OFFICER'S RETURN TO COURT
`
`STATE OF CONNECTICUT:
`: ss: BRISTOL
`COUNTY OF HARTFORD :
`
`August 19, 2019
`
`Then and by virtue hereof and by direction of the Plaintiff's Attorney, on August
`19, 2019, I made due and legal service upon the within named Defendant, The Connecticut
`Light and Power Co. DBA Eversource Energy by leaving a verified true and attested copy of
`the original MOTION TO CITE ADDITIONAL PARTY; WRIT SUMMONS; AMENDED
`COMPLAINT; EXHIBIT A; with and in the hands of Virginia Holloway, Agent for Service,
`Corporation Service Company,person in charge and authorized to accept service at 50 Weston
`St, Hartford, Connecticut.
`
`The within is the original MOTION TO CITE ADDITIONAL PARTY; WRIT
`SUMMONS; AMENDED COMPLAINT; EXHIBITA; with my doings hereon endorsed.
`
` Arthur B. Cyr, State Mar
`
`Hartford County
`
`FEES:
`SERVICE
`PAGES:
`END:
`TRAVEL:
`TOTAL:
`
`$ 40.00
`5.00
`1.60
`28.50
`$ 75.10
`
`

`

`CLERK, SUPERIOR COURT
`JUDICIAL DISTRICT OF NEW BRITAIN
`20 FRANKLIN SQUARE
`NEW BRITAIN, CT 06051
`
`THOMAS CATUCCI
`49 LEOMINSTER ROAD .
`BRISTOL, CT 06010
`
`Notice Issued: 08/13/2019
`Docket Number: HHB-CV-18-5024384-S
`Case Caption: CATUCCI, THOMAS v. PATEL, BHARAT
`
`JDNO NOTICE
`
`Sequence #: 1
`
`PLEASE BE ADVISED THAT THE FOLLOWING ACTION
`HAS TAKEN PLACE WITH REGARD TO THE ABOVE
`MENTIONED CASE:
`
`110.00 MOTION TO CITE ADDITIONAL PARTY
`Granted.
`It appearing that the foregoing motion should be granted, it is hereby
`
`that on or before 8/29/2019 the plaintiff amend his complaint to
`Ordered,
`state facts showing the interest of THE CONNECTICUT LIGHT AND POWER
`COMPANY DBA EVERSOURCE ENERGY in this action and summon THE CONNECTICUT
`LIGHT AND POWER COMPANY DBA EVERSOURCE ENERGY to appear as a defendant in
`this action on or before the second day following 9/10/2019, by causing
`some proper officer to serve on him in the manner prescribed by law a true
`and attested copy of this order, a true and attested or certified copy of
`the complaint in this action as amended, and a Summons Civil Form JD-Cv-1
`and due return make.
`
`(SHORTALL, J.) 8/12/2019
`
`

`

`SUMMONS- CIVIL
`JD-CV-1 Rev.4-16
`C.GS.§§ 51-346,51-347, 51-349,51-350, 52-45a,
`52-48, 52-259, P.B. §§ 3-1 through 3-21, 8-1, 10-13
`
`See other side for instructions
`ca "X"if amount, legal interest or property in demand, notincluding interest and
`, costs is less than $2,500.
`KX if amount, legal interest or property in demand,not including interest and
`
`costs is $2,500 or more.
`)<_"X"if claiming otherrelief in addition to or in lieu of money or damages.
`
`STATE OF CONNECTICUT
`SUPERIOR COURT
`3
`www.jud.ct.gov
`
`Juris number(to be entered by attomeyonly)
`
`TO: Any properofficer; BY AUTHORITY OF THE STATE OF CONNECTICUT,you are hereby commanded to makedue andlegal service of
`this Summons and attached Complaint.
`
`
`
`Return Date (Must be a Tuesday)
`Address of court clerk where writ and other papers shall be filed (Number, street, town and zip code)|Telephonenumber of clerk
`
`(C.G.S. §§ 51-346, 51-350)
`:
`(with area code)
`10 5 019
`SEPTEMBER
`20 FRANKLIN SQUARE, NEW BRITAIN, CT 06051
`( 860 ) 515-5180
`es| ~Year__
`
` eal Dist
`Case type code (See list on page 2)
`At
`(Townin which writ is returnable) (C.G.S. §§ 51-346, 51-349)
`
`Judicial
`District
`Oo GA.
`NEW BRITAIN
`
`
`
`Minor: 20
`Major: P
`
`|_] Housing Session Number:
`Forthe Plaintiff(s) please enter the appearanceof:
`Name and address ofattorney, law firm orplaintiff if self-represented (Number, street, town and zip code)
`THOMAS CATUCCI 49 LEOMINSTER ROAD BRISTOL, CT 06010
`
`Telephone number (with area code)
`atureofBett
`EH
`(860) 585-7143
`The attorneyorlaw firm appearingforthe plaintiff, or the plaintiff if
`self-represented, agrees to accept papers (service) electronically in
`this case under Section 10-13 of the Connecticut Practice Book.
`
`[x] Yes
`
`{2 No
`
`Email address for delivery of papers under Section 10-13 (ifagreed to)
`tom@ludlowlic.com
`
`{_] Form JD-CV-2 attached for additional parties
`1
`NumberofPlaintiffs:
`
`
`
`Name (Last, First, Middle Initial) and Address of Each party (Number; Street; P.O. Box; Town; State; Zip; Country, if not USA)
`Parties
`Name:
`CATUCCI, THOMAS
`P-01
`First
`Plaintiff
`Address: 49 |EOMINSTER ROAD BRISTOL, CT 06010
`Additional
`Name:
`Plaintiff
`Address:
`
`P-02
`
`PATEL, BHARAT
`Name:
`First
`Defendant|Address: 658 STAFFORD AVENUE BRISTOL, CT 06010
`Additional
`Name:
`THE CONNECTICUT LIGHT & POWER CO DBA EVERSOURCE ENERGY
`Defendant
`Address: C/O CORPORATION SERVICE COMPANY 50 WESTON STREET HARTFORD, CT 06120-1537
`Additional
`Name:
`Defendant
`Address:
`Additional
`Name:
`Defendant|Address:
`
`g]8]&&
`
`Notice to Each Defendant
`4. YOU ARE BEING SUED.This paper is a Summonsin a lawsuit. The complaint attached to these papers states the claims that each plaintiff is making
`against you in this lawsuit.
`2. To be notified of further proceedings, you or your attomey mustfile a form called an "Appearance" with the clerk of the above-named Court at the above
`Court address on or before the second day after the above Retum Date. The Retum Dateis not a hearing date. You do not have to cometo court on the
`Return Date unless you receive a separate notice telling you to cometo court.
`3. If you or your attorney do notfile a written “Appearance”form ontime, a judgment maybe entered against you by default. The "Appearance"form may be
`obtained at the Court address above or at www,jud.ct.gov under “Court Forms."
`4. If you believe that you have insurance that may coverthe claim that is being made against you in this lawsuit, you should immediately contact your
`insurance representative. Other action you may haveto take is described in the Connecticut Practice Book which maybe found in a superior court law
`library or on-line at www.jud.ct.gov under“Court Rules."
`5. If you have questions about the Summons and Complaint, you should talk to an attorney quickly. The Clerk of Court is not allowed to give advice on
`
`legal questions.
`ommissionerof
`the
`
`Signed (Sign and "X” proper box)
`
`uperior Court
`|_| Assistant Clerk
`
`
`
`If this Summonsis signed by a Clerk:
`a. The signing has been donesothat the Plaintiff(s) will not be denied access to the courts.
`b.Itis the responsibility of the Plaintiff(s) to see that service is madein the manner provided by law.
`c. The Clerk is not permitted to give any legal advice in connection with any lawsuit.
`d. The Clerk signing this Summonsatthe requestof the Plaintiff(s) is not responsible in any way for any errors or omissions
`in the Summons.any allegations contained in the Complaint, or the service of the Summons or Complaint.
`
`Name of Person Signing at Left
`
`
`
`
`
`File Date
`
`
`
`
`
`
`
`eeriea
`
`
`| certify | have read and
`understand the above:
`
`
`(Page 1 of 2)
`
`8/19/2019
`
`

`

`DOCKET NO: HHB-CV-18-5024384-S
`
`: SUPERIOR COURT
`
`THOMAS CATUCCI
`
`VS
`
`BHARAT PATEL
`
`: J.D. NEW BRITAIN
`
`: AT NEW BRITAIN
`
`: AUGUST 16, 2019
`
`AMENDED COMPLAINT
`
`. Plaintiff is the owner of the subject property known as 642 Stafford
`Avenue,Bristol, CT, which property is further described is “Exhibit A”
`attached hereto and incorporated herein. Property is currently vacant
`land.
`
`. Defendant is the ownerof the abutting property known as 658
`Stafford Avenue, Bristol, CT that is improved with a commercial
`building.
`
`_ The electrical service wires and poles servicing the Defendant's
`property are on the propertyof the Plaintiff. These wires and poles do
`not benefit the Plaintiff in any way and are impeding the development
`of his property.
`
`_ The Defendant has no legal authority for use of the Plaintiff's property
`for the purpose of said electrical service wires and poles.
`
`. The utility wires and poles are owned by The Connecticut Light &
`Power Co. DBA Eversource Energy
`
`

`

`WHEREFORE._
`
`the Plaintiff claims;
`
`1. A judgement determining the rights of the parties in or to the land and
`settling the title thereto.
`
`2. Compensation for the use of the Plaintiff's property.
`
`3. An order requiring the removalof all wires and poles from the land of
`the Plaintiff and restoration of said property.
`
`4. Any andall otherrelief the Court may deem appropriate.
`
`LZ
`
`THOMAS CATUCCI
`49 Leominster Road
`Bristol, CT 06010
`(860) 585-7143
`tom@ludlowllc.com
`
`

`

`EXHIBIT “A”
`
`A certain parcel of land, located in the City of Bristol, County of Hartford
`and State of Connecticut, knownas Lot # 162 (one hundred sixty-two) on the
`Bristol Assessors Map, Page 46(forty-six), Stafford Avenue and Beths Avenue.
`
`Togetherwith a right of way as stated in a quit-claim deed from Julian
`Demora Revocable Trust Dated the 9° Day of October 1990to Liberty Investment
`Corp dated June 22, 2005 and recordedin the Bristol Land Records at Volume
`1647 page 668.
`
`Being the same premises conveyed by Quit-Claim deed to Liberty
`Investment Corp dated September5, 2007 and recordedin the Bristol Land
`Records at Volume 1748 page 696-697.
`
`