DOB: Kondracki & Liu - CD-NOIR-NOIF

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IN THE MATTER OF:

ACAE, L.L.C.
("ACAE")

MICHAEL GEORGE
SEAN KONDRACKI
CRD No. 2179786
("Kondracki")

JUDY BAO-SHAN LIU
CRD No. 1702583
("Liu")

(Collectively "Respondents")



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ORDER TO CEASE AND DESIST

NOTICE OF INTENT TO REVOKE
REGISTRATION AS INVESTMENT
ADVISER AGENT

NOTICE OF INTENT TO FINE

AND

NOTICE OF RIGHT TO HEARING

DOCKET NO. CF-10-7334-S

I. PRELIMINARY STATEMENT

1. The Banking Commissioner (“Commissioner”) is charged with the administration of Chapter 672a of the General Statutes of Connecticut, the Connecticut Uniform Securities Act (“Act”), and the regulations promulgated thereunder (Sections 36b-31-2 to 36b-31-33, inclusive, of the Regulations of Connecticut State Agencies) (“Regulations”).
2. Pursuant to Section 36b-26(a) of the Act, as amended by Public Act 10-141, the Commissioner, through the Securities and Business Investments Division of the Department of Banking (“Department”), has conducted an investigation into the activities of Respondents to determine if Respondents had violated, are violating or are about to violate provisions of the Act or Regulations (“Investigation”).
3.
As a result of the Investigation, the Commissioner has reason to believe that Respondents have violated certain provisions of the Act.
4. As a result of the Investigation, the Commissioner has the authority to issue an order to cease and desist against Respondents pursuant to Section 36b-27(a) of the 2010 Supplement to the General Statutes (“2010 Supplement”), as amended by Public Act 10-141.
5.
As a result of the Investigation, the Commissioner brings this administrative action pursuant to Section 36b-15 of the 2010 Supplement, as amended by Public Act 10-141, and Section 4-182(c) of the General Statutes of Connecticut to revoke the investment adviser agent registration of Kondracki in Connecticut.
6.
As a result of the Investigation, the Commissioner has the authority to impose a fine against Respondents pursuant to Section 36b-27(d) of the Act in effect prior to October 1, 2003, and Section 36b-27(d) of the 2010 Supplement, as amended by Public Act 10-141.

II.  RESPONDENTS

7. Kondracki is an individual whose address last known to the Commissioner is 535 Hunting Ridge Road, Stamford, Connecticut.  Since December 17, 2003 to the present, Kondracki has been registered in Connecticut as an investment adviser agent of Fairport Advisors, Inc. (CRD No. 117177).
8. Liu is an individual whose address last known to the Commissioner is 535 Hunting Ridge Road, Stamford, Connecticut.
9.
At all relevant times hereto, Kondracki and Liu were husband and wife.
10. ACAE is a New York limited liability company whose principal place of business and address last known to the Commissioner is 535 Hunting Ridge Road, Stamford, Connecticut.  From at least September 2000 to October 2007, Kondracki and Liu owned, managed and were the only members of ACAE.

III.  STATEMENT OF FACTS

11. From at least September 2000 to October 2007, ACAE was the investment manager of Assets Consulting, Allocation and Evaluation Offshore Fund of Funds, Ltd. (“Fund”), described in the Fund’s Confidential Information Memorandum as an open-end investment company and a limited liability company formed under the laws of the Cayman Islands.  In making its investment decisions, ACAE relied on Kondracki and Liu, who were the sole members of ACAE.  As such, Kondracki and Liu had responsibility for all investment decisions, subject to the supervision of the Fund’s directors.  Kondracki and Liu were the Fund’s only directors.  ACAE, through Kondracki and Liu, engaged in these activities from Connecticut, and received compensation, directly or indirectly, for providing such advisory services.
12. From at least September 2000 to October 2007, Kondracki and Liu, on behalf of ACAE, solicited business from individuals to invest in the Fund.  From at least September 2000 to October 2007, Kondracki and Liu, on behalf of ACAE, made recommendations and rendered advice regarding securities to the Fund and to investors in the Fund as to the advisability of investing in, purchasing, or selling securities.  Kondracki and Liu engaged in these activities from Connecticut, and received compensation or remuneration for such services.
13. In June of 2000, a husband (“Investor One”) and wife (“Investor Two”) invested Two Million Dollars ($2,000,000) in the Fund.  Investor One and Investor Two were relatives of Kondracki and Liu.
14. Notwithstanding the fact that the Two Million Dollars ($2,000,000) from Investor One and Investor Two had already been invested in the Fund, on July 6, 2000, Investor One and Investor Two organized Galaxy Capital, LLC as a limited liability company under the laws of the Island of Nevis for the purpose of investing in the Fund.  Investor One and Investor Two were the sole members of Galaxy Capital, LLC.  From this time forward, Respondents treated Galaxy Capital, LLC as the investor in the Fund.
15. In March 2005, Investor One and Investor Two consulted with Liu regarding the process for dissolving Galaxy Capital, LLC and transferring Galaxy Capital, LLC’s holdings back into the individual names of Investor One and Investor Two.
16. Investor One died in March 2005.
17. In May of 2005, Investor Two, the sole surviving member of Galaxy Capital, LLC, informed Respondents of her intention to liquidate her entire investment in the Fund.  During May and the beginning of June 2009, Liu advised and assisted Investor Two in the dissolution of Galaxy Capital, LLC.
18. Investor Two, as the sole surviving member of Galaxy Capital, LLC, signed a member resolution dated May 23, 2005 to dissolve Galaxy Capital, LLC.
19.
On or about June 14, 2005, Investor Two informed Liu that she had received the documentation dissolving Galaxy Capital, LLC and that it was dissolved.
20. After Investor Two again informed Respondents of her intention to liquidate her investment in the Fund, Kondracki and Liu suggested alternative investments to Investor Two that would result in Kondracki and Liu’s continued management of Investor Two’s money.  Kondracki and Liu sent Investor Two proposals for new investments in May, June and July suggesting that she transfer her assets to other investments being developed by Kondracki and Liu.
21. Notwithstanding the investment offers made by Kondracki and Liu, on July 25, 2005, Investor Two informed Respondents that she needed to redeem her assets to have access to her funds.  Investor Two indicated that she had already spoken to Liu about transferring her assets the previous week and that Liu promised to assist her in doing so.  Kondracki responded that he and Liu would get Investor Two the procedure to withdraw her assets from the Fund that week.
22. On July 26, 2005, Liu e-mailed Investor Two claiming that Investor One and Investor Two signed the Fund’s subscription agreement in Galaxy Capital, LLC’s name and that it was the only shareholder of record.
23. Following Kondracki and Liu’s instructions regarding the Fund’s redemption policy, in August of 2005, Investor Two provided a written request for redemption of the Galaxy Capital, LLC investment in the Fund to the Fund’s third-party administrator.  Respondents advised Investor Two that redemption requests would be processed at the end of the quarter in which they were made.
24. On September 30, 2005, the end of the business quarter, Respondents failed to transfer the funds to Investor Two as requested in the redemption request.
25. Respondents now denied the redemption request because the Fund’s third-party administrator claimed that it did not have any compliance information on Galaxy Capital, LLC, despite previously making redemptions to Investor One and Investor Two based solely on Investor One’s request.
26. On September 30, 2005, the end of the business quarter, the Fund’s Net Asset Value (“NAV”) of 95.515674 was almost Five Dollars ($5) per share lower than it was when Investor Two initially sought the return of her money, despite the Fund having been invested almost entirely in Government bonds and Money Market accounts.
27. Notwithstanding Investor Two’s redemption request, Kondracki and Liu continued to reinvest the majority of the Fund’s assets in interest bearing instruments and accounts, including the funds that Kondracki and Liu purportedly set aside for Investor Two’s redemption.
28. In approximately January 2006, the third-party Fund administrator resigned and the Fund became self-administered by Kondracki and Liu.
29. In March 2007, rather than providing Investor Two with a complete redemption as requested, Liu offered Investor Two a staggered withdrawal schedule based on the Fund’s NAV as of September 30, 2005, the end of the quarter in which the written redemption request was made.  This offer was made despite having earned substantial income from Investor Two’s funds during this eighteen month period.  Investor Two refused this offer.
30. In approximately November 2007, absent any agreement by Investor Two, Respondents simply wired funds to Investor Two.  Respondents claimed these funds satisfied the redemption request.
31. The funds that were finally paid to Investor Two did not include the interest that was earned during the two-year time period that Kondracki and Liu continued to hold Investor Two’s funds.  Kondracki and Liu simply kept this money.  According to Liu, that money was never returned to Investor Two because “she didn’t ask for it.”
32. Furthermore, the funds repaid to Investor Two were also Sixty-five Thousand Dollars ($65,000) less than Respondents indicated had been set aside for redemption in 2005.  To date, no legitimate accounting of the Fund’s holdings and expenses has been provided to Investor Two.
33. From the time of Investor Two’s redemption request until the summer of 2006, Kondracki and Liu had no other source of income other than that derived from the Fund.  Additionally, at the time of Investor Two’s redemption request, Investor Two’s funds constituted a substantial majority of the Fund’s assets.
34. At no time has ACAE been registered as an investment adviser in Connecticut, nor does it qualify for any exemption or exclusion from registration under the Act.
35. At no time were either Kondracki or Liu registered in Connecticut as an investment adviser agent of ACAE, nor did they qualify for any exemption or exclusion from registration under the Act.
36. On July 21, 2010, the Commissioner gave Kondracki written notice pursuant to Section 4-182(c) of the General Statutes of Connecticut that Kondracki may have engaged in conduct which, if proven, would constitute a basis for the suspension or revocation of Kondracki’s investment adviser agent registration in Connecticut, and gave Kondracki the opportunity to show compliance with all lawful requirements for the retention of his registration as an investment adviser agent in Connecticut.  Kondracki provided the Department with a response to the written notice.  The response, however, was not persuasive.

IV.  STATUTORY BASIS FOR ORDER TO CEASE AND DESIST,
REVOCATION OF REGISTRATION AS
INVESTMENT ADVISER AGENT, AND
ORDER IMPOSING FINE AGAINST RESPONDENTS

a.  Violation of Section 36b-5(a) of the Act -
Prohibited Activity of Investment Adviser

37. Paragraphs 1 through 36, inclusive, are incorporated and made a part hereof as if more fully set forth herein.
38.
The conduct of Respondents, as more fully described in paragraphs 11 through 33, inclusive, in connection with directly or indirectly receiving compensation or other remuneration for advising another person as to the value of securities or their purchase or sale, whether through the issuance of analyses or reports or otherwise, constitutes employing a device, scheme or artifice to defraud, making an untrue statement of a material fact or omitting to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they are made, not misleading, or engaging in an act, practice or course of business which operates as a fraud or deceit upon such other person.  Such conduct constitutes a wilful violation of Section 36b-5(a) of the Act, which forms a basis for an order to cease and desist to be issued against Respondents under Section 36b-27(a) of the 2010 Supplement, as amended, the revocation of Kondracki’s registration as an investment adviser agent in Connecticut pursuant to Section 36b-15(a)(2)(B) of the 2010 Supplement, as amended, and the imposition of a fine against Respondents under Section 36b-27(d) of the 2010 Supplement, as amended.

b.  Violation of Section 36b-5(e) of the Act –
Prohibited Activity on Behalf of an Investment Adviser

39. Paragraphs1 through 38, inclusive, are incorporated and made a part hereof as if more fully set forth herein.
40.
The conduct of Kondracki and Liu, as more fully described in paragraphs 12 through 33, inclusive, in connection with directly or indirectly receiving compensation or other remuneration for soliciting advisory business on behalf of a person subject to the prohibition contained Section 36b-5(a) of the Act constitutes employing a device, scheme or artifice to defraud; making an untrue statement of a material fact or omitting to state a material fact necessary in order to make the statements made, in light of the circumstances under which they are made, not misleading; or engaging in any act, practice or course of business which operates or would operate as a fraud or deceit.  Such conduct constitutes a wilful violation of Section 36b-5(e) of the Act, which forms a basis for an order to cease and desist to be issued against Kondracki and Liu under Section 36b-27(a) of the 2010 Supplement, as amended, the revocation of Kondracki’s registration as an investment adviser agent in Connecticut pursuant to Section 36b-15(a)(2)(B) of the 2010 Supplement, as amended, and the imposition of a fine against Kondracki and Liu under Section 36b-27(d) of the 2010 Supplement, as amended.

c.  Violation of Section 36b-5(f) of the Act –
Prohibited Activity of Investment Adviser or
Person Acting on Behalf of an Investment Adviser

41. Paragraphs 1 through 40, inclusive, are incorporated and made a part hereof as if more fully set forth herein.
42.
The conduct of Respondents, as more fully described in paragraphs 11 through 33, inclusive, in connection with directly or indirectly receiving compensation or other remuneration for advising another person as to the value of securities or their purchase or sale or soliciting advisory business on behalf of a person subject to the prohibition contained in Section 36b-5(a) of the Act constitutes engaging in a dishonest or unethical practice in connection with the rendering of such advice or in connection with such solicitation.  Such conduct constitutes a wilful violation of Section 36b-5(f) of the Act, which forms a basis for an order to cease and desist to be issued against Respondents under Section 36b-27(a) of the 2010 Supplement, as amended, the revocation of Kondracki’s registration as an investment adviser agent in Connecticut pursuant to Section 36b-15(a)(2)(B) of the 2010 Supplement, as amended, and the imposition of a fine against Respondents under Section 36b-27(d) of the 2010 Supplement, as amended.

d.  Violation of Section 36b-6(c)(1) of the Act -
Unregistered Investment Adviser Activity

43. Paragraphs 1 through 42, inclusive, are incorporated and made a part hereof as if more fully set forth herein.
44.
ACAE transacted business as an investment adviser in Connecticut absent registration as such, as more fully described in paragraphs 11 through 34, inclusive.  Such conduct constitutes a violation of Section 36b-6(c)(1) of the Act, as amended by Public Act 10-141, which forms a basis for an order to cease and desist to be issued against ACAE under Section 36b-27(a) of the 2010 Supplement, as amended, and the imposition of a fine against ACAE under Section 36b-27(d) of the Act in effect prior to October 1, 2003, and Section 36b-27(d) of the 2010 Supplement, as amended.

e. Violation of Section 36b-6(c)(3) of the Act –
Engaging Unregistered Investment Adviser Agents

45. Paragraphs 1 through 44, inclusive, are incorporated and made a part hereof as if more fully set forth herein.
46.
ACAE engaged Kondracki and Liu as investment adviser agents in Connecticut, absent registration, as more fully described in paragraphs 11 through 35, inclusive.  Such conduct constitutes a violation of Section 36b-6(c)(3) of the Act, as amended by Public Act 10-141, which forms a basis for an order to cease and desist to be issued against ACAE under Section 36b-27(a) of the 2010 Supplement, as amended, and the imposition of a fine against ACAE under Section 36b-27(d) of the Act in effect prior to October 1, 2003, and Section 36b-27(d) of the 2010 Supplement, as amended.

f. Violation of Section 36b-6(c)(2) of the Act –
Unregistered Investment Adviser Agent Activity

47. Paragraphs 1 through 46, inclusive, are incorporated and made a part hereof as if more fully set forth herein.
48.
Kondracki and Liu transacted business as investments adviser agents of ACAE in Connecticut absent registration as an investment adviser agent, as more fully described in paragraphs 11 through 35, inclusive.  Such conduct constitutes a wilful violation of Section 36b-6(c)(2) of the Act, as amended by Public Act 10-141, which forms a basis for an order to cease and desist to be issued against Kondracki and Liu under Section 36b-27(a) of the 2010 Supplement, as amended, the revocation of Kondracki’s registration as an investment adviser agent of Fairport Advisors, Inc. in Connecticut pursuant to Section 36b-15(a)(2)(B) of the 2010 Supplement, as amended, and the imposition of a fine against Kondracki and Liu under Section 36b-27(d) of the Act in effect prior to October 1, 2003, and Section 36b-27(d) of the 2010 Supplement, as amended.

V.  ORDER TO CEASE AND DESIST, NOTICE OF INTENT TO REVOKE
REGISTRATION AS INVESTMENT ADVISER AGENT,
NOTICE OF INTENT TO FINE AND NOTICE OF RIGHT TO HEARING

WHEREAS, as a result of the Investigation, the Commissioner finds that, with respect to the activity described herein, ACAE has committed at least one violation of Section 36b-5(a) of the Act subsequent to October 1, 2003, at least one violation of Section 36b-5(f) of the Act subsequent to October 1, 2003, at least one violation of Section 36b-6(c)(1) of the Act, as amended, prior to October 1, 2003, at least one violation of Section 36b-6(c)(1) of the Act, as amended, subsequent to October 1, 2003, two violations of Section 36b-6(c)(3) of the Act, as amended, prior to October 1, 2003, and two violations of Section 36b-6(c)(3) of the Act, as amended, subsequent to October 1, 2003;

WHEREAS, as a result of the Investigation, the Commissioner finds that, with respect to the activity described herein, Kondracki has committed at least one violation of Section 36b-5(a) of the Act subsequent to October 1, 2003, at least one violation of Section 36b-5(e) of the Act subsequent to October 1, 2003, at least one violation of Section 36b-5(f) of the Act subsequent to October 1, 2003, at least one violation of Section 36b-6(c)(2) of the Act, as amended, prior to October 1, 2003, and at least one violation of Section 36b-6(c)(2) of the Act, as amended, subsequent to October 1, 2003;

WHEREAS, as a result of the Investigation, the Commissioner finds that, with respect to the activity described herein, Liu has committed at least one violation of Section 36b-5(a) of the Act subsequent to October 1, 2003, at least one violation of Section 36b-5(e) of the Act subsequent to October 1, 2003, at least one violation of Section 36b-5(f) of the Act subsequent to October 1, 2003, at least one violation of Section 36b-6(c)(2) of the Act, as amended, prior to October 1, 2003, and at least one violation of Section 36b-6(c)(2) of the Act, as amended, subsequent to October 1, 2003;

WHEREAS, the Commissioner has reason to believe that Kondracki has engaged in acts or conduct that, pursuant to Section 36b-15 of the 2010 Supplement, as amended, constitute grounds for revoking Kondracki’s registration as an investment adviser agent of Fairport Advisors, Inc., in Connecticut;

WHEREAS, Section 36b-15(f) of the 2010 Supplement, as amended, provides, in pertinent part, that “[n]o order may be entered under this section . . . without (1) appropriate prior notice to the . . . registrant and to the employer . . . if such . . . registrant is an . . . investment adviser agent, (2) opportunity for hearing, and (3) written findings of fact and conclusions of law”.

WHEREAS, the Commissioner further finds that the issuance of this Order to Cease and Desist, and the imposition of a fine against Respondents is necessary or appropriate in the public interest or for the protection of investors and consistent with the purposes fairly intended by the policies and provisions of the Act;

WHEREAS, the Commissioner further finds that the issuance of an order revoking Kondracki’s registration as an investment adviser agent of Fairport Advisors, Inc., in Connecticut is necessary or appropriate in the public interest or for the protection of investors and consistent with the purposes fairly intended by the policies and provisions of the Act;

WHEREAS, notice is hereby given to Kondracki that his registration as an investment adviser agent of Fairport Advisors, Inc., in Connecticut shall be revoked, subject to Kondracki’s right to request a hearing on the allegations set forth above;

WHEREAS, notice is hereby given to Respondents that the Commissioner intends to impose a maximum fine not to exceed Ten Thousand Dollars ($10,000) per violation that occurred prior to October 1, 2003, and a maximum fine not to exceed One Hundred Thousand Dollars ($100,000) per violation that occurred subsequent to October 1, 2003;

WHEREAS, the Commissioner ORDERS that ACAE CEASE AND DESIST from directly or indirectly violating the provisions of the Act, including without limitation:  (1) in connection with directly or indirectly receiving compensation or other remuneration for advising another person as to the value of securities or their purchase or sale, whether through the issuance of analyses or reports or otherwise, employing a device, scheme or artifice to defraud, making an untrue statement of a material fact or omitting to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they are made, not misleading, or engaging in an act, practice or course of business which operates as a fraud or deceit upon such other person; (2) in connection with directly or indirectly receiving compensation or other remuneration for advising another person as to the value of securities or their purchase or sale or soliciting advisory business on behalf of a person subject to the prohibition contained in Section 36b-5(a) of the Act engaging in a dishonest or unethical practice in connection with the rendering of such advice or in connection with such solicitation; (3) engaging in the business of directly advising others, for compensation, as to the advisability of investing in, purchasing and selling securities in Connecticut absent registration as an investment adviser; and (4) engaging unregistered investment adviser agents;

WHEREAS, the Commissioner ORDERS that Kondracki and Liu CEASE AND DESIST from directly or indirectly violating the provisions of the Act, including without limitation, (1) in connection with directly or indirectly receiving compensation or other remuneration for advising another person as to the value of securities or their purchase or sale, whether through the issuance of analyses or reports or otherwise, employing a device, scheme or artifice to defraud, making an untrue statement of a material fact or omitting to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they are made, not misleading, or engaging in an act, practice or course of business which operates as a fraud or deceit upon such other person; (2) in connection with directly or indirectly receiving compensation or other remuneration for soliciting advisory business on behalf of a person subject to the prohibition contained Section 36b-5(a) of the Act employing a device, scheme or artifice to defraud; making an untrue statement of a material fact or omitting to state a material fact necessary in order to make the statements made, in light of the circumstances under which they are made, not misleading; or engaging in any act, practice or course of business which operates or would operate as a fraud or deceit; and (3) transacting business in Connecticut as an investment adviser agent absent registration as such;

AND WHEREAS, pursuant to Sections 36b-15(f) and 36b-27 of the 2010 Supplement, as amended, Respondents will be afforded an opportunity for a hearing on the allegations set forth above.

THE COMMISSIONER FURTHER ORDERS that a hearing will be granted to each Respondent if a written request for a hearing is received by the Department of Banking, 260 Constitution Plaza, Hartford, Connecticut 06103-1800, within fourteen (14) days following each Respondent’s receipt of this Order.  The enclosed Appearance and Request for Hearing Form must be completed and mailed to the above address.  If any Respondent will not be represented by an attorney at the hearing, please complete the Appearance and Request for Hearing Form for any such Respondent as “pro se”.  Once a written request for a hearing is received, the Commissioner may issue a notification of hearing and designation of hearing officer that acknowledges receipt of a request for a hearing, designates a presiding officer and sets the date of the hearing in accordance with Section 4-177 of the General Statutes of Connecticut and Section 36a-1-21 of the Regulations of Connecticut State Agencies.  If a hearing is requested, the hearing will be held on January 12, 2011, at 10 a.m., at the Department of Banking, 260 Constitution Plaza, Hartford, Connecticut.

The hearing will be held in accordance with the provisions of Chapter 54 of the General Statutes of Connecticut.  At such hearing, each Respondent will have the right to appear and present evidence, rebuttal evidence and argument on all issues of fact and law to be considered by the Commissioner.

This Order to Cease and Desist shall remain in effect and become permanent against any Respondent that fails to request a hearing within the prescribed time period or fails to appear at any such hearing.

The Commissioner shall issue an order revoking Kondracki’s registration as an investment adviser agent of Fairport Advisors, Inc., in Connecticut if Kondracki fails to request a hearing within the prescribed time period or fails to appear at any such hearing.

The Commissioner may order that the maximum fine be imposed upon any Respondent that fails to request a hearing within the prescribed time period or fails to appear at any such hearing.

Dated at Hartford, Connecticut,       ________/s/________ 
this 9th day of November 2010.   Howard F. Pitkin 
    Banking Commissioner 



CERTIFICATION

I hereby certify that on this 10th day of November 2010, the foregoing Order to Cease and Desist, Notice of Intent to Fine and Notice of Right to Hearing was sent by certified mail, return receipt requested, to ACAE, L.L.C., 535 Hunting Ridge Road, Stamford, Connecticut 06903, certified mail no. 7010 0290 0002 7489 7815; Michael George Sean Kondracki, 535 Hunting Ridge Road, Stamford, Connecticut 06903, certified mail no. 7010 0290 0002 7489 7822; Judy Bao-Shan Liu, 535 Hunting Ridge Road, Stamford, Connecticut 06903, certified mail no. 7010 0290 0002 7489 7839; Fairport Advisors, Inc., 830 Post Road East, Suite 210, Westport, Connecticut 06880, certified mail no. 7010 0290 0002 7489 7846; and Ellery E. Plotkin, LLC, 777 Summer Street, 2nd Floor, Stamford, Connecticut 06901, certified mail no. 7010 0290 0002 7489 7853.



      
  ______/s/__________ 
  Paul A. Bobruff
  Prosecuting Attorney 


                                                 
 


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