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@ 3‘tat TA LEO CONNECTICUT
SMALL CLAIMS WRIT
AND NOTICE OF SUIT This form is available Fost Gates SURERIOR COURT
JD-CV-40 Rev. 7-22 in other language(s). Payfi SMALBCGEAWMS SESSION
C.G.S. §§ 51-15, 51-345(9) www jud.ct.gov
Dockets C¥2450300258
1.) Address of Court Rel@iy@abbitype B808! 24See list on reverse page 1)
Stamford Superior Court, 123 Hot Street, Stamford, CT 06905 Amwugigs $75.00
3.) Is this claim between a landlord and a tenant? 4.) If "Yes" to question #3, the rental property is "gated in the following toy,
(Selectone) [] Yes [x] No
Parties Name (Last, First, Middle Initial) and Address of Each Party (Number; Street; P.O. Box; Town; State; Zip; Country, if not USA)
Name: Rick's Main Roofing, Ltd / Richard Tavella (Select one) [uc [Partnership
5.) First Address: 26 Fitch Street, Norwalk, CT 06855 01
plaintiff Ci Individual [[] DBA [X] Corporation
Telephone: 203-838-5858 | E-mail: bookkeeping@ricksmainroofing.com
6.) Name, address, and zip code of Attorney for plaintiff(s) Attorney's Juris Number | Telephone number (w/area code)
Name: Judy Soronen
7.) First (Select one) [] LLC [_] Partnership
Address: 135 Lakeside Drive, Fairfield, CT 06824
defendant
Telephone: 203-216-0767 | E-mail: jsoronen.art@gmail.com
[XJ individual [-] DBA [] Corporation
(5 For more than 1 plaintiff/defendant, attach Continuation of Parties (form JD-CV-67) and select this box.
8.) If this claim is a consumer debt, which is a debt or obligation made primarily for personal, family, or household reasons, explain why you
believe the statute of limitations has not expired.
The original debit was incurred in November 2022. This does not exceed the statute of limitations on debt collections.
9.) In the last 6 months, how did you verify that the address given for defendant(s) is accurate?
Select all boxes that apply and provide the dates verified.
mS 2
[x] | checked town or city records (for example, checking a street list or tax records) on: 02/14/2024 “tdat
([] I checked with the Department of Motor Vehicles on: (date) en
ee
(J I received correspondence (letters or other mail) from the defendant with that return address on: N mo (date)
Sz
(J I received other proof from the defendant that the address is current (describe details below) ae
ty
(Atleast 4 weeks before this action was filed, | sent a letter by first class mail to the defendant at the addressaased ‘and. has not
been returned to me by the United States Postal Service as of: (date) =
10.) Amount claimed™ [X] Plus pre-judgment interest** sou, MUST explain how much you
$5336.56 Plus Costs 1] Plus double damages for security deposit withheld** want for each item in section 11 below.
*The Amount claimed cannot exceed $5,000 or $15,000 for a home improvement contract case (S20).
*If you are claiming pre-judgment interest or double damages for security deposit withholding, select the box(es). Do not include these
amounts in box 10.
To defendant(s):
11.) You are being sued. The plaintiff(s) claims you owe this money for the following reasons:
The defendant entered into a contract with the Plaintiff for labor and services. The labor and services have been supplied, yet
defendant has failed to pay the balance due on their contracts.
The person signing below, being duly sworn, states that he or she has read the claim above and the information contagjed inthig form and,
Spshe best of his or her knowledge, information and belief, there is good ground to support the claim and the information is
43) Sign Ty in name of person signing at left and title, if applicable For Coutttlse Oijly:(Dai fe/Stamp)
ichard Tavella. By
Sent: Friday, August 4, 2023 8:18 AM
To: 'kskmail@aol.com'
Subject: RE: Roof Completion
Monday is confirmed. Thank you
a ww ee seen a ne a ae
Frot kskmail aol.com ekskmailé Da0l. com>
Sent: Thursday, August 3, 2023 7:31 PM
To: bookkeeping@ricksmainroofing.com
Subject: Re: Roof Completion
Hi,
| need to change the date to Monday 8/7 at 4PM
| can’t be here tomorrow.
Steven
Sent from my iPhone
On Aug 3, 2023, at 12:55 PM, bookkeeping@ricksmainroofing.com wrote:
Confirmed. Thank you
We would appreciate your having a certified bank check in the amount of $4,186.00 so that we can pick
up the balance due. Once that has been turned over to Neal, he will address and take care of the last
concerns.
Thank you
wenn
From: kskenail aol.¢ com <|ckskmailé Daol com>
Sent: Thursday, August 3, 2023 12:47 PM
To: bookkeeping @ricksmainroofing.com
Subject: Re: Roof Completion
That's fine,
Sent from my iPhone
On Aug 3, 2023, at 9:54 AM, bookkeeping@ricksmainroofing.com wrote:
Good morning, Steve — Neal can be at the house most days after 4:00. We have
tentatively scheduled him for tomorrow after 4:00. Once you have confirmed that you
will be available, we can assure you that he will be there as planned. Please
confirm, thank you.
ow oon a we ~
From . Steven Kunstler
Sent: Tuesday, August 1, 2023 4:50 PM
To: neal@ricksmainroofing.com; bookkeeping@ricksmainroofing.com
Subject: Roof Completion
Hi Neal,
We spoke a week ago and you said that you would be by to complete the
work on the following afternoon.
We are still waiting.
When can we expect you?
Steven
K. Steven Kunstler
bookkeeping@ricksmainroofing.com
From: Judy Soronen
Sent: Wednesday, July 26, 2023 3:28 PM
To: K. Steven Kunstler; bookkeeping @ricksmainroofing.com; neal@ricksmainroofing.com
Subject: Re: Roof and skylight installation completion
| just spoke to Steven and he said he would be a bailable about 4:15 PM. | hope that works for Neal.
On Wed, Jul 26, 2023 at 12:57 PM wrote:
That would be fine. What time would you be available for this call? That way we can be sure that Neal won’t miss
you. Let me know, thank you. Thank you.
oe Seen oe ao — seen
From: Judy Soronen
Sent: Wednesday, July 26, 2023 12:50 PM
To: bookkeeping@ricksmainroofing.com; neal@ricksmainroofing.com
Subject: Re: Roof and skylight installation completion
Hello Linda,
Thank you for sending the statement. Steven would like to have a call
with Neal later this afternoon about the manufacturer's inspection and
warranty for the flat roof that was supposed to be provided upon
completion and a few other items.
Best regards,
Judy & Steven
} On Mon, Jul 24, 2023 at 3:09 PM wrote:
| | Your statement is attached.
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From: Ju
Judy Soronen
Sent: Monday, July 24, 2023 2:37 PM
To: bookkeeping@ricksmainroofing.com
Cc: neal @ricksmainroofing.com; K. Steven Kunstler ; Judy Soronen
a Subject: Re: Roof and skylight installation completion
Hello Bookkeeping (I believe your name is Linda)
You need to provide us with a statement that shows your invoice
amounts, the payments we have made and the balance due. Once we
get that we will authorize a credit card payment.
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It's unfortunate that your tone is so negative and you threaten us with a
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lawsuit. You could have simply emailed us your invoices, credits applied
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and balance due
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Judy Soronen
On Mon, Jul 24, 2023 at 11:38 AM wrote:
Hi
bookkeeping @ricksmainroofing.com
From: bookkeeping @ricksmainroofing.com
Sent: Monday, July 24, 2023 11:39 AM
To: ‘Judy Soronen’; 'neal@ricksmainroofing.com'
Ce: ‘K. Steven Kunstler’
Subject: RE: Roof and skylight installation completion
Good day — We have been informed that the skylight manufacturer has been out to the house and changed out the
skylights. That was a manufacturer’s defect, and we have since had many rains and so the problem has been resolved.
We need to pick up a check for the balance due on your account ($4,186.00) today or tomorrow at the latest. If that
does not happen, we will see you in court. We’re done.
ae . oe
From: Judy Soronen
Sent: Tuesday, May 23, 2023 5:58 PM
To: neal@ricksmainroofing.com; bookkeeping@ricksmainroofing.com
Cc: K. Steven Kunstler ; Judy Soronen
Subject: Re: Roof and skylight installation completion
Hello Neal,
| authorize your bookkeeper to submit a debit to my Visa Account of $4,000.00 (towards the "Entire flat roof” contract)
for the progress Pete made on resolving some of the outstanding issues, | do not approve more than that amount at this
time.
We scheduled a Velux representative to look at the leaky skylights at 2PM on Thursday, June 8, 2023, if you would like to
be here,
We hope to hear from you soon about addressing the additional finishing items in the email that we sent you yesterday
so that this project can get wrapped up.
Thanks and best regards,
Judy Soronen and Steven Kunstler
On Mon, May 22, 2023 at 1:15 AM K. Steven Kunstler wrote:
Dear Neal,
Thank you for sending Pete to make progress towards completing our roof and skylight installation.
There are still some outstanding items we have listed below about the completion of the work and the added charge that
was billed to us. We never agreed to or signed when it was presented to us because the charges submitted were
already included in the cost of the contract.
Outstanding Items:
1. Leaking skylights:
On January 27, 2023 you said:
Sent: Fri, Jan 27, 2023 6:14 am
i Subject: RE: Flat roof and four skylights replacement
Go te to 1d Jo
at. hanks again, and sorry for any inconvenience,
Neal
An inspection never happened. Almost four months later on May 15, 2023, Pete arrived and said that there would be no
replacement of the defective skylight and that he would simply add some sealant to effect a repair.
That did not seem appropriate to us so we called Velux who told us that a new leaky skylight should not be repaired with
sealant and that they would schedule an inspection to determine the proper resolution of the issue. You are most
welcome to be here at the time of that inspection.
2. You told us that GAF would do an inspection so as to determine that the installation was up to their standards so that
they could provide their warranty. We are still waiting for that to happen.
The following items still haven't been discussed nor addressed:
3. One of two areas that were supposed to get replacement plywood did not and remains soft.
4. The areas where the flat roof and pitched roof meet at the garage and the living room were agreed to be covered by
shingles but were not. This was discussed before the existing shingles were removed and it was agreed that the existing
shingles would be glued back on top of the TPO for aesthetic reasons.
5.The TPO termination at the front of our house was installed at an unattractive angle rather than plumb. You said that
this would be corrected, but it has not been.
6. You said that galvanized screws that wouldn't rust would be installed to replace the rusting ones used, but they have
not been replaced.
7. Our existing gutters were cut off and no end cap was put on them. After yesterday's heavy rain, excess water coming
off the peaked roof of the garage and the living room that used to go to the front of the house via the existing gutter, is
now overflowing over the back gutter. You told us that you would correct this by extending the gutter if it proved
necessary. It appears necessary that the gutters be extended.
8. Invoice for Additional Work: We disputed your charge of $2630.00 for additional work immediately upon receiving it
and never signed a contract to pay that amount, but you never addressed the issue. We have no problem paying
for the actual time and material for work that could not have been anticipated, per our
contract. That would apply to the repair done to the rafter on the overhang of the house. It was a
very minor repair only requiring a few feet of 2X6 that was sistered to the rafter over the back sliding
glass door. It was completed by one person, Pete, in about an hour.
Included in this invoice, was work that was done to attach the TPO to the pitched roof. This was not something that was
hidden when the quote was provided to us. This is a standard and required practice for installing a TPO flat roof to a
pitched roof and could be seen in the photos that were taken of the roof to write up the estimate. Your contract stipulates
that additional work as described above would be billed at $85.00 per hour. If we call it two hours of labor, that's $170.00
plus a 2X6 and some bolts. You billed us $2630.00. We are contesting $2000.00 of that pending a resolution regarding
a precise and accurate description of the actual billable work.
We have authorized the credit card company to pay you an additional $4,000.00 towards the completion payment
pending your further progress of the items listed above. .
Please let us know when we can expect further progress towards a final resolution of the above mentioned issues. We
will alert you as to the date of Velux's inspection as soon as they provide it to us.
Thanks.
Steven Kunstler / Judy Soronen
135 Lakeside Drive
Fairfield, CT 06824
im Hick’s
MAIN ROOFING
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Hise Sremeoee
February 20, 2023
Dispute Resolution Department
7300 Chapman Highway
Knoxville, TN 37920-6612
Email: DisputeResolution@elavon.com
Re: Case Number 1049951794
Dear Sirs:
In rebuttal to this dispute we offer the following facts:
On or about April 15, 2022, Ricks Main Roofing Ltd received a call from Judy Soronen. She requested
that we come out and quote replacement of an entire flat roof including replacement of four existing
skylights.
During this estimate, we found that there was rotted plywood below the existing roof which we would
need to repair prior to installing the new flat roof, We discussed this with the customer and completed
the repair. The repair was quoted on September 14, 2022 and was approved and signed. (Copy
attached)
We also sent out our Entire Flat Roof Quote on September 14, 2022, which Judy Soronen approved and
signed. (Copy attached)
The project consisted of two parts: The first contract was for an entire flat roof and was quoted as
$27,830.00. Terms of this contract were 40% ($11,132.00) Upon Signing / 40% ($11,132.00) Midway/
20% ($5,566.00) Upon Completion. On 10/27/2022 the “upon signing” payment was made of
$11,132.00. On 11/04/2022 the “Midway” payment was made. Leaving a balance due upon completion
of the entire flat roof, or 20% as contracted of $5,566.00. The second contract was for the repair work
and skylight installation and was quoted as $5,120.00. Terms of this contract were 50% ($2, 560.00)
upon signing and that payment was made on 10/20/2022. Leaving of balance of $2; BE 10 due upon
completion as were the terms of the contract. This totals § 00 which the customer is disputing.
After completion of the project, the customer called and advised of a possible skylight leak, which we
promptly went back and addressed, documented to have taken place on November 10. This date was
well in advance of the project completion date as contracted. Furthermore, her dispute states that she
cancelled our services on January 13. Our services were a new flat roof and skylight installation. The
services had already been provided and completed. No cancellation was ever received in any form prior
to our services being completed.
im Rick's
MAIN ROOFING
NS LT GENCE
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Page -2-
Dispute Resolution Department
February 20, 2023
We made several telephones calls to Judy Soronen and left several messages in reference in collecting
the “upon completion” payment as contracted. No phone calls were ever returned until January 13
when this customer called and spoke with our accounting department and expressed concern about not
receiving a “wand” (this is an accessory and was not included in our quote), she continued to state that
she did not agree with the repair quote billing which she had signed and approved prior and the work
had already been completed. During this telephone call, she never expressed any dissatisfaction with
the quality of work performed nor the fact that she felt that the “clean-up” was not sufficient.
A message was passed along to our General Manager, Neal Walker to return her call. He called on
several occasions, left messages and never received a return call,
We are adamant that the quality of this work was consistent with all of our projects and not below
professional standards. If this customer was/is having any concerns, she should have returned our
telephone calls and address her concerns with the proper staff.
In addition to receiving the new flat roof and skylight installation, our work is covered for 10 years labor
by Ricks Main Roofing Ltd warranty, and also 20 years manufacturer's warranty. This warranty does not
go into effect until final payment has been received.
FYI - This dispute is dated February 8, and we received this paperworkon February 16, 2023
Thank you.
Aicharcl Tavelle,/le
Richard Tavella
President
RT/la
Enclosure
Dispute Resolution Department
7300 Chapman Highway
Knoxville TN 37920-6612
USA
Phone: 866-600-5008
Fax: 877-888-2034
Monday-Friday
8:30 a.m. to 6:30 p.m. ET
Email: DisputeResolution@elavon.com
FEB 1 6 ate
RICKS MAIN ROOFING LTD Case Number: 1049951794
RICHARD TAVELLA Date of Advice: 02/08/2023
26 FITCH ST Respond By: 02/28/2023
NORWALK CT 06855-1335
USA
Merchant Dispute Advice
For prompt service, please return this cover letter with your rebuttal information.
On 02/08/2023 your account was debited 8,126.00 USD for the disputed transaction listed below. The debit will
post to your account within three to five business days.
Merchant Information
Merchant Name: RICKS MAIN ROOFING LTD
Merchant Number: 8000078884 Ref No.: 26349398
Transaction Information
Cardholder Account #: 417903.000003939 Dispute Amount: 8,126.00 USD
Acquirer Reference #: 24755422326123269604856 Original Transaction Amount: 8,126.00 USD
Transaction Date: 11/21/2022 Dynamic Currency Amount: 8,126.00 USD
Dispute Type: Dispute Authorization Code: 701223
Ticket #
Reason Code: 13.3-Consumer: Not as Described/Defective
The dispute occurred because your customer claims the service or merchandise they received does not conform to
the description they were given, or arrived defective. You may be able to recover these funds by providing information
such as, proof that the cardholder received the goods or services which match the description at the time of the
purchase or proof that the deficiency has been corrected. If you feel this dispute is in error, please submit a rebuttal
by fax or email.
Pursuant to card brand regulations, if the cardholder or issuing bank continues to dispute the transaction, the
cardholder can return the item, even if you submit a response to the dispute, You must provide all relevant information
and documentation related to the above case with your rebuttal. Please allow a minimum of 72 hours for us to process
your response.
Go Please check here if the cardholder has a valid claim and you are willing to accept the dispute.
Ww Please check here if you disagree with the cardholder's claim and are providing a rebuttal response.
Please reply by the “Respond By” date listed above to meet regulatory requirements and ensure a timely
review of a possible reversal request Please include this advice letter with your rebuttal information.
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Judy Soronen & Steven Kunstler
135 Lakeside Drive
Fairfield, CT 06824
We have been trying to reach you unsuccessfully by telephone and email
We are reaching out to you to address the concerns that you have regarding the
roof project we completed at your home as outlined in your email of March 6,
2023
We believe that no action is required regarding your chimney, but are
happy to meet with you on site to discuss this matter.
If we comply with your request to have shingles where the flat roof meets
the garage and living room, it will void your warranty
We will provide a skylight pole to you at no charge. (These poles are
considered accessories and are not included with the skylight unit)
The Velux warranty for the skylights is enclosed
OMMERCIAL, www.ricksmainroofing.com RESIDENTIAL
Kindly call our office at (203) 838-5858 so that we can schedule a time for me to
meet with you to discuss this in depth and resolve the matter to your satisfaction.
Respectfully,
Heal
Neal Walker
Director of Operations
Certified Mail# -7020 2450 0001 5640 5535