Preview
JD-CV-103 Rev. 7-09 Ko
YOU ARE BEING SUED
Cu, ew
AND YOU ARE IN DANGER OF LOSING YOUR PROPERTY
The Connecticut Superior Court requires that this notice be sent to you about the residential foreclosure process
This is not legal advice. Please read it carefully
Itis important that you learn about your options in foreclosure. There are government agencies, legal aid
programs and other non-profit organizations that you may call for information about foreclosure
To protect your rights, you should speak to an attorney or go to the foreclosure clerk, foreclosure caseflow
coordinator or Court Service Center in the Court where your case was filed for information on what to do next.
If you do not take action, you could lose your property.
If you do not file an Appearance form with the Court, you will not get important notices about your case
AND the Court may make a decision (enter a default judgment) against you. File the Appearance form at the
Court where your case is pending.
You should also work with your lender or other person bringing this lawsuit or, if this foreclosure involves your
home, to contact a HUD-certified housing counselor during this process
If this foreclosure involves your home, you may be eligible for the Foreclosure
Mediation program. Information about the program is attached to these papers
and is also available at any Superior Court Judicial District courthouse or on the
court's website at www.jud.ct.gov. To locate assistance near you, you may call
the Connecticut Housing Finance Authority's call center toll free at
1-877-571-2432. Customer Service Representatives are available Monday
through Friday from 8:30 a.m. to 5:00 p.m. You may also call 2-1-1 for other help.
PROCEED WITH CAUTION
You may be contacted by people offering to help you avoid foreclosure. Please follow these precautions:
1 Get legal advice before entering into any deal involving your house.
2: Get legal advice before paying any money to anyone offering to help you avoid foreclosure.
3. Do not sign any papers you do not understand
READ THE PAPERS UNDER THIS NOTICE
APPEARANCE This form is available STATE OF CONNECTICUT
JD-CL-12 Rev. 12-21 in other language(s).
P.B. §§ 3-1 through 3-12, 10-13, 25-64, 252-2, 254-3 SUPERIOR COURT
www jud.ct gov
y
feo?
There are instructions and important notices on page 2 (the back) of this form.
Read page 2 before filling out this form. Reium date (For CivilFamily cases)
/am filing this appearance to let the court and all attorneys and self-represented
Oo parties of record know that | have changed my address. My new address is below.
Docket Number
Name of case (Full name of frst Plaintiff v. Full name of first Defendant) Note: In Criminal/Motor Vehicles cases, the Plaintiffis The State of Connecticut
‘Address of court (Number, street, town and zip code) ‘Scheduled court date (Criminal/Motor Vehicle cases only)
Housing Judicial Geographic
Session District Area
———— Enter the Appearance of
Name (Your name or name of official, firm, professional corporation, or individual aitorney) Juris number (For attorneyAaw fim)
Mailing address Post Office box number Telephone number (Area code first)
Citykown State Zip code Fax number E-mail address
in the case named above for: (Select one of the following parties. See descriptions/notes on page 2 of this form.)
PLAINTIFF DEFENDANT
C The Plaintiff. ([] The Defendant.
[J All Plaintiffs. {_] All Defendants.
[J The following Plaintiff(s) only: {_] The following Defendant(s) only:
(J Other (Specify):
LJ This is a Family Matters case (such as divorce, custody, or child support). My appearance is for (Select one or both)
(LD matters in the Family Division of the Superior Court (J Title 1\V-D Child Support matters
CU This is a Criminal/Motor Vehicle case, and | am filing this appearance as [_] a Public Defender or [] Assigned Counsel
LJ This appearance is for the purpose of a bail hearing only. (Special Public Defender)
LJ This appearance is for the purpose of alternative arraignment proceedings only
If an appearance by other counsel or self-represented party is on file for this party/parties, select one option below:
1. [J This appearance is in place of the appearance of:
Name and Juris Number (iF applicable) to be replaced
2. [_] This appearance is in addition to an appearance already on file.
! agree that documents can be delivered (served) to me electronically in this case. (Practice Book Sec. 10-13) [] Yes [No
Signed (Individual attomey or sel-represented party) Name of person signing at left (Print or type) Date signed
=
Certification FOR COURT USE ONLY
| certify that a copy of this document was or will immediately be mailed or delivered electronically or
non-electronically on (date) to all attorneys and self-represented parties of
record and that written consent for electronic delivery was received from all attorneys and self-
represented parties of record who received or will immediately be receiving electronic delivery
Name and address of each party and attorney that copy was or will be mailed or delivered to”
“ifnecessary, attach additional sheet or sheets with name and address which the copy was or will be mailed or delivered to
Signed (Signature of filer) Print or type name of person signing Date signed
Page 1 of 2
Instructions
Do not use this form for Juvenile cases.
1. Type or print clearly in dark ink.
2. Fill out page 1, including the Certification section at the bottom.
3. Make a copy of the completed form and keep it for your records.
4, File your completed form with the court clerk.
5. For Criminal and Motor Vehicle cases: Mail or deliver a copy of the appearance to the prosecutor.
For all other cases: Mail or deliver a copy to all counsel and self-represented parties of record.
Notice for Civil cases, including Housing Matters and Small Claims
Ifa party who has been defaulted for failure to appear files an appearance before the entry of judgment after default, the default will
automatically be set aside by the clerk.
Notice to people representing themselves
People who represent themselves in court are called self-represented parties.
Self-represented parties: Which party do | select on page 1?
You are a plaintiff if.
+ You filed this court case to sue someone.
+ You are the one who started this court case.
+ Your name is listed before the "in the name of case on court documents
If you are the ONLY plaintiff, select "The Plaintiff".
If there is more than one plaintiff, select "The following Plaintiff(s) only" and write your name on the line.
You are a defendant if..
* This is a criminal or motor vehicle case.
+ You are being sued
» Your name is listed after the "in the name of case on court documents.
+ Your landlord started this case to evict you.
+ You were served with the court papers at the beginning of this case.
If you are the ONLY defendant select "The Defendant”.
If there is more than one defendant, select "The following Defendant(s) only" and write your name on the line.
Select Other...
+ If you and your spouse filed a nonadversarial divorce, select "Other" and write if you are Petitioner A or Petitioner B on the line
+ Ifyou asked the court to let you intervene and you are listed as an intervenor, select "Other" and then describe who you are.
+ Ifyou are listed as a party to the case for some other reason, select "Other" and write who you are in the case on the line
Self-represented parties in Family Matters: Filing “in addition to” an attorney (dual representation)
If you are a self-represented party who is filing an appearance “in addition to” an attorney who already has an appearance in this
court case, be aware of the following:
+ Any document being filed on your behalf must be signed by your attorney pursuant to Practice Book Section 4-2.
+ Ifa document being filed on your behalf is not signed by your attorney, the court may order that the matter be stayed (delayed)
until the attorney adopts the document.
* If you inform the court that there is no attorney actively representing you, the court may delay the matter until you file a new
appearance “in place of” your attorney(s).
+ If your attorney does not adopt your motion and the motion is not disposed of or withdrawn:
+ You are responsible for prosecuting or litigating that motion
+ An attorney for any other party on the case may contact you directly with respect to the subject matter of that motion.
+ If multiple motions are scheduled for hearing at the same time, one or more of which have been adopted by your attorney and
one or more of which have not, it is up to the court how to proceed
* If you file any other document that is not signed by your attorney, it is up to the court how the document will be treated
Self-represented parties: Address changes
Ifyou are a self-represented party, you must give notice if your mailing address changes after you file an appearance
You must tell the court and all attorneys and self-represented parties of record your new mailing address by filling out another
appearance. Select the box at the top of page 1 of this form and fill out the rest of page 1 using your new mailing address.
Notice to attorneys/law firms
1. Except as noted below, if you are an attorney, you are not exempt from e-filing, and the file in this case is electronic, do not use
this form, File your appearance in the E-filing system
2. Notices from the court will be mailed to the address associated with your Juris Number. You cannot use this form to have the
court mail notices to a different address
3. If you are an attorney admitted pro hac vice or filing on behalf of a non-party, you must file this form on paper with the clerk.
ADA NOTICE
The Judicial Branch of the State of Connecticut complies with the Americans with
Disabilities Act (ADA). If you need a reasonable accommodation in accordance with
the ADA, contact a court clerk or an ADA contact person listed at www.jud.ct.gov/ADA.
Page 2 of 2
RETURN DATE: 4/30/2024 SUPERIOR COURT
CITY OF MIDDLETOWN JUDICIAL DISTRICT OF
MIDDLESEX
VS. AT MIDDLETOWN
KIM E. MICHALSKY MARCH 22, 2024
COMPLAINT
FIRST COUNT: (Real Estate Taxes on List of October 2019)
4
On October 1, 2019, the defendant, KIM E. MICHALSKY, was the
Record owner of real estate known as 39 Little River Lane, Middletown,
Connecticut more particularly described in Exhibit A attached hereto and made
a part hereof (the “Premises’).
2. Atax amount in the amount of $2,195.86 was duly and properly
assessed by the plaintiff, City of Middletown (hereinafter “plaintiff’) upon the
Premises, and on July 1, 2020 and January 1, 2021, the tax became due and
payable, and is a lien on the Premises.
3 No portion (or an insufficient portion) of the tax has been paid.
4 The plaintiff duly and properly filed and caused to be recorded in
the Middletown Land Records a certificate of lien for the tax, with interest, fees
and charges thereon which tax liens were recorded in Volume 2006 at Page 990
of the Middletown Land Records.
5 The defendant, KIM E. MICHALSKY is the record owner of the
premises.
Cohen, Burns, Hard & Paul
Attorneys At Law
81 South Main Street, West Hartford CT 06107 - (860)561-4961 Juris#402625
SECOND COUNT: (Real Estate Taxes on List of October 2020)
1 On October 1, 2020, the defendant, KIM E. MICHALSKY, was the
Record owner of real estate known as 39 Little River Lane, Middletown,
Connecticut more particularly described in Exhibit A attached hereto and made
a part nereot (the “Premises ).
2 A tax amount in the amount of $4,371.86 was duly and properly
assessed by the plaintiff, City of Middletown (hereinafter “plaintiff’) upon the
Premises, and on July 1, 2021 and January 1, 2022, the tax became due and
payable, and is a lien on the Premises.
3. No portion (or an insufficient portion) of the tax has been paid.
4 The plaintiff duly and properly filed and caused to be recorded in
the Middletown Land Records a certificate of lien for the tax, with interest, fees
and charges thereon which tax liens were recorded in Volume 2046 at Page 726
of the Middletown Land Records.
5 Paragraph five of the first count is hereby realleged as if more fully
set forth hereinafter.
THIRD COUNT: (Real Estate Taxes on List of October 2021)
1 On October 1, 2021, the defendant, KIM E. MICHALSKY, was the
Record owner of real estate known as 39 Little River Lane, Middletown,
Connecticut more particularly described in Exhibit A attached hereto and made
a part hereof (the “Premises”.
Cohen, Burns, Hard & Paul
Attorney At Law
81 South Main Street, West Hartford CT 06107 - (860)561-4961 Juris#402625
2 A tax amount in the amount of $4,371.86 was duly and properly
assessed by the plaintiff, City of Middletown (hereinafter “plaintiff’) upon the
Premises, and on July 1, 2022 and January 1, 2024 the tax became due and
Payable, and is a lien on the premises.
3 No portion (or an insufficient portion) of the tax has been paid.
4 The plaintiff duly and properly filed and caused to be recorded in
the Middletown Land Records a certificate of lien for the tax, with interest, fees
and charges thereon which tax liens were recorded in Volume 2072 at Page 690
of the Middletown Land Records.
5 Paragraph five of the first count is hereby realleged as if more fully
set forth hereinafter.
FOURTH COUNT:
1. Atall times mentioned herein the defendant, KIM E. MICHALSKY,
was the Record owner of real estate known as 39 Little River Lane,
Middletown, Connecticut more particularly described in Exhibit A attached
hereto and made a part hereof (the “Premises”).
2. Water liens in the following amounts were duly and properly assessed,
with interest fees and charges thereon, by the plaintiff:
a. Dated October 17, 2018 and recorded October 30, 2018 in the amount
of $49.63 in Volume 1931 at Page 388 of the Middletown Land Records;
b. Dated February 24, 2021 and recorded February 26, 2021 in the
amount of $51.75 in Volume 1997 at Page 411 of the Middletown Land Records;
Cohen, Burns, Hard & Paul
Attornegs At Law
81 South Main Street, West Hartford CT 06107 - (860)561-4961 Juris#402625
c. Dated October 15, 2021 and recorded October 25, 2021 in the amount
of $54.77 in Volume 2025 at Page 390 of the Middletown Land Records;
d. Dated July 7, 2022 and recorded April 21, 2022 in the amount of
$106.52 in Volume 2043 at Page 491 of the Middletown Land Records;
e. Dated April 14, 2022 and recorded April 26, 2022 in the amount of
$54.77 in Volume 2043 at Page 906 of the Middletown Land Records;
f Dated March 22, 2023 and recorded March 24, 2023 in the amount of
$54.77 in Volume 2068 at Page 978 of the Middletown Land Records;
g. Dated September 18, 2023 and recorded September 22, 2023 in the
amount of $54.77 in Volume 2081 at Page 941 of the Middletown Land Records;
3. No portion (or an insufficient portion) of the sums due thereunder
has been paid.
4 Paragraph five of the first count is hereby realleged as if more fully
set forth hereinafter.
FIFTH COUNT:
1. Atall times mentioned herein the defendant, KIM E. MICHALSKY,
was the Record owner of real estate known as 39 Little River Lane,
Middletown, Connecticut more particularly described in Exhibit A attached
hereto and made a part hereof (the “Premises’).
2. Sewer liens in the following amounts were duly and properly assessed,
with interest fees and charges thereon, by the plaintiff:
Cohen, Burns, Hard & Paul
Attorneyb At Law
81 South Main Street, West Hartford CT 06107 - (860)561-4961 Juris#402625
a. Dated October 17, 2018 and recorded October 30, 2018 in the amount
of $39.68 in Volume 1931 at Page 448 of the Middletown Land Records;
b. Dated October 15, 2020 and recorded October 21, 2020 in the amount
of $48.00 in Volume 1983 at Page 525 of the Middletown Land Records;
c. Dated February 24, 2021 and recorded March 1, 2021 in the
amount of $57.09 in Volume 1997 at Page 534 of the Middletown Land Records;
d. Dated October 15, 2021 and recorded October 27, 2021 in the amount
of $64.66 in Volume 2025 at Page 725 of the Middletown Land Records;
e. Dated April 7, 2022 and recorded April 19, 2022 in the amount of
$169.75 in Volume 2043 at Page 218 of the Middletown Land Records;
ft Dated April 14, 2022 and recorded April 27, 2022 in the amount of
$64.66 in Volume 2044 at Page 111 of the Middletown Land Records;
g. Dated March 22, 2023 and recorded March 30, 2023 in the amount of
$64.66 in Volume 2069 at Page 474 of the Middletown Land Records;
h. Dated September 18, 2023 and recorded September 20, 2023 in the
amount of $64.66 in Volume 2081 at Page 609 of the Middletown Land Records;
3. No portion (or an insufficient portion) of the sums due thereunder
has been paid.
4 Paragraph five of the first count is hereby realleged as if more fully
set forth hereinafter.
Cohen, Burns, Hard & Paul
Attorneys At Law
81 South Main Street, West Hartford CT 06107 - (860)561-4961 Juris#402625
WHEREFORE, plaintiff claims:
1 Foreclosure of the respective liens;
Immediate possession of the premises;
A deficiency judgment against the defendant, KIM E. MICHALSKY
Mme appointment of areceiver to collect the rents and
profits accruing from the premises.
Such other and further equitable relief as may be
required.
Interest, costs and reasonable attorney’s fees;
Money damages
PLAINTIFF,
By: Ly
Eric Hard, Esq.
Cohen, Burns, Hard & Paul
81 South Main Street
West Hartford, CT 06107
Tel: (860) 561-1036
Fax: (860) 247-2126
Juris No. 402625
Its Attorneys
Cohen, Burns, Hard & Paul
Attorneys At Law
81 South Main Street, West Hartford CT 06107 - (860)561-4961 Juris#402625
RETURN DATE: 4/30/2024 SUPERIOR COURT
CITY OF MIDDLETOWN JUDICIAL DISTRICT OF
MIDDLESEX
VS. AT MIDDLETOWN
KIM E. MICHALSKY MARCH 22, 2024
STATEMENT OF AMOUNT IN DEMAND
The amount, legal interest and property in demand is greater than
$2,500.00 exclusive of interest and costs.
PLAINTIFF, _—
ff
By:
Eric Hard, Esq.
Cohen, Burns, Hard & Paul
81 South Main Street
West Hartford, CT 06107
Tel: (860) 561-1036
Fax: (860) 247-2126
Juris No. 402625
Its Attorneys
Cohen, Burns, Hard & Paul
Attorneys At Law
81 South Main Street, West Hartford CT 06107 - (860)561-4961 Juris#402625
PLEASE RETURN RECORDED DOCUMENT TO:
COHEN, BURNS, HARD & PAUL
mu na NM
%2093 292-994
81 SOUTH MAIN STREET
WEST HARTFORD, CT 06107
RETURN DATE: 4/30/2024 SUPERIOR COURT
CITY OF MIDDLETOWN JUDICIAL DISTRICT OF
MIDDLESEX
VS. AT MIDDLETOWN
KIM E. MICHALSKY MARCH 18, 2024
MERS, INC.
SECETARY OF HOUSING AND URBAN DEVELOPMENT.
LIS_PENDENS
TO WHOM IT MAY CONCERN, TAKE NOTICE, that an action has this
day been brought to the SUPERIOR COURT to be held in the Judicial District of
Middlesex on APRIL 30, 2024, in which THE CITY OF MIDDLETOWN is the
plaintiff, and KIM E. MICHALSKY is the defendant.
The purpose of this action is to foreclose municipal liens for real estate,
water and sewer on property owned by the defendant, KIM E. MICHALSKY as
follows:
Real Estate Tax Liens to the City of Middletown as follows:
List Volume Page Amount Date Date Recorded
10/1/2019 2006 990 $2,195.86 5/12/2021 5/17/2024
10/1/2020 2046 726 4,371.86 5/10/2022 5/24/2022
10/1/2021 2072 630 4,371.86 5/3/2023 5/11/2023
Water Liens to the City of Middletown as follows:
Volume Page Amount Date Date Recorded
1931 388 $ 49.63 10/17/2018 10/30/2018
1997 41. 51.75 2/24/2021 2/26/2021,
2025 390 54.77 10/15/2021 10/25/2021
2043 491 106.52 7/7/2022 4/21/2022
2043 906 54.77 4/14/2022 4/26/2022
2068 978 54.77 3/22/2023 3/24/2023
2081 941 54.77 9/18/2023 9/22/2023
hake
|WASHLEY A. FLYNN-NATALE, TOWN CLERK OF SAID MIDDLETOWN,
AND CUSTODIAN OF THE RECORDS, Of, HEREBY
CERTIFY THAT THE FORGOING _L\ H
TRUE AND CORRECT COPY FR
ae tay ae PAGE. way
IN THE MIDDLETOWN LAND RECORDS,
IN WITNESS WHEREOR, | H AVE i FAR UNTO SET MY HA ND. ae MF
‘THE SEAL OF MY OFFICE THIS DAY OF
ATTEST: Y
CITY AND TOWN GLERKI MIDDLETOWN, CT
Sewer Liens to the City of Middletown as follows:
Volume Page Amount Date Date Recorded
1931 448 $ 39.68 10/17/2018 10/30/2018
1983, 525 48.00 10/15/2020 10/21/2020
1997 534 57.09 2/24/2021 3/1/2021
2025 725 64.66 10/15/2021 10/27/2021
2043 218 169.75 4/7/2022 4/19/2022
2044 111 64.66 4/14/2022 4/27/2022
2069 474 64.66 3/22/2023 3/30/2023
2081 609 64.66 9/18/2023 9/20/2023
In such action the following relief is claimed:
1.) A foreclosure of said liens;
2.) Immediate possession of the premises;
3.) A deficiency judgment against the defendant(s);
4.) Such other and further equitable relief as may be required; and,
5.) Money damages.
The property affected by said liens is known as 39 Little River Lane,
MIDDLETOWN, CONNECTICUT 06457 recorded in the Middletown Land
Records as more particularly described in Schedule A attached hereto and
incorporated herein.
Dated at West Hartford, Connecticut this 18th day of March 2024.
PLAINTIFF,
By:se
Eric
COHEN, BURNS, HARD & PAUL
81 SOUTH MAIN STREET
WEST HARTFORD, CT 06107
JURIS NO. 402625
TEL: (860) 561-1036
FAX: (860) 247-2126
Its Attorneys
E-mail: ehard@cbhplaw.com
SCHEDULE A
PROPERTY DESCRIPTION
a
a certain piece or parcel of land known as 36 Little River Drive, Middletown,
Connecticut which property is more particularly bounded and described as follows:
A certain piece or parcel of land, together with all buildings, improvements and appurtenances thereof,
situated in the Town of Middletown, County of Middlesex and State of Connecticut, and being Lot No.9
in Section 111 on e map entitled; “Achenbach Realty Companies, Brookside Lane, Essex, Conn. 06426,
Subdivision Map of the Farms At ‘Westlake’, Residential Cluster No, 2~ Sections J, J1, & 111 Portion
of Property of George J. Achenbach, Eust Street, Middletown, Conn., Scale 1” 2 50°, Sheet | of 1, Date
May 18, 1973, Drawing B-1, Raymond V, Kotowski, Civil Engineer”, and on file at the Middletown
‘Town Clerk's Office and listed as Map No. 3132 therein. Said premises are more particularly bounded
and described as follows:
NORTHERLY - dy land now or formerly of V.Scaroza, 59.79 feet;
EASTERLY - by Lot No. 10, as shown on said map, 103.54 feet;
SOUTHERLY - by Little River Lane, 56,22 feet; and
WESTERLY - by Lot No, 8, as shown on said map, 102,50 feet,
Receive
” 09/18/2094 pea
llldletoivn CT
SP pron Peete,
Preview
JD-CV-103 Rev. 7-09 Ko YOU ARE BEING SUED Cu, ew AND YOU ARE IN DANGER OF LOSING YOUR PROPERTY The Connecticut Superior Court requires that this notice be sent to you about the residential foreclosure process This is not legal advice. Please read it carefully Itis important that you learn about your options in foreclosure. There are government agencies, legal aid programs and other non-profit organizations that you may call for information about foreclosure To protect your rights, you should speak to an attorney or go to the foreclosure clerk, foreclosure caseflow coordinator or Court Service Center in the Court where your case was filed for information on what to do next. If you do not take action, you could lose your property. If you do not file an Appearance form with the Court, you will not get important notices about your case AND the Court may make a decision (enter a default judgment) against you. File the Appearance form at the Court where your case is pending. You should also work with your lender or other person bringing this lawsuit or, if this foreclosure involves your home, to contact a HUD-certified housing counselor during this process If this foreclosure involves your home, you may be eligible for the Foreclosure Mediation program. Information about the program is attached to these papers and is also available at any Superior Court Judicial District courthouse or on the court's website at www.jud.ct.gov. To locate assistance near you, you may call the Connecticut Housing Finance Authority's call center toll free at 1-877-571-2432. Customer Service Representatives are available Monday through Friday from 8:30 a.m. to 5:00 p.m. You may also call 2-1-1 for other help. PROCEED WITH CAUTION You may be contacted by people offering to help you avoid foreclosure. Please follow these precautions: 1 Get legal advice before entering into any deal involving your house. 2: Get legal advice before paying any money to anyone offering to help you avoid foreclosure. 3. Do not sign any papers you do not understand READ THE PAPERS UNDER THIS NOTICE APPEARANCE This form is available STATE OF CONNECTICUT JD-CL-12 Rev. 12-21 in other language(s). P.B. §§ 3-1 through 3-12, 10-13, 25-64, 252-2, 254-3 SUPERIOR COURT www jud.ct gov y feo? There are instructions and important notices on page 2 (the back) of this form. Read page 2 before filling out this form. Reium date (For CivilFamily cases) /am filing this appearance to let the court and all attorneys and self-represented Oo parties of record know that | have changed my address. My new address is below. Docket Number Name of case (Full name of frst Plaintiff v. Full name of first Defendant) Note: In Criminal/Motor Vehicles cases, the Plaintiffis The State of Connecticut ‘Address of court (Number, street, town and zip code) ‘Scheduled court date (Criminal/Motor Vehicle cases only) Housing Judicial Geographic Session District Area ———— Enter the Appearance of Name (Your name or name of official, firm, professional corporation, or individual aitorney) Juris number (For attorneyAaw fim) Mailing address Post Office box number Telephone number (Area code first) Citykown State Zip code Fax number E-mail address in the case named above for: (Select one of the following parties. See descriptions/notes on page 2 of this form.) PLAINTIFF DEFENDANT C The Plaintiff. ([] The Defendant. [J All Plaintiffs. {_] All Defendants. [J The following Plaintiff(s) only: {_] The following Defendant(s) only: (J Other (Specify): LJ This is a Family Matters case (such as divorce, custody, or child support). My appearance is for (Select one or both) (LD matters in the Family Division of the Superior Court (J Title 1\V-D Child Support matters CU This is a Criminal/Motor Vehicle case, and | am filing this appearance as [_] a Public Defender or [] Assigned Counsel LJ This appearance is for the purpose of a bail hearing only. (Special Public Defender) LJ This appearance is for the purpose of alternative arraignment proceedings only If an appearance by other counsel or self-represented party is on file for this party/parties, select one option below: 1. [J This appearance is in place of the appearance of: Name and Juris Number (iF applicable) to be replaced 2. [_] This appearance is in addition to an appearance already on file. ! agree that documents can be delivered (served) to me electronically in this case. (Practice Book Sec. 10-13) [] Yes [No Signed (Individual attomey or sel-represented party) Name of person signing at left (Print or type) Date signed = Certification FOR COURT USE ONLY | certify that a copy of this document was or will immediately be mailed or delivered electronically or non-electronically on (date) to all attorneys and self-represented parties of record and that written consent for electronic delivery was received from all attorneys and self- represented parties of record who received or will immediately be receiving electronic delivery Name and address of each party and attorney that copy was or will be mailed or delivered to” “ifnecessary, attach additional sheet or sheets with name and address which the copy was or will be mailed or delivered to Signed (Signature of filer) Print or type name of person signing Date signed Page 1 of 2 Instructions Do not use this form for Juvenile cases. 1. Type or print clearly in dark ink. 2. Fill out page 1, including the Certification section at the bottom. 3. Make a copy of the completed form and keep it for your records. 4, File your completed form with the court clerk. 5. For Criminal and Motor Vehicle cases: Mail or deliver a copy of the appearance to the prosecutor. For all other cases: Mail or deliver a copy to all counsel and self-represented parties of record. Notice for Civil cases, including Housing Matters and Small Claims Ifa party who has been defaulted for failure to appear files an appearance before the entry of judgment after default, the default will automatically be set aside by the clerk. Notice to people representing themselves People who represent themselves in court are called self-represented parties. Self-represented parties: Which party do | select on page 1? You are a plaintiff if. + You filed this court case to sue someone. + You are the one who started this court case. + Your name is listed before the "in the name of case on court documents If you are the ONLY plaintiff, select "The Plaintiff". If there is more than one plaintiff, select "The following Plaintiff(s) only" and write your name on the line. You are a defendant if.. * This is a criminal or motor vehicle case. + You are being sued » Your name is listed after the "in the name of case on court documents. + Your landlord started this case to evict you. + You were served with the court papers at the beginning of this case. If you are the ONLY defendant select "The Defendant”. If there is more than one defendant, select "The following Defendant(s) only" and write your name on the line. 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Select the box at the top of page 1 of this form and fill out the rest of page 1 using your new mailing address. Notice to attorneys/law firms 1. Except as noted below, if you are an attorney, you are not exempt from e-filing, and the file in this case is electronic, do not use this form, File your appearance in the E-filing system 2. Notices from the court will be mailed to the address associated with your Juris Number. You cannot use this form to have the court mail notices to a different address 3. If you are an attorney admitted pro hac vice or filing on behalf of a non-party, you must file this form on paper with the clerk. ADA NOTICE The Judicial Branch of the State of Connecticut complies with the Americans with Disabilities Act (ADA). If you need a reasonable accommodation in accordance with the ADA, contact a court clerk or an ADA contact person listed at www.jud.ct.gov/ADA. Page 2 of 2 RETURN DATE: 4/30/2024 SUPERIOR COURT CITY OF MIDDLETOWN JUDICIAL DISTRICT OF MIDDLESEX VS. AT MIDDLETOWN KIM E. MICHALSKY MARCH 22, 2024 COMPLAINT FIRST COUNT: (Real Estate Taxes on List of October 2019) 4 On October 1, 2019, the defendant, KIM E. MICHALSKY, was the Record owner of real estate known as 39 Little River Lane, Middletown, Connecticut more particularly described in Exhibit A attached hereto and made a part hereof (the “Premises’). 2. Atax amount in the amount of $2,195.86 was duly and properly assessed by the plaintiff, City of Middletown (hereinafter “plaintiff’) upon the Premises, and on July 1, 2020 and January 1, 2021, the tax became due and payable, and is a lien on the Premises. 3 No portion (or an insufficient portion) of the tax has been paid. 4 The plaintiff duly and properly filed and caused to be recorded in the Middletown Land Records a certificate of lien for the tax, with interest, fees and charges thereon which tax liens were recorded in Volume 2006 at Page 990 of the Middletown Land Records. 5 The defendant, KIM E. MICHALSKY is the record owner of the premises. Cohen, Burns, Hard & Paul Attorneys At Law 81 South Main Street, West Hartford CT 06107 - (860)561-4961 Juris#402625 SECOND COUNT: (Real Estate Taxes on List of October 2020) 1 On October 1, 2020, the defendant, KIM E. MICHALSKY, was the Record owner of real estate known as 39 Little River Lane, Middletown, Connecticut more particularly described in Exhibit A attached hereto and made a part nereot (the “Premises ). 2 A tax amount in the amount of $4,371.86 was duly and properly assessed by the plaintiff, City of Middletown (hereinafter “plaintiff’) upon the Premises, and on July 1, 2021 and January 1, 2022, the tax became due and payable, and is a lien on the Premises. 3. No portion (or an insufficient portion) of the tax has been paid. 4 The plaintiff duly and properly filed and caused to be recorded in the Middletown Land Records a certificate of lien for the tax, with interest, fees and charges thereon which tax liens were recorded in Volume 2046 at Page 726 of the Middletown Land Records. 5 Paragraph five of the first count is hereby realleged as if more fully set forth hereinafter. THIRD COUNT: (Real Estate Taxes on List of October 2021) 1 On October 1, 2021, the defendant, KIM E. MICHALSKY, was the Record owner of real estate known as 39 Little River Lane, Middletown, Connecticut more particularly described in Exhibit A attached hereto and made a part hereof (the “Premises”. Cohen, Burns, Hard & Paul Attorney At Law 81 South Main Street, West Hartford CT 06107 - (860)561-4961 Juris#402625 2 A tax amount in the amount of $4,371.86 was duly and properly assessed by the plaintiff, City of Middletown (hereinafter “plaintiff’) upon the Premises, and on July 1, 2022 and January 1, 2024 the tax became due and Payable, and is a lien on the premises. 3 No portion (or an insufficient portion) of the tax has been paid. 4 The plaintiff duly and properly filed and caused to be recorded in the Middletown Land Records a certificate of lien for the tax, with interest, fees and charges thereon which tax liens were recorded in Volume 2072 at Page 690 of the Middletown Land Records. 5 Paragraph five of the first count is hereby realleged as if more fully set forth hereinafter. FOURTH COUNT: 1. Atall times mentioned herein the defendant, KIM E. MICHALSKY, was the Record owner of real estate known as 39 Little River Lane, Middletown, Connecticut more particularly described in Exhibit A attached hereto and made a part hereof (the “Premises”). 2. Water liens in the following amounts were duly and properly assessed, with interest fees and charges thereon, by the plaintiff: a. Dated October 17, 2018 and recorded October 30, 2018 in the amount of $49.63 in Volume 1931 at Page 388 of the Middletown Land Records; b. Dated February 24, 2021 and recorded February 26, 2021 in the amount of $51.75 in Volume 1997 at Page 411 of the Middletown Land Records; Cohen, Burns, Hard & Paul Attornegs At Law 81 South Main Street, West Hartford CT 06107 - (860)561-4961 Juris#402625 c. Dated October 15, 2021 and recorded October 25, 2021 in the amount of $54.77 in Volume 2025 at Page 390 of the Middletown Land Records; d. Dated July 7, 2022 and recorded April 21, 2022 in the amount of $106.52 in Volume 2043 at Page 491 of the Middletown Land Records; e. Dated April 14, 2022 and recorded April 26, 2022 in the amount of $54.77 in Volume 2043 at Page 906 of the Middletown Land Records; f Dated March 22, 2023 and recorded March 24, 2023 in the amount of $54.77 in Volume 2068 at Page 978 of the Middletown Land Records; g. Dated September 18, 2023 and recorded September 22, 2023 in the amount of $54.77 in Volume 2081 at Page 941 of the Middletown Land Records; 3. No portion (or an insufficient portion) of the sums due thereunder has been paid. 4 Paragraph five of the first count is hereby realleged as if more fully set forth hereinafter. FIFTH COUNT: 1. Atall times mentioned herein the defendant, KIM E. MICHALSKY, was the Record owner of real estate known as 39 Little River Lane, Middletown, Connecticut more particularly described in Exhibit A attached hereto and made a part hereof (the “Premises’). 2. Sewer liens in the following amounts were duly and properly assessed, with interest fees and charges thereon, by the plaintiff: Cohen, Burns, Hard & Paul Attorneyb At Law 81 South Main Street, West Hartford CT 06107 - (860)561-4961 Juris#402625 a. Dated October 17, 2018 and recorded October 30, 2018 in the amount of $39.68 in Volume 1931 at Page 448 of the Middletown Land Records; b. Dated October 15, 2020 and recorded October 21, 2020 in the amount of $48.00 in Volume 1983 at Page 525 of the Middletown Land Records; c. Dated February 24, 2021 and recorded March 1, 2021 in the amount of $57.09 in Volume 1997 at Page 534 of the Middletown Land Records; d. Dated October 15, 2021 and recorded October 27, 2021 in the amount of $64.66 in Volume 2025 at Page 725 of the Middletown Land Records; e. Dated April 7, 2022 and recorded April 19, 2022 in the amount of $169.75 in Volume 2043 at Page 218 of the Middletown Land Records; ft Dated April 14, 2022 and recorded April 27, 2022 in the amount of $64.66 in Volume 2044 at Page 111 of the Middletown Land Records; g. Dated March 22, 2023 and recorded March 30, 2023 in the amount of $64.66 in Volume 2069 at Page 474 of the Middletown Land Records; h. Dated September 18, 2023 and recorded September 20, 2023 in the amount of $64.66 in Volume 2081 at Page 609 of the Middletown Land Records; 3. No portion (or an insufficient portion) of the sums due thereunder has been paid. 4 Paragraph five of the first count is hereby realleged as if more fully set forth hereinafter. Cohen, Burns, Hard & Paul Attorneys At Law 81 South Main Street, West Hartford CT 06107 - (860)561-4961 Juris#402625 WHEREFORE, plaintiff claims: 1 Foreclosure of the respective liens; Immediate possession of the premises; A deficiency judgment against the defendant, KIM E. MICHALSKY Mme appointment of areceiver to collect the rents and profits accruing from the premises. Such other and further equitable relief as may be required. Interest, costs and reasonable attorney’s fees; Money damages PLAINTIFF, By: Ly Eric Hard, Esq. Cohen, Burns, Hard & Paul 81 South Main Street West Hartford, CT 06107 Tel: (860) 561-1036 Fax: (860) 247-2126 Juris No. 402625 Its Attorneys Cohen, Burns, Hard & Paul Attorneys At Law 81 South Main Street, West Hartford CT 06107 - (860)561-4961 Juris#402625 RETURN DATE: 4/30/2024 SUPERIOR COURT CITY OF MIDDLETOWN JUDICIAL DISTRICT OF MIDDLESEX VS. AT MIDDLETOWN KIM E. MICHALSKY MARCH 22, 2024 STATEMENT OF AMOUNT IN DEMAND The amount, legal interest and property in demand is greater than $2,500.00 exclusive of interest and costs. PLAINTIFF, _— ff By: Eric Hard, Esq. Cohen, Burns, Hard & Paul 81 South Main Street West Hartford, CT 06107 Tel: (860) 561-1036 Fax: (860) 247-2126 Juris No. 402625 Its Attorneys Cohen, Burns, Hard & Paul Attorneys At Law 81 South Main Street, West Hartford CT 06107 - (860)561-4961 Juris#402625 PLEASE RETURN RECORDED DOCUMENT TO: COHEN, BURNS, HARD & PAUL mu na NM %2093 292-994 81 SOUTH MAIN STREET WEST HARTFORD, CT 06107 RETURN DATE: 4/30/2024 SUPERIOR COURT CITY OF MIDDLETOWN JUDICIAL DISTRICT OF MIDDLESEX VS. AT MIDDLETOWN KIM E. MICHALSKY MARCH 18, 2024 MERS, INC. SECETARY OF HOUSING AND URBAN DEVELOPMENT. LIS_PENDENS TO WHOM IT MAY CONCERN, TAKE NOTICE, that an action has this day been brought to the SUPERIOR COURT to be held in the Judicial District of Middlesex on APRIL 30, 2024, in which THE CITY OF MIDDLETOWN is the plaintiff, and KIM E. MICHALSKY is the defendant. The purpose of this action is to foreclose municipal liens for real estate, water and sewer on property owned by the defendant, KIM E. MICHALSKY as follows: Real Estate Tax Liens to the City of Middletown as follows: List Volume Page Amount Date Date Recorded 10/1/2019 2006 990 $2,195.86 5/12/2021 5/17/2024 10/1/2020 2046 726 4,371.86 5/10/2022 5/24/2022 10/1/2021 2072 630 4,371.86 5/3/2023 5/11/2023 Water Liens to the City of Middletown as follows: Volume Page Amount Date Date Recorded 1931 388 $ 49.63 10/17/2018 10/30/2018 1997 41. 51.75 2/24/2021 2/26/2021, 2025 390 54.77 10/15/2021 10/25/2021 2043 491 106.52 7/7/2022 4/21/2022 2043 906 54.77 4/14/2022 4/26/2022 2068 978 54.77 3/22/2023 3/24/2023 2081 941 54.77 9/18/2023 9/22/2023 hake |WASHLEY A. FLYNN-NATALE, TOWN CLERK OF SAID MIDDLETOWN, AND CUSTODIAN OF THE RECORDS, Of, HEREBY CERTIFY THAT THE FORGOING _L\ H TRUE AND CORRECT COPY FR ae tay ae PAGE. way IN THE MIDDLETOWN LAND RECORDS, IN WITNESS WHEREOR, | H AVE i FAR UNTO SET MY HA ND. ae MF ‘THE SEAL OF MY OFFICE THIS DAY OF ATTEST: Y CITY AND TOWN GLERKI MIDDLETOWN, CT Sewer Liens to the City of Middletown as follows: Volume Page Amount Date Date Recorded 1931 448 $ 39.68 10/17/2018 10/30/2018 1983, 525 48.00 10/15/2020 10/21/2020 1997 534 57.09 2/24/2021 3/1/2021 2025 725 64.66 10/15/2021 10/27/2021 2043 218 169.75 4/7/2022 4/19/2022 2044 111 64.66 4/14/2022 4/27/2022 2069 474 64.66 3/22/2023 3/30/2023 2081 609 64.66 9/18/2023 9/20/2023 In such action the following relief is claimed: 1.) A foreclosure of said liens; 2.) Immediate possession of the premises; 3.) A deficiency judgment against the defendant(s); 4.) Such other and further equitable relief as may be required; and, 5.) Money damages. The property affected by said liens is known as 39 Little River Lane, MIDDLETOWN, CONNECTICUT 06457 recorded in the Middletown Land Records as more particularly described in Schedule A attached hereto and incorporated herein. Dated at West Hartford, Connecticut this 18th day of March 2024. PLAINTIFF, By:se Eric COHEN, BURNS, HARD & PAUL 81 SOUTH MAIN STREET WEST HARTFORD, CT 06107 JURIS NO. 402625 TEL: (860) 561-1036 FAX: (860) 247-2126 Its Attorneys E-mail: ehard@cbhplaw.com SCHEDULE A PROPERTY DESCRIPTION a a certain piece or parcel of land known as 36 Little River Drive, Middletown, Connecticut which property is more particularly bounded and described as follows: A certain piece or parcel of land, together with all buildings, improvements and appurtenances thereof, situated in the Town of Middletown, County of Middlesex and State of Connecticut, and being Lot No.9 in Section 111 on e map entitled; “Achenbach Realty Companies, Brookside Lane, Essex, Conn. 06426, Subdivision Map of the Farms At ‘Westlake’, Residential Cluster No, 2~ Sections J, J1, & 111 Portion of Property of George J. Achenbach, Eust Street, Middletown, Conn., Scale 1” 2 50°, Sheet | of 1, Date May 18, 1973, Drawing B-1, Raymond V, Kotowski, Civil Engineer”, and on file at the Middletown ‘Town Clerk's Office and listed as Map No. 3132 therein. Said premises are more particularly bounded and described as follows: NORTHERLY - dy land now or formerly of V.Scaroza, 59.79 feet; EASTERLY - by Lot No. 10, as shown on said map, 103.54 feet; SOUTHERLY - by Little River Lane, 56,22 feet; and WESTERLY - by Lot No, 8, as shown on said map, 102,50 feet, Receive ” 09/18/2094 pea llldletoivn CT SP pron Peete,