AC 48416 Nefarious Motion To Terminate

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AC48416 Illegal Eviction Appellants Motion To Terminate Stays Deprive Due Process of Law 

This was copied from the court's website, so of course they make sure it is not formatted properly

posted 7/1/2026 

APPELLATE COURT STATE OF CONNECTICUT DOCKET NO.: AC 48416 DOCKET NO. NHH-CV24-6024196-S SUPERIOR COURT ANSONIA STATE STREET, LLC NEW HAVEN HOUSING SESSION VS. BRADLEY, ANNE JUNE 30, 2026 MOTION TO TERMINATE STAY Pursuant to Connecticut Rule of Appellate Procedure Section 61-11(d) and (e), Plaintiff moves the Court to terminate any and all appellate stays arising from the trial Court’s entry of judgment of possession on January 24, 2025. [Judge: Alayna Stone]. Plaintiff files this Motion to Terminate Stay in an attempt to close the infinity loop of various motions and requests for extensions of time with which the Defendant has plagued this matter. I. BRIEF HISTORY OF THE CASE This is a summary process action for nonpayment of rent which was originally filed on October 30, 2024. The Court entered judgment of possession on January 24, 2025 after a completed trial. This appeal was brought on January 28, 2025, and has been delayed by the filling of numerous motions and request for extension of time by the Defendant. On June 16, 2026, the Appellate Court affirmed the judgment without an opinion. On June 20, 2026, the Defendant filed a Motion for Extension of Time to file a Motion for Reconsideration. II. FACTUAL GROUNDS RELIED UPON At trial, both Plaintiff and Defendant testified and submitted evidence. The Court fully considered and weighed all of the testimony and evidence at trial. In entering judgment of possession, the Court found that Plaintiff had established all of the elements for nonpayment of rent and that the Defendant’s special defenses failed. The Court stayed execution of the judgment until March 31, 2025 and ordered the Defendant to pay use and occupancy. Thereafter, the Defendant filed multiple applications for stay of execution along with this appeal. III. LEGAL GROUNDS RELIED UPON Plaintiff moves to terminate any and all, whether automatic or otherwise, appellate stays, arising from the trial Court’s Judgment, pursuant to Practice Book §61-11(d) and (e). Authority to terminate a stay is found in Practice Book Section 61-11(e). The relevant standard for consideration of this motion is found in Practice Book Section 61-11(d), which provides in pertinent part that “…termination of a stay may be sought in accordance with subsection (e) of this rule. If the judge who tried the case is of the opinion that (1) an extension to appeal is sought, or the appeal is filed, only for delay or (2) the due administration of justice so requires, the judge may at any time, upon motion or sua sponte, order that the stay be terminated. Whether acting on a motion of a party or sua sponte, the judge shall hold a hearing prior to terminating the stay.” In determining whether the “due administration of justice” requires that the automatic stay be terminated, the court may consider the following factors, articulated by the Supreme Court in Griffin Hospital v. Commission on Hospitals and Health Care, 196 Conn. 451, 456-57 (1985): 1) The likelihood that the appellant will prevail: 2) The irreparability of injury to be suffered from immediate implementation of the court’s order: 3) The effect of a stay upon other parties to the proceeding; and 4) The public interest involved. Further argument for termination of a stay in this matter is found in Deutsche Bank Trust Co. Ams. V. Porzio, 2017 Conn. Super, LEXIS 573*; 2017 WL 1429940, Sav. Inst. Bank & Trust Co. v. 48-54 Hartford Ave., LLC, 2012 Conn. Super, LEXIS 2004*; 2012 WL 3854058, and Citibank, N.A. v. Stein, 2020 Conn. Super; LEXIS 378* In Deutsche Bank, the Court reviewed the four factors of the Giffin Hospital case. The court found “…little or no likelihood” that the appellant would prevail in any future appeal. It found that the defendant had enjoyed the right of occupancy of his property for 6 years during the pendency of the matter. The Judge found the effect of a stay upon other parties to be a neutral fact. And finally, determined that the public interest was involved. The court found that “Any granting of a further stay based upon further litigation would equally be of substantial public interest” as “…public interest would be expressed on the side of bringing finality to this litigation and terminating any further stays of execution” Sousa v. Sousa, 322 Conn. 757, 789-90 (2016). Applying the Giffin Hospital factors to the present case supports the termination of appellate stays. The Defendant has little to no likelihood of prevailing. Her arguments throughout the appeal have mostly consisted of regurgitated prior arguments which were already rejected by the trial Court. The Appellate Court likewise found these arguments unavailing, so much so that it affirmed the trial Court’s decision without an opinion a mere fifteen (15) days after oral argument. Regarding the second factor, it is true that terminating the appellate stays will allow the Plaintiff to seek possession of the premises. But the Defendant has already occupied the premises for an additional fifteen (15) months beyond the trial Court’s original final stay date (March 31, 2025). That is more than sufficient time for the Defendant to seek alternate housing. During this time, the Plaintiff has not received the full amount of use and occupancy it is due (as the Defendant has paid use and occupancy to the Court), resulting in a substantial balance being carried on the Plaintiff’s books. The Plaintiff has also been unable to maintain a lease for this unit, which it typically does with all units in the building. Similarly to the situation in Deutsche Bank, this factor weighs in the Plaintiff’s favor, or is at the very lease neutral. The third factor is neutral, as there are no other relevant parties to the case. The fourth factor also weighs in the Plaintiff’s favor. As the Connecticut Supreme Court previously declared, “[s]ummary process is a special statutory procedure designed to provide an expeditious remedy․ It enable[s] landlords to obtain possession of leased premises without suffering the delay, loss and expense to which, under the common-law actions, they might be subjected by tenants wrongfully holding over their terms․ Summary process statutes secure a prompt hearing and final determination.” (Citations omitted; internal quotation marks omitted.) Young v. Young, 249 Conn. 482, 487-88, 733 A.2d 835 (1999). The trial Court honored this directive with its handling of the case. Unfortunately, the Defendant’s numerous and voluminous motions and request for extensions in the appellate matter have made a mockery of it. The public interest in expeditious resolution of summary process matters weighs heavily in favor of terminating any further appellate stays. IV. CONCLUSION AND STATEMENT OF RELIEF SOUGHT The Plaintiff moves for termination of any and all, whether automatic or otherwise, appellate stays, and that it be allowed to seek possession of the premises without further delay. THE PLAINTIFF/APPELLEE, ANSONIA STATE STREET, LLC By:__/s/________________________________ Joseph W. St. Rock IV - 433022 Hoops & Associates, LLC Juris No. 424021 19A Thames Street Groton, CT 06340 CERTIFICATION OF COMPLIANCE AND SERVICE I hereby certify that the foregoing complies with the requirements of Practice Book Sections 66-2 and 66-3, and that a copy of the foregoing was forwarded via First Class Mail or electronically by consent, on June 30, 2026 to the following in accordance with Practice Book Sections 62-7 and 66-3: ANNE BRADLEY PO BOX 206514 NEW HAVEN, CT 06520 Via Electronic Mail at: illegaleviction2024@aol.com Attorney Lloyd L. Langhammer Email: llanghammer@hotmail.com I further certify that the foregoing document has been redacted or does not contain any names or other personal identifying information that is prohibited from disclosure by rule, statute, court order or case law. ___/s/_______________ Joseph W. St. Rock IV