DOCKET NO.

FST-FA-17-5016797-S : SUPERIOR COURT

JENNIFER DULOS : J.D. OF STAMFORD/NORWALK

VS. : AT STAMFORD

FOTIS DULOS : AUGUST 31, 2019

INTERVENOR’S REPLY TO DEFENDANT’S MOTION FOR PSYCHOLOGICAL

EVALUATION, PENDENTE LITE

The Intervenor, GLORIA FARBER, respectfully replies to the defendant, FOTIS

Pullman & Comley, LLC

DULOS’, Motion for Psychological Evaluation, dated August 29, 2019. In support thereof, Mrs.
Hartford, CT 06103-3702
90 State House Square

Juris No. 4-09177

Farber represents as follows:

1. On or about June 20, 2017, the plaintiff, Jennifer Dulos, initiated the above-

captioned dissolution of marriage action against the defendant, Fotis Dulos.

2. The parties have five minor children, ranging in age from eight to thirteen years

old. The children resided primarily with the plaintiff since the initiation of the dissolution action,

in New Canaan, Connecticut, until the plaintiff’s disappearance on May 24, 2019. Since that

time, they have resided with Mrs. Farber, their maternal grandmother, who was granted

temporary custodianship of the children and permitted to intervene in the instant dissolution

proceeding.

3. On August 29, 2019 the defendant filed a Motion for Psychological Evaluation of

Mrs. Farber. To be clear, Mrs. Farber has no objection to the Court ordering her to undergo a
 psychological evaluation if the Court deems it appropriate. Any such order should be reciprocal

such that the defendant should likewise be evaluated, and the costs of the same should be

allocated between Mrs. Farber and the defendant.

4. Instead of filing a straightforward motion for psychological evaluation, as is done

in countless dissolution proceedings, the defendant’s motion is intended to be salacious and

again demonstrates his capacity for cruelty, inability to abide by Court orders and his efforts to

publicly shame Mrs. Farber as he did to his wife in the context of the earlier divorce proceedings.
Pullman & Comley, LLC

Hartford, CT 06103-3702

Mrs. Farber is the person upon whom the defendant relied to support his wife and children
90 State House Square

Juris No. 409177

during the pendency of their divorce, prior to his wife’s violent disappearance. Mr. and Mrs.

Farber financed the defendant’s business and kept it afloat during the marriage. He now lives in a

home and neglects to pay the mortgage to the Farber estate. Most importantly, Mrs. Farber has

steadfastly demonstrated her devotion to her grandchildren and competence to provide for them

financially, physically and emotionally especially since their mother, whose demise is greatly

feared, went missing.

5. Probable cause has been found to implicate the defendant in the violent

disappearance of Jennifer Dulos. The defendant’s presumption of innocence, to which he is

entitled in the criminal proceeding against him, cannot be used to shield him in the civil court as

it does in the criminal court. The presumption does not deprive the Court in this matter from

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 taking notice of the facts underscoring the finding of probable cause against him and from

drawing adverse inferences, as it has already done, from the defendant’s invocation of the 5th

amendment.

6. Mrs. Farber is not going to publicly respond to the defendant’s allegations about

her in a substantive manner, other than to state that the defendant is making a distorted, self-

serving reference to a private, health-related issue that was resolved many years ago, as the

defendant is well aware. His effort to not only publicly shame Mrs. Farber, but in essence shame
Pullman & Comley, LLC

Hartford, CT 06103-3702

any person that has appropriately addressed a mental health issue, sends a poor message to his
90 State House Square

Juris No. 409177

children. It is Mrs. Farber who has competently managed their care since the dreadful events of

May 24, 2019 have so negatively affected their lives.

7. The defendant’s nuanced references to the report by Dr. Herman, which has been

previously discredited and on which the Court has not relied in entering orders in this matter,

violates this Court’s repeated orders that the defendant not discuss the report or its findings in

any manner. The fact that he continues to violate such orders, and his misuse and

mischaracterization of Dr. Herman’s report which was completed prior to the facts of May 24,

2019 and the defendant’s arrest and implication in the disappearance of his wife, demonstrates

that the Court should use significant caution in entering any further orders that allow the

defendant access to psychological or other medical information pertaining to Mrs. Farber and the

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 children. The defendant clearly cannot be trusted to care about the impact of such information

becoming public, when he has used it with abandon to deflect attention away from his

involvement in the violent disappearance of his wife and mother of his children.

8. Mrs. Farber welcomes a psychological evaluation of the defendant and of her if

the Court deems it appropriate and requests that the Court enter specific, cautionary orders as to

how the results of the evaluation should be reported and protected from future distorted and self-

serving dissemination of such information by the defendant.

Pullman & Comley, LLC

Hartford, CT 06103-3702
90 State House Square

Juris No. 409177

INTERVENOR,
GLORIA FARBER

By: ______________________
Anne C. Dranginis
Kelly A. Scott
Pullman & Comley, LLC
90 State House Square
Hartford, CT 06103-3702
Juris No. 409177
Telephone: 203-330-2000
Facsimile: 860-424-4370
Email: [email protected]
Her Attorneys

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 CERTIFICATION

I certify that a copy of the above will immediately be mailed or delivered electronically
on August 31, 2019, to all counsel and self-represented parties of record and that written consent
for electronic delivery was received from all counsel and self-represented parties of record who
were or will immediately be electronically served.

Reuben S. Midler, Esq. Richard A. Rochlin, Esq.

Law Offices of Wayne D. Effron, P.C. Richard Rochlin Law Group
2 Greenwich Office Park, 2nd Floor West 10 North Main Street, Suite 304
Greenwich, CT 06831-0504 West Hartford, CT 06107
[email protected] [email protected]
Pullman & Comley, LLC

Hartford, CT 06103-3702
90 State House Square

Juris No. 409177

Michael Meehan, Esq.

Meehan Law LLC
76 Lyon Terrace
Bridgeport, CT 06604
[email protected]

______________________________
Anne C. Dranginis
Commissioner of the Superior Court

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