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«
MOTION TO OPEN JUDGMENT A CONNECTICUT
(SMALL CLAIMS AND HOUSING MATTERS) SUPERIOR COURT
JD-CV-51 Rev. 6-19 Re 2 ue -www.jud.ct.gov
C.G.S. §§ 52-212, 52-2124, 52-259¢
P.B. §§ 17-4, 17-43, 24-31
NOTICE: This motion must be filed with the correct fee lired by [.=""—“Court Use Only
section 52-259c(a) of the Connecticut General Statutes.
MTOPJH SCMTO |
" Gwristopher Hafele” | (ENA
30 Nutmeg Lane,Apt-214
East Hartford, CCT.06118
og
ADA NOTICE
The Judicial Branch of the State of Connecticut
kK 4 complies with the Americans with Disabilities Act
(Name and address of defendant or defendant's atfomey) (ADA). If you need a reasonable accommodation in
Hoops & Associates ,LLC. accordance with the ADA, contact a court clerk or an
19a Thames Street ADA contact person listed at www.jud.ct.gov/ADA.
> Groton, CT. 06340
Docket number
L 4 HHD-CV21-5070038-S
“Judiciat Housing ‘Address of Court (Number, street, town, and zip code) q
> Rosner Cl secs 95 Washington Street, Hartford, CI. 06106
Name of case (Plaintiff vs. Defendant)
CHRISTOPHER HASFAL vs. WOODCLIFF ESTATES, LIC.
Motion to Open Judgment S-
| request that the judgment in the case named above be opened because: -C.G.S.S.47a-4 (alt 8,
"Prohibits Exculpatory Lease Clauses,"=that shields landlord from "Ligbitity,".5
-as set forth at C.G.S.S.47a-4;(3);(9)(b). The defendant installation of4 ulty
video surveillance camera and deliberate hinderance, impeded investigation fox :
NOTE: iis a aif fo oat fi Bent ant G8d Bosses ora GSB S? onset Athair aoe REF to by the person filing this
motion or that
Sigtted pig
Date signed
forbetore ae (Date) Sigr
Obfaipioe2
Certificatioh
| certify that a copy of this document was or will immediately be mailed or delivered electronically or non-electronically on
(date), ifs i 2 2 to all attorneys and self-represented parties of record and that written consent for electronic delivery was
received from all attorneys and self-represented parties of record who received or will immediately be receiving electronic delivery.
Name and address of each party and attorney that copy was or will be mailed or delivered to*
Hoops & Associates,LLCc.
19a Thames Street
Groton, CT. 06340
‘Comm. of Superior Court, Notary Public) See NOTE above
ith,name and address which the copy was or will be mailed or delivered to.
Print or type name of person signing Date signed
2 Christopher Hasfal t {23 lo 2
5 Sao — Tdlephghe number
ie ,Apt- Hartford, CT. 06118 (860) 461-3970
Notice of Court Hearing
A court hearing on this case has been scheduled. All parties must come to the héaring at the address and time indicated below. If you
cannot come to the hearing, you should let the other party know and get an agreement before you notify the court that you cannot come to
the hearing. (If you have any witnesses, please let them know about this court hearing so that they can be in court with you. Bring all other
evidence you want to show the court, such as bills, receipts, invoices, etc. If this motion is granted, a trial on the case may start the same day.)
aring (if diferent rom Address of Court above) Date of hearing Time Courtroom
a
Date —
Clerk of Court, by
Me CaWAIN Figo)
EXHIB lite
Date:
RESIDENT PARKING ADDENDUM
March 24, 2021
.
bed
eed WH
(when this Addendumlis filled out)
‘1, DWELLING UNIT DESCRIPTION.
“Unit No. 030214
214
30 Nutmeg Lane
(street address) in
East Hartford
Gity), Connecticut, __06118__ (zip code).
LEASE CONTRACT DESCRIPTION.
Lease Contract Date: March 24, 2021
Owner's name: Ansonia Acquisitions I LLC
2.
Residents (list all residents):
Christophe: Has:
The term of this Parking Addendum is as follows:
Beginsono and
endingon
This Addendum constitutes an Addendum to the above
described Lease Contract for the above described premises,
and is hereby incorporated into and made a part of such Lease
Contract. Where the terms or conditions found in this
Addendum vary or contradict any terms or conditions found
in the Lease Contract, this Addendum shall control.
RESIDENT AND OWNER AGREE AS FOLLOWS;
3. You agree to properly register all vehicles with management.
If you get a new or replacement vehicle you must notify us
and complete a revised agreement.
4, Ifyou are provided with a parking tag or sticker it must be
properly installed and displayed.
5. Unless your vehicle(s) has been assigned a specific space(s)
you may park in any available space(s) in the parking areas,
with the exception of spaces reserved for a particular use or
any marked handicap space, unless you possess a government
issued handicap decal or similar signage.
6. Ifyou are assigned a specific parking space(s) we shall assign
you the space(s) and retain the right to change assigned
space(s) at our sole discretion.
fou understand that we will not be held liable for any
‘damage or theft that may occur while your vehicle(s) is parked
on any part of the property. Upon signing this agreement
you knowingly accept the risk of parking any vehicle(s) on
the property.
Any action by you, any occupant, guest, orvisitor that violates
this addendum shall constitute a violation of the Lease
Contract. .
12. You understand and agree that any judgment of possession
entered against you shall be a judgment for possession of
any parking spaces which you are entitled to under this
addendum. Once such judgment is rendered and executed
upon you, you shall immediately remove all vehicles from
the property parking areas. If you fail to remove your
vehicle(s), ‘we shall tow the vehicle(s) at your expense. You
agree that we shall not be liable to you for damages related
to the physical towing nor any consequential damages you
may incur through loss of use of the vehicle(s).
COST FOR PARKING
Resident agrees to pay a onetime fee of $
per vehicle on or before the
day of
ee - In alternative
resident agrees to pay $. monthly per
vehicle due on or before the day of the month. If
no amount is filled in parking shall be free for properly
registered and authorized vehicles.
Resident understands and accepts that all-parking rights
and privileges will immediately be revoked in the case that
Resident is days delinquentin paying therequired
parking fee,
Resident agrees to pay $. 50.00
checks returned for non-sufficient funds.
VEHICLE INFORMATION:
Vehicle 1
Make:
Model & Year:
State:
License Plate:
Permit Number:
Phone Number:
Parking Space:
Vehicle 2
Make:
Model & Year:
State:
License Plate:
Permit Number:
Phone Number:
Parking Space:
7
NSF fee for all1/2722, 5:00 PM Section 47a-4 - Terms prohibited in rental agreement. :: 2012 Connecticut General Statutes :: US Codes and Statutes :: US Law ::
, a PTS
View the 2020 Connecticut General Statutes | View Previous Versions of the
Connecticut General Statutes
2012 Connecticut General Statutes
Title 47a - Landlord and Tenant
Chapter 830 - Rights and
Responsibilities of Landlord and
Tenant
Section 47a-4 - Terms prohibited in
rental agreement.
Universal Citation: CT Gen Stat § 47a-4 (2012)
rental agreement shall not provide that the tenant(a)grees to waive or forfeit rights
or remedies under this chapter and sections 474-21, 47a-23 to 47a-23b, inclusive, 47a-26 to
47a-26g, inclusive, 47a-35 to 474-35), inclusive, 47a-41a, 47a-43 and 47a-46, or under any
section of the general statutes or any municipal ordinance unless such section or ordinance
expressly states that such rights may be waived; (2) authorizes the landlord to confess
judgment on a claim arising out of the rental agreement grees to the exculpation or
limitation of any liability of the landlord arising under law or to indemnify the landlord for
that liability or the costs connected therewith; (4) agrees to waive his right to the interest
on the security deposit pursuant to section 474-21; (5) agrees to permit the landlord to
dispossess him without resort to court order; (6) consents to the distraint of his property
for rent; (7) agrees to pay the landlord’s attorney’s fees in excess of fifteen per cent of any
judgment against the tenant in any action in which money damages are awarded; (8) agrees
to pay a late charge prior to the expiration of the grace period set forth in section 47a-15a or’
to pay rent in a reduced amount if such rent is paid prior to the expiration of such grace
https://law.justia.com/codes/connecticut/2012/title-47a/chapter-830/section-47a-4/
121/27/22, 5:00 PM Section 47a-4 - Terms prohibited in rental agreement. :: 2012 Connecticut General Statutes
period; o (©) grees to pay a heat or utilities surcharge if heat or utilities is included in the
rental agreement.
|A provision prohibited by subsection (a) of this section included in a rental agreement is
unenforceable.
(P.A. 76-95, S. 4, 27; 76-435, S. 75, 82; P.A. 77-451, S. 1; P.A. 79-571, S. 9; P.A. 82-274, S. 3;
P.A. 87-154, S. 2; May Sp. Sess. P.A. 92-11, S. 37, 70; P.A. 05-56, S. 1.)
History: P.A. 76-435 revised effective date section of P.A. 76-95; P.A. 77-451 substituted
“shall” for “may”; P.A. 79-571 revised list of applicable sections and deleted former Subsec.
(c) prohibiting rental agreements which would permit receipt of rent for period during
which landlord fails to comply with Sec. 47a-7(a); P.A. 82-274 amended Subsec. (a)(7) by
restricting the limitation on the amount of attorney’s fees to actions in which money
damages are awarded; P.A. 87-154 added Subsec. (a)(8) prohibiting a provision whereby a
tenant agrees to pay a late charge or to pay rent in a reduced amount prior to the expiration
of the statutory grace period; May Sp. Sess. P.A. 92-11 amended Subsec. (a)(4) to correct a
statutory reference by replacing Sec. 47a-22 with Sec. 47a-21; P.A. 05-56 added Subsec. (a)
(9) prohibiting heat and utilities surcharge clauses in residential leases, effective October 1,
2005, and applicable to rental agreements or renewals of rental agreements signed on or
after that date.
Cited. 35 CS 151; Id., 549. Cited. 36 CS 611. Cited. 38 CS 683.
Subseec. (a):
Subdiv. (7) cited. 38 CS 341. Cited. Id., 393.
Former Subsec. (c):
Subsection must be read so as to provide tenant with remedy for landlord’s violation of
section 47a-7(a), and therefore tenant was not liable for rent while premises were
uninhabitable; uninhabitability of premises excuses withholding of rent. 35 CS 151. Cited.
36 CS 47.
Disclaimer: These codes may not be the most recent version. Connecticut may have more current or
accurate information. We make no warranties or guarantees about the accuracy, completeness, or
adequacy of the information contained on this site or the information linked to on the state site. Please
check official sources.
https://aw.justia.com/codes/connecticut/2012/title-47a/chapter-830/section-47a-4/ 2/21/27/22, 4:12 PM Section 47a-7 - Landlord's responsibilities, Conn. Gen. Stat. § 47a-7
L Search all cases and statutes...
Statutes, codes, and regulations
General Statutes of C...
Title 47A - LANDLOR...
Chapter 830 - RIGHT...
Conn. Gen. Stat. § 47a-7
Current with legislation from 2021 effective through October 1, 2021.
Section 47a-7 - Landlord's responsibilities
(a) A landlord shall:
(1) Comply with the requirements of chapter 3680 and all. applicable building and housing
codes materially affecting health and safety of both the state or any political subdivision
thereof;
(2) make all repairs and do whatever is necessary to put and keep the premises in a fit and
habitable condition, except where the premises are intentionally rendered unfit or
uninhabitable by the tenant, a member of his family or other person on the premises with
his consent, in which case such duty shall be the responsibility of the tenant;
(3) keep all common areas of the premises in a clean and safe condition;
G@rnainvain in good and safe working order and condition aliGlectrical plumbing,
sanitary, heating, ventilating, and, Qiher facilities and appliances and glevators, supplied or
required to be supplied by him;
- . .
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« MOTION TO OPEN JUDGMENT A CONNECTICUT (SMALL CLAIMS AND HOUSING MATTERS) SUPERIOR COURT JD-CV-51 Rev. 6-19 Re 2 ue -www.jud.ct.gov C.G.S. §§ 52-212, 52-2124, 52-259¢ P.B. §§ 17-4, 17-43, 24-31 NOTICE: This motion must be filed with the correct fee lired by [.=""—“Court Use Only section 52-259c(a) of the Connecticut General Statutes. MTOPJH SCMTO | " Gwristopher Hafele” | (ENA 30 Nutmeg Lane,Apt-214 East Hartford, CCT.06118 og ADA NOTICE The Judicial Branch of the State of Connecticut kK 4 complies with the Americans with Disabilities Act (Name and address of defendant or defendant's atfomey) (ADA). If you need a reasonable accommodation in Hoops & Associates ,LLC. accordance with the ADA, contact a court clerk or an 19a Thames Street ADA contact person listed at www.jud.ct.gov/ADA. > Groton, CT. 06340 Docket number L 4 HHD-CV21-5070038-S “Judiciat Housing ‘Address of Court (Number, street, town, and zip code) q > Rosner Cl secs 95 Washington Street, Hartford, CI. 06106 Name of case (Plaintiff vs. Defendant) CHRISTOPHER HASFAL vs. WOODCLIFF ESTATES, LIC. Motion to Open Judgment S- | request that the judgment in the case named above be opened because: -C.G.S.S.47a-4 (alt 8, "Prohibits Exculpatory Lease Clauses,"=that shields landlord from "Ligbitity,".5 -as set forth at C.G.S.S.47a-4;(3);(9)(b). The defendant installation of4 ulty video surveillance camera and deliberate hinderance, impeded investigation fox : NOTE: iis a aif fo oat fi Bent ant G8d Bosses ora GSB S? onset Athair aoe REF to by the person filing this motion or that Sigtted pig Date signed forbetore ae (Date) Sigr Obfaipioe2 Certificatioh | certify that a copy of this document was or will immediately be mailed or delivered electronically or non-electronically on (date), ifs i 2 2 to all attorneys and self-represented parties of record and that written consent for electronic delivery was received from all attorneys and self-represented parties of record who received or will immediately be receiving electronic delivery. Name and address of each party and attorney that copy was or will be mailed or delivered to* Hoops & Associates,LLCc. 19a Thames Street Groton, CT. 06340 ‘Comm. of Superior Court, Notary Public) See NOTE above ith,name and address which the copy was or will be mailed or delivered to. Print or type name of person signing Date signed 2 Christopher Hasfal t {23 lo 2 5 Sao — Tdlephghe number ie ,Apt- Hartford, CT. 06118 (860) 461-3970 Notice of Court Hearing A court hearing on this case has been scheduled. All parties must come to the héaring at the address and time indicated below. If you cannot come to the hearing, you should let the other party know and get an agreement before you notify the court that you cannot come to the hearing. (If you have any witnesses, please let them know about this court hearing so that they can be in court with you. Bring all other evidence you want to show the court, such as bills, receipts, invoices, etc. If this motion is granted, a trial on the case may start the same day.) aring (if diferent rom Address of Court above) Date of hearing Time Courtroom a Date — Clerk of Court, by Me CaWAIN Figo) EXHIB lite Date: RESIDENT PARKING ADDENDUM March 24, 2021 . bed eed WH (when this Addendumlis filled out) ‘1, DWELLING UNIT DESCRIPTION. “Unit No. 030214 214 30 Nutmeg Lane (street address) in East Hartford Gity), Connecticut, __06118__ (zip code). LEASE CONTRACT DESCRIPTION. Lease Contract Date: March 24, 2021 Owner's name: Ansonia Acquisitions I LLC 2. Residents (list all residents): Christophe: Has: The term of this Parking Addendum is as follows: Beginsono and endingon This Addendum constitutes an Addendum to the above described Lease Contract for the above described premises, and is hereby incorporated into and made a part of such Lease Contract. Where the terms or conditions found in this Addendum vary or contradict any terms or conditions found in the Lease Contract, this Addendum shall control. RESIDENT AND OWNER AGREE AS FOLLOWS; 3. You agree to properly register all vehicles with management. If you get a new or replacement vehicle you must notify us and complete a revised agreement. 4, Ifyou are provided with a parking tag or sticker it must be properly installed and displayed. 5. Unless your vehicle(s) has been assigned a specific space(s) you may park in any available space(s) in the parking areas, with the exception of spaces reserved for a particular use or any marked handicap space, unless you possess a government issued handicap decal or similar signage. 6. Ifyou are assigned a specific parking space(s) we shall assign you the space(s) and retain the right to change assigned space(s) at our sole discretion. fou understand that we will not be held liable for any ‘damage or theft that may occur while your vehicle(s) is parked on any part of the property. Upon signing this agreement you knowingly accept the risk of parking any vehicle(s) on the property. Any action by you, any occupant, guest, orvisitor that violates this addendum shall constitute a violation of the Lease Contract. . 12. You understand and agree that any judgment of possession entered against you shall be a judgment for possession of any parking spaces which you are entitled to under this addendum. Once such judgment is rendered and executed upon you, you shall immediately remove all vehicles from the property parking areas. If you fail to remove your vehicle(s), ‘we shall tow the vehicle(s) at your expense. You agree that we shall not be liable to you for damages related to the physical towing nor any consequential damages you may incur through loss of use of the vehicle(s). COST FOR PARKING Resident agrees to pay a onetime fee of $ per vehicle on or before the day of ee - In alternative resident agrees to pay $. monthly per vehicle due on or before the day of the month. If no amount is filled in parking shall be free for properly registered and authorized vehicles. Resident understands and accepts that all-parking rights and privileges will immediately be revoked in the case that Resident is days delinquentin paying therequired parking fee, Resident agrees to pay $. 50.00 checks returned for non-sufficient funds. VEHICLE INFORMATION: Vehicle 1 Make: Model & Year: State: License Plate: Permit Number: Phone Number: Parking Space: Vehicle 2 Make: Model & Year: State: License Plate: Permit Number: Phone Number: Parking Space: 7 NSF fee for all1/2722, 5:00 PM Section 47a-4 - Terms prohibited in rental agreement. :: 2012 Connecticut General Statutes :: US Codes and Statutes :: US Law :: , a PTS View the 2020 Connecticut General Statutes | View Previous Versions of the Connecticut General Statutes 2012 Connecticut General Statutes Title 47a - Landlord and Tenant Chapter 830 - Rights and Responsibilities of Landlord and Tenant Section 47a-4 - Terms prohibited in rental agreement. Universal Citation: CT Gen Stat § 47a-4 (2012) rental agreement shall not provide that the tenant(a)grees to waive or forfeit rights or remedies under this chapter and sections 474-21, 47a-23 to 47a-23b, inclusive, 47a-26 to 47a-26g, inclusive, 47a-35 to 474-35), inclusive, 47a-41a, 47a-43 and 47a-46, or under any section of the general statutes or any municipal ordinance unless such section or ordinance expressly states that such rights may be waived; (2) authorizes the landlord to confess judgment on a claim arising out of the rental agreement grees to the exculpation or limitation of any liability of the landlord arising under law or to indemnify the landlord for that liability or the costs connected therewith; (4) agrees to waive his right to the interest on the security deposit pursuant to section 474-21; (5) agrees to permit the landlord to dispossess him without resort to court order; (6) consents to the distraint of his property for rent; (7) agrees to pay the landlord’s attorney’s fees in excess of fifteen per cent of any judgment against the tenant in any action in which money damages are awarded; (8) agrees to pay a late charge prior to the expiration of the grace period set forth in section 47a-15a or’ to pay rent in a reduced amount if such rent is paid prior to the expiration of such grace https://law.justia.com/codes/connecticut/2012/title-47a/chapter-830/section-47a-4/ 121/27/22, 5:00 PM Section 47a-4 - Terms prohibited in rental agreement. :: 2012 Connecticut General Statutes period; o (©) grees to pay a heat or utilities surcharge if heat or utilities is included in the rental agreement. |A provision prohibited by subsection (a) of this section included in a rental agreement is unenforceable. (P.A. 76-95, S. 4, 27; 76-435, S. 75, 82; P.A. 77-451, S. 1; P.A. 79-571, S. 9; P.A. 82-274, S. 3; P.A. 87-154, S. 2; May Sp. Sess. P.A. 92-11, S. 37, 70; P.A. 05-56, S. 1.) History: P.A. 76-435 revised effective date section of P.A. 76-95; P.A. 77-451 substituted “shall” for “may”; P.A. 79-571 revised list of applicable sections and deleted former Subsec. (c) prohibiting rental agreements which would permit receipt of rent for period during which landlord fails to comply with Sec. 47a-7(a); P.A. 82-274 amended Subsec. (a)(7) by restricting the limitation on the amount of attorney’s fees to actions in which money damages are awarded; P.A. 87-154 added Subsec. (a)(8) prohibiting a provision whereby a tenant agrees to pay a late charge or to pay rent in a reduced amount prior to the expiration of the statutory grace period; May Sp. Sess. P.A. 92-11 amended Subsec. (a)(4) to correct a statutory reference by replacing Sec. 47a-22 with Sec. 47a-21; P.A. 05-56 added Subsec. (a) (9) prohibiting heat and utilities surcharge clauses in residential leases, effective October 1, 2005, and applicable to rental agreements or renewals of rental agreements signed on or after that date. Cited. 35 CS 151; Id., 549. Cited. 36 CS 611. Cited. 38 CS 683. Subseec. (a): Subdiv. (7) cited. 38 CS 341. Cited. Id., 393. Former Subsec. (c): Subsection must be read so as to provide tenant with remedy for landlord’s violation of section 47a-7(a), and therefore tenant was not liable for rent while premises were uninhabitable; uninhabitability of premises excuses withholding of rent. 35 CS 151. Cited. 36 CS 47. Disclaimer: These codes may not be the most recent version. Connecticut may have more current or accurate information. We make no warranties or guarantees about the accuracy, completeness, or adequacy of the information contained on this site or the information linked to on the state site. Please check official sources. https://aw.justia.com/codes/connecticut/2012/title-47a/chapter-830/section-47a-4/ 2/21/27/22, 4:12 PM Section 47a-7 - Landlord's responsibilities, Conn. Gen. Stat. § 47a-7 L Search all cases and statutes... Statutes, codes, and regulations General Statutes of C... Title 47A - LANDLOR... Chapter 830 - RIGHT... Conn. Gen. Stat. § 47a-7 Current with legislation from 2021 effective through October 1, 2021. Section 47a-7 - Landlord's responsibilities (a) A landlord shall: (1) Comply with the requirements of chapter 3680 and all. applicable building and housing codes materially affecting health and safety of both the state or any political subdivision thereof; (2) make all repairs and do whatever is necessary to put and keep the premises in a fit and habitable condition, except where the premises are intentionally rendered unfit or uninhabitable by the tenant, a member of his family or other person on the premises with his consent, in which case such duty shall be the responsibility of the tenant; (3) keep all common areas of the premises in a clean and safe condition; G@rnainvain in good and safe working order and condition aliGlectrical plumbing, sanitary, heating, ventilating, and, Qiher facilities and appliances and glevators, supplied or required to be supplied by him; - . . EZ casetext SignUp GetaDemo https://casetext.com/statute/general-statutes-of-connecticut/title-47a-landlord-and-tenant/chapter-830-rights-and-responsibilities-oflandlord-and-tenant... 1141/29/22, 7:54 AM 20220128_104430_HDR.jpg https://mail.google.com/mail/u/O/#inbox?projector=1 2 hp pping Plaza / iver. Ly,1/29/22, 7:48 AM 20220128_103228,ipgee jpg 20220128_103517. a: 1/29/22, 8:43 AM4/29/22, 8:21 AM https://mail.google.com/mail/u/O/#inbox/RdDgqeJHpWevcDjPBBKippL JzWFdKKtHKBdtRgqzHXTL ?projector=1&messagePartld=0.1 4A