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`LAMPERT,TOOHEY&RUCCI,LLC
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`46MainStreet,NewCanaan,CT06840
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`
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`(203)972-8100FAX(203)972-8716
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`
`
`
`
`RETURN DATE: MARCH 7, 2017
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`: SUPERIOR COURT
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`CANAAN DISTRIBUTORS CORP.
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`: ].D. OF STAMFORD/ NORWALK
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`VS.
`
`: AT STAMFORD
`
`PARISH MILLWORK, LLC
`
`: FEBRUARY 10, 2017
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`FIRST COUNT: Breach of Contract
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`COMPLAINT
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`1.
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`At all times mentioned within this Complaint, the plaintiff, Canaan
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`Distributor Corp. is a Corporation organized and existing under the law of the State of
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`Connecticut with it’s principle place of business at New Canaan, Connecticut.
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`2.
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`The defendant, Parich Millwork, LLC is a limited liability company
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`organized and existing under the law of the State of Connecticut with a principle place
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`of business at Ridgefield, Connecticut.
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`3.
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`On or about April 21, 2016, the defendant ordered metal hinges and
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`subsequently ordered additional metal hinges on August 19, 2016 and September 22,
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`2016.
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`4.
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`The first set of metal hinges were shipped out by United Parcel Service
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`(hereinafter "U.P. S.) to the defendant's place of business, and the second shipment
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`
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`IurisNo.420060
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`
`
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`
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`were sent UPS directly to the jobsite on September 22, 2017. They were inspected and
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`accepted by the defendant as in satisfactory condition and in compliance with the
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`specifications of the orders.
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`5.
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`Pursuant to the Contract, the purchase price for metal hinges on all
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`orders totaled was $21,215.84.
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`6.
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`The parties agreed and subsequently did an accounting of all goods
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`ordered and accepted, and thereafter agreed the total amount due was $21, 215.84.
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`7.
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`After repeated written demand for payment from the plaintiff, the
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`defendant has failed refused or otherwise neglected to pay the plaintiff the full
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`purchase price in accordance with the Contract.
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`8.
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`The defendant has breached to terms of the Contract, and the plaintiff
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`has suffered monetary damages.
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`9.
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`Pursuant to the terms and conditions of paragraph 10E of the Contract,
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`the plaintiff is entitled to reasonable costs, expenses and attorney fees as a result of the
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`defendant breach of the Contract.
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`1-9.
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`Paragraphs 1 through 9 of the First Count are hereby re-alleged and
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`incorporated as Paragraphs 1 through 9 of the Second Count as if fully alleged and set
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`forth herein.
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` SECOND COUNT: Unjust Enrichment
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`10.
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`As a direct result of the foregoing actions by the defendant and it’s default of
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`the terms of the Contract, the defendant has been unjustly enriched and benefited
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`from its failure to pay the full purchase price for the goods delivered in Violation of
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`the Contract.
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`11.
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`As a direct result of the defendant’s failure to the plaintiff in default of the
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`Contract, the plaintiff has suffered substantial damages and financial losses all to the
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`plaintiff’s detriment.
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`THIRD COUNT: QUANTUM MERUIT
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`1-9.
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`Paragraphs 1 through 9 of the First Count are hereby re-alleged and
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`incorporated as Paragraphs 1 through 9 of the Second Count as if fully alleged and set
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`forth herein.
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`10.
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`The defendant knowingly utilized, ordered and accepted the metal hinges as
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`the parties had agreed, used them in the project and demanded the payment from
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`their customer.
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`11.
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`The defendant represented to the plaintiff they would be compensated under
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`the Agreement described above, which was evidenced by the course of conduct of the
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`parties as it relates to the ordering and delivery of the metal hinges.
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`12.
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`The defendant has received the benefit of the metal hinges delivered by the
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`plaintiff, for which has yet to be paid in full.
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`13. The defendant has failed to pay Columbus the reasonable value of said services.
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`14. Accordingly, the defendant has been damaged in an amount to be proven at trial.
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`WHEREFORE, the Plaintiff respectfully prays for the following relief:
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`1.
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`2.
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`3.
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`4.
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`Money Damages;
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`Interest pursuant to Conn. Gen. Stat. §37—3a
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`Costs of this action; and
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`Such other and further relief as to equity may pertain.
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`THE PLAINTIFF,
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`
`
`
`a
`BY
`Jason P. WV
`
`
`Imupert, oohey & Rucci, LLC
`46 Main Street
`
`New Canaan, CT 06840
`Tel. 203-972-8100
`
`Juris No. 420060
`
`
`
`
`
`
`
`
`
`
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`
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`IurisNo420060
`
`RETURN DATE: MARCH 7, 2017
`
`: SUPERIOR COURT
`
`CANAAN DISTRIBUTORS CORP.
`
`: ].D. OF STAMFORD/ NORWALK
`
`VS.
`
`: AT STAMFORD
`
`PARISH MILLWORK, LLC
`
`: FEBRUARY 10, 2017
`
`STATEMENT OF AMOUNT IN CONTROVERSY
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`The Plaintiff claims money damages of more than Fifteen Thousand
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`($15,000.00) Dollars, exclusive of interest and costs.
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`THE PLAINTIFF,
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`("L one, E q.
`
`a Toohey & ucci, LLC
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`46 Main Street
`New Canaan, CT 0
`Tel. (203) 972-8100
`Juris No. 420060
`
`LawOfiicesof
`
`
`
`
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`LAMPERT,TOOI-lEY&RUCCI,LLC
`
`
`
`46MainStreet,NewCanaan,CT06840
`
`
`
`(203)972-8100FAX(203)972—8716
`
`
`
`
`
`
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