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  • RICK'S MAIN ROOFING, LTD/RICHARD TAVELLA v. SORONEN, JUDYS20 - Small Claims - Small Claims - Contract - Home Improvement document preview
  • RICK'S MAIN ROOFING, LTD/RICHARD TAVELLA v. SORONEN, JUDYS20 - Small Claims - Small Claims - Contract - Home Improvement document preview
  • RICK'S MAIN ROOFING, LTD/RICHARD TAVELLA v. SORONEN, JUDYS20 - Small Claims - Small Claims - Contract - Home Improvement document preview
  • RICK'S MAIN ROOFING, LTD/RICHARD TAVELLA v. SORONEN, JUDYS20 - Small Claims - Small Claims - Contract - Home Improvement document preview
  • RICK'S MAIN ROOFING, LTD/RICHARD TAVELLA v. SORONEN, JUDYS20 - Small Claims - Small Claims - Contract - Home Improvement document preview
  • RICK'S MAIN ROOFING, LTD/RICHARD TAVELLA v. SORONEN, JUDYS20 - Small Claims - Small Claims - Contract - Home Improvement document preview
  • RICK'S MAIN ROOFING, LTD/RICHARD TAVELLA v. SORONEN, JUDYS20 - Small Claims - Small Claims - Contract - Home Improvement document preview
  • RICK'S MAIN ROOFING, LTD/RICHARD TAVELLA v. SORONEN, JUDYS20 - Small Claims - Small Claims - Contract - Home Improvement document preview
						
                                

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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. { i rene 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. it it Pe il ii It's unfortunate that your tone is so negative and you threaten us with a te lawsuit. You could have simply emailed us your invoices, credits applied hi 1é and balance due ti fe We'll look for the statements. Hopefully you can send that today ii 13 hi if it iy i hi Regards, i 1) 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 en 2 sep aceane S et 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 ED G8 ate, a Sganee 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. UM UNM QAO ALO AA y ay FLAT LET Roles MAIN fi ol: SHINGLES SLATE C TILE wooD enema BEE meme CI [Certified Is] Ee Dh 1 CT HOME IMPROVEMENT 26 FITCH STREET, NORWALK,+5 iS aS > xira Services & Foes (check box, add CONTRACTOR REG. TELEPHONE (203) 338.) ‘CRetum Recelpt hardcopy) 580430 FAX NUMBER (203) 838: 3 (CiRetum Recefpt (electronic) me CiCertitied Mall Restricted Delivery office @ricksmalnroofing 3 ClAdutt Signature Required iAdutt signature Restricted Dallory an 23 "ostage [Total Postageand Fees mae fle. nu Bm gerry Heine UAL. IO) Se pra March 22, 2023 o ae 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