On October 21, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Summit Associates, Ltd., An Afghanistan Corporation,
Summit Associates, Ltd., A New York Corporation,
and
Abdul Rahman Yamrali,
for M50 - Misc - Declaratory Judgment
in the District Court of New Haven County.
Preview
REQUEST FOR ARGUMENT For information on ADA GE
STATE OF CONNECTICUT
NON-ARGUABLE CIVIL accommodations, SUPERIOR COURT
SHORT CALENDAR MATTER contact a court clerk or go to: www jud.ct.gov
JD-CV-128 Rev. 8-21 www.jud.ct.gov/ADA. eines s
P.B. §11-18(f)
Instructions COURT USE ONLY
1. Use this form to request argument on a non-arguable matter. REQARG
2. Use one form for each request.
3. Complete each section of the form. OMIA
4. File the form during the short calendar marking period.
Marking periods may be found in the calendar notices or standing orders
at: htip://www jud.ct. gov/external/super/Standorders/,
Notice
If the request is granted, the argument will be scheduled and appearing parties will be notified of its date and time.
Parties should not come to court on the original calendar date unless the court instructs them to do so.
Name of case (Plaintiff v. Defendant) Docket number
SUMMIT ASSOCIATES, LTD. v. YAMRALI, ABDUL RAHMAN NNH-CV19-6097196-S
Judicial District Calendar date ‘Calendar number and position number
New Haven at New Haven 08/30/2021 SC-15 #059
| request argument on the following motion:
Title of motion Entry number of motion
Motion for Default for Failure to Disclose Defenses #141.00
Title and entry number of any related flings
M's to Dismiss (#106.00), to Reargue (#143.00), Extend Time Disc Defense (#117.00) & Extend Time Discovery (#122.00)
Explain the reason(s) for this request:
This case involves a Company established in Afghanistan, alleged agreements entered into with regard to said Company, and
ownership to real estate located in Afghanistan. All significant and relevant contact is in the foreign country of Afghanistan.
There are no significant ties to the State of Connecticut other than the fact that the defendant now lives here. A Motion to
Dismiss this case has been filed due to the lack of Subject Matter Jurisdiction. Although the Court has just issued a decision
denying the motion, a Motion to Reargue has been filed and is still pending which means the ruling on the Motion to Dismiss is
not final and the motion to dismiss is still pend
Obviously, if the Court lacks jurisdiction, then its rulings with regard to other matters become irrelevant, lacking in significance,
and/or moot. Thus, our Courts have held that the proceedings in such circumstances come to a SCREECHING HALT! See
defendants filings #115.00, #116.00, and #117.00, and this Court's ruling in Order #114.10 on the Motion for Default for Failure to
Disclose Defenses.
The defendant has filed and reclaimed Motions to Extend Time in which to respond to the Motions for Default for Failure to
Disclose Defenses and respond to written discovery in #117.00 and #122.00.
Tam the:
(Plaintiff [1] Defendant [_] Attorney for Plaintiff _ [x] Attorney for Defendant [-] Other
Name of law firm, attorney, or self-represented party
Pat Labbadia, Ill - Law Office of Pat Labbadia
‘Address
bg Telephone number (with area code)
63 West Main Street, P.O. Box 365, Clinton, CT 06413 60-669-5656
Certification
| certify that a copy of this document was or will immediately be mailed or delivered electronically or non-electronically on
(date). 08/29/2021 to all attorneys and self-represented parties of record and that written consent for electronic delivery was
received from all attorneys and self-represented parties of record who received or will immediately be receiving electronic delivery.
Name and address of each party and attorney that copy was or will be mailed or delivered to*
David A. Slossberg, Hurwitz Sagarin Slossberg & Knuff LLC (026616), 147 North Broad Street, Milford, CT 06460
- Electronically served to: dslossberg@hssklaw.com
*If necessary, attach additional sheet or sheets with name and address which the copy was or will be mailed or delivered to.
fed (Signa Print or type name of person signing Date signed
Pat Labbadia, III 08/29/2021
Nail addless (Number, sireat, town, state and zip code) Telephone number
63 West Main Street, P.O. Box 365, Clinton, CT 06413 860-669-5656
Document Filed Date
August 30, 2021
Case Filing Date
October 21, 2019
Category
M50 - Misc - Declaratory Judgment
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Preview
REQUEST FOR ARGUMENT For information on ADA GE STATE OF CONNECTICUT NON-ARGUABLE CIVIL accommodations, SUPERIOR COURT SHORT CALENDAR MATTER contact a court clerk or go to: www jud.ct.gov JD-CV-128 Rev. 8-21 www.jud.ct.gov/ADA. eines s P.B. §11-18(f) Instructions COURT USE ONLY 1. Use this form to request argument on a non-arguable matter. REQARG 2. Use one form for each request. 3. Complete each section of the form. OMIA 4. File the form during the short calendar marking period. Marking periods may be found in the calendar notices or standing orders at: htip://www jud.ct. gov/external/super/Standorders/, Notice If the request is granted, the argument will be scheduled and appearing parties will be notified of its date and time. Parties should not come to court on the original calendar date unless the court instructs them to do so. Name of case (Plaintiff v. Defendant) Docket number SUMMIT ASSOCIATES, LTD. v. YAMRALI, ABDUL RAHMAN NNH-CV19-6097196-S Judicial District Calendar date ‘Calendar number and position number New Haven at New Haven 08/30/2021 SC-15 #059 | request argument on the following motion: Title of motion Entry number of motion Motion for Default for Failure to Disclose Defenses #141.00 Title and entry number of any related flings M's to Dismiss (#106.00), to Reargue (#143.00), Extend Time Disc Defense (#117.00) & Extend Time Discovery (#122.00) Explain the reason(s) for this request: This case involves a Company established in Afghanistan, alleged agreements entered into with regard to said Company, and ownership to real estate located in Afghanistan. All significant and relevant contact is in the foreign country of Afghanistan. There are no significant ties to the State of Connecticut other than the fact that the defendant now lives here. A Motion to Dismiss this case has been filed due to the lack of Subject Matter Jurisdiction. Although the Court has just issued a decision denying the motion, a Motion to Reargue has been filed and is still pending which means the ruling on the Motion to Dismiss is not final and the motion to dismiss is still pend Obviously, if the Court lacks jurisdiction, then its rulings with regard to other matters become irrelevant, lacking in significance, and/or moot. Thus, our Courts have held that the proceedings in such circumstances come to a SCREECHING HALT! See defendants filings #115.00, #116.00, and #117.00, and this Court's ruling in Order #114.10 on the Motion for Default for Failure to Disclose Defenses. The defendant has filed and reclaimed Motions to Extend Time in which to respond to the Motions for Default for Failure to Disclose Defenses and respond to written discovery in #117.00 and #122.00. Tam the: (Plaintiff [1] Defendant [_] Attorney for Plaintiff _ [x] Attorney for Defendant [-] Other Name of law firm, attorney, or self-represented party Pat Labbadia, Ill - Law Office of Pat Labbadia ‘Address bg Telephone number (with area code) 63 West Main Street, P.O. Box 365, Clinton, CT 06413 60-669-5656 Certification | certify that a copy of this document was or will immediately be mailed or delivered electronically or non-electronically on (date). 08/29/2021 to all attorneys and self-represented parties of record and that written consent for electronic delivery was received from all attorneys and self-represented parties of record who received or will immediately be receiving electronic delivery. Name and address of each party and attorney that copy was or will be mailed or delivered to* David A. Slossberg, Hurwitz Sagarin Slossberg & Knuff LLC (026616), 147 North Broad Street, Milford, CT 06460 - Electronically served to: dslossberg@hssklaw.com *If necessary, attach additional sheet or sheets with name and address which the copy was or will be mailed or delivered to. fed (Signa Print or type name of person signing Date signed Pat Labbadia, III 08/29/2021 Nail addless (Number, sireat, town, state and zip code) Telephone number 63 West Main Street, P.O. Box 365, Clinton, CT 06413 860-669-5656