On November 8, 2007, the City of Bristol demolished the Historic Titus Roberts house.

This house had been moved only three years previously to avoid demolition.




Request for Proposals (RFP)    Request for Qualifications (RFQ)

COMPLAINT ONE: (Breach of Contract)

That the city of Bristol breached the contract, and the intent of the contract from day one  (Paragraph 9: "Seller agrees to install city water and city sewer at no cost to the buyer.") In addition: Breach of Oral Contract, Breach of Implied Contract, False Promising: Unjust enrichment: Breach of the Implied Covenant of Good Faith and Fair Dealing.

COMPLAINT TWO: (Due Process)

In a continuing series of bad faith incidents by various city departments culminating in unconscionable actions by the City of Bristol Building Department, said City incorrectly interpreted the International Building Code (IBC), incorrectly applied said code in an arbitrary, capricious, unjust and unfair manner resulting in gross unequal treatment under the law. Specifically, failure to provide a clear and understandable appeal procedure as required by said code.

COMPLAINT THREE: (Last Clear Chance)

That the City and its agents failed in their duty under the law to mitigate damage and harm in the demolition of the house. They put themselves in a position where only they had a "last clear chance". They and only they, had a duty to use reasonable care to guard against damage of any private property not specifically in violation of the health and safety clause under which the action was purportedly carried out. Specifically, (1) the foundation that has been recently approved by the City of Bristol Building Department, (2) the removal and loss of irreplaceable 100 year old brownstones from the former Eagle Lock Company building that were stored in the front yard of said property, (3) over 100 brand new unopened cartons of fundraising materials and (4) five rooms full of donated building materials.

This demolition, and the way it was carried out, cannot go unchallenged by fair minded people! We are seeking help in the following 3 ways:

1. We need attorneys to consider taking this case. (Not pro bono)

Several interested law firms have been unable to accept this case, because of the complexity of it.

2. We need donations to defray legal costs.

Attorney have stated that this weill be an expensive time consuming litigation.

3. We need to replace a construction mortgage with a land mortgage

In March, 2007, a generout local mortgage company funded the renovations for theTitus Roberts House. That conventional mortgage was to be secured by the increased equity of the house improvements.)

Your support is desperately needed. Please contact Ken Karl if you can help.

Call 860.583.5025, Write: 462 Washington Street, Bristol, Connecticut 06010

E-mail: KenKarl@TitusRobertsHouseJustice.org