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RETURN DATE: FEBRUARY 13, 2024 SUPERIOR COURT
CITY OF STAMFORD JD STAMFORD/NORWALK
vs. AT STAMFORD
WENDY TEAL
STATE OF CONNECTICUT, DEPARTMENT OF
REVENUE SERVICES,
STAMFORD WATER POLLUTION
CONTROL AUTHORITY,
UNITED STATES OF AMERICA, DEPARTMENT OF
TREASURY — INTERNAL REVENUE SERVICE DECEMBER 21 ,2023
COMPLAINT
1 The plaintiff, CITY OF STAMFORD, is a municipal corporation duly established under the
laws of the State of Connecticut and located in the County of Fairfield.
2 WENDY TEAL (hereinafter “OWNER’) is the record owner of real property located in the
City of Stamford known as 19 WEST STREET (the “Property”), by virtue of her being the sole surving
beneficiary of The Estate of John E. Teal and The Estate of Winnie B. Teal as more particularly described in
Schedule “A” attached hereto.
3. On October 1, 2016, taxes in the amount of $4,313.96 were duly and properly assessed
against the Property, and became due and payable on July 1, 2017.
4. On October 1, 2017, taxes in the amount of $5,584.44 were duly and properly assessed
against the Property, and became due and payable on July 1, 2018.
5. On October 1, 2018, taxes in the amount of $5,763.80 were duly and properly assessed
against the Property, and became due and payable on July 1, 2019.
6. On October 1, 2019, taxes in the amount of $5,763.80 were duly and properly assessed
against the Property, and became due and payable on July 1, 2020.
7. On October 1, 2020, taxes in the amount of $5,892.86 were duly and properly assessed
against the Property, and became due and payable on July 1, 2021.
8. On October 1, 2021, taxes in the amount of $5,943.18 were duly and properly assessed
against the Property, and became due and payable on July 1, 2022.
9 A Certificate of Lien for said taxes on the List of October 1, 2016 in the amount of
$4,500.72 plus interest, fees and costs was recorded on June 12, 2018 in Volume 11960 at Page 291 of
the Stamford Land Records.
10. A Certificate of Lien for said taxes on the List of October 1, 2017 in the amount of
$5,584.44 plus interest, fees and costs was recorded on June 11, 2019 in Volume 12156 at Page 211 of
the Stamford Land Records.
11. A Certificate of Lien for said taxes on the List of October 1, 2018 in the amount of
$5,763.80 plus interest, fees and costs was recorded on June 23, 2020 in Volume 12389 at Page 241 of
the Stamford Land Records.
12. A Certificate of Lien for said taxes on the List of October 1, 2019 in the amount of
$5,763.80 plus interest, fees and costs was recorded on June 9, 2021 in Volume 12712 at Page 256 of the
Stamford Land Records.
13. A Certificate of Lien for said taxes on the List of October 1, 2020 in the amount of
$5,892.86 plus interest, fees and costs was recorded on June 8, 2022 in Volume 13009 at Page 124 of the
Stamford Land Records.
14. A Certificate of Lien for said taxes on the List of October 1, 2021 in the amount of
$5,943.18 plus interest, fees and costs was recorded on June 7, 2023 in Volume 13185 at Page 247 of the
Stamford Land Records.
45. Additionally, the plaintiff also claims an inchoate lien on the Property for taxes on the List
of October 1, 2022 in the amount of $6,271.64, and which, together with interest and costs, remain
wholly unpaid.
16. The Tax Collector of the City of Stamford believes that the collection of the taxes on the
List of October 1, 2022 in the amount of $6,271.64 plus interest and costs will be jeopardized by delay.
Ls Accordingly, pursuant to the provisions of §12-163 and 12-172 of the Connecticut General
Statutes, the plaintiff also seeks to foreclose in this action its inchoate lien for taxes on the List of October
1, 2022.
18. The total amount due the plaintiff for the aforesaid delinquent taxes, interest and lien fees
is $58,611.47 as of August 31, 2023, plus costs of collection and reasonable attorney’s fees.
19. The Defendant, STAMFORD WATER POLLUTION CONTROL AUTHORITY may claim an
interest in the property by virtue of Liens and/or unliened amounts for sewer use charges.
22
20. Upon information and belief, the defendant, OWNER is in possession of the Property.
21. The Defendant, STATE OF CONNECTICUT, DEPARTMENT OF REVENUE SERVICES, may claim
an interest in the property by virtue of a tax lien in the amount of $73,174.56, against OWNER, dated
January 18, 2012, recorded in Volume 10321 at Page 272, of the Stamford Land Records and an inchoate
Succession and/or Estate Tax Lien due to the death of John E. Teal, and an inchoate succession and/or
Estate Tax Lien due to the death of Winnie B. Teal a prior owner of the Property.
22. The Defendants, UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY INTERNAL
REVENUE SERVICE, may claim an interest in the property by virtue of Federal Tax Lien in the amount of
$41,132.82 recorded June 27, 2019 in Volume 12166 at Page 161 of the Stamford Land Records.
WHEREFORE, the plaintiff claims:
4, A foreclosure of the inchoate and recorded liens on the List of October 1, 2022 pursuant to
§12-163 and 12-172 of the Connecticut General Statutes;
A judgment of foreclosure;
Immediate possession of the premises;
Costs and reasonable attorney's fees as by statute, C.G.S. Sec. 12-193 made and
provided;
Interest pursuant to statute, C.G.S. Sec. 12-146;
A deficiency judgment. No deficiency will be sought against any person whose obligation
has been heretofore discharged in bankruptcy; and
7. Such other and further relief as the Court may deem just and proper.
|, VINCENTJ. FRECCIA, Ill, THE SUBSCRIBING AUTHORITY, HEREBY CERTIFY THAT | HAVE PERSONAL
KNOWLEDGE AS TO THE FINANCIAL RESPONSIBILITY OF THE PLAINTIFF AND DEEM IT SUFFICIENT TO PAY
THE COST OF THIS ACTION.
THE PLAINTIFF
CITY OF STAMFORD
by;
Frey ia, Ill Its Attorney
1200 Su er Street
Stamford, CT 06905
20 ~325-8002
Auris No. 101129
SCHEDULE A
All that certain piece or parcel of land, together with the improvements thereon, situated in the City of
Stamford, County of Fairfield and State of Connecticut, being more particularly bounded and described as
follows:
Northerly: 40.4 feet, more or less, by land now or formerly of Charles H. McNally, Deceased;
Easterly: 100 feet, more or less, by land now or formerly of Stanislawa Rekosz,
Southerly: 40 feet, more or less, by West Street;
Westerly: 100 feet, more or less, by land now or formerly of Tomasina Conte, et al.
Said Premises are also known as 19 West Street, Stamford, Connecticut
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RETURN DATE: FEBRUARY 13, 2024 SUPERIOR COURT CITY OF STAMFORD JD STAMFORD/NORWALK vs. AT STAMFORD WENDY TEAL STATE OF CONNECTICUT, DEPARTMENT OF REVENUE SERVICES, STAMFORD WATER POLLUTION CONTROL AUTHORITY, UNITED STATES OF AMERICA, DEPARTMENT OF TREASURY — INTERNAL REVENUE SERVICE DECEMBER 21 ,2023 COMPLAINT 1 The plaintiff, CITY OF STAMFORD, is a municipal corporation duly established under the laws of the State of Connecticut and located in the County of Fairfield. 2 WENDY TEAL (hereinafter “OWNER’) is the record owner of real property located in the City of Stamford known as 19 WEST STREET (the “Property”), by virtue of her being the sole surving beneficiary of The Estate of John E. Teal and The Estate of Winnie B. Teal as more particularly described in Schedule “A” attached hereto. 3. On October 1, 2016, taxes in the amount of $4,313.96 were duly and properly assessed against the Property, and became due and payable on July 1, 2017. 4. On October 1, 2017, taxes in the amount of $5,584.44 were duly and properly assessed against the Property, and became due and payable on July 1, 2018. 5. On October 1, 2018, taxes in the amount of $5,763.80 were duly and properly assessed against the Property, and became due and payable on July 1, 2019. 6. On October 1, 2019, taxes in the amount of $5,763.80 were duly and properly assessed against the Property, and became due and payable on July 1, 2020. 7. On October 1, 2020, taxes in the amount of $5,892.86 were duly and properly assessed against the Property, and became due and payable on July 1, 2021. 8. On October 1, 2021, taxes in the amount of $5,943.18 were duly and properly assessed against the Property, and became due and payable on July 1, 2022. 9 A Certificate of Lien for said taxes on the List of October 1, 2016 in the amount of $4,500.72 plus interest, fees and costs was recorded on June 12, 2018 in Volume 11960 at Page 291 of the Stamford Land Records. 10. A Certificate of Lien for said taxes on the List of October 1, 2017 in the amount of $5,584.44 plus interest, fees and costs was recorded on June 11, 2019 in Volume 12156 at Page 211 of the Stamford Land Records. 11. A Certificate of Lien for said taxes on the List of October 1, 2018 in the amount of $5,763.80 plus interest, fees and costs was recorded on June 23, 2020 in Volume 12389 at Page 241 of the Stamford Land Records. 12. A Certificate of Lien for said taxes on the List of October 1, 2019 in the amount of $5,763.80 plus interest, fees and costs was recorded on June 9, 2021 in Volume 12712 at Page 256 of the Stamford Land Records. 13. A Certificate of Lien for said taxes on the List of October 1, 2020 in the amount of $5,892.86 plus interest, fees and costs was recorded on June 8, 2022 in Volume 13009 at Page 124 of the Stamford Land Records. 14. A Certificate of Lien for said taxes on the List of October 1, 2021 in the amount of $5,943.18 plus interest, fees and costs was recorded on June 7, 2023 in Volume 13185 at Page 247 of the Stamford Land Records. 45. Additionally, the plaintiff also claims an inchoate lien on the Property for taxes on the List of October 1, 2022 in the amount of $6,271.64, and which, together with interest and costs, remain wholly unpaid. 16. The Tax Collector of the City of Stamford believes that the collection of the taxes on the List of October 1, 2022 in the amount of $6,271.64 plus interest and costs will be jeopardized by delay. Ls Accordingly, pursuant to the provisions of §12-163 and 12-172 of the Connecticut General Statutes, the plaintiff also seeks to foreclose in this action its inchoate lien for taxes on the List of October 1, 2022. 18. The total amount due the plaintiff for the aforesaid delinquent taxes, interest and lien fees is $58,611.47 as of August 31, 2023, plus costs of collection and reasonable attorney’s fees. 19. The Defendant, STAMFORD WATER POLLUTION CONTROL AUTHORITY may claim an interest in the property by virtue of Liens and/or unliened amounts for sewer use charges. 22 20. Upon information and belief, the defendant, OWNER is in possession of the Property. 21. The Defendant, STATE OF CONNECTICUT, DEPARTMENT OF REVENUE SERVICES, may claim an interest in the property by virtue of a tax lien in the amount of $73,174.56, against OWNER, dated January 18, 2012, recorded in Volume 10321 at Page 272, of the Stamford Land Records and an inchoate Succession and/or Estate Tax Lien due to the death of John E. Teal, and an inchoate succession and/or Estate Tax Lien due to the death of Winnie B. Teal a prior owner of the Property. 22. The Defendants, UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE, may claim an interest in the property by virtue of Federal Tax Lien in the amount of $41,132.82 recorded June 27, 2019 in Volume 12166 at Page 161 of the Stamford Land Records. WHEREFORE, the plaintiff claims: 4, A foreclosure of the inchoate and recorded liens on the List of October 1, 2022 pursuant to §12-163 and 12-172 of the Connecticut General Statutes; A judgment of foreclosure; Immediate possession of the premises; Costs and reasonable attorney's fees as by statute, C.G.S. Sec. 12-193 made and provided; Interest pursuant to statute, C.G.S. Sec. 12-146; A deficiency judgment. No deficiency will be sought against any person whose obligation has been heretofore discharged in bankruptcy; and 7. Such other and further relief as the Court may deem just and proper. |, VINCENTJ. FRECCIA, Ill, THE SUBSCRIBING AUTHORITY, HEREBY CERTIFY THAT | HAVE PERSONAL KNOWLEDGE AS TO THE FINANCIAL RESPONSIBILITY OF THE PLAINTIFF AND DEEM IT SUFFICIENT TO PAY THE COST OF THIS ACTION. THE PLAINTIFF CITY OF STAMFORD by; Frey ia, Ill Its Attorney 1200 Su er Street Stamford, CT 06905 20 ~325-8002 Auris No. 101129 SCHEDULE A All that certain piece or parcel of land, together with the improvements thereon, situated in the City of Stamford, County of Fairfield and State of Connecticut, being more particularly bounded and described as follows: Northerly: 40.4 feet, more or less, by land now or formerly of Charles H. McNally, Deceased; Easterly: 100 feet, more or less, by land now or formerly of Stanislawa Rekosz, Southerly: 40 feet, more or less, by West Street; Westerly: 100 feet, more or less, by land now or formerly of Tomasina Conte, et al. Said Premises are also known as 19 West Street, Stamford, Connecticut