In Tessitore v. Tessitore, 31 Conn. App. 40, 623 A.2d 496 (1993), the Court reversed that portion of the judgment of the trial court that pertained to the finding that a fraudulent transfer had occurred where the court, in its memorandum of decision, stated only that the transfer at issue was "an obvious effort to deprive the plaintiff of any interest in the property." Id. at 43 n.4. "Because we were not satisfied that the more exacting, clear and convincing standard of proof was used," we concluded that a new trial was necessary. Id. at 43.