Illegal Eviction Housing Motion To Strike And More
Link to this blogpost:
http://www.publiusroots.org/2024/11/illegal-eviction-housing-motion-to.html
REFERENCES
https://singhasongflower.blogspot.com/2024/11/home-on-deranged.html?m=1
https://thunderflower2021.blogspot.com/2024/09/illegal-eviction-2024.html?m=1
http://www.publiusroots.org/2024/12/illegal-eviction-motion-to-continue.html
there are 2 more links showing on this one, if you are up to it.
TRANSCRIPTS
Yet they were corrupted - recording altered which is typical in this corrupted state! They use the same technology as movie producers use.
http://www.publiusroots.org/2024/12/illegal-eviction-transcripts.html
WHY? That is what I would like to know! The Notice To Quit was Invalid! They did not even use the Court Form yet Housing Chief Clerk loves to give mini lectures how the their forms take precedence! Additionally, the attorney failed to cite the law on their tricked document!
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Sec. 47a-23a. Complaint. (a) If, at the expiration of the three days prescribed in section 47a-23, the lessee or occupant neglects or refuses to quit possession or occupancy of the premises, any commissioner of the Superior Court may issue a writ, summons and complaint which shall be in the form and nature of an ordinary writ, summons and complaint in a civil process, but which shall set forth facts justifying a judgment for immediate possession or occupancy of the premises and make a claim for possession or occupancy of the premises. If the claim is for the possession or occupancy of nonresidential property, the writ, summons and complaint shall also make a claim for the forfeiture to the plaintiff of the possessions and personal effects of the defendant in accordance with section 47a-42a. If the plaintiff has properly issued a notice to quit possession to an occupant by alias, if permitted to do so by section 47a-23, and has no further identifying information at the time of service of the writ, summons and complaint, such writ, summons and complaint may also name and serve such occupant or occupants as defendants. In any case in which service is to be made upon an occupant or occupants identified by alias, the complaint shall contain an allegation that the plaintiff does not know the name of such occupant or occupants. Such complaint shall be returnable to the Superior Court. Such complaint may be made returnable six days, inclusive, after service upon the defendant and shall be returned to court at least three days before the return day. Such complaint may be served on any day of the week.
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(a) Any tenant who claims that the landlord has failed to perform his or her legal duties, as required by section 47a-7 or 47a-7a or subdivisions (1) to (13), inclusive, of subsection (a) of section 21-82, may institute an action in the superior court having jurisdiction over housing matters in the judicial district in which such tenant resides to obtain the relief authorized by this section and sections 47a-7a, 47a-20 and 47a-68.
I PAID MY RENT! I SHOWED THE COURT THE CHECKS! THE JUDGE SAYING THE NOTICE TO QUITE IS VALID BECAUSE THEY TYPE AND SOMEONE "SERVES" IT IS CALLED - ABUSE OF PROCEDURE, NOT VALID! AND THERE IS NO PROOF OF THE MARSHAL SERVING IT ON THE 12TH OR THE 13TH - THEY ARGUED BOTH, IF YOU CAN BELIEVE THAT ONE! My neighbor said on the 20th that "A man stopped by two days ago and was looking for you"....she was talking about the alleged marshal....I just told her that was not her concern; he should have gone to the management. He was just using Cindy to add hype and if I used her as a witness, which I would certianly not do since she is disabled from cerebral palsy, she said the 18th it was put in my door! Date on it is the 12th! They flipflopped about serving it on the 13th - a botched job of trickery, which they concocted when they found out I was expecting a Home Depot delivery on the 13th after I called the concierge on the 12th. I was so sick on the 13th, I called and asked to set the crates aside because I expected this would take a while to get over. Most likely they poisoned me somehow.
No tenant may institute an action under this section if a valid notice to quit possession or occupancy based upon nonpayment of rent has been served on such tenant prior to the institution of an action under this section or if a valid notice to quit possession or occupancy based on any other ground has been served on such tenant prior to such tenant making the complaint to the agency referred to in subsection (b) of this section, provided any such notice to quit is still effective.
Definition of VALID:
having legal efficacy or force [a license] ;esp. : executed with proper authority and form [a contract] [a search] 2 : having a legitimate basis.
Note: I will TRY TO provide a link to this complete case and another link to Housing and Section 8 Laws asap; hopefully November 20, 2024 - This is a costly thing and also very difficult to put together in this small apartment. I certainly cannot do it in public.
DOCKET NO. NHH-CV24-6024196-S : SUPERIOR COURT OF CT
ANSONIA STATE STREET, LLC : J.D. OF NEW HAVEN
V : HOUSING SESSION
ANNE M. BRADLEY : November 20, 2024
MEMORANDUM OF LAW
MOTION TO STRIKE PLAINTIFF’S MOTION TO OBJECT TO
MOTION TO DISMISS
HISTORY
1. An invalid Notice To Quit was crumpled in Defendant’s Door on September 18, 2024. There was no cited law on this Notice. It was not a Form JD-HM-7.
2. Upon opening her door on September 20, she discovered it was backdated to September 12, 2024 - two days after September 10 due date for rent, which was paid by Defendant and her account is current with exceptions with Fraudulent Billing by the landlord. No Ledger was produced by this Plaintiff because of that.
3. Marshal’s Proof of Service indicates it was served on September 13, 2024. Yet there was no proof a marshal served it. He would have had to go through the concierge or management to get to that floor if he did not live on the premises. No one rang her doorbell or knocked or called her. Defendant’s neighber next door was obviously told by someone to catch her outside as she was leaving her apartment on the 20th
a) At that time Cindy told her, “A man was looking for you two days ago and came to my apartment asking me where you were”. Defendant told her neighbor that was not any of her concern, no one should be using her for these tactics, it is not fair to her, and that person should have gone to management or the concierge.
4. On September 20, 2024, Defendant Anne Bradley was told by the Housing Court that she could not file a Housing Complaint; that it did not matter that the Notice To Quit was invalid.
5. Defendant did her own research, which was very difficult since the landlord of 360 State Street - which claims to be represented by Hoops & Associates, cut off wifi in her apartment January 2023 after she complained about the maintenance supervisor relieving himself in her bathroom and vandalizing the sink and tub faucets. They also remotely turned off her washing machine and vandalized her bed which caused her to sleep on her floor for almost two years before it was repaired just recently, in August 2024. Other vandalizing took place - all indicated in the Housing Complaint, Case No. NNHCV245006875S.
a) She found the state law which gave her the right to issue a Housing Complaint. The Housing Court again refused to take her papers and said nothing about any forms which were required as reason.
b) Defendant faxed her Complaint, which was formatted as a motion and titled COMPLAINT, along with a fee waiver.
c) The court rejected her complaint and at that point indicated she had to complete forms. The Chief Clerk obviously realized the dynamic and argument was placed on an invalid NOTICE TO QUIT as reason to proceed with her Housing Complaint.
d) Those forms were typed with “see attached” and on the attached had the heading of the case with title, for proper record-keeping. Chief Housing Clerk of New Haven, Attorney Pitt disrupted the form, claimed “The Court never takes attached lists - you have to hand-write everything on forms, creating numerous pages which resulted defective information. This was on a Friday.
i. Attorney Pitt corrected the address for BEACHWOOD PROPERTIES, still referring to it as that name; yet the Secretary of State altered the record to BEACHWOLD having access to the uploaded complaint prior to it being served.
1. Peter Hoops, who claims to be an attorney who entered the BAR in 1987, entered BEACHWOOD instead of BEACHWOLD as his client on an attached list to his appearance.
2. Defendant discovered the change in record over the weekend on her phone and thus used that information while typing the form using wifi elsewhere on another day.
e) The following Tuesday, Defendant submitted in person REPLACEMENT FORMS.
i. Attorney Pitt refused to take them as replacement forms, saying he already uploaded the UNSERVED CASE.
ii. Defendant Anne Bradley claimed that should be illegal to do since it was not served yet.
iii. Defendant thereafter claimed that this eviction case was NOT uploaded even after they served her which reflects ABUSE OF PROCESS, FRAUD. This Eviction case was not uploaded for a week. Attorney Pitt encouraged Defendant not to appear, not Answer, “You have all the time in the world. That was nice they gave you until October 15”. Defendant claimed that it was just a trick and she resented her case not being uploaded in the case information system, and requested to either dismiss the Summons and proceedings thereof or upload it. Attorney Pitt claimed, “I cannot do that. The attorney does that. He is in charge.”
iv. Dates of uploaded documents are not consistent with the actual dates the documents were submitted on either the Housing Case or this Eviction Case, which alters the course.
v. Similarly-situated cases show when the Housing cases are uploaded and when Defendants are ordered out for NonPayment of Rent. That is not what this case fits. Defendant is greatly aggrieved by this abuse by the landlord.
f) Defendant claimed that the reason for the Housing Complaint was numerous and longstanding housing problems: lack of maintenance, numerous illegal entries, vandalism, theft, and a few particularly traumatic situations such as the most recent one on July 2, 2024 when the maintenance manager illegally entered when she was taking a bath. Defendant asserted her rights by submitting her Housing Complaint in Housing Court as she has tried a number of times to get her rights through the landlord and the two agencies on her Housing Complaint - since 2013. She submitted complaints to the landlord numerous times. She complained to the agencies on that Housing Complaint Case and produced numerous pages of proof she contacted Livable City Initiative as well as Elm City Communities. Complaint is 246 pages long. Defendant could not undersand why the non-appearing defendants were at the least not DEFAULTED by the Chief Clerk; and since none of them Answered in the two week time period by law, why they were all not defaulted.
g) Defendant asserted her defense that the NOTICE TO QUIT WAS INVALID and the court agreed by accepting and entering her housing complaint as NNHCV245006875S This is not a “proof” which she is emphasizing; yet certainly portrays that the court was giving this serious thought. The checks were provided, to prove the rents were paid. Judge Stone indicated in that hearing that Defendant did not need to argue the issue about how much her rent should be. Defendant had done this because the Plaintiff added this additional quip to its complaint, which was wrong for all purposes. The last agreed upon rent has been the rent she has been paying. No form was ever sent to her regarding signing anything and the landlord’s record indicates her rent is $171/month - not $198/month. On-site charges are not the responsibility of the Section 8 tenant. This is at the least a regulation set by HUD which Defendant sited years ago, resulting in this landlord getting state police to stalk her in the lobby and falsely arresting her. This way, they could evict her, which has been the dynamic ever since - despite the fact she pays her rent every month by the 10th of the month. The Lease is at Appendix A. This includes the Housing Addendum, which controls the lease for legal purposes.
i. Is it not the responsibility of the court to determine merit on a case by a pro se litigant, prior to accepting it in court and docketing it?
ii. Due to the fact that she paid her rent for August and September; their claim for nonpayment of rent was FALSE which makes the Notice To Quit invalid.
iii. Due to the fact that the marshal made improper service, crumpling this paper in her door on the 18th of September, which appeared to be a bomb or the like. It was not placed through the large separation between her door/doorframe.
1. The man who referred to himself as “Attorney Hoops” and claimed to have written the Motion To Dismiss at the hearing on October 31, had no valid reason for the marshal gaining access to the building on his own and only stated in argument, “He signed an affidavit that he served it”.
a) This man appears to be in his early thirties and yet uses a Pro Hac Vice Juris Number; pulling up that Juris record, the ACTIVE Juris number is also there, but he fails to use it; and it indicates he entered the BAR in 1987, which most likely was before he was born.
iv. No law was cited on the Notice To Quit; they did not use the court form, which cites the law.
v. No ledger was attached; no letter to prove they sent a letter previously was attached. Nor was one produced in court.
vi. There was no explanation on why they consider it lawful to date the Notice To Quit just two days after the 10th of the month, which the rent could be paid by. Appendix Laws_Page_____ And there was no letter given to the Defendant beforehand, which is a requirement by Section 8 when an accusation of nonpayment of rent exists. Defendant has approached the building manager as follow-up of her documented grievances, which she meticulously prepared. His response was, “They told me not to talk to you.”
6. Housing Complaint was initially submitted on September 25, after struggling for weeks with the Housing Court about having her right to do so. This was rejected by Attorney William Pitt, who claimed forms had to be completed. Forms were typed; William Pitt rejected the typed forms and told defendant to hand-write them on October 1. This was done and on October 3, Monday, defendant submitted replacements on October 8. William Pitt claimed because her fee waiver was already granted on October 3, he uploaded the unserved case; and replacements were not acceptable. He told defendant they could only have AMENDED at the top or he would not take them in. Defendant entered AMENDED at the top yet the AMENDED copies are awkward to find on the case.
a) Defendant “360 State Street” was served at 142 Temple Street, c/o Beachwold Properties. This location uses other business names as well. They did not return it to correct the record. They accepted it when it was not valid. The marshal served it when it was not valid according the Defendant’s discovery that 360 State Street has an agent of service on Whitney Avenue.
i. Someone may have altered that record as well. Nevertheless, the Complaint packet should have been returned to the court in order to correct the record that 360 State Street’s agent of service is located on Whitney Avenue.
b) The Court is taking her fair use and value of rent into court, which was requested at the time the complaint was filed. This validated her rent was current since no rent can be accepted by the court unless it is current.
i. There was a delay in getting a marshal to serve papers. Attorney Pitt insisted on making copies of the Complaint and Appendix to be served. He would not allow defendant Anne Bradley to make them for NNHCV245006875S. Yet rather than have them done around October 18, he provided the copies sooner so she could get a marshal to serve the 8 sets of the Complaint. The Return Date is defective. Attorney Pitt indicated these proceedings were pretty informal and not to be concerned. According to law, they are supposed to answer a housing complaint within two weeks. There has been no answer. Defendant does not feel she got a fair shot at that housing complaint; which focused on her primary need to get repairs and maintenance done.
ii. This case was served by the Marshal on October 10. On October 24, her RETURN OF SERVICE was uploaded by the court, dated October 10, stating she served the documents on October 10, 2024. Anne Bradley, defendant, was alarmed that the marshal charged almost $3,000 for this service which seemed way too much. Attorney Pitt accepted her Proof of Service at some point between October 10 and October 24. He indicated at one point she did NOT serve all defendants as reason to not provide defendant the Proof of Service. Apparently there was a miscommunication yet it was ironed out.
a) The marshal was well aware of who was being served, since Attorney Pitt uploaded the case before it was served.
b) Yet the defect in serving 360 State Street still exists. Due to the Defendant Motion To Reargue and her Memorandum of Law needs to be entered into court, this issue will hopefully be submitted in the near future.
c) Defendant found it perplexing that the Secretary of State needed an additional copy and a fee of $50; which she said to the marshal and Attorney Pitt.
iii. Defendant entered her Motion To Dismiss on aforesaid case due to fraud, since she paid her rent and is current with her rent. .
c) Upload of the eviction case was DATED October 30, yet they only showed information from the Plaintiff despite the Defendant entering her Appearance and Answer on the same day it fell off the front of her door, October 24, 2024. This is not dated as such on the case even to date. From viewing former cases by the Hoops & Associates, Attorney Peter Hoops Appearance is not the only problem. The return dates have not matched and it is perplexing that he files a Covid Affidavit when that Act has expired. The moratorium on evictions has expired. Other attorneys are doing that same thing on cases, as noticed.
7. Defendant Anne Bradley called the court regarding this case since the “new” upload of November 4, Document No. 101 was marked as a judicial ruling on the case - not even relating to the defendant or this matter, a ruling dated in 2021 involving a Bank called Comenity and a different Anne Bradley. She considered this an act of fraud when she raised this concern to Attorney Pitt. Statements he made were:
a) Attorney Pitt claimed, “It doesn’t matter; I mailed you what we uploaded”
i. Defendant argued, “Of course it matters. This is cyber fraud at the least! You know I cannot go anywhere most of the time due to illegal entries in my apartment.” Now there are illegal entries on the case. This is typical Devil’s Chessboard tactics by someone.
ii. Defendant presumed that the court actually entered DISMISSAL: and was eager regarding this.
b) Attorney Pitt claimed the court had to ORDER THE PLAINTIFF Hoops Associates to change the return date to November 12, to reflect their Summons. He said it would take a long time to resolve. It is now Document No. 103 on the case information, yet also on Case Information, Document No 104 indicates that on November 7, the PLAINTIFF ordered the court to change what they apparently uploaded which the court allowed. This is quite perplexing.
i. Defendant claimed that it was strange that he allowed the unlawful Juris Number as out-of-state, that Hoops & Associates uploaded two separate pages on two separate occasions secretly added to this appearance file, listing what should either be on the form or on a continuance form, The return date on the Complaint was not complying; the return date on the attorney’s appearance was not complying; yet defendant considered the return date that was on the case file to be moot [since defendant Anne Bradley returned it before it was even uploaded as a case--which took a week for them to upload despite other issues overlooked made her concerned about getting her rights]. Defendant has stated, “How can I submit a motion without the docket number?” There was some difficulty preparing for the next hearing.
ii. Attorney Pitt claimed, “This will take a while to get them to comply. Defendant has worked diligently on this and is unable to get any grocery shopping done due to her struggles with theft in her apartment; she keeps her court documents with her at all times.
8. Plaintiff filed its Motion To Object, dated November 7; and Memorandum of Law on Motion To Object Defendant’s Motion to Dismiss, November 7 and dated these documents as November 6 with no correction to the date on the motion, simultaneously uploading this motion with its “Request To Conform”, which has no rule or law applied to it, which is puzzling to the Defendant.
FACTS/ARGUMENT
1. Notice to Quit was invalid, even fraudulent due to false information regarding nonpayment of rent.
a) Insufficient Service along with the fact that Plaintiff stated reason for eviction is non-payment of rent for August and September; dating it September 12 despite the fact that landlords are first required to previously issue a letter to a tenant to pay the balance in a certain length of time, yet they did not.
b) As Defendant has emphasized, in her opinion, they devised this tactic last minute after seeing notes by the concierge that a Home Depot shipment was going to be delivered on the 13th. Updated notes on her apartment account (by the concierge) indicated that she became very sick with the flu, and could not pick up the Home Depot delivery of 5 wooden crates until she got better. This was provided in the Housing Complaint.
c) On September 18, defendant discovered a wadded up something jammed in her door and was scared to open it since it may have been a bomb. Defendant determined it to be Notice To Quit with an advertisement for attorneys stapled to the Notice when she left apartment on 9/20/2024.
1. This Notice is supposed to be supported by the court since a marshal served it; yet the court denies they have to support the Notice, claiming the attorney or pro se landlord has power to make it an order. Defendant was ordered by the landlord to leave her apartment by October 18 - which is 30 days past the actual day someone set it in her door. It appears the Plaintiff backdated the Notice To Quit to reflect when defendant told the concierge October 12 that she was expecting her Home Depot package on October 13. Shortly thereafter, defendant called the concierge saying she was sick and would not be able to pick up her Home Depot order that was delivered on October 13.
d) A summons should have been issued the day after October 18 if this case was valid; although it was already unravelling since defendant entered a valid housing complaint before the Summons was issued since the Notice To Quit was invalid. No case brought forth by a pro se party can be uploaded if the court has not approved it for merit! Fee Waivers are processed with consideration of the case having merit as well. The Chief Clerk is responsible for this.
e) Defendant entered a Preliminary Statement regarding Costs affected by the continuous illegal entries, vandalism, fraudulent billing, and more on October 23 on the affiliated HOUSING COMPLAINT case. Plaintiff saw this document and seemed to have spontaneously responded the same day as retaliatory behavior with a Summons, . Defendant got home past 8 pm on October 23. The Summons was not seen until the following day, October 24; yet dated October 23 on the document and dated as served on October 23, placed in the common area of the buiding, on the doorknob outside of her door, rolled up, falling on the floor of the common area.
i. Electronic filing allows a party, namely attorneys, to upload pleadings whenever they want.
ii. Both parties are supposed to have equal privileges!
iii. It is not mandatory for anyone to have access to internet in order to have a case in court.
iv. Internet privileges for attorneys seem beyond the SCOPE OF LAW and therefore in many cases illegitamate.
v. Attorney Pitt has allowed Pro Hac Vice appearances yet from looking at other cases, this “F” appearance seems commonplace, as wrong as it is.
vi. It is apparent that Peter Hoops, who appears on the Housing Complaint affiliated with this case - has the same behavior as in aforesaid case. All eight parties served on the Housing case have either filed appearances or defaulted.
1. Exception: According to Hoops & Associates, they claim that the only landlord of 360 State Street is Ansonia State Street; yet fail to prove this; in particular show HUD’s permission for them to be a Section 8 landlord at that premises. No Section 8 tenant is required to process another “Request For Tenancy” packet since they are already here; already approved. The landlord is the one who has to be approved, should landlords change. USC Chapter 42, Section 8 Appendix
a) This man who claims to be “Attorney Hoops” joined the Housing Specialist, as relayed by the defendant in other submitted documents. The Housing Specialist claimed that defendant HAD to see her before the hearing on Motion to Dismiss/Motion To Strike on October 31. The Housing Specialist claimed that the hearing was marked off and the judge was only taking papers and either she negotiated at that meeting or there would be nothing for her. This was relayed in more detail in other documents submitted to the court.
2. There is a Modus Operandi with this Plaintiff, just basing this on the related HOUSING COMPLAINT CASE, which the court accepted in with merit. As Defendant Anne Bradley has claimed, there seems to be a Devil’s Chessboard interfering with this process. She paid her rent and the case should be closed.
3. “REQUEST FOR THE COURT TO CONFORM” by Plaintiff. Pleading has no rule or law in its request. Attorney Pitt claimed he mailed this to the Defendant, yet was it initiated by the Plaintiff, who uploaded this case? Why would they be entering a request like this? Document No. 104, entered three days after Document No 103 was entered by the court. Attorney Pitt assured the defendant on the phone, on Tuesday November 5, that the court order from another case dated 2021 (which pulled up when the defendant Anne Bradley tapped on it) was NOT what they did. She presumed the case was dismissed by the court yet for some strange reason a document replaced it for a time.
a) Document 104 is defective on its face since it has no cited law to verify its purpose. No law or rule was cited on the form; and it was reflecting the plaintiff’s attorney, Hoops & Associates, ORDERING THE COURT to change the return date on the case information, which they in fact uploaded a week after the Summons was served, since no case was even uploaded for that time, which seems wrong. Additionally, another week went by before the Chief Clerk claimed that the Return Date on the Case Information was a “big problem” and “this will take some time to fix since I have to mail them a request” yet they file electronically.
i. The return date on the Plaintiff’s appearance is BEFORE the date it is signed.
4. Plaintiff’s client - alleged landlord of 360 State Street, claimed they were getting Livable City Initiative to inspect all apartments. A trick! This trick failed because Section 8 tenants cannot have inspections through Residential Licensing. They have to be notified by the Housing Authority, which is the for-profit business titled ELM CITY COMMUNITIES, yet they withdrew their registration as a business with the Secretary of State under that name, continue using that name for their course of operations as a for-profit business, and entered several other names which are all run from 360 Orange Street, including one titled as 360 State Street Corporation. Motion For Disclosure seems to be missing in that case, yet the Appended document to Motion For Disclosure is. There was no Objection to this Motion.
5. Livable City Initiative has not appeared on that housing complaint, though Defendant the motion for disclosure on the same day it was entered in court; as was Elm City Communities AND a copy to the Housing Commissioner, Alberta Witherspoon.
1. Attorney Pitt claimed that only the attorneys can change information on the case because they uploaded it.
a) It is troubling to the Defendant that uploads of her documents do not reflect the very date of the documents, particularly in the Housing Complaint.
6. This Motion consists of several more Pages than usual; along with a thick Appendix. Defendant found it necessary to add detail due to the the length of time between the Notice To Quit and Summons. This was very difficult to prepare due to CYBER CRIME, TRAUMA EXPERIENCED CAUSED BY THE LANDLORD, including hacking despite being off-line for much of the duration of this - it occurs off-line as well as on-line.
7. The following directly responds to the plaintiff’s Motion To Object:
Due to cyber crime on defendant Anne Bradley’s laptop, she is unable to continue the auto format. This laptop is manipulated by Microsoft Windows even when offline.
1) The Objection is non-compliant in format as well as content. It is still a motion - WHICH SHOULD BE TREATED AS A MOTION TO OBJECT, ADDRESSING THE COURT, NOT THE SELF-SERVING WANTS OF THE CREATOR OF THE “OBJECTION”. This objection is at Appendix D Pages ___ to ____ due to Defendant’s need to mark identifying areas since there are no numbered paragraphs or even pages.
a. Either a motion is submitted to the court in its entirety the same day or the motion is submitted one day with a notation “Memorandum of Law To Follow”. This has been published as an order from the court due to excessive waste of paper and abuse of process. IT IS NOT ALLOWED.
b. The Objection does not have numbered paragraphs. THIS DISRUPTS THE FLOW IN COMMUNICATION and Defendant learned a long time ago was not allowed by the court through an order. The man who attended defendant’s Housing Complaint Hearing was much too young to be an attorney who entered the BAR in 1987.
i. Defendant is unable to plan anything due to the complexity and great stress that goes on in this case which has no merit and her unexpected need to spend much time just to complete one motion.
2) The concept of “interpreting” what is clearly English, is not only unprofessional but these twisting of words is not legitamate for attorneys to take part in. Page ___ Line ____ (The defendant had to place page numbers and line numbers due to the obtuse and noncompliant formatting of this person who fails to portray being an attorney in person or on paper. He seems as fraudulent as David Wheeler who claimed he was FBI Agent William Aldenburg at the trial involving Alex Jones, claiming that he was in tears and mourned the loss of the those who were shot to death at Sandy Hook Elementary School when in actuality Agent Aldenburg reported nobody died!) The Motion to Dismiss was issued in plain English. Attorneys are not supposed to be bending people’s words -- and to even document it is ludicrous. The argument/facts of the defendant Anne Bradley were enumerated and the fact this “attorney” wants to twist her words expecting himself to be unaccountable seems unfair.
a) Plaintiff’s argument regarding the defendant, Pro Se, not producing the law which states the landlord is required to issue a letter stating how much is owed and why -- is located in the HOUSING COMPLAINT, as argument on why it is valid. The Notice To Quit is invalid; the court docketed the Housing Complaint which reflects rent is current! It would not accept the rent payments if it did not, as part of the process of validation. And certainly this would be correct, since Defendant has paid her rent every month, even when she has requested hardship, which according to the State’s Section 8 Housing Reg, “The Plan” is automatically alloted to the requestor and thereafter reviewed to determine if this hardship exists by their standards. It seems futile to engage in any communication with this Housing Authority. They send her backdated letters which offer no consolation. Such as marking her as a no-show of a hearing which she knew nothing about. .
b) It is common knowledge and certainly a reflection of Plaintiff’s not having any competency by arguing that the law he knows exists was not specifically cited by the Pro Se.
c) This dynamic has absolutely no foundation and is not only a complete waste of time to keep on the books, for all concerned, but is reflective of “Attorney Hoops’” abuse of power over the law, and the court not doing anything about his illegal appearance, though many attorneys are entering Pro Hac Vice as if they are out of state. “Attorney Joseph St. Rock” does this as well. His signature no longer exists on his appearance and he placed a Juris number where it belongs; yet he has signed his appearance on other housing cases he has represented.
3) The very fact that the appearance is illegal and the court fails to address the illegality yet claims the moot return date to have an impact on the proceedings seems very puzzling.
a) The Chesson Law Firm did the same, using pro hac vice in its appearance.
b) The rent was paid for both August and September. Even overpaid for years, according the Section 8 Law Chapter 42, Section 8: if the tenant has a federal poverty level income, the rent is based solely on income and should be 10% of the declared rent which has been accepted by the fair rent commission, et al. As already shown in the Housing Complaint, this has been brought up in detail, documented to the Public Housing Authority, yet they do nothing but send back-dated letters as a means to abuse power..
c) The lease which was produced by the landlord just recently in the past two weeks for the Defendant upon request, comprised of approximately 43 pages and the rent amount indicated was $171.00. Nothing more. On-site charges are not the responsibility of the Section 8 tenant, as stated by the law. Hopefully that law is provided in the Section on Laws.
4) The apartment complex has had false fire alarms just in the past few days, which the defendant Anne Bradley did not leave her apartment for. This landlord has had MANY false alarms during the past 11 years, which are abusive and no longer trusted. Defendant had to go down 7 flights of stairs 3 times a week on an average for months - ON CRUTCHES - due to the abusive false alarms.
5) Attorney Hoops only quoted “too much” as reason to argue what defendant had relayed as a modus operandi,since 30 days was stated in the CARES ACT, WRITTEN BY THE SECRETARY OF TREASURY, NOT HUD, which is for all intense purposes relating to this case, is discontinued.
a) Plaintiff’s Attorney Hoops” claimed defendant stated in its Motion to Dismiss aforesaid case:
i. Defendant gave “too much” time on the Notice To Quit
b) Defendant’s Motion to Dismiss did not have “too much” as a phrase in the motion; nor did Plaintiff provide copy thereof in where it was to validate. Defendant’s Motion To Dismiss emphasized there was haphazzard corelation to what the Plaintiff cited as the CARES ACT, failing to even indicate any portion of it to validate which is a routine expectation for motions. He stated at the Housing Complaint hearing as well in his objection on aforesaid case, “The court knows this” This man who claims he is Attorney Hoops who entered the BAR in 1987, yet is obviously about 30 years old, said this a few times as argument in the Housing Complaint Case. Defendant objected His argument on the Housing Complaint case which was centered around his claim to be a valid NOTICE TO QUIT, which for all intense purposes is preposterous. He justified nothing except the fact it was typed by someone and someone placed it in her door.
c) Plaintiff’s representation, who calls himself Attorney Hoops, may perceive whatever he says will be altered for him by cyber crime, or an illegal intruder during a false fire alarm. There is no mention of “too much” let alone any of the other nonsense his “objection” indicates! This truly is a slap in the face of justice!
6) 1 (a) (1) page 2/Paragraph 1 entered by the Defendant in its entirety:
Insufficiency of Process; and Insufficiency of Service Process. The Notice To Quit was insufficiently served. It is unknown if the marshal even served it or when the marshal was actually paid. The marshal very likely lives at the same apartment complex. It was dated the 12th. The marshal may have approached Defendant’s door on the 18th since that was when an unknown object was wedged in her door. The only way the unknown would have been accessible is by possibly opening her door yet she feared it may have been a bomb. She stated that on internet along with posting a picture - if anything happened to her, there would be a record of this circumstance. Two days after it was wedged in her door, Defendant left her apartment to run some errands. She noticed they dated October 18 as the date for her to move out yet it was dated September 12, which made no sense.
i. Insufficiency of Process. People who do not pay rent are given just a few days to move out. Landlords do not give a 30-day “grace period” if rent had not been paid for two months and they have demanded the rent as part of the preliminary requirements to serving a Notice To Quit.
1. There was no letter of demand served the Defendant prior to the Notice To Quit, in accordance with the law. This so-called attorney who claims to specialize in LANDLORD-TENANT LAW, would know that as a basic requirement, particularly for nonpayments of rent.
2. The Housing Authority of the city is required to stop payments after three months of nonpayment of a Section 8 tenant. If this was a valid Notice to Quit, they would have dated the move-out sooner to continue an income for this apartment and also rent it to someone else before the three months were up.
3. There was no demand for payment signed by anyone at 360 Street.
a) There was no signed demand for payment submitted prior to the Notice To Quit, as required by Law.
b) There is a timeframe that should be issued to the tenant if no rent is paid; and October 12, just 2 days past the rent is due is not legitamate.
c) Defendant, Pro Se, says this whole case is botched together is a quick manner upon realizing that she got sick, and most likely they have attempted this and failed many times yet were successful on several incidences; to include twice she had to be on CIPRO for ten days.
4. Plaintiff claimed “paragraphs 4 and the CARES ACT paragraph on page 4” which has no logic as a response/argument yet the defendant stated this on Page 4, which by the way also has nothing to do with insufficiency of process by a marshal. Yet it has to do with the insufficiency of the Plaintiff preparing the Notice To Quit and thereof the Summons, which claimed the CARES ACT as reason with nothing quoted or cited. That aspect would be LACK OF MERIT OF THE CASE and would go along with the fact that rent was paid for August and September; proven by the defendant in her housing case, which was accepted due to the very fact that rent was paid! Why is this even a matter which the court is allowing to be heard? There is no merit to the case. Another copy of the cancelled checks is provided, with notations by the branch manager of her bank indicating in the upper right corners when they were cashed or deposited - into a bank account which most likely was fraudulent; nevertheless, that would take another case and a federal agent to prosecute.
5. Moratorium on Rental Evictions by CDC, which means the CDC would not allow rental evictions with the excuse of containing the alleged WUHAN VIRUS-> CORONAVIRUS->COVID VIRUS, whatever. They kept changing the name which showed lack of actual scientific validation. Nevertheless, the US Supreme Court ruled eviction bans were no longer allowed as of August 26, 2021. The CARES Act has no relevance to this case since it was written by the Secretary of Treasury, not HUD. There was not even any articulated argument by the Plaintiff in the Housing Complaint hearing regarding this in the associated Housing Complaint. He only said “The court knows this” and The Notice To Quit and Summons were typed and served; therefore legitamate. This only further proves how invalid the Notice To Quit was, and additionally, how greatly lacking in professionalism Plaintiff has in preparing its Motion To Object.
6. Even on Page ____ Line ___, Appendix ___, this alleged attorney states “as the court is well aware” which is not only inferring a conspiracy with the court yet complete disregard for responding legitamately to the defendant’s Motion To Dismiss - referring to it as absurd would be an understatement. It is disrespect to the court for an attorney make such a statement. Should he argue the point, he should produce documentation in which the court stated that attorneys are all required to produce affidavits on an act that was discontinued in 2022! From talking to an individual outside of court, defendant has learned that ATTORNEYS GET GOVERNMENT MONEY by referring to the CARES ACT. It was discontinued in 202! Not even an affidavit on this case has been produced to that affect. Attorneys as a rule, do not produce any affidavits anyway! It is not acceptable to the court.
a) Thereafter, a form with no valid law, was submitted, Appendix ______. It is unknown how often this form is used in court. It is not a published form.
7) On Page ___ Lines ____ this plaintiff states that defendant “admits the Notice To Quit was served at her door” . Defendant stated firmly that she did not know who placed the paper wedged in her door like a bomb; and she did not know what fit was for two days until she opened her door. This was a futile attempt in twisting words.
8) On Page ____ Lines ________ Plaintiff states:
a) Undersigned counsel’s office sent the Notice to Quit to Marshal Sandillo’s office on September 12. It is much more likely that the marshal served it on the following day and the defendant simply misremembered the day she discovered it, or did not discover it for several days.
i. This statement has no logic or point. It fails to respond to the actual facts which defendant set forth. This is a very small apartment. Plaintiff goes to her door often to retrieve kitchen items as well as clean and use for space since her apartment is not fully organized after the last round of dumping which was done by illegal intruders - placing nonessential items in her apartment which were in her storage unit at Storquest. They obviously stole anything of value, as Public Storage did with the help of Judge John Abrams, interfering with the lawsuit which the Plaintiff submitted, to include the marshal’s promising to serve Public Storage yet doing a complete reversal and holding onto the original documents for several weeks to cause dismissal of the case. Public Storage owed Defendant $450 from a prior case; and lied about not getting her money order which she submitted every month due to problems with making phone payments. She had a copy of it and since it was prepaid, they would have to wait for a replacement. This was all such a corrupted and evil violation on her, which was further enjoyed by corruption by the court.
b) The plaintiff admits the date of the Notice to be the 12th of October; the Marshal served it the following day instead of the day it was dated. These are tricks. They did this with the Summons also.
i. Aside from the fact that the marshal did not crumple it up and wedge it in her door until September 18; and aside from the fact there was not any statement as to why the paper was not slid through the obvious separation which exists in her door, the plaintiff admits the marshal broke the law by serving it on the wrong day it was dated.
9) This motion comprises of 17 pages and has been certified as served to the plaintiff with an illegal Juris Number in its appearance on this case on this day, November 19, 2024. Cyber Crime disrupted the formatting. Preferably, this should be PARAGRAPH 8 and the paragraph below should be PARAGRAPH 9 yet the formatting was disrupted and will not extend back out to the left margin.
10) The extra pages were necessary in order to relay to the court specific manipulations made by the Plaintiff, who has an illegal appearance yet the court failed to remove the case or even act on the fraudulent appearance - and a week after it was uploaded, which was two weeks after the Summons was served, the court picks the RETURN DATE to correct, which was moot. Why is it that attorneys are making pro hac vice appearances? .
Is it not fraudulent for a marshal to serve a Notice To Quit on a different day it is dated?
1. NonPayment of Rent accusation has no merit. Rent was paid. Appendix ___ shows the checks once again, since they have been already presented to the court and no dismissal on this case has taken place, although it was requested in the Housing Complaint.
a) Livable City Initiative failed to appear on the Housing Complaint and are party to the case. The court should have served them a DEFAULT yet did not.
b) The Plaintiff entered BEACHWOOD instead of BEACHWOLD as a client of theirs. It is the Defendant’s belief this fraud goes deep, altering records goes deep.
Plaintiff admits they used the Juris number for pro hac vice, which is out of state - and rather argue an error (on such an everyday task, which would be a hard-sell yet it was not even attempted) he defends using a pro hac vice appearance with a ‘we’re good guys’ - type of reasoning. Pro Hac Vice means they are out of state; they are frauding records! Additionally, as already stated, the Plaintiff has already shown to be a fraud on many counts based on his nefarious behavior including statements to the court. At the hearing on October 31, the young man who claimed he was “Attorney Hoops” said he wrote the Motion To Dismiss on that case and claimed it was his motion he was arguing. Rather, the motion was signed by an alleged attorney “Joseph St. Rock" using a fraudulent Juris number, Pro Hac Vice.
2) This motion comprises of 17 pages. Defendant trimmed as much as possible from this, yet page numbering seemed to be same. It was prepared to the best of Defendant’s ability and is true and correct to the best of her ability.
LAW
1. “In Connecticut, a “strike” refers to a legal motion called a “Motion To Strike:, which allows a party to request the court to remove any “irrelevant, false, or improper matter asserted in any pleading.” from the case, essentially meaning that the court can eliminate parts of a complaint or other legal document that are deemed legally insufficient or not relevant to the case at hand.
Key points about a Connecticut Motion To Strike:
Purpose:
To challenge the legal sufficiency of allegations within a pleading. Including whether the claims stated are legally valid or if the requested relief is appropriate.
What can be struck:
Any part of a pleading that contains irrelevant, false, or improper information
When to file: Note, this Motion was difficult to put together. The three pages are of Defendant’s Statement regarding her Motion To Strike, the third page having been altered. This statement is located at Appendix E; being that for some strange reason her third page was up;oaded without her hand. This motion is typically filed before trial, giving the opposing party a chance to address any issues with their pleading.” - quoted from the Connecticut Judicial Branch Law Library
Additional Laws are Provided in Appendix
Summary
This Motion To Strike on the plaintiff’s Objection has three issues:
1) There is no merit to the case; rent was paid for August and September! They cannot argue anything else on this case!
2) Formats of Motions by attorneys cannot be off-the-hip. There was not even any section on Law, nor was any law or caselaw provided for the pro se defendant to read. This alleged “Law Firm” which calls itself “Hoops & Associates” submitted an equally-deficient Motion To Dismiss on the Housing Complaint, which Anne Bradley, Plaintiff on that case, entered a Motion To Strike on. For an attorney, that is clearly disrespect to the court on several counts. The additional deliberate abuses of the law and Devil’s Chessboard tactics only make this Eviction case more reason to throw out.
3) This catch-me-if-you can breaking laws, depriving the defendant of access to internet, causing even her phone to be extremely difficult to read - all through cyber crime - and more -- is all about CORRUPTION AND MALICIOUS AND VEXATIOUS INTENT - not administering the law. Not even administering any logic. Defendant has been greatly abused for the duration of time she has been at 360 State Street in the same small 150 square feet or smaller apartment - though other Section 8 residents who are single have larger apartments and most likely pay the same or less. She has shown in her complaint on the affiliated case that she has tried to get her rights in every way and was cheated or ignored. Defendant pays her rent timely every month and will not pay any more; will not allow them to cheat her; and reminds this court their constant illegal entries and even breaking into her apartment while she is in it - have never been litigated. This is not run by professional people. When they claim that Ansonia State Street took over this building, November 2022, Appendix ____, no one even sent defendant any notice regarding any balance due BECAUSE IT WAS FRAUDULENT AND A COURT ORDER MADE THEM REMOVE THE APPROX $14,000 FRAULENT CHARGES from her ledger - approximately two months after this alleged owner took over this buidling. They turn around and add the same fraudulent charges all over again as well as lie about bounced checks as TD Bank repeatedly mailed them fraudulent checks for a year or more. Despite the office fully knowing the checks were on a non-existent account, they charged the defendant in excess of $30 each for overdrafts and made up more charges The ledger has been nothing but fraudulent billing on a Section 8 tenant who is only obligated to pay the Section 8 Rent-To-Owner. On-site charges are to be submitted to the administrator.
4) In fact, as a Title 19 poverty level income with QMB and Medicare is proof she has a Federal Poverty Level Income. APPENDIX E
a) She does NOT have MEDICAID AND NEVER WILL. The State of Connecticut is very corrupted. There is obscunding of Federal Funds, allowing Medicaid to attach to QMB recipients. APPENDIX E The State of Connecticut has no right to her medical records and this whole political agenda is nothing but criminal. Medical Facilities are already refusing to continue to participate in 3d party commerial insurance billings referred to as “Medicare Advantage” such as Aetna and Blue Cross and Blue Shield; which means the insurane companies are fed government money and the indigent insured are left “high and dry”. It is criminal on so many levels. Nevertheless QMB cannot be discontinued and that is what she has. Never will she be willing to see a doctor in Connecticut. She has been almost killed by them and knew people who were; even a public friend who just went in the hospital to get a bunion removed. These elite doctors “play God” and target anyone the elite politicians want to be killed or further harmed.
b) Note, Social Services were informed by this Housing Authority or Plaintiff that defendant pays $93.20 for rent, which is fraudulent and cause for them to lower food stamps even more. Appendix E.
Appendix Included
Prepared and Submitted,
_________________________
Anne M. Bradley, Pro Se
PO Box 206514
New Haven, CT 06520
Ph 203-508-0858
RULING
The foregoing motion, having been heard, is GRANTED/DENIED
___________________
THE COURT
CERTIFICATION OF SERVICE
DEFENDANT’S MOTION TO STRIKE PLAINTIFF’S MOTION TO OBJECT
DOCKET NO. NHH-CV24-6024196-S
November 19, 2024
Plaintiff certifies that a copy of the foregoing has been served on the following REPRESENTING Plaintiff WITH ILLEGAL APPEARANCE as Pro Hac Vice:
HOOPS & ASSOCIATES FAX: 860-445-8919
_________________________
Anne M. Bradley, Pro Se
DOCKET NO. NHH-CV24-6024196-S : SUPERIOR COURT OF CT
ANSONIA STATE STREET, LLC : J.D. OF NEW HAVEN
V : HOUSING SESSION
ANNE M. BRADLEY : November 19, 2024
APPENDIX
DEFENDANT’S MOTION TO STRIKE
PLAINTIFF’S MOTION TO OBJECT TO MOTION TO DISMISS
PAGE___
A Lease
B Laws
C Case Examples
D Plaintiff’s Objection to
Defendant’s Motion To Strike
E MISC ADDED
F Motion For Disclosure
G Backdated Housing Authority Letter
Obtained by Defendant in person
No request to sign/agree; no hearing at Defendants Request
H Marshal’s Proof of Service
On Housing Complaint and Charge which seems excessive
I Request To Conform
Both Court Documents 103 and 104
J Mortgage and one of several media articles: “360 State Street sold for $160 million”
_______________________________
Anne M. Bradley, Pro Se
DOCKET NO. NHH-CV24-6024196-S : SUPERIOR COURT OF CT
ANSONIA STATE STREET, LLC : J.D. OF NEW HAVEN
V : HOUSING SESSION
ANNE M. BRADLEY : November 19, 2024
APPENDIX E
Statement by Defendant
Re: Cyber Crime
Page No.
The Defendant emphasizes this motion was extremely difficult to put together due to Cyber Crime interferences. Please note:
1) November 15 “Defendant’s Memorandum Of Law” as titled in case information. It is a Notice to court on delay in submission. Though the actual copy has “x”’d out “Ryan P. Driscoll”, etc. with Defendant’s initials, the upload of this document has been altered by Cyber Crime in the court. Consider this: where there is smoke, there is fire.
2) Hacker on defendant’s laptop. This includes her mousepad being disabled by cyber crime. Also, Pages 15-16. This was left on the document as a means to show one incident of many while preparing this. The hacker takes text from the clipboard and inserts it like this FREQUENTLY. Defendant used [brackets] to section that off.
___________________
Anne M. Bradley, Pro Se
J
UPDATE 12/5/2024
GUESS WHAT BOYS, AND GIRLS? THE INTERNET IS USED AS A RESOURCE BY THE JUDGE IN DECIDING MOTIONS - F*K THE LAW!
A Notice to Quit is valid if it complies with the law - not BS internet! The judge, who did not even appear at the housing complaint hearing - someone else did and the assigned judge ruled on it.
How much sense does it make for someone to use abuse of process to harass someone? The Notice To Quit can only be valid if it complies with the law!
But the judge stated it was valid for the housing hearing and not for the eviction ....but she wants trial anyway for the eviction. I focused on arguing two things:
Complaint on the Notice to Quit indicated I did not pay rent for August and September
I paid my rent!!!
CASE CLOSED!
=========================================
Using internet to cover for lies and incompetency is what I am up against!
- Must be in writing and properly delivered to the tenant.
- Includes the tenant's name, address of the rental property, and the date the tenant must vacate.
- Specifies a valid reason for termination, such as non-payment of rent, lease violations, or other breaches of the rental agreement.
- Follows the required notice period mandated by state laws depending on the tenancy type (e.g., month-to-month, fixed term).
- Missing information: Failing to include necessary details like the reason for termination or the move-out date.
- Incorrect delivery: Not properly serving the notice to the tenant as per legal requirements.
- Discriminatory intent: Attempting to evict a tenant based on protected characteristics like race or religion.
- Unlawful reason: Citing a reason for termination that is not legally permissible.
DOCKET NO. NHH-CV-6024196-S : SUPERIOR COURT OF CT
ANSONIA STATE STREET, LLC : J.D. OF NEW HAVEN
V : HOUSING SESSION
ANNE M. BRADLEY : December 4, 2024
DEFENDANT’S REQUEST AND NOTARIZED STATEMENT
Hearing took place December 3, 2024 at 2pm
Plaintiff Ansonia State Street, LLC stated in court that he was unaware of the attempted eviction on the defendant in 2019, although it was referred to more than once in the defendant’s Housing Complaint and thereafter.
Nevertheless, it is imperative that the court will upload whatever it provides to the plaintiff, to ensure an accurate record. This is the request of the defendant, should that not take place as a natural course of events.
Additionally, defendant was permitted by Judge Stone at this hearing that she may submit a deposition. Instead, defendant emphasizes that her argument was straight-forward; this case is based on nonpayment of rent for August and September and she has proven she has paid her rent and the plaintiff has not proven anything; to include failing to submit a ledger and failing to produce a letter from the landlord which demands payment by the defendant; and failing to produce proof that the Housing Authority was notified - all required by law. Telling the court that the defendant cannot cite those laws only reflects lack of professionalism and playing ‘catch me if you can’. as stated in court.
Defendant has suffered for many years from poor maintenance, illegal entries, and even trauma caused by employees who have been on this premises before, during and after this property was allegedly purchased by Ansonia State Street. There is no proof shown to the defendant that they are HUD approved, which should be quite a simple thing to determine and provide - and even reflect a better image of the company. The trauma from the maintenance manager breaking into her apartment and screaming for her life is indeed a serious housing matter. Should she prevail on this case, she will seek a Motion To Open on the Housing Complaint, and will be submitting a request for the Appellate Court Extension of Time, if incase she does not prevail on this case. A copy of that submission for Extension of Time will be provided to this court on the Housing Complaint. E-Services is processing her request for Exemption from e-filing since wifi was blocked from her apartment two years ago, after defendant complained about the maintenance manager defecating in her bathroom trashcan.
1
Prepared and Submitted,
FOR THE DEFENDANT
_______________________
Anne M. Bradley, Pro Se
CERTIFICATION OF SERVICE
DOCKET NO. NHH-CV24-6024196-S
December 4, 2024
Plaintiff certifies that a copy of the foregoing has been served on the following REPRESENTING Plaintiff WITH ILLEGAL APPEARANCE as Pro Hac Vice
HOOPS & ASSOCIATES FAX: 860-445-8919
_____________
++++++++++++++++++++++++++++++++++++++++++++++++++
Dec 6 - to submit tomorrow
DOCKET NO. NHH-CV24-5006875-5 : SUPERIOR COURT OF CT
ANNE M. BRADLEY : J.D. OF NEW HAVEN
V : HOUSING SESSION
ANSONIA STATE STREET, LLC et al : December 6, 2024
PLAINTIFF’S REQUEST TO CONTINUE ACCEPTING
FAIR USE AND VALUE INTO COURT
PENDING APPEAL OR MOTION TO OPEN
Plaintiff requests this court to allow her to continue paying fair use and value into court since fee waiver for appeal was granted and appeal is pending. Motion to Open is pending, should plaintiff prevail in eviction matter involving both plaintiff and defendant on this aforesaid matter.
Bank check for $198.00 to cover rent for December 2024 is included with this.
Prepared and Submitted,
FOR THE PLAINTIFF PRO SE
____________________
Anne M. Bradley
PO Box 206514
New Haven, CT 06520
203-508-0858
CERTIFICATION OF SERVICE
DOCKET NO. NHH-CV24-5006875-5
December 6, 2024
Plaintiff certifies that a copy of the foregoing REQUEST has been served on the following REPRESENTING certain Defendants WITH ILLEGAL APPEARANCE as Pro Hac Vice. Other non-appearing defendants on aforesaid case should be defaulted.
HOOPS & ASSOCIATES FAX: 860-445-8919
SECTION 47a-35a - Bond on appeal. Rent to be paid into court(a) When any appeal is taken by the defendant occupying a dwelling unit in an action of summary process, the chief clerk of the Appellate Court, or the chief clerk's designee, shall transmit notice of the pendency of the appeal to the Superior Court that rendered the judgment that is the subject of the appeal. Upon receipt of the notice of the pendency of such appeal, the Superior Court shall schedule and conduct a hearing to guarantee payment for all rents that may accrue during the pendency of such appeal. The Superior Court shall schedule and conduct such hearing not later than fourteen days after the date of receiving notice of the pendency of such appeal. After conducting such hearing the Superior Court may order the defendant to deposit with the court (1) an amount equal to the defendant's portion of the last-agreed upon rent, or (2) where no lease had existed, an amount equal to the reasonable value for such use and occupancy that may so accrue. After hearing thereon, the court shall order the defendant to deposit with the court payments for the reasonable fair rental value of the use and occupancy of the premises during the pendency of such appeal accruing from the date of such order. Such order shall permit the payment of such amount in monthly installments, as it becomes due. If all or a portion of the defendant's rent is being paid to the plaintiff by a housing authority, municipality, state agency or similar entity, this requirement shall be satisfied if the defendant deposits with the court an amount equal to the defendant's portion of the rent.(b) In any other appeal the court on its own motion or on motion of the parties, may fix a sufficient bond with surety to the adverse party in such amount as it may determine.(c) When any appeal is taken by a plaintiff in an action of summary process, the court, upon motion of the plaintiff and after a hearing thereon, shall order the defendant to deposit with the court payments in monthly installments, as each payment becomes due, for the reasonable fair rental value of the use and occupancy of the premises during the pendency of the appeal accruing from the date of such order.
Conn. Gen. Stat. § 47a-35a
(P.A. 79-571, S. 61; P.A. 89-254, S. 11; P.A. 93-209 , S. 3 .)
Amended by P.A. 24-0108,S. 8 of the Connecticut Acts of the 2024 Regular Session, eff. 7/1/2024.
Where no lease existed and defendant made a motion to make payments for reasonable fair rental value of the property, an appeal bond is not required. 249 C. 482 . Cited. 5 Conn.App. 153 ; 29 CA 139 ; 40 Conn.App. 513 . Defendants who occupy dwelling units and appeal summary process actions have affirmative duty to initiate process by which court sets amount of bond with security or establishes use and occupancy payments. 140 CA 383 . Cited. 38 Conn.Supp. 70 .
+++++++++++++++++++++++++++++++++++++++++++++++++++++++
Dec 6 - MOTION FOR EXTENSION OF TIME TO APPEAL
THIS GOES SIMULTANEOUSLY WITH REQUEST TO PAY FAIR USE AND VALUE IN COURT
DOCKET NO. NHH-CV24-5006875-5 : SUPERIOR COURT OF CT
ANNE M. BRADLEY : J.D. OF NEW HAVEN
V : HOUSING SESSION
ANSONIA STATE STREET, LLC et al : December 6, 2024
PLAINTIFF’S MOTION FOR EXTENSION OF TIME TO APPEAL
HOUSING COMPLAINT
Pursuant to all laws on Appeal Form, as provided in Section on Law of this Motion, Plaintiff, Pro Se, motions this court for extension of time to appeal.
History
1. Aforesaid case had no trial and one hearing on Defendant’s Motion to Dismiss. Dismiss was granted by Judge Alayana Stone, though she was not the attending judge at the hearing. It is unknown who attended.
a) Several defendants failed to appear; they were not defaulted by the court.
2. Plaintiff submitted a fee waiver to appeal and submitted appeal form with the fee waiver including Request For Exemption due to not having wifi in her apartment anymore since her landlord blocked it two years ago after she complained about the maintenance manager defecating in her trash can in her bathroom when he was supposed to be just changing a filter in the dryer.
3. E-Services denied application for exemption, just discovered on December 5, 2024. They informed the plaintiff that she could re-apply, which she will be doing.
4. Hearing on Eviction case for non-payment of rent which reflects the same landlord on Case No. NHH-CV-24-6024196-S took place on December 3, 2024. Judge Alayana Stone officiated this hearing and said that the Notice To Quit was valid for aforesaid housing complaint and not valid - or may be considered not valid - for that eviction case. Plaintiff mentioned for that hearing on October 31, that she was denied articulation, re-argument, and another motion to sustain her rights. Judge Stone ruled on that hearing yet a different person was acting judge using her name. (According to the clerk of the court, on October 31, 2024, Plaintiff was informed that Judge Alayana Stone would officiate at 2:30 pm rather than noon as docketed.)
5. Plaintiff submitted a Statement the day after the eviction hearing, on December 4, indicating her preference to Motion to Reopen the Housing Complaint case; yet seeks to retain appeal rights should she not prevail on the eviction matter despite proving her rent was paid for August and September and she did NOT take possession of her apartment, as documented in the complaint, since November 2022 when acclaimed “new ownership” took place yet no HUD approval has been provided by management as she requested. No addendum to her lease has been created to validate new ownership.
FACTS/ARGUMENT
1. Plaintiff claims that it was not fair for E-Services to deny her Request For Exemption. She was told by E-Services that they did not make that decision, due to the fact it is not a Superior Court matter, but an Appellate Court matter. Upon calling the Appellate Court, they informed the plaintiff that they did NOT deny her request; that E-Services denied her request. Plaintiff called E-Services back and discovered the Appellate Court employee was misinforming her.
2. Plaintiff is disabled from a 20-ton truck slamming into her head-on deliberately. Both of her legs were operated on for 5 hours by three orthopedic surgeons. They are disabled to this day, along with having longstanding effects from broken ribs, severe head injury, and severe neck injury, and more.
3. Plaintiff has only used the court services computer to access information and also on two occasions had to type motions comprising of three pages or less due to cyber crime on her computer. She previously had to retype her housing complaint due to cyber crime and mentioned this in the complaint, being it was prepared later due to this struggle on her HP laptop. It was successfully typed on her computer by using strategies she has learned from experience, to counteract cyber crime.
4. Plaintiff, as Defendant, in the Housing Eviction case, motioned for transfer of that case since the same judge had already ruled that the Notice To Quit was valid, which is, among other things, conflict of interest, and reflects a predisposition to the outcome of the eviction case. Additionally parties which did not appear at the hearing were not defaulted. Judge Stone assured plaintiff she would have time to motion this later, should she want that; and that “we have not even had trial yet” and made statements regarding her ruling on that housing complaint, though without articulation.
LAW
The Laws and rules cited on the JD-SC -33 form are as follows:
PB Sections 3-8, 60-7, 62-7, 62-8, 63-3, 63-4, 63-10, and 72-3
CGS Sections 31-301b, 51-197f, and 52-470
Summary
This is a circumstance which has been longstanding, since 2013. Plaintiff has filed complaints with the landlord several times, along with the Housing Section 8 Authority, and with Livable City Initiative - all to no avail. She filed a complaint with the Better Business Bureau against Bozzuto Management, who were and may still be technically the owner. MEPT Chapel Street claimed to be nonprofit and solicited for donations, claiming they were part of the Church Community, with Satanic symbols displayed throughout the building. This landlord attempted to get her evicted using NONPAYMENT OF RENT in 2019 and was unsuccessful. Ruling by the court claimed she could not be evicted due to the landlord failing to issue a letter at least 30 days in advance of a Notice to Quit as what this ruling indicated to be a “cure period” for a Section 8 tenant. Additionally they failed to notify the Housing Authority. Defendant’s argument was “I pay the Section 8 rent every month and it is shown in the ledger. I owe nothing more and they fraud the billing.” The housing judge told the defendant, aforesaid plaintiff, in 2019, that she could not issue complaints on the landlord through the court. In July 2024, the maintenance manager smashed in her door while she was taking a bath, causing Plaintiff to scream for her life. Someone had gone to her door 1/2 hour before that. She got out of the tub and asked who it was; they would not answer. She called out again; they would not answer. She then emphasized to whoever was out there that no one would be allowed to enter unless they call beforehand. Her notes posted on her door are repeatedly ripped off by someone. She then resumed her bath. Plaintiff issued complaints on this to no avail. The manager on this premises, Kyle Huckle, responded, “I was told not to talk to you”. He did not respond in writing either. He was Assistant Property Manager and became Community Services Manager. There is no one with the title of Property Manager on this premises, which for all intense purposes is illogical.
It was only recently that she discovered that contrary to what Housing Court has told her, she could file a housing complaint as long as a VALID Notice to Quit was not served. The Notice to Quit was not valid to include the following reasons:
1) Primary: Rent was paid for August and September; rent has been paid into court thereafter and a separate motion to continue fair use and value into court pending appeal is being submitted.
a) Defendant Ansonia State Street claimed nonpayment of rent for August and September.
b) Hearing on October 31, was not officiated by Judge Stone; although Judge Stone briefly showed a fair amount of knowledge on the case during the eviction hearing of December 3; and she was the one who ruled on it.
c) Hearing On October 31 did not not involve Peter Hoops, who partly or wholly owns Hoops and Associates. The young man could never have entered the BAR in 1987, yet he claimed to be Peter Hoops and also claimed to be the writer of the Motion To Dismiss, yet it was signed by another alleged attorney in that office, Joseph St. Rock. These discoveries took place after the hearing took place and were documented, including the fact they, Hoops & Associates, have a Pro Hac Vice appearance, which reflects they claim to be out of state attorneys, yet they are not out of state.
Plaintiff is hopeful she will prevail in the Housing Eviction which has no merit and may proceed on the Housing Complaint with a Motion To Open. It is unknown why a different person officiated on the Housing Complaint Hearing and why Judge Alayana Stone ruled on it. As a Pro Se, Plaintiff seeks her rights as a harmed tenant, which is what she has submitted multiple times. It appears that Judge Stone would hear the housing case fairly should she prevail on the eviction matter. Therefore a Motion To Open would take precedence over going forward with an appeal, yet she is motioning for extension of time to appeal to retain her rights. She has contacted the ADA Office in order to resubmit a more detailed version of her Request For Exemption.
WHEREFORE, Plaintiff Anne Bradley motions this court for an extension of time to appeal, up to 30 days if necessary, not knowing when a final ruling will take place on the eviction case.
Prepared and Submitted,
FOR THE PLAINTIFF
_________________________
Anne M. Bradley, Pro Se
PO Box 206514
New Haven, CT 06520
Ph 203-508-0858
CERTIFICATION OF SERVICE
DOCKET NO. NHH-CV24-5006875-5
December 6, 2024
Plaintiff certifies that a copy of the foregoing has been served on the following REPRESENTING certain Defendants WITH ILLEGAL APPEARANCE as Pro Hac Vice. Other non-appearing defendants should be defaulted.
HOOPS & ASSOCIATES FAX: 860-445-8919
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There is an unknown - since the Appellate Court apparently sends its confirmation appeal is granted - and this would be an extension of time - which the appellate court claims is up to superior court to decide on. I have acknowledged the law regarding appeals and payment of rent into court; so I am not hiding anything. It is very very unusual to have wifi in my apartment and I was able to prepare another Request for Exemption to forward to E-Services. I was told I could re-request it.
None if this is any pleasure trip for me! THE CLAIM I DIDN'T PAY MY RENT IS A LIE! THEY HAVE NO CASE! THE NOTICE TO QUIT IS NOT VALID! THAT IS THE LANGUAGE OF THE LAW - NOT BS INTERNET - TECHNOCRACY USE INTERNET AS A TOOL TO TURN EVERYTHING UPSIDE-DOWN! THEY ARE NOT GODS, YET NOTICE TRUMP CREATED A NEW HUGE EXPENSE: DOGE = REVERSE e-GOD so Wake up to these psychopaths!
+++++++++++++++++++++++++++++++++++++++++++++++ 12/5/2024
Updated 12/18/2024
I submitted two fee waivers in the court to get transcripts of the housing complaint hearing and the transcript of the eviction hearing of Dec 3.
My fee waivers submitted previously had defective information on the first page - including indicating my social security income was income from wages. I would not have done that.
This is another sleepless night because the housing authority is conspiring with the landlord.
The landlord not only lied about my not paying rent for August and September but the court damaged the copies of the checks which is one of the reasons why I was DEPRIVED of doing my own copies! I had a right to make my own copies!
I go to the housing authority to pick up two things: The November 7 letter from Hoops Associates telling them they were evicting me - 2 months too late according to the law.
I also was getting proof they were continuing to pay HUD supplements since Hoops lied in court about the contract ending. That "she took possession of the apartment in November 2022"
Even though I argued those fraudulent statement, the court denied my motion to strike. Her reasoning is like this: a check is valid because you place the right spelling on it; so what if there is no money to back it up.
This is my email to the housing authority tonight:
Anne Bradley
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