Appellant-Defendant's Statement on Judicial Memo of Law
Link to this blogpost:
Ref: https://publiusroots.blogspot.com/2025/12/appellant-defendants-statement-on.html
https://publiusroots.blogspot.com/2025/12/ac48416-motion-for-judicial-notice.html
https://publiusroots.blogspot.com/2025/11/ac48416-brief-of-appellant.html
Ref: https://motherearthtoo2022.blogspot.com/2024/10/illegal-eviction-2024.html?m=1
I have no more time to share more references. I am tired.
The following statement will be notarized and submitted into court on Monday, the 15th of December. I need to check it for spelling errors and may reupload later. It is almost 2 am on December 14 and I need to get some rest.
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NHH-CV24-6024196-S : APPELLATE COURT
ANNE M BRADLEY : STATE OF CONNECTICUT
V : HOUSING SESSION
ANSONIA STATE STREET : December 15, 2025
AFFIDAVIT OF APPELLANT-DEFENDANT
ON MEMORANDUM OF LAW, BACKDATED TO JANUARY 25, 2025
1. This affidavit is based on the Memorandum of Law, which was not uploaded on the trial court case, causing the Appellant-Defendant to motion for the Memorandum of Law, which she was aware of existing upon researching in Westlaw.
2. This Memorandum is placed after this affidavit, and paginated accordingly in the Appellant-Defendant’s Motion to Supplement Brief. Sections are marked with reference numbers, which are referred to in the Affidavit.
3. The case is described as “a summary process action for non-payment of rent against the Defendant” which is a fraudulent description since the Summons indicated “Nonpayment of rent for August and September 2024” only.
a) Appellant-Defendant paid the same rent for over two years, despite being in opposition of it due to the numerous abuses of the landlord as well as the personal struggles as a tenant with a Federal Poverty Level income, who should be paying 10% of the rent. In fact they mocked her by reporting to DSS that her rent was 10%, which is $93.20 - without contacting her that this is what they reported, this was a nefarious abuse to get her food stamps to be lowered even more.
b) Appellant is well aware of tenants who pay nothing for rent on this premises yet they have social security income.
4. REFERENCE 1. Plaintiff did not purchase the property at 360 State Street, New Haven, CT. They do not hold the title. This was emphasized in court. Yet the Appellee-Plaintiff never produced the title as proof when they had the ability to do so. Additionally, for emphasis, when a 15 minute break was called before the trial, which had nothing to do with Due Process, Attorney Peter Hoops could have easily obtained it if one existed. And it was Attorney Peter Hoops, who entered the BAR in 1987, who attended the trial - not an Attorney St. Rock, who had no appearance on the case. Appellant does not even know if this Attorney St. Rock exists, let alone know what he looks like. Alayna Stone completely ignored this fact, that they do not have the title to the property and they do not have any legal ability to sell the property, and therefore are not the owners of this $2.2 billion property which they claim to have PURCHASED for $160 million and yet have an $89 billion mortgage on the property. All of these real estate documents were presented to the court in an Appendix of 246 pages to the complaint in the Housing Complaint Case, which has been referred to throughout this case. Additionally, most or all of those documents were uploaded on this aforesaid case in trial court. For the court to deliberately ignore this and claim it can call the shots as to what it reviews and what it doesn’t is obstruction of justice - abuse of process! Any person who has any logic about landlord-tenant rights fully knows that the Summons has to be paid for before it is served and a docket number has to be created! Other cases are shown to have that. That is why there is a square “For court purposes only” where the receipt is shown and the docket number is shown. If for whatever reason it is not shown there, it is the obligation of the marshal and the landlord to provide it in attached documents. In fact, the only attachment was an advertisement for attorneys! There was no letter of arrearage which is legally required for even regular tenants to receive 10 days prior to serving an eviction. That is a universal law, so to speak, always a legal responsibility. Additionally, a PRETERMINATION LETTER IS REQUIRED BY LAW FOR HAP contracts. This inept so-called judge who is obviously not an attorney, claimed that the Notice to Quit sufficed as a Pretermination Letter which is fraudulent. The Notice To Quit is a federal order, stating to the tenant that the landlord has ended the lease and all payments are not considered rent but for use and occupancy. A Pretermination Letter does not end the lease and is provided to the tenant to circumvent a Notice To Quit by using that month or more to resolve a landlord’s claim. The Notice To Quit had no LEGAL EFFICACY, yet this Alayna Stone claimed that the Notice to Quit was valid beause it was spelled right! She stated that in court and even what the transcript has from the frauded recording of the hearing, shows that the hearing was a botched up self-serving event which had nothing to do with abiding by the law. After all, the Chief Clerk let this Appellee-Plaintiff pay a marshal who lived at 360 State Street to shove this crumpled up Notice To Quit in her door frame, appearing to look like a bomb. Not even using her doorbell, when she was sick in her apartment. Fully knowing she was sick since the management has to be contacted before the marshal served her. He did not even serve her! This was illegal, and someone ordered him out of the building immediately - most likely the FBI, since the landord wanted this dishonest person to deliberately evade the process of serving a person according to law. Serving an intentional illegal document should have been of the interest of the court and thus a Housing Complaint was issued to include the longstanding breaches of HAP Contract as well as outrright criminal entries in her apartment when she is not in her apartment. It is a violation of the HAP contract, as already relayed to the court. THIS CASE HAS HAD NO MERIT TO EVEN HEAR AND SHOULD NOT HAVE BEEN DOCKETED, AND THEREFORE THE SUMMONS WAS ILLEGALLY SERVED FOR THAT REASON AND SEVERAL OTHERS, SUCH AS A FRAUDULENT RETURN DATE.
5. REFERENCE 2. The judge based a 2024 letter stating the rent will be $264 in 2022. How is that even a legal document? Appellant-Defendant said in court, “Go ahead, you frame yourselves if you want to submit that as evidence. Where is the orignal?” They would not even respond where the original was and they did not care since Alayna Stone had every intent to evict the Appellant prior to the trial. It was all set up and that is why it was scheduled for the same day. A Pre-arranged event rather than a trial! Appellant-Defendant claimed the evidence to be fraudulent, demanding the original letter which was never received by her. Alayna Ston is the alleged judge who seems to be a paid actor, who defendant claims to be either a very incompentent attorney - or not an attorney at all. She has no juris number in the Juris Lookup, though the juris lookup provides juidge’s juris numbers, as provided in Appendix E of this supplement. The judge had no evidence to prove that $264 was last agreed upon rent - there was no addendum to the lease entered at trial by the Appellee-Plaintiff, as stated by Appellant, who reminded the court she included it in her complaint on the housing complaint case and additionally most likely uploaded it in the trial court case of this aforesaid case. This addendum will be included in this supplement since the court has a propensity -even an obvious obsession to favor the Appellee, who is an obviously illegal landlord who fraudulently claims to be owner without even holding the title to the property and having an illegal mortgage as well as purchasing it for way below its value which disrupts the laws of insurance. In fact, they most liley use it as leverage in insurance claims - particularly ones which tenants dispute.
6. REFERENCE 3. The Memorandum of Law indicates a Notice To Quit was served on September 13, 2024. It was prepared on September 12, 2024, which was the date which the Appellant-Defendant called the Concierge and asked her to hold onto her Home Depot order. (some of which was stolen from her when she picked up the order a week later, as she said she would try to do, since she was very sick and had to sleep on the floor since her bed was vandalized by illegal intruders who enter her apartment on a regular basis for over 12 years.) The Notice to Quit and Summons are provided at Appendix C. The Return date of November 12 is fraudulent on the Summons.. The Return Date of November 4 on the Case Information is also also fraudulent. Nevertheless, the proof of payment for this Notice To Quit apparently only requires the payment to the marshal, despite being a legal federal order according to law. The Notice to Quit is a TERMINATION OF THE LEASE as of the very day it is served, and therefore it states any payments are considered for use and occupancy only. The lease is the HAP Contract. If there is no HAP contract, there is no lease. It states this right on the tenancy addendum to the HAP contract, which they court has received from the Appellant-Plaintiff and yet refuses to recogonize anything that is submitted into court. That is a violation of Due Process of Law.
a) Thereafter, on 2/11/2025, Alayna Stone oddly claimed that the Notice To Quit was valid for the Housing Complaint because it was spelled right, despite the fact the law specifically emphasizes legal efficacy - not preparation of the form. She also said it did not need to meet the same criteria for the aforesaid case, which is legal malpractice. December paymnent was made to the landlord because the court was using tactics to cause her to be evicted for nonpayment. The check had to be left on the management’s desk because Kyle Huckler refused it - despite what the Notice To Quit had right on it, that all future payments would be entered as payment for use and occupancy. Additionally, the landlord continued to receive HAP payments, which meant the contract continues and deviates from the Notice To Quit’s legal efficacy. Additionally, as for another emphasis, the Notice To Quit claimed the rent was not paid for August and September 2024, when in fact they got both the tenant’s portion and the HAP portion. They also have a reputation for frauding billing and were ordered by a court to remove fraudulent charges amounting to almost $14,000 in November 2022. This leasing of the property is just a tactic to evade from accountability by the real owner - who may be Bozzutos or the City of New Haven.
i. At the hearing of 2/11/2025, Alayna Stone additionally overrides the legal efficacy of the Notice To Quit by informing her to pay the rent to the landlord and not the court; and she took it iupon herself to increase the rent based on a 2024 letter which stated the tenant’s portion of the rent WILL BE $264 effective in 2022. which was PRIOR to the court order for them to remove all the fraudulent charges, which included the fraudulent increase in rent when it was not an agreed upon rent. The Appellee-Plaintiff even submitted another self-incriminating piece of evidence, which was the landlord lease, indicating the rent for her portion was $171. That, in fact was the only agreed upon rent which she signed. She requested hearings and instead was abused more - to include being harmed physically, sexually when someone caused her to lose conciousness and her apartment was ransacked when she got up and on another day which was election day when Bob Stefanowski was running for Governor - and also damage to and theft of her property. This is the consequence in reporting wrongfulness by the Appellee-Plaintiff.
7. REFERENCE 4. The “Discussion”. admits the Housing Case is a Summary Process yet the court breaks laws and procedures reflecting what a summary process is, including the right to cross claim. The Housing Complaint covers issues of longstanding harm to the Appellant-Defendant and most importantly to note is that she had no confidence in this court to ever issue a housing complaint due to the corrupted officials that run it, not due to the clerks who do processing efficiently and honestly. Therefore submitting a housing complaint into court was not only futile but would result in more harm to her. The fact this “Discussion” begins with “it enables landlords to obtain possession of leased premises” is a direct reflection of what takes precidence in eviction processes. Yet the landlord has no legal right to just kick out tenants they feel like kicking out. Yet certainly that has occurred to the Appellant-Defendant in the past and she is facing more legal abuse now.
8. REFERENCE 5. To prevail on the case, the subject matter jurisdiction must be met first. For the Memorandum of Law deliberately not even mentioning subject matter jurisdiction when this same alleged judge, Alayna Stone, dismissed the associated case, the housing complaint, for lack of subject matter jurisdiction, is reflective of malicious and vexatious prosecution - not serving as a judge - particularly since Attorney Pitt, the chief clerk PREMATURELY UPLOADED that case - a week before it was served - which violated Due Process of Law. He would not allow the Appellant-Defendant to even mail those complaint packets through certified return receipt mail - which also violates Due Process - and he made some sort of inept agreement with the marshal so she got paid either two or three thousand dollars for serving 4 people at a local office owned by COLONIAL FOUNTAIN MANAGEMENT, and two others locally, only just blocks and away, and two others in Hartford and East Hartford. She claimed it was because she had to verify everything, which she obviously did not do since the one she served in E Hartford, MEPT Chapel, was dissolved by the Secretary of State, backdated on record, since they were listed as still active at the time the Complaint was submitted into court. This marshal also served the Secretary of State prior to going to East Hartford, CT. A simple circumstance like that, yet she claimed she validated everything.
9. REFERENCE 5. This “Discussion” refers to an 8-point requirement which is a law regarding nonpayment of rent. Point 6: “The date of nonpayments” was not even indicated in the Notice to Quit or the Summons. How absolutely illegal it is for the court to have in her hand the Summons which only states non-payment for August and September and yet cites the law, admits the law by signing this memo - and thereafter defends the Apellee-Plaintiff despite even knowing the intentional history of abuse, breach of contract, and even the maintenance manager using violence to break in her door when she was taking a bath!
i. All of this time and expense will be included in the Housing Complaint/lawsuit! Additionally, more has been stolen and more has been vandalized by the Apellee-Plaintiff! This will also be included!
10. Additionally, in REFERENCE 6, It is a complete lie that “the only element that is disputed is the amount of rent” AND Kyle Huckle is not the Plaintiff. He is the employee of the Plaintiff. This is another deliberate lie, by someone who is supposed to be a judge.
11. REFERENCE 7 is also false. In REFERENCE 6, the alleged judge claims that rent had been increased in January 2022. in this REFERENCE 7, these are the following lies:
a) The tenant portion of payment had only been recorded since January 2023.
i. It can be clearly seen right in the ledger that was a lie. The tenant portion of payment had always been in the ledger, not that the ledger was even justified. This is a judge who is lying about the evidence entered into court. No attorney in their right mind would be so innately dishonest - even career criminals.
ii. The ledger shows they were ordered by the court to remove the fraudulent charges, which took place in February 2023 WITH A BALANCE OF ZERO, which means all those fake additional $66/month charges were erased due to fraud. This Apellee-Plaintiff attempting to ride off the back of Kyle Huckle, who is obviously wired to say and do what they want, who answered questions with “That’s above my pay grade” is beyond comprehension how this governor-appointed judge has even been allowed to be appointed a judge. She is obviously not an attorney. She is a paid actor, as was David Wheeler in the Alex Jones case, lying that he was Agent William Aldenburg. That is indeed a federal offense!
1. They removed the inept, unagreed upon charges February 2023. This judge claims the $264 increase in rent began in 2022 only because the 2024 letter says that, which is absurd. THE TENANT BALANCE WENT TO ZERO; she continued to pay $198/month, which in fact was generous since the last agreed upon rent was $171 and she has a federal poverty level income!
12. REFERENCE 8. Alayna Stone lied again about Appellant-Defendant’s mailing address. In 2019, this Apellee-Plaintiff brought eviction proceedings, again not issueing a Pretermination letter and the Appellant-Defendant won the case, proving she had paid the rent timely every month. Her mailing address was PO Box 206514, New Haven - not 360 State Street. She also had a great struggle getting the USPS to rout her mail to her mailbox, particularly since Apellee-Plaintiff manager, Dragana LaCore, who is also still affiliated with the operations of this building, had their employee tamper with her mail, giving her the key. Appellant-Defendant told her that was her mailbox and never to access it. Yet Appellant-Defendant managed to get the USPS to do what she wanted, which was to rout her mail to her PO Box permanently. There was a time around 2023 in which a postal worker asked her if she wanted all the mail in it. She said she only gets mail at her PO Box and nothing should ever be delivered there. That was over two years before that, and she cannot control the corruption by this landlord, conspiring with certain ones at the post office. The distribution center on Sargent Drive assured her it would not happen again. Whether it does or not is unknown. The Appellant never looks in that mailbox and stopped when she changed her mail in 2019 or 2020. She believes it was in 2019 since that is when they tried to illegally evict her.
13. The Subject Matter Jurisdiction is nonpayment of rent for August and September. The rent was paid! It was proven it was paid! It was the same amount paid in July 2024 and that check was presented as well! Whatever less the landlord got from the Housing Authority should have been the result of abatement since they were ordered to remove the almost $14,000 in charges February 2023. This page of the ledger is provided in Appendix F, which reflects general communications.
14. There is no testimony that can reflect “She knew or should have known” This is complete lie! There is a big difference between “She knew” versus “She Should have known” . the court failed to determine either regarding any rent increase and then clumped this description together, evading from the subject matter jurisdiction! Turning the tables, the court knows this and yet disrupts justice by lying about this and allowing a letter which only proves more that the Apellee-Plaintiffs are frauds.
This concludes this nine-page Appellant-Defendant’s Notarized Statement reflecting this unlawful Memorandum of Law, backdated to January 24, 2025. Page numbers significant to this document are on the right. Yet this is also enumerated in the middle of the footer, for the Motion To Supplement Brief which ended with Page 415. .
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Anne M. Bradley, Pro Se (notarized)
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