APPELLANTS MOTION FOR RECONSIDERATION TO MODIFY
link to blogpost:
https://publiusroots.blogspot.com/2026/06/appellants-motion-for-reconsideration.html
I am submitting this because this case SHOULD be treated as an Appeal; yet they court may wrongfully still process it as a Motion to Open.
For the most part it is what the final will be as a submission. Yet there are a few things I need to correct, regarding the appendix:
AC 48452
NHH-CV24-5006875-S : APPELLATE COURT OF CT
ANNE BRADLEY : STATE OF CONNECTICUT
V : HOUSING SESSION
ANSONIA STATE
STREET, LLC, et al : JUNE 8, 2026
PLAINTIFF-APPELLANT’S MOTION FOR RECONSIDERATION FOR PERMISSION TO MODIFY Preliminary Statement To Court’s Declaratory Judgment (Statement of Damages)
Pursuant to PB 71-5, Appellant-Plaintiff, Pro Se, motions the Appellate Court for permission to modify Statement submitted in trial court on October 23, 2024, titled to reflect cases which she researched: Preliminary Statement To Court’s Declaratory Judgment - Remedy For Compensating Plaintiff Notarized.
HISTORY
Appellant-Plaintiff found an illicit NOTICE TO QUIT, which was wedged and bunched up in her door, appearing to be a bomb September 12, 2024 - the same day which Appellant-Plaintiff’s Home Depot order was ready to be picked up at the Concierge Desk, though she asked the Concierge to hold onto it because she was very sick with the flu. There was not any demand for payment, no proof of a Demand For Payment previously sent attached. Marshal Sandello, who also lived on the premises did this without knocking or ringing her doorbell. This paper was changed by someone prior to when Appellant opened her door on September 18, 2024, or shortly thereafter, Appellant left her apartment and realized it was a Notice To Quit, accusing her of not paying rent for August and September 2024 and also claiming she “took possession of the apartment November 2022 and is a month-to-month tenant”. The landlord received the HAP payments for those months along with the Appellant’s checks. Appellant located her scanned proofs of checks for those months and brought them to the court along with a housing complaint on October 1, 2024. Appellant-Plaintiff Motioned to Pay Fair Use and value, to supplement the complaint. Attorney Pitt refused to accept her motion. The Housing Court told Appellant-Plaintiff she could not file a Housing Complaint yet she discovered the law which indicated her right to file one as long as a VALID Notice to Quit was not served on her. The trial court granted her fee waiver after several days of efforts in filing the Complaint, Housing forms, and a 246 page Appendix. Appellant also submitted a MOTION TO PAY RENT INTO COURT, supplementing her complaint. Attorney Pitt refused to take it and also requested her to prepare a different Complaint, which HE titled “Anne Bradley v Ansonia State Street” which was against her will, The fee waiver for the Complaint was titled the same as her original Complaint, “Anne Bradley vs Bozzutto, Inc” which remains on the docket.
1. Though a hearing was required to be set by the court two weeks from docketing the case, the court waited an additional 8 days beyond the two weeks - set for Halloween Day, October 31, 2024. The marshal claimed she served all 8 defendants. The Secretary of State of Connecticut thereafter altered two records (of 360 State Street, LLC and MEPT Chapel Street, as provided in Certification, and the spelling of Beachwood to Beachwold) reporting they had been dissolved or withdrawn over a year before this case was served on their Agents, who said nothing about their companies no longer existing.
2. Alayna Stone was marked to be the judge at the hearing of October 31, 2024. The housing mediator threatened the plaintiff that if she did not meet with her (and so-called Attorney Peter Hoops, who was a fraud instead) that she would lose the case. Appellant-Plaintiff said that was blackmail. The first thing this housing mediator said was that the case was marked off for that day. Appellant-Plaintiff claimed she was lying. There was nothing resolved in the hearing, particularly since there were no answers to the complaint. The hearing lasted for more than 40 minutes. Appellant emphasized there were no answers to her complaint, no one there to hold a valid hearing, and yet the impersonator of Alayna Stone (who was obviously in her 60’s) allowed this fraud, a non-attorney, to argue the inept Motion To Dismiss, which in fact Alayna Stone has the record altered to granting before the hearing took place (record has been altered, a typical circumstance which obstructs justice on this case) The complaiut was not heard. There was no mention of a denial of the Motion To Strike, issued by the Appellant-Defendant, nor was the Motion To Strike heard. [note, the recording of the hearing was frauded to 14 minutes, resulting in a 14-page transcript by the court reporter, first name is Sotonya, who typed this transcript as swiftly as she could after speaking to the Appellant-Plaintiff who was seeking her rights and considered the hearing to be completely fraudulent since Alayna Stone was impersonated and defendants failed to show yet the woman impersonating Alayna Stone had no regard, nor did Alayna Stone thereafter and Dismissed the case.
Appellant-Plaintiff made great effort to file a timely appeal yet the Housing Court in collaboration with e-services unit (both under the guise of Elizabeth Bozzuto (who is now retired as of a month ago) used means of delay on Appellant-Plaintiff’s Request For Exemption to e-File form, submitted timely and accurately. Appellant-Plaintiff, who is a Pro Se, only knew it was past the deadline to appeal the trial court case, though the fee waiver was granted allegedly without any appeal form, which made no sense to her since she has appealed before and has always submitted the Appeal form with the fee waiver, as REQUIRED. The Appellate Court refused to take the Appeal without e-filing unless exemption was approved. It was not approved, serving the wants of Elizabeth Bozzuto, Administrative Judge of the State of Connecticut. Continuous struggle with these efforts thwarted Appellant-Plaintiff Pro Se’s rights and thus she claimed abuse of procedure, serving themselves, particularly since she motioned for a timely Extension of time to Appeal, after the fee waiver was granted, not knowing the Appellate Court had even created an Appellate Case for her, until after the trial court DENIED the motion. Though Appellant had worked a lot in preparing Appeal Documents, she knew of no other recourse than to file a Motion To Open. Appellant additionally had the stress of Hoops & Associates breaking the Order of the Court, by serving a Summons on her on October 22, 2024 - eight days before the delayed hearing of October 31, 2004. The court allowed it. The Court did not docket the hearing for 8 days beyond the two weeks it docketed the aforesaid case, as stated right on the ORDER OF THE COURT, which Appellant claimed was unlawful by Appellee Ansonia State Street as well as the trial court. The Appellant’s papers were eventually stamped in by the clerk and Attorney Pitt had them placed in a wired basket on the counter and they remained there for about a week. Just prior to the hearing on the housing complaint, the illegal eviction case was uploaded and it was mentioned by the Appellant-Plaintiff, Pro Se at that housing complaint hearing, claiming it was unlawful. Motion To Open was submitted to the trial court along with a fee waiver. Fee waiver was granted and simultaneously a denial of the Motion To Open took place. Motion for Articulation was submitted and there was no Memorandum of Law ever issued by this trial court on the case despite the fact Alayna Stone and William Pitt were fully aware of the fact that she had every intent to appeal. Motion For Articulation was denied. William Pitt, Chief Clerk of Housing for New Haven District as well as the State of Connecticut, claimed “Motions to Open can only be submitted by defaulted defendants” at which time Appellant-Plaintiff argued: No motion can favor just one side. Either side has a right to submit any motion if circumstances warrant it. The court did not reject the motion”
FACTS
1. Appellant only knew she could file a Motion To Open and did this timely, not to use as a means of delay, while contending with the illegal eviction case of Ansonia State Street vs Anne M. Bradley, which the court failed to enter a docket number for prior to serving the Summons.
2. Three months prior to this, the landlord’s maintenance supervisor terrorized her when she was taking a bath, smashing in her door locks, violently forcing his way in her apartment, which in fact they have described on record as used by the Janitors in Appraisal document, marked as M240, Page 7 of the original Complaint which was served on the Appellees.
3. A Direct Appeal (Appendix __) was submitted on aforesaid case, yet was thwarted by the trial court’s abuse of procedure along with the e-services unit abuse of procedure - both of which were under the auspices of Administrative Judge Elizabeth Bozzuto. Appellant had no knowledge of furthering her rights in filing her Direct Appeal.
4. This motion is for Reconsideration for Plaintiff-Appellant’s Motion To Modify Preliminary Statement of Court’s Declaratory Judgment (Statement of Damages, due to no Declaratory Judgment. Appendix ___)
5. There is a 3500 word limit, thus resulting in a large Appendix. Word Count upon Completion: 3496. This includes approximately 400 words covering the required Certification.
1. GROUNDS
a) Motion To Modify was submitted on 5/31/2026. Appendix __. The motion was not heard on the following day, June 1, which was the day of the hearing of the Appellant. One Appellee of all Appellees on record appeared unexpectedly since Appellant was informed no one else would be appearing on either case, according to their computer system. Non-appearing Appellees failed to respond to Preliminary Documents and Appellant’s brief. All appellees failed to Answer the Complaint and failed to appear at the trial court hearing of October 31, 2024.
b) To date, there has been no Declaratory Judgment!
i. Plaintiff motioned the trial court for this Memorandum of Law, Pursuant to PB 64-1, It was denied using false informaton that an Order of Denial sufficed. The Appellate Court denied her Statement of Noncompliance to PB 64-1, which is not even logical. It was not a motion. Appendix __
ii. Since Alayna Stone was not at the hearing of October 31, 2024, she would have to explain how she can even rule on the case in a Memorandum Of Law/Declaratory Judgment, which gave substantive reason to for Appellant to file a Direct Appeal. A woman impersonating her was there, identifying herself as Alayna Stone, despite obviously being in her 60’s and Appellant-Plaintiff thereafter discovered the real Alayna Stone is in her 40’s.
1. A Declaratory Judgment would provide ample opportunity for this landlord to use its insurance policy since the maintenance employees have to be bonded and the owner has to have ample insurance to cover for circumstances which a tenant is harmed and/or violated.
iii. Appellant-Plaintiff is aggrieved.
1. Lack of Due Process. Overwhelming proof that her right to file a Direct Appeal was circumvented by ABUSE OF PROCEDURE by both the trial court and e-services unit, both of which are under the auspices of the Administrative Judge, who has been Elizabeth Bozzuto until about a month ago when she apparently retired.
a) Appellate Court should have ruled on its own motion to treat this case as a Direct Appeal due to the Pro Se’s efforts being thwarted.
2. Notice to Quit and Marshal’s Service, along with proof the rent was paid for both months, is at Appendix __ to ensure the judge who signs on the ruling of this sees the documents and does not rely on a clerk to determine their opinion.
c) It is a Federal Requirement for the landlord to submit a Pretermination Notice and a copy to prove one was submitted 30 days prior to issuing a Notice To Quit, which is a termination of the lease - which would include a demand for a certain payment amount. There are Appellate Cases which refer to the required Pretermination Notice in Section 8 cases. Appellant has argued this at Trial Court as well as in her Brief. There was not even a demand for payment in the Complaint or attached to the Notice To Quit.
d) The legal OWNER Ansonia State Street has not proven itself to be one. Numerous other illegal circumstances involving the associated eviction case were brought forth in Case AC48416, which involves Appellee-Defendant Ansonia State Street using an illegal eviction to harm the Appellant. Appellee-Defendant Beachwold Rentals, and possibly more of the Appellees profited from Bozzutos obtaining this track of land from the city for $1. The Deed on the property is only a LIMITED WARRANTEE DEED, which has been known to restrict anyone who has such document only to not be able to sell the property since titleship cannot be secured/cleared. They purchased the $2.6 billion property (Appendix __) for only $160 million and have an $89 billion mortgage, which should be construed as unlawful transactions. The rent was paid for August and September of 2024, and Appellant did NOT take possession, which is the subject matter jurisdiction of the case. The HAP contract had no effect to the Appellant on changes of ownership. The alleged “new owner” needed to be approved, which included several of the same employees as the alleged prior owner, MEPT Chapel Street - which Dragana LaCore ordered the Appellant to make checks to “360 State Street” which Bozzutos actually handed the property over to 360 State Street, Inc. (was located in Fairfield, CT) after it was developed, for only $1 in a Quit Claim. Somehow it was tossed back to Bozzutos. That was also shown in the Complaint with 246 pages in the Appendix - which has now been frauded by cyber crime on the case. Thereafter, the records indicated MEPT Chapel Street was the new owner on another sale for $1. According to the Secretary of State’s record, which was altered after Appellee-Defendants were served, 360 State Street, Inc. Disappeard - dissolved, backdating it to PRIOR the uploading of this case, yet the marshal claimed she successfully served it on their Agent of Service, who said nothing about the company no longer existing.
i. Numerous other illegal circumstances involving the illegal eviction case, reflecting AC48416 were relayed to the Court in other pleadings as well as the Brief of Appellant in AC48416.
2. Laws reflecting rights to file housing complaints have been repeatedly submitted to include, with emphasis, a Summary Process cannot be served when the court orders the defendants they cannot serve it. (Appendix __: Court Order on the Housing Lawsuit. Housing Court reviewed the complaint, approved the complaint to be heard and served on defendants listed, and granted the fee waiver.)
a) Attorney Pitt claimed the complaint could not be replaced because the judge reviewed it and granted the case to be heard. Attorney Pitt uploaded the case eight days prior to Mashal’s service of the complaint, which is supposed to be served the same day it is uploaded.
b) This also matches the eight days which emphasizes Hoops & Associates filed a Summons Process eight days before Appellant-Plaintiff’s aforesaid Section 8 Complaint Hearing on October 31, 2024
c) Adidtionally, it was recently discovered that the Appellate Court waited eight days before they had the case manager issue a DELINQUENCY NOTICE to the only Appellee who had motioned for Extension of time to file a Response Brief, having time extended to 1/26/2026 yet eight days transpired after this before a DELINQUENCY ORDER was issued even though the DELINQUENT APPELLEE did not contact the case manager.
d) Laws on rights to file Housing Complaints are cited right on the forms submitted. MOTION TO PAY RENT INTO COURT, supplemented the Housing forms entered, and should have been entered on the trial court docket along with the complaint yet it WAS REFUSED BY ATTORNEY PITT. This motion, included with the Complaint, is unavailable due to theft of e-files by Homeland Security Contractors. .
3. The courts have shown a Modus Operandi obsession with the Number 8 dictating its own deviance to the rules of court, which reflects Satanic behavior - not justice. Appellant-Plaintiff actually sought to include two more defendants, Knox Rentals and SOM Living - yet she was deprived of business information to do so - which reflects another obsession with the Number 8.
4. The hearing on Argument on June 1, came as quite a surprise to the Appellant-Plaintiff regarding an attorney showing up. It would have bohooved the court to have permitted time to argue the MOTION TO MODIFY. The the court also oddly treated STATEMENT OF NONCOMPLIANCE TO PB 64-1 as a motion despite its published rule regarding the proper compliance of motions. Why is that? Appellant-Plaintiff is a Pro Se and there was nothing else she could select for her Statement of Noncompliance so she had to select motion when uploading it and leave a message for the case manager. It is the responsibility of the court to correct any document which it has taken in by a Pro Se to ensure it is processed properly. The Motion To Modify was not even heard yet ruled on June 1, 2026.
5. At the hearing of AC48452, Appellant EMPHASIZED that a Summary Process is REQUIRED BY LAW to have a return date of 3 days. This was deliberately violated and that sentence in which it was stated on June 1, 2026, was removed from the recording, which is supposed to be 100% correct. A copy of Appellant’s actual statement, with the corrections she made in writing, notarized, is at Appendix __.
6. Since the Appellate Court has remanded other motions to trial court, Appellant will therefore submit Modification to Preliminary Statement of Court’s Declaratory Judgment (Statement of Damages) which is at Appendix __.
LAW
As referenced in Appendix __
SUMMARY
Appellant-Plaintiff deserves her rights. All court officials have to give an oath to comply and administer the law; not their wants. The Ends do NOT justify the means in a lawful court. There is a right to Due Process Of Law for a reason. There has not even been a Memorandum of Law/Declaratory Judgment issued at trial court, which violates PB 64-1, and why Appellant has submitted her Statement of Noncompliance. For the court to rule on a statement is illogical. The court knew it is a Statement Of Noncompliance. It is the court’s duty to process CORRECTLY documents from the Plaintiff Pro Se in a legal matter once taken in and not not be abusive with procedure.
WHEREFORE, APPELLANT-PLAINTIFF MOTIONS THIS COURT TO RECONSIDER ITS DENIAL OF PLAINTIFF-APPELLANT’S MOTION FOR PERMISSION TO MODIFY PRELIMINARY STATEMENT OF COURT’S DECLARATORY JUDGMENT (STATEMENT OF DAMAGES - TRIAL COURT SUBMISSION)
Appendix Attached
Oral Argument Requested
Prepared and Submitted,
FOR THE APPELLANT-PLAINTIFF
IllegalEviction2024____________
Anne M. Bradley
Illegal Eviction 2024
PO Box 206514
New Haven, CT 06520
Ph. 203-508-0858
CERTIFICATION
THIS MOTION FOR RECONSIDERATION TO MODIFY COMPRISES OF 14 PAGES. It is Pursuant to P.B. §§ 62-7 and 66-3, it is hereby certified that a copy of the foregoing was sent electronically this 8th Day of June, 2026, to the following Attorneys who are listed by the Appellate Court:
Lloyd L. Langhammer (Appellate)
JURIS NO. Is oddly different than AC 48416 appearance
LAW OFFICES OF LLOYD L. LANGHAMMER, LLC
18A Granite Street
New London, CT 06320
860-440-3340
LTKE LAW OFFICES
52 Trumbull Street
New Haven, CT 06510
203-787-0275
Fax: 203-401-3343
Bercham Moses
75 Broad Street
Milford, CT 06460
FAX: 203-878-2235
info@bmdlaw.com email on appearance was not revised and does not go through: lstilson@berchmoses.com
HOOPS & ASSOCIATES
19A THAMES STREET
GROTON, CT 06340
PHONE: 860-445-8911
FAX: 860-445-8919
APPELLEES NON-APPEARING / NO APPEARANCE ON FILE
ALL APPELLEES FAILED TO ANSWER THE COMPLAINT AT ANY TIME. A TWO-WEEK PERIOD IS SET BY LAW; DESPITE THE INEPT RETURN DATE SET BY CHIEF CLERK WILLIAM PITT.
* BOZZUTO MANAGEMENT COMPANY
* BEACHWOLD RESIDENTIAL (trial court refused to correct spelling error; Appellate Court prints what the Trial Court dictates)
* LIVABLE CITY INTITIATIVE, WHICH IS PART OF THE CITY OF NEW HAVEN OFFICES, WHICH HAVE ATTORNEYS
* ELM CITY COMMUNITIES - THOUGH BERCHAM & MOSES ARE NOW LISTED; THEY SHOW NO DILIGENCE AND USE A FRAUDULENT APPEARANCE; THEREAFTER ADDING LTKE LAW OFFICE
* MEPT CHAPEL - MARKED INACTIVE BY SECRETARY OF STATE YET AGENT OF SERVICE FAILED TO REPORT THIS TO MARSHAL
* 360 STATE STREET, LLC, WHICH WAS LISTED AS DISSOLVED SHORTLY AFTER SERVICE BY MARSHAL; yet Hoops & Associates thereafter altered their appearance again indicating they were representing this dissolved company. Attempt to reach the active company, 360 State Street, 100 Crown Street, New Haven, resulted in being hung up on.
_Illegal Eviction2024____
Anne M. Bradley, Pro Se
PO Box 206514
New Haven, CT 06520
Ph 203-508-0858
IllegalEviction2024
It is also certified that this document has been redacted or does not contain any names or other personal identifying information that is known by appellant to be prohibited from disclosure by rule, statute, court order, or case law. It is also certified that this document complies with all applicable rules of appellate procedure.
PLAINTIFF-APPELLANT
Illegal Eviction 2024__
Anne M. Bradley, Pro Se
PO Box 206514
New Haven, CT 06520
Ph 203-508-0858
IllegalEviction2024 IllegalEviction2024@aol.com
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