Multiple Law Violations, civil & constitutional rights violations, perjury, docket tampering, amending laws without approval from Legislature, no waivers (as required by Connecticut state laws), no DNA to support any claim of a punitive father - even going as far as no court appointed attorney...These are the facts which are outlined in this website and needs to be publicly announced to incriminate the State of Connecticut as well as the lower courts for their feeble attempts to hold me accountable for child support which they have not been able to prove since inception, but instead opted for illegal actions, compromising ethics, conduct and integrity of a system that is supposed to just and fair for all parties - now a conspiracy to cover up these illegal actions to convict an innocent man who became a victim of paternity entrapment [fraud] due to the heinous actions of a mentally unstable young woman.
Paternity Entrapment is an action committed by a woman against a man's consent to conceive for pregnancy purposes/reasons. This action is the one of the most hanious crimes a woman can commit against a man because it bears potential of destroying a man's life and no woman has any right to do that - Consent is everything and once a man's right to consent has been violated, it undermines and destroys the morality, liability and legality of such a right. This action is so severe, it is considered both rape and criminal theft in one heinous crime - Yes, entrapment is a crime and is punishable to those women who do knowingly commit such a crime. The only reason why a woman can conveivably plot this crime and "get away with it" because the judicial system (for those women who seek state assistance) is undoubtably flawed and highly favors a woman over man in this capacity. Woman have taken advantage of this flawed system for many years without providing any proof whatsoever in a system that has potential monetary gain with a background in male discrimination on many levels.
WHY WAS THIS WEBSITE CREATED? This website was created to generate public interest in a subject that most would choose to just bury under the rug because state agencies gain from the numerous flaws generated by a system that is supposed to declare fairness, justice and law compliances, but in fact, takes advantage of those flaws whereby equal rights for men have been compromised, denied and manipulated - and woman reap the benefits of a severely flawed system.
This is not Roe v. Wade - This is about 2 adults who engage in an act of coitus whereby the woman has "other intentions" without informing her partner of such intentions [of intended pregnancy]. You may say to yourself that a man, as well as a woman, should protect themselves from such intended conceivance, but in my particular case, I was informed that Pauline Tata [Plaintiff] was taking oral contraceptive (the "pill") and was never an issue - The Plaintiff didn't even like male condoms. No one has the right the right to take anything from you without consent - this is simple law on moral and legislative levels. (Case Reference is Public Record: http://civilinquiry.jud.ct.gov/CaseDetail/PublicCaseDetail.aspx?DocketNo=HHBFA880432921S)
Pregnancy is a conscious adult choice which is between two (2) individuals – not just one; but when a male is found to be liable for paternity for a conscious choice he did NOT make or consent to, then he should not be forced to pay the terrible, life-altering price for this occurrence! Inequities may always exist between females and males in every society, but in my view, this one's the most hideous. Until our legal system mandates that women are equally and mentally responsible for these "entrapments" (one-sided intentions of pregnancy), men will continue to be brutalized by governing bodies that persistently ignore this travesty. Furthermore, if we sanction a woman's "right to choose," how is it even remotely fair that a man's denied this same liberty (Assuming that a woman has the right to choose to violate a man's right to consent)? How is it even possible that a woman has the right to choose to rape a man and still be legal due to system flaws?! - this is insane...
Females determined to impregnate themselves without a partner's consent, lack adult emotional development--which means their capacity for empathy (ability to identify with another's feelings and needs) is extremely limited. Accompanying moral deficits allow them to premeditate conception, which is diabolical, unconscionable behavior that's akin to criminal theft and should be punished accordingly.
This cold-hearted act is sickening and mentally disturbing – to blatantly lie to man to get pregnant is without a doubt – a crime of rape and theft.
I was informed, at the barely legal age of 18, that the Plaintiff was pregnant - at a time when my life should just be beginning, it had ended. Shock and awe doesn't even describe what I was feeling and thinking at that time. Why, on God's great earth, would I, at the barely legal of 18, even THINK of having a family?! If the Plaintiff cared about me, which she claimed, then why would she do this to me? If I had seen the clues and listened to her close friends at that time, this [alleged pregnancy] would have never happened. NEVER did I consent to such an act or a decision to father any child (that's just insane), but nonetheless, it spread us apart...I was betrayed, decieved, lied to...scarred for life indeed.
The Plaintiff, after the child was born, sought out state assistance and provided the State of Connecticut my name and address....but I didn't know this. I only found out after receiving a letter in the mail to arrive at the State of Connecticut Child Support Division or I would risk incarceration if I didn't - even further devasted by this action from the Plaintiff, I had no choice. I arrived there and was intimidated by state workers and coerced into signing an Acknowledgment of Paternity - I can't even tell you the thoughts going through my head of how someone could do this to me...what did I do to deserve this?!
When I confronted the Plaintiff about this action, she produced excuses such as "well, you can't expect me to take the pill everyday...I do forget"...and then another excuse of "obviously, the pill didn't work" - These are common terms and phrases used by women who intend to trap men into fatherhood without consent - thinking the excuses are valid over reasons of trust and morality - elements which I grew up with...to trust people you care about, but alas....
Since the Plaintiff and I had some of the same friends, I was later told that the Plaintiff was obsessed with me....obsessed with the fact and possibility that she could become pregant with someone who she was obsessed with - not to mention in part that she was mentally unstable and very self conscience; thinking that she'll never get anyone because of the way she looked (overweight) and took advantage of the ideal situation. I even sat at the table with her and her parents (she was living with her parents at the time and never left home to create her own life) and told them this was not supposed to happen, never intended for it to happen and to abort this child because it was wrong. She said she didn't believe in abortion and later said that the female child [name withheld] would never know she was an accident....excuse me?!....AN ACCIDENT?!....lies on top of lies, story changes, intent changes - these are acts of an unstable woman without a doubt.
I still don't know at this point if this child is mine or not....and never did know.
At my first hearing in family court, my court appointed attorney informed me, at that time, said there was nothing I could do because "too much time had lapsed" (The Plaintiff hadn't applied for assistance until 1.5 years later after the birth of her daughter) - I'm not sure what he meant by this because I had never been in court before for anything and didn't understand court/attorney jargon, laws, etc. I just trusted what he said. I don't have much memory of that event that day (many years had passed since then). I was informed that I have to make weekly payments, submit my entire list of assets, provide my employer's address and a host of other requirements. Since that time, I did what the court said because, in my own thinking, the court has followed and addressed laws and I should comply with the court order; which I did for years until I got sick and tired of being harrassed by the State, threatened with incarceration (due to non-payment because of employment gaps), numerous license suspensions, credit destruction, tax return interception and more. My research uncovered more than what the State and court wanted me to know...
Since the time passed of being informed I was a father and complying with the State of Connecticut (to avoid threats and incarceration), the Plaintiff and I no longer had relations of any kind. I never thought another human being could do that against me when I did nothing to ask for that - I was filled with anger/hate, thoughts of betrayal and being taken advantage of - even raped; something taken from me the purpose of pro-creation without my consent. How could I possibly continue any relations with a human being who did this to me...
Entrapment by a woman to a man is CLEARLY a crime in itself and NOT recognizable by the Family Support Division of Connecticut – The arrogance of the State Department clearly demonstrates the need to re-evaluate the morals of this crime to recognize AND acknowledge the difference between fault and intention.
Connecticut state law permits a plaintiff to petition paternity up to a child's 18th birthday (but yet the punitive father only has 3 years to contest - this is fair?!), but the Plaintiff never did...neither did the State of Connecticut Child Support Enforcement. After I reviewed the laws pertaining to the Acknowledgment of Paternity for Connecticut, here is how it is written:
CHAPTER 815y - Sec. 46b-172. Acknowledgment of paternity and agreement to support; judgment. Review of acknowledgment of paternity. (a)(1) In lieu of or in conclusion of proceedings under Section 46b-160, a written acknowledgment of paternity executed and sworn to by the putative father of the child when accompanied by (A) an attested waiver of the right to a blood test, the right to a trial and the right to an attorney, and (B) a written affirmation of paternity executed and sworn to by the mother of the child shall have the same force and effect as a judgment of the Superior Court.
WHERE DO I BEGIN WITH LAWS REGARDING THE ABOVE?
The State of Connecticut collected an Acknowledgment of Paternity which was so enemic, it only had a signature which was coerced [illegally] and no accompanying waivers (also required by law) and then submitted to the court for ruling. The State of Connecticut Child Support Enforcement did not check all the documents to ensure that all laws were complied with to ensure they did not violate any laws, statues or defendant's civil and/or constitutional rights. The state also laid claim to an alleged second child, but has yet to produce any court order, any waiver of right, any attorney that was present on my behalf....shall I continue?! The presiding magistrate (magistrates are not judges because they are governor-appointed attorney's who act as magistrates in the lower courts and do not share the same privileges reserved for judges), then ruled in favor of the State without validating the State's submission of the Acknowledgment of Paternity which resulted in Connecticut and Statute(s), civil and constitutional violations. Neither the State nor the Court even bothered to validate documents to ensure law compliances and even denied the right to trial, because let's face it...Teenagers [generally] do not possess the necessary knowledge to contest any action of the State or Court (unless represented) and cases (such as mine) could easily be ruled upon without any consenquence(s) or questioned to the courts (yes, courts do take advantage of the less fortunate and less knowledgeable)...until the unraveling of the facts began with me...
In recent years, I began unveiling all sorts of violations - on civil and constitutional levels. I then educated myself on drafting motions with the court (unable to afford counsel or other representation - turned down and not even acknowledged when seeking counsel for representation). My first motion indicated fraud on many levels, but the magistrate on the case attempted to apply a law which only pertains to CONTESTING paternity, whereby my claim was fraud which has no statute of limitation. Magistrates do NOT have approval from any legislative member, group or entity to amend laws which do not exist or apply laws to a claim which do not exist - yet, this is what the magistrate's have done.
This past January (2018), I filed the following motion:
CHAPTER 815y - Sec. 46b-172. Acknowledgment of paternity and agreement to support; judgment. Review of acknowledgment of paternity. (a)(1) In lieu of or in conclusion of proceedings under Section 46b-160, a written acknowledgment of paternity executed and sworn to by the putative father of the child when accompanied by (A) an attested waiver of the right to a blood test, the right to a trial and the right to an attorney, and (B) a written affirmation of paternity executed and sworn to by the mother of the child shall have the same force and effect as a judgment of the Superior Court.Connecticut state law (mandated by legislature) grants every defendant a right to trial where accusation of paternity is present. The State of Connecticut Child Support Enforcement Bureau in conjunction with multiple family court magistrates having illegally denied this right to trial. An accused defendant has not only civil rights, but also constitutional rights to a trial for which the above aforementioned have been denied to defendant.
A magistrate who denied a motion pointing out his own illegal actions is permitted to dismiss his own allegations in the Appellate Court?! Since this decision cannot be challenged (according to the court), an appeal must be filed with the State Supreme Court. Magistrate Carbonneau is not, nor ever has been, a fair and impartial jurist in any case (history of cases speaks for itself). I can further support this by his actions of agreeing with another Magistrate (already construed as a conspiracy) that the 3-year rule/law applies to my case when in fact there is no possibility of it - you cannot challenge that which does not exist; much less apply a 3-year rule which is challenging paternity. This case if pure fraud and no proof - it's that simple. Carbonneau then continued to state in his response that I wilfilly signed the Acknowledgement of Paternity - if that were so, I would have not claimed coercian in ALL of my motions filed with court and in ALL the transcripts one would request. A magistrate is going to tell me what I did yet is unable to prove any of it? This is a complete fabrication to my defense and this magistrate has compromised his conduct and integrity to the oath he took when he accepted the position of magistrate to uphold and cite laws mandated by legislature. His ruling is cowardly and without any basis.
The State of Connecticut Child Support Enforcement, The Legislative Commissioner's Office and the Attorney General's office was faxed the following document to be provided with the option of settlement or trial - no reponse was ever received after sending this letter to all parties multiple times:
CHAPTER 815y - Sec. 46b-172 states that a "written acknowledgment of paternity executed and sworn to by the putative father...." (1)
"...when accompanied by (A) an attested waiver of the right to a blood test..." (1)
"...the right to a trial and the right to an attorney..." (1)
The Attorney General's office filed a motion to dismiss my complaint, but falsified statements and claims to facscilate their claim to persuade the judge's decision:
Mr. Lavigne is an independant contractor who has been providing web/graphics/IT services for a client. The State of Connecticut attempted to order my client to comply with a wage garnishment, but my client is not my employer as the state has claimed. My client does not have to comply with any order because he is not my employer and he could have severed my contract with him and compromised my income. So I sent a stern letter to the Attorney General's Office who not only attempted this once before, but is now trying again - the first attempt was quickly rescinded after my letter to the AG's office but was again coerced into defending myself and my client....
A reply was never received by the AG's office....
Attn: Attorney General Tong's Office,
My client [CLIENTS NAME REMOVED] received an income withholding for Support document today and advised me of this illegal action.
[CLIENTS NAME REMOVED] is a client and is not an employer – your office has been advised of this on a prior illegal action committed by Derik Rodriguez who attempted a wage garnishment, but quickly rescinded this action after I submitted a stern letter to your office advising against it or civil action would commence.
You are hereby notified to cease and desist ANY/ALL actions against me as any action which involves my client could terminate any work performed for him and I would lose my income. Derik Rodriguez, a Child Support Enforcement Officer, is already in Federal Court for multiple law violations and civil rights violations – THERE IS NO STATE ACTION WHILE CHILD SUPPORT ENFORCEMENT IS IN COURT FOR PATERNITY FRAUD.
Should you deviate from my immediate request to withdrawal your action against my client, I will be coerced into filing an immediate motion with Federal Court requesting an immediate hearing regarding this matter.
This letter will serve you as an official notification to cease and desist immediately.
You may reply to this email address or contact me directly: [phone number removed].
Please govern yourself accordingly,
The State illegally intecepted my lottery winnings for which I had to file a motion to reclaim such winnings - The Attorney General's Office and the State of Connecticut is not permitted to violate laws mandated by legislature to pursue me for child support, but lay claim to a statute that allows monetary gain.
Due to the illegall actions of the Attorney General's Office assistant who is representing the State of Connecticut in Federal Court, I was compelled to file a formal complaint against her for multiple violations in actions, conduct, ethics and deceiving the court...
You solemnly swear or solemnly and sincerely affirm, as the case may be, that you will do nothing dishonest, and will not knowingly allow anything dishonest to be done in court, and that you will inform the court of any dishonesty of which you have knowledge; that you will not knowingly maintain or assist in maintaining any cause of action that is false or unlawful; that you will not obstruct any cause of action for personal gain or malice; but that you will exercise the office of attorney, in any court in which you may practice, according to the best of your learning and judgment, faithfully, to both your client and the court.
THE ATTORNEY'S OATH
The State of Connecticut Department of Social Services Adminstrative Hearings Division denied my appeal to reclaim my lottery winnings. I'm not surprised because the State works with the State and would never deviate from covering each other's backs - they said in a hearing that they are bound by laws when making a decision, yet deviated from that in it's entirety. Here is my reponse to that [appeal]...
a. A Magistrate [judge] is not permitted to bring his own personal beliefs to a case for ruling purposes. Magistrate Carbonneau can belief whatever he chooses, but when in a position as a fair and impartial jurist who is bound by Code of Conduct and Ethics freely violates his conduct and ethics compromises not only his position and authority, but also acts outside of his privileges and authority.
b. Magistrate Carbonneau submitted a false statement in his ruling indicating that “…Defendant by his signature declared that he freely and voluntarily signed the Acknowledgment”… - Connecticut state law mandates that a signature must be voluntary and evidence of such must be presented to state [make] such claim. A family court magistrate is not permitted under his/her authority and position to lay any claim that a defendant committed an act without providing burden of proof to support such claim for which is the SES's obligation to do so and not that of a jurist. Magistrate Carbonneau acted outside of his authority.
c. 1868—14th Amendment: "All persons born or naturalized in the US...are citizens...nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person...the equal protection of the laws." Also, according to Civil Rights and Affirmative Action Laws, the Civil Rights Act of 1991 — adds provisions to title VII protections, including right to jury trial.
I filed for unemployment compensation because I am a contractor who is considered to be in "non-essential" industry and was put out of work. After receiving my benefits (only $141/week), the State of Connecticut has illegally garnished my benefits for child support never proven - for which they claim that a prior ruling permits them to take such action - but the action involves a magistrate who engaged in misconduct, conspiracy, declaring false statement(s), deviating from laws mandated by legislature and infringing upon my right to trial as mandated by legislature...so now I have to file another motion...
Section 242 of Title 18 makes it a crime for a person acting under color of any law to willfully deprive a person of a right or privilege protected by the Constitution or laws of the United States.For the purpose of Section 242, acts under "color of law" include acts not only done by federal, state, or local officials within the their lawful authority, but also acts done beyond the bounds of that official's lawful authority, if the acts are done while the official is purporting to or pretending to act in the performance of his/her official duties. Persons acting under color of law within the meaning of this statute include police officers, prisons guards and other law enforcement officials, as well as judges, care providers in public health facilities, and others who are acting as public officials. It is not necessary that the crime be motivated by animus toward the race, color, religion, sex, handicap, familial status or national origin of the victim. The offense is punishable by a range of imprisonment up to a life term, or the death penalty, depending upon the circumstances of the crime, and the resulting injury, if any.
Today, May 4, 2020, I received a letter from the IRS indicating that my stimulus check for $1,200 has been intercepted by the State of Connecticut Child Support Enforcement - illegally. They are already aware they are in court for paternity fraud and continue to illegally take money from me wherever and whenever they can. THIS WILL STOP! I have drafted a letter to Child Support Enforcement demanding the release of my stimulus check or I am filing criminal charges in federal court to include 1st Degree Larceny. My letter to them as follow...
May 5, 2020
State of Connecticut
Dept. of Social Services
Bureau of Child Support Enforcement
55 Farmington Avenue
Harford, CT 06105
To Whom It May Concern:
On May 4, 2020, I received a notice (see enclosure) from the U.S. Department of Treasury that my payment of $1,200 was applied toward an illegal debt. As you may or may not know (depending on the individual reading this letter), The State of Connecticut Child Support Enforcement is already in Federal Court for paternity fraud not only facing law and civil rights violations, but also possible 1st Degree Larceny and other criminal charges (misconduct, multiple code of conduct violations, deceiving the court, falsifying claims to facilitate a motion to dismiss my case, etc.).
The Attorney General's office assistant, Alma Nunley, is already being investigated for violating conduct, code of ethics and deceiving the court who is representing Child Support Enforcement for the above aforementioned claims.
I am hereby demanding that you release the IRS check in the amount of $1,200 to me immediately or I will be coerced into filing criminal charges in federal court for illegally intercepting monies owed to me by your agency which will include 1st degree larceny (illegally intercepting lottery winnings recently filed in Federal Court). I will extend my intent to criminal charges being filed against the Attorney General's office for falsifying claims to facilitate a motion to dismiss my case in court and to include deceiving the court (criminal charges).
Please govern yourself accordingly.
A hearing officer who works for the Department of Social Services, Office of Legal Counsel, Regulations and Administrative Hearings has acted outside of his authority, failed to cite laws in his decision/ruling and conspired to conceal fraud committed by State of Connecticut Support Enforcement Services. A complaint has been submitted to the Statewide Bar for processing and employment termination - a motion may need to be filed with Superior Court as well...it never ends...
2. When Mr. Lavigne asked Mr. Celinski if he would entertain Appellant's request to break down [and dissect] any/all laws referencing Chapter 815y Section 47b-172, he provided no answer or was not able to do so.
3. The ruling for which Mr. Celinski references regarding Magistrate Carbonneau's decision who did not [failed] cite any laws, infringed upon Appellant's right to trial as outlined on the first page of the Acknowledge of Paternity [with Appellant's coerced signature] and Chapter 815y Section 47b-172, brought his [Carbonneau] own personal beliefs to the table that a signature is valid paternity [with no law or evidence to support his false claim] and made a false claim that Appellant’s signature on the Acknowledgment of Paternity was voluntary.
a. Under the Code of Judicial Conduct; Rule 2.2. impartiality and Fairness; subsection (2)"...a judge must interpret and apply the law without regard to whether the judge approves or disapproves of the law in question...” Magistrate Carbonneau did not cite laws in his ruling, but instead opted for misconduct and deprived and infringed upon Mr. Lavigne’s rights under Color of Law [abuse of power] defined as follows:
Section 242 of Title 18 makes it a crime for a person acting under color of any law to willfully deprive a person of a right or privilege protected by the Constitution or laws of the United States. For the purpose of Section 242, acts under "color of law" include acts not only done by federal, state, or local officials within the their lawful authority, but also acts done beyond the bounds of that official's lawful authority, if the acts are done while the official is purporting to or pretending to act in the performance of his/her official duties. Persons acting under color of law within the meaning of this statute include police officers, prisons guards and other law enforcement officials, as well as judges, care providers in public health facilities, and others who are acting as public officials. It is not necessary that the crime be motivated by animus toward the race, color, religion, sex, handicap, familial status or national origin of the victim. The offense is punishable by a range of imprisonment up to a life term, or the death penalty, depending upon the circumstances of the crime, and the resulting injury, if any. In Connecticut, Section 19 of article first of the [state] constitution is amended to read as follows: “The right of trial by jury shall remain inviolate (free or safe from injury or violation).”
a) A Magistrate [judge] is not permitted to bring his own personal ' beliefs to a case for ruling purposes. Magistrate Carbonneau can belief whatever he chooses, but when in a position as a fair and impartial jurist who is bound by Code of Conduct and Ethics freely violates his conduct and ethics compromises not only his position and authority, but also acts outside of his privileges and authority.
b) Magistrate Carbonneau submitted a false Statement in his ruling indicating that “...Defendant by his signature declared that he freely and voluntarily signed the Acknowledgment... - Connecticut state law mandates that a signature must be voluntary and evidence of such must be presented to state [make] such claim. Evidence of law compliance does not exist because SES nor the courts did not record any hearing at the conception of the original cased which commenced in 1989. A family court magistrate is not permitted under his/her authority and position to lay any claim that a defendant committed an act without providing burden of proof to support such claim for which is the SES's obligation to do so and not that of a jurist. Magistrate Carbonneau acted outside of his authority.
c) 1868—14th Amendment: "All persons born or naturalized in the US...are citizens...nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person...the equal protection of the laws." Also, according to Civil Rights and Affirmative Action Laws, the Civil Rights Act of 1991 — adds provisions to title VII protections, including right to jury trial.
It is imperative that Mr. Mencseli reverse his decision in this ruling effective immediately. Mr. Mencseli failed to abide by and adhere to the laws of Connecticut (engaging in unlawful procedure) in his decision to find in favor of SES as Mr. Mencseli is bound by Code of Conduct and state protocols to cite laws in his findings for his ruling and has engaged in procedural irregularities (failure to cite law with clear and concise error of laws mandated by legislature for which the SES knowingly violated).
Mr. Celinski did not cite any laws which would otherwise permit the SES to pursue Mr. Lavigne for child support which denies the SES to make a claim for Section 52-362d(c). There is total non-compliance with laws mandated by legislature on behalf of the SES. Should Mr. Mencseli fail to reverse this decision, Mr. Lavigne will have no compunction about filing a formal complaint against Mr. Mencseli for willfully violating the guidelines 7 according to his position which involves citing laws mandated by legislature and violating his code of conduct and ethics according to protocol and procedure for his ill- made decision.
Furthermore, Mr. Lavigne will seek Mr. Mencseli's employment termination citing such violations and will exercise every resource available for such conviction. This action may be necessary to ensure that the public trust is not compromised and that this hearing officer [Mr. Mencseli] is required to be in full compliance with his responsibilities as a hearing officer which does not permit any action [decision] to any party without citing laws. As stated by Appellant, rulings are not laws and such ruling that Mr. Mencseli found in favor of is open to incrimination, ridicule and multiple law/civil rights violations committed by the SES and referenced unlawful ruling of Magistrate Carbonneau.
Bruce Lavigne (Plaintiff)
Miklos Mencseli (Defendant)
Dkt No.: UWY-CV20-5026709-S
Date: July 28, 2020
Plaintiff, BRUCE LAVIGNE, brings forth this complaint against Defendant, MIKLOS MENCSELI, HEARING OFFICER FOR STATE OF CONNECTICUT DEPARTMENT OF SOCIAL SERVICES OFFICE OF LEGAL COUNSEL, REGULATIONS AND ADMINISTRATIVE HEARINGS I. PARTIES 1. Plaintiff, BRUCE LAVIGNE, (hereinafter "Plaintiff") is an individual who is currently residing at (address removed). Defendant, MIKLOS MENCSELI employment address is currently 55 Farmington Avenue, Hartford, CT 06105
On February 24, 2020, Plaintiff requested an administrative hearing to contest the State of Connecticut Support Enforcement Services' action to withhold Plaintiff's lottery winnings [Exhibit A]. On March 26, 2020, an administrative hearing commenced via telephone with Plaintiff, Andrew Celinski (Supervisor Support Enforcement Officer) and Miklos Mencseli [defendant] (Hearing Officer for the Department of Social Services; Office of Legal Counsel, Regulations and Administrative Hearings). During this telephone conference for oral argument, Plaintiff interrogated defendant with the regard to laws for which he [defendant] is bound to in his decision/ruling process — he admitted he was bound by law.
During the oral arguments, Mr. Celinski, representing the State of Connecticut Support Enforcement Services, could not and was not able to cite any laws for claiming Section 52-362d. Mr. Celinski only referenced a ruling by the court which allegedly permits Support Enforcement Services to take such action to intercept lottery winnings, but in fact, if no laws were cited or referenced in such action [ruling], then such action is deemed illegal and violates laws mandated by legislature combined with Code of Ethics and Professional Code of Conduct violations demonstrated by the defendant and the State of Connecticut Support Enforcement Services.
On April 13, a NOTICE OF DECISION [Exhibit B] was mailed to Plaintiff with a determination that defendant found in favor of SES citing a court ruling which did not cite laws in the requirement of citing laws in the decision-making process.
On April 17, 2020, a letter of Request For Consideration was drafted by Plaintiff contesting the decision of defendant's ruling [Exhibit C].
On a letter dated June 24, 2020, Plaintiff received a notification of denial [Exhibit D] for the appeal citing laws and facts, but the defendant did not require laws to be cited by SES nor did defendant cite laws in his findings and ruling. Furthermore, Plaintiff received the complaint filed against the Defendant back from the Statewide Grievance Committee [Exhibit E] who revealed that the Defendant was not licensed in Connecticut indicating the Defendant acted in his current employment position as a Hearing Officer for the State Of Connecticut Department Of Social Services Office Of Legal Counsel, Regulations And Administrative Hearings and ruled illegally upon Plaintiff's Request for Reconsideration unable to cite laws and was not licensed within his capacity as a hearing officer. It is a requirement by the State that any/all Hearing Officers be licensed at time of employment. The defendant's ruling is considered invalid and illegal.
Citing the requirement of licensing for all hearing officers employed in a state agency capacity, the Plaintiff is requesting that the court immediately reverse the decision of the Defendant because the defendant was not in a legal status when he ruled upon Plaintiff's hearing and that the court consider laws which were not referenced in either the defendant's finding(s) / ruling combined with Support Enforcement Services lack of laws cited in their illegal action to intercept Plaintiff's lottery winnings.
Furthermore, the Plaintiff is also seeking the immediate employment termination of the defendant. The public trust has been compromised because a state agency employs individuals without the required license credentials.
The Plaintiff is also requesting that the court impose heavy sanctions against the State Of Connecticut Department of Social Services Office of Legal Counsel, Regulations and Administrative Hearings for employing a hearing officer who is not legally authorized to conduct any services in any capacity due to non-compliance of required licensing.
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
No. 3:19-cv-01576 (VAB)