Preview
NO: FBT-CV23-6121803-S SUPERIOR COURT
TLOA OF CT, LLC ET AL JD OF HARTFORD
VS. AT HARTFORD
ROBERT A MONTELEONE APRIL 2, 2024
LIVING TRUST, et al
MOTION TO CITE IN PARTY DEFENDANT
The Plaintiff in the above captioned matter respectfully moves this court for permission to
cite in the Defendant, Manuel Ramos, as per the Amended Complaint attached herewith. It is
necessary to cite in the parties as it has come to the attention of the Plaintiff that Manuel Ramos
has an interest in the subject premises. A Memorandum of Law in support of this Motion is
attached hereto.
THE PLAINTIFF,
/s/ 102078
Gary J. Greene, Esq.
Greene Law, P.C.
Its Attorney
11 Talcott Notch Road
Farmington, CT 06032
Juris No.: 428354
ORAL ARGUMENT NOT REQUESTED
NO TESTIMONY REQUIRED
1
Greene Law, P.C. | 11 Talcott Notch Road | Farmington, CT 06032
Tel: 860-676-1336 | Fax: 860-676-2250 | E-Service: service@greenelawpc.com
NO: FBT-CV23-6121803-S SUPERIOR COURT
TLOA OF CT, LLC ET AL JD OF HARTFORD
VS. AT HARTFORD
ROBERT A MONTELEONE APRIL 2, 2024
LIVING TRUST, et al
ORDER
It appearing that the foregoing Motion should be granted, it is hereby ORDERED:
That on or before . 2024, the Plaintiff amend its complaint to state facts
showing its claim against the interests of Manuel Ramos in this action, and summon Manuel
Ramos to appear as a Defendant in this action on or before the second day following
. 2024, by causing some proper officer to serve on them in the manner
prescribed by law, a true and attested copy of this order and a true and attested copy of the
Amended Complaint in this action, and a Summons-Civil and due return make.
Dated at Hartford, CT, this day of 2024.
BY THE COURT
Judge/Assistant Clerk
2
Greene Law, P.C. | 11 Talcott Notch Road | Farmington, CT 06032
Tel: 860-676-1336 | Fax: 860-676-2250 | E-Service: service@greenelawpc.com
NO: FBT-CV23-6121803-S SUPERIOR COURT
TLOA OF CT, LLC ET AL JD OF HARTFORD
VS. AT HARTFORD
ROBERT A MONTELEONE APRIL 2, 2024
LIVING TRUST, et al
MEMORANDUM OF LAW IN SUPPORT OF
MOTION TO CITE IN PARTY DEFENDANT
The Plaintiff in the above captioned matter respectfully moves this court for permission
to cite in Defendant, Manuel Ramos, as per the Amended Complaint attached herewith. It is
necessary to cite in the parties as it has come to the attention of the Plaintiff that Manuel Ramos,
have an interest in premises which is the subject of the instant lawsuit.
FACTS:
Manuel Ramos claims or may claim an interest in the subject premises of ROBERT A
MONTELEONE LIVING TRUST is deceased and was transferred by a Trustees Deed Dated
July 15, 2018 and recorded on July 20, 2018 in Volume 9857 Page 62 et al. See attached Exhibit
A
LAW AND ARGUMENT:
“Upon motion made by any party or nonparty to a civil action, the person named in the
party’s motion or the nonparty so moving, as the case may be, (1) may be named a party by the
court if that person has or claims an interest in the controversy, or any part thereof, adverse to the
plaintiff or (2) shall be made a party by the court if that person is necessary for a complete
determination or settlement of any question involved therein...” Connecticut General Statutes §
52-102. The Plaintiff in the above captioned matter represents that the proposed Defendant
3
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Manuel Ramos has an interest in this matter that is adverse to the Plaintiff and is necessary for a
complete determination or settlement of the above captioned claim.
“Any court, or a judge when the court is not in session, upon motion, may cite in a new
party or parties to any action pending...” Connecticut General Statutes § 52-103. The Plaintiff in
this matter moves this court to grant permission to cite in as an additional Defendant, Manuel
Ramos.
CONCLUSION
As the proposed Defendant, Manuel Ramos, has a claim or interest adverse to the
Plaintiff in this matter, the Plaintiff respectfully moves this court to cite in the additional party
Defendant. The proposed Defendant is a necessary party to this action in order to make a
complete determination or settlement of the above captioned matter.
THE PLAINTIFF,
/s/ 102078
Gary J. Greene, Esq.
Greene Law, P.C.
Its Attorney
11 Talcott Notch Road
Farmington, CT 06032
Juris No.: 428354
4
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Tel: 860-676-1336 | Fax: 860-676-2250 | E-Service: service@greenelawpc.com
CERTIFICATION
I hereby certify that a copy of the above was mailed or electronically delivered on this 2
day of April 2024 to all counsel and self-represented parties of record and that written consent
for electronic delivery was received from all counsel and self-represented parties of record who
were electronically served:
WATER POLLUTION CONTROL AUTHORITY
Russell. Liskov@Bridgeportct.gov
sf 102078
Gary J. Greene, Esq.
Commissioner of the Superior Court
5
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EXHIBIT A
BK:
INSTs
P2S7 FG: 62
NDO1L 2969
Richard Cerrato, Esquire
3180 Main Street
‘Bridgeport,CT 6606
TRUSTEE! ‘S DEED
To All People To Whom These Presents Shall Come, Greeting:
Know Ye, that I, JILL. A. RODRIGUEZ AS SUCCESSOR TRUSTEE OF THE ROBERT
of the sum of
A. MONTELEONE LIVING TRUST DATED OCTOBER 7, 2003, in consideration
to
ONE HUNDRED EIGHTY THOUSAND AND 00!100 ($180,000.00) DOLLARS, received
my full satisfaction of MANUEL RAMOS of 80 Huntington Road, Bridgeport, CT 06608, do
grant, bargain, sell ‘and confirm unto the said MANUEL RAMOS (hereafter “Grantec"), all
to have,
right, title, interest, claim and demand which ! t he said Successor Trustee have or ought
in and to:
in the City of Bridgeport,
‘That certain piece or parcel of land with the buildings thereon, situated
to wit:
County of Fairfield and State of Connecticut and bounded and described as follows,
NORTH: On land now or formerly of Juliette Meaney, 65 feet;
EAST: On Kent Street, now Anton Drive, 116 feet, more or less;
SOUTH: ‘On land now of Mary Peluchette, 65 feet;
or less.
WEST: On land ow or formerly of Pasquale Aldo, 116 feet, more
Said premises are also known as No, 45 Anton Drive.
SUBJECT TO:
ental regulations, including
1. Building lines, if established, all laws, ordinances and governm
building and zoning ordinances affecting said premises.
liens have yet to be filed.
2. Any assessment, or pending assessments. for which a tien or
2017, and subsequent lists, having been
3. Taxes to the City of Bridgeport on the Grand List of
adjusted, which the Grantex herein assumes and agrees to pay.
4. Sewer use charges to the Bridgeport WPCA us the same may become duc and payable,
pave 0)
TAXA
Z Seas. TATE
BRIDGEPORT TOWN CLERKS
OFFICE
BK P2857 FG: 63
INST: OOMII 2769
To Haye and to Hold the above granted and bargained premises with the appurtenances
thereof, unto the said Grantee, and unto his heirs, successors and assigns forever, to him and his
own proper use and behoof forever. And | the said Successor Trustee do hereby covenant with
the said Grantee, his heirs, successorands assigns, that the Grantor is well seized of the premises
us a good indefeasibl e estate in FEE SIMPLE; and that I have full power and authority, as
Successor Trustee aforesaid, to grant and convey the above described premises in manner and
form aforesaid, and for myself and my successors do hereby covenant to warrant and defend the
same :o the said Grantee, and his heirs, successors and assigns, against the claims of any person
or persons claiming by, from or under mysell as such Successor Trustee.
a) (hd
f, as such Successor Trustee, | hay reunto set my hand and seal
EReaie ea bil arte
In Witness Whe
this _f4°"
day of
Witnefsed by:
eases » 2018.
LUskie rxM
ft wt ut
i
2
Cot “8004 LS.
Mark C. Val Nine JILL A. RODRIGUEZ AS SUCCESSOR
TRUSTEE OF THE ROBERT A.
MONTELEONE LIVING TRUST
DATED OCTOBER 7, 2003
STATE OF CONNECTICUT
28s. Stratford
COUNTY OF FAIRFIELD
_/4 day
The foregoing instrament was acknowledged before me this
Robert A.
of Q ily . 2018, by Jill A. Rodriguez as Successor ‘Trustee of the
Monteleone Living Trust dated October 7, 2093
Mark C
Lf alentine is
Commi ner of the Superivt Court
RECEIVEG FOR Fe
ut 216 40: S20,
CHARLES 0. Cl FNONS
TOWN CLERA
BR LOGEPORT
—
MEND
SUMMONS - CIVIL For information on STATE OF CONNECTICUT
JD-CV-1 Rev. 2-22 ADA accommodations, SUPERIOR COURT
C.G.S. §§ 51-346, 51-347, 1-349, 51-350, 52-45a, 52-48, 52-259; contact a court clerk or www.jud.ct.gov
P.B. §§ 3-1 through 3-21, 8-1, 10-13 go to: www.jud.ct.gov/ADA. i
Instructions are on page 2.
CO Select if amount, legal interest, or property in demand, not including interest and costs, is LESS than $2,500.
/703
(7 Select if amount, legal interest, or property in demand, not including interest and costs =
is $2,500 or MORE
[X] Select if claiming other relief in addition to, or in place of, money or damages. rE
+
TO: Any proper officer
By authority of the State of Connecticut, you are hereby commanded to make due and legal service of this summons and attached complaint.
‘Address of courl clerk (Number, street, town and zip code) Telephone number of clerk Return Date (Must be a Tuosday)
1061 Main Street, Bridgeport, 06604 (203 )579 -6527
[x] Judicial District G. ‘At (Giy/Town) Case type code (See list on page 2)
(J Housing Session (1 Number: Bridgeport Major: P. Minor: 00
For the plaintiff(s) enter the appearance of:
Name and address of attorney, law firm or plaintiff if sell-represented (Number, street, town and zip code) Juris number (if attorney or law Timm)
Greene Law PG, 11 Talcott Notch Road, Farmington 06032 428354
Telephone number Signature of plaintif (if self represented)
(860 )676 ~ 1336
The attorney or law firm appearing for the plaintiff, or the plaintiffif E-mail address for delivery of papers under Section 10-13 of the
selfrepresented, agrees to accept papers (service) electronically Connecticut Practice Book (if agree:
in this case under Section 10-13 of the Connecticut Practice Book. [kX] Yes [] No service@greenelawpc.com
Parties Name (Last, First, Middle Initial) and address of each party (Number; street; P.O. Box; town; state; zip; country, if not USA)
First Name: TLOA of CT, LLC P-01
plaintiff Address: 11 WEST 42ND STREET 9TH FLOOR, NEW YORK, NY, 10036
Additional Name: P02
plaintiff Address:
First Name: Ramos, Manuel D-01
defendant Address: 80 Huntington Road, Bridgeport, CT 06608
Additional Name: D-02
defendant Address:
Additional Name: D-03
defendant Address:
Additional Name: D-04
defendant Address:
Total number of plaintiffs: 1 Total number of defendants: 4 (J Form JD-CV-2 attached for additional parties
Notice to each defendant
1 You are being sued. This is a summons in a lawsuit. The complaint attached states the claims the plaintiff is making against you.
2. To receive further notices, you or your attorney must file an Appearance (form JD-CL-12) with the clerk at the address above. Generally,
it must be filed on or before the second day after the Return Date. The Return Date is not a hearing date. You do not have to come to
court on the Return Date unless you receive a separate notice telling you to appear.
If you or your attorney do not file an Appearance on time, a default judgment may be entered against you. You can get an Appearance
form at the court address above, or on-line at https://jud.ct.gov/webformsy/.
If you believe that you have insurance that may cover the claim being made against you in this lawsuit, you should immediately contact
your insurance representative. Other actions you may take are described in the Connecticut Practice Book, which may be found in a
superior court law library or on-line at https://www.jud.ct.gov/pb. htm.
If you have questions about the summons and complaint, you should talk to an attorney.
The court staff is not allowed to give advice on legal matters.
AB
Date Bi.
Bisand select, Sling
= Commissioner of Superior Court | Name of person signing
Yar} Clerk. Gary I_Greena
If this summons nage For Court Use Only
File Date
a. The signing has. sige wy fp soe the plaintiff(s) will not be denied access to the courts.
b. Itis the responsibility of the plaintifi(s)
(s) to ensure that service is made in the manner provided by law.
c. The court staff is not permitted to give any legal advice in connection with any lawsuit.
d. The Clerk signing this summons at the request of the plaintiff(s) is not responsible in any way for any
errors or omissions in the summons, any allegations contained in the complaint, or the service of the
summons or complaint.
certify [have read and | Sisned (SelFrepresented plaintif) Date Docket Number
understand the above:
Print Form Page 1 of 2 Reset Form
Instructions
1. Type or print legibly. If you are a self-represented party, this summons must be signed by a clerk of the court.
2 If there is more than one defendant, make a copy of the summons for each additional defendant. Each defendant must receive a copy of
this summons. Each copy of the summons must show who signed the summons and when it was signed. If there are more than two
plaintiffs or more than four defendants, complete the Civil Summons Continuation of Parties (form JD-C\V-2) and attach it to the original
and all copies of the summons.
Attach the summons to the complaint, and attach a copy of the summons to each copy of the complaint. Include a copy of the Civil
Summons Continuation of Parties form, if applicable.
After service has been made by a proper officer, file the original papers and the officer's return of. service with the clerk of the court.
Use this summons for the case type codes shown below.
Do not use this summons for the following actions:
(a) Family matters (for example divorce, child support, (e) Administrative appeals
custody, parentage, and visitation matters) (f) Proceedings pertaining to arbitration
(b) Any actions or proceedings in which an attachment, (g) Summary Process (Eviction) actions
garnishment or replevy is sought (h) Entry and Detainer proceedings
(c) Applications for change of name (i) Housing Code Enforcement actions
(d) Probate appeals
Case Type Codes
MAJOR CODE MAJOR CODE
Major! MINOR DESCRIPTION
DESCRIPTION
Majors MINOR DESCRIPTION
DESCRIPTION Minor Minor.
Contracts C00 Construction - All other Property P00 Foreclosure
10 Construction - State and Local P40 Partition
c20 Insurance Policy P20 Quiet Title/Discharge of Mortgage or Lien
30 Specific Performance P30 Asset Forfeiture
C40 Collections P90 All other
C50 Uninsured/Underinsured Motorist Coverage
c60 Uniform Limited Liability Company Act~ C.G.S, 34-243
C30 All other Torts (Other T02 Defective Premises - Private - Snow or Ice
than Vehicular) T03 Defective Premises - Private - Other
Eminent E00 ‘State Highway Condemnation TH Defective Premises - Public - Snow or Ice
Domain E10 Redevelopment Condemnation Ti2 Defective Premises - Public - Other
E20 Other State or Municipal Agencies T20 Products Liability - Other than Vehicular
E30 Public Utilities & Gas Transmission Companies 128 Malpractice - Medical
E90 All other T29 Malpractice - Legal
T30 Malpractice - All other
Housing- Return of Security Deposit T40 Assault and Battery
Housing H10 T50 Defamation
H12 Housing- Rent andlor Damages T6I Animals - Dog
40 Housing - Housing - Audita Querela/Injunction T69 Animals - Other
H50 Housing - Administrative Appeal T70 False Arrest
H60 Housing - Municipal Enforcement TH Fire Damage
H30 Housing- All Other T90 Allother
Miscellaneous M00 Injunetion Vehicular Torts vot Motor Vehicles’ - Driver and/or Passenger(s) vs. Drivers)
M10 Receivership vod Motor Vehicles’ - Pedestrian vs. Driver
M15 Receivership for Abandoned/Biighted Property Motor Vehicles* - Property Damage only
V05
M20 Mandamus Motor Vehicle’ - Products Liability Including Warranty
Habeas Corpus (extradition, release from Penal Institution) V06
M30 Motor Vehicle’ - All other
Vvo9
M40 Arbitration
M50 Declaratory Judgment vi0 Boats
M63 Bar Discipline v20 Airplanes
M66 Department of Labor Unemployment Compensation v30 Railroads
Enforcement v40 Snowmobiles
Vv90 All other
M68 Bar Discipline - Inactive Status *Motor Vehicles include cars, trucks,
M70 ‘Municipal Ordinance and Regulation Enforcement motorcycles, and motor scooters.
a0 Foreign Civil Judgments - C.G.S. 52-604 & C.G.S. 50a-30
M83 ‘Small Claims Transfer to Regular Docket Wills, Estates wi0 Construction of Wills and Trusts
Me4 Foreign Protective Order and Trusts wa0 All other
Mag CHRO Action in the Public Interest - P.A. 19-93
M90 Allother
Page 2 of 2
REEURN DATE: FEBRUARY 28_2923 SUPERIOR COURT
NO: FBT-CV23-6121803-S
TLOA OF CT, LLC ET AL JD OF HARTFORD
VS. AT HARTFORD
ROBERT A MONTELEONE FANE ARAHS2023
APRIL 2. 2024
LIVING TRUST, et al
AMENDED TAX LIEN FORECLOSURE COMPLAINT
COUNT ONE: (2017 Tax Lien on 45 Anton Drive, Bridgeport, CT)
+A—Moentel. I 7,
1 The Defendant, Manuel Ramos Ret t, is
the record owner of real estate known as 45 Anton Drive, Bridgeport, CT,
bounded and described as follows:
SEE ATTACHED EXIDBIT A
2 Taxes in the amount of $3,235.29 were duly and properly assessed upon
this property, on the list of October 1, 2017 and became due and payable on July
1, 2018 and January 1, 2019 and the taxes are a lien on this property.
3 No part of the tax has been paid.
4 On April 2, 2019, the City of Bridgeport duly and properly filed and
caused to be recorded in the land records of the City of Bridgeport a
certificate of lien for the tax together with interest fees and charges thereon in
Volume 9992 at Page 153 of the Bridgeport Land Records.
5 By Assignment of tax lien recorded in Volume 10013 at Page 258
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of _the Bridgeport Land Records, the tax lien described herein was assigned from
the City of Bridgeport to TLOA of CT, LLC.
6 The following encumbrances are subsequent to the interest of the
plaintiff being foreclosed herein.
a The Defendant, Water Pollution Control Authority,
claims or may claim an interest in the subject premises by virtue of any sewer
charges and/or liens as the same may be recorded or assessed against the
property.
b The Defendant, Aquarion Water Company, claims or
may claim an interest in the subject premises by virtue of any sewer charges
and/or liens as the same may be recorded or assessed against the property.
7. The Defendants, Rebert Living Trust Manuel Ramos, owns
A-Menteleene
the premises and are-isin possession thereof.
8 A true and attested copy of the Amended Lis Pendens to be recorded on
the Bridgeport Land Records giving notice of the institution of this foreclosure
action is attached hereto as Exhibit B and made a part hereof, in accordance with
the provisions of C.G.S. §52-325.
COUNT TWO: (2018 Tax Lien 45 Anton Drive, Bridgeport. CT)
] Paragraph 1 of Count One is hereby incorporated as Paragraph 1 of this
Second Count as if more fully set forth herein.
2
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2 Taxes in the amount of $6,425.36 were duly and properly assessed upon this
property, on
the list of October 1, 2018 and became due and payable on July 1, 2019 and
Januaryl1, 2020
and the taxes are a lien on this property.
3 No part of the tax has been paid.
4 On April 24, 2020, the City of Bridgeport duly and properly filed and
caused to be recorded in the land records of the City of Bridgeport a
certificate of lien for the tax together with interest fees and charges thereon in
Volume 10209 at Page 8 of the Bridgeport Land Records.
5 By Assignment of tax lien recorded in Volume 10224 at Page 1 of the
Bridgeport Land Records, the tax lien described herein was assigned from City
of Bridgeport to TLOA of CT, LLC.
6-8. Paragraphs 6 through 8 of the First Count are incorporated herein and made
Paragraphs 6 through 8 of this Second Count.
COUNT THREE: (2019 Tax Lien on 45 Anti Drive, Brid. rt T
1 Paragraph 1 of Count One is hereby incorporated as Paragraph 1 of this
Third Count as if more fully set forth herein.
2 Taxes in the amount of $6,425.36 were duly and properly assessed upon
this property, on the list of October 1, 2019 and became due and payable on July
1, 2020 and January 1, 2021 and the taxes are a lien on this property.
3
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3 No part of the tax has been paid.
4 On April 5, 2021, the City of Bridgeport duly and properly filed and
caused to be recorded in the land records of the City of Bridgeport a certificate
of lien for the tax together with interest fees and charges thereon in Volume
10416 at Page 138 of the Bridgeport Land Records.
5 By Assignment of tax lien recorded in Volume 10448 at Page 74 of the
Bridgeport Land Records, the tax lien described herein was assigned from City of
Bridgeport to TLOA of CT, LLC.
6-8. Paragraphs 6 through 8 of the First Count are incorporated herein and made
Paragraphs 6 through 8 of this Third Count.
NT FO : (2020 Tax Li on 45 Anton Drive, Bri: rt, CT
Paragraph 1 of Count One is hereby incorporated as Paragraph | of this
Fourth Count as if more fully set forth herein.
Taxes in the amount of $6,386.72 were duly and properly assessed upon
this property, on the list of October 1, 2020 and became due and payable on
July 1, 2021 and January 1, 2022 and the taxes are a lien on this property.
No part of the tax has been paid
On April 1, 2022, the City of Bridgeport duly and properly filed and
caused to be recorded in the land records of the City of Bridgeport a
certificate oflien for the tax together with interest fees and charges thereon in
4
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Volume 10750 at Page 21 of the Bridgeport Land Records.
5 By Assignment of tax lien recorded in Volume 10799 at Page 109 of the
Bridgeport Land Records, the tax lien described herein was assigned from
City of Bridgeport to TLOA ofCT,LLC.
6-8. Paragraphs 6 through 8 of the First Count are incorporated herein and
made Paragraphs 6 through 8 of this Fourth Count.
5
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WHEREFORE, the Plaintiff claims:
1 A foreclosure of the lien pursuant to Connecticut General Statute §12-181;
2. Immediate possession of the premises;
3 Attorney's fees pursuant to Connecticut General Statute §12-193;
4 Interest pursuant to Connecticut General Statute§ 12-146;
Costs pursuant to Connecticut General Statute §12-193;
That a receiver be appointed to collect the rents and profits accruing from
said premises; and
Such other relief in law or equity as may appertain.
THE PLAINTIFF,
/s/ 102078.
Gary J. Greene, Esq.
Greene Law, P.C.
Its Attorney
11 Talcott Notch Road
Farmington, CT 06032
Juris No.: 428354
6
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REFURN DAT PEBRUAR 2$.2023 SUPERIOR COURT
J.D. OF FAIRFIELD
NO: FBT-CV23-6121803-S
AT BRIDGEPORT
TLOA OF CT, LLC
JANEPARY 18,2023
vs.
APRIL 2. 2024
ROBERT A. MONTELEONE LIVING TRUST, ET AL
STATEMENT. : AMOUNT IN DEM.
The Plaintiff, TLOA OF CT, LLC, claims money damages of more than $2,500.00,
exclusive of statutory interest and costs.
THE PLAINTIFF,
/s/ 102078
Gary J. Greene, Esq.
Greene Law, P.C.
Its Attorney
1] Talcott Notch Road
Farmington, CT 06032
Juris No.: 428354
7
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Tel: 860-676-1336 1 Fax: 860-676-2250 1 E-Service: service@greenelawpc.com
EXHIBIT A
That certain piece or parcel of land with the buildings thereon, situated in the City of Bridgeport,
County of Fairfield, and State of Connecticut and bounded and described as follows, to wit:
NORTH: On land nor or formerly of Juliette Meaney, 65 feet;
EAST: On Kent Street, now Anton Drive, 116 feet, more or less;
SOUTH: On land now of Mary Peluchette, 65 feet;
WEST: On land now or formerly of Pasquale Aldo, 116 feet, more or less.
Said premises are also known as No. 45 Anton Drive.
8
Greene Law, P.C. | 11 Talcott Notch Road | Farmington, CT 06032
Tel: 860-676-1336 1 Fax: 860-676-2250 1 E-Service: service@greenelawpc.com
Aft Ri rn
Greene Law, PC XAT. DVD
11 Talcott Notch Road
Farmington. CT 06032
RETURN
FEBRUARY
DATE: 28,2023 SUPERIOR COURT
NO: FBT-CV23-6121803-S
TLOA OF CT, LLC ET AL JD OF HARTFORD
VS. AT HARTFORD
ROBERT A. MONTELEONE LIVING TRUST,
MANUEL RAMOS, WATER POLLUTION CONTROL AUTHORITY
AQUARION WATER COMPANY JANUARY 18,2023 APRIL2. 2024
AMENDED NOTICE OF LIS PENDENS
Notice is hereby given of the pendency of a civil action between the above-named parties
by complaint and summons thereon, dated JANUARY 18, 2023 and made returnable to the
Superior Court for the Judicial District of Fairfield at Bridgeport on FEBRUARY 28, 2023.
which Notice amends the Lis Pendens Dated JANUARY 18, 2023, and recorded on January 27
2023 in Volume 10935 at Page 141 etal of the Bridgeport land records with regards to this
action that seeks action-is-broughtto foreclose the following Tax Liens recorded in Volume
9992 at Page 153, Volume 10209 at Page 8, Volume 10416 at Page 138, and Volume 10750
at Page 21
Said Tax Liens were assigned to TLOA OF CT, LLC by an Assignment of Real Property Tax
Liens recorded in Volume 10013 at Page 258; Volume 10224 at Page 1, Volume 10448 at
Page 74, and Volume 10799 at Page 109; all of the Bridgeport Land Records. Such action
specifically requests the following
1 A foreclosure of said tax liens.
2 Immediate possession of the premises
3 A deficiency judgment. No deficiency will be sought against any person whose
obligation under the subject promissory note has been heretofore or hereafter
9
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discharged in bankruptcy.
The appointment of a receiver to collect rents and profits accruing from the
premises.
Reasonable attorney's fees and costs.
Such other relief and further equitable relief as may be required.
The Premises is that certain real property with buildings thereon, situated in the City of
Bridgeport, County of Fairfield, and State of Connecticut, which is at 45 Anton Drive, more
particularly bounded and described as set forth in Exhibit A, attached hereto and incorporated by
reference as if herein set forth verbatim.
Dated at Farmington, Connecticut,
RESPECTFULLY SUBMITTED
PLAINTIFF,
/s/ 102078
Gary J. Greene, Esq.
Greene Law, P.C.
Its Attorney
11 Talcott Notch Road
Farmington, CT 06032
Juris No.: 428354
10
Greene Law, P.C. | 11 Talcott Notch Road | Farmington, CT 06032
Tel: 860-676-1336 1 Fax: 860-676-2250 1 E-Service: service@greenelawpc.com
EXHIBIT A
That certain piece or parcel of land with the buildings thereon, situated in the City of Bridgeport,
County of Fairfield, and State of Connecticut and bounded and described as follows, to wit:
NORTH: On land nor or formerly of Juliette Meaney, 65 feet;
EAST: On Kent Street, now Anton Drive, 116 feet, more or less;
SOUTH: On land now of Mary Peluchette, 65 feet;
WEST: On land now or formerly of Pasquale Aldo, 116 feet, more or less.
Said premises are also known as No. 45 Anton Drive.
11
Greene Law, P.C. | 11 Talcott Notch Road | Farmington, CT 06032
Tel: 860-676-1336 1 Fax: 860-676-2250 ; E-Service: service@greenelawpc.com
NO: FBT-CV23-6121803-S SUPERIOR COURT
TLOA OF CT, LLC ET AL JD OF HARTFORD
VS. AT HARTFORD
ROBERT A MONTELEONE APRIL 2, 2024
LIVING TRUST, et al
AMENDED TAX LIEN FORECLOSURE COMPLAINT.
T
COUN’ E: (2017 Tax Lien on 45 Anton Drive, Bridgeport
9 The Defendant, Manuel Ramos , is the record owner of real estate
known as 45 Anton Drive, Bridgeport, CT, bounded and described as follows:
SEE ATTACHED EXIDBIT A
10. Taxes in the amount of $3,235.29 were duly and properly assessed upon
this property, on the list of October 1, 2017 and became due and payable on July
1, 2018 and January 1, 2019 and the taxes are a lien on this property.
.
11. No part of the tax has been paid.
12. On April 2, 2019, the City of Bridgeport duly and properly filed and
caused to be recorded in the land records of the City of Bridgeport a
certificate of lien for the tax together with interest fees and charges thereon in
Volume 9992 at Page 153 of the Bridgeport Land Records.
13. By Assignment of tax lien recorded in Volume 10013 at Page 258
of the Bridgeport Land Records, the tax lien described herein was assigned from
12
Greene Law, P.C. | 11 Talcott Notch Road 1 Farmington, CT 06032
Tel: 860-676-1336 1 Fax: 860-676-2250 1 E-Service:
service@greenelawpc.com
the City of Bridgeport to TLOA of CT, LLC.
14. The following encumbrances are subsequent to the interest of the
plaintiff being foreclosed herein.
a. The Defendant, Water Pollution Control Authority,
claims or may claim an interest in the subject premises by virtue of any sewer
charges and/or liens as the same may be recorded or assessed against the
property.
b The Defendant, Aquarion Water Company, claims or
may claim an interest in the subject premises by virtue of any sewer charges
and/or liens as the same may be recorded or assessed against the property.
15. The Defendant, Manuel Ramos, owns the premises and is in possession
thereof.
16. A true and attested copy of the Amended-Lis Pendens to be recorded on
the Bridgeport Land Records giving notice of the institution of this foreclosure
action is attached hereto as Exhibit B and made a part hereof, in accordance with
the provisions of C.G.S. §52-325.
COUNT TWO: (2018 Tax Lien 45 Anton Drive. idge| rt.C
1 Paragraph 1 of Count One is hereby incorporated as Paragraph | of this
Second Count as if more fully set forth herein.
Taxes in the amount of $6,425.36 were duly and properly assessed upon this
Preview
NO: FBT-CV23-6121803-S SUPERIOR COURT TLOA OF CT, LLC ET AL JD OF HARTFORD VS. AT HARTFORD ROBERT A MONTELEONE APRIL 2, 2024 LIVING TRUST, et al MOTION TO CITE IN PARTY DEFENDANT The Plaintiff in the above captioned matter respectfully moves this court for permission to cite in the Defendant, Manuel Ramos, as per the Amended Complaint attached herewith. It is necessary to cite in the parties as it has come to the attention of the Plaintiff that Manuel Ramos has an interest in the subject premises. A Memorandum of Law in support of this Motion is attached hereto. THE PLAINTIFF, /s/ 102078 Gary J. Greene, Esq. Greene Law, P.C. Its Attorney 11 Talcott Notch Road Farmington, CT 06032 Juris No.: 428354 ORAL ARGUMENT NOT REQUESTED NO TESTIMONY REQUIRED 1 Greene Law, P.C. | 11 Talcott Notch Road | Farmington, CT 06032 Tel: 860-676-1336 | Fax: 860-676-2250 | E-Service: service@greenelawpc.com NO: FBT-CV23-6121803-S SUPERIOR COURT TLOA OF CT, LLC ET AL JD OF HARTFORD VS. AT HARTFORD ROBERT A MONTELEONE APRIL 2, 2024 LIVING TRUST, et al ORDER It appearing that the foregoing Motion should be granted, it is hereby ORDERED: That on or before . 2024, the Plaintiff amend its complaint to state facts showing its claim against the interests of Manuel Ramos in this action, and summon Manuel Ramos to appear as a Defendant in this action on or before the second day following . 2024, by causing some proper officer to serve on them in the manner prescribed by law, a true and attested copy of this order and a true and attested copy of the Amended Complaint in this action, and a Summons-Civil and due return make. Dated at Hartford, CT, this day of 2024. BY THE COURT Judge/Assistant Clerk 2 Greene Law, P.C. | 11 Talcott Notch Road | Farmington, CT 06032 Tel: 860-676-1336 | Fax: 860-676-2250 | E-Service: service@greenelawpc.com NO: FBT-CV23-6121803-S SUPERIOR COURT TLOA OF CT, LLC ET AL JD OF HARTFORD VS. AT HARTFORD ROBERT A MONTELEONE APRIL 2, 2024 LIVING TRUST, et al MEMORANDUM OF LAW IN SUPPORT OF MOTION TO CITE IN PARTY DEFENDANT The Plaintiff in the above captioned matter respectfully moves this court for permission to cite in Defendant, Manuel Ramos, as per the Amended Complaint attached herewith. It is necessary to cite in the parties as it has come to the attention of the Plaintiff that Manuel Ramos, have an interest in premises which is the subject of the instant lawsuit. FACTS: Manuel Ramos claims or may claim an interest in the subject premises of ROBERT A MONTELEONE LIVING TRUST is deceased and was transferred by a Trustees Deed Dated July 15, 2018 and recorded on July 20, 2018 in Volume 9857 Page 62 et al. See attached Exhibit A LAW AND ARGUMENT: “Upon motion made by any party or nonparty to a civil action, the person named in the party’s motion or the nonparty so moving, as the case may be, (1) may be named a party by the court if that person has or claims an interest in the controversy, or any part thereof, adverse to the plaintiff or (2) shall be made a party by the court if that person is necessary for a complete determination or settlement of any question involved therein...” Connecticut General Statutes § 52-102. The Plaintiff in the above captioned matter represents that the proposed Defendant 3 Greene Law, P.C. | 11 Talcott Notch Road | Farmington, CT 06032 Tel: 860-676-1336 | Fax: 860-676-2250 | E-Service: service@greenelawpc.com Manuel Ramos has an interest in this matter that is adverse to the Plaintiff and is necessary for a complete determination or settlement of the above captioned claim. “Any court, or a judge when the court is not in session, upon motion, may cite in a new party or parties to any action pending...” Connecticut General Statutes § 52-103. The Plaintiff in this matter moves this court to grant permission to cite in as an additional Defendant, Manuel Ramos. CONCLUSION As the proposed Defendant, Manuel Ramos, has a claim or interest adverse to the Plaintiff in this matter, the Plaintiff respectfully moves this court to cite in the additional party Defendant. The proposed Defendant is a necessary party to this action in order to make a complete determination or settlement of the above captioned matter. THE PLAINTIFF, /s/ 102078 Gary J. Greene, Esq. Greene Law, P.C. Its Attorney 11 Talcott Notch Road Farmington, CT 06032 Juris No.: 428354 4 Greene Law, P.C. | 11 Talcott Notch Road | Farmington, CT 06032 Tel: 860-676-1336 | Fax: 860-676-2250 | E-Service: service@greenelawpc.com CERTIFICATION I hereby certify that a copy of the above was mailed or electronically delivered on this 2 day of April 2024 to all counsel and self-represented parties of record and that written consent for electronic delivery was received from all counsel and self-represented parties of record who were electronically served: WATER POLLUTION CONTROL AUTHORITY Russell. Liskov@Bridgeportct.gov sf 102078 Gary J. Greene, Esq. Commissioner of the Superior Court 5 Greene Law, P.C. | 11 Talcott Notch Road | Farmington, CT 06032 Tel: 860-676-1336 | Fax: 860-676-2250 | E-Service: service@greenelawpc.com EXHIBIT A BK: INSTs P2S7 FG: 62 NDO1L 2969 Richard Cerrato, Esquire 3180 Main Street ‘Bridgeport,CT 6606 TRUSTEE! ‘S DEED To All People To Whom These Presents Shall Come, Greeting: Know Ye, that I, JILL. A. RODRIGUEZ AS SUCCESSOR TRUSTEE OF THE ROBERT of the sum of A. MONTELEONE LIVING TRUST DATED OCTOBER 7, 2003, in consideration to ONE HUNDRED EIGHTY THOUSAND AND 00!100 ($180,000.00) DOLLARS, received my full satisfaction of MANUEL RAMOS of 80 Huntington Road, Bridgeport, CT 06608, do grant, bargain, sell ‘and confirm unto the said MANUEL RAMOS (hereafter “Grantec"), all to have, right, title, interest, claim and demand which ! t he said Successor Trustee have or ought in and to: in the City of Bridgeport, ‘That certain piece or parcel of land with the buildings thereon, situated to wit: County of Fairfield and State of Connecticut and bounded and described as follows, NORTH: On land now or formerly of Juliette Meaney, 65 feet; EAST: On Kent Street, now Anton Drive, 116 feet, more or less; SOUTH: ‘On land now of Mary Peluchette, 65 feet; or less. WEST: On land ow or formerly of Pasquale Aldo, 116 feet, more Said premises are also known as No, 45 Anton Drive. SUBJECT TO: ental regulations, including 1. Building lines, if established, all laws, ordinances and governm building and zoning ordinances affecting said premises. liens have yet to be filed. 2. Any assessment, or pending assessments. for which a tien or 2017, and subsequent lists, having been 3. Taxes to the City of Bridgeport on the Grand List of adjusted, which the Grantex herein assumes and agrees to pay. 4. Sewer use charges to the Bridgeport WPCA us the same may become duc and payable, pave 0) TAXA Z Seas. TATE BRIDGEPORT TOWN CLERKS OFFICE BK P2857 FG: 63 INST: OOMII 2769 To Haye and to Hold the above granted and bargained premises with the appurtenances thereof, unto the said Grantee, and unto his heirs, successors and assigns forever, to him and his own proper use and behoof forever. And | the said Successor Trustee do hereby covenant with the said Grantee, his heirs, successorands assigns, that the Grantor is well seized of the premises us a good indefeasibl e estate in FEE SIMPLE; and that I have full power and authority, as Successor Trustee aforesaid, to grant and convey the above described premises in manner and form aforesaid, and for myself and my successors do hereby covenant to warrant and defend the same :o the said Grantee, and his heirs, successors and assigns, against the claims of any person or persons claiming by, from or under mysell as such Successor Trustee. a) (hd f, as such Successor Trustee, | hay reunto set my hand and seal EReaie ea bil arte In Witness Whe this _f4°" day of Witnefsed by: eases » 2018. LUskie rxM ft wt ut i 2 Cot “8004 LS. Mark C. Val Nine JILL A. RODRIGUEZ AS SUCCESSOR TRUSTEE OF THE ROBERT A. MONTELEONE LIVING TRUST DATED OCTOBER 7, 2003 STATE OF CONNECTICUT 28s. Stratford COUNTY OF FAIRFIELD _/4 day The foregoing instrament was acknowledged before me this Robert A. of Q ily . 2018, by Jill A. Rodriguez as Successor ‘Trustee of the Monteleone Living Trust dated October 7, 2093 Mark C Lf alentine is Commi ner of the Superivt Court RECEIVEG FOR Fe ut 216 40: S20, CHARLES 0. Cl FNONS TOWN CLERA BR LOGEPORT — MEND SUMMONS - CIVIL For information on STATE OF CONNECTICUT JD-CV-1 Rev. 2-22 ADA accommodations, SUPERIOR COURT C.G.S. §§ 51-346, 51-347, 1-349, 51-350, 52-45a, 52-48, 52-259; contact a court clerk or www.jud.ct.gov P.B. §§ 3-1 through 3-21, 8-1, 10-13 go to: www.jud.ct.gov/ADA. i Instructions are on page 2. CO Select if amount, legal interest, or property in demand, not including interest and costs, is LESS than $2,500. /703 (7 Select if amount, legal interest, or property in demand, not including interest and costs = is $2,500 or MORE [X] Select if claiming other relief in addition to, or in place of, money or damages. rE + TO: Any proper officer By authority of the State of Connecticut, you are hereby commanded to make due and legal service of this summons and attached complaint. ‘Address of courl clerk (Number, street, town and zip code) Telephone number of clerk Return Date (Must be a Tuosday) 1061 Main Street, Bridgeport, 06604 (203 )579 -6527 [x] Judicial District G. ‘At (Giy/Town) Case type code (See list on page 2) (J Housing Session (1 Number: Bridgeport Major: P. Minor: 00 For the plaintiff(s) enter the appearance of: Name and address of attorney, law firm or plaintiff if sell-represented (Number, street, town and zip code) Juris number (if attorney or law Timm) Greene Law PG, 11 Talcott Notch Road, Farmington 06032 428354 Telephone number Signature of plaintif (if self represented) (860 )676 ~ 1336 The attorney or law firm appearing for the plaintiff, or the plaintiffif E-mail address for delivery of papers under Section 10-13 of the selfrepresented, agrees to accept papers (service) electronically Connecticut Practice Book (if agree: in this case under Section 10-13 of the Connecticut Practice Book. [kX] Yes [] No service@greenelawpc.com Parties Name (Last, First, Middle Initial) and address of each party (Number; street; P.O. Box; town; state; zip; country, if not USA) First Name: TLOA of CT, LLC P-01 plaintiff Address: 11 WEST 42ND STREET 9TH FLOOR, NEW YORK, NY, 10036 Additional Name: P02 plaintiff Address: First Name: Ramos, Manuel D-01 defendant Address: 80 Huntington Road, Bridgeport, CT 06608 Additional Name: D-02 defendant Address: Additional Name: D-03 defendant Address: Additional Name: D-04 defendant Address: Total number of plaintiffs: 1 Total number of defendants: 4 (J Form JD-CV-2 attached for additional parties Notice to each defendant 1 You are being sued. This is a summons in a lawsuit. The complaint attached states the claims the plaintiff is making against you. 2. To receive further notices, you or your attorney must file an Appearance (form JD-CL-12) with the clerk at the address above. Generally, it must be filed on or before the second day after the Return Date. The Return Date is not a hearing date. You do not have to come to court on the Return Date unless you receive a separate notice telling you to appear. If you or your attorney do not file an Appearance on time, a default judgment may be entered against you. You can get an Appearance form at the court address above, or on-line at https://jud.ct.gov/webformsy/. If you believe that you have insurance that may cover the claim being made against you in this lawsuit, you should immediately contact your insurance representative. Other actions you may take are described in the Connecticut Practice Book, which may be found in a superior court law library or on-line at https://www.jud.ct.gov/pb. htm. If you have questions about the summons and complaint, you should talk to an attorney. The court staff is not allowed to give advice on legal matters. AB Date Bi. Bisand select, Sling = Commissioner of Superior Court | Name of person signing Yar} Clerk. Gary I_Greena If this summons nage For Court Use Only File Date a. The signing has. sige wy fp soe the plaintiff(s) will not be denied access to the courts. b. Itis the responsibility of the plaintifi(s) (s) to ensure that service is made in the manner provided by law. c. The court staff is not permitted to give any legal advice in connection with any lawsuit. d. The Clerk signing this summons at the request of the plaintiff(s) is not responsible in any way for any errors or omissions in the summons, any allegations contained in the complaint, or the service of the summons or complaint. certify [have read and | Sisned (SelFrepresented plaintif) Date Docket Number understand the above: Print Form Page 1 of 2 Reset Form Instructions 1. Type or print legibly. If you are a self-represented party, this summons must be signed by a clerk of the court. 2 If there is more than one defendant, make a copy of the summons for each additional defendant. Each defendant must receive a copy of this summons. Each copy of the summons must show who signed the summons and when it was signed. If there are more than two plaintiffs or more than four defendants, complete the Civil Summons Continuation of Parties (form JD-C\V-2) and attach it to the original and all copies of the summons. Attach the summons to the complaint, and attach a copy of the summons to each copy of the complaint. Include a copy of the Civil Summons Continuation of Parties form, if applicable. After service has been made by a proper officer, file the original papers and the officer's return of. service with the clerk of the court. Use this summons for the case type codes shown below. Do not use this summons for the following actions: (a) Family matters (for example divorce, child support, (e) Administrative appeals custody, parentage, and visitation matters) (f) Proceedings pertaining to arbitration (b) Any actions or proceedings in which an attachment, (g) Summary Process (Eviction) actions garnishment or replevy is sought (h) Entry and Detainer proceedings (c) Applications for change of name (i) Housing Code Enforcement actions (d) Probate appeals Case Type Codes MAJOR CODE MAJOR CODE Major! MINOR DESCRIPTION DESCRIPTION Majors MINOR DESCRIPTION DESCRIPTION Minor Minor. Contracts C00 Construction - All other Property P00 Foreclosure 10 Construction - State and Local P40 Partition c20 Insurance Policy P20 Quiet Title/Discharge of Mortgage or Lien 30 Specific Performance P30 Asset Forfeiture C40 Collections P90 All other C50 Uninsured/Underinsured Motorist Coverage c60 Uniform Limited Liability Company Act~ C.G.S, 34-243 C30 All other Torts (Other T02 Defective Premises - Private - Snow or Ice than Vehicular) T03 Defective Premises - Private - Other Eminent E00 ‘State Highway Condemnation TH Defective Premises - Public - Snow or Ice Domain E10 Redevelopment Condemnation Ti2 Defective Premises - Public - Other E20 Other State or Municipal Agencies T20 Products Liability - Other than Vehicular E30 Public Utilities & Gas Transmission Companies 128 Malpractice - Medical E90 All other T29 Malpractice - Legal T30 Malpractice - All other Housing- Return of Security Deposit T40 Assault and Battery Housing H10 T50 Defamation H12 Housing- Rent andlor Damages T6I Animals - Dog 40 Housing - Housing - Audita Querela/Injunction T69 Animals - Other H50 Housing - Administrative Appeal T70 False Arrest H60 Housing - Municipal Enforcement TH Fire Damage H30 Housing- All Other T90 Allother Miscellaneous M00 Injunetion Vehicular Torts vot Motor Vehicles’ - Driver and/or Passenger(s) vs. Drivers) M10 Receivership vod Motor Vehicles’ - Pedestrian vs. Driver M15 Receivership for Abandoned/Biighted Property Motor Vehicles* - Property Damage only V05 M20 Mandamus Motor Vehicle’ - Products Liability Including Warranty Habeas Corpus (extradition, release from Penal Institution) V06 M30 Motor Vehicle’ - All other Vvo9 M40 Arbitration M50 Declaratory Judgment vi0 Boats M63 Bar Discipline v20 Airplanes M66 Department of Labor Unemployment Compensation v30 Railroads Enforcement v40 Snowmobiles Vv90 All other M68 Bar Discipline - Inactive Status *Motor Vehicles include cars, trucks, M70 ‘Municipal Ordinance and Regulation Enforcement motorcycles, and motor scooters. a0 Foreign Civil Judgments - C.G.S. 52-604 & C.G.S. 50a-30 M83 ‘Small Claims Transfer to Regular Docket Wills, Estates wi0 Construction of Wills and Trusts Me4 Foreign Protective Order and Trusts wa0 All other Mag CHRO Action in the Public Interest - P.A. 19-93 M90 Allother Page 2 of 2 REEURN DATE: FEBRUARY 28_2923 SUPERIOR COURT NO: FBT-CV23-6121803-S TLOA OF CT, LLC ET AL JD OF HARTFORD VS. AT HARTFORD ROBERT A MONTELEONE FANE ARAHS2023 APRIL 2. 2024 LIVING TRUST, et al AMENDED TAX LIEN FORECLOSURE COMPLAINT COUNT ONE: (2017 Tax Lien on 45 Anton Drive, Bridgeport, CT) +A—Moentel. I 7, 1 The Defendant, Manuel Ramos Ret t, is the record owner of real estate known as 45 Anton Drive, Bridgeport, CT, bounded and described as follows: SEE ATTACHED EXIDBIT A 2 Taxes in the amount of $3,235.29 were duly and properly assessed upon this property, on the list of October 1, 2017 and became due and payable on July 1, 2018 and January 1, 2019 and the taxes are a lien on this property. 3 No part of the tax has been paid. 4 On April 2, 2019, the City of Bridgeport duly and properly filed and caused to be recorded in the land records of the City of Bridgeport a certificate of lien for the tax together with interest fees and charges thereon in Volume 9992 at Page 153 of the Bridgeport Land Records. 5 By Assignment of tax lien recorded in Volume 10013 at Page 258 1 Greene Law, P.C. | 11 Talcott Notch Road | Farmington, CT 06032 Tel: 860-676-1336 1 Fax: 860-676-2250 1 E-Service: service@greenelawpc.com of _the Bridgeport Land Records, the tax lien described herein was assigned from the City of Bridgeport to TLOA of CT, LLC. 6 The following encumbrances are subsequent to the interest of the plaintiff being foreclosed herein. a The Defendant, Water Pollution Control Authority, claims or may claim an interest in the subject premises by virtue of any sewer charges and/or liens as the same may be recorded or assessed against the property. b The Defendant, Aquarion Water Company, claims or may claim an interest in the subject premises by virtue of any sewer charges and/or liens as the same may be recorded or assessed against the property. 7. The Defendants, Rebert Living Trust Manuel Ramos, owns A-Menteleene the premises and are-isin possession thereof. 8 A true and attested copy of the Amended Lis Pendens to be recorded on the Bridgeport Land Records giving notice of the institution of this foreclosure action is attached hereto as Exhibit B and made a part hereof, in accordance with the provisions of C.G.S. §52-325. COUNT TWO: (2018 Tax Lien 45 Anton Drive, Bridgeport. CT) ] Paragraph 1 of Count One is hereby incorporated as Paragraph 1 of this Second Count as if more fully set forth herein. 2 Greene Law, P.C. | 11 Talcott Notch Road | Farmington, CT 06032 Tel: 860-676-1336 1 Fax: 860-676-2250 1 E-Service: service@greenelawpc.com 2 Taxes in the amount of $6,425.36 were duly and properly assessed upon this property, on the list of October 1, 2018 and became due and payable on July 1, 2019 and Januaryl1, 2020 and the taxes are a lien on this property. 3 No part of the tax has been paid. 4 On April 24, 2020, the City of Bridgeport duly and properly filed and caused to be recorded in the land records of the City of Bridgeport a certificate of lien for the tax together with interest fees and charges thereon in Volume 10209 at Page 8 of the Bridgeport Land Records. 5 By Assignment of tax lien recorded in Volume 10224 at Page 1 of the Bridgeport Land Records, the tax lien described herein was assigned from City of Bridgeport to TLOA of CT, LLC. 6-8. Paragraphs 6 through 8 of the First Count are incorporated herein and made Paragraphs 6 through 8 of this Second Count. COUNT THREE: (2019 Tax Lien on 45 Anti Drive, Brid. rt T 1 Paragraph 1 of Count One is hereby incorporated as Paragraph 1 of this Third Count as if more fully set forth herein. 2 Taxes in the amount of $6,425.36 were duly and properly assessed upon this property, on the list of October 1, 2019 and became due and payable on July 1, 2020 and January 1, 2021 and the taxes are a lien on this property. 3 Greene Law, P.C. | 11 Talcott Notch Road | Farmington, CT 06032 Tel: 860-676-1336 1 Fax: 860-676-2250 i E-Service: service@greenelawpc.com 3 No part of the tax has been paid. 4 On April 5, 2021, the City of Bridgeport duly and properly filed and caused to be recorded in the land records of the City of Bridgeport a certificate of lien for the tax together with interest fees and charges thereon in Volume 10416 at Page 138 of the Bridgeport Land Records. 5 By Assignment of tax lien recorded in Volume 10448 at Page 74 of the Bridgeport Land Records, the tax lien described herein was assigned from City of Bridgeport to TLOA of CT, LLC. 6-8. Paragraphs 6 through 8 of the First Count are incorporated herein and made Paragraphs 6 through 8 of this Third Count. NT FO : (2020 Tax Li on 45 Anton Drive, Bri: rt, CT Paragraph 1 of Count One is hereby incorporated as Paragraph | of this Fourth Count as if more fully set forth herein. Taxes in the amount of $6,386.72 were duly and properly assessed upon this property, on the list of October 1, 2020 and became due and payable on July 1, 2021 and January 1, 2022 and the taxes are a lien on this property. No part of the tax has been paid On April 1, 2022, the City of Bridgeport duly and properly filed and caused to be recorded in the land records of the City of Bridgeport a certificate oflien for the tax together with interest fees and charges thereon in 4 Greene Law, P.C. | 11 Talcott Notch Road | Farmington, CT 06032 Tel: 860-676-1336 1 Fax: 860-676-2250 1 E-Service: service@greenelawpc.com Volume 10750 at Page 21 of the Bridgeport Land Records. 5 By Assignment of tax lien recorded in Volume 10799 at Page 109 of the Bridgeport Land Records, the tax lien described herein was assigned from City of Bridgeport to TLOA ofCT,LLC. 6-8. Paragraphs 6 through 8 of the First Count are incorporated herein and made Paragraphs 6 through 8 of this Fourth Count. 5 Greene Law, P.C. | 11 Talcott Notch Road | Farmington, CT 06032 Tel: 860-676-1336 1 Fax: 860-676-2250 1 E-Service: service@greenelawpc.com WHEREFORE, the Plaintiff claims: 1 A foreclosure of the lien pursuant to Connecticut General Statute §12-181; 2. Immediate possession of the premises; 3 Attorney's fees pursuant to Connecticut General Statute §12-193; 4 Interest pursuant to Connecticut General Statute§ 12-146; Costs pursuant to Connecticut General Statute §12-193; That a receiver be appointed to collect the rents and profits accruing from said premises; and Such other relief in law or equity as may appertain. THE PLAINTIFF, /s/ 102078. Gary J. Greene, Esq. Greene Law, P.C. Its Attorney 11 Talcott Notch Road Farmington, CT 06032 Juris No.: 428354 6 Greene Law, P.C. | 11 Talcott Notch Road | Farmington, CT 06032 Tel: 860-676-1336 1 Fax: 860-676-2250 1 E-Service: service@greenelawpc.com REFURN DAT PEBRUAR 2$.2023 SUPERIOR COURT J.D. OF FAIRFIELD NO: FBT-CV23-6121803-S AT BRIDGEPORT TLOA OF CT, LLC JANEPARY 18,2023 vs. APRIL 2. 2024 ROBERT A. MONTELEONE LIVING TRUST, ET AL STATEMENT. : AMOUNT IN DEM. The Plaintiff, TLOA OF CT, LLC, claims money damages of more than $2,500.00, exclusive of statutory interest and costs. THE PLAINTIFF, /s/ 102078 Gary J. Greene, Esq. Greene Law, P.C. Its Attorney 1] Talcott Notch Road Farmington, CT 06032 Juris No.: 428354 7 Greene Law, P.C. | 11 Talcott Notch Road | Farmington, CT 06032 Tel: 860-676-1336 1 Fax: 860-676-2250 1 E-Service: service@greenelawpc.com EXHIBIT A That certain piece or parcel of land with the buildings thereon, situated in the City of Bridgeport, County of Fairfield, and State of Connecticut and bounded and described as follows, to wit: NORTH: On land nor or formerly of Juliette Meaney, 65 feet; EAST: On Kent Street, now Anton Drive, 116 feet, more or less; SOUTH: On land now of Mary Peluchette, 65 feet; WEST: On land now or formerly of Pasquale Aldo, 116 feet, more or less. Said premises are also known as No. 45 Anton Drive. 8 Greene Law, P.C. | 11 Talcott Notch Road | Farmington, CT 06032 Tel: 860-676-1336 1 Fax: 860-676-2250 1 E-Service: service@greenelawpc.com Aft Ri rn Greene Law, PC XAT. DVD 11 Talcott Notch Road Farmington. CT 06032 RETURN FEBRUARY DATE: 28,2023 SUPERIOR COURT NO: FBT-CV23-6121803-S TLOA OF CT, LLC ET AL JD OF HARTFORD VS. AT HARTFORD ROBERT A. MONTELEONE LIVING TRUST, MANUEL RAMOS, WATER POLLUTION CONTROL AUTHORITY AQUARION WATER COMPANY JANUARY 18,2023 APRIL2. 2024 AMENDED NOTICE OF LIS PENDENS Notice is hereby given of the pendency of a civil action between the above-named parties by complaint and summons thereon, dated JANUARY 18, 2023 and made returnable to the Superior Court for the Judicial District of Fairfield at Bridgeport on FEBRUARY 28, 2023. which Notice amends the Lis Pendens Dated JANUARY 18, 2023, and recorded on January 27 2023 in Volume 10935 at Page 141 etal of the Bridgeport land records with regards to this action that seeks action-is-broughtto foreclose the following Tax Liens recorded in Volume 9992 at Page 153, Volume 10209 at Page 8, Volume 10416 at Page 138, and Volume 10750 at Page 21 Said Tax Liens were assigned to TLOA OF CT, LLC by an Assignment of Real Property Tax Liens recorded in Volume 10013 at Page 258; Volume 10224 at Page 1, Volume 10448 at Page 74, and Volume 10799 at Page 109; all of the Bridgeport Land Records. Such action specifically requests the following 1 A foreclosure of said tax liens. 2 Immediate possession of the premises 3 A deficiency judgment. No deficiency will be sought against any person whose obligation under the subject promissory note has been heretofore or hereafter 9 Greene Law, P.C. | 11 Talcott Notch Road | Farmington, CT 06032 Tel: 860-676-1336 1 Fax: 860-676-2250 1 E-Service: service@greenelawpc.com discharged in bankruptcy. The appointment of a receiver to collect rents and profits accruing from the premises. Reasonable attorney's fees and costs. Such other relief and further equitable relief as may be required. The Premises is that certain real property with buildings thereon, situated in the City of Bridgeport, County of Fairfield, and State of Connecticut, which is at 45 Anton Drive, more particularly bounded and described as set forth in Exhibit A, attached hereto and incorporated by reference as if herein set forth verbatim. Dated at Farmington, Connecticut, RESPECTFULLY SUBMITTED PLAINTIFF, /s/ 102078 Gary J. Greene, Esq. Greene Law, P.C. Its Attorney 11 Talcott Notch Road Farmington, CT 06032 Juris No.: 428354 10 Greene Law, P.C. | 11 Talcott Notch Road | Farmington, CT 06032 Tel: 860-676-1336 1 Fax: 860-676-2250 1 E-Service: service@greenelawpc.com EXHIBIT A That certain piece or parcel of land with the buildings thereon, situated in the City of Bridgeport, County of Fairfield, and State of Connecticut and bounded and described as follows, to wit: NORTH: On land nor or formerly of Juliette Meaney, 65 feet; EAST: On Kent Street, now Anton Drive, 116 feet, more or less; SOUTH: On land now of Mary Peluchette, 65 feet; WEST: On land now or formerly of Pasquale Aldo, 116 feet, more or less. Said premises are also known as No. 45 Anton Drive. 11 Greene Law, P.C. | 11 Talcott Notch Road | Farmington, CT 06032 Tel: 860-676-1336 1 Fax: 860-676-2250 ; E-Service: service@greenelawpc.com NO: FBT-CV23-6121803-S SUPERIOR COURT TLOA OF CT, LLC ET AL JD OF HARTFORD VS. AT HARTFORD ROBERT A MONTELEONE APRIL 2, 2024 LIVING TRUST, et al AMENDED TAX LIEN FORECLOSURE COMPLAINT. T COUN’ E: (2017 Tax Lien on 45 Anton Drive, Bridgeport 9 The Defendant, Manuel Ramos , is the record owner of real estate known as 45 Anton Drive, Bridgeport, CT, bounded and described as follows: SEE ATTACHED EXIDBIT A 10. Taxes in the amount of $3,235.29 were duly and properly assessed upon this property, on the list of October 1, 2017 and became due and payable on July 1, 2018 and January 1, 2019 and the taxes are a lien on this property. . 11. No part of the tax has been paid. 12. On April 2, 2019, the City of Bridgeport duly and properly filed and caused to be recorded in the land records of the City of Bridgeport a certificate of lien for the tax together with interest fees and charges thereon in Volume 9992 at Page 153 of the Bridgeport Land Records. 13. By Assignment of tax lien recorded in Volume 10013 at Page 258 of the Bridgeport Land Records, the tax lien described herein was assigned from 12 Greene Law, P.C. | 11 Talcott Notch Road 1 Farmington, CT 06032 Tel: 860-676-1336 1 Fax: 860-676-2250 1 E-Service: service@greenelawpc.com the City of Bridgeport to TLOA of CT, LLC. 14. The following encumbrances are subsequent to the interest of the plaintiff being foreclosed herein. a. The Defendant, Water Pollution Control Authority, claims or may claim an interest in the subject premises by virtue of any sewer charges and/or liens as the same may be recorded or assessed against the property. b The Defendant, Aquarion Water Company, claims or may claim an interest in the subject premises by virtue of any sewer charges and/or liens as the same may be recorded or assessed against the property. 15. The Defendant, Manuel Ramos, owns the premises and is in possession thereof. 16. A true and attested copy of the Amended-Lis Pendens to be recorded on the Bridgeport Land Records giving notice of the institution of this foreclosure action is attached hereto as Exhibit B and made a part hereof, in accordance with the provisions of C.G.S. §52-325. COUNT TWO: (2018 Tax Lien 45 Anton Drive. idge| rt.C 1 Paragraph 1 of Count One is hereby incorporated as Paragraph | of this Second Count as if more fully set forth herein. Taxes in the amount of $6,425.36 were duly and properly assessed upon this