`
`SANDPIPER WOODS CONDOMINIUM
`ASSOCIATION, INC.
`
`V.
`
`DEFUSCO, DONNA
`
`:
`
`:
`
`:
`
`2
`
`SUPERIOR COURT
`
`JUDICIAL DISTRICT OF
`
`NEW BRITAIN
`
`April 24, 2015
`
`REPLY TO OBJECTION TO MOTION TO OPEN
`
`Donna DeFusco, defendant in the above-entitled action, hereby replies to Plaintiffs
`
`Objection to Motion to Open.
`
`The Notice of Judgment sent by Plaintiffs counsel was certified to the incorrect address,
`
`and Donna DeFusco did not receive it. In addition, the Motion for Judgment was also certified to
`
`the incorrect address. One can only assume that if the Motion for Judgment and Notice of
`
`Judgment went to wrong address that short calendar marking of the Motion for Judgment also
`
`went to the incorrect address. As such, she did not have knowledge that the judgment was even
`
`pending, entered or the date by which she had to redeem.
`
`Accordingly, the Defendant respectfully request the Court open the Judgment in this
`
`matter.
`
`ORAL ARGUMENT REQUESTED
`TESTIMONY REQUIRED
`
`EFENDANT,
`
` Beth ny E. Balibi , Esqf
`
`KLEIN & BABB rr, LLC
`36-BlWest Main Street
`Avon, CT 06001
`Juris No. 427437
`
`Tel. (860) 677-5885
`Fax (860) 677-5887
`Her Attorneys
`
`1
`
`KLEIN & BABBITT, LLC
`36—B West Main Street, Avon, Connecticut 06001 (860) 677-5885 Fax (860) 677-5887 Juris No. 427437
`
`
`
`ORDER
`
`The foregoing Motion having come before this Court, it is hereby ordered: GRANTED/DENIED
`BY THE COURT
`
`
`
`Judge/Clerk/Assistant Clerk
`
`KLEIN & BABBITT, LLC
`36—B West Main Street, Avon, Connecticut 06001 (860) 677-5885 Fax (860) 677-5887 Juris No. 427437
`
`2
`
`
`
`CERTIFICATION
`
`SANDPIPER WOODS CONDOMINIUM ASSOCIATION, INC
`COHEN BURNS HARD & PAUL
`81 SOUTH MAIN STREET
`2ND FLOOR
`
`WEST HARTFORD, CT 06107
`
`MORTGAGE ELECTRONIC SYSTEMS/ GREENTREE SERVICING LLC
`BENDETT & MCHUGH PC
`160 FARMINGTON AVE.
`FARMINGTON, CT 06032
`
`
`
`CACH LLC
`
`AGENT: CT CORPORATION SYSTEM
`ONE CORPORATE CENTER
`HARTFORD, CT 06103
`BUS: 4340 S. MONACO STREET, 2D FLR
`DENVER, CO 80237
`
`CAPITAL ONE BANK (USA), NA.
`c/0 AGENT FOR SERVICE:
`LAW OFFICES OF HOWARD LEE SCHIFF PC
`510 TOLLAND STREET
`EAST HARTFORD, CT 06108
`BUS: 15075 CAPITAL ONE DRIVE, 2D FLR
`RICHMOND, VA 23238
`
`
` Betha - y’ . Babbitt I 4’:
`
`Commissioner(t):t‘\£hj: Superior Court
`
`KLEIN & BABBITT, LLC
`36—B West Main Street, Avon, Connecticut 06001 (860) 677-5885 Fax (860) 677-5887 Juris No. 427437
`
`3



