Preview
CASEFLOW REQUEST For information on ADA STATE OF CONNECTICUT
JD-CV-116 Rev. 9-23 accommodations, contact the JUDICIAL BRANCH ,
Centralized ADA Office at 860-706-5310 SUPERIOR COURT
or go to: www.jud.ct.gov/ADA/ www.jud.ct.gov
Instructions COURT USE ONLY
Select the appropriate type of request being made, provide the additional information requested, and the reason for
your request. File at least 3 days before the scheduled date. If you need to request a continuance of a scheduled CSFLREQ
court date, do not use this form. Use form JD-CV-21, Motion for Continuance, for all continuance requests.
Note: If the request if granted, the court will schedule the event for the requested date, if that date is available. 111111111111111111111111111111111111111111111
If that date is not available, the court will schedule the event for the next available date.
Name of case (Plaintiff v. Defendant) Docket number
David Ford v. Stephen Curley HHD-CV23-5079774-S
ta1 Judicial
L") District
â–¡ Housing
Session
Address of court (Number, street, town and zip code)
95 Washington Street, Hartford, CT 06103
Name of Judge who scheduled the event (if known) Date of request Date of scheduled event (if applicable)
Hon.Rosen 1211812023
Requested Action
I am requesting: (Select box(es) that apply and give reason(s) for request below)
[] Status Conference on or about: (date)
[]Client/adjuster to be available by phone for (event) scheduled on (date)
[]Pretrial on or about: (date)
[]Party to be excused from (event) scheduled on (date)
[] Other: Clarification of the Court's order in #151.00,
Reason(s) for request:
The transcript of the 11121123 hearing (DE #151.00), at pg 34, contains a discrepancy between the subpoena which was
discussed at the hearing, and the subpoena which was served on Jon Biller on October 30th. It appears that Judge Rosen was
discussing the 7119123 subpoena that was served in the first Curley case (Exh. A), which included production request #4 that
sought "All written communications between [Biller] and the Defendant ... " The subpoena that was served on Oct. 30th (Exh.
B, and at DE #131.00), contains a different set of production demands which do not include the request for written
communications. We request that the Court clarify its order, stating that the 10130 subpoena is operative.
I have informed all counsel of record and self-represented parties of this request, and agree to notify them of the court's
ruling. All Counsel and Self-represented Parties:
e action requested above Defendant consents. Plaintiff does not consent.
Name of attorney and juris number or self-represented party (Print or type)
Stephen P. Brown, 413936
Counsel for
Defendant [] Attorney for Plaintiff [] Attorney for Defendant non-party witness
Firm name (If applicable) E-mail address
Wilson Elser Moskowitz Edelman & Dicker LLP stephen.brown@wilsonelser.com
Address Telephone number (with area code)
1010 Washington Blvd., Stamford, CT 06901 203-388-2450
Certification
I certify that a copy of this document was or will immediately be mailed or delivered electronically or non-electronically on
(date) 1211812023 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•
David Ford, dford45sky@hotmail.com - Plaintiff
Step en Curley, scurley@cur-law.com - Defendant
and address which the copy was or will be mailed or delivered to.
Print or type name of person signing Date signed
Stephen P. Brown 1211812023
Exhibit A
DOCKET NO: HHD CV 23 5078773 SUPERIOR COURT
DAVID FORD JD OF HARTFORD
vs. AT HARTFORD
STEPHEN CURLEY JULY 19, 2023
To: Jon Biller
6 Cove Road
East Haddam, CT
SUBPOENA TO ATTEND DEPOSITION
BY AUTHORITY OF THE STATE OF CONNECTICUT, You are hereby
commanded to appear at a deposition at Brandon Legal Tech, 370 Asylum Street,
Hartford, CT, on August 8, 2023, at 9:00 a.m., then and there to testify as to what you
know in a certain cause therein pending, wherein David Ford is plaintiff and Stephen
Curley is the Defendant. You are further commanded to bring with you the documents
included in the attached Schedule A.
HEREOF FAIL NOT, UNDER PENALTY OF THE LAW IN THAT CASE PROVIDED.
Dated at Avon, Connecticut this JULY 19, 2023.
Silkened and issued b
ZN-ANNA VIFKERMAN
NOTARY PUBLIC
WY COMMISSION EXPIRES 1 0/31/2023
PLAINTIFF
David Ford, Sr. Pro se
34 Valley View Drive
Avon, CT 06001
T 860-918-2772
Eservice: dford45skv@hotmail.com
SCHEDULE A
As to paragraph 9 of the complaint:
The Defendant's client Attorney Biller violated the hourly Jee agreement in multiple
ways, including but not limited to:
a. Depositing the advance fee retainers into the Defendant's client's bank account
instead ofhis client's trust account.
1. Please bring your firm's monthly bank statement for September 2018, showing
what account the Plaintiff's retainer of $17,500.00 was deposited into on or
around September 18, 2018.
2. Please bring your firm's monthly bank statement for February 2021, showing
what account the Plaintiff's retainer of $50,000.00 was deposited into on or
around February 4, 2021.
As to paragraph 18 of the complaint:
Despite all of the above, the Defendant conspired with Attorney Biller and demanded the
Plaintiff pay a "$122,500.00" contingency fee that was unenforceable, illegal and/or
unethical.
3. Please bring every document you relied upon to support your claim that the
Plaintiff owed you a contingency fee of $122,500.00.
4. As the Plaintiff has claimed you conspired with the Defendant to extort and
defraud the Plaintiff, please produce all written communications between you
and the Defendant, including, but not limited to, emails, letters and text
messages.
5. Any investigative report(s) of or concerning the Plaintiff.
2
Subpoena Return
State of Connecticut }
County of New Haven } Hamden July 27, 2023
Then and there by virtue hereto, I made due and legal service of this
subpoena by leaving a true and attested copy of the original subpoena in the hands
of:
Jon Biller
6 Cove Road
East Haddam, CT
The within and foregoing is a true and attested copy of the original subpoena
with my doings thereon endorsed.
ATTEST:
z
Frank P. Santillo, State Marshal
New Haven County
Fees
Service $ 50.00
Travel 15.00
Pages 2.00
Ends 1.50
Fee
Total $ 68.50
Exhibit B
DOCKET NO: HHD-CV23-5079774-S SUPERIOR COURT
DAVID FORD JD OF HARTFORD
VS. AT HARTFORD
STEPHEN CURLEY OCTOBER 31, 2023
PLAINTIFF'S NOTICE OF COMPLIANCE WITH COURT ORDER 102.86
The Plaintiff in the above-entitled matter, David Ford, provides this Court with
Notice, that he served the attached Notice of Deposition upon the non-party witness,
Attorney Biller, per Court Order 102.86 (Attached hereto for the Court's convenience).
Also attached is the Notice of Deposition and the Marshal's proof of service.
It should be noted that the Plaintiff was forced to choose the date of November 6,
2023, unilaterally. Attorney Biller, to this day, has not confirmed or even provided a
specific date he is willing to be deposed. This is no different than what Attorney Biller
has done throughout the litigation (See Docket entry #124, 126). He has routinely ignored
the Plaintiff's attempts to resolve any issue. He has repeatedly evaded service. He has
defied multiple subpoenas. He has violated Court orders.
The Plaintiff had to choose the date of November 6, 2023. If Attorney Biller seeks
a different date, the Plaintiff assures this Court that he will be as flexible as possible to
find a suitable date, so long as a new date is agreed upon prior to November 4, 2023.
THE PLAINTIFF,
BY/S/DAVID M. FORD
David M. Ford
Valley View Drive
Avon, CT 06001
Phone: (860) 918-2772
dford45sky@hotmail.com
CERTIFICATION
The Plaintiff hereby certifies that a copy of the foregoing was emailed to the Defendant
and all counsel of record on this date.
THE PLAINTIFF,
BY_JS/DAVID M. FORD
David M. Ford
Valley View Drive
Avon, CT 06001
Phone: (860) 918-2772
dford45sky@hotmail.com
ORDER 439611
DOCKET NO: HHDCV235079774S SUPERIOR COURT
FORD, DAVID JUDICIAL DISTRICT OF HARTFORD
V. AT HARTFORD
CURLEY, STEPHEN
10/23/2023
ORDER
ORDER REGARDING:
09/29/2023 102.00 MOTION FOR ORDER
The foregoing, having been considered by the Court, is hereby:
ORDER:
Non-party witness Biller is ordered to appear for a deposition, which shall be completed by November
30, 2023. Once noticed, the deposition may not be continued or canceled absent agreement of the parties
or with prior court approval for good cause shown. Failure to appear for a properly noticed deposition
may result in the issuance of a capias and/or sanctions.
The plaintiff is ordered to have a marshal serve a copy of this Order on the deponent, together with a re-
notice of deposition and subpoena, and shall file proof of such service with the court. Service shall be
made at least seven (7) days before the date noticed for the deposition.
Judicial Notice (JDNO) was sent regarding this order.
439611
Judge: STUART D ROSEN
This document may be signed or verified electronically and has the same validity and status as a document with a physical
(pen-to-paper) signature. For more information, see Section I.E. of the State of Connecticut Superior Court E-Services
Procedures and Technical Standards (https://jud.ct.gov/external/super/E-Services/e-standards.pdf), section 5 I-I 93c of the
Connecticut General Statutes and Connecticut Practice Book Section 4-4.
HHDCV235079774S 10/23/2023 Page l of l
RETURN OF SERVICE
STATE OF CONNECTICUT)
) SS: HAMDEN October 30, 2023
COUNTY OF NEW HAVEN)
RE: Ford, David v. Curley, Stephen
Docket #HHD-CV23-5079774-5
Then and by virtue hereof this Subpoena Duces Tecum, Notice Of Deposition, Schedule A,
Superior Court Order 439611 Regarding 102.00 Motion For Order, I served the within named,
ATTORNEY JON BILLER, by reading the same in the presence and hearing of and by leaving a
true and attested copy hereof, with my endorsement thereon, with and in the hands of the within
named, ATTORNEY JON BILLER, c/o The Biller Law Firm, 2750 Whitney Avenue, Hamden, CT 06518.
The within and foregoing is the Subpoena Duces Tecum, Notice Of Deposition, Schedule A,
Superior Court Order 439611 Regarding 102.00 Motion For Order, with my doings hereon endorsed.
3"
SUSAN DERCOLE, STATE MARSHAL
NEW HAVEN COUNTY
Service $ 70.00
Travel 1.30
Pages 4.00
Endorse 1.50
Total $ 76.80
SUBPOENA DUCES TECUM
Attorney Jon Biller
c/ o The Biller Law Firm
2750 Whitney Ave
Hamden, CT 06518
BY AUTHORITY OF THE STATE OF CONNECTICUT, You are hereby commanded to
appear at a deposition at Brandon Legal Tech, 370 Asylum Street, Hartford, CT, on
November 6, 2023, at 9:00 a.m., to be deposed and to testify regarding matters at issue in
the case David Ford vs Stephen Curley, pending in the Judicial District of Hartford
bearing Docket No: HHD-CV23-5079774-S.
You are further commanded to bring with you the documents included in the attached
Schedule A
HEREOF FAIL NOT, UNDER PENALTY OF THE LAW IN THAT CASE PROVIDED.
Dated at Hartford, Connecticut this 25day of October 2023.
To any proper officer or indifferent person to serve and return this Subpoena and Notice
of Deposition and Schedule A attached hereto.
Signed and issued by Notary Public per CGS 52-148
-;, .
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Preview
CASEFLOW REQUEST For information on ADA STATE OF CONNECTICUT JD-CV-116 Rev. 9-23 accommodations, contact the JUDICIAL BRANCH , Centralized ADA Office at 860-706-5310 SUPERIOR COURT or go to: www.jud.ct.gov/ADA/ www.jud.ct.gov Instructions COURT USE ONLY Select the appropriate type of request being made, provide the additional information requested, and the reason for your request. File at least 3 days before the scheduled date. If you need to request a continuance of a scheduled CSFLREQ court date, do not use this form. Use form JD-CV-21, Motion for Continuance, for all continuance requests. Note: If the request if granted, the court will schedule the event for the requested date, if that date is available. 111111111111111111111111111111111111111111111 If that date is not available, the court will schedule the event for the next available date. Name of case (Plaintiff v. Defendant) Docket number David Ford v. Stephen Curley HHD-CV23-5079774-S ta1 Judicial L") District □ Housing Session Address of court (Number, street, town and zip code) 95 Washington Street, Hartford, CT 06103 Name of Judge who scheduled the event (if known) Date of request Date of scheduled event (if applicable) Hon.Rosen 1211812023 Requested Action I am requesting: (Select box(es) that apply and give reason(s) for request below) [] Status Conference on or about: (date) []Client/adjuster to be available by phone for (event) scheduled on (date) []Pretrial on or about: (date) []Party to be excused from (event) scheduled on (date) [] Other: Clarification of the Court's order in #151.00, Reason(s) for request: The transcript of the 11121123 hearing (DE #151.00), at pg 34, contains a discrepancy between the subpoena which was discussed at the hearing, and the subpoena which was served on Jon Biller on October 30th. It appears that Judge Rosen was discussing the 7119123 subpoena that was served in the first Curley case (Exh. A), which included production request #4 that sought "All written communications between [Biller] and the Defendant ... " The subpoena that was served on Oct. 30th (Exh. B, and at DE #131.00), contains a different set of production demands which do not include the request for written communications. We request that the Court clarify its order, stating that the 10130 subpoena is operative. I have informed all counsel of record and self-represented parties of this request, and agree to notify them of the court's ruling. All Counsel and Self-represented Parties: e action requested above Defendant consents. Plaintiff does not consent. Name of attorney and juris number or self-represented party (Print or type) Stephen P. Brown, 413936 Counsel for Defendant [] Attorney for Plaintiff [] Attorney for Defendant non-party witness Firm name (If applicable) E-mail address Wilson Elser Moskowitz Edelman & Dicker LLP stephen.brown@wilsonelser.com Address Telephone number (with area code) 1010 Washington Blvd., Stamford, CT 06901 203-388-2450 Certification I certify that a copy of this document was or will immediately be mailed or delivered electronically or non-electronically on (date) 1211812023 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• David Ford, dford45sky@hotmail.com - Plaintiff Step en Curley, scurley@cur-law.com - Defendant and address which the copy was or will be mailed or delivered to. Print or type name of person signing Date signed Stephen P. Brown 1211812023 Exhibit A DOCKET NO: HHD CV 23 5078773 SUPERIOR COURT DAVID FORD JD OF HARTFORD vs. AT HARTFORD STEPHEN CURLEY JULY 19, 2023 To: Jon Biller 6 Cove Road East Haddam, CT SUBPOENA TO ATTEND DEPOSITION BY AUTHORITY OF THE STATE OF CONNECTICUT, You are hereby commanded to appear at a deposition at Brandon Legal Tech, 370 Asylum Street, Hartford, CT, on August 8, 2023, at 9:00 a.m., then and there to testify as to what you know in a certain cause therein pending, wherein David Ford is plaintiff and Stephen Curley is the Defendant. You are further commanded to bring with you the documents included in the attached Schedule A. HEREOF FAIL NOT, UNDER PENALTY OF THE LAW IN THAT CASE PROVIDED. Dated at Avon, Connecticut this JULY 19, 2023. Silkened and issued b ZN-ANNA VIFKERMAN NOTARY PUBLIC WY COMMISSION EXPIRES 1 0/31/2023 PLAINTIFF David Ford, Sr. Pro se 34 Valley View Drive Avon, CT 06001 T 860-918-2772 Eservice: dford45skv@hotmail.com SCHEDULE A As to paragraph 9 of the complaint: The Defendant's client Attorney Biller violated the hourly Jee agreement in multiple ways, including but not limited to: a. Depositing the advance fee retainers into the Defendant's client's bank account instead ofhis client's trust account. 1. Please bring your firm's monthly bank statement for September 2018, showing what account the Plaintiff's retainer of $17,500.00 was deposited into on or around September 18, 2018. 2. Please bring your firm's monthly bank statement for February 2021, showing what account the Plaintiff's retainer of $50,000.00 was deposited into on or around February 4, 2021. As to paragraph 18 of the complaint: Despite all of the above, the Defendant conspired with Attorney Biller and demanded the Plaintiff pay a "$122,500.00" contingency fee that was unenforceable, illegal and/or unethical. 3. Please bring every document you relied upon to support your claim that the Plaintiff owed you a contingency fee of $122,500.00. 4. As the Plaintiff has claimed you conspired with the Defendant to extort and defraud the Plaintiff, please produce all written communications between you and the Defendant, including, but not limited to, emails, letters and text messages. 5. Any investigative report(s) of or concerning the Plaintiff. 2 Subpoena Return State of Connecticut } County of New Haven } Hamden July 27, 2023 Then and there by virtue hereto, I made due and legal service of this subpoena by leaving a true and attested copy of the original subpoena in the hands of: Jon Biller 6 Cove Road East Haddam, CT The within and foregoing is a true and attested copy of the original subpoena with my doings thereon endorsed. ATTEST: z Frank P. Santillo, State Marshal New Haven County Fees Service $ 50.00 Travel 15.00 Pages 2.00 Ends 1.50 Fee Total $ 68.50 Exhibit B DOCKET NO: HHD-CV23-5079774-S SUPERIOR COURT DAVID FORD JD OF HARTFORD VS. AT HARTFORD STEPHEN CURLEY OCTOBER 31, 2023 PLAINTIFF'S NOTICE OF COMPLIANCE WITH COURT ORDER 102.86 The Plaintiff in the above-entitled matter, David Ford, provides this Court with Notice, that he served the attached Notice of Deposition upon the non-party witness, Attorney Biller, per Court Order 102.86 (Attached hereto for the Court's convenience). Also attached is the Notice of Deposition and the Marshal's proof of service. It should be noted that the Plaintiff was forced to choose the date of November 6, 2023, unilaterally. Attorney Biller, to this day, has not confirmed or even provided a specific date he is willing to be deposed. This is no different than what Attorney Biller has done throughout the litigation (See Docket entry #124, 126). He has routinely ignored the Plaintiff's attempts to resolve any issue. He has repeatedly evaded service. He has defied multiple subpoenas. He has violated Court orders. The Plaintiff had to choose the date of November 6, 2023. If Attorney Biller seeks a different date, the Plaintiff assures this Court that he will be as flexible as possible to find a suitable date, so long as a new date is agreed upon prior to November 4, 2023. THE PLAINTIFF, BY/S/DAVID M. FORD David M. Ford Valley View Drive Avon, CT 06001 Phone: (860) 918-2772 dford45sky@hotmail.com CERTIFICATION The Plaintiff hereby certifies that a copy of the foregoing was emailed to the Defendant and all counsel of record on this date. THE PLAINTIFF, BY_JS/DAVID M. FORD David M. Ford Valley View Drive Avon, CT 06001 Phone: (860) 918-2772 dford45sky@hotmail.com ORDER 439611 DOCKET NO: HHDCV235079774S SUPERIOR COURT FORD, DAVID JUDICIAL DISTRICT OF HARTFORD V. AT HARTFORD CURLEY, STEPHEN 10/23/2023 ORDER ORDER REGARDING: 09/29/2023 102.00 MOTION FOR ORDER The foregoing, having been considered by the Court, is hereby: ORDER: Non-party witness Biller is ordered to appear for a deposition, which shall be completed by November 30, 2023. Once noticed, the deposition may not be continued or canceled absent agreement of the parties or with prior court approval for good cause shown. Failure to appear for a properly noticed deposition may result in the issuance of a capias and/or sanctions. The plaintiff is ordered to have a marshal serve a copy of this Order on the deponent, together with a re- notice of deposition and subpoena, and shall file proof of such service with the court. Service shall be made at least seven (7) days before the date noticed for the deposition. Judicial Notice (JDNO) was sent regarding this order. 439611 Judge: STUART D ROSEN This document may be signed or verified electronically and has the same validity and status as a document with a physical (pen-to-paper) signature. For more information, see Section I.E. of the State of Connecticut Superior Court E-Services Procedures and Technical Standards (https://jud.ct.gov/external/super/E-Services/e-standards.pdf), section 5 I-I 93c of the Connecticut General Statutes and Connecticut Practice Book Section 4-4. HHDCV235079774S 10/23/2023 Page l of l RETURN OF SERVICE STATE OF CONNECTICUT) ) SS: HAMDEN October 30, 2023 COUNTY OF NEW HAVEN) RE: Ford, David v. Curley, Stephen Docket #HHD-CV23-5079774-5 Then and by virtue hereof this Subpoena Duces Tecum, Notice Of Deposition, Schedule A, Superior Court Order 439611 Regarding 102.00 Motion For Order, I served the within named, ATTORNEY JON BILLER, by reading the same in the presence and hearing of and by leaving a true and attested copy hereof, with my endorsement thereon, with and in the hands of the within named, ATTORNEY JON BILLER, c/o The Biller Law Firm, 2750 Whitney Avenue, Hamden, CT 06518. The within and foregoing is the Subpoena Duces Tecum, Notice Of Deposition, Schedule A, Superior Court Order 439611 Regarding 102.00 Motion For Order, with my doings hereon endorsed. 3" SUSAN DERCOLE, STATE MARSHAL NEW HAVEN COUNTY Service $ 70.00 Travel 1.30 Pages 4.00 Endorse 1.50 Total $ 76.80 SUBPOENA DUCES TECUM Attorney Jon Biller c/ o The Biller Law Firm 2750 Whitney Ave Hamden, CT 06518 BY AUTHORITY OF THE STATE OF CONNECTICUT, You are hereby commanded to appear at a deposition at Brandon Legal Tech, 370 Asylum Street, Hartford, CT, on November 6, 2023, at 9:00 a.m., to be deposed and to testify regarding matters at issue in the case David Ford vs Stephen Curley, pending in the Judicial District of Hartford bearing Docket No: HHD-CV23-5079774-S. You are further commanded to bring with you the documents included in the attached Schedule A HEREOF FAIL NOT, UNDER PENALTY OF THE LAW IN THAT CASE PROVIDED. Dated at Hartford, Connecticut this 25day of October 2023. To any proper officer or indifferent person to serve and return this Subpoena and Notice of Deposition and Schedule A attached hereto. Signed and issued by Notary Public per CGS 52-148 -;, .