DOCKET NO. BDB-CV22-6042406-S
`
`: SUPERIOR COURT
`
`
`GIRISH ARORA and ANJALI B. ARORA
`
`
`vs.
`
`
` : JD OF DANBURY
`
`: AT DANBURY
`
`
`FOX HILL CONDOMINIUM ASSOCIATION, INC.,
`SCALZO PROPERTY MANAGEMENT INC.,
`SPM MAINTENANCE AND CONSTRUCITON
`LLC and JOHN J. RUSSINKO
`
`
`
`: May 2, 2023
`
`ANSWER OF FOX HILL CONDOMINIUM ASSOCIATION, INC. and
`SCALZO PROPERTY MANAGEMENT, INC.
`TO PLAINTIFF’S SUBSITUTE COMPLAINT
`WITH SPECIAL DEFENSES AND CROSS-COMPLAINT
`
`Defendants Fox Hill Condominium Association, Inc. and Scalzo Property
`
`Management, Inc. (“Defendants”) hereby serve this Answer with Special Defenses and Cross-
`
`Claims to the Plaintiffs’ Substitute Complaint, February 16, 2023.
`
`BY WAY OF ANSWERS TO THE FIRST COUNT:
`
`
`
`
`1.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “1” and, therefore, leave the Plaintiffs to their proof, except admit that
`
`Defendant Fox Hill Condominium Association was a Connecticut corporation and otherwise
`
`refers to the “Declaration” referenced in the allegation for its terms and conditions.
`
`2.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “2” and, therefore, leave the Plaintiffs to their proof, except admit that
`
`Scalzo Property Management, Inc. was a Connecticut corporation with a business address of 2
`
`Stony Hill Road, Bethel, Connecticut.
`
`3.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “3” and, therefore, leave the Plaintiffs to their proof.
`
`
`
`: SUPERIOR COURT
`
`
`GIRISH ARORA and ANJALI B. ARORA
`
`
`vs.
`
`
` : JD OF DANBURY
`
`: AT DANBURY
`
`
`FOX HILL CONDOMINIUM ASSOCIATION, INC.,
`SCALZO PROPERTY MANAGEMENT INC.,
`SPM MAINTENANCE AND CONSTRUCITON
`LLC and JOHN J. RUSSINKO
`
`
`
`: May 2, 2023
`
`ANSWER OF FOX HILL CONDOMINIUM ASSOCIATION, INC. and
`SCALZO PROPERTY MANAGEMENT, INC.
`TO PLAINTIFF’S SUBSITUTE COMPLAINT
`WITH SPECIAL DEFENSES AND CROSS-COMPLAINT
`
`Defendants Fox Hill Condominium Association, Inc. and Scalzo Property
`
`Management, Inc. (“Defendants”) hereby serve this Answer with Special Defenses and Cross-
`
`Claims to the Plaintiffs’ Substitute Complaint, February 16, 2023.
`
`BY WAY OF ANSWERS TO THE FIRST COUNT:
`
`
`
`
`1.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “1” and, therefore, leave the Plaintiffs to their proof, except admit that
`
`Defendant Fox Hill Condominium Association was a Connecticut corporation and otherwise
`
`refers to the “Declaration” referenced in the allegation for its terms and conditions.
`
`2.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “2” and, therefore, leave the Plaintiffs to their proof, except admit that
`
`Scalzo Property Management, Inc. was a Connecticut corporation with a business address of 2
`
`Stony Hill Road, Bethel, Connecticut.
`
`3.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “3” and, therefore, leave the Plaintiffs to their proof.
`
`
`
`4.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “4” and, therefore, leave the Plaintiffs to their proof.
`
`5.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “5” and, therefore, leave the Plaintiffs to their proof and refer all
`
`questions of law to this Honorable Court, including the determination of whether or not
`
`plaintiffs’ are to be considered “unit owner” as per the referenced Declarations.
`
`6.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “6” and, therefore, leave the Plaintiffs to their proof and refer all
`
`questions of law to this Honorable Court for a determination of what duties were owed and/or
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`not owed.
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`7.
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`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “7” and, therefore, leave the Plaintiffs to their proof.
`
`8.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “8” and, therefore, leave the Plaintiffs to their proof.
`
`9.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “9” and, therefore, leave the Plaintiffs to their proof.
`
`10.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “10” and, therefore, leave the Plaintiffs to their proof.
`
`11.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “11” and, therefore, leave the Plaintiffs to their proof.
`
`12.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “12” and, therefore, leave the Plaintiffs to their proof.
`
`
`
`13.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “13” and, therefore, leave the Plaintiffs to their proof.
`
`14.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “14” and, therefore, leave the Plaintiffs to their proof.
`
`15.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “15” and, therefore, leave the Plaintiffs to their proof.
`
`16.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “16” and, therefore, leave the Plaintiffs to their proof, and refer all
`
`question of law to the Honorable Court for a determination as to conditions precedent
`
`concerning ADR.
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`17.
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`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “17” and, therefore, leave the Plaintiffs to their proof.
`
`18.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “18” and, therefore, leave the Plaintiffs to their proof.
`
`19.
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`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “19” and, therefore, leave the Plaintiffs to their proof.
`
`20.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “20” and, therefore, leave the Plaintiffs to their proof.
`
`21.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “21” and, therefore, leave the Plaintiffs to their proof.
`
`22.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “22” and, therefore, leave the Plaintiffs to their proof.
`
`
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`23.
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`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “23” and, therefore, leave the Plaintiffs to their proof.
`
`24.
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`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “24” and, therefore, leave the Plaintiffs to their proof.
`
`25.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “25” and, therefore, leave the Plaintiffs to their proof
`
`26.
`
`27.
`
`Defendants deny each and every allegation contained in Paragraph “26.”
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “27” and, therefore, leave the Plaintiffs to their proof.
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`28.
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`Defendants deny each and every allegation contained in Paragraph “28” and all
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`sub-paragraphs therein in their entirety.
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`29.
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`30.
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`31.
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`32.
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`Defendants deny each and every allegation contained in Paragraph “29.”
`
`Defendants deny each and every allegation contained in Paragraph “30.”
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` Defendants deny each and every allegation contained in Paragraph “31.”
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`Defendants deny each and every allegation contained in Paragraph “32.”
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`BY WAY OF ANSWERS TO THE SECOND COUNT:
`
`
`1-26. Defendants repeat each and every response to Paragraphs “1” through “26” of
`
`the First Count as if more fully set forth herein.
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`27.
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`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “27” and, therefore, leave the Plaintiffs to their proof and refer all
`
`questions of law to this Honorable Court and otherwise deny that the Plaintiffs are entitled to
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`the relief demanded.
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`
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`
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`BY WAY OF ANSWERS TO THE THIRD COUNT:
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`
`
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`1-26. Defendants repeat each and every response to Paragraphs “1” through “26” of
`
`the First Count as if more fully set forth herein.
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`27.
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`Defendants deny each and every allegation contained in Paragraph “27” and all
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`sub-paragraphs contained therein.
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`28.
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`29.
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`30.
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`Defendants deny each and every allegation contained in Paragraph “28.”
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`Defendants deny each and every allegation contained in Paragraph “29.”
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`Defendants deny each and every allegation contained in Paragraph “30.”
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`BY WAY OF ANSWERS TO THE FOURTH COUNT:
`
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`1-26. Defendants repeat each and every response to Paragraphs “1” through “26” of
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`the First Count as if more fully set forth herein.
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`27.
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`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “27” and all sub-paragraphs therein and therefore, leave the Plaintiffs
`
`to their proof.
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`28.
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`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “28” and, therefore, leave the Plaintiffs to their proof.
`
`29.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “29” and, therefore, leave the Plaintiffs to their proof.
`
`30.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “30” and, therefore, leave the Plaintiffs to their proof.
`
`31.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “31” and, therefore, leave the Plaintiffs to their proof.
`
`
`
`
`
`BY WAY OF ANSWERS TO THE FIFTH COUNT:
`
`
`
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`1-26. Defendants repeat each and every response to Paragraphs “1” through “26” of
`
`the First Count as if more fully set forth herein.
`
`27.
`
`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “27” and all sub-paragraphs contained therein.
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`28.
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`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “28” and all sub-paragraphs contained therein.
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`29
`
`Defendants have insufficient knowledge to admit or deny the allegations
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`contained in Paragraph “29” and all sub-paragraphs contained therein.
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`30.
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`Defendants have insufficient knowledge to admit or deny the allegations
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`contained in Paragraph “30” and all sub-paragraphs contained therein.
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`31.
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`Defendants have insufficient knowledge to admit or deny the allegations
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`contained in Paragraph “31” and all sub-paragraphs contained therein.
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`BY WAY OF ANSWERS TO THE SIXTH COUNT:
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`
`
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`1-30. Defendants repeat each and every response to Paragraphs “1” through “30” of
`
`the First Count as if more fully set forth herein.
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`31. Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “31” and, therefore, leave the Plaintiffs to their proof and refer all
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`questions of law to this Honorable Court for a determination of what defines the boundaries of
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`a Unit.
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`32. Defendants deny each and every allegation contained in Paragraph “32.”
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`33. Defendants deny each and every allegation contained in Paragraph “33” and all
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`sub-paragraphs contained therein.
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`34. Defendants deny each and every allegation contained in Paragraph “34.”
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`35. Defendants deny each and every allegation contained in Paragraph “35.”
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`36. Defendants deny each and every allegation contained in Paragraph “36.”
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`BY WAY OF ANSWERS TO THE SEVENTH COUNT:
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`
`
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`1-30. Defendants repeat each and every response to Paragraphs “1” through “30” of
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`the Third Count as if more fully set forth herein.
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`31.
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`Defendants deny each and every allegation contained in Paragraph “31” and all
`
`sub-paragraphs contained therein.
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`32. Defendants deny each and every allegation contained in Paragraph “32.”
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`33. Defendants deny each and every allegation contained in Paragraph “33.”
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`BY WAY OF ANSWERS TO THE EIGHTH COUNT:
`
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`1-30. Defendants repeat each and every response to Paragraphs “1” through “30” of
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`the Fourth Count as if more fully set forth herein.
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`31.
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`Defendants have insufficient knowledge to admit or deny the allegations
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`contained in Paragraph “31” and all sub-paragraphs contained therein.
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`BY WAY OF ANSWERS TO THE NINTH COUNT:
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`1-26. Defendants repeat each and every response to Paragraphs “1” through “26” of
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`the Fist Count as if more fully set forth herein.
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`27. Defendants have insufficient knowledge to admit or deny the allegations
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`contained in Paragraphs “27”, “28”, “28”1 and all sub-paragraphs contained therein, and
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`therefore, leave the Plaintiffs to their proof and refer all questions of law to this Honorable
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`Court.
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`28.
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`Defendants deny each and every allegation contained in Paragraphs “32”, “33”,
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`“34”, “35” and “36” of the Supplemental Complaint.2
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`BY WAY OF ANSWERS TO THE TENTH COUNT:
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`1-35. Defendants repeat each and every response to Paragraphs “1” through “35” of
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`the Sixth Count as if more fully set forth herein.
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`
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`36. Defendants deny each and every allegation contained in Paragraph “36.”
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`37. Defendants deny each and every allegation contained in Paragraph “37.”
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`BY WAY OF ANSWERS TO THE ELEVENTH COUNT:
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`1-31. Defendants repeat each and every response to Paragraphs “1” through “31” of
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`the Seventh Count as if more fully set forth herein.
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`
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`32. Defendants deny each and every allegation contained in Paragraph “32.”
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`33. Defendants deny each and every allegation contained in Paragraph “33.”
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`BY WAY OF ANSWERS TO THE TWELFTH COUNT:
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`1-30. Defendants repeat each and every response to Paragraphs “1” through “30” of
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`the Fourth Count as if more fully set forth herein.
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`31.
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`Defendants have insufficient knowledge to admit or deny the allegations
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`contained in Paragraph “31” and, therefore, leave the Plaintiffs to their proof.
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`1 The Supplemental Complaint has two Paragraphs numbered “28.”
`2 The Supplemental Complaint’s Paragraph numbering jumps from “28” to “32.”
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`32.
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`Defendants have insufficient knowledge to admit or deny the allegations
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`contained in Paragraph “32” and, therefore, leave the Plaintiffs to their proof.
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`BY WAY OF ANSWERS TO THE THIRTEENTH COUNT:
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`
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`1-26. Defendants repeat each and every response to Paragraphs “1” through “26” of
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`the First Count as if more fully set forth herein.
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`27.
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`Defendants have insufficient knowledge to admit or deny the allegations
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`contained in Paragraphs “27”, “28” and “29” of the Supplemental Complaint, and all sub-
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`paragraphs therein and, therefore, leave the Plaintiffs to their proof.
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`BY WAY OF ANSWERS TO THE FOURTEENTH COUNT:
`
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`1-25. Defendants repeat each and every response to Paragraphs “1” through “25” of
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`the First Count as if more fully set forth herein.
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`26.
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`Defendants deny each and every allegation contained in Paragraphs “26” and
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`“27” of the Supplemental Complaint, and all sub-paragraphs contained therein.
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`BY WAY OF ANSWERS TO THE FIFTEENTH COUNT:
`
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`1-25. Defendants repeat each and every response to Paragraphs “1” through “25” of
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`the First Count as if more fully set forth herein.
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`26.
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`Defendants have insufficient knowledge to admit or deny the allegations
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`contained in Paragraph “26” and all sub-paragraphs therein and, therefore, leave the Plaintiffs
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`to their proof.
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`27.
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`Defendants have insufficient knowledge to admit or deny the allegations
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`contained in Paragraph “27”, “28”, “29” and “30” of the Supplemental Complaint.
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`
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`28.
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`Defendants deny each and every allegation contained in Paragraphs “31”, “32”,
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`“33”, “34”, “35”, “36” and “38” and all sub-paragraphs contained therein.3
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`BY WAY OF ANSWERS TO THE SIXTEENTH COUNT:
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`1-26. Defendants repeat each and every response to Paragraphs “1” through “26” of
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`the First Count as if more fully set forth herein.
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`27.
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`Defendants have insufficient knowledge to admit or deny the allegations
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`contained in Paragraph “27” and therefore leave the Plaintiffs to their proof.
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`28.
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`Defendants deny each and every allegation contained in Paragraph “28” of the
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`Supplemental Complaint.
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`29.
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`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “29” and therefore leave the Plaintiffs to their proof.
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`30.
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`Defendants deny each and every allegation contained in Paragraph “30” of the
`
`Supplemental Complaint.
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`BY WAY OF ANSWERS TO THE SEVENTEENTH COUNT:
`
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`1-29. Defendants repeat each and every response to Paragraphs “1” through “29” of
`
`the Thirteenth Count as if more fully set forth herein.
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`30.
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`Defendants have insufficient knowledge to admit or deny the allegations
`
`contained in Paragraph “30” and, therefore, leave the Plaintiffs to their proof.
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`BY WAY OF A FIRST SPECIAL DEFENSE TO ALL COUNTS
`
`If the plaintiffs sustained any injuries or damages as alleged in the Complaint, then said
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`injuries and damages were solely and/or proximately caused by the negligence of the plaintiffs
`
`in that they:
`
`3 There is no Paragraph “37”.
`
`
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`
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`a.
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`b.
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`c.
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`d.
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`Failed to adequately maintain their Unit;
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`Failed to timely repair their Unit;
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`Failed to make necessary and recommended repairs to their Unit.
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`Failed to ensure that their tenant properly and adequately maintained their Unit.
`
` e.
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`Exposed themselves to any toxic substances.
`
`
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`BY WAY OF A SECOND SPECIAL DEFENSE TO ALL COUNTS
`
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`Any award for damages that is recovered by the Plaintiff must be reduced pursuant to
`
`Connecticut General Statutes Section 52-225a.
`
`
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`BY WAY OF A THIRD SPECIAL DEFENSE TO ALL COUNTS
`
`The injuries and damages alleged by the plaintiffs were not caused by or the result of
`
`the alleged negligence of the defendants, but were associated with pre-existing conditions
`
`and/or the negligence of other parties.
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`
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`BY WAY OF A FOURTH SPECIAL DEFENSE TO ALL COUNTS
`
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`The plaintiffs have failed to mitigate their damages.
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`
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`BY WAY OF A FIFTH SPECIAL DEFENSE TO ALL COUNTS
`
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`The plaintiffs claims are barred by the applicable Statute of Limitations including but
`
`not limited to Conn. Gen. Stat. Sections 52-577, 52-577(c) and 52-584.
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`BY WAY OF A SIXTH SPECIAL DEFENSE TO ALL COUNTS
`
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`The plaintiffs’ claims are barred by the doctrines of waiver, release or estoppel.
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`BY WAY OF A FIRST CROSS-CLAIM AGAINST DEFENDANT SPM
`MAINTENANCE AND CONSTRUCTION
`
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`Defendants here assert the following cross-claim against defendant SPM Maintenance
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`and Construction and allege as follows:
`
`1.
`
`Defendant SPM Maintenance and Construction performed work on the
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`plaintiffs’ Unit.
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`2.
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`That the work performed by SPM Maintenance and Construction was
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`performed pursuant to a contract.
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`3.
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`That no work was performed by Defendants Fox Hill Condominium
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`Association, Inc. and/or Scalzo Property Management, Inc., who complied with all terms of
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`the contract.
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`4.
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`That the to the extent any work performed by SPM Maintenance and
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`Construction contributed to the damages alleged by the plaintiff, then SPM Maintenance and
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`Construction breached its contract.
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`5.
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`That to the extent the contract was breached, then SPM Maintenance and
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`Construction is obligated to indemnify Fox Hill Condominium Association, Inc. and/or Scalzo
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`Property Management, Inc. for any award the plaintiffs secure against the defendants.
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`BY WAY OF A SECOND CROSS-CLAIM AGAINST DEFENDANT SPM
`MAINTENANCE AND CONSTRUCTION
`
`Defendants here assert the following cross-claim against defendant SPM Maintenance
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`and Construction and allege as follows:
`
`1.
`
`Defendant SPM Maintenance and Construction performed work on the
`
`plaintiffs’ Unit.
`
`
`
`2.
`
`That the work performed by SPM Maintenance and Construction was not
`
`performed properly and/or was performed in a negligent manner.
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`3.
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`That the to the extent any work performed by SPM Maintenance and
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`Construction contributed to the damages alleged by the plaintiff, then SPM Maintenance and
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`Construction is obligated to contribute towards any award issued to the plaintiffs caused by its
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`negligence.
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`BY WAY OF A CROSS-CLAIM AGAINST DEFENDANT JOHN J. RUSSINKO
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`Defendants hereby assert the following cross-claim against defendant John J. Russinko
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`and allege as follows:
`
`1.
`
`2.
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`Defendant John J. Russinko was hired to perform work on the plaintiffs’ Unit.
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`That the work performed by John J. Russinko was performed in an inadequate
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`and otherwise negligent manner.
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`3.
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`That the to the extent any work performed by John J. Russinko contributed to
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`the damages alleged by the plaintiff, then John J. Russinko is obligated to contribute to any
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`award the plaintiffs secure against the defendants.
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`WHEREFORE, the Defendants demand judgment:
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`(a) dismissing the Supplemental Complaint;
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`(b) awarding them judgment on their cross-claims;
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`
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`(b) awarding them the costs and disbursements of this action; and
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` (c) awarding them such other and further relief as this Court may deem just and
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` proper.
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`DEFENDANTS
`FOX HILL CONDOMINIUM
`ASSOCIATION INC. and SCALZO
`PROPERTY MANAGEMENT, INC.
`
`
`
`
`_____________________________
`James K. Baden
`MILBER MAKRIS PLOUSADIS
` & SEIDEN, LLP
`100 Manhattanville Road Suite 420
`Purchase, New York 10577
`(914) 681-8700
`Firm Juris Number: 419029
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`By:
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`C E R T I F I C A T I O N
`
`I certify that a copy of this A n s w e r T o S u p p l e m e n t a l C o m p l a i n t
`w i t h S p e c i a l D e f e n s e s a n d C r o s s - C l a i m s was or will immediately be
`mailed or delivered electronically or non-electronically on M a y 2 , 2 0 2 3 , to all attorneys
`and self- represented parties of record and that written consent for electronic delivery was
`received from all attorneys and self-represented parties of record who received or will
`immediately be receiving electronic delivery.
`
`
`Plaintiff Pro Se
`
`Mr. and Mrs. Arora
`358 Newtown Turnpike
`Redding, Connecticut 06896
`aroragi@gmail.com
`anjaliberiarora@gmail.com
`
`Counsel for John R. Russinko
`
`David A. Corbett, Esq.
`Litchfield Cavo LLP
`82 Hopmeadow Street, Suite 210
`Simsbury, CT 06089
`corbett@litchfieldcavo.com
`
`
`Counsel for SPM Maintenance and Construction
`
`Stephanie S. Berry, Esq.
`Tang & Maravelis, P.C.
`67 West Main Street
`Clinton, CT 06413
`(860) 443 – 8900
`sberry@tangmaravelis.com
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`___________________________
`
`By: James K. Baden
`jbaden@milbermakris.com
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