741 Colonel Ledyard Highway  
Ledyard, Connecticut 06339-1551  
(860) 464-3203  
TOWN OF LEDYARD  
Town Council  
council@ledyardct.org  
Meeting Minutes  
Chairman Gary St. Vil  
Public Hearing  
Monday, November 10, 2025  
5:00 PM  
Town Hall Council Chambers  
WORKING DRAFT  
In-Person: Council Chambers Town Hall Annex  
Remote: Information noted below:  
Join Zoom Meeting from your Computer, Smart Phone or Tablet:  
https://us06web.zoom.us/launch/edl?muid=0ec0d0ed-c495-4aa5-adaa-ac97f88014e2  
or by audio only dial: +1 646 558 8656 Meeting ID: 872 3852 2319; Passcode: 298911  
I.  
CALL TO ORDER  
Chairman St. Vil called to order the Public Hearing at 5:00 p.m. regarding a proposed “An  
Ordinance Establishing a Town of Ledyard Code of Ethics And Ethics Commission” as  
updated on or about October 29, 2025.  
II.  
PLEDGE OF ALLEGIANCE  
VI.  
PROCEDURE OF THE PUBLIC HEARING  
Chairman St. Vil welcomed all to the Hybrid Meeting. He stated for the members of  
the Town Council and the Public who were participating via video conference that  
the remote meeting information was available on the Agenda that was posted on the  
Town’s Website - Granicus-Legistar Meeting Portal.  
Chairman St. Vil provided an overview of the procedure of the Public Hearing, and  
he asked those attending remotely to put their name and address in the “Chat”  
noting that they would be called upon during the Public Comment portion of  
tonight’s meeting.  
VII. CALL OF THE PUBLIC HEARING  
LEGAL NOTICE  
TOWN OF LEDYARD  
NOTICE OF PUBLIC HEARING  
The Ledyard Town Council will conduct a Hybrid Format Public Hearing  
(In-Person & Video Conference)  
on Monday, November 10, 2025 at 5:00 p.m.  
to receive comments/recommendations regarding a Proposed  
“An Ordinance Establishing a Town of Ledyard Code of Ethics And Ethics  
Commission”  
As updated on or about October 29, 2025  
Please join the Public Hearing in-person or remotely as follows:  
In-person attendance will be at the  
Council Chambers, Town Hall Annex Building  
741 Colonel Ledyard Highway, Ledyard, Connecticut  
Please join the video conference meeting from your computer, tablet, or smartphone at:  
<https://us06web.zoom.us/launch/edl?muid=0ec0d0ed-c495-4aa5-adaa-ac97f88014e2>  
Meeting ID: 872 3852 2319; Passcode: 298911  
or by audio only dial: +1 646 558 8656 Meeting ID: 872 3852 2319; Passcode: 298911  
At this hearing interested persons may appear and be heard and written  
communications will be accepted at towncouncil@ledyardct.org  
<mailto:towncouncil@ledyardct.org>.  
Dated at Ledyard, Connecticut this 30th day of October, 2025.  
For the Ledyard Town Council  
s/s Gary St. Vil, Chairman  
Please Publish on Friday, October 31, 2025  
Public Hearing- Legal Notice- November 10, 2025 at 5:00 p.m. “An Ordinance Establishing  
a Town of Ledyard Code of Ethics and Ethics Commission,” as revised on or about October  
29, 2025.  
IV.  
PRESENTATIONS  
Chairman St. Vil called upon Councilor Buhle to present the proposed “An  
Ordinance Establishing a Town of Ledyard Code of Ethics And Ethics Commission”  
as updated on or about October 29, 2025.  
DRAFT: 10/29/2025  
Ordinance # _______  
AN ORDINANCE ETABLISHING A  
TOWN OF LEDYARD CODE OF ETHICS AND ETHICS COMMISSION  
Be it ordained by the Town Council of the Town of Ledyard:  
Section 1. Authority  
In accordance with Chapter III of the Town Charter, there is hereby established a  
Town of Ledyard Code of Ethics and Ethics Commission.  
Section 2. Declaration of Policy and Purpose  
The trust of the public is essential for government to function effectively. The proper  
operation of the Town government requires that Town officials, Town employees,  
and Town consultants be independent, impartial, and responsible to the people; that  
governmental decision and policies be made in the proper channels of governmental  
structure; that public office and employment not be used for beneficial and/or  
financial interest; and that the public has confidence in the integrity of its  
government.  
The purpose of the Town of Ledyard Code of Ethics is to:  
· Identify standards of ethical conduct to guide all Town officials, including  
members of the Board of Education, and all Town and Board of Education  
officers, employees, and consultants as they conduct their public responsibilities.  
· Clarify the role of the Ethics Commission.  
· Outline a process that allows Town officials, including members of the Board of  
Education, and all Town and Board of Education employees, and consultants to  
seek guidance and advice about ethical issues connected with their public  
responsibilities, and  
· Establish a process that enables citizens to report, and the Ethics Commission to  
investigate and respond to possible violation of the Code.  
Section 3. Definitions  
As used in this ordinance, the following words or phrases shall have the meaning  
indicated:  
1. “Agency” is any board, commission, authority, or committee of the Town, including  
the Town Council and Board of Education.  
2. “Beneficial interest” means any nonfinancial interest or special treatment that is not  
common to other citizens of the Town.  
3. “Business associate” means a person joined together with another person through  
employment or to achieve a common financial and/or business-related objective.  
4. “Business day” means a day other than a Saturday, Sunday, or other day on which  
the office of the Ledyard Town Clerk is closed to the public for business.  
5. “Campaigning” - to be defined by attorney  
6. “Complainant” means a person or persons who files a complaint under penalties of  
false statement against an official, employee, or consultant containing allegation of  
prohibited activities under the Code of Ethics.  
7. “Confidential Information” means information acquired by a Town official,  
employee, or consultant in the course of and by reason of performing an individual’s  
official duties and which is not a matter of public record or public knowledge.  
8. “Consultant” means any independent contractor or professional person or firm that is  
by virtue of an award of a public bid or contract engaged by and receives  
compensation from the Town or Board of Education for the purpose of providing  
professional, scientific, technical, or other specialized opinion, and is in a position to  
influence any decision of an agency, official, or employee.  
9. “Employee” is any person receiving a salary, wages, or stipend from the Town or  
Board of Education for services rendered, whether full-time or part-time.  
10. “Family” means the spouse, domestic partner, fiancé, fiancée, parents,  
daughter-in-law, son-in-law, mother-in-law, father-in-law, sister-in-law,  
brother-in-law, grandparents, great-grandparents, lineal descendants, stepchildren,  
foster children, siblings, stepsiblings, foster siblings; lineal descendants of siblings,  
stepsiblings, and foster siblings of an official, employee, or consultant, or his/her  
spouse or domestic partner.  
11. “Financial Interest” means any interest that:  
a. has a monetary value of one hundred dollars ($100.00) or more or generates a  
financial gain or loss of one hundred dollars ($100.00) or more in a calendar year;  
b. is not common to the other citizens of the Town. An individual’s financial interests  
shall include the financial interests of all members of his/her family but shall not  
include any duly authorized compensation from the town.  
12. “Gift” is a gift of more than one hundred dollars ($100.00) in value. A gift includes,  
but is not limited to, entertainment, food, beverage, travel, and lodging to the extent  
that the gift value exceeds one hundred dollars ($100.00) in any one (1) year from the  
same person, as well as loans that are not commercially reasonable. A gift may also  
include donations to a third party on behalf of an official, employee, or consultant for  
which she/he receives some favor, advantage, or consideration.  
Gifts do not include:  
1. A political contribution that is otherwise reported in accordance with the law.  
2. A loan made on terms that are commercially reasonable and not more favorable  
than loans made in the ordinary course of business.  
3. Any gift regardless of value received from: (i) any family member who resides in  
the same household as the recipient of the gift, or (ii) another family member  
unless the other family member who makes the gift is interested, directly or  
indirectly, in a business transaction or pending matter that is within the purview  
or responsibilities of (a) the recipient of the gift, or (b) another family member  
residing in the same household as the recipient of the gift.  
4. Certificates, plaques, or other ceremonial awards costing less than fifty dollars  
($50.00).  
5. A rebate or discount on the price of anything of value made in the ordinary course  
of business, without regard to that person’s status.  
6. Honorary degrees.  
7. Costs associated with attending a conference or business meeting and/or  
registration or entrance fee to attend such conference or business meeting in  
which the Town official or Town employee participates in his/her official  
capacity.  
8. Any gift provided to a Town Official or Town Employee or to a family member  
of a Town Official or Town Employee for the celebration of a major life event  
provided any such gift provided to an individual does not exceed one thousand  
dollars ($1,000.00) in value. A major life event shall include, but not be limited  
to, a ceremony commemorating an individual’s induction into religious adulthood  
such as a confirmation or bar mitzvah; a wedding; a funeral; the birth or adoption  
of a child; and retirement from public service or Town employment.  
13. “Inquiry” means a complaint or allegation of a possible violation of the Code.  
14. “Official” is any person holding elective or appointive office in the government of  
the town and shall include, but not limited to, the Town Council, Board of Education,  
Town commissions and committees, or any other agency.-  
15. “Respondent” means a person who is the subject of a complaint.  
Section 4. Confidential information  
Town officials, employees, or consultants may not disclose or use any  
information or records that are not available to the public except in the performance  
of official duties or as required by law or court order.  
Section 5. Conflict of Interest Provisions  
a. A Town official, employee, or consultant has a conflict of interest when that  
individual engages in or participates in any contract, transaction, decision,  
employment, or rendering of service where the Town official, employee, or  
consultant has a financial or beneficial interest. Notwithstanding anything contained  
in this ordinance to the contract, a Town official, employee, or consultant may enter  
into a contract with the Town if the contract is (i) publicly quoted or bid; or (ii) the  
Town official, employee, or consultant is not involved in the awarding of the contract  
In addition, the provisions of this section shall not apply to any employment contracts  
in which a Town official, employee, or consultant is hired by the Town or the Board  
of Education to perform necessary services.  
b. A financial interest or beneficial interest presents a conflict of interest that is  
incompatible with the proper discharge of official responsibilities in the public  
interest if the Town official, employee, or consultant has reason to believe or expect  
that he/she or any member of his family or business associate will obtain, secure, or  
advance such interest by reason of his/her actions in performance or nonperformance  
of his/her official responsibilities.  
c. A Town official, employee, or consultant does not have a financial interest or  
beneficial interest that is incompatible with the proper discharge of his/her official  
responsibilities in the public interest if the interest accrues to such individual, his/her  
family members or business associate(s) as a member of a profession, occupation, or  
group to no greater extent that it accrues to any other member of the profession,  
occupation, or group with which he/she is affiliated as set forth in G.S. 7-148h(b).  
d. No Town Official or employee may directly hire a member of his/her family. Town  
employee supervision of a member of his/her family may occur in temporary  
emergency situations, including but not limited to winter storms, tropical storms, and  
labor shortages.  
e. Town officials and Town employees shall not use Town owned vehicles, equipment,  
facilities, materials, or property for personal convenience or profit. Personal  
convenience or profit refer to those matters that are not related to the individual’s  
official duties. This section does not apply to Town-owned vehicles issued to  
emergency responders who are authorized by the Mayor, Fire Chief or Police Chief to  
take their Town-owned vehicles home, or vehicles issued to employees who are  
permitted to bring their Town-owned vehicles homes as part of an employment  
agreement or contract.  
f. No Town official, employee, or consultant may withhold information or make a  
dishonest or fraudulent statement with the intent to deceive or to misrepresent  
material facts in the performance of his or her official duties.  
Section 6. Consultants  
a. The Code of Ethics shall be incorporated by reference into all contracts entered into  
by the Town of Ledyard and the Board of Education with a consultant.  
b. Persons or firms who are engaged by and receive compensation from other  
governmental entities, such as the state or federal government, and who are in a  
position to influence any decision of an agency, official, or employee shall be guided  
by the Code.  
Section 7. Gifts and favors  
a. No Town official, employee, or consultant, or any business associate, or member of  
his/her family nor any agency, employee organization, or group of employees shall  
solicit or accept any gift, whether in the form of a service, a loan at a less than a  
commercially available rate, a material thing, or a promise, from any person or entity  
who or which is interested directly or indirectly in any business transaction or  
pending matter that is within the purview of such official, employee, consultant,  
agency, employee organization, or group of employees. No Town official, employee,  
or consultant shall accept, or knowingly seek or cause to be given to any member of  
his/her family, any valuable favor, treatment, consideration, or advantage beyond that  
which is generally available to the citizens of the Town from any person who, to the  
knowledge of the official, employee, or consultant, is interested directly or indirectly  
in any business transaction or pending matter that is within the responsibilities of the  
official, employee, or consultant. For purposes of this section, a pending matter  
includes, but is not limited to, any application to an agency, commission, committee,  
a bid for work to be performed, an application for employment, and any bid for the  
furnishing of supplies, equipment, or services.  
b. This section shall not apply to any political contribution that is reported as required  
by law.  
Section 8. Equal treatment  
Without proper authorization, no Town official, employee, or consultant shall accept,  
seek, grant, or cause to be granted any special consideration, treatment, or advantage  
to such individual, or his/her family by virtues of his/her position or business  
association.  
Section 9. Disclosure and disqualification  
a. Any Town official, employee, or consultant who has a conflict of interest, financial  
interest, or beneficial interest, direct or indirect, in any contract, transaction or  
decision within the purview of his/her official responsibilities shall disclose that  
conflict of interest in accordance with section 9(b) through 9(e). Such disclosure  
shall disqualify the official, employee, or consultant from participation in the matter,  
transaction, or decision.  
b. No Town official, employee, or consultant shall appear on behalf of any private  
person or party before any agency in connection with any cause, proceeding,  
application, or other matter in which he/she has financial interest or beneficial  
interest without first disclosing such interest to the agency, which shall record such  
disclosure in the record of the agency’s proceeding.  
c. All Town Councilors, Board of Education members, and the Mayor shall, on or  
before January 1st each year, file with the Town Clerk, on a form to be prepared by  
the Town Attorney, a statement, under oath, containing the following information:  
1. All real estate located within the Town of Ledyard owned by such elected official  
or held under lease for a term exceeding five years, excluding, however, his/her  
principal residence. The foregoing shall also apply to real estate in the Town of  
Ledyard owned or leased, as aforesaid, by a corporation, trust or partnership in  
which any such elected official is the legal or equitable holder of at least five (5)  
percent of the legal or equitable interest in said corporation, trust, or partnership.  
2. The names of any firm, proprietorship, partnership, or corporation of which said  
elected official is an employee or in which such elected official holds at least a  
five (5) percent interest, and which firm, proprietorship, partnership, corporation,  
or limited liability corporation has sold or supplied goods or services in excess of  
ten thousand dollars ($10,000.00) per annum to the Town of Ledyard during the  
two (2) years immediately preceding such official’s election to office.  
3. Any income, fees, salary, or wages directly or indirectly, received by such official  
from the Town of Ledyard during the two (2) years immediate proceeding such  
official’s election to public office.  
d. If there is an uncertainty whether a Town official, employee, or consultant has a  
conflict of interest, financial interest, or beneficial interest that could disqualify that  
individual from participation in a matter, such individual shall disclose such possible  
conflict of interest to the following:  
1. For a Town official who is a member of an elective or appointive board,  
commission, committee, or authority - to the particular chair of the commission  
or committee of which such official is a member.  
2. For Town employees and officials appointed by the appropriate authorities - the  
Mayor or Town Council.  
3. For Board of Education employees - to the superintendent of schools  
4. The Town department directors - to the Mayor or the Town Council.  
5. The superintendent of schools - to the Board of Education.  
6. For a consultant - to the agent executing the contract on behalf of the Town or  
Board of Education.  
e. The appropriate authority to which the disclosure is made shall make an appropriate  
record of such disclosure and shall recommend to the Town official, employee, or  
consultant making the report to seek an advisory opinion from the Ethics  
Commission regarding whether such official, employee, or consultant should abstain  
from participating in the transaction or decision related to the possible conflict of  
interest.  
f. Any such questions concerning a possible conflict of interest may be referred to the  
Ethics Commission pursuant to Section 13 for an advisory opinion.  
Section 10. Incompatible activities  
a. This Code shall not prohibit any current or former Town official, employee, or  
consultant from appearing before any agency on his/her own behalf. To avoid an  
actual or perceived conflict, Town officials are strongly discouraged from appearing  
before the agency on which they are a member or officer, absent extenuating  
circumstances, unless he/she has received a prior favorable advisory opinion by the  
Ethics Commission pursuant to Section 14(b) prior to appearing.  
b. Nothing in the Code shall be interpreted to authorize conduct restricted or prohibited  
by any provision of the Connecticut General Statutes including, but not limited to,  
G.S. 8-11, 8-21, and 22a-42(c) that restrict conduct of members of municipal zoning  
and planning authorities and members of Inland, Wetlands and Watercourses  
commissions.  
c. To avoid even the appearance of impropriety or creation of a situation that would be  
contrary to the declared policy and purpose of the Code, a Town official shall  
exercise care when appearing before other agencies and shall disclose whether he/she  
is appearing in his/her official capacity or as a private citizen.  
Section 11. Penalty for violation  
A failure to comply with the Code shall be considered grounds for censure,  
reprimand, suspension, demotion, removal, or dismissal of Town officials,  
employees, and consultants as applicable. The remedies and procedures specified in  
applicable statutory and Charter provisions, personnel rules, contract grievance rules,  
or other work rules, policies, and procedures, shall be followed in the enforcement of  
this section.  
Section 12. Acknowledgment form  
a. The Town Clerk shall provide a copy of the Code of Ethics to every Town official  
and employee within sixty (60) days of date that he/she begins his/her duties. Every  
Town official and employee shall sign and file with the Town Clerk an  
acknowledgment form indicating his/her awareness of the provisions of this Code.  
Current Town officials and employees shall acknowledge the Code of Ethics within  
one-hundred-twenty (120) days of its effective date.  
b. Each consultant shall sign and file with the Town Clerk an acknowledgment form  
indicating his or her awareness of the provisions of this Code on or before being  
retained by the Town, Board of Education, or other agency. Current consultants shall  
acknowledge the Code of Ethics within one-hundred-twenty (120) days of its  
effective date.  
c. The Mayor and superintendent of schools shall develop a protocol for periodic  
training of employees concerning the Code of Ethics. The Commission shall develop  
a protocol for periodic training of officials.  
d. The Town Council shall approve a procedure for monitoring compliance with this  
section and approve the training protocols specified in subsection (c).  
Section 13. Ethics Commission  
a. Structure  
1. The Ethics Commission shall be comprised of five (5) regular members and two  
(2) alternate members. All members of the Ethics Commission shall be electors  
of the Town  
2. No more than two (2) of the regular members may be affiliated with any one  
political party. At all times, at least one regular member shall be unaffiliated with  
any political party. Both alternate members may not be affiliated with the same  
political party.  
3. Members will not be compensated for their service on the Commission.  
4. Within thirty (30) days of the appointment of the Ethics Commission, an  
organizational meeting shall be held at which members shall choose a Chairman,  
Vice-Chairman, and a Secretary  
b. Member and alternate member qualifications  
a. Members and alternate members must be residents of the Town of Ledyard.  
b. No member or alternate member shall:  
a. Be employed by the Town;  
b. Have been employed by the Town for a period of two years prior to being  
appointed to the Ethics Commission.  
c. Hold or seek any Town office.  
d. Have campaigned for any other person seeking a town office.  
e. Have held any Town office for a period of two years prior to being appointed to  
the Ethics Commission.  
f. Serve as a member of another Town agency.  
g. Hold office in a political party or political committee.  
h. Have been found in violation of state, local, or professional code of ethics.  
c. Method of appointment: The Town Council shall appoint the Ethics Commission  
members in the manner provided in the Town Charter. Members of the Ethics  
Commission shall be appointed by a minimum of (6) affirmative votes of the Town  
Council.  
d. Terms of appointment  
1. Members will be appointed for three (3) year terms.  
2. If a member is appointed to fill an unexpired term, then that member’s term ends at  
the same time as the term of the person being replaced.  
3. In making the original appointments under this ordinance, the Town Council shall  
designate two (2) regular members to serve for three (3) years, two (2) regular  
members to serve for two (2) years; one (1) regular member to serve for (1) year; one  
(1) alternate member to serve for three (3) years and one (1) alternate member to  
serve for two (2) years. Thereafter, vacancies shall be filled for a three (3) year term.  
4. Inaugural members shall be eligible to serve two (2) additional three (3) years term  
beyond his/her initial appointment. No member may serve more than three (3) terms  
total.  
5. The Town Council may remove members for cause and fill the vacancy in  
accordance with the Town Charter. Cause for removal shall include, but is not  
limited to, an unexcused absence from three (3) consecutive meetings. It shall be the  
responsibility of the Chairman of the Ethics Commission to notify the Town Council  
when a member has not properly performed his/her duties.  
e. Powers and duties  
1. The Ethics Commission shall be authorized to consult the Town Attorney or another  
attorney hired by the Commission if so authorized by the Town Council.  
2. The Ethics Commission shall be authorized to request that the Town Attorney  
provide advisory opinions.  
3. The Ethics Commission has the power to render advisory opinions to any Town  
official, employee, or consultant on whether conduct by that person would constitute  
a violation of the Code of Ethics. Individuals seeking an advisory opinion should  
follow the procedures outlined in Section 14 of the Code.  
4. The Ethics Commission has the power to examine complaints and to make a  
determination of probable cause, pursuant to the procedures outlined in Section 14.  
5. The Ethics Commission has the power to hold hearings concerning alleged violations  
of the code, may administer oaths, and may compel attendance of witnesses by  
subpoena to the extent permitted by law.  
6. The Ethics Commission has the power to review the Code of Ethics policies and  
procedures on an as-needed basis and will make recommendations to the Town  
Council regarding changes to the Code of Ethics policies and procedures.  
7. The Ethics Commission will make advisory opinions available to the public unless  
doing so would violate the confidentiality provision of this Code of Ethics or is  
otherwise prohibited by law.  
8. The Ethics Commission will protect the personal privacy rights of any individual who  
is the subject of an inquiry or complaint, except as necessary to investigate and make  
determinations of probable cause. If there is a finding of no probable cause, the  
existence of an inquiry or complaint and any records relating to that inquiry or  
complaint shall remain confidential pursuant to Section 14.  
9. The Ethics Commission may take action to increase public awareness of the Code of  
Ethics.  
Section 14. Ethics Commission rules of procedure  
(a) These procedures shall be used by the Ethics Commission established in Section 14  
hereof, and are designed to guide public officials, officers, employees, consultants,  
and citizens of the process to be followed if they seek advice or question the conduct  
of those in or affiliated with town government. Subsection (b), advisory opinions,  
describes a process for Town officers, officials, employees, or consultants, and other  
parties doing business with the Town who are seeking advice about their own conduct  
or the conduct of a Town office or function. Subsection (c), complaints, describes a  
formal, public procedure for filing complaints. Subsection (d), other communications;  
miscellaneous, describes the process to be followed by anyone wishing to bring  
something to the attention of the Ethics Commission, without requesting an advisory  
opinion or filing a complaint.  
(b) Advisory opinions  
1. Any current, former, or prospective Town of Ledyard employee, official, or  
consultant may request an advisory opinion from the Ethics Commission as to  
whether conduct by that person or entity would violate the Code of Ethics. Any  
current Town official also may request an advisory opinion concerning the activities  
of any department over which he/she has jurisdiction or board or commission on  
which he/she serves.  
2. Individuals initiating a request for an advisory opinion must do so by completing a  
form available through the Ledyard Town Clerk’s Office or through the Town’s  
website www.ledyardct.org <http://www.ledyardct.org>. The form must contain a  
statement setting forth the advice requested and the relevant facts known to the  
individual making the request so that the Ethics Commission can reasonably be  
expected to understand the nature of the request. The individual making the request  
must sign it the form.  
3. Requests must be addressed in a sealed envelope to the Ethics Commission, c/o The  
Ledyard Town Clerk, 741 Colonel Ledyard Highway, Ledyard, CT 06339-1511 who  
will date stamp, but not open, the envelope and forward same promptly to the chair or  
vice-chair of the Ethics Commission. On the day said request is received by the  
Town Clerk, the Town Clerk or his/her representative shall notify the chair or  
vice-chair of the Ethics Commission, or both, of same.  
4. The date the request is received by the Town Clerk will mark the official date of  
receipt for purpose of deadlines for decisions.  
5. Proceedings  
i. The chair will present the request to the Ethics Commission at its next regular  
meeting or at a special meeting under executive session, except upon the request of  
the individual that is seeking the advisory opinion regarding whether his/her conduct  
constitutes a violation of the Code of Ethics, called by the Ethics Commission chair  
or vice-chair.  
ii. The Ethics Commission will meet in to review the request. At that time, it may  
decide to (1) Seek additional information, (2) Create a subcommittee of at least two  
(2) commission members to make a recommendation for consideration by the full  
Ethics Commission, (3) Hold an informal hearing to receive comments from the  
individual who request the advisory opinion and/or from the public, (4) Investigate  
the relevant facts and issues in order to render the advisory opinion.  
6. Decisions  
i. Advisory opinions will be made by a majority of the Ethics Commission members  
voting at a meeting at which a quorum is present.  
ii. The Ethics Commission will issue an advisory opinion as expeditiously as possible  
but in any event within ninety (90) days from the day it first considers the request.  
The Ethics Commission may extend the time for a decision for up to an additional  
thirty (30) days.  
iii. All advisory opinions must be in writing and communicated to the individual making  
the request.  
iv. The Ethics Commission may decline to render an advisory opinion if (1) the subject  
matter is not covered by the Code of Ethics, (2) the known facts are incomplete or  
incorrect, and the omission or misstatements are material to the advisory opinion  
requested, or (3) other reasonable grounds exist for not taking action. If the Ethics  
Commission decides to so act, it shall state its reasons.  
7. Confidentiality  
i. Requests for advisory opinions will be reviewed in executive session except upon the  
request of the individual that is seeking the advisory opinion regarding whether  
his/her conduct constitutes a violation of the Code of Ethics.  
ii. Advisory opinions reviewed in open sessions will be made available for public  
inspection by delivery to the Town Clerk’s office.  
c. Complaints  
1. A complaint alleging any violation of the Code of Ethics shall be made on a form  
prescribed by the Ethics Commission available at the Town’s website  
www.ledyardct.org <http://www.ledyardct.org> or through the Town’s Clerk office,  
and signed under penalty of false statement. The form shall be delivered to the Town  
Clerk in a sealed envelope who will date stamp, but not open, the envelope and  
forward same promptly to the chair or vice-chair of the Ethics Commission. On the  
day said request is received by the Town Clerk, the Town Clerk or his/her  
representative shall notify the chair or vice-chair of the Commission, or both, and the  
respondent within five (5) days of receipt of the complaint. The Ethics Commission  
shall also notify the respondent that it will conduct a probable cause determination  
and invite the respondent to provide any information the respondent deems relevant  
to the Ethics Commission’s determination of probable cause.  
No complaint may be made under the Code of Ethics unless it is filed with the Ethics  
Commission within three (3) years after the violation alleged in the complaint has  
been committed.  
The Complaint shall include:  
· Name of the person accused (respondent).  
· Name of the person filing the complaint.  
· The specific acts alleged to constitute a violation of the Code of Ethics and when  
said actions occurred.  
1. Evaluation and Acknowledgment  
a. Within sixty (60) business days of the receipt of a complaint, the Ethics  
Commission shall review and determine whether there is probable cause that a  
violation of the Code of Ethics has occurred. A finding of probable cause means  
that based on a review of the available information, the Ethics Commission  
determines that reasonable grounds exist to believe that the respondent engaged in  
prohibited conduct by the Code of Ethics. If the Ethics Commission does not  
make a finding of probable cause, the complaint shall be dismissed, and a copy of  
its decision shall be mailed to both the complainant and the respondent. Unless  
the Ethics Commission makes a finding of probable cause, a complaint alleging a  
violation of this Code of Ethics shall be confidential except upon the request of the  
respondent.  
b. If the Ethics Commission makes a finding of probable cause, which shall require  
three (3) affirmative votes, it shall so advise both the complainant and the  
respondent and begin a formal investigation process.  
2. Hearings  
i. If the Ethics Commission decides that probable cause of a violation of the Code  
of Ethics exists, it will conduct a public hearing to determine whether or not a  
violation occurred in accordance with Uniform Administrative Procedure Act  
(“UAPA”) (See Chapter 54 of the Connecticut General Statutes). At the hearing,  
the respondent will have the right to be represented by legal counsel, to present  
evidence and witnesses and compel attendance of witnesses and the production of  
books, documents, records, and papers, and to examine and cross-examine  
witnesses and inspect and copy relevant and material records, papers and  
documents not in such person’s possession. Hearings are not governed by the  
legal rules of evidence and any information relevant to the matter may be  
considered. The Ethics Commission will respect the rules of privilege recognized  
by the law. Not later than ten (10) days before the start of the hearing, the Ethics  
Commission will provide the respondent with a list of its intended witnesses. The  
Ethics Commission will make a record of the proceedings.  
3. Final Decisions  
ii. Decisions by the Ethics Commission that a person is in violation of the Code  
of Ethics must result from the concurring vote of four (4) of its members.  
iii. The Ethics Commission must render its decision within sixty (60) days of the  
closing of the hearing.  
iv. Such finding and memorandum will be deemed to be the final decision of the  
Ethics Commission for the purposes of the UAPA. The respondent may appeal  
to the superior court in accordance with the provisions of Section 4-183 of the  
Connecticut General Statutes.  
v. If the Ethics Commission determines that the Code of Ethics was violated, it  
will provide the respondent, the Mayor, and the Ledyard Town Council wi  
Discussion and possible action to review and consider text amendments to the proposed "An  
Ordinance Establishing a Town of Ledyard Code of Ethics and Ethics Commission" as  
updated on or about October 29, 2025.  
V.  
RESIDENT & PROPERTY OWNERS (COMMENTS LIMITED TO THREE (3)  
MINUTES  
Chairman St. Vil thanked Councilor Buhle for her prestation regarding the proposed “An  
Ordinance Establishing a Town of Ledyard Code of Ethics And Ethics Commission”. He  
stated at this time he would open the floor to residents comments; and he asked residents to  
keep their comments to 3 minutes or less. He also asked that if residents have already  
submitted written comments to the Town Council, that they not read their written  
communication, because the Town Council has already received their comments, and  
to allow time for all those who would like to speak this evening. He stated the written  
communications were already part of the record, noting that residents were welcome  
to provide other comments that they have not already been submitted. He also asked  
for those attending on-line to please put their name and address in the “Chat” and  
they would be called on in the order that they were signed up.  
Mr. Carlo Porazzi, 30 Chapman Lane, Gales Ferry,  
Mr. M. Dave Schroeder, Jr., 290 Whalehead Road, Gales Ferry  
Mr. Gary Schneider, 101 Inchcliffe Drive, Gales Ferry  
Mrs. Karen Parkinson. 55 Rose Hill Road, Ledyard  
Mr. Mike Cherry, 5 Whippoorwill Drive, Gales Ferry  
Mrs. Pamela Ball, 674 Shewville Road, Ledyard, attending remotely via Zoom  
Mr. Dan Pealer , 48 Highland Drive, Ledyard  
Mr. Brandon Sabbag, 16 Nutmeg Drive, Gales Ferry,  
Mr. Mike Cherry, 5 Whippoorwill Drive, Gales Ferry  
Mrs. Pamela Ball, 674 Shewville Road, Ledyard  
Mr. Carlo Porazzi, 30 Chapman Lane, Gales Ferry,  
Ms. Jessica Buhle, 65 Pheasant Run Drive, Gales Ferry, Town Councilor  
Mr. Tim Ryan, 62 Inchcliffe Drive, Gales Ferry, Town Councilor  
Mr. Gary St. Vil, 2 Thompson Road, Ledyard, Town Council Chairman:  
Mr. Dan Pealer, 48 Highland Drive, Ledyard,  
XV. ADJOURNMENT  
Chairman St. Vil stated hearing no further public comment, that the Public Hearing was  
adjourned at 5:42 p.m.  
________________________________  
Transcribed by Roxanne M. Maher  
Administrative Assistant to the Town Council  
I, Gary St. Vil, Chairman of the Ledyard Town Council,  
hereby certify that the above and foregoing is a true and correct  
copy of the minutes of the Public Hearing held on November 10, 2025  
Attest:________________________________________  
Gary St. Vil, Chairman  
DISCLAIMER:  
Although we try to be timely and accurate these are not official records of the Town.  
The Town Council's Official Agenda and final Minutes will be on file in the Town Clerk's  
Office.