`:
`Ae
`App ure
`lo 200
`RETURN DATE: DEGEVIBERGS-2922
`
`JULIET GRAHAM
`
`Vv.
`
`SAINT MATTHEW ANGLICAN CHURCH OF ISLIP, INC.
`
`AND REV. JUAN MARENO
`
`:
`
`:
`
`:
`
`:
`
`SUPERIOR COURT
`
`JUDICIAL DISTRICT OF
`
`BRIDGEPORT
`
`DECEMBER 9, 2022
`
`COUNT ONE (Breach of Contract-Rev. Juan Mareno)
`
`COMPLAINT
`
`1. On July 10, 2019, Plaintiff entered into an agreement with the Defendant Rev. Juan Mareno,
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`to provide consultant services to Saint Matthew Anglican Church ofIslip, Inc., (“SAINT MATTHEW”) in
`helping Saint Matthew secure a loan to buy property.located at 88 Hawthorne Avenue, Brentwood, NY
`11717. The agreementstated the terms and conditions that both
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`the Plaintiff and Defendants were bound by until Saint Matthew closed on the transaction in
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`January 2020.
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`2. The Defendant, Rev. Juan Mareno , has failed and refused to pay for the consultant
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`services rendered by the Plaintiff based on the agreement.
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`3. Asaresult of Defendant Rev. Mareno’s conduct,the Plaintiff has been damaged.
`
`COUNT TWO (Unjust Enrichment- Saint Matthew Anglican Church ofIslip, Inc.)
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`1-2. Paragraphs 1 and 2 of Count One are hereby made Paragraphs 1 and 2 of Count Two asis
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`morefully set forth herein.
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`3. The Defendant, Saint Matthew Anglican ChurchofIslip, Inc., was the buyer of the Property at
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`the time said consultant services were rendered and/or materials supplied.
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`4. The Defendant, Saint Matthew Anglican Church ofIslip, Inc., has failed and refused to pay
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`Plaintiff for the value of said consultant services and/or materials provided despite receiving the
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`benefit and value of same and thus has been unjustly enriched.
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`5. Asa result of Defendant, Saint Matthew Anglican ChurchofIslip, Inc’s conduct, the Plaintiff has
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`been damaged.
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`
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`WHEREFORE,the Plaintiff claims:
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`1. Money damages.
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`2. Reasonable fees and costs for money damages in an amount more than $15,000 exclusive of
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`interest and costs.
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`3. Such other and further relief as to equity may belong.
`
`Dated at Bridgeport, Connecticut, this 9° day of December, 2022.
`
` atfet Graham
`
`2040 Huntington Road
`Stratford, CT 06614
`Telephone No.:
`(203) 685-6877
`Plaintiff Pro Se
`
`
`
`et vnc iW 22%
`RETURN DATE: DECEMBER 29, 2022
`
`JULIET GRAHAM
`
`V.
`
`SAINT MATTHEW ANGLICAN CHURCH OF ISLIP, INC.
`
`AND REV. JUAN MARENO
`
`:
`
`:
`
`:
`
`:
`
`SUPERIOR COURT
`
`JUDICIAL DISTRICT OF
`
`BRIDGEPORT
`
`DECEMBER 9, 2022
`
`BY WAY OF RELIEF
`
`1. Money Damages;
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`2. The amount in demand bythe Plaintiff is less than $15,000, exclusive of interest and
`costs;
`,
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`3. The remedy sought is based upon and implied promise to pay a definite sum.
`
` THE PLAINTIFF
`
`2040 Huntington Road
`Stratford, CT 06614
`Telephone No.:
`(203) 685-6877
`Plaintiff Pro Se
`
`
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