throbber
DOCKET NO. MMX-CV24-6039835S
`
`BOLDERDASH, LLC
`
`VS.
`
`CONNECTICUT COASTAL
` ACADEMY, INC., ET AL
`
`
`
`:
`
`:
`
`:
`
`:
`
`SUPERIOR COURT
`
`J.D. OF MIDDLESEX
`
`AT MIDDLETOWN
`
`JUNE 11, 2024
`
`COUNT ONE - BREACH OF CONTRACT
`
`REVISED COMPLAINT
`
`1.
`
`The Defendant, Connecticut Coastal Academy, Inc. is a for profit company that
`
`provides educational services.
`
`2.
`
`The Defendant, CT Coastal Academy, LLC is a limited liability company that has
`
`assumed and succeeded the business operations of Connecticut Coastal Academy, Inc.
`
`3.
`
`The Defendant, Pamela Potemri, is an owner and executive director of the
`
`Defendant, Connecticut Coastal Academy, Inc. and is an owner and member of the Defendant, CT
`
`Coastal Academy, LLC.
`
`4.
`
`On or about August 1, 2019, the Plaintiff, Bolderdash, LLC, as Lessor and the
`
`Defendant, Connecticut Coastal Academy, Inc., as lessee, entered into a written lease, a copy of
`
`which is attached and marked Exhibit A, for the use and occupancy of 10,873 square feet in the
`
`building located at 192 Westbrook Road, Essex, Connecticut.
`
`5.
`
`On or about March 31, 2020, the Plaintiff and the Defendant, Connecticut Coastal
`
`Academy, Inc., entered into a Power Purchase Agreement, which is attached and marked as
`
`GOULD, LARSON, BENNET, McDONNELL, QUILLIAM & TUKEY, P.C.
`30 PLAINS ROAD
`ESSEX, CONNECTICUT 06426
`(860) 767-9055/ FAX (860) 767-2742
`JURIS NO. 024198
`
`1
`
`

`

`Exhibit B, for the sale and purchase of energy produced by the solar array at 192 Westbrook Road,
`
`Essex, Connecticut, for use by the Defendant at the same address.
`
`6.
`
`The Defendant, Connecticut Coastal Academy, Inc. took possession of the
`
`premises pursuant to the lease and purchased energy pursuant to the Power Purchase Agreement.
`
`7.
`
`The Defendant, Connecticut Coastal Academy, Inc., has failed to make the
`
`payments due on the lease and the Power Purchase Agreement and now owes the Plaintiff
`
`$125,443.05.
`
`COUNT TWO - TORTIOUS INTERFERENCE WITH A CONTRACT AGAINST PAMELA
`POTEMRI:
`
`1 - 7. Paragraphs 1 - 7 of Count One are hereby incorporated into Paragraphs 1 - 7 of this
`
`Count Two.
`
`8.
`
`The Defendant, Connecticut Coastal Academy, Inc., would not have defaulted
`
`under its obligation to pay the amounts due under the lease and Power Purchase Agreement if the
`
`Defendant, Pamela Potemri, had not intentionally removed the Defendant, Connecticut Coastal
`
`Academy, Inc.’s business operations from the premises and transferred those operations to a new
`
`location under the auspices of a new legal entity, the Defendant, CT Coastal Academy, LLC.
`
`9.
`
`The Defendant, Pamela Potemri, intentionally and fraudulently interfered with the
`
`Plaintiff’s contractual relationship with the Defendant, Connecticut Coastal Academy, Inc. by
`
`setting up a new company to operate the same business and by transferring that business to a new
`
`location causing the Defendant, Connecticut Coastal Academy, Inc. to default on its obligations
`
`and fail to pay the amounts owed the Plaintiff.
`
`GOULD, LARSON, BENNET, McDONNELL, QUILLIAM & TUKEY, P.C.
`30 PLAINS ROAD
`ESSEX, CONNECTICUT 06426
`(860) 767-9055/ FAX (860) 767-2742
`JURIS NO. 024198
`
`2
`
`

`

`COUNT THREE - TORTIOUS INTERFERENCE WITH A CONTRACT AGAINST
`CONNECTICUT COASTAL ACADEMY, LLC:
`
`1 - 7. Paragraphs 1 - 7 of Count One are hereby incorporated into Paragraphs 1 - 7 of this
`
`Count Three.
`
`8 - 9. Paragraphs 8 - 9 of Count Two are hereby incorporated into Paragraphs 8 - 9 of this
`
`Count Three.
`
`10.
`
`The Defendant, Connecticut Coastal Academy, Inc., would not have defaulted
`
`under its obligation to pay the amounts due under the lease and Power Purchase Agreement if the
`
`Defendant, Connecticut Coastal Academy, LLC, acting by and at the direction of the Defendant,
`
`Pamela Potemri, had not intentionally removed the Defendant, Connecticut Coastal Academy,
`
`Inc.’s business operations from the premises and transferred those operations to itself.
`
`11.
`
`The Defendant, Connecticut Coastal Academy, LLC, acting by and at the direction
`
`of Pamela Potemri, intentionally and fraudulently interfered with the Plaintiff’s contractual
`
`relationship with the Defendant, Connecticut Coastal Academy, Inc. and caused the Defendant,
`
`Connecticut Coastal Academy, Inc., to default on its obligations and fail to pay the amounts owed
`
`the Plaintiff.
`
`GOULD, LARSON, BENNET, McDONNELL, QUILLIAM & TUKEY, P.C.
`30 PLAINS ROAD
`ESSEX, CONNECTICUT 06426
`(860) 767-9055/ FAX (860) 767-2742
`JURIS NO. 024198
`
`3
`
`

`

`WHEREFORE, the Plaintiff claims:
`
`1. Money damages;
`2.
`Attorney’s fees as provided by the lease;
`3.
`Such other and further relief as the Court deems just and proper.
`
`THE PLAINTIFF
`BOLDERDASH, LLC
`
`By: 302018
` Kenneth J. McDonnell, Esq.
` Gould, Larson, Bennet, McDonnell,
` Quilliam & Tukey, P.C.
` Juris #024198
` (860) 767-9055
` Fax (860) 767-2742
` mcdonnell@gould-larson.com
`
`
`
`CERTIFICATION
`
`This is to certify that the foregoing is a true copy of the document submitted to the Clerk
`
`of Court and to further certify that a copy of the foregoing was delivered electronically this 11th
`
`day of June, 2024, to all counsel and pro-se parties as follows:
`
`Michael S. Bonnano, Esq.
`Geraghty & Bonnano, LLC - service@geraghtybonnano.com
`
` 302018
`Kenneth J. McDonnell
`Commissioner of the Superior Court
`
`GOULD, LARSON, BENNET, McDONNELL, QUILLIAM & TUKEY, P.C.
`30 PLAINS ROAD
`ESSEX, CONNECTICUT 06426
`(860) 767-9055/ FAX (860) 767-2742
`JURIS NO. 024198
`
`4
`
`

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket