RETURN DATE: SEPTEMBER10, 2024
`
`> SUPERIOR COURT
`
`MOUNTAIN RIDGE CONDOMINIUM ASSOCIATION,
`INC.
`
`:
`
`JD OF NEW BRITAIN
`
`PHILIP PANARELLAa/k/a PHIL J. PANARELLA,
`ET AL
`
`: August 12, 2024
`
`: AT NEW BRITAIN
`
`COMPLAINT
`
`1. The Plaintiff, Mountain Ridge Condo Association, Inc., was and is a common interest
`
`community as set forth in the Declaration of Mountain Ridge Condo Association, Inc. dated
`
`August 18, 1988 and recorded in Volume 954 at page 28 in the New Britain Land Records, and
`
`as it may have been or may be amended.
`
`2. The Defendant, Philip Panarella a/k/a Phil J. Panarella and Steven Panarella, acquired
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`title to 30 N. Mountain Road #E, New Britain, CT 06053 by a warranty deed dated October 21,
`
`1988 and recorded in Vol. 971, Page 152 of the New Britain Land Records, subject to all terms
`
`and conditions of said Declaration and as amended which legal description is attached hereto and
`
`made a part hereof as Exhibit “A”. Defendant remains record ownerto date.
`
`3, C.G,S, Section 47-244(2) and said Declaration provide for the assessment of common
`
`expenses by the Plaintiff against all units in the condominium in proportion to their respective
`
`percentages of interest in the common areas of the condominium.
`
`Pilicy & Ryan, P.C.
`235 Main Street Watertown, CT 06795
`Firm Juris: 414927
`
`

`

`4, C.G.S. Section 47-258(a) and said Declaration provide for a lien in favor of the
`
`Plaintiff for all assessments levied and forall fines, fees, late charges, attorney’s fees or interest
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`charges assessed against any unit owner from the time of the assessment or delinquency of such.
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`C.G.S. Section 4-258 (a) and said Declaration further provide that such fines, fees, late charges,
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`interest charges and attorney’s fees are enforceable as assessments.
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`5. C.G.S, Section 47-258(g) and said Declaration further provide that a judgment or
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`decree in any action brought by the Plaintiff shall include a reasonable attorney’s fee and costs.
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`The Plaintiff has complied with the provisions of Connecticut General Statutes Section 47-258
`
`including Section 47-258(m) and Section 47-261b. The Plaintiff has the authority to initiate the
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`instant foreclosure action based on the fact that a standard collection policy has been adopted as
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`a rule which provides for foreclosure against this unit. The rule, as adopted,satisfies the notice
`
`and comment requirements of C.G.S. 47-2616 (a) and (b). Furthermore, this action is in
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`compliance with C.G.S. 47-258 (m) (1) (A) and (B)in that the Defendant Unit Owner owed,at
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`the time the instant action was commenced, a sum equal to at least two months of common
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`charges and the association has made demand for payment and has provided a similar demand to
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`all holders of a 1st or 2nd security interest. Based on the foregoing the Plaintiff claims that this
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`Court has subject matter jurisdiction over this matter by virtue of the Plaintiff having satisfied
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`the requirements of C.G.S. 47-258 (m) (1) (C).
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`6. After crediting Defendant for payments madeto date, there remains an outstanding
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`balance due in the amount equal to or greater than two months’ worth of common expense
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`assessment, inclusive of late fees and charges, which sums continue to accrue.
`
`Pilicy & Ryan, P.C.
`235 Main Street Watertown, CT 06795
`Firm Juris: 414927
`
`

`

`7. Pursuant to C.G.S. Section 47-258(a), the Plaintiff's lien has a priority to the extent of
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`the value of nine months of assessments, plus a reasonable attorney’s fee and costs.
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`8. The following encumbrancesof record are prior in right to the Plaintiff’s interest to
`
`the extent that same are valid:
`
`(a) The Defendant, THE BOARD OF WATER COMMISSIONERS CITY OF NEW
`BRITAIN, may claim an interest by virtue of a Lien in the principal amount of $105.46 dated
`and recorded September 30, 2016 in Volume 1949 at Page 1246, A Lien in the principal amount
`of $99.27 dated and recorded March 31, 2017 in Volume 1963 at Page 668 , a Lienin the
`principal amount of $102.63 dated and recorded September 29, 2017 in Volume 1977 at Page 67,
`A Lien in the principal amount of $109.30 dated and recorded March 29, 2018 in Volume 1989 at
`Page 799 , A Lien in the principal amount of $145.80 dated and recorded September 28, 2018 in
`Volume 2004 at Page 22, A Lien in the principal amount of $113.29 dated and recorded March
`29, 2018 in Volume 2016 at Page 151, A Lien in the principal amount of $128.21 dated and
`recorded September 30, 2018 in Volume 2031 at Page 470, A Lien in the principal amount of
`$128.21 dated and recorded March 31, 2019 in Volume 2046 at Page 1055, A Lien in the
`principal amount of $130.41 dated and recorded September 30, 2020 in Volume 2062 at Page
`397, A Lien in the principal amount of $108.39 dated and recorded March 31, 2021 in Volume
`2080 at Page 760, A Lien in the principal amount of $112.40 dated and recorded October5, 2021
`in Volume 2103 at Page 86 , A Lien in the principal amount of $89.51 dated and recorded March
`31, 2022 in Volume 2123 at Page 288, A Lien in the principal amount of $98.44 dated and
`recorded October 3, 2022 in Volume 2140 at Page 603, A Lien in the principal amount of $77.05
`dated and recorded January 31, 2023 in Volume 2149 at Page 74, A Lien in the principal amount
`of $69.16 dated and recorded May 1, 2023 in Volume 2156 at Page 70, A Lien in the principal
`amount of $68.86 dated and recorded August 1, 2023 in Volume 2163 at Page 860 and a Lien in
`the principal amount of $115. dated and recorded October 31, 2023 in Volume 2170 at Page
`1112, all of the New Britain Land Records.
`
`(b) The Defendant, CITY OF NEW BRITAIN,mayclaim an interest by virtue of
`Certificate continuing Tax Lien in the amount of $3,209.78 dated and recorded June 2, 2021 in
`Volume 2087 at Page 970, A Tax Lien in the amount of $3,146.22 a dated and recorded May5,
`2022 in Volume 2217 at Page 881, and a Tax Lien for not more than fifteen years in the principal
`amount of $3,146. dated and recorded May 5, 2023 in Volume 2156 at Page 999,all of the New
`Britain Land Records.
`
`Pilicy & Ryan, P.C.
`235 Main Street Watertown, CT 06795
`Firm Juris: 414927
`
`

`

`9, The following encumbrancesof record are priorin right to the Plaintiff's interest,
`
`except to the extent of the nine month priority of C.G.S Section 47-258(a):
`
`(a) The Defendant, WEBSTER BANK,may claim an interest in said premises by
`virtue of a Mortgage in the amount of $85,600.00 dated April 13, 2016 and
`recorded April 28, 2016 in Volume 1937 at Page 1272 of the New Britain Land
`Records.
`
`10. The following encumbrances of record are subsequent in right to the Plaintiff's
`interest to the extent sameare valid:
`
`(a) The Defendant, DISCOVER BANK,may claim an interest in said premises by
`virtue of a Judgment Lien in the amount of $3,012.44 dated September 20, 2012
`and recorded October 4, 2012 in Volume 1849 at Page 8 of the New Britain Land
`Records.
`(b) The Defendant, CONNECTICUT ORTHOPAEDIC SPECIALIST, may claim an
`interest in said premises by virtue of a Judgment Lien in the amount of $563.84
`dated February 4, 2021 and recorded February 16, 2021 in Volume 2076 at Page
`77 of the New Britain land Records.
`
`Pilicy & Ryan, P.C.
`235 Main Street Watertown, CT 06795
`Firm Juris: 414927
`
`

`

`WHEREFORE, the Plaintiff claims:
`
`L
`
`ONghbo!BS
`
`6.
`
`te
`
`8.
`2,
`10,
`
`A foreclosure of its condominium commonchargelien pursuant to C.G.S. Section
`47-258.
`A Judgmentof Strict Foreclosure.
`Immediate possession of the premises.
`Money Damages.
`A Deficiency Judgment against the Defendants, Philip Panarella a/k/a Phil J.
`Panarella and Steven Panarella.
`The appointment of a Receiver to collect the rents and profits accruing from the
`said premises.
`Interest.
`
`Cost.
`Attorney’s Fees; and
`Such otherand furtherrelief as the Court deem just and equitable.
`
`Notice is hereby given to the defendants, Philip Panarella a/k/a Phil J. Panarella and
`Steven Panarella, that the Plaintiff intends to seek satisfaction of any judgment rendered
`in its favor in this action out of any debt accruing to the defendants, Philip Panarella a/k/a
`Phil J. Panarella and Steven Panarella, by reason of said Defendant’s personal services.
`
`THE PLAINTIFF,
`
`BY:_Wh
`G. Pilicy, Esq.
`Franklin
`Pilicy & Ryan, P.C.
`Its Attorneys
`235 Main Street
`Watertown, CT 06795
`860-274-0018 (p)
`860-274-0061 (f)
`Juris No.: 414927
`
`Pilicy & Ryan, P.C.
`235 Main Street Watertown, CT 06795
`Firm Juris: 414927
`
`

`

`EXHIBIT A
`
`A certain real property described as Unit No. E-30 of Mountain Ridge Condominium, whichis
`located in the Town of New Britain, County of Hartford and State of Connecticut. Said Unit
`exists pursuant to a Declaration of Condominium by Mountain Ridge Development N.B. Limited
`Partnership (“Declaration”) filed in the Land Records of said Town of New Britain on August
`18, 1988 in Volume 954 at Page 28.
`
`Pilicy & Ryan, P.C.
`235 Main Street Watertown, CT 06795
`Firm Juris: 414927
`860-274-0018
`
`

`

`RETURN DATE: SEPTEMBER 10, 2024
`
`> SUPERIOR COURT
`
`MOUNTAIN RIDGE CONDOMINIUM ASSOCIATION,
`INC,
`
`:
`
`JD OF NEW BRITAIN
`
`PHILIP PANARELLAa/k/a PHIL J, PANARELLA,
`ET AL
`
`: August 12, 2024
`
`: ATNEW BRITAIN
`
`WE ARE REQUIRED BY LAW TO INDICATE TO YOU
`THAT UNLESS YOU DISPUTE THE VALIDITY OF THE
`ABOVE DEBT OR ANY PORTION THEREOF, WITHIN
`THIRTY DAYS AFTER YOU RECEIVE SERVICE OF THIS
`COMPLAINT, THE ABOVE DEBT WILL BE PRESUMED
`VALID AND ACCURATE. IF WITHIN THE THIRTY DAY
`PERIOD YOU NOTIFY THE UNDERSIGNED IN WRITING
`THAT THE DEBT OR ANY PORTION OF IT JIS DISPUTED,
`THE UNDERSIGNED WILL OBTAIN WRITTEN
`VERIFICATION OF THE DEBT AND MAIL THE SAME TO
`YOU. FURTHER, IF YOU MAKE A WRITTEN REQUEST
`WITHIN THE THIRTY DAY PERIOD, THE UNDERSIGNED
`WILL PROVIDE YOU WITH THE NAME AND ADDRESS FOR
`THE ORIGINAL CREDITOR IF DIFFERENT THAN THE
`CURRENT CREDITOR.
`
`WE ARE ATTEMPTING TO COLLECT THIS DEBT AND
`ANY INFORMATION OBTAINED WILL BE USED FOR THAT
`PURPOSE.
`
`Pilicy & Ryan, P.C.
`235 Main Street Watertown, CT 06795
`Firm Juris: 414927
`860-274-0018
`
`

`

`RETURN DATE: SEPTEMBER10, 2024
`
`: SUPERIOR COURT
`
`MOUNTAIN RIDGE CONDOMINIUM ASSOCIATION,
`INC.
`
`:
`
`JD OF NEW BRITAIN
`
`PHILIP PANARELLAa/k/a PHIL J. PANARELLA,
`ET AL
`
`: August 12, 2024
`
`: AT NEW BRITAIN
`
`STATEMENT OF AMOUNT IN DEMAND
`
`The Plaintiff, MOUNTAIN RIDGE CONDOMINIUM ASSOCIATION,INC. claims
`
`damages sought in the foregoing action are greater than TWO THOUSAND FIVE HUNDRED
`
`DOLLARSand 00/100 ($2,500.00), exclusive of interest and costs.
`
`THE PLAINTIFF,
`
`BY:
`Franklin G. Pilicy, Esq.
`Pilicy & Ryan, P.C.
`Its Attorneys
`235 Main Street
`Watertown, CT 06795
`860-274-0018 (p)
`860-274-0061 (f)
`Juris No.: 414927
`
`Pilicy & Ryan, P.C.
`235 Main Street Watertown, CT 06795
`Firm Juris: 414927
`
`

`

`RETURN DATE: SEPTEMBER10, 2024
`
`SUPERIOR COURT
`
`MOUNTAIN RIDGE CONDOMINIUM ASSOCIATION,
`INC.
`
`:
`
`JD OF NEW BRITAIN
`
`AT NEW BRITAIN
`
`PHILIP PANARELLAa/k/a PHIL J. PANARELLA,
`ET AL
`
`August 12, 2024
`
`“NOTICE: A PERSON WHO IS UNEMPLOYED OR UNDEREMPLOYED AND WHO HAS
`(FOR AT LEAST TWO YEARS PRIOR TO THE COMMENCEMENTOF THIS
`FORECLOSURE ACTION) OWNED AND OCCUPIED THE PROPERTY BEING
`FORECLOSED AS HIS/HER PRINCIPAL RESIDENCE, MAY BE ENTITLED TO CERTAIN
`RELIEF PROVISIONS UNDER CONNECTICUT GEN.STAT. 49-31D ET. SEQ. YOU
`SHOULD CONSULT AN ATTORNEY TO DETERMINE YOUR RIGHTS UNDER THIS
`ACI.
`
`THE PLAINTIFF,
`
`
`
`BY: (Franklin
`
`G. Pilicy, Esq.
`Pilicy & Ryan, P.C.
`Its Attorneys
`235 Main Street
`Watertown, CT 06795
`860-274-0018 (p)
`860-274-0061 (f)
`Juris No.: 414927
`
`Pilicy & Ryan, P.C.
`235 Main Street Watertown, CT 06795
`Firm Juris: 414927
`
`

`

`RETURN DATE: SEPTEMBER10, 2024
`
`: SUPERIOR COURT
`
`MOUNTAIN RIDGE CONDOMINIUM ASSOCIATION,
`INC,
`
`:
`
`JD OF NEW BRITAIN
`
`: AT NEW BRITAIN
`
`PHILIP PANARELLAa/k/a PHIL J. PANARELLA,
`ET AL
`
`: August 12, 2024
`
`LIS PENDENS
`
`Notice is hereby given ofthe pendencyofa civil action made returnableto the Superior
`Court for the Judicial District ofNew Britain at New Britain on Tuesday, September10, 2024
`brought to foreclose on property due to unpaid common charges by the Defendants, Philip
`Panarella. The premises affected by said action are described as follows:
`
`A certain real property described as Unit No. E-30 of Mountain Ridge Condominium,
`whichis located in the Town ofNew Britain, County of Hartford and State of Connecticut. Said
`Unit exists pursuant to a Declaration of Condominium by Mountain Ridge Development N.B.
`Limited Partnership (“Declaration”) filed in the Land Records of said Town ofNew Britain on
`August 18, 1988 in Volume 954 at Page 28.
`
`BEINGthe same premises conveyed to Philip Panarella & Steven Panarella by Warranty Deed
`Mountain Ridge DevelopmentN. B. Limited Partnership dated October 21, 1988 and recorded
`October 21, 1988 in Volume 971 at Page 152 of the New Britain Land Records.
`
`Dated Watertown, Connecticut on August 12, 2024,
`
`Franklin G.Pilicy, Esq.
`Pilicy & Ryan, P.C.
`Its Attorneys
`235 Main Street
`Watertown, CT 06795
`860-274-0018 (p)
`860-274-0061 (f)
`Juris No.: 414927
`
`Pilicy & Ryan, P.C.
`235 Main Street Watertown, CT 06795
`Firm Juris: 414927
`
`

`

`"ATTORNEYSatLAW
`WATERTOWN,CONNECTICUT06795
`
`235 MAIN STREET
`PRO. BOX 760
`
`ATAA MN
`BK21 92 rad00
`
`ID: 007011800001 Type: LAN
`
`Doc
`
`RETURN DATE: SEPTEMBER16, 2024
`
`: SUPERIOR COURT
`
`MOUNTAIN RIDGE CONDOMINIUM ASSOCIATION,
`INC.
`
`:
`
`JD OF NEW BRITAIN
`
`: AT NEW BRITAIN
`
`PHILIP PANARELLAa/k/a PHIL J. PANARELLA,
`ET AL
`
`: August 12, 2024
`
`LIS PENDENS
`
`Notice is hereby given of the pendency ofa civil action made retumable to the Superior
`Court for the Judicial District of New Britain at New Britain on Tuesday, September 10, 2024
`brought to foreclose on property due to unpaid common charges by the Defendants, Philip
`Panarella, The premises affected by said action are described as follows:
`
`A certain real property described as Unit No. E-30 of Mountain Ridge Condominium,
`which is located in the Town of New Britain, County of Hartford and State of Connecticut. Said .
`Unit exists pursuant to a Declaration of Condominium by Mountain Ridge Development N.B.
`Limited Partnership (“Declaration”) filed in the Land Records of said Town of New Britain on
`August 18, 1988 in Volume 954 at Page 28.
`
`BEINGthe same premises conveyed to Philip Panarella & Steven Panareila by Warranty Deed
`Mountain Ridge Development N. B. Limited Partnership dated October 21, 1988 and recorded
`October 21, 1988 in Volume 971 at Page 152 of the New Britain Land Records.
`
`Dated Watertown, Connecticut on August 12, 2024.
`
`| herevy certify that the foregoingis
`A true copy of record in this office.
`
`,
`d Ie Wa hy
`
`Town & City Clerk - NEW BRITAIN
`
`AUG 19 2924
`Date
`are
`
`Byi
`ee
`Franklin G. Pilicy, Esq.
`Pilicy & Ryan, P.C. °
`Its Attorneys
`235
`Main Street
`anaes
`Watertown, CT 06795
`860-274-0018 (p)
`860-274-0061 (f)
`Juris No.: 414927
`
`Pilicy & Ryan, P.C.
`235 Main Street Watertown, CT 06795
`Firm Juris: 414927
`860-274-0018
`
`