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DOC. NO. FBT-CV22-6116004S : SUPERIOR COURT
WILLIAM JOHN WATSON, EXECUTOR : J.D. OF FAIRFIELD
V. : AT BRIDGEPORT
GIUSEPPE BOCCANFUSCO : MARCH 21, 2024
EXHIBIT IN SUPPORT OF DEFENDANT’S PENDING
REQUEST TO AMEND (DKT. NO. 137.00) & REPLY
TO PLAINTIFF’S OBJECTION (DKT. NO. 140.00)
T: 203-908-3100 F: 203-908-3101
GANIM LEGAL, P.C.
BRIDGEPORT, CT 06604
2370 PARK AVENUE
To the extent an additional redlined copy of the Defendant’s Requested Amended
Answer is necessary, the Defendant, Giuseppe Boccanfuso (hereinafter, the “Defendant”), in the
above-captioned matter, hereby respectfully submits the attached Exhibit A is support of his
pending Request for Leave to Amend his Answer (Dkt. No. 137.00). The Defendant avers that a
copy of substantially the same redlined Answer (aside from minor formatting changes) was
submitted in connection with Defendant’s January 12, 2024, Request to Amend (Dkt. No.
129.00) and simultaneously filed February 23, 2024, Motion to Cite in Additional Parties (Dkt.
No. 136.00).
In an effort to avoid further delay in this matter, which has been mired in a procedural
morass for close to a year, the Defendant respectfully submits the attached Exhibit A containing
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a redlined copy of the Amended Answer in support of the Defendant’s pending Request for
Leave to Amend his Answer (Dkt. No. 137.00).
THE DEFENDANT,
GIUSEPPE BOCCANFUSO
By: /s/_406546__________________
Nicholas J. Taylor, Esquire
T: 203-908-3100 F: 203-908-3101
Ganim Legal, P.C.
GANIM LEGAL, P.C.
2370 Park Avenue
BRIDGEPORT, CT 06604
2370 PARK AVENUE
Bridgeport, CT 06604
Juris No. 406546
2
CERTIFICATION
This is to certify that the foregoing has been electronically filed with the Court and a
copy has been sent, via facsimile, email and/or first class, postage, paid and U.S. Mail, on this
date to the following counsel of record:
Colin B. Connor, Esq.
Russo and Rizio LLC
10 Sasco Hill Road
Fairfield, CT 06824
VIA FACSIMILE: (203) 255-6618
T: 203-908-3100 F: 203-908-3101
/s/ 406546__________________________
GANIM LEGAL, P.C.
Nicholas J. Taylor, Esq.
BRIDGEPORT, CT 06604
2370 PARK AVENUE
Commissioner of Superior Court
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EXHIBIT A
DOCKET NO: FBT-CV22-6116004 S : SUPERIOR COURT
WILLIAM JOHN WATSON, EXECUTOR OF : J.D. OF FAIRFIELD
THE ESTATE WILLIAM J. WATSON
V. : AT BRIDGEPORT
GIUSEPPE BOCCANFUSO : MAY FEBRUARY 23,
20243
T: 203-908-3100 F: 203-908-3101
AMENDED ANSWER, SPECIAL DEFENSES AND COUNTERCLAIM
GANIM LEGAL, P.C.
BRIDGEPORT, CT 06604
2370 PARK AVENUE
The defendant, Giuseppe Boccanfuso, files the following amended Aanswer,s Special
Defenses and Counterclaim to the Plaintiff’s allegations in the Complaint dated May 19, 2022.
FACTS (Common to All Counts)
1. As to paragraph number 1, The undersigned defendant has insufficient information
or knowledge upon which to form a belief as to the truth or falsity of this statement and therefore
leaves the plaintiff to his proof.
2. Admitted insofar as the Defendant is domiciled in the State of Connecticut. As to the
remainder, it is denied.Paragraph number 2 is denied.
3. Denied insofar as the Defendant did not execute the Mortgage and Mortgage Note.
As to the remainder, the Defendant leaves the Plaintiff to his proof.Paragraph number 3 is denied.
4. Document speaks for itself. Defendant leaves Plaintiff to his proof. As to paragraph
number 4, this allegation refers to and relies on the language of a document which speaks for
itself, and therefore the Defendant leaves the Plaintiff to his proof.
5. Paragraph number 5 is admitted.
6. Paragraph number 6 is denied.
7. Paragraph number 7 is admitted.
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COUNT ONE: Declaratory Judgement
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1-7. The Defendant hereby incorporates the answers to FACTS, Paragraphs 1 to 7, as
the answers to Count One, Paragraphs 1 to 7.repeats and re-alleges every admission, denial, and
denial of information alleged in Paragraphs 1 through 7 above as if fully set forth herein in
response to Paragraphs 1 through 7 of Count One of Plaintiff’s Complaint.
8-10. Paragraphs number 8 through 10 are denied.
COUNT TWO: Quiet Title Action Pursuant to C.G.S.A. §47-31
1-10. Defendant hereby incorporates the answers to Count One, Paragraphs 1 to 10, as
the answers to Count Two, Paragraphs 1 to 10.repeats and re-alleges every admission, denial,
and denial of information alleged in Paragraphs 1 through 10 above as if fully set forth herein in
response to Paragraphs 1 through 10 of Count Two of Plaintiff’s Complaint.
11. Paragraph number 11 is denied.
THE DEFENDANT,
GIUSEPPE BOCCANFUSO
By: ________________
Giuseppe Boccanfuso
104 Bayberry Lane
Easton, CT 06612
By: __/s/406546______________
Nicholas J. Taylor, Esq.
T: 203-908-3100 F: 203-908-3101
Ganim Legal P.C.
GANIM LEGAL, P.C.
2370 Park Avenue
BRIDGEPORT, CT 06604
2370 PARK AVENUE
Bridgeport, CT
(203) 908-3100
Juris No.: 406546
CERTIFICATION
I hereby certify that a copy of the foregoing was sent via first class, postage paid mail
to the following parties of record:
Vanessa R. Wambolt, Esq.
Russo & Rizio, LLC
10 Sasco Hill Road
Fairfield, CT 06824
T: 203-908-3100 F: 203-908-3101
GANIM LEGAL, P.C.
BRIDGEPORT, CT 06604
2370 PARK AVENUE
_________________
Giuseppe Boccanfuso
DOCKET NO.: FBT-CV22-6116004S : SUPERIOR COURT
WILLIAM JOHN WATSON, EXECUTOR : JUDICIAL DISTRICT OF
OF THE ESTATE OF WILLIAM J. WATSON
V. : FAIRFIELD AT BRIDGEPORT
GIUSEPPE BOCCANFUSCO : FEBRUARY 23, 2024
BY WAY OF SPECIAL DEFENSES
FIRST SPECIAL DEFENSE TO FIRST AND
SECOND COUNTS: BREACH OF CONTRACT.
T: 203-908-3100 F: 203-908-3101
Plaintiff breached the parties’ contract when he signed the Deed that purported to transfer
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the Subject Property to the Defendant, accepted the Defendant’s payment of more than $117,000,
in exchange, and then informed the Court that Defendant was not making payments and had no
legal interest in the Property, in an attempt to keep the Property and collect rent monies from the
Defendant’s tenant.
SECOND SPECIAL DEFENSE TO FIRST AND
SECOND COUNTS: NEGLIGENT MISREPRESENTATION.
In 2016, Plaintiff informed the Defendant that he, as executor of his father’s estate, was
going to sell the Subject Property to the Defendant, although the Probate Court had distributed
the Property and closed his father’s estate the previous year, in 2015.
In his role as executor, the Plaintiff: 1.) signed a Deed that purported to transfer the
Property; 2.) accepted the Defendant’s continuous and ongoing payments of more than $117,000;
3.) rejected the Defendant’s offer to pay off the total amount owed in a lump sum, although the
contract included the right to prepay the principal and interest, without penalty; and 4.) attempted
to obtain a Court order by falsely claiming that Defendant was not making payments, and his
father’s estate was the sole owner.
Plaintiff falsely misrepresented his intent to transfer legal title to the Defendant. Plaintiff
falsely indicated that he was acting as executor of his father’s estate, although the Probate Court
distributed the Subject Property and the estate was closed in 2015. He declined Defendant’s
request to correct mistake(s) in the legal document(s). He declined the Defendant’s offer to pay
off the amount owed in a lump sum payment. Defendant reasonably relied on the Plaintiff’s
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GANIM LEGAL, P.C.
misrepresentations.
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Plaintiff falsely informed the Court that Defendant “is not making payments” and “has
no interest in subject premises,” in a blatant attempt to: 1.) keep the Subject Property for himself;
2.) keep the Defendant’s money for himself; 3.) keep rent monies from the Defendant’s tenant;
and 4.) not pay the judgment lien for money owed to his former wife.
THIRD SPECIAL DEFENSE TO FIRST AND
SECOND COUNTS: FRAUDULENT MISREPRESENTATION.
In 2016, Plaintiff informed the Defendant that he, as executor of his father’s estate, was
going to sell the Subject Property to the Defendant, although the Probate Court had distributed
the Property and closed his father’s estate the previous year, in 2015.
In his role as executor, the Plaintiff: 1.) signed a Deed that purported to transfer the
Property; 2.) accepted the Defendant’s continuous and ongoing payments of more than $117,000;
3.) rejected the Defendant’s offer to pay off the total amount owed, although the contract
included the right to prepay the principal and interest, without penalty; and 4.) attempted to
obtain a Court order by falsely claiming that Defendant was not making payments, and his
father’s estate was the sole owner.
Plaintiff falsely misrepresented his intent to transfer legal title to the Defendant. Plaintiff
falsely indicated that he was acting as executor of his father’s estate, although the Probate Court
distributed the Subject Property and the estate was closed in 2015. He declined Defendant’s
request to correct mistake(s) in the legal document(s). He declined the Defendant’s offer to pay
T: 203-908-3100 F: 203-908-3101
GANIM LEGAL, P.C.
off the amount owed in a lump sum payment. Defendant reasonably relied on the Plaintiff’s
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misrepresentations.
Plaintiff falsely informed the Court that Defendant “is not making payments” and “has
no interest in subject premises,” in a blatant attempt to: 1.) keep the Subject Property for himself;
2.) keep the Defendant’s money for himself; 3.) keep rent monies from the Defendant’s tenant;
and 4.) not pay the judgment lien for money owed to his former wife.
FOURTH SPECIAL DEFENSE TO FIRST AND
SECOND COUNTS: FRAUD IN THE INDUCEMENT.
In 2016, Plaintiff informed the Defendant that he, as executor of his father’s estate, was
going to sell the Subject Property to the Defendant, although the Probate Court had distributed
the Property and closed his father’s estate the previous year, in 2015.
In his role as executor, the Plaintiff: 1.) signed a Deed that purported to transfer the
Property; 2.) accepted the Defendant’s continuous and ongoing payments of more than $117,000;
3.) rejected the Defendant’s offer to pay off the total amount owed, although the contract
included the right to prepay the principal and interest, without penalty; and 4.) attempted to
obtain a Court order by falsely claiming that Defendant was not making payments, and his
father’s estate was the sole owner.
Plaintiff falsely misrepresented his intent to transfer legal title to the Defendant. Plaintiff
falsely indicated that he was acting as executor of his father’s estate, although the Probate Court
distributed the Subject Property and the estate was closed in 2015. He declined Defendant’s
T: 203-908-3100 F: 203-908-3101
GANIM LEGAL, P.C.
request to correct mistake(s) in the legal document(s). He declined the Defendant’s offer to pay
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off the amount owed in a lump sum payment. Defendant reasonably relied on the Plaintiff’s
misrepresentations.
Plaintiff falsely informed the Court that Defendant “is not making payments” and “has
no interest in subject premises,” in a blatant attempt to: 1.) keep the Subject Property for himself;
2.) keep the Defendant’s money for himself; 3.) keep rent monies from the Defendant’s tenant;
and 4.) not pay the judgment lien for money owed to his former wife.
FIFTH SPECIAL DEFENSE TO FIRST AND
SECOND COUNTS: UNJUST ENRICHMENT.
Defendant conferred a benefit on the Plaintiff when he paid the Plaintiff more than
$117,000 to purchase the Subject Property. Plaintiff, individually or as executor of his father’s
estate, was unjustly enriched when he signed the Deed to transfer the Subject Property to the
Defendant, accepted the Defendant’s payments of more than $117,000, and then informed the
Court that Defendant was not making payments and lacked any ownership interest.
SIXTH SPECIAL DEFENSE TO FIRST AND
SECOND COUNTS: PROMISSORY ESTOPPEL
Plaintiff is promissorily estopped from claiming that Defendant lacks an ownership
interest in the Subject Property, as Plaintiff signed a Deed that expressly transferred the Subject
Property to the Defendant. Defendant reasonably and foreseeably relied on the Deed that the
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Plaintiff signed when Defendant paid the Plaintiff more than $117,000. Defendant also made
GANIM LEGAL, P.C.
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improvements, added a new roof, and paid the Property’s maintenance, taxes and insurance
costs. Plaintiff is promissorily estopped from claiming that he did not transfer the Subject
Property to the Defendant, and that Plaintiff or his father’s estate kept sole ownership of the
Property.
SEVENTH SPECIAL DEFENSE TO FIRST AND SECOND
COUNTS: LACHES.
Plaintiff is barred by laches from claiming that he or his father’s estate are entitled to a
declaratory judgment that they are the sole legal owners of the Subject Property. Plaintiff signed
the Deed that transferred the Property to the Defendant in April 2016. The Plaintiff’s decision to
delay commencement of a legal proceeding for six years and one month, i.e., until May 19, 2022,
constitutes an unreasonable delay. Defendant has been prejudiced by the delay, as he did not
preserve various documents that he might have used to defend his interests.
EIGHTH SPECIAL DEFENSE TO FIRST AND
SECOND COUNT: ABUSE OF LEGAL PROCESS.
Plaintiff misused the power of the court to perpetrate an injustice when 1.) he signed the
Deed that transferred the Subject Property to the Defendant; 2.) falsely informed the Court that
Defendant was not making payments and lacked an ownership interest; and 3.) obtained a Court
order and informed the Defendant’s tenant that Plaintiff or his father’s estate owned the Property,
when he knew that the Court order was based on false misrepresentations. Plaintiff signed
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GANIM LEGAL, P.C.
documents as executor of his father’s estate, although the Probate Court had distributed his
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father’s property and closed the estate. Plaintiff misused the Court’s power and abused the legal
process, in violation of the Restatement (Second) of Torts, §682.
NINTH SPECIAL DEFENSE TO FIRST AND
SECOND COUNT: LACK OF CLEAN HANDS.
Plaintiff lacks clean hands, as required to receive relief in equity, because he signed the
Deed that transferred the Property to the Defendant in his role as executor of his father’s estate,
although the Probate Court had distributed the Property and closed the estate the previous year,
falsely informed the Court that Defendant was not making payments and lacked an ownership
interest, obtained a Court order and then informed the Defendant’s tenant that Plaintiff or his
father’s estate owned the Property, in an attempt to receive rent money. Plaintiff misused the
Court’s power and abused the legal process, in violation of the Restatement (Second) of Torts,
§682, and he lacks clean hands.
THE DEFENDANT,
GIUSEPPE BOCCANFUSO
By: __/s/406546______________
Nicholas J. Taylor, Esq.
Ganim Legal P.C.
2370 Park Avenue
Bridgeport, CT
(203) 908-3100
Juris No.: 406546
T: 203-908-3100 F: 203-908-3101
GANIM LEGAL, P.C.
BRIDGEPORT, CT 06604
2370 PARK AVENUE
DOCKET NO.: FBT-CV22-6116004S : SUPERIOR COURT
WILLIAM JOHN WATSON, EXECUTOR : JUDICIAL DISTRICT OF
OF THE ESTATE OF WILLIAM J. WATSON
V. : FAIRFIELD AT BRIDGEPORT
GIUSEPPE BOCCANFUSCO : FEBRUARY 23, 2024
COUNTERCLAIM
COUNT ONE: (Giuseppe Boccanfuso v. William J. Watson, Executor): Breach of
Contract as to the Defendant, William J. Watson, Executor.
T: 203-908-3100 F: 203-908-3101
1. On or about May 20, 2013, the Counterclaim Defendant, William J. Watson
GANIM LEGAL, P.C.
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(hereinafter, “Watson” or the “Counterclaim Defendant”), became the executor of his
father’s estate. His father had owned 266 Linley Drive in Fairfield, Connecticut
(hereinafter, the “Property”) until he passed.
2. On or about November 13, 2015, William Watson’s former wife, Paula Watson, filed
a judgment lien against the Property (hereinafter, the “Judgment Lien”).
3. On or about November 17, 2015, the Probate Court in Fairfield, Connecticut distributed
the Property to William Watson, individually, and closed the estate.
4. Even though the Property had been distributed to him individually, on or about April
11, 2016, William Watson, as executor of his father’s estate, “granted” and conveyed
the Property to Giuseppe Boccanfuso (hereinafter, “Boccanfuso” or the “Counterclaim
Plaintiff”) via a “Mortgage” Deed.
5. The “Mortgage” Deed stated that “William John Watson, Executor of the Estate . . .
grants to Giuseppe Boccanfuso . . . all that certain piece or parcel of real property
known and designated as 266 Linley Drive.” (Emphasis added.)
6. The legal document should have been titled “Mortgage Deed and Warranty Deed” as
it indicated both the amount of the debt owed and served to transfer ownership from
Watson or his father’s estate to Boccanfuso.
7. Watson also signed a Mortgage Note that stated, “William John Watson, Executor of
the Estate . . . promises to pay to . . . Giuseppe Boccanfuso . . . the sum of . . . $275,000
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GANIM LEGAL, P.C.
. . . interest free.” The Mortgage Note included “a reasonable attorney’s fee in the event
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of any legal proceedings” and “the right to prepay the principal and interest.”
(Emphasis added.)
8. The Mortgage Note appears to have switched the parties’ names, as it was Boccanfuso
who made continuous, periodic and ongoing payments to Watson or his father’s estate
to purchase the Property.
9. If, however, the Mortgage Note had correctly stated the terms, then Boccanfuso had a
potential cause of action against Watson or his father’s estate for six years after the
legal documents were signed, i.e., until April 2022, as a result of their failure to pay
him $275,000.
10. Watson fraudulently concealed his cause of action and waited until six years after he
signed the “Mortgage” Deed and Note to file the subject action.
11. Boccanfuso understood from numerous conversations and texts with Watson that a.)
Watson, or his father’s estate, was selling the Property to him; b.) Boccanfuso was
going to make continuous, periodic and ongoing payments over time that would total
$275,000; and c.) the 2016 Mortgage Deed and Note were legal documents that
properly transferred the Property.
12. When Boccanfuso asked Watson to permit him to pay off the amount owed in a lump
sum, and to amend the Mortgage Deed and Note, Watson declined, although the
contract included the right to pre-pay the principal and interest.
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GANIM LEGAL, P.C.
13. Watson indicated that he did not want to receive a lump sum or amend the documents
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as, when the property formally changed hands, and the transfer was recorded, Watson
might be required to pay a judgment lien filed by his former wife, Paula Watson.
14. Boccanfuso believed that he was the owner and acted as such, taking occupancy, paying
taxes and utility bills, purchasing homeowner’s insurance, making improvements and
repairs, working on the roof and paying Watson or his father’s estate more than
$117,000.
15. Watson’s Complaint misrepresented key facts in his Complaint and incorrectly stated
that “Boccanfuso executed a Mortgage and Mortgage Note,” although Watson was the
one who signed.
16. Watson misrepresented key facts in his Complaint and incorrectly stated that
“Defendant [Boccanfuso] is not making payments” when, in fact, Boccanfuso made
continuous, periodic and ongoing payments and paid more than $117,000 toward the
purchase price.
17. William Watson’s Complaint misrepresented key facts and incorrectly stated that
“Defendant [Boccanfuso] has no interest in subject premises,” although the
“Mortgage” Deed explicitly stated that “Watson . . . grants to Giuseppe Boccanfuso . .
. all that certain piece or parcel of real property known and designated as 266 Linley
Drive.”
18. Watson’s Complaint sought a declaratory judgment that “Defendant [Boccanfuso] does
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not have an interest in subject premises” and an order vesting title to the Property in
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him, or his father’s estate.
19. William Watson breached the parties’ contract(s) when he failed to properly transfer
the Subject Property to Boccanfuso, so that no question existed as to ownership.
20. William Watson breached the parties’ contract(s) when he denied Boccanfuso’s request
to pay off the amount owed in a lump sum, although the Mortgage Note permitted the
pre-payment of principal and interest, without penalty.
21. Watson breached the parties’ contract(s) when he filed the subject lawsuit so that he or
his father’s estate could keep the Property, keep the money paid by Boccanfuso, collect
rent from a tenant, and not be required to pay the judgment lien to his former wife.
22. William Watson negligently or falsely misrepresented his intent to transfer legal title
and then denied requests to permit Boccanfuso to pay off the amount owed and to
correct the legal documents.
23. William Watson’s fraudulent conduct, in signing the “Mortgage” Deed and Note as
“executor,” when he knew that the Probate Court had distributed the property to him,
individually, served to toll the statute of limitations.
24. Watson’s fraudulent conduct, in falsely misrepresenting his intent transfer legal title to
Boccanfuso, served to toll the statute of limitations.
COUNT TWO (Giuseppe Boccanfuso v. William J. Watson, Executor): Negligent
Misrepresentation as to the Defendant, William J. Watson, Executor.
T: 203-908-3100 F: 203-908-3101
1-24. Paragraphs 1 through 24 of Count One are hereby incorporated and made Paragraphs 1
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through 24 of this Count Two.
25. William Watson, acting individually or as estate executor, agreed to sell the Subject
Property to Boccanfuso.
26. William Watson, acting individually or as estate executor, tried to shoehorn a warranty
deed into a “Mortgage” Deed. The “Mortgage” Deed explicitly states that Watson, as
executor of his father’s estate, “grants” the Property to Boccanfuso, thus transforming
it into a de facto warranty deed.
27. Boccanfuso relied on representation(s) from Watson that he was selling the Property to
him and paid more than $117,000 toward the purchase price. He also paid the taxes,
made improvements, added a new roof, and paid for maintenance and insurance.
28. Watson’s misrepresentations harmed Boccanfuso, as Watson now claims that either he
or the estate kept legal title and that Boccanfuso lacks any ownership interest.
COUNT THREE (Giuseppe Boccanfuso v. William J. Watson, Executor): Fraudulent
Misrepresentation as to the Defendant, William J. Watson, Executor.
1-24. Paragraphs 1 through 24 of Count One are hereby incorporated and made Paragraphs 1
through 24 of this Count Two.
25. William Watson, acting individually or as estate executor, agreed to sell the Subject
Property to Boccanfuso.
26. William Watson, acting individually or as estate executor, tried to shoehorn a
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warranty deed into a “Mortgage” Deed. The “Mortgage” Deed explicitly states that
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Watson, as executor of his father’s estate, “grants” the Property to Boccanfuso, thus
transforming it into a de facto warranty deed.
27. Boccanfuso relied on representation(s) from Watson that he was selling the
Property to him and paid more than $117,000 toward the purchase price. He also paid
the taxes, made improvements, added a new roof, and paid for maintenance and
insurance.
28. Watson’s misrepresentations harmed Boccanfuso, as Watson now claims that either
he or the estate kept legal title and that Boccanfuso lacks any ownership interest.
COUNT FOUR (Giuseppe Boccanfuso v. William J. Watson, Executor): Fraud in the
Inducement as to the Defendant, William J. Watson, Executor.
1-24. Paragraphs 1 through 24 of Count One are hereby incorporated and made Paragraphs 1
through 24 of this Count Two.
25. William Watson, acting individually or as estate executor, agreed to sell the Subject
Property to Boccanfuso.
26. William Watson, acting individually or as estate executor, tried to shoehorn a warranty
deed into a “Mortgage” Deed. The “Mortgage” Deed explicitly states that Watson, as
executor of his father’s estate, “grants” the Property to Boccanfuso, thus transforming
it into a de facto warranty deed.
27. Boccanfuso relied on representation(s) from Watson that he was selling the Property to
him and paid more than $117,000 toward the purchase price. He also paid the taxes, made
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GANIM LEGAL, P.C.
improvements, added a new roof, and paid for maintenance and insurance.
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28. Watson’s misrepresentations harmed Boccanfuso, as Watson now claims that either he
or the estate kept legal title and that Boccanfuso lacks any ownership interest.
COUNT FIVE (Giuseppe Boccanfuso v. William J. Watson, Executor): Unjust Enrichment
as to the Defendant, William J. Watson, Executor.
1-24. Paragraphs 1 through 24 of Count One are hereby incorporated and made Paragraphs 1
through 24 of this Count Five.
25. Watson is denying that he transferred any ownership interest to Boccanfuso in April
Preview
DOC. NO. FBT-CV22-6116004S : SUPERIOR COURT WILLIAM JOHN WATSON, EXECUTOR : J.D. OF FAIRFIELD V. : AT BRIDGEPORT GIUSEPPE BOCCANFUSCO : MARCH 21, 2024 EXHIBIT IN SUPPORT OF DEFENDANT’S PENDING REQUEST TO AMEND (DKT. NO. 137.00) & REPLY TO PLAINTIFF’S OBJECTION (DKT. NO. 140.00) T: 203-908-3100 F: 203-908-3101 GANIM LEGAL, P.C. BRIDGEPORT, CT 06604 2370 PARK AVENUE To the extent an additional redlined copy of the Defendant’s Requested Amended Answer is necessary, the Defendant, Giuseppe Boccanfuso (hereinafter, the “Defendant”), in the above-captioned matter, hereby respectfully submits the attached Exhibit A is support of his pending Request for Leave to Amend his Answer (Dkt. No. 137.00). The Defendant avers that a copy of substantially the same redlined Answer (aside from minor formatting changes) was submitted in connection with Defendant’s January 12, 2024, Request to Amend (Dkt. No. 129.00) and simultaneously filed February 23, 2024, Motion to Cite in Additional Parties (Dkt. No. 136.00). In an effort to avoid further delay in this matter, which has been mired in a procedural morass for close to a year, the Defendant respectfully submits the attached Exhibit A containing 1 a redlined copy of the Amended Answer in support of the Defendant’s pending Request for Leave to Amend his Answer (Dkt. No. 137.00). THE DEFENDANT, GIUSEPPE BOCCANFUSO By: /s/_406546__________________ Nicholas J. Taylor, Esquire T: 203-908-3100 F: 203-908-3101 Ganim Legal, P.C. GANIM LEGAL, P.C. 2370 Park Avenue BRIDGEPORT, CT 06604 2370 PARK AVENUE Bridgeport, CT 06604 Juris No. 406546 2 CERTIFICATION This is to certify that the foregoing has been electronically filed with the Court and a copy has been sent, via facsimile, email and/or first class, postage, paid and U.S. Mail, on this date to the following counsel of record: Colin B. Connor, Esq. Russo and Rizio LLC 10 Sasco Hill Road Fairfield, CT 06824 VIA FACSIMILE: (203) 255-6618 T: 203-908-3100 F: 203-908-3101 /s/ 406546__________________________ GANIM LEGAL, P.C. Nicholas J. Taylor, Esq. BRIDGEPORT, CT 06604 2370 PARK AVENUE Commissioner of Superior Court 3 EXHIBIT A DOCKET NO: FBT-CV22-6116004 S : SUPERIOR COURT WILLIAM JOHN WATSON, EXECUTOR OF : J.D. OF FAIRFIELD THE ESTATE WILLIAM J. WATSON V. : AT BRIDGEPORT GIUSEPPE BOCCANFUSO : MAY FEBRUARY 23, 20243 T: 203-908-3100 F: 203-908-3101 AMENDED ANSWER, SPECIAL DEFENSES AND COUNTERCLAIM GANIM LEGAL, P.C. BRIDGEPORT, CT 06604 2370 PARK AVENUE The defendant, Giuseppe Boccanfuso, files the following amended Aanswer,s Special Defenses and Counterclaim to the Plaintiff’s allegations in the Complaint dated May 19, 2022. FACTS (Common to All Counts) 1. As to paragraph number 1, The undersigned defendant has insufficient information or knowledge upon which to form a belief as to the truth or falsity of this statement and therefore leaves the plaintiff to his proof. 2. Admitted insofar as the Defendant is domiciled in the State of Connecticut. As to the remainder, it is denied.Paragraph number 2 is denied. 3. Denied insofar as the Defendant did not execute the Mortgage and Mortgage Note. As to the remainder, the Defendant leaves the Plaintiff to his proof.Paragraph number 3 is denied. 4. Document speaks for itself. Defendant leaves Plaintiff to his proof. As to paragraph number 4, this allegation refers to and relies on the language of a document which speaks for itself, and therefore the Defendant leaves the Plaintiff to his proof. 5. Paragraph number 5 is admitted. 6. Paragraph number 6 is denied. 7. Paragraph number 7 is admitted. T: 203-908-3100 F: 203-908-3101 GANIM LEGAL, P.C. COUNT ONE: Declaratory Judgement BRIDGEPORT, CT 06604 2370 PARK AVENUE 1-7. The Defendant hereby incorporates the answers to FACTS, Paragraphs 1 to 7, as the answers to Count One, Paragraphs 1 to 7.repeats and re-alleges every admission, denial, and denial of information alleged in Paragraphs 1 through 7 above as if fully set forth herein in response to Paragraphs 1 through 7 of Count One of Plaintiff’s Complaint. 8-10. Paragraphs number 8 through 10 are denied. COUNT TWO: Quiet Title Action Pursuant to C.G.S.A. §47-31 1-10. Defendant hereby incorporates the answers to Count One, Paragraphs 1 to 10, as the answers to Count Two, Paragraphs 1 to 10.repeats and re-alleges every admission, denial, and denial of information alleged in Paragraphs 1 through 10 above as if fully set forth herein in response to Paragraphs 1 through 10 of Count Two of Plaintiff’s Complaint. 11. Paragraph number 11 is denied. THE DEFENDANT, GIUSEPPE BOCCANFUSO By: ________________ Giuseppe Boccanfuso 104 Bayberry Lane Easton, CT 06612 By: __/s/406546______________ Nicholas J. Taylor, Esq. T: 203-908-3100 F: 203-908-3101 Ganim Legal P.C. GANIM LEGAL, P.C. 2370 Park Avenue BRIDGEPORT, CT 06604 2370 PARK AVENUE Bridgeport, CT (203) 908-3100 Juris No.: 406546 CERTIFICATION I hereby certify that a copy of the foregoing was sent via first class, postage paid mail to the following parties of record: Vanessa R. Wambolt, Esq. Russo & Rizio, LLC 10 Sasco Hill Road Fairfield, CT 06824 T: 203-908-3100 F: 203-908-3101 GANIM LEGAL, P.C. BRIDGEPORT, CT 06604 2370 PARK AVENUE _________________ Giuseppe Boccanfuso DOCKET NO.: FBT-CV22-6116004S : SUPERIOR COURT WILLIAM JOHN WATSON, EXECUTOR : JUDICIAL DISTRICT OF OF THE ESTATE OF WILLIAM J. WATSON V. : FAIRFIELD AT BRIDGEPORT GIUSEPPE BOCCANFUSCO : FEBRUARY 23, 2024 BY WAY OF SPECIAL DEFENSES FIRST SPECIAL DEFENSE TO FIRST AND SECOND COUNTS: BREACH OF CONTRACT. T: 203-908-3100 F: 203-908-3101 Plaintiff breached the parties’ contract when he signed the Deed that purported to transfer GANIM LEGAL, P.C. BRIDGEPORT, CT 06604 2370 PARK AVENUE the Subject Property to the Defendant, accepted the Defendant’s payment of more than $117,000, in exchange, and then informed the Court that Defendant was not making payments and had no legal interest in the Property, in an attempt to keep the Property and collect rent monies from the Defendant’s tenant. SECOND SPECIAL DEFENSE TO FIRST AND SECOND COUNTS: NEGLIGENT MISREPRESENTATION. In 2016, Plaintiff informed the Defendant that he, as executor of his father’s estate, was going to sell the Subject Property to the Defendant, although the Probate Court had distributed the Property and closed his father’s estate the previous year, in 2015. In his role as executor, the Plaintiff: 1.) signed a Deed that purported to transfer the Property; 2.) accepted the Defendant’s continuous and ongoing payments of more than $117,000; 3.) rejected the Defendant’s offer to pay off the total amount owed in a lump sum, although the contract included the right to prepay the principal and interest, without penalty; and 4.) attempted to obtain a Court order by falsely claiming that Defendant was not making payments, and his father’s estate was the sole owner. Plaintiff falsely misrepresented his intent to transfer legal title to the Defendant. Plaintiff falsely indicated that he was acting as executor of his father’s estate, although the Probate Court distributed the Subject Property and the estate was closed in 2015. He declined Defendant’s request to correct mistake(s) in the legal document(s). He declined the Defendant’s offer to pay off the amount owed in a lump sum payment. Defendant reasonably relied on the Plaintiff’s T: 203-908-3100 F: 203-908-3101 GANIM LEGAL, P.C. misrepresentations. BRIDGEPORT, CT 06604 2370 PARK AVENUE Plaintiff falsely informed the Court that Defendant “is not making payments” and “has no interest in subject premises,” in a blatant attempt to: 1.) keep the Subject Property for himself; 2.) keep the Defendant’s money for himself; 3.) keep rent monies from the Defendant’s tenant; and 4.) not pay the judgment lien for money owed to his former wife. THIRD SPECIAL DEFENSE TO FIRST AND SECOND COUNTS: FRAUDULENT MISREPRESENTATION. In 2016, Plaintiff informed the Defendant that he, as executor of his father’s estate, was going to sell the Subject Property to the Defendant, although the Probate Court had distributed the Property and closed his father’s estate the previous year, in 2015. In his role as executor, the Plaintiff: 1.) signed a Deed that purported to transfer the Property; 2.) accepted the Defendant’s continuous and ongoing payments of more than $117,000; 3.) rejected the Defendant’s offer to pay off the total amount owed, although the contract included the right to prepay the principal and interest, without penalty; and 4.) attempted to obtain a Court order by falsely claiming that Defendant was not making payments, and his father’s estate was the sole owner. Plaintiff falsely misrepresented his intent to transfer legal title to the Defendant. Plaintiff falsely indicated that he was acting as executor of his father’s estate, although the Probate Court distributed the Subject Property and the estate was closed in 2015. He declined Defendant’s request to correct mistake(s) in the legal document(s). He declined the Defendant’s offer to pay T: 203-908-3100 F: 203-908-3101 GANIM LEGAL, P.C. off the amount owed in a lump sum payment. Defendant reasonably relied on the Plaintiff’s BRIDGEPORT, CT 06604 2370 PARK AVENUE misrepresentations. Plaintiff falsely informed the Court that Defendant “is not making payments” and “has no interest in subject premises,” in a blatant attempt to: 1.) keep the Subject Property for himself; 2.) keep the Defendant’s money for himself; 3.) keep rent monies from the Defendant’s tenant; and 4.) not pay the judgment lien for money owed to his former wife. FOURTH SPECIAL DEFENSE TO FIRST AND SECOND COUNTS: FRAUD IN THE INDUCEMENT. In 2016, Plaintiff informed the Defendant that he, as executor of his father’s estate, was going to sell the Subject Property to the Defendant, although the Probate Court had distributed the Property and closed his father’s estate the previous year, in 2015. In his role as executor, the Plaintiff: 1.) signed a Deed that purported to transfer the Property; 2.) accepted the Defendant’s continuous and ongoing payments of more than $117,000; 3.) rejected the Defendant’s offer to pay off the total amount owed, although the contract included the right to prepay the principal and interest, without penalty; and 4.) attempted to obtain a Court order by falsely claiming that Defendant was not making payments, and his father’s estate was the sole owner. Plaintiff falsely misrepresented his intent to transfer legal title to the Defendant. Plaintiff falsely indicated that he was acting as executor of his father’s estate, although the Probate Court distributed the Subject Property and the estate was closed in 2015. He declined Defendant’s T: 203-908-3100 F: 203-908-3101 GANIM LEGAL, P.C. request to correct mistake(s) in the legal document(s). He declined the Defendant’s offer to pay BRIDGEPORT, CT 06604 2370 PARK AVENUE off the amount owed in a lump sum payment. Defendant reasonably relied on the Plaintiff’s misrepresentations. Plaintiff falsely informed the Court that Defendant “is not making payments” and “has no interest in subject premises,” in a blatant attempt to: 1.) keep the Subject Property for himself; 2.) keep the Defendant’s money for himself; 3.) keep rent monies from the Defendant’s tenant; and 4.) not pay the judgment lien for money owed to his former wife. FIFTH SPECIAL DEFENSE TO FIRST AND SECOND COUNTS: UNJUST ENRICHMENT. Defendant conferred a benefit on the Plaintiff when he paid the Plaintiff more than $117,000 to purchase the Subject Property. Plaintiff, individually or as executor of his father’s estate, was unjustly enriched when he signed the Deed to transfer the Subject Property to the Defendant, accepted the Defendant’s payments of more than $117,000, and then informed the Court that Defendant was not making payments and lacked any ownership interest. SIXTH SPECIAL DEFENSE TO FIRST AND SECOND COUNTS: PROMISSORY ESTOPPEL Plaintiff is promissorily estopped from claiming that Defendant lacks an ownership interest in the Subject Property, as Plaintiff signed a Deed that expressly transferred the Subject Property to the Defendant. Defendant reasonably and foreseeably relied on the Deed that the T: 203-908-3100 F: 203-908-3101 Plaintiff signed when Defendant paid the Plaintiff more than $117,000. Defendant also made GANIM LEGAL, P.C. BRIDGEPORT, CT 06604 2370 PARK AVENUE improvements, added a new roof, and paid the Property’s maintenance, taxes and insurance costs. Plaintiff is promissorily estopped from claiming that he did not transfer the Subject Property to the Defendant, and that Plaintiff or his father’s estate kept sole ownership of the Property. SEVENTH SPECIAL DEFENSE TO FIRST AND SECOND COUNTS: LACHES. Plaintiff is barred by laches from claiming that he or his father’s estate are entitled to a declaratory judgment that they are the sole legal owners of the Subject Property. Plaintiff signed the Deed that transferred the Property to the Defendant in April 2016. The Plaintiff’s decision to delay commencement of a legal proceeding for six years and one month, i.e., until May 19, 2022, constitutes an unreasonable delay. Defendant has been prejudiced by the delay, as he did not preserve various documents that he might have used to defend his interests. EIGHTH SPECIAL DEFENSE TO FIRST AND SECOND COUNT: ABUSE OF LEGAL PROCESS. Plaintiff misused the power of the court to perpetrate an injustice when 1.) he signed the Deed that transferred the Subject Property to the Defendant; 2.) falsely informed the Court that Defendant was not making payments and lacked an ownership interest; and 3.) obtained a Court order and informed the Defendant’s tenant that Plaintiff or his father’s estate owned the Property, when he knew that the Court order was based on false misrepresentations. Plaintiff signed T: 203-908-3100 F: 203-908-3101 GANIM LEGAL, P.C. documents as executor of his father’s estate, although the Probate Court had distributed his BRIDGEPORT, CT 06604 2370 PARK AVENUE father’s property and closed the estate. Plaintiff misused the Court’s power and abused the legal process, in violation of the Restatement (Second) of Torts, §682. NINTH SPECIAL DEFENSE TO FIRST AND SECOND COUNT: LACK OF CLEAN HANDS. Plaintiff lacks clean hands, as required to receive relief in equity, because he signed the Deed that transferred the Property to the Defendant in his role as executor of his father’s estate, although the Probate Court had distributed the Property and closed the estate the previous year, falsely informed the Court that Defendant was not making payments and lacked an ownership interest, obtained a Court order and then informed the Defendant’s tenant that Plaintiff or his father’s estate owned the Property, in an attempt to receive rent money. Plaintiff misused the Court’s power and abused the legal process, in violation of the Restatement (Second) of Torts, §682, and he lacks clean hands. THE DEFENDANT, GIUSEPPE BOCCANFUSO By: __/s/406546______________ Nicholas J. Taylor, Esq. Ganim Legal P.C. 2370 Park Avenue Bridgeport, CT (203) 908-3100 Juris No.: 406546 T: 203-908-3100 F: 203-908-3101 GANIM LEGAL, P.C. BRIDGEPORT, CT 06604 2370 PARK AVENUE DOCKET NO.: FBT-CV22-6116004S : SUPERIOR COURT WILLIAM JOHN WATSON, EXECUTOR : JUDICIAL DISTRICT OF OF THE ESTATE OF WILLIAM J. WATSON V. : FAIRFIELD AT BRIDGEPORT GIUSEPPE BOCCANFUSCO : FEBRUARY 23, 2024 COUNTERCLAIM COUNT ONE: (Giuseppe Boccanfuso v. William J. Watson, Executor): Breach of Contract as to the Defendant, William J. Watson, Executor. T: 203-908-3100 F: 203-908-3101 1. On or about May 20, 2013, the Counterclaim Defendant, William J. Watson GANIM LEGAL, P.C. BRIDGEPORT, CT 06604 2370 PARK AVENUE (hereinafter, “Watson” or the “Counterclaim Defendant”), became the executor of his father’s estate. His father had owned 266 Linley Drive in Fairfield, Connecticut (hereinafter, the “Property”) until he passed. 2. On or about November 13, 2015, William Watson’s former wife, Paula Watson, filed a judgment lien against the Property (hereinafter, the “Judgment Lien”). 3. On or about November 17, 2015, the Probate Court in Fairfield, Connecticut distributed the Property to William Watson, individually, and closed the estate. 4. Even though the Property had been distributed to him individually, on or about April 11, 2016, William Watson, as executor of his father’s estate, “granted” and conveyed the Property to Giuseppe Boccanfuso (hereinafter, “Boccanfuso” or the “Counterclaim Plaintiff”) via a “Mortgage” Deed. 5. The “Mortgage” Deed stated that “William John Watson, Executor of the Estate . . . grants to Giuseppe Boccanfuso . . . all that certain piece or parcel of real property known and designated as 266 Linley Drive.” (Emphasis added.) 6. The legal document should have been titled “Mortgage Deed and Warranty Deed” as it indicated both the amount of the debt owed and served to transfer ownership from Watson or his father’s estate to Boccanfuso. 7. Watson also signed a Mortgage Note that stated, “William John Watson, Executor of the Estate . . . promises to pay to . . . Giuseppe Boccanfuso . . . the sum of . . . $275,000 T: 203-908-3100 F: 203-908-3101 GANIM LEGAL, P.C. . . . interest free.” The Mortgage Note included “a reasonable attorney’s fee in the event BRIDGEPORT, CT 06604 2370 PARK AVENUE of any legal proceedings” and “the right to prepay the principal and interest.” (Emphasis added.) 8. The Mortgage Note appears to have switched the parties’ names, as it was Boccanfuso who made continuous, periodic and ongoing payments to Watson or his father’s estate to purchase the Property. 9. If, however, the Mortgage Note had correctly stated the terms, then Boccanfuso had a potential cause of action against Watson or his father’s estate for six years after the legal documents were signed, i.e., until April 2022, as a result of their failure to pay him $275,000. 10. Watson fraudulently concealed his cause of action and waited until six years after he signed the “Mortgage” Deed and Note to file the subject action. 11. Boccanfuso understood from numerous conversations and texts with Watson that a.) Watson, or his father’s estate, was selling the Property to him; b.) Boccanfuso was going to make continuous, periodic and ongoing payments over time that would total $275,000; and c.) the 2016 Mortgage Deed and Note were legal documents that properly transferred the Property. 12. When Boccanfuso asked Watson to permit him to pay off the amount owed in a lump sum, and to amend the Mortgage Deed and Note, Watson declined, although the contract included the right to pre-pay the principal and interest. T: 203-908-3100 F: 203-908-3101 GANIM LEGAL, P.C. 13. Watson indicated that he did not want to receive a lump sum or amend the documents BRIDGEPORT, CT 06604 2370 PARK AVENUE as, when the property formally changed hands, and the transfer was recorded, Watson might be required to pay a judgment lien filed by his former wife, Paula Watson. 14. Boccanfuso believed that he was the owner and acted as such, taking occupancy, paying taxes and utility bills, purchasing homeowner’s insurance, making improvements and repairs, working on the roof and paying Watson or his father’s estate more than $117,000. 15. Watson’s Complaint misrepresented key facts in his Complaint and incorrectly stated that “Boccanfuso executed a Mortgage and Mortgage Note,” although Watson was the one who signed. 16. Watson misrepresented key facts in his Complaint and incorrectly stated that “Defendant [Boccanfuso] is not making payments” when, in fact, Boccanfuso made continuous, periodic and ongoing payments and paid more than $117,000 toward the purchase price. 17. William Watson’s Complaint misrepresented key facts and incorrectly stated that “Defendant [Boccanfuso] has no interest in subject premises,” although the “Mortgage” Deed explicitly stated that “Watson . . . grants to Giuseppe Boccanfuso . . . all that certain piece or parcel of real property known and designated as 266 Linley Drive.” 18. Watson’s Complaint sought a declaratory judgment that “Defendant [Boccanfuso] does T: 203-908-3100 F: 203-908-3101 GANIM LEGAL, P.C. not have an interest in subject premises” and an order vesting title to the Property in BRIDGEPORT, CT 06604 2370 PARK AVENUE him, or his father’s estate. 19. William Watson breached the parties’ contract(s) when he failed to properly transfer the Subject Property to Boccanfuso, so that no question existed as to ownership. 20. William Watson breached the parties’ contract(s) when he denied Boccanfuso’s request to pay off the amount owed in a lump sum, although the Mortgage Note permitted the pre-payment of principal and interest, without penalty. 21. Watson breached the parties’ contract(s) when he filed the subject lawsuit so that he or his father’s estate could keep the Property, keep the money paid by Boccanfuso, collect rent from a tenant, and not be required to pay the judgment lien to his former wife. 22. William Watson negligently or falsely misrepresented his intent to transfer legal title and then denied requests to permit Boccanfuso to pay off the amount owed and to correct the legal documents. 23. William Watson’s fraudulent conduct, in signing the “Mortgage” Deed and Note as “executor,” when he knew that the Probate Court had distributed the property to him, individually, served to toll the statute of limitations. 24. Watson’s fraudulent conduct, in falsely misrepresenting his intent transfer legal title to Boccanfuso, served to toll the statute of limitations. COUNT TWO (Giuseppe Boccanfuso v. William J. Watson, Executor): Negligent Misrepresentation as to the Defendant, William J. Watson, Executor. T: 203-908-3100 F: 203-908-3101 1-24. Paragraphs 1 through 24 of Count One are hereby incorporated and made Paragraphs 1 GANIM LEGAL, P.C. BRIDGEPORT, CT 06604 2370 PARK AVENUE through 24 of this Count Two. 25. William Watson, acting individually or as estate executor, agreed to sell the Subject Property to Boccanfuso. 26. William Watson, acting individually or as estate executor, tried to shoehorn a warranty deed into a “Mortgage” Deed. The “Mortgage” Deed explicitly states that Watson, as executor of his father’s estate, “grants” the Property to Boccanfuso, thus transforming it into a de facto warranty deed. 27. Boccanfuso relied on representation(s) from Watson that he was selling the Property to him and paid more than $117,000 toward the purchase price. He also paid the taxes, made improvements, added a new roof, and paid for maintenance and insurance. 28. Watson’s misrepresentations harmed Boccanfuso, as Watson now claims that either he or the estate kept legal title and that Boccanfuso lacks any ownership interest. COUNT THREE (Giuseppe Boccanfuso v. William J. Watson, Executor): Fraudulent Misrepresentation as to the Defendant, William J. Watson, Executor. 1-24. Paragraphs 1 through 24 of Count One are hereby incorporated and made Paragraphs 1 through 24 of this Count Two. 25. William Watson, acting individually or as estate executor, agreed to sell the Subject Property to Boccanfuso. 26. William Watson, acting individually or as estate executor, tried to shoehorn a T: 203-908-3100 F: 203-908-3101 warranty deed into a “Mortgage” Deed. The “Mortgage” Deed explicitly states that GANIM LEGAL, P.C. BRIDGEPORT, CT 06604 2370 PARK AVENUE Watson, as executor of his father’s estate, “grants” the Property to Boccanfuso, thus transforming it into a de facto warranty deed. 27. Boccanfuso relied on representation(s) from Watson that he was selling the Property to him and paid more than $117,000 toward the purchase price. He also paid the taxes, made improvements, added a new roof, and paid for maintenance and insurance. 28. Watson’s misrepresentations harmed Boccanfuso, as Watson now claims that either he or the estate kept legal title and that Boccanfuso lacks any ownership interest. COUNT FOUR (Giuseppe Boccanfuso v. William J. Watson, Executor): Fraud in the Inducement as to the Defendant, William J. Watson, Executor. 1-24. Paragraphs 1 through 24 of Count One are hereby incorporated and made Paragraphs 1 through 24 of this Count Two. 25. William Watson, acting individually or as estate executor, agreed to sell the Subject Property to Boccanfuso. 26. William Watson, acting individually or as estate executor, tried to shoehorn a warranty deed into a “Mortgage” Deed. The “Mortgage” Deed explicitly states that Watson, as executor of his father’s estate, “grants” the Property to Boccanfuso, thus transforming it into a de facto warranty deed. 27. Boccanfuso relied on representation(s) from Watson that he was selling the Property to him and paid more than $117,000 toward the purchase price. He also paid the taxes, made T: 203-908-3100 F: 203-908-3101 GANIM LEGAL, P.C. improvements, added a new roof, and paid for maintenance and insurance. BRIDGEPORT, CT 06604 2370 PARK AVENUE 28. Watson’s misrepresentations harmed Boccanfuso, as Watson now claims that either he or the estate kept legal title and that Boccanfuso lacks any ownership interest. COUNT FIVE (Giuseppe Boccanfuso v. William J. Watson, Executor): Unjust Enrichment as to the Defendant, William J. Watson, Executor. 1-24. Paragraphs 1 through 24 of Count One are hereby incorporated and made Paragraphs 1 through 24 of this Count Five. 25. Watson is denying that he transferred any ownership interest to Boccanfuso in April