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RETURN DATE: MAY 19, 2015
THE SOUTHERN CONNECTICUT GAS, SUPERIOR COURT
COMPANY
JUDICIAL DISTRICT OF
VS. NEW HAVEN AT NEW HAVEN
JAMES BRADLEY APRIL 7, 2015
COMPLAINT
COUNT ONE: CONTRACT
] At all times relevant hereto, Plaintiff was a specially chartered corporation,
organized and existing under the laws of the State of Connecticut with a business address
in Orange, Connecticut.
2. At all times relevant hereto, Plaintiff was a public service company which
distributes, transmits and sells gas utility service in the State of Connecticut.
3 Plaintiff provided gas utility service to Defendant, JAMES BRADLEY at the
service address known as 65 BRISTOL ST NEW HAVEN, CT 06511.
4 Plaintiff has charged and billed the Defendant for gas utility service in
accordance with rates approved by the Connecticut Public Utilities Regulatory Authority.
5, As of March 19, 2015, Defendant, JAMES BRADLEY owes the Plaintiff
$7,448.79 for unpaid gas utility services.
6 Plaintiff is continuing to provide gas utility services at the aforesaid service
address and, as such, charges continue to accrue on the Defendant's account.
7 Defendant, JAMES BRADLEY has negelected and failed fo pay for such
gas utility service despite being billed on a monthly basis and Plaintiff seeks post-
NAIR & LEVIN, P.C.
ATTORNEYS AT LAW
707 BLOOMFIELD AVENUE BLOOMFIELD, CT 06002 TEL, (BGO) 242-7585 Fax (B60) 242-2980 Juris No. 042122
judgment interest pursuant to Connecticut General Statutes §37-3a.
COUNT TWO: UNJUST ENRICHMENT
1-3. Paragraphs One through Three of Count One are hereby incorporated by
reference as Paragraphs One through Three of Count Two as if set forth individually
herein.
4 Defendant, JAMES BRADLEY either owns and/or has resided at the service
address where the gas utility services were provided at all times relevant hereto.
5 Defendant, JAMES BRADLEY has received, used and benefitted from the
gas utility service provided by Plaintiff.
6. Plaintiff provided said gas utility service with the expectation of being
paid for same.
7 Defendant, JAMES BRADLEY has neglected and failed to pay for the gas
utility service provided by Plaintiff and has been unjustly enriched to the detriment of
Plaintiff.
8 Plaintiff has suffered loss and damages in the amount of $7,448.79 as a
result of providing gas ulility service to Defendant and charges continue to accrue
without compensation therefor.
9 Plaintiff seeks post-j/Udgment interest pursuant to Connecticut General
Statutes §37-3a.
NAIR & LEVIN, P.C.
ATTORNEYS AT LAW
707 BLOOMFIELD AVENUE BLOOMFIELD, CT 06002 TEL, (B60) 242-7585 Fax (860) 242-2980 JURIS No. 042122
NOTICE REQUIRED BY THE FAIR DEBT COLLECTION
PRACTICES ACT, (the Act) 15 U.S.C. Section 1601 AS AMENDED
This law firm may be deemed a “delot collector” under the Fair Debt Collection
Practices Act. Any and all information obtained during the prosecution of this lawsuit
may be used for the purpose of collecting a debt.
Unless you within thirty (30) days after receipt of this notice, dispute the validity of
the debt, or any portion thereof, the debt will be assumed to be valid by this office.
If you notify this office in writing within the thirty (30) day period that the debt, or
any portion thereof, is disputed this office will obtain a verification of the debt or a copy
of the judgment against you and a copy of such verification or judgment will be mailed
to you by this office.
Upon your written request within the thirty (30) day period, this office will provide
you with the name and address of the original creditor, if different from the current
creditor. The original creditor was The Southern Connecticut Gas Company.
Written requests should be addressed to Nair & Levin, P.C., 707 Bloomfield Avenue,
Bloomfield, CT 06002.
THE ATTORNEYS FOR THE PLAINTIFF ARE ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.
NAIR & LEVIN, P.c.
ATTORNEYS AT LAW
707 BLOOMFIELD AVENUE BLOOMFIELD, CT 06002 TEL. (860) 242-7585 Fax (860) 242-2980 JURIS No. 042122
WHEREFORE, the Plaintiff claims:
] Fair, just and reasonable money damages.
2. Post-judgment interest pursuant to Conn. Gen. Stat §37-3a.
3 Costs.
4 An order for the Defendants for reasonable weekly payments to be made
out of sums earned or to be earned for services rendered or to be rendered by each
such Defendants in accordance with the statute made and provided.
The amount in demand is greater than $2,500.00, but less than $15,000.00.
Diane =Chachulski of 707 Bloomfield Avenue, Bloomfield, Connecticut is
recognized in the sum of $250.00 to prosecute, etc.
Of this writ, with your doings thereon, make due service and return.
Dated at Bloomfield, Connecticut on April 7, 2015.
PLAINTIFF 2
Peter’. Steffing, Esquire
Nair & Ley P.C
707 Bloo field Avenue
Bloomfield, CT 06002
Juris No. 042122
Telephone No. (860) 242-7585
Its Attorneys
Please enter our appearance for the Plaintiff.
This is an attempt to collect a debt. Any information obtained will be used for that
purpose.
594867
UTC2
NAIR & LEVIN, P.c.
ATTORNEYS AT LAW
707 BLOOMFIELD AVENUE BLOOMFIELD, CT 06002 TEL. (860) 242-7585 Fax (B60) 242-2980 JURIS No. 042122
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RETURN DATE: MAY 19, 2015 THE SOUTHERN CONNECTICUT GAS, SUPERIOR COURT COMPANY JUDICIAL DISTRICT OF VS. NEW HAVEN AT NEW HAVEN JAMES BRADLEY APRIL 7, 2015 COMPLAINT COUNT ONE: CONTRACT ] At all times relevant hereto, Plaintiff was a specially chartered corporation, organized and existing under the laws of the State of Connecticut with a business address in Orange, Connecticut. 2. At all times relevant hereto, Plaintiff was a public service company which distributes, transmits and sells gas utility service in the State of Connecticut. 3 Plaintiff provided gas utility service to Defendant, JAMES BRADLEY at the service address known as 65 BRISTOL ST NEW HAVEN, CT 06511. 4 Plaintiff has charged and billed the Defendant for gas utility service in accordance with rates approved by the Connecticut Public Utilities Regulatory Authority. 5, As of March 19, 2015, Defendant, JAMES BRADLEY owes the Plaintiff $7,448.79 for unpaid gas utility services. 6 Plaintiff is continuing to provide gas utility services at the aforesaid service address and, as such, charges continue to accrue on the Defendant's account. 7 Defendant, JAMES BRADLEY has negelected and failed fo pay for such gas utility service despite being billed on a monthly basis and Plaintiff seeks post- NAIR & LEVIN, P.C. ATTORNEYS AT LAW 707 BLOOMFIELD AVENUE BLOOMFIELD, CT 06002 TEL, (BGO) 242-7585 Fax (B60) 242-2980 Juris No. 042122 judgment interest pursuant to Connecticut General Statutes §37-3a. COUNT TWO: UNJUST ENRICHMENT 1-3. Paragraphs One through Three of Count One are hereby incorporated by reference as Paragraphs One through Three of Count Two as if set forth individually herein. 4 Defendant, JAMES BRADLEY either owns and/or has resided at the service address where the gas utility services were provided at all times relevant hereto. 5 Defendant, JAMES BRADLEY has received, used and benefitted from the gas utility service provided by Plaintiff. 6. Plaintiff provided said gas utility service with the expectation of being paid for same. 7 Defendant, JAMES BRADLEY has neglected and failed to pay for the gas utility service provided by Plaintiff and has been unjustly enriched to the detriment of Plaintiff. 8 Plaintiff has suffered loss and damages in the amount of $7,448.79 as a result of providing gas ulility service to Defendant and charges continue to accrue without compensation therefor. 9 Plaintiff seeks post-j/Udgment interest pursuant to Connecticut General Statutes §37-3a. NAIR & LEVIN, P.C. ATTORNEYS AT LAW 707 BLOOMFIELD AVENUE BLOOMFIELD, CT 06002 TEL, (B60) 242-7585 Fax (860) 242-2980 JURIS No. 042122 NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT, (the Act) 15 U.S.C. Section 1601 AS AMENDED This law firm may be deemed a “delot collector” under the Fair Debt Collection Practices Act. Any and all information obtained during the prosecution of this lawsuit may be used for the purpose of collecting a debt. Unless you within thirty (30) days after receipt of this notice, dispute the validity of the debt, or any portion thereof, the debt will be assumed to be valid by this office. If you notify this office in writing within the thirty (30) day period that the debt, or any portion thereof, is disputed this office will obtain a verification of the debt or a copy of the judgment against you and a copy of such verification or judgment will be mailed to you by this office. Upon your written request within the thirty (30) day period, this office will provide you with the name and address of the original creditor, if different from the current creditor. The original creditor was The Southern Connecticut Gas Company. Written requests should be addressed to Nair & Levin, P.C., 707 Bloomfield Avenue, Bloomfield, CT 06002. THE ATTORNEYS FOR THE PLAINTIFF ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NAIR & LEVIN, P.c. ATTORNEYS AT LAW 707 BLOOMFIELD AVENUE BLOOMFIELD, CT 06002 TEL. (860) 242-7585 Fax (860) 242-2980 JURIS No. 042122 WHEREFORE, the Plaintiff claims: ] Fair, just and reasonable money damages. 2. Post-judgment interest pursuant to Conn. Gen. Stat §37-3a. 3 Costs. 4 An order for the Defendants for reasonable weekly payments to be made out of sums earned or to be earned for services rendered or to be rendered by each such Defendants in accordance with the statute made and provided. The amount in demand is greater than $2,500.00, but less than $15,000.00. Diane =Chachulski of 707 Bloomfield Avenue, Bloomfield, Connecticut is recognized in the sum of $250.00 to prosecute, etc. Of this writ, with your doings thereon, make due service and return. Dated at Bloomfield, Connecticut on April 7, 2015. PLAINTIFF 2 Peter’. Steffing, Esquire Nair & Ley P.C 707 Bloo field Avenue Bloomfield, CT 06002 Juris No. 042122 Telephone No. (860) 242-7585 Its Attorneys Please enter our appearance for the Plaintiff. This is an attempt to collect a debt. Any information obtained will be used for that purpose. 594867 UTC2 NAIR & LEVIN, P.c. ATTORNEYS AT LAW 707 BLOOMFIELD AVENUE BLOOMFIELD, CT 06002 TEL. (860) 242-7585 Fax (B60) 242-2980 JURIS No. 042122