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COMPLAINT STATE OF CONNECTICUT
CMIL CASES ONLY : Retam dats
. Ne 2019
JDCV-108 Rev. 6-414 N SUPERIOR COURT tovenbor 25,
te LV18-5040849
= —
Name of cage (Full nanje of Plaintiff v. Fullname of Defendant)
Raymond Panigutti vs Fairfield Probate Court
‘Address of Court (Number, street, town end zip coda)
| 1081 Main St. Bridgeport CT 06806
Answer t ay, ‘
In response to each paragraph of the Complaint, please "X" whether you agree, disal ree or do not know.
4.[[)Agree | [x] Disagree [7] Do Not Know 5.[}Agree —[X] Disagree [J Do Not Know
2.[] Agree | [x] Disagree [[] Do Not Know 6.[_] Agree. - {x} Disagree [—] Do Not Know
3.[] Agree j [XJ Disagree [_] Da Not Know 7.[] Agres [XJ Disagree [| Do Not Know
4.[JAgree | [x] Disagree [] Do Not Know [Agree JX] Disagree [7] Do Not Know
Special Defenses* (Facts that show the court that the plaintiff has no legal right }o whet the plaintiff has requested in this case.
. your case, you must show the court evidence to prove these|facts.)
An amended fili i dated July 23, 2009 adding defendant, Louis Panigutti, Trustee of the Mary Panigutti Trust and who is not
an attorney but pro se believes Raymond Paniguttl, plaintiff's complaint is‘to de considered Null and Void for the following
two (2) reasons and motions for a summary dismissal: .
1) Expired Process - The probate Judge Fred Anthony's decree that plaintiff Raymond appeals was adjudicated
November 2, 2019 to which he appeals on April 30, 2019. This is 151 days and on October 24, 2019, 207 days later
he adds an additional defendant, Louis Panigutti.
it is defendants understanding that according to Sec. 45a-186 (formerly Sec. 45-288). Appeal from probate. Venue. Service
of process. Any-person aggrieved by any order, denial oridecree of a Probate Court in any matter, unless otherwise specially
provided by law, |may, not later than forty after the mailing of an order, denial or decree for a matter heard and
not Jater than thir days after malling of an order, denial/or decree for any other matter in a Probate Court, appeal there
from to the Superior Court. .
2) This is a qneritless claim replete with false and misleading facts and facts not in evidence. Plaintiff's appeal is not
based on the metits or reasonableness of the Judges decree but is vexatious afd vendetta litigation and a misuse of court
process which is pvidenced with the attached copy of selFincriminating plaintifi's email threats and actions.
SEE CONTINUATION ATTACHED AND ATTACHED EVIDENCE -
*if you need more Space, continue on another sheet or sheets of paper and attach them to this Answer.
Defendant's Certifications
| certify that this answer is true to the best of my knowledge.
Signed (Di f 2 7 Dats tigned
> a [ aE . November 25, 2019
J als certify that a bopy is document was malled or delivered electronically or non-etectronically on (date) “44125119 toall
attorneys and self-nep) parties of record and that written consent for electronic delivery was received from all attorneys and self-
represented parties receiving electronic delivery. |
Name and address ofeach party and attomey that copy was mailed or dellverad to* S
Raymond rd 298 Pansy Rd. Fairfield CT 05824; Raymond Panigutti Apollo Apart Hotel #38 352/69-70 Pratat nak 20188 Thalland:
Raymond Panigutt}-at : Fairfield Probate Court 725 Old Post Ad Fairfield, CT 06824
*Hfnecessary, attach aliditional sheet or sheets with nama aiid address which the copy was mailed qr delivered to,
‘Signed ( Tara party) Frintor type tisha otperson signing |
> Zo ep Fa dovig Fauigoth’
Mpitha address: | blephone number
0 ibe df e Zu Lor VE PIB » Yio LB
I
The Judicial Brandh of the State of Connecticut complies with the Americans with Disabilitiés Act (ADA). Ifyou need a
reasonable aecomModation In accordance with the ADA, contact a court clerk or an ADA contact person listed at
www jud.ct.gov/ADA,November 25, 2019
Re: Answer to Complaint ~ Raymond Rohinsky Matter
Name of Case: Raymond Panigutti vs Faitfield Probate Court. Dockyt No: LV19-504D849
An amended filing dated July 23, 2009 adding defendant, Louis vant Trustee of the Mary Panigutti
Trust and who is not an attorney but pro se believes Raymond Panigutti, plaintiffs complaint Is to be ©
considered Null and Void for the following two (2) reasons and motjons for a summary dismissal:
1) Expired Process - The probate Judge Fred Anthony's decreejthat plaintiff Raymond appeals was
djudicated November 2, 2019 to which he appeals on April 30, 2019. This is 151 days and dn
ctober 24, 2019, 207 days later he adds an additional defendant, Louis Panigutti.
It Is defandants understanding that according to Sec. 458-186 vei Sec. 45-288). Appeal from
probate; Venue. Service of process. Any person aggrieved by any ofder, denial or decree of a Probate
Court injany matter, unless otherwise specially provided by Jaw, may, not later than forty-five days after
the mailing of an order, denial or décree for a matter, heard and-not later than thirty days after mailing
of an order, denial or decree for any other matter in a Probate Coutt, appeal there from to the Superior
Court. .
2) This is a meritless claim replete with false and misleading fats and facts not in evidence.
laintiff’s appeal is not based on the merits or reasonablendss of the Judges decree but'is
vexatious and vendetta litigation and a misuse of court prodess which is evidenced with the
ttached copy of self-incriminating plaintiff's email threats ind actions.
This matter has naw been claimed in a Probate Court of Law and reviewed and adjudicated “Three
Times.” Raymond has been ina continuing pattern of repeated denial, repudiation and remorseless
relitigating and it is shown in plaintiffs disorganized writings and is believed by Defendant in his
management and medical experience that Raymond, now 72 years pf age and a longtime resident in
Thailand suffers from age related cognitive issues and a narcissistic personality disorder with Tainted
This matter was first heard and adjudicated by the Honorable Judge Caruso in May 2014. In October
2016 into 2017 prior to the late Honorable hidge Caruso’s passing, Raymond again included this matter
in other{Trust related administration obstructions in new hearings tb Judge Caruso’s probate court.
Sadly, the Judge passed prior to Issuing his rulings and a new Trial was decreed by the Honorable Judge
Fred Anthony in mid-2018. Raymond made his repeated and previously judged claims in the new
hearings which was adjudicated by Judge Anthony November 2, 1038,
acre parcel known as 145 Brookside Dr, which was formefly pasture adjoining a 9-acre farm
on 220 Ransy Rd in Fairfield CT that was owned|with undivided inteyests as tenants in common by the
estate and family of Ellen Mario and Mary Panigutti, Ellen’s sister. The properties were originally
acquired through the sister’s family inheritance. Mary Panigutti's sds, Louis, John and Raymond were
family members but held no ownership interests or no authority with said parcel or in any otherpropert}
appoint
In 2003
known
Brookside parcel enhanced the development and rasale value of
- purchased by the joint owners (not by Louis) with a loan to the join}
Louis Panigutti’s home equity line. The transaction was administrat
Raymond Hesche. Louls held no interest in the purchase other than}
‘ records of attorney Hesche and a just debt repayment promise frort
After multiple sale attempts, including one developer suit, that did
solely against the Mario family for breach of contract and settled s
Mario family initiated a partition suit against Mary in 2006. After fo!
the Marjo estate one half undivided interests and all obligations in
the added half acre of property were purchased by Mary Panigutti i
Trust that had been formed'in 2009. Mother's attorney, Michael So!
Louis, the POA and administrated its settlement and purchase of th
up into mother’s Trust.
X
The suit|by the Mario family was only for partition as there was nev
repayment with accrued interest was to be repaid from a subsequet
property. And, Louis whose loan interests were|secured in the prop
or issue and never filed any personal suit against the Mario family o}
claim as falsely alleged by Raymond. .
The Mar} lo Farm and Brookside propérty interests was purchased in
facilitatad with a $60,000 Trust mortgage on the property to the Ma
$200,009 loan from Louis obtained from his home equity line.
interests of Mary Panigutti. Louis, who at the time was a Vice President of us Bancorp was
ed Mother’s Durabje Power of Attorney In 2006 and with the Grantor, sole Trustee in 2009.
the families put the entire farm including the Brookside partel up for sale, An adjacent %acre lot
is the Rohinsky parcel became available for quick sale for $400,000. This parcel along with the
combined property and was
ownership that was facilitated from
d by the joint owner’s attorney,
ja [oan which was in evidence in the
Mary Panigutti.
jot include Mary Panigutti, that was _
ir years of hearings and arbitrations,
he Farm including the Brookside and
2010 and roiled up into mother’s
jon managed the partition sult with
Mario estate interests and its roll
ren by the Mario family, the
r any loss or loan default as the loan
sale of the property or other
rty and a future sale had no cause
against mother for any default
2010 for $260,000 and was
rio family and cash from a new
The $200,000 loan was repaid principle with interest in 201.1 from t!
the Trust.
$100,00
in part aj
final bal
accepte
bank an
Raymond
* account
3 personal loans from and to the Estate - Trust both from ai
_ AMerit!
The decry 0
appears fo be “Definitive and Unequivocal.” The Decree for Schedule
$158,952 reads: “... The court makes a specific finding that the debt
formatian as it was directly related to assets under its control. Desp|
“the claim for repayment to be reasonable and rejects the objection
2 sale of other real estate owned by
After other Trust priority obligations, there were insufficignt funds to repay the first loan of
and the principal and accrued interest was carried forward in the Trust accounting and repaid
a family 2013 post mortem settlement and accounting frofn the sale of Trust property. The
ince due was paid in 2015 from the development and sale df the Brookside property. Commonly
and accounted Interest on the principle was 5% and to be hoted was consistent with other
to family members John and
d. Ail estate and Trust proceeds of sale and funds were heldjin attorney Sohon’s Trust escrow
and disbursed and recorded according to the directives of the Trust and law.
less Claim anda Vexatious and Vianota Litigation by Raymond :
ee of Judge Anthony of November 2, 2018 (which is the thitd time reviewed by the courts)
b B-1, Repayment of Rohinski Loan -
was assumed by the Trust after its
ite the lack of a note, the court finds
put forth.”Althoug} Raymond acts as if he understands Fact conclusions, pr and law, he fails to explain any
“Unreasonableness” and makes “No” cogent “ners of fact or e idence of Judicial error.
r, Raymond, who is currently under Trust and Court review r obstruction to Trust
ered indicatable bank mortgage
nstrues and misunderstands facts
tions which are not relative or in
he Trust Grantor’s wishes and
felony fraud relating to a purchase of Trust property, mii
for a fabrication and furtherance of his personal mo j
hed exhibit evidence shows, Raymond’ ’s submission of this appeal is not on any merits but is
for Vexat tious and Vendetta Litigation in his objection and retaliation for an appeal (timely submitted) of
e Trust matter docket number FBT-CV.18- -5038970-S. Rayn nond clearly in writing “threatens” to
file and subsequently “acts” in the afore mentioned Rohinski claim, Raymond's other threats, also thrice
court dismissed remain open,
i certify that this answer is true to the best of m y knowledge and ask the court for a summary dismissal. :
SFE
ae |
Chouis Panigutti and£ouis Panigutti, Trustee
The Mary Margref Panigutti Family TrustVoek-f bq. gob wp
Ve Peewueut ter .
Ew ele Lew eect oot
From: . Panigutti@lycos.com
Sent: Thursday, December 6, 2018 11:35 AM
To: louis 2015 panigutti; john panigutti; Carol;/panigutti
Subject: Appeals Court > : .
Lou,
I think you can agree with me that-yesterday did/not go well for yo) in Court.
Iam also amazed that your Accounting withheld $55,000 from me, after I had given the Trust this
$55,000 In exdhange for the $55,000 equity down payment for 278 Pansy rd. I am amazed you tried to
get away with this, and 1 Tam amazed how dishoh t thi
At any rate,. Judge Anthony was all over this.
This is not the reason for this e-mall.
Tam writing you about being sensible on your Dec. 3 Appeal to-Suberlor Court.
Do you really Want to start;this litigation process all over again?
If you do, thantI will be filing Monday two appeals to the Decree, in| reaction to your filing., and this
litigation that You are'starting will likely go’on for years. If the litigation outlasts you, Tony and Lance can
take over or walk.away. Tf the litigation outlasts me, then 1 won't dare.
What I learned}from attorriéy Jim Rubino, is Superior court goes by} law. Probate.Court
has a lot of lee} way.
1) Your Issue, the $66, oh Lharge was ruled by Judge Anthony accgrding to the letter of the law, and is
highly unlikely ito be léd by Superior Court,| regardless of what you think now that It might, Please
reread his judgment gn th issue carefully, and you will see what Ilmean. You used trust funds for a
private ventu ret allowed. Simple letter of the law. insult with Mike Sohon on this if you
disagree.
2) The two Appeals 1 pil
|Monday,If yours is not cancelled, are tthe A) $59,000 Rohinsky interest, and -
the B) Capital gains iss .
A) $59,000 R
of glving your the $59, 000 Interest, NDT by the Jetter of the law. He was
ng you $18,000 in compound interest, |I do not understand why, but he was
Superior court will over turn this decision using the letter of the law, the
ist funds for a private venture years before the Trust was formed. Simple
. Judge Anthony|
very generous
kind to you. I
entire $59,000)
"Letter of the [
fant did not include the $100,000 loan, {f will have to submit a Petition to
ait for. the judgment before appealing it to Superior Court. ‘This will wait until
: 1
In addition, sin
Fairfield Court ¢!
i
after Judge Anthion
to Fairfield {courte o tew months ago, on this issue,
£
8) Capital co issue. :
I . . |
Secondly, at olir Probate hearings a few months;
y's Next Decree, Included will be the docs relati
included 298 Pansy rd. transferred as a gift, to be included in the TI
law, 298 is not part of the Trust distributions.
Attorney Jim {ubino said to me back in 2014 that If appealed to Su
and the decisian by Judge Caruso would be overturned. 1 trust.his
$285,000, not
You are forcin:
Judge Anthony}
enormous pati
T think all four
I behin
64,000,
| me to fly back from Thailand to with an issue q
is an amazing Judge, as you know. He is extremely|
nce. We could not have asked fora better Judge,
T
|
|
|
of us, you, Carol, John and. myself are tired of this liq
hg to the Marios’ that. I had submitted
ago, Judge Anthoiy repeatedly asked you why you
rust. This means by the letter of the
berlor Court, they go by the rule of law
judgment. We are talking about
ais ag ier we OS oe
may have observed these last few
Hecision to appeal one of Judge
Ay. 10 fo:
hat was decided by Judge Anthony.
fair, highly intelligent, and has
igation after 4 years. It is time to put
If you choose to go the Appeals route, you are starting a new litigation war.
|
Let me know y'
turning back.
Lou, yesterday}
this litigation).
task you, do n
Ray
pur decision by Sunday, because if this starts ail ove!
. |
‘in Court, you said “one thing that you and I agree oO
(I agreed, we both made a mistake.
jot make this mistake a second time.
again at the Appeals level, there is no
1, is. we both made a mistake” (with