Preview
. .
SUMMONS - CIVIL STATE OF CONNECTICUT
JD-CV-1 Rev. 4-16
51-346, 51-347, 51-349, 51.350, 52-45a, SUPERIOR COURT
58 8: 259, P.B. §§ 3-1 through 3-21, 8-1, 10-13 www,jud.ct.gov
See other side for instructions
"X" if amount, legal interest or property in demand, not including interest and
oO costs is less than $2,500.
"X" if amount, legal interest or proper ty in demand, not including interest and
& costs is $2,500 or more.
(J "x" if claiming other relief in addition to or in lieu of money or damages.
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 court clerk where writ and other papers shall be filed (Number, street, town and zip code) | Telephone number of clerk Return Date (Musibe a Tuesday)
(C.G.S. §§ 51-346, 51-350) (with area code) ~
50 FIELD STREET, TORRINGTON, CT 06790 (860 ) 626-2100 “pay Year
(own in which wits returnable) (C.G.S. §§ 51-346, 51-349) Case
type code (See list on page 2)
“Px] dudicial District
[J Housing Session
0 sa
Number: be
[x RRINGTON Major: C Minor: 40 *
For the Plaintiff(s) please enter the appearance of:
Name and address of allorney, law firm or plaintiffif self-represented (Number, street, town and zip code) Juris number (tobe onfared
by attomey only)
CharlesT. Busek, PC. P-O Box,759, Norwalk, CT 06852 100330
Telephone number (with area code) Signature of Plaintiff (if self-represented)
(203 ) 838-4466
‘The attorney or faw firm appearing for the plaintiff, or the plaintiff if Email address for delivery of papers under Section 10-13 (agreed fo)
self-represented, agraes to accept papers (service) electronically in {X] yes (JNo buseklaw@gmail.com
this case under Section 10-13 of the Connecticut Practice Book.
Number of Plaintiffs: 1 Number of Defendants: 41 CO Form JD-CV-2 attached for additional parties
Parties Name (Last, First, Middle Initial) and Address of Each party (Number; Street; P.O, Box; Town; State; Zip; Country, if not USA)
Name: KENT SCHOOL CORPORATION pot
First om
Plaintiff Address: 4 W/ACEDONIA ROAD, KENT, CT 06757 Be =
Additional Name: = e waa P02
Plaintiff Address: i BS
Name: D-01
First HAMMOUD, JAMAL oC
Defendant Address: _4 VIOUNTAIN LAUREL DRIVE, GREENWICH, CT 06831
Name: HAMMOUD, ELISSAR a D-02
Additional
Defendant Address: 4 MOUNTAIN LAUREL DRIVE, GREENWICH, CT 06831 7
D-03
Additional Name:
Defendant Address: nh
Name: D-04
Additional
Defendant Address:
Notice to Each Defendant
4. YOU ARE BEING SUED. This paper is a Summons in a lawsuit. The complaint attached to these papers states the claims that each plaintiff is making
against you in this lawsuit.
2. To be notified of further proceedings, you or your attorney must file a form called an "Appearance" with the clerk of the above-named Court at the above
Court address on or before the second day after the above 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 come to court.
3. If you or your attorney do not file a written "Appearance" form on time, a judgment may be entered against you by default. The "Appearance". form may be.
obtained at the Court address above or at www,jud.ct.gov under "Court Forms."
4, If you believe that you have insurance that may cover the claim that is being made against you in this lawsuit, you should immediately contact your
insurance representative, Other action you may have to take is described in the Connecticut Practice Book which may be found in a ‘superior court law £
library or online at www,jud.ct.gov under "Court Rules.”
5. If you have questions about the Summons and Complaint, you should talk to an attorney quickly. The Clerk of Court is not allowed to give advice on
legal questions. 8
‘Commissionerof the | Name of Person Signing at Left Date signed
‘Signed (Sign and "X" proper box) iy ‘Superior Court
Charles T. Busek
Assistant Clerk
{f this Summons is signed by a Clerk: For Court Use Only
a. The signing has been done so that the Plaintiff(s) will not be denied access to the courts, File Date
b. Itis the responsibility of the Plaintiff(s) to see that service is made in the manner provided by law.
. The Clerk 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.
.
I certify | have read and | Signed (Self-Represented Plaintif) Date Docket Number
understand the above: ULAEvHS01 6410
(Page T of 2) t
ERSSSEESTEE]
4
’ . .
Instructions
1. Type or print legibly; sign summons.
2. Prepare or photocopy a summons for each defendant. a
3. Attach the original summons to the original complaint, and attach a copy of the summons to each copy of the complaint. Also, if there are
more than 2 plaintiffs or more than 4 defendants prepare form JD-CV-2 and attach it to the original and all copies of the complaint.
4. After service has been made by a proper officer, file original papers and officer's return with the clerk of court.
5. Do not use this form for the following actions:
(a) Family matters (for example divorce, child support, (f) Proceedings pertaining to arbitration
custody, paternity, and visitation matters) (g) Any actions or proceedings in which an attachment,
(b) Summary Process actions garnishment or replevy is sought
(c) Applications for change of name (h) Entry and Detainer proceedings
(d) Probate appeals (i) Housing Code Enforcement actions
(e) Administrative appeals
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 o
the ADA, contact a court clerk or an ADA contact person listed at www,jud.ct.gov/ADA.
Case Type Codes
Codes Codes
Major Deseri tion Major! Minor Description Major Description Major! Minor Description
Minor Minor
Contracts C00 Construction - All other Property P00 Foreclosure
c10 Construction - State and Local P10 Partition
20 Insurance Policy P20 Quiet Title/Discharge of Mortgage or Lien
30 Specific Performance P30 Asset Forfeiture
cao Collections P90 Allother
C90 Allother
Torts (Other than T02 Defective Premises - Private - Snowor Ice
Eminent Domain E00 State Highway Condemnation Vehicular) T03 Defective Premises - Private - Other
E10 Redevelopment Condemnation TH Defective Premises - Public - Snow or Ice
£20 Other State or Mur ipal Agencies T12 Defective Premises - Public - Other
£30 Public Utilities & Gas Transmission Companies T20 Products Liability - Other than Vehicular
E90 All other T28 Malpractice - Medical
T29 Malpractice - Legal
Miscellaneous moo Injunction T30 Malpractice - All other
M10 Receivership T40 Assault and Battery
M20 Mandamus T50 Defamation
M30 Habeas Corpus (extradition, release from Penal Té61 Animals - Dog
Insti tion) T69 Animals - Other
40 Arbitration T70 False Arrest
M50 Declaratory Judgment 7H Fire Damage
M63 Bar Discipline T90 Allother
mes Department of Labor Unemployment Compensation
Enforcement vot Motor Vehicles* - Driver and/or Passenger(s) vs.
Vehicular Torts
M68 Bar Dis ipline - Inactive Status Driver(s)
M70 Municipal Ordinance and Regulation Enforcement vo4 Motor Vehicles" - Pedestrian vs. Driver
Meo Foreign Civil Judgments - C.G.S. 52-604 & C.G.S. vos Motor Vehicles* - Property Damage only
50a-30 vos Motor Vehicle” - Products Liability Including Warranty
mga ‘Small Claims Transfer to Regular Docket vos Motor Vehicle" - All other
M84 Foreign Protective Order vio Boats
mg0 Allother v20 Airplanes
Housing H10 Housing - Return of Security Deposit v30 Railroads
H12 Housing - Rent and/or Damages v40 ‘Snowmobiles
H40 Housing - Audita Querela/Injunction v90 Allother
H50 Housing - Administrative Appeal *Motor Vehicles include cars, trucks, motorcycles,
H6O Housing - Municipal Enforcement and motor scooters.
H90 Housing - All Other
Wills, Estates wo Construction of Wills and Trusts
and Trusts wao Allother
i
JD-CV-1 Rev, 4-16 (Back/Page 2)
(Page 2 of 2)
LULTCVANSD) © [0
RETURN DATE SUPERIOR COURT
KENT SCHOOL CORPORATION
J:D. OF LITCHFIELD
V. AT TORRINGTON
JAMAL HAMMOUD AND
ELISSAR HAMMOUD MAY 2024
“ COMPLAL NT 4
1 _The Plaintif Kent “School | Corporation, isa corporation with aa place ofof business
locatéd at-1Macé laa Road, Ke "Connecticut. -
ag
BZ 2. ~@nor about April 10, 2022, the Plaintiff and the Defendants, Jamal Harfimoud and
Zaz
Bd Elissar Hammoud, entered into an enrollment agreement for Ryan Hammoud, the son of the
%
gz
BO Defendants, for his tuition and education costs at-Kent School, for his.attendance for.the 2022-
an 2023 school year. The enrollment agreement is attached hereto-and incorporated herein as
Exhibit 1 -
Of
3. The Plaintiff Provided the education services called for in the Agreement. The
Defendants have failed to pay: for the tuition fees and. balance of their son's. education costs. The
Defendants owe the. principal sum of Sixty One Thousand Four Hundred and Six ‘Dollars and
ae
Twenty Five Cents (61, 406. 26) plus reasonable attomey Ss feos and late
la fees at the’ rate of 1. 5%
- ~-
per month -
4. Despite demand, Defendants have failed, and refused .to pay said sum which is,
F
due and owing
5. There are no set-offs, counterclaims or defensés to this action,
6 Defendants, reside at 4 Mountain Laurel Road, Greenwich, Connecticut.
WHEREFORE. Plaintif Claims:
Money Damages;
Interest;
Costs of Collection;
Attorney Fees; %*
Such other relief as the Court deems is fair and equitable.
~
AND-NOTICE.IS. HEREBY. GIVEN TO. THE DEFENDANTS THAT RLAINTIFF INTENDS TO
SEEK SATISFACTION OF ANY JUDGMENT RENDERED IN ITS FAVOR IN THIS ACTION FROM
ANY DEBT ACCRUING -TO DEFENDANTS BY REASON OF THEIR PERSONAL SERVICES.
THIS IS AN:ATTEMPT, TO COLLECT THE DEBT AND ANY INFORMATION OBTAINED
a5 WILL BE USED: FOR THAT PURPOSE, : - ~
Lo ATTORNEY FOR THE PLAINTIFF,
2
a O B =
ge Charles T.. Busek
Ba
A. P.O. Box 759
Bx Norwalk, CT 06850
(203) 838-4466
Juris No. 100330
EXHIBIT “1”
EXHIBIT 1
KENT SCROOL
StudentID Student Form Entering Residency Group Date
of Birth
ATGTSA Ryan Hammoud PG Boarding Comestic Sep
2, 2004
This Enrollment Agreement Js entered Into by the Kent School Corporation ("Kenl,” “Kent School,” or the “Schoor") and the
barents) or egal guardians) of Ryan Hammous (Ue"), The School the Shident, and Uwe understand, acknowiedge and agres as
ES
By signing this Agreement, lve enroll Ryan Hammoud (‘the Student’), 8s 8 Boarding student for the 2022-2023 school year, based upon
the terms and conditions stated herein and contingent upon the Student's successful completion of the current school year. whether at Kent
or elsewhere, in good academic, disciptinary, and financial standing, as determined by the Schoal In its sole discretion.
~
By signing this Agreement, Uwe also confirm that al the information provided to Kent in the application for enrofiment af the Student is
complete and accurate. lwe understand that Kent relies upon the completeness and accuracy of the information contained in sald
application and live agree that If any of that information is found not to be truthful, the Student may be subject fo discipline up to and
inctuding dismissal from the School.
This Agreement must be signed and the non-refundable Enrolimant Deposit must ba paid by April 10, 2022 (‘Agreement
Due Data’) in
order to secure the Student's enrofmant for the 2022-2023 school year.
Se
Tultion $69,950.00
‘Standard Fees $2,075.60
oe ems fete nant -
Net Tuition and Fees $72, 025. 68
ei ncn cet
Enrolment Deposit $1
Tuition Belence
Security Depostit : $500.68
New Student Registration $185.00
igation 5a
Tare: ih)
IWwe understand that our obligalion to pay the Tuition and Fees, as described in Section Il. for the full 2022-2023 academic year is
unconditional ang that after July 1. 2022, no portion of the Tuitlon of Fees, paid or outstanding, will be refunded or cancelled in the event of
absence, exclusion, withdrawal, or dismissat of the Student from the School, With this understanding, we acknowledge thal Uwe are
required to enroll in the A.W.G. Dewar Tuilion Refund Insurance Plan (“TRP”) if we do not pay the full year’s Tuition and Fees by
September 1. 2022. The TRP premium equats 3.5% of Net Tuition and Fees. Uwe further understand that if the full year’s Tuition and Foes.
CONTRACT: O16 098 PAGE
1 CF 8 PRINTED: NOV 15, 2023 10:5? AK
we
KERT
do not pay all Tuition and
is paidby September 1, 2022, |then wwe can decline TRP by selecting he box below. If tive decline TRP and
to pay, the TRP premium.
Fees by September 1, 2022, then lie will be charged, and Uwe agree
TRP
sof the brochur e. In accordance with the TRP, hve authorize q
‘we have received a copy of the policy outlining the terms and condition
the TRP and to apply such payment lo the Student's.
Kent Schoo! (0 process and collect any claim payment to which Ive are entilled under
after applying any claim payment, or in the event that the
account, paying any excess to me/us. if a balance owedto Kent School remeins
by the TRP, then we agree fo pay Kent School al remaining amounts
Student's absance, exclusion, withdrawal or dismissal 1 1s not covered
due under this Agreement.
Tercera earn Ch Ga oF]
ACCEPT: | eect to enroll in the Tuition Refund Insurance Plan.
$2,520.88
and therefore decline the
DECLINE: | agree to pay the total Financial Obligaton by September 1, 2022
‘Tuition Refund Insurance Plan,
a aan i
all Tuition and Fees. Please select one of the payment
Kent School uses VCPay Tuillon Management by Veracross to process and collect it must be paid by the Agreement
arder to finalize the ‘Student's enrolment, the non-refundable Enrolment Depost
plans outlined betow. In
Due Date.
Piease select one of the payment plans below:
OQ One Pay - ACH or Credit Card (U.S. Banks Only)
One invoice generated June 1 and full financial obligation due by June 20. (U.S. Benks Only)
& Two Pay Plan - June/Aug
Two Invoices generated (TRP optional; payments mada via ACH, credit card or wire transfer):
and tuition refund plan premium due June 30,
+ dune 4 for 60% of the financial obligation (less deposit)
« August 4 for 40% of the financial objigation (less deposit) due August 31.
oa Two Pay Plan - June/Nov (TRP & AutoPay required)
ACH, credit card or wire tranofor):
Two invoices generated (TRP required, AutoPay through VCPay Is required; payments made via
+ dune 1 for 60% of the financial obligation (less deposit} and tuition refund plan premum due June 30.
due November 30.
+ November 4 for 40% of the financial obfigation (tess deposit)
a
Ten Pay Plan (5th of each month, TRP required)
required, and the premium
Ten equal monthly payments will be due on the Sth of each month beginning in June. Tu'ton refund Insurance is
fee apphes:
ts due with (he firs! payment. AutoPay through VGPay is required. Two percent (2.0%) payment plan
BDownlosd
Tash in Landing Disclosura
Paymant Plan Fee: $1,224.43
O32 USS BAGE 2 OF D PRINTED: NOV 1G, 2023 10:57 AM
*
eh
RENT STECOL
,
co Ten Pay Plan (20th of each month, TRP required) the Brammurn,
Ten equal monthly payments wil i] be due on the 20th of each
month beginning 1n June. Tultion refund insurance Is required, and
{2.0%) payment plan fae applies.
is dye with the first payment. Aut toPay through VCPay Is required. ‘Two percent
oa
in Lendina
Truthnl
(Dow d re
Disclosu
Payment Plan Foe: $1,224.43
a
the Student recognize thal the offer of Financial Aid is for the current
the Student is offered a Financial Ald grant from the School. Uwe and grant-
ion, and verification of current, signed tex farms and other
academic year onty and is contingent upon the receipt, review, evaluat
Aid Office.
related documentation required by the Financial
a oe
paid upon signing this Agr gamont and no later than he
A nor-refundabte Enrollment Deposit in the amount of $10,603.75 must be Due
Deposit is not paid by the Agreement
Agreement Dus Dale to enroll for the 2022-2023 school year. if the non-refundable Enrollment
acceptan ce for the 2022-202 3 academi c year.
Date, Kent reserves the right to revoke the Student's
-
we further agree to pay the Tuition and Fees related to the Student's
enrollment on or before due dates as sel forth according tothe |
agree that in the event the ‘Student is absent, exciuded , -
payment pian Ifve have chosen in Section !V, Furthermore. Uwe understand and of the school year, lfwe remain fully
voluntarily or involuntarily withdraws from Kent, oris dismissed by Kent for any reason before the end
Any outstand ing balance will be immediataly due and payable if the
rasponsibie for payment of all remaining Tuition and Fees owad to Kent.
Student withdraws orIs dismissed from the School.
‘Wwe further agree to pay all fees, including (hose for books, supphes, Incidental ex; panses, and
other charges Incurred by the Student which
are nol part of the Tuition or Fees in Section Il or covered by Financial Aid or other sourc of es
funding (collectively referred to as “Other
Charges’). Ifwe agree lo pay these charges ‘each month within 30 days of each bit! issued by Kent. Click
hare for examples of Other
Charges
payment from almost any
‘amilies wishing to pay tuition with foreign cul rrancy may do so via Flywire, which allows individuals to submil
when payment
country and any bank, Families using Flywire wi} be able to track the progress of payment and raceive notification by email
is received by Kent. Families can visit Elywire to make payment.
up two billing accounts.
As an accommodation for parents or guardians who wish to establish separate billing accounts, the School may set
that, even if separate accounts are established, IWve are Jointly and severally liabte for the entirety of Tuition.
Io understand and agree
tiwe further understand that the
Fees and Other Charges due under this Agreement, whether or not one of the accounts is delinquent.
‘School will not become involved in payment disputes between or among Ainancsaly responsible parties.
GIRO eel Armies Ta
2022, without ;
tAve understand that Wwe may cancel this Agreement by providing a written, signed nolce to Kent School on or before July 1,
after July 1, 2022, we
penalty except forfeiture Of the non-refundable Enrollment Deposit which equals $10.803,75. we understand that
ly oF involuntarily withdraws from ‘:,
are obligated to pay all Tuition, Fees and Other Charges even if tha Student is absent. exctuded, valuntasi
Kent or is dismissed by Kent for any reason before the end af the school year.
iy
(we further agree that If any payment under this Agreement is delinquer nt, Kent may assess 0 monthly ate fee atthe rata of 1.5% pet
paid in full, Retumed checks will be assessed a $30 processing fee. Wwe
enonth, or the maximum amount permitted by law, unt! the bills
=
wee
213 oN Tank Se QRiNTED: NOV 1S. 2025 19:97 aH
PRACT
i
KENT SCHOOL
further agree to pay, to the extent permitted by law, any expenses wk, in the collaction of Tuition, Fees and Other Charges or
tn otherwise enforcing Kent's rights under (ns Agreement, including reasonable attornays’ and accountants’ fees and expenses.
class, examinalion. or :
anying
\we understand that if payments are not current, Kent may prohibit the Student from starting school or altend
examination s. The Schao! may also
schoo! activity Including athletic practices and games and extracurricular activilles, and from taking
of each trimester. tAwe further understand and agree
disenroil the Student if all outstanding charges have not been pald by the beginning allowed by law,
reports, or di iplomas unhi the Student's account is paid in ful. To the extent
that the Schoo! may refuse to issue transcripts,
awarded, transcripts and references provided,
‘only when accounts are pald in full and al Agreement provisi Jons are mat will diplomas be
School may delay enforcing any of iis ~
invitations for re-anrollment issued, and participation in commencement exercises p ermitted. Tha
including accepting tate or partial payments. Forbearanc e on any one pay! meant does not affect
Fight s under this Agreement,
or remedies
Kent's rights to declare a defauit on thal or any subsequent payment.
‘The financial obligations set forth in this Agreement are uncondilional, and no portion of the Tul
iHlon, Fees, Other Charges will be
refunded or cancelled for any student for any reson, including in the event that some or all of the
Schoo!'s facifities are closed or rendered
civil unrest, flood, earthquake, or any other cause .
unavallable for reasons including, but not limited to, fire, acts of God, tarrorism, pandamic,
the
beyond the Schoot's reasonably foreseeable control, Including eny mechanical, etectronic, or communica
tions failure, in the event
e education al Instructio n on or off campus. and
School Is closed for any reason, the School may, but Is not required to, provide altemativ
Student are expected ta comply
such instruction may extend beyond the scheduled academic year. In such circumstances, le and the
with all changes in location or method of instruction, academic requirements, and the Schoo! calendar. tAve ut inderetand thal the obligation to
pay alt Tultlon, Fees and Other Charges for the full academic year, as set forth in this Agreement, will remain in ful} force and effect in the
of any reasonably unforeseeable schoo! interruption or closing.
‘evant of the occurrence
Iwe understand and agree that the School can make changes related to School operations, including but not fimited to its curriculum,
that the
courses, programming, leacher assignment, and student-teacher ratio at ts sole discretion. tiwe further understand and egree
‘School has no obligation to modify, amend, or provide an attemative educational program for (he Student, who may be absent for
disciptnary, medical, extended vacation, and/or any other reason. This Agreement entitles the Student to enroll and participate n School:
outcome in
programs consistent with School rutes and policies and should not be construed as a guarantee of specific success or certain
any academic, athletic, extracurricular, or other area of school programming.
SPS Tet) TCE Cra
Itwe acknowledge and understand the nature of the Schoof's programs and actuities, including Kent's extracuriculot, athletic and
ceskential activities. we understand thal Kent may uthze digital teaming platforms, software programs, ontine or 3rd party applications a8 ...
pant of its institutonal program and that onfine instruction and actvities may be recorded or fivestreamed and twe authorize the School lo. -..,,.
consent on my/our behalf to the Student's use of or participation in such digital or online programs thet are part of the School's programs.
jh this understanding, tWwe further agree that the Student may take part in: (i) all school-sponsored activities, whether on or off campus,
including all extracurricular and athletic activitie (i) onbna instruction, and (\i!) school-sponsored trips and has my/our permission to travel
in vehicles owned, operated, authorized or chartered by the School, liwe understand that | must provide written notice to Kent to restrict
such activities and agree fo complete and promptly retum any requested or required permission slips, releases and/or other forms related to:
school activities.
i ret ROMs TE
Uwe and the Student have read, understand end will abide by Kent’s rules and regulations as stated in the Student and ParentiGuardi
.
Handbook ('Handbook’) and other School policies as they may be adopted, modifiad, or revised by the ‘School during the Student's period
rep
CONTRACT: GLA O88 PAGE 4 OF @ PRINTED: NOV 23, 2023 10:57 AM
DOR *
&
zt
Student must comply with these
of enrollment. we understand that the Handbook does not constitute a contract bul that lwe and the
policies, rules and standards at ail mes. In the event ol any inappropriate behavior, fa.iure to meet the School's academic standards, or
messure
violation of the Schoo!'s regulations or policies on the partof the Student, the School reserves the rightto employ any disciplinary
reserves the right within its sole discretion to determine wheat
up to, and including, immediate dismissal from the School, The School
or policy.
constitutes “appropriate behavior,” failure to meat academic standards, and/or a violat.on of a Schoo! regutatlon
een aee] ra PSiie
or other adults and/or chitdren
A positive and constructive relationship between the School ar nd the Student's parent(sV/guardian{s)
interacting with the School andfor School community by virtue of thelr relationship with the Student Is essential to the mission of the School.
Thus, Kent reserves the right to dismiss or suspend the Student, of require the Student's withdrawal at any time, If the Schoo! conchudes in
interacting vath the School and/cy,
is sole discretion that the actions of the Student's parent{s¥guardian(s) or ol ther adults and/or children
the Student violate Schoo! or rutes, impede the School's ability to meet its.
Schoo} community by virtue of their retationship with policies
the Schoo! regarding
School, The decision of
educational objectives or mission, or jeopardize a positive or constructive relationship with the
discontinuing the Studant's enroiiment shall be final and not subject to arbitration as set forth batow,
nah
w
Preview
. . SUMMONS - CIVIL STATE OF CONNECTICUT JD-CV-1 Rev. 4-16 51-346, 51-347, 51-349, 51.350, 52-45a, SUPERIOR COURT 58 8: 259, P.B. §§ 3-1 through 3-21, 8-1, 10-13 www,jud.ct.gov See other side for instructions "X" if amount, legal interest or property in demand, not including interest and oO costs is less than $2,500. "X" if amount, legal interest or proper ty in demand, not including interest and & costs is $2,500 or more. (J "x" if claiming other relief in addition to or in lieu of money or damages. 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 court clerk where writ and other papers shall be filed (Number, street, town and zip code) | Telephone number of clerk Return Date (Musibe a Tuesday) (C.G.S. §§ 51-346, 51-350) (with area code) ~ 50 FIELD STREET, TORRINGTON, CT 06790 (860 ) 626-2100 “pay Year (own in which wits returnable) (C.G.S. §§ 51-346, 51-349) Case type code (See list on page 2) “Px] dudicial District [J Housing Session 0 sa Number: be [x RRINGTON Major: C Minor: 40 * For the Plaintiff(s) please enter the appearance of: Name and address of allorney, law firm or plaintiffif self-represented (Number, street, town and zip code) Juris number (tobe onfared by attomey only) CharlesT. Busek, PC. P-O Box,759, Norwalk, CT 06852 100330 Telephone number (with area code) Signature of Plaintiff (if self-represented) (203 ) 838-4466 ‘The attorney or faw firm appearing for the plaintiff, or the plaintiff if Email address for delivery of papers under Section 10-13 (agreed fo) self-represented, agraes to accept papers (service) electronically in {X] yes (JNo buseklaw@gmail.com this case under Section 10-13 of the Connecticut Practice Book. Number of Plaintiffs: 1 Number of Defendants: 41 CO Form JD-CV-2 attached for additional parties Parties Name (Last, First, Middle Initial) and Address of Each party (Number; Street; P.O, Box; Town; State; Zip; Country, if not USA) Name: KENT SCHOOL CORPORATION pot First om Plaintiff Address: 4 W/ACEDONIA ROAD, KENT, CT 06757 Be = Additional Name: = e waa P02 Plaintiff Address: i BS Name: D-01 First HAMMOUD, JAMAL oC Defendant Address: _4 VIOUNTAIN LAUREL DRIVE, GREENWICH, CT 06831 Name: HAMMOUD, ELISSAR a D-02 Additional Defendant Address: 4 MOUNTAIN LAUREL DRIVE, GREENWICH, CT 06831 7 D-03 Additional Name: Defendant Address: nh Name: D-04 Additional Defendant Address: Notice to Each Defendant 4. YOU ARE BEING SUED. This paper is a Summons in a lawsuit. The complaint attached to these papers states the claims that each plaintiff is making against you in this lawsuit. 2. To be notified of further proceedings, you or your attorney must file a form called an "Appearance" with the clerk of the above-named Court at the above Court address on or before the second day after the above 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 come to court. 3. If you or your attorney do not file a written "Appearance" form on time, a judgment may be entered against you by default. The "Appearance". form may be. obtained at the Court address above or at www,jud.ct.gov under "Court Forms." 4, If you believe that you have insurance that may cover the claim that is being made against you in this lawsuit, you should immediately contact your insurance representative, Other action you may have to take is described in the Connecticut Practice Book which may be found in a ‘superior court law £ library or online at www,jud.ct.gov under "Court Rules.” 5. If you have questions about the Summons and Complaint, you should talk to an attorney quickly. The Clerk of Court is not allowed to give advice on legal questions. 8 ‘Commissionerof the | Name of Person Signing at Left Date signed ‘Signed (Sign and "X" proper box) iy ‘Superior Court Charles T. Busek Assistant Clerk {f this Summons is signed by a Clerk: For Court Use Only a. The signing has been done so that the Plaintiff(s) will not be denied access to the courts, File Date b. Itis the responsibility of the Plaintiff(s) to see that service is made in the manner provided by law. . The Clerk 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. . I certify | have read and | Signed (Self-Represented Plaintif) Date Docket Number understand the above: ULAEvHS01 6410 (Page T of 2) t ERSSSEESTEE] 4 ’ . . Instructions 1. Type or print legibly; sign summons. 2. Prepare or photocopy a summons for each defendant. a 3. Attach the original summons to the original complaint, and attach a copy of the summons to each copy of the complaint. Also, if there are more than 2 plaintiffs or more than 4 defendants prepare form JD-CV-2 and attach it to the original and all copies of the complaint. 4. After service has been made by a proper officer, file original papers and officer's return with the clerk of court. 5. Do not use this form for the following actions: (a) Family matters (for example divorce, child support, (f) Proceedings pertaining to arbitration custody, paternity, and visitation matters) (g) Any actions or proceedings in which an attachment, (b) Summary Process actions garnishment or replevy is sought (c) Applications for change of name (h) Entry and Detainer proceedings (d) Probate appeals (i) Housing Code Enforcement actions (e) Administrative appeals 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 o the ADA, contact a court clerk or an ADA contact person listed at www,jud.ct.gov/ADA. Case Type Codes Codes Codes Major Deseri tion Major! Minor Description Major Description Major! Minor Description Minor Minor Contracts C00 Construction - All other Property P00 Foreclosure c10 Construction - State and Local P10 Partition 20 Insurance Policy P20 Quiet Title/Discharge of Mortgage or Lien 30 Specific Performance P30 Asset Forfeiture cao Collections P90 Allother C90 Allother Torts (Other than T02 Defective Premises - Private - Snowor Ice Eminent Domain E00 State Highway Condemnation Vehicular) T03 Defective Premises - Private - Other E10 Redevelopment Condemnation TH Defective Premises - Public - Snow or Ice £20 Other State or Mur ipal Agencies T12 Defective Premises - Public - Other £30 Public Utilities & Gas Transmission Companies T20 Products Liability - Other than Vehicular E90 All other T28 Malpractice - Medical T29 Malpractice - Legal Miscellaneous moo Injunction T30 Malpractice - All other M10 Receivership T40 Assault and Battery M20 Mandamus T50 Defamation M30 Habeas Corpus (extradition, release from Penal Té61 Animals - Dog Insti tion) T69 Animals - Other 40 Arbitration T70 False Arrest M50 Declaratory Judgment 7H Fire Damage M63 Bar Discipline T90 Allother mes Department of Labor Unemployment Compensation Enforcement vot Motor Vehicles* - Driver and/or Passenger(s) vs. Vehicular Torts M68 Bar Dis ipline - Inactive Status Driver(s) M70 Municipal Ordinance and Regulation Enforcement vo4 Motor Vehicles" - Pedestrian vs. Driver Meo Foreign Civil Judgments - C.G.S. 52-604 & C.G.S. vos Motor Vehicles* - Property Damage only 50a-30 vos Motor Vehicle” - Products Liability Including Warranty mga ‘Small Claims Transfer to Regular Docket vos Motor Vehicle" - All other M84 Foreign Protective Order vio Boats mg0 Allother v20 Airplanes Housing H10 Housing - Return of Security Deposit v30 Railroads H12 Housing - Rent and/or Damages v40 ‘Snowmobiles H40 Housing - Audita Querela/Injunction v90 Allother H50 Housing - Administrative Appeal *Motor Vehicles include cars, trucks, motorcycles, H6O Housing - Municipal Enforcement and motor scooters. H90 Housing - All Other Wills, Estates wo Construction of Wills and Trusts and Trusts wao Allother i JD-CV-1 Rev, 4-16 (Back/Page 2) (Page 2 of 2) LULTCVANSD) © [0 RETURN DATE SUPERIOR COURT KENT SCHOOL CORPORATION J:D. OF LITCHFIELD V. AT TORRINGTON JAMAL HAMMOUD AND ELISSAR HAMMOUD MAY 2024 “ COMPLAL NT 4 1 _The Plaintif Kent “School | Corporation, isa corporation with aa place ofof business locatéd at-1Macé laa Road, Ke "Connecticut. - ag BZ 2. ~@nor about April 10, 2022, the Plaintiff and the Defendants, Jamal Harfimoud and Zaz Bd Elissar Hammoud, entered into an enrollment agreement for Ryan Hammoud, the son of the % gz BO Defendants, for his tuition and education costs at-Kent School, for his.attendance for.the 2022- an 2023 school year. The enrollment agreement is attached hereto-and incorporated herein as Exhibit 1 - Of 3. The Plaintiff Provided the education services called for in the Agreement. The Defendants have failed to pay: for the tuition fees and. balance of their son's. education costs. The Defendants owe the. principal sum of Sixty One Thousand Four Hundred and Six ‘Dollars and ae Twenty Five Cents (61, 406. 26) plus reasonable attomey Ss feos and late la fees at the’ rate of 1. 5% - ~- per month - 4. Despite demand, Defendants have failed, and refused .to pay said sum which is, F due and owing 5. There are no set-offs, counterclaims or defensés to this action, 6 Defendants, reside at 4 Mountain Laurel Road, Greenwich, Connecticut. WHEREFORE. Plaintif Claims: Money Damages; Interest; Costs of Collection; Attorney Fees; %* Such other relief as the Court deems is fair and equitable. ~ AND-NOTICE.IS. HEREBY. GIVEN TO. THE DEFENDANTS THAT RLAINTIFF INTENDS TO SEEK SATISFACTION OF ANY JUDGMENT RENDERED IN ITS FAVOR IN THIS ACTION FROM ANY DEBT ACCRUING -TO DEFENDANTS BY REASON OF THEIR PERSONAL SERVICES. THIS IS AN:ATTEMPT, TO COLLECT THE DEBT AND ANY INFORMATION OBTAINED a5 WILL BE USED: FOR THAT PURPOSE, : - ~ Lo ATTORNEY FOR THE PLAINTIFF, 2 a O B = ge Charles T.. Busek Ba A. P.O. Box 759 Bx Norwalk, CT 06850 (203) 838-4466 Juris No. 100330 EXHIBIT “1” EXHIBIT 1 KENT SCROOL StudentID Student Form Entering Residency Group Date of Birth ATGTSA Ryan Hammoud PG Boarding Comestic Sep 2, 2004 This Enrollment Agreement Js entered Into by the Kent School Corporation ("Kenl,” “Kent School,” or the “Schoor") and the barents) or egal guardians) of Ryan Hammous (Ue"), The School the Shident, and Uwe understand, acknowiedge and agres as ES By signing this Agreement, lve enroll Ryan Hammoud (‘the Student’), 8s 8 Boarding student for the 2022-2023 school year, based upon the terms and conditions stated herein and contingent upon the Student's successful completion of the current school year. whether at Kent or elsewhere, in good academic, disciptinary, and financial standing, as determined by the Schoal In its sole discretion. ~ By signing this Agreement, Uwe also confirm that al the information provided to Kent in the application for enrofiment af the Student is complete and accurate. lwe understand that Kent relies upon the completeness and accuracy of the information contained in sald application and live agree that If any of that information is found not to be truthful, the Student may be subject fo discipline up to and inctuding dismissal from the School. This Agreement must be signed and the non-refundable Enrolimant Deposit must ba paid by April 10, 2022 (‘Agreement Due Data’) in order to secure the Student's enrofmant for the 2022-2023 school year. Se Tultion $69,950.00 ‘Standard Fees $2,075.60 oe ems fete nant - Net Tuition and Fees $72, 025. 68 ei ncn cet Enrolment Deposit $1 Tuition Belence Security Depostit : $500.68 New Student Registration $185.00 igation 5a Tare: ih) IWwe understand that our obligalion to pay the Tuition and Fees, as described in Section Il. for the full 2022-2023 academic year is unconditional ang that after July 1. 2022, no portion of the Tuitlon of Fees, paid or outstanding, will be refunded or cancelled in the event of absence, exclusion, withdrawal, or dismissat of the Student from the School, With this understanding, we acknowledge thal Uwe are required to enroll in the A.W.G. Dewar Tuilion Refund Insurance Plan (“TRP”) if we do not pay the full year’s Tuition and Fees by September 1. 2022. The TRP premium equats 3.5% of Net Tuition and Fees. Uwe further understand that if the full year’s Tuition and Foes. CONTRACT: O16 098 PAGE 1 CF 8 PRINTED: NOV 15, 2023 10:5? AK we KERT do not pay all Tuition and is paidby September 1, 2022, |then wwe can decline TRP by selecting he box below. If tive decline TRP and to pay, the TRP premium. Fees by September 1, 2022, then lie will be charged, and Uwe agree TRP sof the brochur e. In accordance with the TRP, hve authorize q ‘we have received a copy of the policy outlining the terms and condition the TRP and to apply such payment lo the Student's. Kent Schoo! (0 process and collect any claim payment to which Ive are entilled under after applying any claim payment, or in the event that the account, paying any excess to me/us. if a balance owedto Kent School remeins by the TRP, then we agree fo pay Kent School al remaining amounts Student's absance, exclusion, withdrawal or dismissal 1 1s not covered due under this Agreement. Tercera earn Ch Ga oF] ACCEPT: | eect to enroll in the Tuition Refund Insurance Plan. $2,520.88 and therefore decline the DECLINE: | agree to pay the total Financial Obligaton by September 1, 2022 ‘Tuition Refund Insurance Plan, a aan i all Tuition and Fees. Please select one of the payment Kent School uses VCPay Tuillon Management by Veracross to process and collect it must be paid by the Agreement arder to finalize the ‘Student's enrolment, the non-refundable Enrolment Depost plans outlined betow. In Due Date. Piease select one of the payment plans below: OQ One Pay - ACH or Credit Card (U.S. Banks Only) One invoice generated June 1 and full financial obligation due by June 20. (U.S. Benks Only) & Two Pay Plan - June/Aug Two Invoices generated (TRP optional; payments mada via ACH, credit card or wire transfer): and tuition refund plan premium due June 30, + dune 4 for 60% of the financial obligation (less deposit) « August 4 for 40% of the financial objigation (less deposit) due August 31. oa Two Pay Plan - June/Nov (TRP & AutoPay required) ACH, credit card or wire tranofor): Two invoices generated (TRP required, AutoPay through VCPay Is required; payments made via + dune 1 for 60% of the financial obligation (less deposit} and tuition refund plan premum due June 30. due November 30. + November 4 for 40% of the financial obfigation (tess deposit) a Ten Pay Plan (5th of each month, TRP required) required, and the premium Ten equal monthly payments will be due on the Sth of each month beginning in June. Tu'ton refund Insurance is fee apphes: ts due with (he firs! payment. AutoPay through VGPay is required. Two percent (2.0%) payment plan BDownlosd Tash in Landing Disclosura Paymant Plan Fee: $1,224.43 O32 USS BAGE 2 OF D PRINTED: NOV 1G, 2023 10:57 AM * eh RENT STECOL , co Ten Pay Plan (20th of each month, TRP required) the Brammurn, Ten equal monthly payments wil i] be due on the 20th of each month beginning 1n June. Tultion refund insurance Is required, and {2.0%) payment plan fae applies. is dye with the first payment. Aut toPay through VCPay Is required. ‘Two percent oa in Lendina Truthnl (Dow d re Disclosu Payment Plan Foe: $1,224.43 a the Student recognize thal the offer of Financial Aid is for the current the Student is offered a Financial Ald grant from the School. Uwe and grant- ion, and verification of current, signed tex farms and other academic year onty and is contingent upon the receipt, review, evaluat Aid Office. related documentation required by the Financial a oe paid upon signing this Agr gamont and no later than he A nor-refundabte Enrollment Deposit in the amount of $10,603.75 must be Due Deposit is not paid by the Agreement Agreement Dus Dale to enroll for the 2022-2023 school year. if the non-refundable Enrollment acceptan ce for the 2022-202 3 academi c year. Date, Kent reserves the right to revoke the Student's - we further agree to pay the Tuition and Fees related to the Student's enrollment on or before due dates as sel forth according tothe | agree that in the event the ‘Student is absent, exciuded , - payment pian Ifve have chosen in Section !V, Furthermore. Uwe understand and of the school year, lfwe remain fully voluntarily or involuntarily withdraws from Kent, oris dismissed by Kent for any reason before the end Any outstand ing balance will be immediataly due and payable if the rasponsibie for payment of all remaining Tuition and Fees owad to Kent. Student withdraws orIs dismissed from the School. ‘Wwe further agree to pay all fees, including (hose for books, supphes, Incidental ex; panses, and other charges Incurred by the Student which are nol part of the Tuition or Fees in Section Il or covered by Financial Aid or other sourc of es funding (collectively referred to as “Other Charges’). Ifwe agree lo pay these charges ‘each month within 30 days of each bit! issued by Kent. Click hare for examples of Other Charges payment from almost any ‘amilies wishing to pay tuition with foreign cul rrancy may do so via Flywire, which allows individuals to submil when payment country and any bank, Families using Flywire wi} be able to track the progress of payment and raceive notification by email is received by Kent. Families can visit Elywire to make payment. up two billing accounts. As an accommodation for parents or guardians who wish to establish separate billing accounts, the School may set that, even if separate accounts are established, IWve are Jointly and severally liabte for the entirety of Tuition. Io understand and agree tiwe further understand that the Fees and Other Charges due under this Agreement, whether or not one of the accounts is delinquent. ‘School will not become involved in payment disputes between or among Ainancsaly responsible parties. GIRO eel Armies Ta 2022, without ; tAve understand that Wwe may cancel this Agreement by providing a written, signed nolce to Kent School on or before July 1, after July 1, 2022, we penalty except forfeiture Of the non-refundable Enrollment Deposit which equals $10.803,75. we understand that ly oF involuntarily withdraws from ‘:, are obligated to pay all Tuition, Fees and Other Charges even if tha Student is absent. exctuded, valuntasi Kent or is dismissed by Kent for any reason before the end af the school year. iy (we further agree that If any payment under this Agreement is delinquer nt, Kent may assess 0 monthly ate fee atthe rata of 1.5% pet paid in full, Retumed checks will be assessed a $30 processing fee. Wwe enonth, or the maximum amount permitted by law, unt! the bills = wee 213 oN Tank Se QRiNTED: NOV 1S. 2025 19:97 aH PRACT i KENT SCHOOL further agree to pay, to the extent permitted by law, any expenses wk, in the collaction of Tuition, Fees and Other Charges or tn otherwise enforcing Kent's rights under (ns Agreement, including reasonable attornays’ and accountants’ fees and expenses. class, examinalion. or : anying \we understand that if payments are not current, Kent may prohibit the Student from starting school or altend examination s. The Schao! may also schoo! activity Including athletic practices and games and extracurricular activilles, and from taking of each trimester. tAwe further understand and agree disenroil the Student if all outstanding charges have not been pald by the beginning allowed by law, reports, or di iplomas unhi the Student's account is paid in ful. To the extent that the Schoo! may refuse to issue transcripts, awarded, transcripts and references provided, ‘only when accounts are pald in full and al Agreement provisi Jons are mat will diplomas be School may delay enforcing any of iis ~ invitations for re-anrollment issued, and participation in commencement exercises p ermitted. Tha including accepting tate or partial payments. Forbearanc e on any one pay! meant does not affect Fight s under this Agreement, or remedies Kent's rights to declare a defauit on thal or any subsequent payment. ‘The financial obligations set forth in this Agreement are uncondilional, and no portion of the Tul iHlon, Fees, Other Charges will be refunded or cancelled for any student for any reson, including in the event that some or all of the Schoo!'s facifities are closed or rendered civil unrest, flood, earthquake, or any other cause . unavallable for reasons including, but not limited to, fire, acts of God, tarrorism, pandamic, the beyond the Schoot's reasonably foreseeable control, Including eny mechanical, etectronic, or communica tions failure, in the event e education al Instructio n on or off campus. and School Is closed for any reason, the School may, but Is not required to, provide altemativ Student are expected ta comply such instruction may extend beyond the scheduled academic year. In such circumstances, le and the with all changes in location or method of instruction, academic requirements, and the Schoo! calendar. tAve ut inderetand thal the obligation to pay alt Tultlon, Fees and Other Charges for the full academic year, as set forth in this Agreement, will remain in ful} force and effect in the of any reasonably unforeseeable schoo! interruption or closing. ‘evant of the occurrence Iwe understand and agree that the School can make changes related to School operations, including but not fimited to its curriculum, that the courses, programming, leacher assignment, and student-teacher ratio at ts sole discretion. tiwe further understand and egree ‘School has no obligation to modify, amend, or provide an attemative educational program for (he Student, who may be absent for disciptnary, medical, extended vacation, and/or any other reason. This Agreement entitles the Student to enroll and participate n School: outcome in programs consistent with School rutes and policies and should not be construed as a guarantee of specific success or certain any academic, athletic, extracurricular, or other area of school programming. SPS Tet) TCE Cra Itwe acknowledge and understand the nature of the Schoof's programs and actuities, including Kent's extracuriculot, athletic and ceskential activities. we understand thal Kent may uthze digital teaming platforms, software programs, ontine or 3rd party applications a8 ... pant of its institutonal program and that onfine instruction and actvities may be recorded or fivestreamed and twe authorize the School lo. -..,,. consent on my/our behalf to the Student's use of or participation in such digital or online programs thet are part of the School's programs. jh this understanding, tWwe further agree that the Student may take part in: (i) all school-sponsored activities, whether on or off campus, including all extracurricular and athletic activitie (i) onbna instruction, and (\i!) school-sponsored trips and has my/our permission to travel in vehicles owned, operated, authorized or chartered by the School, liwe understand that | must provide written notice to Kent to restrict such activities and agree fo complete and promptly retum any requested or required permission slips, releases and/or other forms related to: school activities. i ret ROMs TE Uwe and the Student have read, understand end will abide by Kent’s rules and regulations as stated in the Student and ParentiGuardi . Handbook ('Handbook’) and other School policies as they may be adopted, modifiad, or revised by the ‘School during the Student's period rep CONTRACT: GLA O88 PAGE 4 OF @ PRINTED: NOV 23, 2023 10:57 AM DOR * & zt Student must comply with these of enrollment. we understand that the Handbook does not constitute a contract bul that lwe and the policies, rules and standards at ail mes. In the event ol any inappropriate behavior, fa.iure to meet the School's academic standards, or messure violation of the Schoo!'s regulations or policies on the partof the Student, the School reserves the rightto employ any disciplinary reserves the right within its sole discretion to determine wheat up to, and including, immediate dismissal from the School, The School or policy. constitutes “appropriate behavior,” failure to meat academic standards, and/or a violat.on of a Schoo! regutatlon een aee] ra PSiie or other adults and/or chitdren A positive and constructive relationship between the School ar nd the Student's parent(sV/guardian{s) interacting with the School andfor School community by virtue of thelr relationship with the Student Is essential to the mission of the School. Thus, Kent reserves the right to dismiss or suspend the Student, of require the Student's withdrawal at any time, If the Schoo! conchudes in interacting vath the School and/cy, is sole discretion that the actions of the Student's parent{s¥guardian(s) or ol ther adults and/or children the Student violate Schoo! or rutes, impede the School's ability to meet its. Schoo} community by virtue of their retationship with policies the Schoo! regarding School, The decision of educational objectives or mission, or jeopardize a positive or constructive relationship with the discontinuing the Studant's enroiiment shall be final and not subject to arbitration as set forth batow, nah w