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RETURN DATE: MARCH 9, 2024 SUPERIOR COURT
JSIP TANNERY, LLC J.D. OF HARTFORD
Vs. AT HARTFORD
(HOUSING SESSION)
PATRICK QUINN AND ANGELA QUINN FEBRUARY 26, 2024
COMPLAINT
FIRST COUNT
1. On or before September 27, 2023, plaintiff entered into a written lease
agreement with defendants for the rental of the apartment known as 3102 Flanagan Drive,
Glastonbury, CT 06033, for the term of one year (“Lease”).
2. Defendants took possession of the premises under the Lease and still occupy
the premises.
3. Defendants engaged in and/or allowed guests to engage in disturbing activity on
the premises. Specifically, on several occasions defendants created disturbances in their
unit and the common areas which involve violating the community's no-smoking policy by
smoking excessively in their unit and the common areas. This smoke escapes their unit
and enters other residents units and common areas severely disturbing other residents.
Additionally, defendants conducted themselves in a manner involving: creating excessive
noise at all hours of the day and night; yelling; engaging in altercations in the common
areas; and propping open the main doors to the building to allow unauthorized individuals
to come and go freely severely compromising the security of the building and safety of
other residents. This disorderly conduct is in direct violation of their lease and No-
Smoking Lease Addendum; disrupts the landlords business operations, disturbs the
neighbors’ peaceful enjoyment of the premises; and interferes substantially with the
comfort or safety of other tenants or occupants of the same or adjacent buildings or
structures.
4. The conduct described in Paragraph 3 violated sections 19; 20; 21; 33; and (No-
Smoking Addendum — Sections: 4, 5, 6, 9, and 11) of the Lease.
5. On December 29, 2028, plaintiff delivered to defendants written notice of said
violations (attached as Exhibit 1).
6. On January 22, 2024 plaintiff caused a notice to quit possession to be served on
defendants to vacate the premises on or before February 23, 2024 for reason of the
aforementioned violations (attached as Exhibit 2).
7. Although the time designated in the notice to quit possession of said premises
has passed, defendants still remain in possession.
SECOND COUNT
1-3. Paragraphs 1 through 3 of the First Count are hereby made Paragraphs 1
through 3 of the Second Count as if fully set forth herein.
4. Defendants have conducted themselves in a manner that violated Connecticut
General Statutes § 47a-11(a) by engaging in the conduct described in Paragraph 3.
5. On December 29, 2023, plaintiff delivered to defendants written notice of said
violations (attached as Exhibit 1).
6. On January 22, 2024 plaintiff caused a notice to quit possession to be served on
defendants to vacate the premises on or before February 23, 2024 for reason of the
aforementioned violations (attached as Exhibit 2).
7. Although the time designated in the notice to quit possession of said premises
has passed, defendants still remain in possession.
THIRD COUNT
1-3. Paragraphs 1 through 3 of the First Count are hereby made Paragraphs 1
through 3 of the Third Count as if fully set forth herein.
4. Defendants have conducted themselves in a manner that violated Connecticut
General Statutes § 47a-11(g) by engaging in the conduct described in Paragraph 3.
5. On December 29, 2023, plaintiff delivered to defendants written notice of said
violations (attached as Exhibit 1).
6. On January 22, 2024 plaintiff caused a notice to quit possession to be served on
defendants to vacate the premises on or before February 23, 2024 for reason of the
aforementioned violations (attached as Exhibit 2).
7. Although the time designated in the notice to quit possession of said premises
has passed, defendants still remain in possession.
FOURTH COUNT
1-3. Paragraphs 1 through 3 of the First Count are hereby made Paragraphs 1
through 3 of the Fourth Count as if fully set forth herein.
4. Defendants have conducted themselves in a manner that constitutes a nuisance
in violation of Connecticut General Statutes §§ 47a-11(g) and 47a-32 by engaging in the
conduct described in Paragraph 3, which interferes substantially with the comfort or safety
of other tenants or occupants of the same or adjacent buildings or structures.
5. On December 29, 2023, plaintiff delivered to defendants written notice of said
violations (attached as Exhibit 1).
6. On January 22, 2024 plaintiff caused a notice to quit possession to be served on
defendants to vacate the premises on or before February 23, 2024 for reason of the
aforementioned violations (attached as Exhibit 2).
7. Although the time designated in the notice to quit possession of said premises
has passed, defendants still remain in possession.
FIFTH COUNT
1-2. Paragraphs 1 through 2 of the First Count are hereby made Paragraphs 1
through 2 of the Fifth Count as if fully set forth herein.
3. Defendants failed to pay the monthly rent due on October 1, 2023 through and
including January 1, 2024.
4. On December 29, 2023, plaintiff delivered to defendants written notice of said
violations (attached as Exhibit 1).
5. On January 22, 2024, plaintiff caused a notice to quit possession to be served
on defendants to vacate the premises on or before February 23, 2024 as required by law
(attached as Exhibit 2).
6. Although the time designated in the notice to quit possession of said premises
has passed, defendants still remain in possession.
WHEREFORE, PLAINTIFF CLAIMS:
Judgment for the immediate possession of said premises, with costs.
JSIP Tannery, LLC
By
. Chesson, Esq.
. Adam Schweickert, Esq.
Jeff M. Mastrianni, Esq.
Chesson & Schweickert LLC
215 Broad Street
Milford, CT 06460
Tel.: 203-874-4747
Juris No. 423788
THEIR ATTORNEY
3113-0010
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LandlordLawFirm
Chesson & Schweickert LLC
215 Broad Street
Milford, CT 06460
Tel. 203-874-4747
Fax 203-874-4701
HAND DELIVERED and
SENT VIA FIRST CLASS MAIL
December 28, 2023
Patrick Quinn
Angela Quinn
3102 Flanagan Drive
Glastonbury, CT 06033
Dear Patrick Quinn and Angela Quinn:
| am writing on behalf of your landlord, JSIP Tannery, LLC, as they have retained
our firm to represent them regarding their rights and interests under your lease.
You are hereby notified that you are allegedly in violation of your dwelling lease
and the Connecticut General Statutes in that you have materially failed to comply
with the following provisions of that lease and the rules and regulations
concerning your use and occupancy of the premises, and the Connecticut
General Statutes, as is more specifically set forth below.
|
A. Section 19. Community Policies or Rules:
“You and all guests and occupants must comply with any written dwelling
unit rules and community policies, including instructions for care of our
property. Our rules are considered part of this Lease Contract...”
You are allegedly in violation of this provision of your lease because you
engaged in and/or allowed guests to engage in disturbing activity on the
premises. Specifically, on several occasions you created disturbances in
your unit and the common areas which involve violating the community's no-
smoking policy by smoking excessively in your unit and the common areas.
This smoke escapes your unit and enters other residents units and common
areas severely disturbing other residents. Additionally, you conducted
yourselves in a manner involving: creating excessive noise at all hours of the
day and night; yelling; engaging in altercations in the common areas; and
propping open the main doors to the building to allow unauthorized individuals
to come and go freely severely compromising the security of the building and
EXHIBIT 1
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safety of other residents. This disorderly conduct is in direct violation of your
lease and No-Smoking Lease Addendum; disrupts your landlords business
operations, disturbs your neighbors’ peaceful enjoyment of the premises;
interferes substantially with the comfort or safety of other tenants or
occupants of the same or adjacent buildings or structures.
Section 20. Limitations on Conduct:
“...We may exclude from the apartment community guests or others who,
in our judgment, have been violating the law, violating this Lease Contract
or any dwelling unit rules, or disturbing other residents, neighbors, visitors,
or owner representatives...”
You are allegedly in violation of this provision of your lease because you
engaged in and/or allowed guests to engage in disturbing activity on the
premises. Specifically, on several occasions you created disturbances in
your unit and the common areas which involve violating the community's no-
smoking policy by smoking excessively in your unit and the common areas.
This smoke escapes your unit and enters other residents units and common
areas severely disturbing other residents. Additionally, you conducted
yourselves in a manner involving: creating excessive noise at all hours of the
day and night; yelling; engaging in altercations in the common areas; and
propping open the main doors to the building to allow unauthorized individuals
to come and go freely severely compromising the security of the building and
safety of other residents. This disorderly conduct is in direct violation of your
lease and No-Smoking Lease Addendum; disrupts your landlords business
operations, disturbs your neighbors’ peaceful enjoyment of the premises;
interferes substantially with the comfort or safety of other tenants or
occupants of the same or adjacent buildings or structures.
Section 21. Prohibited Conduct:
“You, your occupants or guests, or the guests of any occupants may not
engage in the following activities: behaving in a loud or obnoxious
manner; disturbing or threatening the rights, comfort, health, safety, or
convenience of others (including our agents and employees) in or near the
community; disrupting our business operations...”
You are allegedly in violation of this provision of your lease because you
engaged in and/or allowed guests to engage in disturbing activity on the
premises. Specifically, on several occasions you created disturbances in
your unit and the common areas which involve violating the community's no-
Landlord_awFirm and LLF are registered trademarks of Chesson & Schweickert LLC
Z§LLF
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smoking policy by smoking excessively in your unit and the common areas.
This smoke escapes your unit and enters other residents units and common
areas severely disturbing other residents. Additionally, you conducted
yourselves in a manner involving: creating excessive noise at all hours of the
day and night; yelling; engaging in altercations in the common areas; and
propping open the main doors to the building to allow unauthorized individuals
to come and go freely severely compromising the security of the building and
safety of other residents. This disorderly conduct is in direct violation of your
lease and No-Smoking Lease Addendum; disrupts your landlords business
operations, disturbs your neighbors’ peaceful enjoyment of the premises;
interferes substantially with the comfort or safety of other tenants or
occupants of the same or adjacent buildings or structures.
Section 33. Default By Resident:
“Non-monetary Default. You will be in default if you or any guest or
occupant violates any other terms of this Lease Contract including but not
limited to the following violations: (1) you or any guest or occupant
violates the dwelling unit rules, or fire, safety, health, or criminal laws,
regardless of whether or where arrest or conviction occurs...(6) you or any
guest or occupant engages in any of the prohibited conduct described in
Paragraph 21...”
You are allegedly in violation of this provision of your lease because you
engaged in and/or allowed guests to engage in disturbing activity on the
premises. Specifically, on several occasions you created disturbances in
your unit and the common areas which involve violating the community's no-
smoking policy by smoking excessively in your unit and the common areas.
This smoke escapes your unit and enters other residents units and common
areas severely disturbing other residents. Additionally, you conducted
yourselves in a manner involving: creating excessive noise at all hours of the
day and night; yelling; engaging in altercations in the common areas; and
propping open the main doors to the building to allow unauthorized individuals
to come and go freely severely compromising the security of the building and
safety of other residents. This disorderly conduct is in direct violation of your
lease and No-Smoking Lease Addendum; disrupts your landlords business
operations, disturbs your neighbors’ peaceful enjoyment of the premises;
interferes substantially with the comfort or safety of other tenants or
occupants of the same or adjacent buildings or structures.
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E. No-Smoking Addendum:
“4. Smoking Anywhere Inside Buildings of the Apartment
Community is Strictly Prohibited. All forms and use of burning,
lighted, vaporized, or ignited tobacco products and smoking of
tobacco products inside any dwelling, building, or interior of any
portion of the apartment community is strictly prohibited. Any
violation of the no-smoking policy is a material and substantial
violation of this Addendum and the Lease Contract.
The prohibition on use of any burning, lighted, vaporized, or ignited
tobacco products or smoking of any tobacco products extends to all
residents, their occupants, guests, invitees and all others who are
present on or in any portion of the apartment community. The no-
smoking policy and rules extend to, but are not limited to, the
management and leasing offices, building interiors and hallways,
building common areas, dwelling units, club house, exercise or spa
facility, tennis courts, all interior areas of the community,
commercial shops, businesses, and spaces, work areas, and all
other spaces whether in the interior of the community or in the
enclosed spaces on the surrounding community grounds. Smoking
of non-tobacco products which are harmful to the health, safety,
and welfare of other residents inside any dwelling or building is also
prohibited by this addendum and other provisions of the Lease
Contract.
Smoking Outside Buildings of the Apartment Community.
Smoking is permitted only in specially designated areas outside the
buildings of the apartment community. Smoking must be at least
25 feet from the buildings in the apartment community, including
administrative office buildings. If the previous filed is not
completed, smoking is only permitted at least 25 feet from the
buildings in the apartment community, including administrative
office buildings. The smoking-permissible areas are marked by
signage.
Smoking on balconies, patios, and limited common areas attached
to or outside of your dwelling is not permitted.
The following outside areas of the community may be used for
smoking: This is a non-smoking community. Smoking is not
permitted anywhere on the property.
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Even though smoking may be permitted in certain limited outside
areas, we reserve the right to direct that you and your occupants,
family, guests, and invitees cease and desist from smoking in those
areas if smoke is entering the dwelling units or buildings or if it is
interfering with the health, safety, or welfare or disturbing the quite
enjoyment, or business operations of us, other residents or guests.
Smoking of Drugs or Other Illegal Substances. The smoking of
any illegal or controlled substances, including specifically marijuana
(regardless of the legalization or decriminalization of marijuana by
local or State law), inside any Dwelling Unit, common area,
building, or in any outdoor portion of the apartment community is
strictly prohibited by this Addendum and other provisions of the
Lease Contract.
Lease Contract Termination for Violation of the Addendum.
We have the right to terminate your Lease Contract or right of
occupancy of the dwelling for any violation of this No-Smoking
Addendum. Violation of the no-smoking provisions is a material
and substantial default or violation of the Lease Contract...
11 Your Responsibility for Conduct of Occupants, Family
Members, and Guests. You are responsible for communicating
this community's no-smoking policy and for ensuring compliance
with this Addendum by your occupants, family, guests, and
invitees.”
You are allegedly in violation of each of these provisions of your lease
because you engaged in and/or allowed guests to engage in disturbing
activity on the premises. Specifically, on several occasions you created
disturbances in your unit and the common areas which involve violating the
community’s no-smoking policy by smoking excessively in your unit and the
common areas. This smoke escapes your unit and enters other residents
units and common areas severely disturbing other residents. Additionally,
you conducted yourselves in a manner involving: creating excessive noise at
all hours of the day and night; yelling; engaging in altercations in the common
areas; and propping open the main doors to the building to allow
unauthorized individuals to come and go freely severely compromising the
security of the building and safety of other residents. This disorderly conduct
is in direct violation of your lease and No-Smoking Lease Addendum; disrupts
your landlords business operations, disturbs your neighbors’ peaceful
5
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enjoyment of the premises; interferes substantially with the comfort or safety
of other tenants or occupants of the same or adjacent buildings or structures.
Connecticut General Statutes Section 47a-11(a):
“Sec. 47a-11. Tenant's responsibilities. A tenant shall: (a) Comply with all
obligations primarily imposed upon tenants by applicable provisions of any
building, housing or fire code materially affecting health and safety...”
You are allegedly in violation of this provision because you engaged in and/or
allowed guests to engage in disturbing activity on the premises. Specifically,
on several occasions you created disturbances in your unit and the common
areas which involve violating the community's no-smoking policy by smoking
excessively in your unit and the common areas. This smoke escapes your
unit and enters other residents units and common areas severely disturbing
other residents. Additionally, you conducted yourselves in a manner
involving: creating excessive noise at all hours of the day and night; yelling;
engaging in altercations in the common areas; and propping open the main
doors to the building to allow unauthorized individuals to come and go freely
severely compromising the security of the building and safety of other
residents. This disorderly conduct is in direct violation of your lease and No-
Smoking Lease Addendum; disrupts your landlords business operations,
disturbs your neighbors’ peaceful enjoyment of the premises; interferes
substantially with the comfort or safety of other tenants or occupants of the
same or adjacent buildings or structures.
Connecticut General Statutes Section 47a-11(g):
“Sec. 47a-11. Tenant's responsibilities. A tenant shall: ... (g) conduct
himself and require other persons on the premises with his consent to
conduct themselves in a manner that will not disturb his neighbors’
peaceful enjoyment of the premises ...”
You are allegedly in violation of this provision because you engaged in and/or
allowed guests to engage in disturbing activity on the premises. Specifically,
on several occasions you created disturbances in your unit and the common
areas which involve violating the community’s no-smoking policy by smoking
excessively in your unit and the common areas. This smoke escapes your
unit and enters other residents units and common areas severely disturbing
other residents. Additionally, you conducted yourselves in a manner
involving: creating excessive noise at all hours of the day and night; yelling;
engaging in altercations in the common areas; and propping open the main
6
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doors to the building to allow unauthorized individuals to come and go freely
severely compromising the security of the building and safety of other
residents. This disorderly conduct is in direct violation of your lease and No-
Smoking Lease Addendum; disrupts your landlords business operations,
disturbs your neighbors’ peaceful enjoyment of the premises; interferes
substantially with the comfort or safety of other tenants or occupants of the
same or adjacent buildings or structures.
Connecticut General Statutes Sections 47a-11(g) and 47a-32:
“Sec. 47a-11. Tenant's responsibilities. A tenant shall: .... (g) conduct
himself and require other persons on the premises with his consent to
conduct themselves in a manner that will not ... constitute a nuisance, as
defined in section 47a-32 . . .”
“Sec. 47a-32. Nuisance defined. In any action of summary process
based upon nuisance, that term shall be taken to include, but shall not be
limited to, any conduct which interferes substantially with the comfort or
safety of other tenants or occupants of the same or adjacent buildings or
structures.”
You are allegedly in violation of these provisions because you engaged in
and/or allowed guests to engage in disturbing activity on the premises.
Specifically, on several occasions you created disturbances in your unit and
the common areas which involve violating the community's no-smoking policy
by smoking excessively in your unit and the common areas. This smoke
escapes your unit and enters other residents units and common areas
severely disturbing other residents. Additionally, you conducted yourselves in
a manner involving: creating excessive noise at all hours of the day and night;
yelling; engaging in altercations in the common areas; and propping open the
main doors to the building to allow unauthorized individuals to come and go
freely severely compromising the security of the building and safety of other
residents. This disorderly conduct is in direct violation of your lease and No-
Smoking Lease Addendum; disrupts your landlords business operations,
disturbs your neighbors’ peaceful enjoyment of the premises; interferes
substantially with the comfort or safety of other tenants or occupants of the
same or adjacent buildings or structures.
7
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i
A. Section 6. Rent and Charges:
“Unless modified by addenda, you will pay $3,191.00 per month for rent,
payable in advance and without demand ...If you don’t pay rent on time,
you'll be delinquent and all remedies under this Lease Contract will be
authorized...”
You are allegedly in violation of this provision of your lease because as of
today, your Landlord has not received your full rent payment — your overdue
balance is $10,033.40 for the amounts owed through December 2023.
You will also owe $3,191.00 rent due for January 2024. Please be advised
that your rent payment is due on the 1st of each month, with a grace period
until the 10'* — payments received after the 10th are subject to a late fee
pursuant to the Lease.
Section 32. Default By Resident:
“You'll be in default if you or any guest or occupant violates any terms of
this Lease Contract including but not limited to the following violations: (1)
you don’t pay rent or other amounts that you owe when due...”
You are allegedly in violation of this provision of your lease because as of
today, your Landlord has not received your full rent payment — your overdue
balance is $10,033.40 for the amounts owed through December 2023.
You will also owe $3,191.00 rent due for January 2024. Please be advised
that your rent payment is due on the 1st of each month, with a grace period
until the 10'" — payments received after the 10th are subject to a late fee
pursuant to the Lease.
I.
If the above-noted violations can be and are remedied by repair or payment of
damages on your part within fifteen (15) days of this notice, no action will be
taken against you based on these violations. If however, the above-noted
violations are not remedied within that fifteen (15) day period, your rental
agreement shall thereafter terminate upon service of a notice to quit.
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In the event that judicial proceedings for your eviction are instituted, you will be
entitled to present any defense that you may have under the laws of the State of
Connecticut.
Sincerel
‘obeft W. Chesson, Esq.
Attorney for Landlord, JSIP Tannery, LLC
cc: Brittany Santana
Kamari Dudley
Joanne Aviles
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Para informacion y FORMULARIOS DE DESALOJOS
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STATE OF CONNECTICUT}
} SS: GLASTONBURY, DECEMBER 29 2023
COUNTY OF HARTFORD }
Then and by virtue hereof, on the 29" day of December, 2023, I left a verified true
and attested copy of the within original Pretermination Notice, and Right to Counsel
Flyer in English and Spanish, at the usual place of abode of the within named tenant,
PATRICK QUINN, at 3102 Flanagan Drive, in the Town of Glastonbury.
Also on the 29" day of December, 2023, I left a verified true and attested copy of the
within original Pretermination Notice, and Right to Counsel Flyer in English and
Spanish, at the usual place of abode of the within named tenant, ANGELA QUINN, at
3102 Flanagan Drive, in the Town of Glastonbury.
The within is the original Pretermination Notice, and Right to Counsel Flyer in
English and Spanish, with my doings hereon endorsed.
FEES: $ 50.00 ATTEST
J. RODRIGUEZ
STATE MARSHAL
HARTFORDYCOUNTY
TO: Patrick Quinn
Angela Quinn
3102 Flanagan Drive
Glastonbury, CT 06033
PLEASE TAKE NOTICE that you are to QUIT POSSESSION and occupancy of the
premises now occupied by you, consisting of 3102 Flanagan Drive, Glastonbury, CT 06033 on
or before February 23, 2024, pursuant to the statute in such cases made and provided, for the
following reasons:
1. Violation of Lease — Sections 19; 20; 21; 33; and (No-Smoking Addendum —
Sections: 4, 5, 6, 9, and 11) — You have violated each of these provisions of your lease
because you engaged in and/or allowed guests to engage in disturbing activity on the
premises. Specifically, on several occasions you created disturbances in your unit and the
common areas which involve violating the community's no-smoking policy by smoking
excessively in your unit and the common areas. This smoke escapes your unit and enters
other residents units and common areas severely disturbing other residents. Additionally, you
conducted yourselves in a manner involving: creating excessive noise at all hours of the day
and night; yelling; engaging in altercations in the common areas; and propping open the main
doors to the building to allow unauthorized individuals to come and go freely severely
compromising the security of the building and safety of other residents. This disorderly
conduct is in direct violation of your lease and No-Smoking Lease Addendum; disrupts your
See
landlords business operations, disturbs your neighbors’ peaceful enjoyment of the premises;
interferes substantially with the comfort or safety of other tenants or occupants of the same or
adjacent buildings or structures; or
2. Violation of Connecticut General Statutes Section 47a-11(a). You have violated this
provision because you engaged in and/or allowed guests to engage in disturbing activity on the
premises. Specifically, on several occasions you created disturbances in your unit and the
common areas which involve violating the community's no-smoking policy by smoking
excessively in your unit and the common areas. This smoke escapes your unit and enters
other residents units and common areas severely disturbing other residents. Additionally, you
conducted yourselves in a manner involving: creating excessive noise at all hours of the day
and night; yelling; engaging in altercations in the common areas; and propping open the main
doors to the building to allow unauthorized individuals to come and go freely severely
compromising the security of the building and safety of other residents. This disorderly
conduct is in direct violation of your lease and No-Smoking Lease Addendum; disrupts your
landlords business operations, disturbs your neighbors’ peaceful enjoyment of the premises;
interferes substantially with the comfort or safety of other tenants or occupants of the same or
adjacent buildings or structures; or
3. Violation of Connecticut General Statutes Section 47a-11(g). You have violated this
provision because you engaged in and/or allowed guests to engage in disturbing activity on the
premises. Specifically, on several occasions you created disturbances in your unit and the
common areas which involve violating the community's no-smoking policy by smoking
excessively in your unit and the common areas. This smoke escapes your unit and enters
other residents units and common areas severely disturbing other residents. Additionally, you
conducted yourselves in a manner involving: creating excessive noise at all hours of the day
and night; yelling; engaging in altercations in the common areas; and propping open the main
doors to the building to allow unauthorized individuals to come and go freely severely
compromising the security of the building and safety of other residents. This disorderly
conduct is in direct violation of your lease and No-Smoking Lease Addendum; disrupts your
landlords business operations, disturbs your neighbors’ peaceful enjoyment of the premises;
interferes substantially with the comfort or safety of other tenants or occupants of the same or
adjacent buildings or structures; or
4. Nuisance, in violation of Connecticut General Statutes Sections 47a-11(g) and 47a-
32. You have violated these provisions because you engaged in and/or allowed guests to
engage in disturbing activity on the premises. Specifically, on several occasions you created
disturbances in your unit and the common areas which involve violating the community’s no-
smoking policy by smoking excessively in your unit and the common areas. This smoke
escapes your unit and enters other residents units and common areas severely disturbing
other residents. Additionally, you conducted yourselves in a manner involving: creating
excessive noise at all hours of the day and night; yelling; engaging in altercations in the
common areas; and propping open the main doors to the building to allow unauthorized
individuals to come and go freely severely compromising the security of the building and safety
of other residents. This disorderly conduct is in direct violation of your lease and No-Smoking
Lease Addendum; disrupts your landlords business operations, disturbs your neighbors’
peaceful enjoyment of the premises; interferes substantially with the comfort or safety of other
tenants or occupants of the same or adjacent buildings or structures; or
5. Non-payment of Rent.
ANY PAYMENTS TENDERED AFTER SERVICE OF THE NOTICE TO QUIT
WILL BE ACCEPTED FOR REIMBURSEMENT OF COSTS AND FOR USE
AND OCCUPANCY ONLY, AND NOT FOR RENT, WITH FULL RESERVATION
OF RIGHTS TO CONTINUE WITH THE EVICTION ACTION.
DATED at Milford, Connecticut, this day, Thursday, January 18, 2024.
JSIP Tannery, LLC
By:
Robert W. Chesson, Esq.
G. Adam Schweickert, Esq.
Jeff M. Mastrianni, Esq.
Chesson & Schweickert LLC
215 Broad Street
Milford, CT 06460
Tel.: 203-874-4747
Juris No. 423788
THEIR ATTORNEY
3113-0010
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learn about the eviction referrals for housing, utility, about the eviction process Eviction Prevention Fund by visiting
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process and how to respond forms/eviction_prevention
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RETURN DATE: MARCH 9, 2024 SUPERIOR COURT JSIP TANNERY, LLC J.D. OF HARTFORD Vs. AT HARTFORD (HOUSING SESSION) PATRICK QUINN AND ANGELA QUINN FEBRUARY 26, 2024 COMPLAINT FIRST COUNT 1. On or before September 27, 2023, plaintiff entered into a written lease agreement with defendants for the rental of the apartment known as 3102 Flanagan Drive, Glastonbury, CT 06033, for the term of one year (“Lease”). 2. Defendants took possession of the premises under the Lease and still occupy the premises. 3. Defendants engaged in and/or allowed guests to engage in disturbing activity on the premises. Specifically, on several occasions defendants created disturbances in their unit and the common areas which involve violating the community's no-smoking policy by smoking excessively in their unit and the common areas. This smoke escapes their unit and enters other residents units and common areas severely disturbing other residents. Additionally, defendants conducted themselves in a manner involving: creating excessive noise at all hours of the day and night; yelling; engaging in altercations in the common areas; and propping open the main doors to the building to allow unauthorized individuals to come and go freely severely compromising the security of the building and safety of other residents. This disorderly conduct is in direct violation of their lease and No- Smoking Lease Addendum; disrupts the landlords business operations, disturbs the neighbors’ peaceful enjoyment of the premises; and interferes substantially with the comfort or safety of other tenants or occupants of the same or adjacent buildings or structures. 4. The conduct described in Paragraph 3 violated sections 19; 20; 21; 33; and (No- Smoking Addendum — Sections: 4, 5, 6, 9, and 11) of the Lease. 5. On December 29, 2028, plaintiff delivered to defendants written notice of said violations (attached as Exhibit 1). 6. On January 22, 2024 plaintiff caused a notice to quit possession to be served on defendants to vacate the premises on or before February 23, 2024 for reason of the aforementioned violations (attached as Exhibit 2). 7. Although the time designated in the notice to quit possession of said premises has passed, defendants still remain in possession. SECOND COUNT 1-3. Paragraphs 1 through 3 of the First Count are hereby made Paragraphs 1 through 3 of the Second Count as if fully set forth herein. 4. Defendants have conducted themselves in a manner that violated Connecticut General Statutes § 47a-11(a) by engaging in the conduct described in Paragraph 3. 5. On December 29, 2023, plaintiff delivered to defendants written notice of said violations (attached as Exhibit 1). 6. On January 22, 2024 plaintiff caused a notice to quit possession to be served on defendants to vacate the premises on or before February 23, 2024 for reason of the aforementioned violations (attached as Exhibit 2). 7. Although the time designated in the notice to quit possession of said premises has passed, defendants still remain in possession. THIRD COUNT 1-3. Paragraphs 1 through 3 of the First Count are hereby made Paragraphs 1 through 3 of the Third Count as if fully set forth herein. 4. Defendants have conducted themselves in a manner that violated Connecticut General Statutes § 47a-11(g) by engaging in the conduct described in Paragraph 3. 5. On December 29, 2023, plaintiff delivered to defendants written notice of said violations (attached as Exhibit 1). 6. On January 22, 2024 plaintiff caused a notice to quit possession to be served on defendants to vacate the premises on or before February 23, 2024 for reason of the aforementioned violations (attached as Exhibit 2). 7. Although the time designated in the notice to quit possession of said premises has passed, defendants still remain in possession. FOURTH COUNT 1-3. Paragraphs 1 through 3 of the First Count are hereby made Paragraphs 1 through 3 of the Fourth Count as if fully set forth herein. 4. Defendants have conducted themselves in a manner that constitutes a nuisance in violation of Connecticut General Statutes §§ 47a-11(g) and 47a-32 by engaging in the conduct described in Paragraph 3, which interferes substantially with the comfort or safety of other tenants or occupants of the same or adjacent buildings or structures. 5. On December 29, 2023, plaintiff delivered to defendants written notice of said violations (attached as Exhibit 1). 6. On January 22, 2024 plaintiff caused a notice to quit possession to be served on defendants to vacate the premises on or before February 23, 2024 for reason of the aforementioned violations (attached as Exhibit 2). 7. Although the time designated in the notice to quit possession of said premises has passed, defendants still remain in possession. FIFTH COUNT 1-2. Paragraphs 1 through 2 of the First Count are hereby made Paragraphs 1 through 2 of the Fifth Count as if fully set forth herein. 3. Defendants failed to pay the monthly rent due on October 1, 2023 through and including January 1, 2024. 4. On December 29, 2023, plaintiff delivered to defendants written notice of said violations (attached as Exhibit 1). 5. On January 22, 2024, plaintiff caused a notice to quit possession to be served on defendants to vacate the premises on or before February 23, 2024 as required by law (attached as Exhibit 2). 6. Although the time designated in the notice to quit possession of said premises has passed, defendants still remain in possession. WHEREFORE, PLAINTIFF CLAIMS: Judgment for the immediate possession of said premises, with costs. JSIP Tannery, LLC By . Chesson, Esq. . Adam Schweickert, Esq. Jeff M. Mastrianni, Esq. Chesson & Schweickert LLC 215 Broad Street Milford, CT 06460 Tel.: 203-874-4747 Juris No. 423788 THEIR ATTORNEY 3113-0010 SOLLF LandlordLawFirm Chesson & Schweickert LLC 215 Broad Street Milford, CT 06460 Tel. 203-874-4747 Fax 203-874-4701 HAND DELIVERED and SENT VIA FIRST CLASS MAIL December 28, 2023 Patrick Quinn Angela Quinn 3102 Flanagan Drive Glastonbury, CT 06033 Dear Patrick Quinn and Angela Quinn: | am writing on behalf of your landlord, JSIP Tannery, LLC, as they have retained our firm to represent them regarding their rights and interests under your lease. You are hereby notified that you are allegedly in violation of your dwelling lease and the Connecticut General Statutes in that you have materially failed to comply with the following provisions of that lease and the rules and regulations concerning your use and occupancy of the premises, and the Connecticut General Statutes, as is more specifically set forth below. | A. Section 19. Community Policies or Rules: “You and all guests and occupants must comply with any written dwelling unit rules and community policies, including instructions for care of our property. Our rules are considered part of this Lease Contract...” You are allegedly in violation of this provision of your lease because you engaged in and/or allowed guests to engage in disturbing activity on the premises. Specifically, on several occasions you created disturbances in your unit and the common areas which involve violating the community's no- smoking policy by smoking excessively in your unit and the common areas. This smoke escapes your unit and enters other residents units and common areas severely disturbing other residents. Additionally, you conducted yourselves in a manner involving: creating excessive noise at all hours of the day and night; yelling; engaging in altercations in the common areas; and propping open the main doors to the building to allow unauthorized individuals to come and go freely severely compromising the security of the building and EXHIBIT 1 LandlordLawFirm and LLF are registered trademarks of Chesson & S S§LLF LandlordLawFirm safety of other residents. This disorderly conduct is in direct violation of your lease and No-Smoking Lease Addendum; disrupts your landlords business operations, disturbs your neighbors’ peaceful enjoyment of the premises; interferes substantially with the comfort or safety of other tenants or occupants of the same or adjacent buildings or structures. Section 20. Limitations on Conduct: “...We may exclude from the apartment community guests or others who, in our judgment, have been violating the law, violating this Lease Contract or any dwelling unit rules, or disturbing other residents, neighbors, visitors, or owner representatives...” You are allegedly in violation of this provision of your lease because you engaged in and/or allowed guests to engage in disturbing activity on the premises. Specifically, on several occasions you created disturbances in your unit and the common areas which involve violating the community's no- smoking policy by smoking excessively in your unit and the common areas. This smoke escapes your unit and enters other residents units and common areas severely disturbing other residents. Additionally, you conducted yourselves in a manner involving: creating excessive noise at all hours of the day and night; yelling; engaging in altercations in the common areas; and propping open the main doors to the building to allow unauthorized individuals to come and go freely severely compromising the security of the building and safety of other residents. This disorderly conduct is in direct violation of your lease and No-Smoking Lease Addendum; disrupts your landlords business operations, disturbs your neighbors’ peaceful enjoyment of the premises; interferes substantially with the comfort or safety of other tenants or occupants of the same or adjacent buildings or structures. Section 21. Prohibited Conduct: “You, your occupants or guests, or the guests of any occupants may not engage in the following activities: behaving in a loud or obnoxious manner; disturbing or threatening the rights, comfort, health, safety, or convenience of others (including our agents and employees) in or near the community; disrupting our business operations...” You are allegedly in violation of this provision of your lease because you engaged in and/or allowed guests to engage in disturbing activity on the premises. Specifically, on several occasions you created disturbances in your unit and the common areas which involve violating the community's no- Landlord_awFirm and LLF are registered trademarks of Chesson & Schweickert LLC Z§LLF LandlordLawFirm smoking policy by smoking excessively in your unit and the common areas. This smoke escapes your unit and enters other residents units and common areas severely disturbing other residents. Additionally, you conducted yourselves in a manner involving: creating excessive noise at all hours of the day and night; yelling; engaging in altercations in the common areas; and propping open the main doors to the building to allow unauthorized individuals to come and go freely severely compromising the security of the building and safety of other residents. This disorderly conduct is in direct violation of your lease and No-Smoking Lease Addendum; disrupts your landlords business operations, disturbs your neighbors’ peaceful enjoyment of the premises; interferes substantially with the comfort or safety of other tenants or occupants of the same or adjacent buildings or structures. Section 33. Default By Resident: “Non-monetary Default. You will be in default if you or any guest or occupant violates any other terms of this Lease Contract including but not limited to the following violations: (1) you or any guest or occupant violates the dwelling unit rules, or fire, safety, health, or criminal laws, regardless of whether or where arrest or conviction occurs...(6) you or any guest or occupant engages in any of the prohibited conduct described in Paragraph 21...” You are allegedly in violation of this provision of your lease because you engaged in and/or allowed guests to engage in disturbing activity on the premises. Specifically, on several occasions you created disturbances in your unit and the common areas which involve violating the community's no- smoking policy by smoking excessively in your unit and the common areas. This smoke escapes your unit and enters other residents units and common areas severely disturbing other residents. Additionally, you conducted yourselves in a manner involving: creating excessive noise at all hours of the day and night; yelling; engaging in altercations in the common areas; and propping open the main doors to the building to allow unauthorized individuals to come and go freely severely compromising the security of the building and safety of other residents. This disorderly conduct is in direct violation of your lease and No-Smoking Lease Addendum; disrupts your landlords business operations, disturbs your neighbors’ peaceful enjoyment of the premises; interferes substantially with the comfort or safety of other tenants or occupants of the same or adjacent buildings or structures. LandlordLawFirm and LLF are registered trademarks of Chesson & Schweickert LLC SSLLF LandlordLawFirm E. No-Smoking Addendum: “4. Smoking Anywhere Inside Buildings of the Apartment Community is Strictly Prohibited. All forms and use of burning, lighted, vaporized, or ignited tobacco products and smoking of tobacco products inside any dwelling, building, or interior of any portion of the apartment community is strictly prohibited. Any violation of the no-smoking policy is a material and substantial violation of this Addendum and the Lease Contract. The prohibition on use of any burning, lighted, vaporized, or ignited tobacco products or smoking of any tobacco products extends to all residents, their occupants, guests, invitees and all others who are present on or in any portion of the apartment community. The no- smoking policy and rules extend to, but are not limited to, the management and leasing offices, building interiors and hallways, building common areas, dwelling units, club house, exercise or spa facility, tennis courts, all interior areas of the community, commercial shops, businesses, and spaces, work areas, and all other spaces whether in the interior of the community or in the enclosed spaces on the surrounding community grounds. Smoking of non-tobacco products which are harmful to the health, safety, and welfare of other residents inside any dwelling or building is also prohibited by this addendum and other provisions of the Lease Contract. Smoking Outside Buildings of the Apartment Community. Smoking is permitted only in specially designated areas outside the buildings of the apartment community. Smoking must be at least 25 feet from the buildings in the apartment community, including administrative office buildings. If the previous filed is not completed, smoking is only permitted at least 25 feet from the buildings in the apartment community, including administrative office buildings. The smoking-permissible areas are marked by signage. Smoking on balconies, patios, and limited common areas attached to or outside of your dwelling is not permitted. The following outside areas of the community may be used for smoking: This is a non-smoking community. Smoking is not permitted anywhere on the property. 4 andlordLawFirm and LLF are registered trademarks of Chesson & Schweickert LLC. SSLLF LandlordLawFirm Even though smoking may be permitted in certain limited outside areas, we reserve the right to direct that you and your occupants, family, guests, and invitees cease and desist from smoking in those areas if smoke is entering the dwelling units or buildings or if it is interfering with the health, safety, or welfare or disturbing the quite enjoyment, or business operations of us, other residents or guests. Smoking of Drugs or Other Illegal Substances. The smoking of any illegal or controlled substances, including specifically marijuana (regardless of the legalization or decriminalization of marijuana by local or State law), inside any Dwelling Unit, common area, building, or in any outdoor portion of the apartment community is strictly prohibited by this Addendum and other provisions of the Lease Contract. Lease Contract Termination for Violation of the Addendum. We have the right to terminate your Lease Contract or right of occupancy of the dwelling for any violation of this No-Smoking Addendum. Violation of the no-smoking provisions is a material and substantial default or violation of the Lease Contract... 11 Your Responsibility for Conduct of Occupants, Family Members, and Guests. You are responsible for communicating this community's no-smoking policy and for ensuring compliance with this Addendum by your occupants, family, guests, and invitees.” You are allegedly in violation of each of these provisions of your lease because you engaged in and/or allowed guests to engage in disturbing activity on the premises. Specifically, on several occasions you created disturbances in your unit and the common areas which involve violating the community’s no-smoking policy by smoking excessively in your unit and the common areas. This smoke escapes your unit and enters other residents units and common areas severely disturbing other residents. Additionally, you conducted yourselves in a manner involving: creating excessive noise at all hours of the day and night; yelling; engaging in altercations in the common areas; and propping open the main doors to the building to allow unauthorized individuals to come and go freely severely compromising the security of the building and safety of other residents. This disorderly conduct is in direct violation of your lease and No-Smoking Lease Addendum; disrupts your landlords business operations, disturbs your neighbors’ peaceful 5 LandlordLawFirm and LLF are registered trademarks of Chesson & Schweickert LLC Z§LLF LandlordLawFirm enjoyment of the premises; interferes substantially with the comfort or safety of other tenants or occupants of the same or adjacent buildings or structures. Connecticut General Statutes Section 47a-11(a): “Sec. 47a-11. Tenant's responsibilities. A tenant shall: (a) Comply with all obligations primarily imposed upon tenants by applicable provisions of any building, housing or fire code materially affecting health and safety...” You are allegedly in violation of this provision because you engaged in and/or allowed guests to engage in disturbing activity on the premises. Specifically, on several occasions you created disturbances in your unit and the common areas which involve violating the community's no-smoking policy by smoking excessively in your unit and the common areas. This smoke escapes your unit and enters other residents units and common areas severely disturbing other residents. Additionally, you conducted yourselves in a manner involving: creating excessive noise at all hours of the day and night; yelling; engaging in altercations in the common areas; and propping open the main doors to the building to allow unauthorized individuals to come and go freely severely compromising the security of the building and safety of other residents. This disorderly conduct is in direct violation of your lease and No- Smoking Lease Addendum; disrupts your landlords business operations, disturbs your neighbors’ peaceful enjoyment of the premises; interferes substantially with the comfort or safety of other tenants or occupants of the same or adjacent buildings or structures. Connecticut General Statutes Section 47a-11(g): “Sec. 47a-11. Tenant's responsibilities. A tenant shall: ... (g) conduct himself and require other persons on the premises with his consent to conduct themselves in a manner that will not disturb his neighbors’ peaceful enjoyment of the premises ...” You are allegedly in violation of this provision because you engaged in and/or allowed guests to engage in disturbing activity on the premises. Specifically, on several occasions you created disturbances in your unit and the common areas which involve violating the community’s no-smoking policy by smoking excessively in your unit and the common areas. This smoke escapes your unit and enters other residents units and common areas severely disturbing other residents. Additionally, you conducted yourselves in a manner involving: creating excessive noise at all hours of the day and night; yelling; engaging in altercations in the common areas; and propping open the main 6 LandlordLawFirm and LLF are registered trademarks of Chesson & Schweickert LLC Z§LLF LandlordLawFirm doors to the building to allow unauthorized individuals to come and go freely severely compromising the security of the building and safety of other residents. This disorderly conduct is in direct violation of your lease and No- Smoking Lease Addendum; disrupts your landlords business operations, disturbs your neighbors’ peaceful enjoyment of the premises; interferes substantially with the comfort or safety of other tenants or occupants of the same or adjacent buildings or structures. Connecticut General Statutes Sections 47a-11(g) and 47a-32: “Sec. 47a-11. Tenant's responsibilities. A tenant shall: .... (g) conduct himself and require other persons on the premises with his consent to conduct themselves in a manner that will not ... constitute a nuisance, as defined in section 47a-32 . . .” “Sec. 47a-32. Nuisance defined. In any action of summary process based upon nuisance, that term shall be taken to include, but shall not be limited to, any conduct which interferes substantially with the comfort or safety of other tenants or occupants of the same or adjacent buildings or structures.” You are allegedly in violation of these provisions because you engaged in and/or allowed guests to engage in disturbing activity on the premises. Specifically, on several occasions you created disturbances in your unit and the common areas which involve violating the community's no-smoking policy by smoking excessively in your unit and the common areas. This smoke escapes your unit and enters other residents units and common areas severely disturbing other residents. Additionally, you conducted yourselves in a manner involving: creating excessive noise at all hours of the day and night; yelling; engaging in altercations in the common areas; and propping open the main doors to the building to allow unauthorized individuals to come and go freely severely compromising the security of the building and safety of other residents. This disorderly conduct is in direct violation of your lease and No- Smoking Lease Addendum; disrupts your landlords business operations, disturbs your neighbors’ peaceful enjoyment of the premises; interferes substantially with the comfort or safety of other tenants or occupants of the same or adjacent buildings or structures. 7 LandlordLawFirm and LLF are registered trademarks of Chesson & Schweickert LLC S§LLF LandlordLawFirm i A. Section 6. Rent and Charges: “Unless modified by addenda, you will pay $3,191.00 per month for rent, payable in advance and without demand ...If you don’t pay rent on time, you'll be delinquent and all remedies under this Lease Contract will be authorized...” You are allegedly in violation of this provision of your lease because as of today, your Landlord has not received your full rent payment — your overdue balance is $10,033.40 for the amounts owed through December 2023. You will also owe $3,191.00 rent due for January 2024. Please be advised that your rent payment is due on the 1st of each month, with a grace period until the 10'* — payments received after the 10th are subject to a late fee pursuant to the Lease. Section 32. Default By Resident: “You'll be in default if you or any guest or occupant violates any terms of this Lease Contract including but not limited to the following violations: (1) you don’t pay rent or other amounts that you owe when due...” You are allegedly in violation of this provision of your lease because as of today, your Landlord has not received your full rent payment — your overdue balance is $10,033.40 for the amounts owed through December 2023. You will also owe $3,191.00 rent due for January 2024. Please be advised that your rent payment is due on the 1st of each month, with a grace period until the 10'" — payments received after the 10th are subject to a late fee pursuant to the Lease. I. If the above-noted violations can be and are remedied by repair or payment of damages on your part within fifteen (15) days of this notice, no action will be taken against you based on these violations. If however, the above-noted violations are not remedied within that fifteen (15) day period, your rental agreement shall thereafter terminate upon service of a notice to quit. 8 LandlordLawFirm and LLF are registered trademarks of Chesson & Schweickert LLC — SLLF LandlordLawFirm In the event that judicial proceedings for your eviction are instituted, you will be entitled to present any defense that you may have under the laws of the State of Connecticut. Sincerel ‘obeft W. Chesson, Esq. Attorney for Landlord, JSIP Tannery, LLC cc: Brittany Santana Kamari Dudley Joanne Aviles 9 andlord_LawFirm and LLF are registered trademarks of Chesson & Schweickert LLC eyaKoad ce) a) The State of Connecticut created a You are facing the A Right to Counsel program (CT-RTC) loss of your home to provide free legal representation to income eligible tenants facing or housing subsidy. eviction or loss of housing subsidy. The program began ina few communities on We are here to help. i B: January 31, 2022 and will grow over time. __ __ = aroRataeReltaa iced Clete) asl eee) SVL) NVdateinom COUN INU coeTae ni Motte (UE]nace I| bet :{0 10 Sto yoh' e Ro Ys ROME wa fend (olay aX=vi sXeumee) 34 ne ONLINE LEGAL HELP Go 2-1-1 HELPLINE GUIDE AND FORM FILLER EVICTION PREVENTION FUND Go to cteviction.guide to learn Check your eligibility for UniteCT’s to ctlawhelp.org/eviction to Call 211 for information and learn about the eviction referrals for housing, utility, about the eviction process Eviction Prevention Fund by visiting process and how to respond and food assistance or go to and prepare court forms for unitectprescreen.formstack.com/ 214ctorg. | your case. forms/eviction_prevention to eviction notices. El estado de Connecticut ha creado Usted esta en riesgo el programa “Derecho aun Abogado” WA Cod de) al LA cd de perder su hogar (CT-RTC, por sus siglas en inglés) con el fin de brindar representacién juridica o su subsidio de gratuita a inquilinos de bajos ingresos que corran riesgo de desalojo o pérdida vivienda. Estamos del subsidio de vivienda. Te aqui para ayudarle. El programa comenzé el 31 de enero de 2022 en un numero Elbe limitado de comunidades y continuard expandiéndose. = ae cole aoa Coma =Le O11Cos} PY- Lic] Sicerste niece aac reeset) Uae rec liee Kort Deve MeN ota UE Tec MU veo Ree Reet OreN eure ets 01) ers lo dh oeh bo So ROMUEL Cwrarenake)alatsy i ove ece) a4 = = = | LINEA DE ASISTENCIA 2-1-1 GUIA PARA COMPLETAR FONDO PREVENTIVO ASISTENCIA LEGAL Para informacion y FORMULARIOS DE DESALOJOS PORINTERNET Para verificar si rene los Visite ctlawhelp.org/eviction derivaciones a programas Visite cteviction.guide para | obtener informacién sobre el requisitos para recibir asistencia para obtener informacidn sobre de asistencia con el alquiler, del Fondo Preventivo de el proceso de desalojo y como servicios publicos y alimentos, proceso de desalojo y como. Desalojos de UniteCT, visite responder a una notificacion lame al 211 or visite 214ct.org. completar los formularios unitectprescreen.formstack.com/ de desalojo. judiciales. forms/eviction_prevention NAUK SCs Ca Cee a Lg Tattle Ela celn: oneAe ky ae MORE cM Pama Ln STATE OF CONNECTICUT} } SS: GLASTONBURY, DECEMBER 29 2023 COUNTY OF HARTFORD } Then and by virtue hereof, on the 29" day of December, 2023, I left a verified true and attested copy of the within original Pretermination Notice, and Right to Counsel Flyer in English and Spanish, at the usual place of abode of the within named tenant, PATRICK QUINN, at 3102 Flanagan Drive, in the Town of Glastonbury. Also on the 29" day of December, 2023, I left a verified true and attested copy of the within original Pretermination Notice, and Right to Counsel Flyer in English and Spanish, at the usual place of abode of the within named tenant, ANGELA QUINN, at 3102 Flanagan Drive, in the Town of Glastonbury. The within is the original Pretermination Notice, and Right to Counsel Flyer in English and Spanish, with my doings hereon endorsed. FEES: $ 50.00 ATTEST J. RODRIGUEZ STATE MARSHAL HARTFORDYCOUNTY TO: Patrick Quinn Angela Quinn 3102 Flanagan Drive Glastonbury, CT 06033 PLEASE TAKE NOTICE that you are to QUIT POSSESSION and occupancy of the premises now occupied by you, consisting of 3102 Flanagan Drive, Glastonbury, CT 06033 on or before February 23, 2024, pursuant to the statute in such cases made and provided, for the following reasons: 1. Violation of Lease — Sections 19; 20; 21; 33; and (No-Smoking Addendum — Sections: 4, 5, 6, 9, and 11) — You have violated each of these provisions of your lease because you engaged in and/or allowed guests to engage in disturbing activity on the premises. Specifically, on several occasions you created disturbances in your unit and the common areas which involve violating the community's no-smoking policy by smoking excessively in your unit and the common areas. This smoke escapes your unit and enters other residents units and common areas severely disturbing other residents. Additionally, you conducted yourselves in a manner involving: creating excessive noise at all hours of the day and night; yelling; engaging in altercations in the common areas; and propping open the main doors to the building to allow unauthorized individuals to come and go freely severely compromising the security of the building and safety of other residents. This disorderly conduct is in direct violation of your lease and No-Smoking Lease Addendum; disrupts your See landlords business operations, disturbs your neighbors’ peaceful enjoyment of the premises; interferes substantially with the comfort or safety of other tenants or occupants of the same or adjacent buildings or structures; or 2. Violation of Connecticut General Statutes Section 47a-11(a). You have violated this provision because you engaged in and/or allowed guests to engage in disturbing activity on the premises. Specifically, on several occasions you created disturbances in your unit and the common areas which involve violating the community's no-smoking policy by smoking excessively in your unit and the common areas. This smoke escapes your unit and enters other residents units and common areas severely disturbing other residents. Additionally, you conducted yourselves in a manner involving: creating excessive noise at all hours of the day and night; yelling; engaging in altercations in the common areas; and propping open the main doors to the building to allow unauthorized individuals to come and go freely severely compromising the security of the building and safety of other residents. This disorderly conduct is in direct violation of your lease and No-Smoking Lease Addendum; disrupts your landlords business operations, disturbs your neighbors’ peaceful enjoyment of the premises; interferes substantially with the comfort or safety of other tenants or occupants of the same or adjacent buildings or structures; or 3. Violation of Connecticut General Statutes Section 47a-11(g). You have violated this provision because you engaged in and/or allowed guests to engage in disturbing activity on the premises. Specifically, on several occasions you created disturbances in your unit and the common areas which involve violating the community's no-smoking policy by smoking excessively in your unit and the common areas. This smoke escapes your unit and enters other residents units and common areas severely disturbing other residents. Additionally, you conducted yourselves in a manner involving: creating excessive noise at all hours of the day and night; yelling; engaging in altercations in the common areas; and propping open the main doors to the building to allow unauthorized individuals to come and go freely severely compromising the security of the building and safety of other residents. This disorderly conduct is in direct violation of your lease and No-Smoking Lease Addendum; disrupts your landlords business operations, disturbs your neighbors’ peaceful enjoyment of the premises; interferes substantially with the comfort or safety of other tenants or occupants of the same or adjacent buildings or structures; or 4. Nuisance, in violation of Connecticut General Statutes Sections 47a-11(g) and 47a- 32. You have violated these provisions because you engaged in and/or allowed guests to engage in disturbing activity on the premises. Specifically, on several occasions you created disturbances in your unit and the common areas which involve violating the community’s no- smoking policy by smoking excessively in your unit and the common areas. This smoke escapes your unit and enters other residents units and common areas severely disturbing other residents. Additionally, you conducted yourselves in a manner involving: creating excessive noise at all hours of the day and night; yelling; engaging in altercations in the common areas; and propping open the main doors to the building to allow unauthorized individuals to come and go freely severely compromising the security of the building and safety of other residents. This disorderly conduct is in direct violation of your lease and No-Smoking Lease Addendum; disrupts your landlords business operations, disturbs your neighbors’ peaceful enjoyment of the premises; interferes substantially with the comfort or safety of other tenants or occupants of the same or adjacent buildings or structures; or 5. Non-payment of Rent. ANY PAYMENTS TENDERED AFTER SERVICE OF THE NOTICE TO QUIT WILL BE ACCEPTED FOR REIMBURSEMENT OF COSTS AND FOR USE AND OCCUPANCY ONLY, AND NOT FOR RENT, WITH FULL RESERVATION OF RIGHTS TO CONTINUE WITH THE EVICTION ACTION. DATED at Milford, Connecticut, this day, Thursday, January 18, 2024. JSIP Tannery, LLC By: Robert W. Chesson, Esq. G. Adam Schweickert, Esq. Jeff M. Mastrianni, Esq. Chesson & Schweickert LLC 215 Broad Street Milford, CT 06460 Tel.: 203-874-4747 Juris No. 423788 THEIR ATTORNEY 3113-0010 The State of Connecticut created a eared ded) You are facing the 4 Ac Right to Counsel program (CT-RTC) loss of your home to provide free legal representation to income eligible tenants facing or housing subsidy. | eviction or loss of housing subsidy. | The program began ina few communities on Es Cr] We are here to help. January 31, 2022 and will grow over time. os aos CM ete cc Niiatcla-m COUN IN ORIN M LE Bohai a icy Creel Mas deere te al at=yr| xeumco) a4 WieNU oUFIn VacerI bet sX0\0 eto doh om Bol So Nels waae) — 2-1-4 HELPLINE GUIDE AND FORM FILLER EVICTION PREVENTION FUND ONLINE LEGAL HELP Go to ctlawhelp.org/eviction to Call 211 for information and Go to cteviction.guide to learn Check your eligibility for UniteCT’s learn about the eviction referrals for housing, utility, about the eviction process Eviction Prevention Fund by visiting and food assistance or go to and prepare court forms for unitectprescreen.formstack.com/ process and how to respond forms/eviction_prevention to eviction notices. 21ictorg. your case. El estado de Connecticut ha creado Usted esta en riesgo el programa “Derecho a un Abogado” read eda} de perder su hogar (CT-RTC, por sus siglas en inglés) con el a o su subsidio de fin de brindar representaci6n juridica gratuita a inquilinos de bajos ingresos que corran riesgo de desalojo o pérdida vivienda. Estamos del subsidio de vivienda. aqui para ayudarle. El programa comenz6 el 31 de enero de 2022 en un numero Dl Tak limitado de comunidades y continuard expandiéndose. es aes | | ___ Le Kok tec petrelce Te Ns (age Te-Tn reel) Pl etatel Pree a UCase helene oaacle (elke) 1K} eee Poets Seesis knee Meller aE Br: Yo\ 0 eho} oi: on Pa Soper eke NA Cel Ue) LL AN=) | 8x94 ol 6 ==