the SOTS certi?ed the Independent Party as a minor party.i and noti?ed all town registrars of voters of the Independent Party?s new status as a statewide minor party. See Defendants? Exhibit Z. Subsequently, anyone in the state could register to vote as a member 17 of the Independent Party. Following the 2008 election, Telesca and Mertens drafted bylaws for the new statewide party. Telesca sent out 700-800 postcards about a meeting to be held on March 20, 2010 concerning proposed bylaws to any registered member of the Independent Party who had voted in the last two elections. Mertens created a website and posted the proposed bylaws on it months in advance of the meeting. Telesca put an advertisement in the Hartford Courant announcing the meeting/caucus and gave advance notice to the SOTS. Telesca also sent Fand a postcard and gave him a copy of the proposed bylaws before the meeting, which Fand acknowledged. Telesca and Iorio met with Fand about the bylaws for the new statewide party before the meeting was held. On March 20, 2010, the Independent Party held a meeting in Waterbury of registered Independent Party members from around the state to ratify the bylaws for the new statewide party. At the meeting, Fand did not object either to the meeting, the idea of creating bylaws for the new statewide party or the bylaws themselves, nor did he request any changes to the bylaws as proposed. There was an agenda for the meeting and a sign-up sheet. Only registered Independent Party members were allowed to vote on the bylaws. The vote to approve the bylaws was unanimous. The bylaws were ?led with the SOTS on March 22, 2010 (2010 bylaws). No objections were ?led with the SOTS within sixty days of the ?ling date. The 2010 bylaws, as rati?ed at the March 20, 2010 meeting, invited all residents of the state to become members of the Independent Party. They created a process for membership on the ?Independent Party State Central Committee,? a process for the election of of?cers, rules for 18 local town committees, a process for conducting statewide and local caucuses, voting eligibility, a process for nominating candidates for statewide of?ces and statewide central committee members, ?lling vacancies, changes in party rules and a pathway for existing town committees to participate. Telesca and Mertens sent the draft bylaws to Independent Party town committee chairs around the state and arranged for a statewide party meeting. A caucus was held on August 21, 2010 to nominate Independent Party candidates for placement on the November 2, 2010 ballot. The 2010 bylaws were used to guide the nomination process at the caucus. The Independent Party got ballot access for statewide of?ces in 2010 by going through the petitioning process for candidates and by ?ling a Form Application for Reservation of Party Designation. See Defendants Exhibit NN. The purpose of the caucus was to endorse candidates for certain of?ces and to ratify endorsements for other of?ces that had been made through the petitioning process. At a meeting held on August 21, 2010 immediately prior to the caucus, Telesca was authorized to preside over the statewide caucus, ?le all paperwork regarding the upcoming state elections, and to act as the agent and acting chairman of the Independent Party. Following the caucus, a document con?rming the nominations and endorsements of the statewide Independent Party candidates for the 2010 election was ?led with the SOTS. The document was signed by Telesca as presiding of?cer of the caucus, and LaFrance and Fand as I agents of the Independent Party. See Defendants? Exhibit MM. At the time, Fand and LaFrance constituted two-thirds of the The SOTS subsequently approved a revised list of nominees on September 8, 2010. See Defendants? Exhibit PP. All of the candidates were 19 nominated pursuant to the 2010 bylaws. The new statewide Independent Party subsequently published a political advertisement showing its endorsed candidates for the 2010 election. See Defendants? Exhibit Based on the evidence presented at trial, in the 2010 election cycle, there was no con?ict between the Waterbury and Danbury factions of the Independent Party. That year, all but one of the Independent Party statewide candidates received over 1 percent of vote, giving the statewide Independent Party ballot access for those races by nomination and endorsement in the next 1 election for those of?ces, pursuant to the 2010 bylaws, without the need to petition. There was no evidence of con?ict between the Waterbury and Danbury factions in the 2008, 2009, 2010, or 2011 election cycles. The 2006 bylaws were not used by the Independent Party to nominate anyone for president in 2008 or for statewide of?ce in 2008, 2010, 2012, or 2014. The Danbury faction did not object to the caucuses held pursuant to the 2010 bylaws to nominate candidates for statewide of?ce in either 2010 or 2012. On June 10, 2012, the Independent Party held a caucus to elect the of?cers of the statewide party. At that caucus, Telesca was elected chairman, Frank was elected vice chairman, DePillo was elected treasurer, Bruce Walczak was elected secretary and Richard Sieron was elected parliamentarian. In early 2012, Fand invited Telesca to a meeting with Danbury mayor Mark Boughton in an effort to gain Telesca?s support for Boughton as the endorsed candidate of the Independent Party. Boughton h0ped to run for governor as the next nominee of the Republican Party. Telesca refused to give Fand his assurance, as chairman of the Independent Party, that he would endorse Boughton for governor and informed Fand that the Independent Party?s endorsement of 20 candidates was up to the party membership, not him. After that meeting, Telesca and Fand?s relationship ?soured.? Because Nader received more than 1 percent of the vote in 2008 presidential election, the Independent Party was able to nominate and endorse a candidate for the 2012 presidential election without having to go through the petitioning process. On August 21, 2012, the Independent Party held a caucus, conducted pursuant to the 2010 bylaws, to nominate and endorse a presidential candidate for 2012. The votes were limited to Independent Party members. At the caucus, Rocky Anderson was selected as the presidential nominee of the Independent Party. Although the 2006 bylaws reserved the right of the Danbury faction to make the Independent Party?s nomination for president, the nomination for president was decided at the August 21, 2012 caucus based on the 2010 bylaws without objection. Because Anderson failed to garner at least 1 percent of the vote for president, the Independent Party lost its presidential ballot line for the 2016 presidential election. In 2014, the Independent Party held a statewide caucus and nominated candidates pursuant to the 2010 bylaws. No one objected to the use of the 2010 rules for Independent Party nominations in the 2014 statewide elections. In 2015, local Independent Party chapteIrs nominated candidates for municipal elections. In 2016, the Danbury faction and the Iill/aterbury faction nominated different candidates for the Independent Party?s State Senate endorsement for one particular race. On August 23, 2016, the Danbury faction held an endorsement event at which nominations for president, vice president, United States Senate, United States House of Representatives, State Senate and State Representatives were made and thereafter ?led with the 21 SOTS.8 Notice of the meeting was given pursuant to General Statutes 9-452a. See Pl. Ex. 3. Telesca attended that endorsement meeting and voted no without comment when the nominees were presented for a vote. Telesca did not challenge how Duff, the presiding of?cer, conducted the meeting. Nor did Telesca challenge anyone?s right to vote at the meeting. Telesca ?led a complaint with the State Elections Enforcement Commission against the current members of the IPCT-SC, Duff, LaFrance, Palanzo and others. The IP-CT also selected nominees at an event noticed for that purpose which were also ?led with the SOTS. Where there were competing nominations, the SOTS did not accept either nomination for placement on the ballot. A major point of contention between the two factions is that the Waterbury faction believes that the I Danbury faction is merely a proxy for the Republican Party and not truly representative of the Independent Party. In 2014, there were over 17,000 Independent Party members statewide, compared to ten years earlier when there were only 450. See Defendants? Exhibit Following Fand?s death in 2013, Palanzo replaced him as a member of the Palanzo was a registered Republican at the time. He was appointed by Dietter and LaFranoe. Prior to becoming a member of the Palanzo had never been registered to vote as a member of the Independent Party. As previously found, there is no provision in the 21006 bylaws 1 8 Although the plaintiff refers to an exhibit documenting this ?ling as Plaintiff 3 Exhibit 3, that exhibit 13 the notice of the meeting published 1n the Hartford Couram? on August 15, 2016. See Plaintiff?s Posttrial Memorandum of Law, 2/2/2018, p. 3. The notice indicates that the purpose of the meeting was ?to endorse candidates for President of the United States, US Senate, US House of Representatives, CT State Representatives, and CT State Senate.? Although the plaintiff references a ?Certi?cation of Party Endorsement? filed with the SOTS as required by General Statutes 9-452, in its posttrial memorandum, no such document is in evidence. 22 which addresses how replacement members are to be selected. Palanzo was elected to serve on the Danbury Republican Town Committee in Danbury for at least two terms until 2015. At the time of his appointment to the IPCT-SC, he was the communications director for Danbury Republican Mayor Boughton. Palanzo is also currently the deputy treasurer for Boughton?s gubernatorial campaign. In 2016, the IPCT-SC endorsed more than seventy candidates for the Connecticut General Assembly. All of them were cross-endorsed Republican candidates. In 2014, ?most? of the candidates endorsed by the IPCT-SC were also cross-endorsed Republican candidates. Although the IPCT-CT ?led a notice for a caucus in 2016 ?to endorse candidates for President of the United States, US Senate, US House of Representatives . . . there is no evidence that they held any other caucuses for those of?ces in any other year. See Plaintiff 3 Exhibit 3. In the 2017 municipal elections, the IPCT-SC cross-endorsed one Democrat, and the rest of the candidates it endorsed, approximately 115-120 individuals, were Republicans. Neither Palanzo nor Duff, the current chair of the IPCT-SC, could estimate the number of Independent Party members there are in Connecticut. The court ?nds that by their actions and/0r inaction, the plaintiffs have waived any right they may have had to challenge the validity of the 2010 bylaws because they actively participated, without objection, in the process which created and adopted those bylaws and used the 2010 bylaws to nominate and endorse candidates for statewide and municipal of?ces in 2010, 2011, 2012 and 2014. They also failed to object to the 2010 bylaws as the statewide iaarty rules until con?icts began to arise between the Danbury and Waterbury factions over the nominations 23 of candidates for of?ce. See Defendants? Exhibits U, MM, NN and PP. The only evidence offered by the plaintiffs at trial was the testimony of Palanzo, Duff and Telesca and six exhibits, three of which are court decisions in other cases. The remaining exhibits are the plaintiff?s 2006 bylaws, a notice of a caucus/meeting held by the plaintiffs in August 2016 and the notice of the meeting published in The Hartford Courant. CONCLUSIONS OF LAW A. Preliminary Matters In the present action, the plaintiff seeks a declaratory judgment and injunctive relief. The defendants have raised several special defenses and a counterclaim which also seeks a declaratory judgment. As previously quoted herein, the plaintiffs seek a declaration from the court stating that the 2006 bylaws are the validly adopted and currently effective party rules of the IPCT- SC within the meaning of party rules pursuant to General Statutes 9-374 and that the individually named plaintiffs are the validly elected board members of the party. Notably, the plaintiffs do not speci?cally request a corollary declaration that the 2010 bylaws are invalid. The plaintiffs also seek an injunction prohibiting the defendants ?from purporting to act? for or make ?lings on behalf of the SC. On the other hand, the individual defendants seek Ila declaratory judgment that the 2010 bylaws are the rightful bylaws of the statewide Incilependent Party within the meaning of party rules pursuant to General Statutes 9-3 74, that they are the rightful of?cers of the Independent Party and that the individual plaintiffs are not. They also ask the court to declare that the 2006 bylaws apply only to the Danbury faction?s local committee of 24 I i I the Independent Party. The defendants also seek an order from the court to the SOTS to accept only the nominations and endorsements of the Independent Party made pursuant to the 2010 bylaws. Although the defendants have raised several special defenses, only the third special defense raising rati?cation of the 2010 bylaws and waiver by the defendants is herein considered by the court as the others have not been briefed or argued, and therefore, are deemed abandoned.9 At the conclusion of the evidence, in setting a brie?ng schedule, the court ordered the parties to submit proposed ?ndings of fact with citations to the evidentiary record and proposed conclusions of law. Contrary to this speci?c direction of the court, the plaintiffs failed to do so. To the extent that the plaintiffs did cite to the record, many of the references are unclear at best. For example, transcript references do not contain dates and confusing references are made in footnotes. The defendants argue that because the plaintiffs did not cite to the transcript or otherwise to the trial record that the plaintiffs have failed to sustain their burden of prbof. Although the plaintiffs have failed to assist the court in this regard, the court declines'to reject the plaintiffs? claim on this basis and does reach a decision based on the admissible evidence, that is, the testimony, full exhibits and agreed upon facts and legal arguments, such as they are. 9 ?It is well settled that [w]e are not required to review issues that have been iinproperly presented to this court through an inadequate brief. . . . Analysis, rather than mere abstract assertion, is required in order to avoid abandoning an issue by failure to brief the issule properly. . . . Where a claim is asserted in the statement of issues but thereafter receives only cuisory attention in the brief without substantive discussion or citation of authorities, it is deemed to be abandoned. . . . These same principles apply to claims raised in the trial court.? (Emphasis in original; internal quotation marks omitted.) Walker v. Commissioner of Correction, 176 Conn. App. 843, 856, 171 A.3d 525 (2017). 25 However, for the reasons pointed out in the defendants? memoranda, the court recognizes that several statements made by the plaintiffs in their oral and written arguments to the court are not based on evidence contained in the record. For example, certain statements made about Fand?s role as the ?founder? of the Independent Party in Connecticut, the 1987 rules and their relationship to the 2006 bylaws, and the fact that the plaintiffs did not ?le endorsements for the 2012 and 2014 statewide candidates and their reason for not doing so are not contained within the record.10 B. Declaratory Judgment ?The purpose of a declaratory judgment action, as authorized by General Statutes 52?29 and Practice Book [17?55], is to secure an adjudication of rights [when] there is a substantial question in dispute or a substantial uncertainty of legal relations between the parties. . . . Subdivisions and (2) of Practice Book 17?55 respectively require that the plaintiff in a declaratory judgment action have an interest, legal or equitable, by reason of danger of loss or of uncertainty as to the party?s rights or other jural relations and that there be an actual bona ?de and substantial question or issue in dispute or substantial uncertainty of legal relations which requires settlement between the parties . . . . This court previously has observed that our ?0 In addition, in their reply memorandum, the plaintiffs make the following curious statement about the evidence: ?Defendants? post-trial brief further demonstrates that Defendants have failed to carry their burden [presumably on their counterclaim or special defense], relies almost entirely on witness testimony which cannot be corroborated by evidence, and effectively asks this court to set aside a plethora of case law unfavorable to their position.? (Emphasis added.) Plaintiff Reply Memorandum, p. 2. Certainly testimony is a critical part of the evidence in any trial. Plaintiffs? counsel either misunderstands the role of testimony or has made an inadvertent misstatement on this point. 26 declaratory judgment statute provides a valuable tool by which litigants may resolve uncertainty of legal obligations.? (Citation omitted; internal quotation marks omitted.) New London County _Mutual Ins. Co. v. Nantes, 303 Conn. 737, 747?48, 36 A.3d 224, 232 (2012). ?We also have recognized that our declaratory judgment statute is unusually liberal. An action for declaratory judgment . . . is a statutory action as broad as it well could be made. . . . Indeed, our declaratory judgment statute is broader in scope than . . . the statutes in most, if not . all, other jurisdictions . . . and [w]e have consistently construed our statute and the rules under it in a liberal spirit, in the belief that they serve a sound social purpose. . . . [Although] the declaratory judgment procedure may not be utilized merely to secure advice employed in a justiciable controversy where the interests are adverse, where there is an actual bona ?de and substantial question or issue in dispute or substantial uncertainty of legal relations which requires settlement, and where all persons having an interest in the subject matter of the complaint are parties to the action or have reasonable notice thereof.? (Citations omitted; internal quotation marks omitted.) Id., 748. ?In an action seeking a declaratory judgment, the sole function of the trial court is to ascertain the rights of the parties under existing law. . . . While we have characterized the proceeding as a special statutory action and therefore distinct from one seeking the in?iposition of equitable relief . . . the trial court may, in determining the rights of the parties, properiy consider equitable principles in rendering its judgment. . . . This conclusion not only harmonizes the rule that actions in law and equity may be combined in this state . . . it is also in accord with our position favoring liberal construction of the declaratory judgment statute in order to effectuate its 27 sound social purpose.? (Citations omitted; internal quotation marks omitted.) Middlebury v. Steinmann, 189 Conn. 710, 715?16, 458 A.2d 393 (1983). ?[T]he determination of what equity requires in a particular case, the balancing of the equities, is a matter for the discretion of the trial court. . . . Discretion means a legal discretion, to be exercised in conformity with the spirit of the law and in a manner to subserve and not to impede or defeat the ends of substantial justice. . . . For that reason, equitable remedies are not bound by formula but are molded to the needs of justice.? (Citations omitted; internal quotation marks omitted.) McKeever v. iore, 78 Conn. App. 783, 788, 829 A.2d 846 (2003). ?The equitable powers of the court are broad, but they are not without limit. Equitable power must be exercised equitably.? (Internal quotation marks omitted.) 1d,, 793. ?The governing motive of equity in the administration of its remedial system is to grant full relief, and to adjust in the one suit the rights and duties of all the parties, which really grow out of or are connected with the subj ect?matter of that suit . . . Equity regards as done what ought to be done . . . or which ought to have been done. . . . Equity always looks to the substance of a transaction and not to mere form . . . and seeks to prevent injustice. . . . The principles of equity evolved as a necessity in order to obtain justice because the law by reason of its universality was deficient. Equity in its true and genuine meaning is the soul and Spirit of all law, and positive law is construed by it and rational law is made by it. In this, equity is i synonymous with justice. Equity depends essentially upon the articular circumstances of each individual case. That being so, there can be no established rules and ?xed principles laid down for its application, without destroying its very existence, and reducing it to positive law. The nature of equity is to amplify, enlarge, and add to the letter of the law and every particular case 28 stands upon its own circumstances.? (Citations omitted; emphasis in original; internal quotation marks omitted.) Natural Harmony, Inc. V. Normand, 211 Conn. 145, 149-50, 558 A.2d 231 (1989). 1. Statutory Interpretation Concerning a Minor Party The determination of which party is entitled to the declaratory judgment it seeks depends in large part on issues of statutory interpretation, speci?cally General Statutes 9-374 and related provisions. ?When construing'a statute, [the court?s] ?lndamental objective is to ascertain and give effect to the apparent intent of the legislature. . . . In other words, [the court] seek[s] to determine, in a reasoned manner, the meaning of the statutory language as applied to the facts of [the] case, including the question of whether the language actually does apply. . . . In seeking to determine that meaning, General Statutes 1?22 directs [the court] first to consider the text of the statute itself and its relationship to other statutes. If, after examining such text and considering such relationship, the meaning of such text is plain and unambiguous and does not yield absurd or unworkable results, extratextual evidence of the meaning of the statute shall not be considered. . . . The test to determine ambiguity is whether the statute, when read in context, is susceptible to more than one reasonable interpretation.? (Citation omitted; internal quotation marks omitted.) Price v. Independent Party of CT-State Central, supra, 323 Conn. 5:39-40. ?Signi?cantly, our case law is clear that ambiguity exists only if the statutory language at issue is susceptible to more than one plausible interpretation.? (Internal quotation marks omitted.) Tomick v. United Parcel Service, Inc., 324 Conn. 470, 478, 153 A.3d 615 (2016). ?When a statute is not plain and unambiguous, we also look for interpretive guidance to the legislative 29 history and circumstances surrounding its enactment, to the legislative policy it was designed to implement, and to its relationship to existing legislation and common law principles governing the same general subject matter . . . . The question of statutory interpretation presented in this case is a question of law . . . (Internal quotation marks omitted.) Valliere V. Commissioner of Social Services, 328 Conn. 294, 309, 178 A.3d 346 (2018). The central issue in this case, that is, which bylaws are the rightful bylaws governing the Independent Party as it is presently constituted, requires the court to ?rst interpret 9-3 74. The parties offer differing interpretations of 9-374. The plaintiffs argue that they are entitled to a declaratory judgment because Fand was the de facto founder of the Independent Party of Connecticut, and that the bylaws he ?led in 1987 and later amended in 2006 are the governing bylaws of the party pursuant to General Statutes 9?374. As previously stated herein in part (A) of this memorandum, the plaintiffs did not introduce the 1987 bylaws into evidence, nor did they introduce any evidence concerning the founding of the Independent Party by Fand. The plaintiffs further contend that the Superior Court already found in Independent Party of CT v. Dietter, supra, Superior Court, Docket No. that the 2006 bylaws are the validly adopted bylaws of the Independent Party and that they remain in ?ll] force and effect. In response, the defendants counter that the 2006 bylaws are not controlling because they were adopted before the statewide Independent Party came into existence, and that, pursuant to 9-3 74, the Independent Party could not adopt bylaws applicable to a statewide party until after it achieved status as a statewide minor party by garnering 1 percent of the vote in the 2008 30 presidential election. The defendants also contend that the Superior Court?s decision in Independent Party of v. Dietrer has no effect on the present action before the court because the ruling denying their preliminary motion in that case was not a decision on the merits of their underlying claim. Finally, the defendants argue that the plaintiffs have acquiesced to the applicability of the 2010 bylaws by allowing them without objection to be adopted, ?led, and then applied in numerous statewide elections. The present case demonstrates that the statutory scheme governing minor parties is skeletal in Connecticut. In contrast to major parties, which are governed by a comprehensive statutory scheme, minor parties in Connecticut are essentially governed by four statutes: General Statutes 9-3 74, 9-451, 9-452, and 9? 452a. In addition, General Statutes 9-453u regulates applications to the SOTS to reserve a party designation concerning the petitioning process for candidates to gain ballot access. Section 9-3 74, which governs the requirement of ?ling party rules with the SOTS is central to the dispute between the parties. Section 9-374 provides, in relevant part, that the case of a minor party, no authority of the state or any subdivision thereof having jurisdiction over the conduct of any election shall permit the name of a candidate of such party for any of?ce to be printed on the of?cial ballot unless at least one COpy of the party rules regulating the manner of nominating a candidate for such of?ce has been ?led in the of?ce of the Secretary of :the State at least sixty days before the nomination of such candidate. . . . Party rules shall not be effective until sixty days after the ?ling of the same with the Secretary of the State. . . Pursuant to 9- 31 372 (6), a ?minor party? is ?a political party or organization which is not a major party and whose candidate for the of?ce in question received at the last-preceding regular election for such of?ce, under the designation of that political party or organization, at least one percent of the whole number of votes cast for all candidates for such of?ce at such election.? When read together, the plain language of the foregoing statutes indicates that a minor party does not exist in Connecticut until it designates a candidate for of?ce who achieves 1 percent of the vote. Further, once a minor party is established for a particular of?ce, to secure a place on the ballot for a future candidate for that of?ce by nomination, the minor party must ?le a copy of the party rules regulating the nomination process for that of?ce with the SOTS sixty days before the nomination is made. No bylaws need be ?led with the SOTS pursuant to 9-374 until status as a minor party is achieved by a candidate receiving at least 1 percent of the vote for the of?ce for which future ballot access is sought by way of nomination. In other words, a party does not need to ?le bylaws until it of?cially achieves minor party status. Before that happens, party rules governing the nomination process are not required because ballot access comes from the petitioning process and not from the party. Beyond the foregoing requirement concerning the ?ling of party rules, 9-3 74 states no other requirements for a minor party other than that the party rules do not become effective until sixty days after they are ?led with the SOTS and that any amendments to the party rules must also be ?led with the SOTS in the same manher. In the i case of a mlnor party, there IS no requlrement concermng who is el1g1ble to ?le such rules. In the present case, the defendants argue that minor party is created by past '32 performance, not future intent.? Def. Reply Mem., p. 9. The court agrees with this statement. Prior to 2008, there was no need for the Independent Party to ?le party rules concerning the nominating process for candidates for statewide of?ce because until that year no statewide candidate had achieved 1 percent of the vote for any elected of?ce. According to 9-3 72 (6), a minor party is a political party whose candidate for a particular o?ice received 1 percent of the vote in the ?last-preceding? regular election for that of?ce under the designation of that political party. In 2008, the so-designated ?Independent Party?gained ballot access for president, vice president and other statewide of?ces by the petitioning process and Ralph Nader, the candidate for president, received 1 percent of the vote. In order to select a candidate for president in the 2012 presidential election by way of nomination and endorsement, Independent Party rules governing the nominating process had to be ?led with the SOTS sixty days before the nomination was made. When the IPCT-SC ?led the 2006 bylaws on March 27, 2006, the party so-named had not achieved minor party status for any statewide of?ce. In the present case, the defendants adopted and properly ?led the 2010 bylaws on March 22, 2010, thus establishing those bylaws as the controlling party rules for the statewide Independent Party, after the passage of sixty days in accordance with 9?3 74. To create the 2010 bylaws, the defendants invited Independent Party members and local parties from across the state to participate in the process. The faci that the 2010 bylaws were adopted and properly ?led pursuant to 9-3 74 is one of several reasons which necessitates the conclusion that they are valid and are the governing provisions of the statewide 33 Independent Party. On the other hand, the 2006 bylaws were created by a limited process and were ?led before the Independent Party achieved statewide status as a minor party. This was virtually no evidence beyond the information contained in Plaintiffs Exhibit labout the process employed by the three original members of the There is also little evidence that the IPCT-SC is anything more than a local committee of the Independent Party. The only thing that distinguishes it from other local independent parties formed before 2008 is that the 2006 bylaws purported to reach beyond Danbury to control the nominations and endorsements of candidates who were not local to Danbury. As previously noted in the findings of fact, there is no evidence that any other local party adhered to the 2006 bylaws or that the actually sought to impose the will of its three member state central committee beyond its boundaries. Although the IPCT-SC may have won the race to the SOTS of?ce and referred to themselves by a name which included the designation ?State Central,? that is not enough to anoint them as the governing body of the Independent Party post-2008. As the plaintiffs themselves point out, ?[u]nlike the major parties which have State Central Committees acting as agents of National Committees, minor party nominations in Connecticut are governed exclusively by four statutes: C.G.S. 9?3 74, 9-451, 9-452, and 9- 452a.? Thus the designation ?State Central? has no real signi?cance inlthe organization or operation of a minor party. It is simply a name chosen by the carries with it no special status. For reasons previously stated in the findings of fact, there is no indication that has statewide reach although they continue to claim that they are the true governing entity of the statewide Independent Party. The court ?nds, however, that the 2006 34 bylaws are valid only to the extent they are recognized as such within the local committee.11 Although the plaintiffs ?led the 2006 bylaws with the SOTS, the ?ling of these rules merely allowed the IPCT-SC to nominate local candidates and get them on an of?cial ballot once they had attained 1 percent of the vote for a particular of?ce. The 2006 bylaws did not automatically allow the IPCT-SC to gain control of the statewide Independent Party after the 2008 presidential election. A close reading of General Statutes 9-453u gives ?irther credence to the idea that the IPCT-SC was nothing more than a local committee as opposed to a statewide minor party at the time it adopted the 2006 bylaws. Section 9-453u describes the steps that a petitioning party must take to reserve its party designation with the SOTS. Section 9-453u provides, in relevant part, that ?[t]he statement shall include the party designation to be reserved which . . . (3) shall not incorporate the name of any minor party which is entitled to nominate candidates for any of?ce which will appear on the same ballot with any of?ce included in the statement; (4) shall not be the same as any party designation for which a reservation with the secretary is currently in effect for any of?ce included in the statement . . . Pursuant to this statute, had the IPCT-SC been an of?cially recognized minor party with viable statewide candidates, the statewide Independent Party would not have been able to reserve the word ?Independent? in its 1 11Section 9?3 74 explicitly allows a minor party to have both state party rules eind local rules for particular municipalities. Section 9-3 74 provides, in relevant part, that party in any municipality for which local rules with respect to any of?ce or position have not been ?led as provided in this section shall, as to such of?ce or position, be subject to the provisions of the effective state rules of such party applicable in municipalities which do not have local party rules ,3 35 party designation when Fand and Telesca joined together to ?le the ED-601 party designation form with the SOTS in 2008. See Defendants? Exhibit U. There was no evidence introduced at trial that the IPCT-SC ever sought to reserve a party name containing the designation ?Independent? for candidates for statewide of?ce in 2008, 2010, or any other year. Accordingly, for all the foregoing reasons, the only statewide Independent Party was created post-2008 and the 2010 bylaws are the only valid governing rules of that party. 2. Waiver In further support of the defendants? claim that they are the rightful of?cers of the Independent Party and that the 2010 bylaws are the only valid governing rules of that party, the defendants argue by way of a special defense that the plaintiffs waived any right they may have had to have their bylaws control the Independent Party by their tacit acceptance of the defendants? use of the 2010 bylaws for numerous elections as well as other reasons. ?Waiver is the intentional relinquishment or abandonment of a known right or privilege.? (Internal quotation marks omitted.) C. R. Klewin Northeast, LLC v. Bridgeport, 282 Conn. 54, 87, 919 A.2d 1002 (2007). ?Waiver involves an intentional relinquishment of a known right. . . . There cannot be a ?nding of waiver unless the party has both knowledge of the existence of the right and intention to relinquish it. . . (Internal quotation marks omitted.) J. Wm. Foley,?1nc. v. United Illuminating Ca, 158 Conn. App. 27, 43, 118 A.3d 573 (2015). ?[V]arious statutory and contract rights may be waived. . . . Waiver is based upon a species of the principle of estoppel and where applicable it will be enforced as the estoppel would be enforced. . . . Estoppel has its 36 roots in equity and stems from the voluntary conduct of a party whereby he is absolutely precluded, both at law and in equity, from asserting rights which might perhaps have otherwise existed . . . . Waiver does not have to be express, but may consist of acts or conduct from which waiver may be implied. . . . In other words, waiver may be inferred from the circumstances if it is reasonable to do so.? (Citation omitted; internal quotation marks omitted.) C. R. Klewz'n Northeast, LLC v. Bridgeport, supra, 282 Conn. 87. ?Whether conduct constitutes a waiver is a question of fact. . . . The issue of waiver is a question of fact, dependent on all of the surrounding circumstances and the testimony of the parties.? (Internal quotation marks omitted.) J. Wm. Foley, Inc. v. United Illuminating Co., supra, 158 Conn. App. 43. As noted in various ?ndings of fact in Part II of this memorandum, there are numerous indicators that the plaintiffs have waived their right to contest the validity of the 2010 bylaws. Most signi?cantly, Fand and Telesca actively worked together starting in 2008 to create a statewide Independent Party in 2008 by petitioning to get Nader ballot access for the of?ce of president of the United States.12 Both Fand and Telesca ?led a joint ED-601 party designation form on behalf of the Independent Party on May 5, 2008. See Defendants? Exhibit U. Telesca and Mertens then began drafting bylaws for the new statewide party in an effort to comply with 9-3 74. They sent the bylaws they drafted to local Independent Party town committee chairs, and arranged for a statewide party meeting/caucus to vote on the proposed bylaws. Telesca and addition to indicating that the plaintiffs waived their right to contest the validity of the 2010 bylaws, the collaboration between and and Telesca provides further eviderlce that the IPCT-SC was a local committee rather than a statewide party when Fand and Telesca? realized that they that they needed to work together to create a statewide party. 37 Iorio met personally with Fand to discuss the proposed bylaws; Fand did not object to the planned meeting, nor did he object to the idea of creating new bylaws for the statewide party or to the bylaws themselves. After the bylaws were unanimously adopted at the March 20, 2010 party meeting and later ?led with the SOTS, neither Fand nor any other member of the Danbury faction objected to them. Moreover, when the Independent Party held a caucus on August 21, 2010 to endorse candidates for various of?ces pursuant to the 2010 bylaws, Fand and other members of the Danbury faction attended the meeting and did not question or object to their use. In addition, both Fand and LaFrance, two-thirds of the signed the endorsement form ?led with the Waterbury town clerk and the SOTS along with Telesca, which speci?ed the candidates that the Independent Party had endorsed for the 2010 elections at the August 21 meeting. See Defendants? Exhibit MM. Fand and others in the Danbury faction also used the 2010 bylaws to govern nominations/endorsements for the 2010, 2012 and 2014 election cycles without any objection. Fand and Telesca did not call the legitimacy of the 2010 bylaws into question until sometime in 2012 when they ?rst disagreed about the nomination of Mark Boughton, the Republican mayor of Danbury, who was hoping for the endorsement of the Independent Party in connection with his gubernatorial ambitions in 2012. These facts and pieces of evidence, taken together, indicate that there is nothing in the law that prevented Telesca from ?ling the 2010 bylaws with the SOTS, and that the plaintiffs? knowledge about the drafting and adoption of such bylaws and their failure to object demonstrate their de facto acceptance of them. Therefore, based on all foregoing circumstances, the court concludes that the defendants have established by 38 a preponderance of the evidence submitted in this case that the plaintiffs have waived any right they may have had to challenge the validity of the 2010 bylaws. 3. The Plaintiffs? Additional Arguments The plaintiffs make several additional arguments as to why they are entitled to a declaratory judgment that their bylaws are controlling, none of which are availing. First, the plaintiffs argue that the 2010 bylaws are not valid because Telesca was not the party chairman or the secretary of the state central committee when he ?led them. However, contrary to the plaintiffs? argument, 9-3 74 does not contain any language mandating that minor party rules may only be ?led by such individuals. Section 9-3 74 provides, in relevant part, that the case of a minor party, no authority of the state or any subdivision thereof having jurisdiction over the conduct of any election shall permit the name of a candidate of such party for any of?ce to be printed on the of?cial ballot unless at least one copy of the party rules regulating the manner of nominating a candidate for such of?ce has been ?led in the of?ce of the Secretary of the State at least sixty days before the nomination of such candidate. . . The plain language of the statute, therefore, does not require minor party rules to be ?led by the party chairman or the secretary of the state central committee. Moreover, the other statutes governing minor parties make no mention of a state central committee or of a secretary of such committee. As previously discussed, the statutes that de?ne and discuss the role of state central committees apply only to a major party and not to a minor party. Even though members of the Danbury faction designated themselves as ?State Central,? this designation is simply a name and has no legal signi?cance 39 under state law. Telesca?s status as a designated agent, along with and, was thus suf?cient to afford Telesca the authority to act on behalf of the statewide party to form the committee that proposed and eventually passed the 2010 bylaws. Second, the plaintiffs argue that the Superior Court has already found that the 2006 bylaws were the validly adopted Independent Party rules in Independent Party of CT v. Dietter, and that as such, they remain in full force and effect. In Independent Party of v. Dietter, however, the merits of the 2006 bylaws versus the 2010 bylaws as to their statewide effect was not the issue before the court. The competing candidates in that case were not candidates for statewide of?ce. Moreover, the only matter addressed by the court (Taylor, .I), was a motion for a temporary order of mandamus and the case was thereafter withdrawn. Finally, at a hearing held on August 3, 2018, when confronted with the fact that the plaintiffs joined the defendants in employing the 2010 bylaws for the 2010, 2011, and 2012 elections, the plaintiffs argued that, assuming the defendants are correct that the 2010 bylaws became the bylaws of the party in 2010, those bylaws ?only entitle[d] . . . [the defendants] to ?le bylaws for that of?ce, not for the entire slate statewide.? T. 8/3/18, 63:3-14. While there is no doubt that candidates seeking to be nominated by the Independent Party would have to petition to get onto the ballot if the candidate for a particular of?ce did not achieve 1 percent of the vote in the next-preceding election, it makes little sense that new bylaws would necessarily have to be ?led each time 1 percent of the vote is garnered for a given of?ce. Contrary to argument of the plaintiff, although minor party status is achieved of?ce by 40 of?ce, a statewide party was created in 2008 according to the SOTS. The bylaws passed and ?led with the SOTS in 2010 govern the party, not each of?ce sought or any single election. Filing the bylaws afforded the Independent Party the ability to nominate candidates to occupy the Independent Party line on a ballot. According to Defs. Ex. Z, the SOTS Information Bulletin Issue 51 October 2, 2009, ?[T]he Independent Party became an of?cially recognized minor party in each town because they ran Ralph Nader for President in 2008 and he received at least 1% of the votes cast for the of?ce of President.? Once this information was put into the SOTS computer system, ?it automatically moved any voter who may have been enrolled in the Independent Party when they were not of?cially recognized as a minor party from Unaf?liated/Independent Party to straight Independent Party members.? In 2010, although candidates for state executive of?ces had to petition to get on the ballot, if they achieved 1 percent of the vote, they thereafter could only be nominated for the of?ce in question by the Independent Party in accordance with party rules ?regulating the manner of nominating a candidate for such of?ce . . . at least sixty days before the nomination of such candidate? before the name of the candidate could be printed on the of?cial ballot. See General Statutes 9?3 74. The recognition, therefore, of the Independent Party as a statewide party by the SOTS after achieving 1 percent of the vote in 2008 and meeting the requirement of ?ling party rules sixty days before a nomination is made to secure a place on the of?cial ballot by a candidate of the Independent Party for of?ce are two separate things. Moreover, nothing in 9- 374 or any other statute concerning minor parties states that bylaws must be repeatedly ?led every time a minor party candidate achieves 1 percent of the vote for any of?ce, unless those 41 bylaws are amended. In the absence of such statutes or evidence, the court rejects the plaintiffs? assertion on this issue.13 C. Injunctive Relief In their prayer for relief, the plaintiffs seek the following by way of an injunction: ?An immediate injunction restraining and prohibiting Defendants Telesca and Frank, jointly and severally, from directly and/or indirectly: a. Purporting to act on behalf of Plaintiff Independent Party of CT - State Central; b. Making ?lings on behalf of Plaintiff Independent Party of CT State Central with the State of Connecticut and/or any agency and/or political subdivision thereof; 0. Representing to any person or entity in any form of communication or technology that they are officers of the Plaintiff Independent Party of CT - State Central; d. Taking any action which serves to contradict or is otherwise inconsistent with the lawful incumbency of the individual Plaintiffs in their respective capacities with the Plaintiff Independent Party of CT - State Central. party seeking [permanent] injunctive relief has the burden of alleging and proving irreparable harm and a lack of an adequate remedy at law. . . . The extraordinary nature of injunctive relief requires that the harm complained of is occurring or will occur if therinjunction is not granted. Although an absolute certainty is not required, it must appear that there is a ?3 The plaintiffs also complain that the 2010 bylaws follow major party requirements while minor party rules are minimal with far fewer requirements. It matters not that the 2010 bylaws are modeled after the major political parties as along as those rules comport with the statutes governing minor parties. 42 substantial probability that but for the issuance of the injunction, the party seeking it will suffer irreparable harm. . . . Additionally, decision to grant or deny an injunction must be compatible with the equities in the case, which should take into account the gravity and willfulness of the violation, as well as the potential harm to the defendant.? (Citation omitted; emphasis omitted; internal quotation marks omitted.) Steroco, Inc. V. Szymanski, 166 Conn. App. 75, 87-88, 140 A.3d 1014 (2016). Even if the plaintiffs were able to establish they were entitled to the declaratory relief they seek, they have failed to demonstrate a basis for the injunctive relief requested in their prayer for relief in that they have not demonstrated a substantial probability of irreparable harm, that the balance of equities tips in their favor, or that they do not have an adequate remedy at law. Although the 2010 bylaws use the terminology ?Independent Party State Central Committee? to establish a statewide governing organization of the Independent Party, the weight of the evidence establishes that the passage of the bylaws on March 20, 2010 and the meeting/caucus held on August 21, 2010, were actually the result of the combined efforts of local parties throughout the state, including Danbury. Since 2010, the evidence demonstrates that Telesca and Frank have sought to solidify the name ?Independent Party? or ?Independent Party of Connecticut? as the established name of the statewide party going forward. Fand and LaFrance were part of that effort. See Defendants? Exhibit MM. At argument, the plaintiffs claimed continuing irreparable harm caused by con?icting ?lings with the SOTS but conceded that the defendants are equally subject to the same harm. 43 Essentially, the claimed harm is harm suffered by the parties so much as it is harm to the Independent Party itself. Further, for reasons detailed in part (B) of this memorandum of decision, the balance of equities is decidedly not the plaintiffs favor for the principal reason that they waived their right to complain about the formation of a statewide party organization, the statewide 2010 bylaws and the leadership of Telesca and Frank throughout the process. In sum, to the extent that there was evidence presented by the plaintiffs in support of the relief they seek, it was deficient. For similar reasons, to the extent that the plaintiffs seek an injunction prohibiting the defendants from taking action which serves to contradict or is otherwise inconsistent with the lawful incumbency of the individual plaintiffs ?in their respective capacities with the plaintiff ?Independent Party of CT - State Central,?? that relief is also denied, in that those individuals have not demonstrated that they have any incumbency within the statewide minor party now known as the Independent Party or the Independent Party of Connecticut. The inj unctive relief sought in the latter request lacks clarity, but if what the individual plaintiffs seek is an order prohibiting Telesca and Frank from acting as of?cers of the statewide Independent Party, for all the reasons previously stated, the plaintiffs are not entitled to any such relief. The individual plaintiffs have an adequate remedy at law in that there is nothing to prevent them from seeking leadership positions within the statewide party. They are not entitled to achieve leadership by court order when they may well accomplish it by engaging in activities that are within the control 44 of each one of them. For this reason as well, any harm to them is not irreparable.14 IV. COUNTERCLAIM The defendants have established by a preponderance of the evidence that they are entitled to the declaratory relief that they seek as more speci?cally set forth in the conclusion of this memorandum of decision. V. CONCLUSION Accordingly, for all the foregoing reasons, the court ?nds that the plaintiffs have failed to establish by a preponderance of the evidence that they are entitled to the declaratory and injunctive relief requested in their second amended complaint. They failed either to claim by way of relief or to demonstrate by a preponderance of the evidence that the 2010 bylaws are invalid. Further, the court ?nds that the defendants, Telesca and Frank, have established by a preponderance of the evidence that the 2010 bylaws are the validly adopted and operative bylaws of the Independent Party/Independent Party of Connecticut, filed pursuant to the requirements of 9-3 74, and that Michael Telesca and Rocco Frank, Jr. are the duly elected officers tf the Independent Party/Independent Party of Connecticut, and the individual plaintiffs are: not. In ?4 The plaintiffs have not demonstrated irreparable harm for the further reason that, to the extent that the 2006 bylaws ?led by the plaintiffs are not inconsistent with the operation of the 2010 bylaws, which govern the statewide party, the plaintiffs may continue to govern and use them as rules local to Danbury. 45 addition, the court hereby declares that the 2006 bylaws apply only to the Danbury faction?s local committee of the Independent Party. Finally, the court hereby declares and orders that the SOTS must accept only the nominations and endorsements of the Independent Party/Independent Party of Connecticut, made pursuant to the 2010 bylaws ?led with the SOTS on March 22, 2016, or as may be amended, pursuant to General Statutes 9-374. BY THE PECK, Judge Trial Referee 46 CHECKLIST FOR CLERK DocketNumber . CaseName AZ CW 37? 212mg Memorandum of Decision dated File Sealed: yes no Memo Sealed: yes . no This memorandum of Decision may . eased to the Reporter of Judicial Decisions for publication. . . This Memorandum of DeCision may NOT be released to the Reporter of Judicial Decisions for publication. i Case Detail - HHD-CV16-6071180-S Page 1 of 5 superior Court-Case Look-up Civil/Family Housing Small Claims as HHD-CV16- 6071180-3 SECRETARY OF THE STATE Et Al Pr'refix: HD5 (Case Type: M00 Case Detail Notices lHistory lScheduled Court Dates Attorney/Firm Juris Number Leok- -up an Case Look- -up By _Party Name By Docket Number By Attorney/Firm Juris Number fo Pro'perty?Address . File Date: 09/1 312016 lEaServices Login, INDEPENDENT PARTY OF CT STATE CENTRAL Et Al v. DENISE MERRILL Return Date: 10/04/2016 Screen _Sectidn =I-Ielp To receive an email when there is activity on this case, click here. it; ?05 Information Updated as of: 08/20/2018 Calendar Look-up A . Case Information CaseType: M00- Misc- Injunction Court Location: HARTFORD JD COURT (CT) Trial List Claim: 04/18/2017 By Court Location By Attorney/Firm Juris Number Motion to Seal or Close Calendar Notices Couit Events Look?up 1 - Last Action Date: 08/03/2018 (The "last action date" is the date the information was entered in the system) By Date By Docket Number: . . . . ?By Attorney/FirmJuris Number . Information Disposition Date: Pending Foreclosure Sales 9" Disposition: Understanding Judge or Magistrate: Display of Case Infor 99"th Us i 'i Parts/f P-01 INDEPENDENT PARTY OF CT STATE CENTRAL Party 81 Appearance Information Attorney: MATTHEW JOSEPH GRIMES JR (435105) 11 ORCHARD STREET BROOKFIELD. CT 06804 File Date: 09/13/2016 Attorney: 81? BRYAN THOMAS CAFFERELLI (421878) 129 COLLEGE PLACE FAIRFIELD. CT 06824 File Date: 09/14/2016 Attorney: 5: DOMENICO CHIEFFALO (418161) DOM CHIEFFALO 36 MILL PLAIN RD-STE 305 DANBURY, CT 06811 File Date: 04/24/2017 P-02 JOHN DIETTER CHAIRMAN, INDEPENDENT PARTY OF CT STATE CENTRAL Attorney: MATTHEW JOSEPH GRIMES JR (435105) 11 ORCHARD STREET BROOKFIELD, CT 06804 File Date: 09/13/2016 Attorney: BRYAN THOMAS CAFFERELLI (421878) ,129 COLLEGE PLACE FAIRFIELD. CT 06824 File Date: 09/14/2016 Attorney: it? DOMENICO CHIEFFALO (418161) DOM CHIEFFALO 36 MILL PLAIN 305 DANBURY. CT 06811 File Date: 04/24/2017 P-03 DONNA LAFRANCE TREASURER, INDEPENDENT PARTY OF CT STATE CENTRAL Attorney: MATTHEW JOSEPH GRIMES JR (435105) 11 ORCHARD STREET BROOKFIELD. CT 06804 File Date: 09/13/2016 Attorney: BRYAN THOMAS CAFFERELLI (421878) 129 COLLEGE PLACE FAIRFIELD. CT 06824 File Date: 09/14/2016 Attorney: 8? DOMENICO CHIEFFALO (418161) DOM CHIEFFALO 36 MILL PLAIN RD-STE 305 DANBURY. CT 06811 File Date: 04/24/2017 P-04 ROGER PALANZO SECJDEP. TREAS., INDEPENDENT PARTY OF CT - STATE CENTRAL Attorney: MATTHEW JOSEPH GRIMES JR (435105) 11 ORCHARD STREET BROOKFIELD CT 06804 File Date: 09/13/2016 Attorney. BRYAN THOMAS CAFFERELLI (421878) 129 COLLEGE PLACE FAIRFIELD, CT 06824 File Date: 09/14/2016 Attorney: 8 DOMENICO CHIEFFALO (418161) DOM CHIEFFALO 36 MILL PLAIN 305 DANBURY. CT 06811 File Date: 04/24/2017 http://civilinquiry. jud.ct. gov/CaseD etail/PublicCaseD etai1.aspx?D 1 No i 1 Fee Categoryji Party? 1 Plaintiff Plaintiff Plaintiff Plaintiff 8/20/2018 Case Detail - Page 2 of 5 P-05 P-06 P-07 P-08 P-09 D-01 D-02 D.-03 D-04 DAN CARTER Plaintiff? Attorney: BENJAMIN PROTO JR (306192) File Date: 09/14/2016 Intervening 2885 MAIN STREET STRATFORD. CT 06614 GAYLE SLOSSBERG Plaintiff Attorney: HURWITZ SACARIN SLOSSBERG KNUFF LLC (026616) File Date: 09/16/2016 intervening 147 NORTH BROAD STREET - MILFORD. CT 06460 PAM STANESKI Plaintiff - Attorney: DEY SMITH STEELE LLC (412130) File Date: 09/16/2016 Intervening 9 DEPOT STREET MILFORD. CT 06460 RICH VERRONE Plaintiff- Attorney: DEY SMITH STEELE LLC (412130) File Date: 09/16/2016 ?Intervening 9 DEPOT STREET . CT 06460 PATRICIA LIEERO . Plaintiff Attorney: DEY SMITH STEELE LLC (412130) File Date: 09/16/2016 Intervening 9 DEPOT STREET MILFORD. CT 06460 DENISE MERRILL, SECRETARY OF THE STATE Defendant Attorney. MAURA BRIDGET MURPHY-OSBORNE (423915) File Date: 09/14/2016 AG- SPECIAL LIT 2ND FL 55 ELM ST PO BOX 120 HARTFORD. CT 061410120 Attorney: 22 PHILIP MILLER (421759) 1File Date: 08/03/2018 AG-SPECIAL LIT 2N FL 55 ELM ST PO BOX 120 HARTFORD. CT 061410120 MICHAEL TELESCA Defendant Attorney: 1? KOSKOFF KOSKOFF PC (032250) File Date: 06I12I2017 350 FAIRFIELD AVENUE - BRIDGEPORT. CT 06604 ROCCO FRANK JR Defendant Attorney: 62' KOSKOFF KOSKOFF BIEDER PC (032250) File Date: 0611212017 350 FAIRFIELD AVENUE BRIDGEPORT. CT 06604? 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