On April 30, 2019 a
Party Statement
was filed
involving a dispute between
Par Parallel Llc,
and
Catalina Sposato,
Christopher Sposato,
for H00 - Housing - Summary Process
in the District Court of Fairfield County.
Preview
State of Connecticut Superior Court
Housing Session at Norwalk
Docket Number NWH-CV-19-6004664S
PAR Parallel LLC v. Christopher Sposato et al.
DEFENDANTS’ OBJECTION TO
PLAINTIFF’S AFFIDAVIT OF NONCOMPLIANCE WITH STIPULATION
DUE TO FALSE STATEMENTS AND PERJURY IN THE AFFIDAVIT
1. Defendants have recently discovered facts that give it reason to believe that
Plaintiff has submitted a False and Untrue and Inaccurate Affidavit to the
Court to support its request for issuance of Summary Process (Eviction)
Execution for Possession.
2. Plaintiff’s Affiant submitted an Affidavit subscribed and sworn to before a
Notary stating that:
“4. To date, payment has not been received In full – defendants
have only paid $846.38 towards the above obligation which puts
them $1,653.62 behind in their stipulation required payments.”
3. This statement was and remains patently false and untrue. Defendants’ had
made payments totaling $1,250.00 on and before July 23 and had received
contemporaneous Payment Confirmation Receipts for such payments from
Plaintiff (the “Receipts”) – which Receipts and company records Affiant had
full access to and was, or should have been with reasonable diligence, well
aware of the true facts.
4. In addition, Plaintiff’s online portal provides timely information about a
tenant’s account and clearly reflected Defendants’ numerous payments toward
satisfying the stipulation required payment (the “Online Ledger”).
5. Appended to this Defendants’ Objection as EXHIBIT ONE are true and correct
copies of the Online Ledger and the Receipts.
Page 1 of 8
6. Plaintiff’s Affiant is and was aware at the time that she subscribed and sworn to
the Affidavit before a Notary that her statements were false and untrue and
inaccurate as a matter of fact; she also knew that prior to July 24, 2019 she had
conversations with one of the Defendants who assured her and confirmed that
payment was being made post haste and that such payments would fulfill the
required stipulation payments and that payment for Augusts’ rent would be
made immediately thereafter.
7. Defendants request the Court to examine the Affiant’s Affidavit and the facts
and Evidence contained herein. Defendants’ believe Plaintiff’s Affiant
intentionally, or with willful disregard to the truth, committed perjury in
subscribing to and swearing to the Affidavit before the Notary.
Defendants’ request that no credibility be assigned to this Affidavit and that
appropriate action against the Affiant be considered.
8. Defendants also request that the Court examine Plaintiff’s Counsel’s role in the
preparation and presentation to the Court of this Document as they may have
intentionally, or unintentionally through gross neglect, suborned perjury from
this Affiant, or at best, may have been complicit in supporting this activity in a
rush to charge Defendants with additional legal fees and cost which were
promptly added to Defendants’ Online Ledger – See EXHIBIT TWO.
Defendants’ request that these excessive and inappropriate charges be stricken
and that Plaintiff’s Counsel be reviewed and sanctioned as determined fit by the
Court.
9. Defendants hereby request that the Plaintiff’s request for Summary Process
Eviction be denied forthwith; and Defendants hereby also request that the
Court impose such additional appropriate relief as the Court determines to be
fair and further requests the Court review the Defendants’ Statements
contained in Item E of Defendants Affidavit and Objection to Execution
previously filed.
Page 2 of 8
This Defendants’ Objection to Plaintiff’s Affidavit is hereby submitted on behalf
of the Defendants and the contents herein are verified as true to the best knowledge
and belief of the Undersigned
Attorney for Defendants
Christopher D. Sposato
Attorney-at-Law
Juris Number: 304017
The Law Firm of Christopher D. Sposato
PARALLEL 41 – SUITE 517
1340 WASHINGTON BOULEVARD
STAMFORD, CONNECTICUT 06902
U.S.A.
Page 3 of 8
EXHIBIT ONE
DEFENDANTS’ PAYMENT ACCOUNT ACTIVITY AS POSTED ON WEBSITE
https://paredimcommunities.securecafe.com/residentservices/parallel-
41/payments.aspx#tab_RecentActivity
7/29/2019 Online Payment - EFT Payment. Web - Resident Services $0.00 $1,250.00 $
7/25/2019 ANC prepared and filed/Court $370.00 $0.00 $
7/23/2019 Credit Card On-Line Payment ; Web - Resident Services $0.00 $666.25 $
7/23/2019 Convenience Fee for Receipt Ctrl #366339 $16.25 $0.00 $
7/22/2019 Credit Card On-Line Payment ; Web - Resident Services $0.00 $615.00 $
7/22/2019 Convenience Fee for Receipt Ctrl #366225 $15.00 $0.00 $
ON-LINE PAYMENT RECEIPTS FOR EACH PAYMENT FOLLOW BELOW:
Page 4 of 8
From: Paredim Partners LLC [mailto:no-reply@rentcafe.com]
Sent: Monday, July 22, 2019 12:20 AM
To: cdsposato@integrity-resources.com
Subject: Payment Confirmation
Dear Christopher,
This email confirms we have received your one-time online payment. Please review the payment
information below and keep this email for your personal records.
PAYMENT INFORMATION
Payment Confirmation Number: 600366225
Payment Account: MC XXXX-6602
Payment Amount: $615.00
Your credit card statement will reflect this payment as "Property Payment Rent".
To view additional payment details, please log in to your Resident Portal account at:
Login.
Your account security is important to us. If any of the above information is inaccurate, please contact
us immediately.
From: Paredim Partners LLC [mailto:no-reply@rentcafe.com]
Sent: Tuesday, July 23, 2019 4:23 PM
Page 5 of 8
To: cdsposato@integrity-resources.com
Subject: Payment Confirmation
Dear Christopher,
This email confirms we have received your one-time online payment. Please review the payment
information below and keep this email for your personal records.
PAYMENT INFORMATION
Payment Confirmation Number: 600366339
Payment Account: MC XXXX-6602
Payment Amount: $666.25
Your credit card statement will reflect this payment as "Property Payment Rent".
To view additional payment details, please log in to your Resident Portal account at:
Login.
Your account security is important to us. If any of the above information is inaccurate, please contact
us immediately.
Page 6 of 8
From: Paredim Partners LLC [mailto:no-reply@rentcafe.com]
Sent: Monday, July 29, 2019 1:44 PM
To: cdsposato@integrity-resources.com
Subject: Payment Confirmation
Dear Christopher,
This email confirms we have received your one-time online payment. Please review the payment
information below and keep this email for your personal records.
PAYMENT INFORMATION
Payment Confirmation Number: 600366838
Payment Account: CDS HSBC Checking Chk *****5845
Payment Amount: $1,250.00
To view additional payment details, please log in to your Resident Portal account at:
Login.
Your account security is important to us. If any of the above information is inaccurate, please contact
us immediately.
Page 7 of 8
EXHIBIT TWO
5/6/2019 Litigation Fees; Writ, Summons and Complaint $425.00
5/6/2019 Marshal Fee for serving NTQ $88.00
5/6/2019 Courier and Filing Fees $191.29
5/11/2019 LATE FEES, 10% of $6965.00 $696.50
6/1/2019 Amenity Fee (06/2019) $60.00
6/1/2019 PARKING INCOME (06/2019) $100.00
6/1/2019 RENT (06/2019) $1,585.00
7/25/2019 ANC prepared and filed/Court $370.00
Page 8 of 8
Document Filed Date
July 30, 2019
Case Filing Date
April 30, 2019
Category
H00 - Housing - Summary Process
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State of Connecticut Superior Court Housing Session at Norwalk Docket Number NWH-CV-19-6004664S PAR Parallel LLC v. Christopher Sposato et al. DEFENDANTS’ OBJECTION TO PLAINTIFF’S AFFIDAVIT OF NONCOMPLIANCE WITH STIPULATION DUE TO FALSE STATEMENTS AND PERJURY IN THE AFFIDAVIT 1. Defendants have recently discovered facts that give it reason to believe that Plaintiff has submitted a False and Untrue and Inaccurate Affidavit to the Court to support its request for issuance of Summary Process (Eviction) Execution for Possession. 2. Plaintiff’s Affiant submitted an Affidavit subscribed and sworn to before a Notary stating that: “4. To date, payment has not been received In full – defendants have only paid $846.38 towards the above obligation which puts them $1,653.62 behind in their stipulation required payments.” 3. This statement was and remains patently false and untrue. Defendants’ had made payments totaling $1,250.00 on and before July 23 and had received contemporaneous Payment Confirmation Receipts for such payments from Plaintiff (the “Receipts”) – which Receipts and company records Affiant had full access to and was, or should have been with reasonable diligence, well aware of the true facts. 4. In addition, Plaintiff’s online portal provides timely information about a tenant’s account and clearly reflected Defendants’ numerous payments toward satisfying the stipulation required payment (the “Online Ledger”). 5. Appended to this Defendants’ Objection as EXHIBIT ONE are true and correct copies of the Online Ledger and the Receipts. Page 1 of 8 6. Plaintiff’s Affiant is and was aware at the time that she subscribed and sworn to the Affidavit before a Notary that her statements were false and untrue and inaccurate as a matter of fact; she also knew that prior to July 24, 2019 she had conversations with one of the Defendants who assured her and confirmed that payment was being made post haste and that such payments would fulfill the required stipulation payments and that payment for Augusts’ rent would be made immediately thereafter. 7. Defendants request the Court to examine the Affiant’s Affidavit and the facts and Evidence contained herein. Defendants’ believe Plaintiff’s Affiant intentionally, or with willful disregard to the truth, committed perjury in subscribing to and swearing to the Affidavit before the Notary. Defendants’ request that no credibility be assigned to this Affidavit and that appropriate action against the Affiant be considered. 8. Defendants also request that the Court examine Plaintiff’s Counsel’s role in the preparation and presentation to the Court of this Document as they may have intentionally, or unintentionally through gross neglect, suborned perjury from this Affiant, or at best, may have been complicit in supporting this activity in a rush to charge Defendants with additional legal fees and cost which were promptly added to Defendants’ Online Ledger – See EXHIBIT TWO. Defendants’ request that these excessive and inappropriate charges be stricken and that Plaintiff’s Counsel be reviewed and sanctioned as determined fit by the Court. 9. Defendants hereby request that the Plaintiff’s request for Summary Process Eviction be denied forthwith; and Defendants hereby also request that the Court impose such additional appropriate relief as the Court determines to be fair and further requests the Court review the Defendants’ Statements contained in Item E of Defendants Affidavit and Objection to Execution previously filed. Page 2 of 8 This Defendants’ Objection to Plaintiff’s Affidavit is hereby submitted on behalf of the Defendants and the contents herein are verified as true to the best knowledge and belief of the Undersigned Attorney for Defendants Christopher D. Sposato Attorney-at-Law Juris Number: 304017 The Law Firm of Christopher D. Sposato PARALLEL 41 – SUITE 517 1340 WASHINGTON BOULEVARD STAMFORD, CONNECTICUT 06902 U.S.A. Page 3 of 8 EXHIBIT ONE DEFENDANTS’ PAYMENT ACCOUNT ACTIVITY AS POSTED ON WEBSITE https://paredimcommunities.securecafe.com/residentservices/parallel- 41/payments.aspx#tab_RecentActivity 7/29/2019 Online Payment - EFT Payment. Web - Resident Services $0.00 $1,250.00 $ 7/25/2019 ANC prepared and filed/Court $370.00 $0.00 $ 7/23/2019 Credit Card On-Line Payment ; Web - Resident Services $0.00 $666.25 $ 7/23/2019 Convenience Fee for Receipt Ctrl #366339 $16.25 $0.00 $ 7/22/2019 Credit Card On-Line Payment ; Web - Resident Services $0.00 $615.00 $ 7/22/2019 Convenience Fee for Receipt Ctrl #366225 $15.00 $0.00 $ ON-LINE PAYMENT RECEIPTS FOR EACH PAYMENT FOLLOW BELOW: Page 4 of 8 From: Paredim Partners LLC [mailto:no-reply@rentcafe.com] Sent: Monday, July 22, 2019 12:20 AM To: cdsposato@integrity-resources.com Subject: Payment Confirmation Dear Christopher, This email confirms we have received your one-time online payment. Please review the payment information below and keep this email for your personal records. PAYMENT INFORMATION Payment Confirmation Number: 600366225 Payment Account: MC XXXX-6602 Payment Amount: $615.00 Your credit card statement will reflect this payment as "Property Payment Rent". To view additional payment details, please log in to your Resident Portal account at: Login. Your account security is important to us. If any of the above information is inaccurate, please contact us immediately. From: Paredim Partners LLC [mailto:no-reply@rentcafe.com] Sent: Tuesday, July 23, 2019 4:23 PM Page 5 of 8 To: cdsposato@integrity-resources.com Subject: Payment Confirmation Dear Christopher, This email confirms we have received your one-time online payment. Please review the payment information below and keep this email for your personal records. PAYMENT INFORMATION Payment Confirmation Number: 600366339 Payment Account: MC XXXX-6602 Payment Amount: $666.25 Your credit card statement will reflect this payment as "Property Payment Rent". To view additional payment details, please log in to your Resident Portal account at: Login. Your account security is important to us. If any of the above information is inaccurate, please contact us immediately. Page 6 of 8 From: Paredim Partners LLC [mailto:no-reply@rentcafe.com] Sent: Monday, July 29, 2019 1:44 PM To: cdsposato@integrity-resources.com Subject: Payment Confirmation Dear Christopher, This email confirms we have received your one-time online payment. Please review the payment information below and keep this email for your personal records. PAYMENT INFORMATION Payment Confirmation Number: 600366838 Payment Account: CDS HSBC Checking Chk *****5845 Payment Amount: $1,250.00 To view additional payment details, please log in to your Resident Portal account at: Login. Your account security is important to us. If any of the above information is inaccurate, please contact us immediately. Page 7 of 8 EXHIBIT TWO 5/6/2019 Litigation Fees; Writ, Summons and Complaint $425.00 5/6/2019 Marshal Fee for serving NTQ $88.00 5/6/2019 Courier and Filing Fees $191.29 5/11/2019 LATE FEES, 10% of $6965.00 $696.50 6/1/2019 Amenity Fee (06/2019) $60.00 6/1/2019 PARKING INCOME (06/2019) $100.00 6/1/2019 RENT (06/2019) $1,585.00 7/25/2019 ANC prepared and filed/Court $370.00 Page 8 of 8