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`Appellate Court
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`Appellate Docket No. AC-49418 &
`AC-49419
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`Docket Nos. HFH-CV25-6035877-S &
`HFH-CV25-6035878-S
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`WASHINGTON, ANNETTE L.
`WASHINGTON, BASIL C.
`
` VS
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`FEDERAL HOME LOAN
`MORTGAGE CORPORATION
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`Return Date October 10th, 2025
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`SUPERIOR COURT
`
`HOUSING COURT SESSION
`JUDICIAL DISTRICT OF
`HARTFORD
`(at 80 Washington St., Hartford)
`
`
`
`January 27th, 2026
`
` WRITTEN OBJECTION BY: Basil-Clifton Washington Annette-Lois Washington
`Competent Witness
`FILED: On or about 30th Day month of January year 2026
`
`(Start of Word Count)
`APPELLANTS’ OBJECTION AND REPLY TO OPPOSING
`APPELLEE’S MOTION TO TERMINATE PROSPECTIVE AND
`CURRENT STAYS ON APPEAL
`NOW COMES the Joint Appeal Appellants, Annette-Lois Washington
`and Basil-Clifton Washington (Mr./Mrs. Washington-Appellants), a natural
`person (Woman and Man), appearing specially and in propria persona, pursuant to
`Practice Book §§ 61-11(d) and 61-11(e), the Appellants hereby respectfully
`submit this Objection and Reply to the Appellee’s Motion to Terminate Current
`and Prospective Stays on Appeal. In opposition to this motion, Appellants state as
`follows:
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`I. PRELIMINARY STATEMENT
`The Trial Court lacks jurisdiction to rule due to the fact of the existence of an
`Automatic Appellate Stay in the appeals of: AC-49418, AC-49419, AC 49476
`and AC 49477 and that Appellee’s Motion is untimely and makes false
`misrepresentation of material fact by using Practice Book § 61-11(e) see Motion
`at pages 3-4 by alleging and we quote:
`“As no new appeal has been filed, it is appropriate to file this Motion with
`the clerk of the trial court.”
`“Further, “[t]he court can take prospective action to terminate repetitive,
`automatic stays which, when so misused, can create a proverbial
`‘perpetual motion machine’ preventing the case from ever
`concluding…….”
`Judgment has already been rendered and timely appeals have followed in AC-
`49418 re: HFH-CV25-6035877-S and AC-49419 re: HFH-CV25-6035878-S
`challenging jurisdiction, then another appeal of AC 49476 re: HFH-CV25-
`6035877-S and AC 49477 re: HFH-CV25-6035878-S were filed after a post-
`judgment ruling was made despite the fact there was an appellate jurisdictional
`challenge. Appellee’s Motion is a procedurally improper and substantively
`meritless attempt to leverage a lengthy and complex history of related litigation to
`circumvent the fundamental jurisdictional defects that render the underlying
`judgment in this summary process action void ab initio. The Motion misstates the
`procedural record, ignores Appellee’s own contradictory judicial admissions, and
`is predicated on incompetent evidence. The Motion seeks an extraordinary
`remedy based on a false premise that the current appeal is merely dilatory. In
`truth, these appeals present substantial, non-frivolous challenges to subject matter
`jurisdiction, personal jurisdiction, and fraud upon the court—defects which
`cannot be waived and which mandate reversal. The automatic stay must be
`preserved to prevent the irreparable harm of an eviction based on a void order.
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`II. PRELIMINARY OBJECTION & STATEMENT
`Appellants Annette L. Washington and Basil Washington (collectively,
`“Appellants”) hereby object to and reply in opposition to Appellee’s Motion to
`Terminate Prospective and Current Stays on Appeal. The Motion is procedurally
`improper, factually misleading, and seeks an extraordinary remedy based on an
`incomplete and prejudicial recitation of irrelevant history. The current appeals of:
`AC-49418, AC-49419, AC 49476 and 49477 are derived from the summary
`process judgments in Docket Nos. HFH-CV25-6035877-S and HFH-CV25-
`6035878-S which are meritorious, raising fundamental, non-frivolous challenges
`to the trial court’s subject matter jurisdiction and the constitutional due process
`violations that void the underlying judgment. The automatic stay must be
`preserved to prevent the irreparable execution of a void order.
`III. BRIEF HISTORY IN SUPPORT OF OBJECTION
`1. On October 3, 2025, Petitioner/Appellee filed defective summary process
`Complaints lacking essential jurisdictional allegations and proofs in Docket
`No. HFH-CV25-6035877-S and HFH- CV25-6035878-S.
`2. Respondents and Appellants Annette L. Washington and Basil Washington
`timely filed individually with their appearances an attached statutory Claim of
`Exemption – Summary Process (Eviction) (Form JD-HM-3, C.G.S. § 47a-
`26h) with supporting Affidavit (Entry nos. 112.50 and 112.60 in Docket No.
`HFH-CV25-6035877-S and Entry nos. 111.50 and 111.60 in Docket No.
`HFH-CV25-6035878-S).
`3. Judge Walter Michael Spader Jr., without hearing or legal authority,
`reclassified this statutory claim as an "Answer," thereby fraudulently closing
`pleadings and denying Respondents their rights to: (a) an exemption hearing;
`(b) challenge subject matter jurisdiction; and (c) access to the court.
`4. Based on this jurisdictional fraud and defective complaint, Judge Spader
`entered a Judgment of Possession on November 18, 2025.
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`5. Despite repeated challenges, Judge Spader has refused to: (a) address the
`jurisdictional defects in the Complaint; (b) hold a hearing on the Claim of
`Exemption; and (c) rule on Respondents' pending motions and or pleadings
`challenging jurisdiction.
`IV. SPECIFIC FACTS AND LEGAL GROUNDS RELIED UPON FOR
`OBJECTION
`6. The Motion Improperly Conflates Separate Legal Actions and Appeals.
`Appellee’s Motion is an improper collateral attack dressed as a procedural
`request. It dedicates the majority of its argument to cataloging appeals from
`a different, contested foreclosure action (Appellants contest that the
`foreclosure docket of HHD-CV-17-6076206-S is jurisdictionally defective,
`based upon acts of fraudulent inducement, fraudulent misrepresentation of
`material facts and failure to comply with EMAP1 prerequisites which includes
`acts of EMAP fraud which is an issue of Standing among the other issues of
`Standing and “Standing cannot be waived or forfeited2”) to paint Appellants
`
`1 In the precedence of: see KEYBANK, N.A. v. EMRE YAZAR Et Al.; 347 Conn.
`381 Id* at 393 – 394, 297 A.3d 968 (2023) also see Stuart v. Stuart 996 A.2d 259,
`297 Conn. 26 (2010) that states as follows: “In any event, it is manifest to our
`hierarchical judicial system that this court has the final say on matters of
`Connecticut law and that the Appellate Court and Superior Court are bound by
`our precedent.”, “…….. ("[i]t is axiomatic that a trial court is bound by Supreme
`Court precedent"); Martin v. Plainville, 40 Conn. App. 179, 182, 669 A.2d 1241
`(1996) (Appellate Court, as intermediate court, is prevented from "reexamining
`or reevaluating Supreme Court precedent")……”
`2 In the precedence of: see VIRGINIA HOUSE OF DELEGATES, et al., Appellants
`v. Golden BETHUNE-HILL, et al. 587 U.S. ___ (2019); Docket No. 18-281; 139 S.
`Ct. 1945 *Id at 1948 syllabus and at 1951 (2019) states as follows: *Id at 1948
`….“Standing must be met at every stage of the litigation, including on appeal.
`Arizonans for Official English v. Arizona, 520 U.S. 43, 64, 117 S.Ct. 1055, 137
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`as vexatious. This Motion, however, arises from a new, separate summary
`process actions (HFH-CV25-6035878-S and HFH-CV25-6035878-S) filed in
`October of 2025. The validity of this new eviction depends entirely on its own
`jurisdictional footing, which is fatally defective. A party’s litigation history in
`a prior case cannot serve to waive or excuse the jurisdictional and due process
`deficiencies in a new, independently commenced action. Castro v. Viera, 207
`Conn. 420, 429 (1988) (subject matter jurisdiction can be raised at any time).
`7. The Motion Ignores the Core Jurisdictional Defect: A Fraud Upon the
`Court.
`The trial court’s handling of the summary process case demonstrates a fraud
`upon the court that voids all subsequent proceedings.
`
`L.Ed.2d 170. And as a jurisdictional requirement, standing cannot be waived or
`forfeited. To appeal a decision that the primary party does not challenge, an
`intervenor must independently demonstrate standing. Wittman v. Personhuballah,
`578 U.S. ___, ___, 136 S.Ct. 1732, 1736-1737, 195 L.Ed.2d 37. Pp. 1950-1951”
`*Id at 1951 ….. “The standing requirement therefore "must be met by persons
`seeking appellate review, just as it must be met by persons appearing in courts of
`first instance." Arizonans for Official English v. Arizona, 520 U.S. 43, 64, 117 S.Ct.
`1055, 137 L.Ed.2d 170 (1997). As a jurisdictional requirement, standing to litigate
`cannot be waived or forfeited. And when standing is questioned by a court or an
`opposing party, the litigant invoking the court's jurisdiction must do more than
`simply allege a nonobvious harm. See Wittman v. Personhuballah, 578 U.S. ___,
`___-___, 136 S.Ct. 1732, 1736-1737, 195 L.Ed.2d 37 (2016).
`To cross the standing threshold, the litigant must explain how the elements essential
`to standing are met.”
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`a) Judicial Admission of Non-Appearance: The record demonstrates that
`Appellee itself moved for a default judgment based on Appellants’
`“fail[ure] to file an appearance.” This is a formal judicial admission that
`Appellants were not properly before the court.
`b) The Court’s Unauthorized Act: While that motion was pending, the trial
`judge, Hon. Walter Spader, unilaterally and without notice or a hearing,
`mischaracterized Appellants’ timely filed “Claim of Exemption –
`Summary Process (Eviction)” (Form JD-HM-3) and supporting Affidavit
`as an “Answer” (Entry nos. 112.50 and 112.60 in Docket No. HFH-CV25-
`6035877-S and Entry nos. 111.50 and 111.60 in Docket No. HFH-CV25-
`6035878-S). This act was fraudulent and in excess of the court’s authority
`because:
`i. It directly contradicted Appellee’s own pleaded position.
`ii. It unlawfully denied Appellants their statutory right to an
`adjudication of their Claim of Exemption under C.G.S. § 47a-26h.
`iii. It was a transparent attempt to manufacture jurisdiction and avoid
`ruling on the explicit jurisdictional challenges contained within
`Appellants’ filing.
`A judgment procured through such a fraudulent manipulation of the
`court’s own docket is a nullity. Old Wayne Mut. Life Ass’n v. McDonough,
`204 U.S. 8, 9 (1907) (“[I]f the court is without jurisdiction… its
`proceedings are absolutely void.”).
`8. The Summary Process Complaint is Jurisdictionally Void.
`The initiating complaint is a legal nullity. It is an unverified, unsworn
`pleading that fails to state material facts upon the personal knowledge of an
`injured party or competent witnesses as required by C.G.S. § 52-91. It
`provides no proof that Appellee was the holder of equitable title—a
`prerequisite for standing in a post-foreclosure summary process. A court
`cannot exercise subject matter jurisdiction over a cause of action that has not
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`been properly invoked by a valid pleading. Pellegrino v. O’Neill, 193 Conn.
`670, 679 (1984); Practice Book § 10-33.
`9. The Motion’s “Balancing of Equities” is Flawed and Inapplicable.
`Applying the Griffin Hospital factors, 196 Conn. 451, 456 (1985), to an
`untimely and inapplicable termination of the stay motion is not warranted:
`a) Griffin Hospital v. Commissioner on Hospitals and Health Care case
`is inapplicable to this matter.
`i. The argument raised and factors that the trial court should consider
`when determining whether to terminate a stay and sites Griffin
`Hospital v. Commissioner on Hospitals and Health Care. 196
`Conn. 451 (1985) to support Appellee’s argument. However, in
`“Griffin” this case involved the factors to be considered by the trial
`court in determining whether to terminate a stay in an
`administrative appeal wherein the imposition of a stay is not
`automatic. Therefore, Griffin Hospital v. Commissioner on
`Hospitals and Health Care case is inapplicable to this matter, in
`order to deprive a litigant of a secured right requires proper notice
`and a hearing on the matter.
`b) Likelihood of Success on Appeal: HIGH. The appeal presents
`substantial questions of law regarding (a) fraud upon the court, (b) lack of
`subject matter jurisdiction due to a defective complaint, and (c) denial of
`due process. Appellee’s reliance on Green Tree Servicing, LLC v. Clark is
`irrelevant, as that case did not involve the foundational, uncontested
`jurisdictional fraud present here.
`c) Irreparability of Injury: IRREPARABLE TO APPELLANTS.
`Termination would result in eviction from their home based on a void
`judgment. Appellee’s alleged injury—delay—is monetary and speculative,
`and stems from its own decision to initiate a defective action.
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`d) Effect on Other Parties: NONE.
`e) Public Interest: The public interest is not served by executing a judgment
`obtained through court fraud and in defiance of jurisdictional mandates.
`The interest in judicial integrity outweighs any interest in expediency. See,
`e.g., Conn. Nat’l Bank v. Zuckerman, 31 Conn. App. 440, 442 (1993)
`(distinguishing between legitimate appeals and dilatory tactics).
`V. REPLY TO APPELLEE'S LEGAL GROUNDS AND BALANCING OF
`EQUITIES
`The Appellee's reliance on Practice Book §§ 61-11(d) and (e) is misplaced, as
`the underlying judgment is void for lack of jurisdiction. Termination of stays
`is inappropriate where the appeal challenges fundamental jurisdictional
`defects that render the judgment unenforceable. Moreover, applying the
`balancing of equities test from Griffin Hospital v. Commissioner of Hospitals
`& Health Care, 196 Conn. 451, 456 (1985), weighs heavily against
`termination:
`10. Likelihood of Success on Appeal: Contrary to the Appellee's assertion, the
`appeal is meritorious due to the jurisdictional voids outlined above. The
`Appellee's citation to Green Tree Servicing, LLC v. Clark is inapposite, as
`that case did not involve fraud upon the court or admitted non-appearance.
`The appeal is not frivolous but raises substantial questions of due process and
`jurisdictional integrity.
`11. Irreparability of Injury: Immediate enforcement would irreparably harm
`Appellants by evicting them from their home based on a void judgment, while
`the Appellee suffers no comparable harm from delay, having already delayed
`proceedings through its own procedural failures.
`12. Effect on Other Parties: No other parties are affected, but preserving the stay
`protects the integrity of the judicial process.
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`13. Public Interest: The public interest favors upholding jurisdictional safeguards
`and preventing fraudulent judgments, not expediting void proceedings. The
`Appellee's history of procedural inconsistencies undermines any claim to
`expeditious resolution.
`VI. CONCLUSION
`Appellee’s Motion is a transparent attempt to use this Appellate Court’s authority
`to enforce a void judgment from the trial court. The extraordinary remedy of
`terminating prospective stays is reserved for clear cases of bad-faith delay, not for
`appeals that legitimately challenge a trial court’s fundamental lack of power to
`act.
`WHEREFORE, Appellants respectfully request that this Honorable
`Court DENY Appellee’s Motion to Terminate Prospective and Current Stays on
`Appeal in its entirety, and maintain the automatic stay pending the resolution of
`Appeals of: AC-49418, AC-49419, AC 49476 and 49477. The Appellee's Motion
`should be denied. The underlying judgment is void ab initio due to fraud,
`jurisdictional defects, and procedural violations. The equities strongly favor
`maintaining the stays to allow full appellate review. For the foregoing reasons, the
`Court should deny the Motion in its entirety.
`(End of Word Count 2,211)
`
`Respectfully submitted by Appellants Mr./Mrs. Washington-Pro Se Litigants,
`BASIL WASHINGTON
`Basil Washington
`Basil Clifton Washington
`
`
`_____/s/ jahslaw613__1-29-2026
`141 and 143 Pearl Street
`Manchester, Connecticut near [06040]
`non–domestic
`ANNETTE L. WASHINGTON
`Annette Washington
`Annette Lois Washington
`
`
`____/s/ dental13_____ 1-29-2026
`141 and 143 Pearl Street
`Manchester, Connecticut near [06040]
`non–domestic
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`Basil-Clifton: Washington
`non-negotiable autograph under thumb
`seal and in service, all rights reserved
`with Prejudice without waiver of any
`defense3.
`
`
`Annette-Lois: Washington
`non-negotiable autograph under thumb
`seal and in service, all rights reserved
`with Prejudice without waiver of any
`defense 4.
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`ORDER
`
`The foregoing having been heard; it is hereby ORDERED that the OBJECTION
`TO ORDER is hereby: GRANTED / DENIED and SUSTAINED /
`OVERRULED
`
`BY THE COURT
`
`________________________
`Judge
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`3 All Constitutional Rights Invoked and None are Waived
`4 All Constitutional Rights Invoked and None are Waived
`Thumb Print Seal
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`Thumb Print Seal
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`CERTIFICATE OF SERVICE AND NOTICES
`We the undersigned are non-attorneys and non-bar members and state and give
`notice that the following: We are standing on Constitutional Secured Rights
`and Common Law Rights are Invoked and that None are Waived and The
`Appellants, “Real Parties of Interest”, Basil-Clifton: Washington and Annette-
`Lois: Washington, hereby certifies that a true and correct copy of the foregoing:
`has been furnished via U.S. First Class Mail on 30th Day of Month of January
`2026 or around the date of filing or will be mailed to the office of Counsel for the
`Opposing Party and see notices below:
`
`1. FEDERAL HOME LOAN MORTGAGE CORPORATION
` c/o Attorney:
`BROCK AND SCOTT PLLC (439942)
`270 FARMINGTON AVENUE
`SUITE 151
`FARMINGTON, CT 06032
`
`2. Hon. Walter Spader, Superior Court Judge C/o Office of the Clerk 80
`Washington Street, Hartford, CT 06106
`
`3. CC: Connecticut Attorney General – William Tong (Attorney
`General) – 165 Capitol Avenue, Hartford, CT 06106
`
`4. CC: United States Attorney for the District of Connecticut – 157
`CHURCH STREET 17TH, FLOOR NEW HAVEN, CT 06510
`
`
`
`______________________________________
`Basil-Clifton Washington
`With Prejudice UCC 1-308
`C/o MAILING 141 and 143 PEARL ST
`MANCHESTER, CT 06040
`
`______________________________________
`Annette-Lois Washington
`With Prejudice UCC 1-308
`C/o MAILING 141 and 143 PEARL ST
`MANCHESTER, CT 06040
`
`
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`Appellate Court
`
`Appellate Docket No. AC-49418 &
`AC-49419
`
`Docket No. HFH-CV25-6035877-S &
`HFH- CV25-6035878-S
`
`WASHINGTON, ANNETTE L.
`WASHINGTON, BASIL C.
`
` VS
`
`FEDERAL HOME LOAN
`MORTGAGE CORPORATION
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`Return Date October 10th, 2025
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`SUPERIOR COURT
`
`HOUSING COURT SESSION
`JUDICIAL DISTRICT OF
`HARTFORD
`(at 80 Washington St., Hartford)
`
`
`January 27th, 2026
`
`WRITTEN OBJECTION BY: Basil-Clifton Washington Annette-Lois Washington
`Competent Witness
`FILED: On or about 30th Day month of January year 2026
`(Start of Word Count)
`
`MOTION TO STRIKE ALL ATTORNEY PLEADINGS
`WITH ATTACHED AFFIDAVIT IN SUPPORT
`TO THE HONORABLE JUDGES OF THE APPELLATE
`COURT:
`NOW COMES the Joint Appeal Appellants, Annette-Lois Washington
`and Basil-Clifton Washington (Mr./Mrs. Washington-Appellants), a natural
`person (Woman and Man), appearing specially and in propria persona, and
`respectfully moves this Court to strike all pleadings, memoranda, motions, and
`other submissions filed by or on behalf of any purported attorney for the alleged
`Opposing Party-Appellee per General Statutes § 51-14 and Practice Book § 1-8
`("Movant"), and in support thereof states:
`
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`I. BRIEF HISTORY
`After Opposing Party’s filings: (1) dated January 23rd, 2026 of Motion to
`Terminate Current and Prospective Stays on Appeal with the Appellate Court and
`(2) refiling again after being returned as a Trial Court Motion on January 27th,
`2026. This Motion to Strike is again necessitated by a documented pattern of
`procedural fraud and the unauthorized practice of law that has corrupted the
`record of this case from its inception in the underlying summary process for
`possession actions (HFH-CV25-6035877-S & HFH-CV25-6035878-S) and in
`the resulting appeals of AC-49418, AC-49419, AC-49476 & AC-49477.
`1. The Unauthorized Initiation of Proceedings: The summary process for
`possession actions were initiated by pleadings that are fatally jurisdictionally
`defective. The complaints lack verification by FEDERAL HOME LOAN
`MORTGAGE CORPORATION (“FREDDIE MAC”, the “Opposing Party”)
`or any parties with personal knowledge as required by Practice Book § 4-2(b),
`(c) and common law see Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007)
`and Ashcroft v. Iqbal, 566 U.S. 662 (2009). Complaints were filed by
`attorneys whose allege authority to represent the named “Opposing Party”
`which has never been established by competent evidence and or proof.
`2. The Fraudulent Procurement of Jurisdiction: In the instant summary
`process action, the Opposing Party’s-Appellee's attorneys filed a Motion for
`Default for Failure to Appear (JD-HM-9) knowing the fact that there are no
`John Doe 1, John Doe 2, Jane Doe 1 and Jane Doe 2 and they do not exist
`and the Opposing Party’s failure to remove all “Doe(s)” and Opposing Party
`has failed to provide proof of existence after affidavits were filed by Mr./Mrs.
`Washington disavowing any existence of any “Doe(s)” this is fraudulent
`procurement of jurisdiction by Opposing Party’s failure to file a counter
`affidavit of Proof of perjury committed by Mr./Mrs. Washington stating a
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`position of a fact of “Knowing of the presence of an occupant but does not
`know the name of such occupant”, this means that the alleged owner or lessor,
`or the alleged owner's or lessor's legal representative, attorney-at-law or
`attorney-in-fact knows there are 2 other males and 2 other females other than
`in addition to Mr./Mrs. Washington not speculative, that is a clear violation of
`Conn. Gen. Stat. § 47a-23(b) as this is fraud and the law cannot support such
`an act Ex dolo malo non oritur action Out of fraud no action arises; fraud
`never gives a right of action. No court will lend its aid to a man who founds
`his cause of action upon an immoral or illegal act. As found in Black's Law
`Dictionary, Fifth Edition, page 509. Formally representing to the court that the
`Appellants had "failed to file an appearance." Simultaneously and
`irreconcilably, the presiding judge (Hon. Walter Spader) fraudulently
`mischaracterized the properly filed Claim of Exemption and Affidavit (JD-
`HM-3) by Mr./Mrs. Washington as an "Answer." This fraudulent
`reclassification is evidenced by the Opposing Party’s own responsive
`pleadings, titled "OPPOSING PARTY’S OPPOSITION TO THE
`MOTION" (Entry 118.00 in HFH-CV25-6035877-S and Entry 117.00 in
`HFH-CV25-6035878-S), in which Opposing Party's counsel explicitly
`states: "Opposing Party hereby supplies this opposition to Defendants’
`filing at 112.50 (HFH-CV25-6035877-S). While the court has
`characterized it as an ‘Answer,’ Opposing Party is responding to it as if it
`is a motion..." and "Opposing Party hereby supplies this opposition to
`Defendants’ filing at 111.60 (HFH-CV25-6035878-S). While the court has
`characterized it as an ‘Answer,’ Opposing Party is responding to it as if it
`is a motion in case it is later considered a motion at the remote trial
`scheduled November 18, 2025."
`3. The Unauthorized and Evidentiary-Deficient Prosecution: Throughout
`these proceedings, the attorneys from BROCK & SCOTT PLLC, have
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`prosecuted this action without ever providing competent, admissible evidence
`of:
`a) Their lawful authority to represent the named FEDERAL HOME
`LOAN MORTGAGE CORPORATION.
`b) The Opposing Party's standing as the holder of any equitable right or
`title to the premises.
`c) Any sworn testimony or affidavit from parties with personal
`knowledge of the facts alleged.
`Their role has been exclusively that of unsworn narrators, attempting
`to substitute argument for evidence in violation of Krawczyk v.
`Stingle and State v. Ferguson.
`4. The Self-Incriminating "Military Affidavit": The "Affidavit Concerning
`Military Status" filed by these attorneys' agent, Lisa Whittemore, admits to
`their lack of a bona fide attorney-client relationship and their function as third-
`party interlopers. It demonstrates an attempt to perform a factual investigation
`(for SCRA compliance Service-Members Civil Relief Act, 50 U.S.C. § 3931.)
`through a non-attorney employee, rather than through lawful client
`instructions, further proving they are not acting under the direction of a true
`client-in-interest.
`This history reveals a litigation strategy built not on lawful advocacy, but
`on the filing of procedurally defective pleadings by unauthorized persons,
`followed by reliance on the court's clerical processes to confer an illusion of
`validity. In this case also demonstrates the fraudulent misuse of Connecticut
`General Statute § 47a-23(b) - Notice to quit possession or occupancy of premises,
`Form, Delivery, Federal termination notice and § 47a-23a(a) - Complaint.
`II. STATEMENT OF FACTS RELIED UPON
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`5. No Verified Complaint: The Summary Process for Possession Complaints
`are not verified by the oath or affirmation of the Opposing Party, nor of any
`parties with personal knowledge of the facts alleged, as required by Practice
`Book § 4-2(b), (c) and the common law see Bell Atlantic Corp. v. Twombly,
`550 U.S. 544 (2007) and Ashcroft v. Iqbal, 566 U.S. 662 (2009).
`6. No Proof of Attorney Authority: The Appearance filed by Brock & Scott
`PLLC and all subsequent pleadings filed by Diane S. Summers, Esq., and
`related attorneys, are unaccompanied by any sworn affidavit, power of
`attorney, or other authenticated document demonstrating they have been
`retained by, and have the authority to act for, the named Opposing Party,
`"Federal Home Loan Mortgage Corporation."
`7. Judicial Admission of Non-Appearance: On or about October 6, 2025, the
`Opposing Party's attorneys filed a Motion for Default for Failure to
`Appear (JD-HM-9) (attached as composite Exhibit A to Opposing Party's
`own Motion to Dismiss), which states: "The Opposing Party... asks that
`judgment for possession... be entered... because the defendant(s)... have failed
`to file an appearance."
`8. Fraudulent Reclassification of Pleading: On October 31, 2025, the Mr./Mrs.
`Washington-Appellants filed a Claim of Exemption – Summary Process
`(Eviction) (Form JD-HM-3) and supporting Affidavit. The court (Hon. Walter
`Spader), on the same day, fraudulently docketed this filing as an "Answer."
`The Opposing Party's own attorney confirmed this confusion and fraud in
`the "OPPOSITION TO THE MOTION" (Entries 117.00 in HFH-CV25-
`6035878-S & 118.00 in HFH-CV25-6035877-S.), stating they were
`responding to the filing "as if it is a motion" despite the court's
`characterization. This act fraudulently created a contradiction in the record
`and denied the statutory right to an exemption hearing under C.G.S. § 47a-
`26h.
`
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`9. Unsworn Attorney Factual Assertions: The Opposing Party's "Motion to
`Dismiss the Appeal" is replete with factual assertions regarding procedural
`history, the Mr./Mrs. Washington's actions, and the status of the proceedings,
`all presented without a supporting affidavit, sworn testimony, or authenticated
`exhibit. These are statements of counsel, not evidence.
`10. The "Military Affidavit" Admissions:
`a. The affiant, Lisa Whittemore, identifies herself as an "Operations
`Manager," not an attorney, and not an officer or agent of the
`opposing party “Freddie Mac”.
`b. She attests to attempting to contact the Mrs. Washington-Appellant
`directly via email and phone for case-related information, an act
`inconsistent with a legitimate attorney-client relationship where the
`client's identity and knowledge are presumed.
`c. She admits to using a third-party "Accurint search" from
`LexisNexis to obtain information on an Unknown Defendant(s),
`John Doe 1, John Doe 2, Jane Doe 1 and Jane Doe 2 confirming
`the firm's role as a third-party data collector, not a representative of
`an injured party.
`11. Mr./Mrs. Washington's Uncontested Affidavits: The Appellant's Affidavits
`filed on October 31, 2025, and in prior proceedings, which detail the
`jurisdictional defects and lack of service, remain uncontested by any
`admissible evidence. Under Duke v. Bruce Indep. Sch. Dist., 96 N.W.2d 172,
`175 (S.D. 1959), these uncontested factual allegations must be accepted as
`true.
`12. Unlawful Filings in the Town of Manchester’s Land Records: There have
`been various unlawful filings in the Town of Manchester’s land records based
`upon a defective complaint in the foreclosure docket of HHD-CV17-6076206-
`S and notice of fraudulent conveyance with exhibits filed as docket entry nos.
`
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`143.00 Notice and 144.00 Exhibits in Docket No. HFH-CV25-6035877-S and
`Entry no. 141.00 Notice and 142.00 Exhibits in Docket No. HFH-CV25-
`6035878-S attached hereto as Exhibit A.
`III. CHALLENGE TO AUTHORITY AND DUTY TO PROVE
`SAME
`13. Direct Challenge to Authority: Mr./Mrs. Washington as Joint Appellants are
`required to initiate a direct challenge to the authority of anyone representing
`themselves as an attorney, judicial officer, or commissioner of the court
`before the finality of any proceeding, to avoid the improper application of the
`de facto officer doctrine. This challenge is now formally made. All persons
`filing as attorneys, officers, or agents of “Freddie Mac” are hereby put on
`notice that their authority is contested. Upon such a challenge, the burden
`shifts irrevocably to them to affirmatively prove whatever authority they
`claim. In the absence of such proof, they may be held personally accountable
`for any loss, injury, or damages resulting from their unauthorized acts. The
`Appellants stands on the authority of Montgomery v. State, 55 Fla. 97 (1908),
`regarding the duty to challenge unauthorized officers.
`14. Duty of Full Disclosure and Burden of Proof: "Where one under duty to
`disclose facts to another fails to do so, and the other is injured thereby, an
`action in tort lies against the party whose failure to perform his duty caused
`injury." Regan v. First Nat. Bank, 55 Ariz. 320 (1940). A relationship
`invoking trust or confidence imposes a duty of full and truthful
`disclosure. Stewart v. Phoenix Nat. Bank, 49 Ariz. 34 (1937). The attorneys
`prosecuting this action have breached this duty by failing to disclose and
`prove their foundational authority.
`15. The Opposing Party's Non-Delegable Burden: The law is unequivocal: the
`burden of proving the court's jurisdiction rests solely on the party asserting
`
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`it, not its attorneys. Bindell v. City of Harvey, 212 Ill.App.3d 1042
`(1991); Regan, supra. The attorney is not a party and cannot assume this
`burden. This includes proving the attorney's own lawful authority to appear.
`See Conn. Practice Book § 3-7(a) ("No attorney shall be permitted to appear
`in court or to be heard on behalf of a party until the attorney’s appearance has
`been entered."). The alleged Complainant is "bound" to appear and testify.
`Conn. Code Evid. §§ 6-1, 6-2. Its failure to do so, and its reliance on unsworn
`attorney argument, is a fatal failure of proof.
`16. The Alleged Appearance is a Legal N