DOCKET NO. NHH-CV24-6021250-S
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`MARCELA OCAMPO
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`v.
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`SERAMONTE CT LLC, AND
`SERAMONTE ESTATES, LLC
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`SUPERIOR COURT
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`JUDICIAL DISTRICT
`OF NEW HAVEN
`AT NEW HAVEN
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`HOUSING SESSION
`APRIL 15, 2024
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`The plaintiff Marcela Ocampo, by and through counsel, hereby submits this Revised
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`REVISED COMPLAINT
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`Complaint per Practice Book §§ 10-35 et seq. against the defendants Seramonte CT LLC and
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`Seramonte Estates, LLC, and states as follows:
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`COUNT I: BREACH OF CONTRACT
`(as to Seramonte Estates, LLC)
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`1. The plaintiff Marcela Ocampo is a natural person residing in Hamden, CT.
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`2. The plaintiff is a “person” within the meaning of the Connecticut Unfair Trade Practices
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`Act, General Statutes § 42-110a et seq. (“CUTPA”), in that she is a “natural person” under
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`General Statutes § 42-110a(3).
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`3. Seramonte CT LLC is a limited liability company, engaged in the business of owning and
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`managing the Seramonte Estates apartment complex, which is the apartment complex consisting
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`of buildings at and around the vicinity of 609 Mix Avenue, Hamden, CT 06514, with its office
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`located at 1 Kaye Plaza, Hamden, CT 06514 (“Seramonte Estates”), with its principal place of
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`business located at 50 Chestnut Ridge Road, Suite 205, Montvale, NJ 07645.
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`4. Seramonte Estates, LLC is a limited liability company that was administratively
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`dissolved on August 1, 2023, which was engaged in the business of owning and managing
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`Seramonte Estates during a period of the misconduct detailed herein, with its principal place of
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`business located at 3 Forest Park Drive, Farmington, CT 06032. Seramonte Estates, LLC is also
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`a signatory to all leases signed by Ms. Ocampo for her tenancy at Seramonte Estates.
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`5. Ms. Ocampo is a naturalized citizen from Colombia who teaches Spanish at Quinnipiac
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`University and Sacred Heart University.
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`6. Ms. Ocampo initially moved to Seramonte Estates in 2019 and lived there until Spring
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`2022.
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`7. Ms. Ocampo’s relationship with Seramonte Estates, LLC began to deteriorate in
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`December 2020 when a severe weather event caused severe water damage in her unit, causing a
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`large hole to form in her ceiling. This damage also extended to other nearby units.
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`8. Ms. Ocampo repeatedly requested that Seramonte Estates, LLC repair the unit, but
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`management ignored her pleas. Pl. Ex. 1. For a month, Seramonte Estates, LLC (specifically
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`through Maria, the Seramonte Estates secretary; Nene, the Seramonte Estates building
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`superintendent; and a third Seramonte Estates employee who managed them) promised to fix Ms.
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`Ocampo’s ceiling, but this promise was never fulfilled. Ms. Ocampo brought in videos to
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`Seramonte Estates, LLC as evidence of damage to her unit which, given its size (a studio
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`apartment with one main room), meant that her unit was largely uninhabitable. The water seeped
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`into and ruined the books and student tests she needed for her job, threatening her source of
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`income and livelihood.
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`9. Ms. Ocampo feared that the amount of water entering her apartment would also create
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`life-endangering problems with the apartment’s electricity.
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`10. Frustrated by the leaking roof, Ms. Ocampo attempted to solve the problem herself by
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`hiring a repair person and buying her own supplies at Home Depot. However, Seramonte Estates,
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`LLC arranged to have the repair person’s car towed on one occasion and then cut the same repair
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`person’s car’s cables on another day.
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`11. Desperate to resolve the problem after nearly 20 days with a waterlogged and still-
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`leaking ceiling, Ms. Ocampo then sent letters to the Hamden Fire Department and the
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`Quinnipiack Valley Health Department, complaining about the dangerous conditions. Pl. Ex. 2.
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`Per General Statutes § 19a-240 et seq. (health department authority) and Hamden Code of
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`Ordinances § 8-5(B) (fire department authority), these are the agencies with jurisdiction to
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`address Ms. Ocampo’s claims.
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`12. The dangerous conditions in the apartment were not limited to the water damage and
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`leaking. Rather, the increased humidity in the apartment created the perfect conditions for the
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`growth of mold, which created a musty smell, damaged the paint in the apartment, damaged Ms.
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`Ocampo’s possessions, and exposed her to a serious health hazard.
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`13. Other conditions issues Ms. Ocampo experienced at Seramonte Estates during her
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`tenancy included persistent issues with door handles not locking, broken laundry machines,
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`broken laundry payment machines, unannounced cuts to water, and weekly false and
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`unscheduled fire alarms—all of which Seramonte Estates, LLC failed to adequately mitigate.
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`14. Following her report of unsafe housing conditions, Ms. Ocampo was also subjected to the
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`predatory towing practices of Seramonte Estates, LLC’s contracted towing company
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`MyHoopty.com LLC (“MyHoopty”). MyHoopty served as Seramonte Estates, LLC’s agent at all
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`relevant times.
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`15. Upon information and belief, Seramonte Estates, LLC broke the door handle of Ms.
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`Ocampo’s car while her car was in its correct location within the complex’s parking lot and had
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`MyHoopty capriciously tow Ms. Ocampo’s car more than an hour away from the apartment.
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`Seramonte Estates, LLC and MyHoopty tried to base this towing on a rule requiring Ms.
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`Ocampo to have her parking permits displayed directly below the rearview mirror instead of on
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`the front dashboard where Ms. Ocampo had placed it. Seramonte Estates, LLC also refused to
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`provide Ms. Ocampo a long-term parking permit when it provided those permits to other tenants,
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`instead requiring her to use temporary permits that had to be replaced every few days and
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`sometimes were completely unavailable. When Seramonte Estates, LLC refused to provide Ms.
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`Ocampo with a temporary permit, she was forced to park in neighboring lots where she feared
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`for both her own safety and her car’s safety.
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`16. Seramonte Estates, LLC’s gross misconduct caused Ms. Ocampo to experience extreme
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`anxiety, fear, and emotional distress. Ms. Ocampo was anxious about her unit’s horrible
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`conditions, stressed about how Seramonte Estates, LLC’s misconduct and its resulting harm
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`would risk her employment, and fearful of Seramonte Estates, LLC’s abusive and retaliatory
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`treatment of her. Ms. Ocampo also feared having to walk alone at night to the parking lots
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`outside of Seramonte Estates where she was sometimes forced to park, and she constantly
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`worried that her car would be robbed in the unsecured lots.
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`17. Ms. Ocampo’s distress resulted in harmful physical side effects, including significant loss
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`of sleep and disruptive bouts of mental and emotional anguish.
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`18. During the incidents in question, Ms. Ocampo and Seramonte Estates, LLC were parties
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`to a lease agreement.
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`19. The lease defined Ms. Ocampo as the “Resident” and Seramonte Estates, LLC as the
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`“Landlord.”
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`20. Upon information and belief, Section 9 of the lease provided as follows:
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`Resident(s) will not have to pay rent for any time that Resident(s) use and
`enjoyment of the Unit is materially affected because the Unit or the building is
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`damaged by fire or other casualty. If Resident(s) continues to occupy any portion
`of the Unit, Resident(s) rent shall be reduced by the decrease in the fair rental
`value of the Unit, which will be determined solely by Landlord. If said damage,
`was caused by Resident(s), or others mentioned above, Resident(s) will be
`responsible for payment of any and all losses, expenses and costs incurred by
`Landlord due to damage, as well as all rent due pursuant to this lease.
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`21. Ms. Ocampo’s unit suffered a casualty event when severe weather caused heavy water
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`damage, including a gaping hole in her ceiling and pouring water that destroyed her personal
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`property. The damage severely impaired her enjoyment of the unit and threatened her
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`professional standing due to destruction of the documents she needed for work.
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`22. However, Seramonte Estates, LLC provided no reduction in Ms. Ocampo’s rent to
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`account for the decrease in the fair value of her rent. Nor did Seramonte Estates, LLC permit Ms.
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`Ocampo to discontinue her rental payments.
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`23. Ms. Ocampo did not cause the damage to her unit. Rather, she expended her own time,
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`money, and other resources to attempt to fix the damage when Seramonte Estates, LLC refused
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`to do so.
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`24. Seramonte Estates, LLC breached its contract with Ms. Ocampo when it (1) failed to
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`repair Ms. Ocampo’s ceiling in a timely manner and (2) failed to reduce her rent while her
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`enjoyment of the unit was impaired.
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`COUNT II: BREACH OF THE IMPLIED COVENANT OF GOOD FAITH AND FAIR
`DEALING
`(as to Seramonte Estates, LLC)
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`1-24. Ms. Ocampo restates and incorporates all of her statements and allegations contained in
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`paragraphs 1 through 24 of Count I in their entirety, as if fully rewritten herein.
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`25. The covenant of good faith and fair dealing in common law presupposes that the parties
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`agree upon the terms and purposes of the contract, and that what is in dispute is the parties’
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`interpretation or application of a contract term. Capstone Building Corp. v. American Motorists
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`Ins. Co., 308 Conn. 760, 795 (2013) (citing Renaissance Mgmt. Co. v. Connecticut Housing Fin.
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`Auth., 281 Conn. 227, 240 (2007)).
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`26. The Supreme Court has defined bad faith as the “lack of good faith.” Generally, bad faith
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`implies actual or constructive fraud, actions designed to mislead or deceive others, or a neglect
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`or refusal to fulfill a duty that is part of the legal agreement.
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`27. The implied duty to engage in good faith and fair dealing arises when an agreement is
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`formalized within a contractual relationship. “‘[T]he existence of a contract between the parties
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`is a necessary antecedent to any claim of breach of the duty of good faith and fair dealing.’”
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`Macomber v. Travelers Prop. & Cas. Corp., 261 Conn. 620, 638 (2002) (quoting Hoskins v.
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`Titan Value Equities Group, Inc., 252 Conn. 789, 793 (2000)).
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`28. Ms. Ocampo and Seramonte Estates, LLC began contracting formally with one another in
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`2017 and continued to do so until she moved out in 2022 in the form of annual leases.
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`29. As a tenant at Seramonte Estates, Ms. Ocampo was entitled to receive repairs on her unit
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`“within a reasonable time.”
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`30. Seramonte Estates, LLC’s dereliction of its duty to provide repairs in a timely fashion, as
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`well as its continual obfuscations about its intentions to remedy Ms. Ocampo’s plight, was an
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`intentional breach of the covenant of good faith and fair dealing.
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`31. Seramonte Estates, LLC’s breach caused Ms. Ocampo damage by forcing her to pay
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`substantial out-of-pocket expenses to mitigate the water damage in the form of construction
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`materials, a contractor, and supplies to replace the damaged items and paperwork. The breach
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`caused numerous documents to be destroyed that were vital for Ms. Ocampo’s job as a Spanish
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`instructor, requiring her to spend significant time and money to mitigate the harm caused.
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`COUNT III: TRESPASS TO CHATTEL
`(as to Seramonte Estates, LLC)
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`1-24. Ms. Ocampo restates and incorporates all of her statements and allegations contained in
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`paragraphs 1 through 24 of Count I in their entirety, as if fully rewritten herein.
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`25. Seramonte Estates, LLC caused Ms. Ocampo’s car to be towed from its proper parking
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`space without just cause or authority to do so.
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`26. In doing so, Seramonte Estates, LLC intentionally dispossessed Ms. Ocampo of her car.
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`Because Seramonte Estates, LLC, through its agent MyHoopty, refused to return Ms. Ocampo’s
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`car when she tried to retrieve it on the day of the towing, Seramonte Estates, LLC intentionally
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`deprived Ms. Ocampo of the use of her car for a substantial period of time.
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`27. Ms. Ocampo incurred costs in recovering her car, including the substantial expense and
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`time required to travel twice more than an hour away from her apartment to where Seramonte
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`Estates, LLC, via MyHoopty, towed her car. Pl. Ex. 4.
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`28. Seramonte Estates, LLC’s intentional dispossession of Ms. Ocampo’s car without
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`authority constitutes a trespass to chattel for which Seramonte Estates, LLC is liable. See Simms
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`v. Chaisson, 277 Conn. 319, 331 (2006) (recognizing trespass to chattel as a valid cause of
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`action); Applied Adver., Inc. v. Jacobs, Superior Court, judicial district of Hartford at Hartford,
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`Docket No. CV-15-6059689-S, 2016 WL 6603587, *3 (Oct. 6, 2016, Elgo, J.) (“‘A trespass to a
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`chattel may be committed by intentionally (a) dispossessing another of the chattel, or (b) using or
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`intermeddling with a chattel in the possession of another.’ 1 Restatement (Second) of Torts,
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`§ 217, p. 417 (1965). ‘One who commits a trespass to a chattel is subject to liability to the
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`possessor of the chattel if . . . he dispossesses the other of the chattel, or . . . the possessor is
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`deprived of the use of the chattel for a substantial time . . . .’ Id., § 218, p. 420.”); see also
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`Gilmore v. Public Storage, Inc., Superior Court, judicial district of Fairfield at Bridgeport,
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`Docket No. FBT-CV04-0409678-S, 2009 WL 765400 (Feb. 25, 2009); Iovene v. Shree Ram
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`Corp., Superior Court, judicial district of New Haven at Meriden, Docket No. CV-00-0273630-S,
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`2001 WL 577182 (May 9, 2001).
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`COUNT IV: UNFAIR ACTS OR PRACTICES UNDER CUTPA –
`HOUSING CONDITIONS
`(as to Seramonte Estates, LLC and Seramonte CT LLC)
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`1-24. Ms. Ocampo restates and incorporates all of her statements and allegations contained in
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`paragraphs 1 through 24 of Count I in their entirety, as if fully rewritten herein.
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`25. For weeks on end, Ms. Ocampo’s unit had severe water damage due to the gaping hole
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`caused by the ceiling leak. Her job security was put at risk because the water also damaged her
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`students’ tests and other paperwork. Moreover, over time the water damage increased the
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`humidity in her apartment, leading to the growth of mold as well as damaging the apartment’s
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`paint and Ms. Ocampo’s possessions.
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`26. Ms. Ocampo informed Seramonte Estates, LLC of these conditions as early as December
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`5, 2020 and asked Seramonte Estates, LLC to remedy the conditions pursuant to Seramonte
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`Estates, LLC’s obligations under the lease.
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`27. Seramonte Estates, LLC deliberately ignored Ms. Ocampo’s request for weeks and only
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`acted when forced to do so because of Ms. Ocampo’s pleas to the Quinnipiack Valley Health
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`Department and the Hamden Fire Department. The Departments responded, in part, under the
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`authority of Hamden Housing Code § 152.05, which authorizes the Director of Health to “make
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`inspections to determine the condition of dwellings, dwelling units, rooming units, and premises
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`located within this town, in order that he may perform his duty of safeguarding the health and
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`safety of the occupants of dwellings and of the general public.”
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`28. Ms. Ocampo was forced to pay substantial out-of-pocket expenses to mitigate the water
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`damage by paying for her own construction materials, contractor, and supplies to replace the
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`damaged items and paperwork.
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`29. Seramonte Estates, LLC failed to perform its legal duty to maintain the unit under
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`General Statutes § 47a-7 (Landlord’s Responsibilities). By failing to address the mold and water
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`damage in Ms. Ocampo’s apartment, Seramonte breached the implied warranty of habitability,
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`i.e., the landlord’s responsibility to maintain safe and habitable premises. This breach materially
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`affected the health and safety of Ms. Ocampo.
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`30. Seramonte Estates, LLC became noticeably more hostile to Ms. Ocampo following the
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`report of water damage to the local authorities. Seramonte Estates, LLC continued to be
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`unresponsive to additional conditions problems in Ms. Ocampo’s unit.
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`31. Seramonte Estates, LLC’s failure to fulfill its legal duties and responsibilities to ensure
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`their tenant’s abode was fit and habitable throughout each defendant’s leasehold while continuing
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`to collect rent payments, as detailed above, is demonstrably unfair under CUTPA. Seramonte
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`Estates, LLC’s conduct offends public policy as established by statute.
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`32. Ms. Ocampo’s ascertainable loss of money and property due to Seramonte Estates, LLC’s
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`failure to fulfill its responsibilities as a landlord violates CUTPA, which prohibits “unfair acts or
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`practices in the conduct of any trade or commerce,” including the leasing of real property.
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`General Statutes § 42-110b(a).
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`33. Seramonte Estates, LLC’s systematic abuse and neglect constituted a continuous course
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`of wrongful conduct that continued up until Ms. Ocampo was finally able to leave Seramonte
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`Estates in Spring 2022. Seramonte Estates, LLC’s wrongful conduct thus falls well within
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`CUTPA’s three-year statute of limitations. General Statutes § 42-110g(f).
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`34. Seramonte Estates, LLC is liable for violating CUTPA as the owner of Seramonte Estates
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`during a period in which Ms. Ocampo suffered from the aforementioned poor housing
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`conditions. Seramonte Estates, LLC is also liable as the signatory for all leases signed by Ms.
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`Ocampo for the duration of her tenancy at Seramonte Estates.
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`35. Seramonte CT LLC is liable for violating CUTPA as the owner of Seramonte Estates
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`during a period in which Ms. Ocampo suffered from the aforementioned poor housing
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`conditions. Seramonte CT LLC is also liable as the successor in interest of Seramonte Estates
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`after Seramonte Estates, LLC sold the property to Seramonte CT LLC.
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`36. Further, Ms. Ocampo suffered additional substantial injury through the aforementioned
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`economic and emotional damages.
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`37. Accordingly, Ms. Ocampo is entitled to actual damages under General Statutes § 42-
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`110g(a).
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`COUNT V: UNFAIR ACTS OR PRACTICES UNDER CUTPA –
`TOWING
`(as to Seramonte Estates, LLC)
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`1-24. Ms. Ocampo restates and incorporates all of her statements and allegations contained in
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`paragraphs 1 through 24 of Count I in their entirety, as if fully rewritten herein.
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`25. Seramonte Estates, LLC had MyHoopty enforce the unjustifiably punitive rule about
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`permit placement against Ms. Ocampo the day before the rule was supposed to take effect.
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`Seramonte Estates, LLC’s actions constitute retaliation that is illegal under CUTPA. Moreover,
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`MyHoopty refused Ms. Ocampo’s initial attempts to retrieve her car on the day of the towing,
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`which meant she had to make two roundtrips and incur additional fees for having her car held
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`overnight. Pl. Ex. 4.
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`26. Throughout Ms. Ocampo’s tenancy at Seramonte Estates, she and other tenants were
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`subject to predatory towing practices that were costly and unpredictable.
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`27. For example, Seramonte Estates, LLC changed its parking permitting practices in July
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`2021, with little notice to tenants. Seramonte Estates, LLC directed the towing company
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`MyHoopty to enforce its new rules, which included a requirement to back into parking spots and
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`a new permitting scheme with strict requirements about permit placement.
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`28. Seramonte Estates, LLC posted a threatening message about its aggressive enforcement
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`plan: “IF YOU BECOME AGRESSIVE [sic] WITH MANAGEMENT . . . IT MAY BE
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`GROUNDS FOR MANAGEMENT TO DENY YOU A PARKING PERMIT, TO REVOKE
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`YOUR PERMIT, & OR FINE YOU. IT IS ALSO A VIOLATION OF YOUR LEASE.” Pl. Ex. 3.
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`29. Due to Seramonte Estates, LLC’s punitive and retaliatory parking enforcement, Ms.
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`Ocampo incurred substantial injury. For example, she was forced to pay hundreds of dollars in
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`fees and transportation to recover her improperly towed car in July 2021. Pl. Ex. 4.
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`30. Seramonte Estates, LLC’s exploitative, unreasonable, and arbitrary towing practices
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`violated General Statutes § 14-145a because Ms. Ocampo’s vehicle was not trespassing when she
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`placed her parking permit on her dashboard and her car was in the correct location. Seramonte
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`Estates, LLC is therefore responsible for the costs of Ms. Ocampo’s towing and lost time.
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`General Statutes § 14-145c. Moreover, Seramonte Estates, LLC’s conduct offends public policy
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`as established by the statutes cited herein.
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`31. Ms. Ocampo’s ascertainable loss of money due to Seramonte Estates, LLC’s capricious
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`towing practices violate CUTPA. General Statutes § 42-110b(a). Seramonte Estates, LLC’s
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`towing practices also violate the statute because they unethically and oppressively make Ms.
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`Ocampo and other tenants constantly fear that their vehicle will be confiscated for arbitrary
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`reasons determined at Seramonte Estates, LLC’s whim. Due to Seramonte Estates, LLC’s towing
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`practices, Ms. Ocampo experienced fear, stress, and anxiety about the loss of her car and the
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`possibility that her job would be put at risk if she could no longer travel to her workplace.
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`32. Seramonte Estates, LLC is liable for violating CUTPA as the owner of Seramonte Estates
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`during a period in which Ms. Ocampo suffered from the aforementioned unlawful towing
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`practices. Seramonte Estates, LLC is also liable as the signatory for all leases signed by Ms.
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`Ocampo for the duration of her tenancy at Seramonte Estates.
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`33. Accordingly, Ms. Ocampo is entitled to actual damages under General Statutes § 42-
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`110g(a).
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`COUNT VI: UNFAIR ACTS OR PRACTICES UNDER CUTPA –
`ILLEGAL RENTAL FEES
`(as to Seramonte CT LLC)
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`1-24. Ms. Ocampo restates and incorporates all of her statements and allegations contained in
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`paragraphs 1 through 24 of Count I in their entirety, as if fully rewritten herein.
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`25. Ms. Ocampo was forced to pay $1,000 to end her lease at Seramonte Estates. Seramonte
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`CT LLC described this money as a debt, even though Ms. Ocampo habitually paid her rent on
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`time and in full.
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`26. Maria, the secretary at Seramonte Estates, threatened Ms. Ocampo that if she did not
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`comply with this demand to pay $1,000, she would find out who the employee really was
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`(“Ahora sí me vas a conocer”)—a clear threat to Ms. Ocampo. Maria blamed Ms. Ocampo for
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`brining unwanted attention to the complex that led to the firing of the Seramonte Estates
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`manager who had been overseeing her and Nene, her spouse. Ms. Ocampo feared reporting the
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`extortion to state authorities because her mother was going through the citizenship naturalization
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`process at the time and did not want to impede that process.
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`27. By demanding the payment of $1,000 from Ms. Ocampo without reason, Seramonte CT
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`LLC extorted her and unjustly enriched itself by taking funds that Ms. Ocampo desperately
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`needed to find new housing and escape Seramonte CT LLC’s abuse.
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`28. Ms. Ocampo’s ascertainable loss of money caused by Seramonte CT LLC’s demand for
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`an invalid debt violates CUTPA. General Statutes § 42-110b(a). Seramonte CT LLC’s conduct
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`offends public policy as established by statute. See General Statutes § 53a-119 et seq.
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`(criminalizing extortion).
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`29. Seramonte CT LLC is liable as the owner of Seramonte Estates at the time when the
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`illegal rental fee was imposed on Ms. Ocampo.
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`30. Accordingly, Ms. Ocampo is entitled to actual damages under General Statutes § 42-
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`110g(a).
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`COUNT VII: INTENTIONAL VIOLATIONS OF CUTPA
`(as to Seramonte Estates, LLC and Seramonte CT LLC)
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`1-30. Ms. Ocampo restates and incorporates all of her statements and allegations contained in
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`Counts IV-VI as if fully stated herein.
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`31. Seramonte Estates, LLC’s egregious and exploitative practices lasted for months on end.
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`This unfair conduct was without reasonable justification or excuse and persisted even after Ms.
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`Ocampo requested that Seramonte remedy her unit’s uninhabitable conditions and make its
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`towing practices less abusive and unreasonable.
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`32. Seramonte CT LLC’s demand for $1,000 in false debt prior to allowing Ms. Ocampo to
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`terminate her lease was egregious and exploitative, as Seramonte CT LLC was aware that Ms.
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`Ocampo had consistently paid her rent on time and in full. Seramonte CT LLC exploitatively
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`took advantage of Ms. Ocampo due to its knowledge that she urgently needed to find new
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`housing.
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`33. In refusing to remedy the situation, Seramonte Estates, LLC and Seramonte CT LLC both
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`demonstrated a willful indifference to Ms. Ocampo’s rights, and to the harm done to her
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`economic, physical, and emotional well-being due to both entities’ failure to fulfill their
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`respective duties.
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`34. Accordingly, Ms. Ocampo is entitled to actual and punitive damages under General
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`Statutes § 42-110g(a).
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`PRAYER FOR RELIEF
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`The plaintiff Marcela Ocampo respectfully requests that this Court enter an order granting
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`Judgment against the defendants for the following:
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`Against Seramonte Estates, LLC:
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`1. Actual damages under Counts I, II, III under the common law and under Counts IV, V,
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`and VII pursuant to General Statutes § 42-110g(a);
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`2. Punitive damages under Count III under the common law and under Count VII pursuant
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`to General Statutes § 42-110g(a); and
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`3. Reasonable attorney fees and costs under Counts I and II pursuant to General Statutes §
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`42-150bb, under Counts IV, V, and VII pursuant to General Statutes § 42-110g(d), and under
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`Counts V and VII pursuant to General Statutes § 14-145c.
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`Against Seramonte CT LLC:
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`14
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`1. Actual damages under Count VI pursuant to General Statutes § 42-110g(a);
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`2. Punitive damages under Count VII pursuant to General Statutes § 42-110g(a); and
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`3. Reasonable attorney fees and costs under Counts VI and VII pursuant to General Statutes
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`§ 42-110g(d).
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`Dated: April 15, 2024
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`Law Student Interns:
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`Vivekae Kim
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`Yale Law School ‘26
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`Kyle Ranieri
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`Yale Law School ‘24
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`Dylan Shapiro
`Yale Law School ’26
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`Respectfully Submitted,
`THE PLAINTIFF
`Marcela Ocampo
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`/422009/
`By:
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`Jeffrey Gentes
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`Anika Singh Lemar
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`Jerome N. Frank Legal Services Organization
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`Juris No. 443705
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`P.O. Box 209090
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`New Haven, CT 06520-9090
`jeffrey.gentes@ylsclinics.org
`anika.lemar@ylsclinics.org
`lso.juris@ylsclinics.org
`Phone: (203) 432-4806
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`15
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`DOCKET NO. NHH-CV24-6021250-S
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`MARCELA OCAMPO
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`v.
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`SERAMONTE CT LLC, AND
`SERAMONTE ESTATES, LLC
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`SUPERIOR COURT
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`JUDICIAL DISTRICT
`OF NEW HAVEN
`AT NEW HAVEN
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`HOUSING SESSION
`APRIL 15, 2024
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`STATEMENT OF AMOUNT IN DEMAND
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`
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`WHEREFORE, the plaintiff claims a cause of action seeking damages not less than
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`$15,000, exclusive of interest and costs, which cause is within the jurisdiction of the Superior
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`Court.
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`Dated: April 15, 2024
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`Law Student Interns:
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`
`
`Vivekae Kim
`
`Yale Law School ‘26
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`
`
`
`Kyle Ranieri
`
`
`Yale Law School ‘24
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`
`Dylan Shapiro
`Yale Law School ’26
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`Respectfully Submitted,
`THE PLAINTIFF
`Marcela Ocampo
`
`
`
`
`
`
`/422009/
`By:
`
`Jeffrey Gentes
`
`Anika Singh Lemar
`
`Jerome N. Frank Legal Services Organization
`
`Juris No. 443705
`
`P.O. Box 209090
`
`New Haven, CT 06520-9090
`jeffrey.gentes@ylsclinics.org
`anika.lemar@ylsclinics.org
`lso.juris@ylsclinics.org
`Phone: (203) 432-4806
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`16
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`EXHIBIT 1
`EXHIBIT 1
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`

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`bo\e'f"a) G3
`
`Monday, December 22, 2020
`
`. I am he~e to ann_~unce that the apartment G3 could be shorted because there is a leak next
`to a_ light bulb in the ceiling. The roof is flat and there must be a pool of rainwater. 1 am here to
`avoid a tragedy because water and electricity should not mix.
`
`It's Marcela Ocampo, I am writing this letter to denounce the unfortunate situation that 1
`have had to endure due to the negligence of the Seramonte Estates Administration and the
`abandonment of the Administration towards me and the problem of a leak that runs through the
`entire My room at 609 Mix Avenue, Apartment G3, Hamden, 06514.
`
`Last Friday, December 4 and Saturday, 5, there was a rainstorm that caused a long belly on
`the ceiling of the room, a belly that was made in the L-shaped lying position, which was filled with
`water and was so long that it spread with an approximate measurement of 86 inch-inches (2
`meters 20 centimeters) with another belly of water crossing it in an L shape, measuring
`approximately 39 inches -inches (1 meter). Additionally, there is another leak that falls from the
`same lying on the wall of the room. Leak that is damaging my personal belongings, my property's
`carpet that covers the floor, and my furniture where I keep my clothes and personal belongings.
`To date, the humidity on the floor due to the leaks that arose from the tummies when lying down,
`and the humidity on the wall and the mold on the ceiling have me worried because my health and
`the health of my mother are in danger.
`On Saturday, December 5, as soon as the leaks began to fall, I wrote a message written in
`Spanish at 1:30 pm to the telephone number (855) 9128824, which corresponds to the emergency
`telephone number through which the community received urgent messages from the
`Administration and of which it was announced to me that it is the one we can use in an
`emergency. This message I sent at 1:30 says: "Hello, good afternoon. I'm Marcela from 609,
`apartment G3. I'm writing to tell you that today a long leak appeared in the roof of the
`apartment. A hug, Thank you ".
`As the hours passed, the leak continued to grow and I decided to send a second message: a
`47-second video of the leaks on the roof. And I wrote the following message to the same phone
`number mentioned above: "Water leak 609 apt. G3 ".
`
`em,
`Because the number of leaks increased and since I had to put more vessels to hoard
`on the same Saturday, December 5 at 7:37 at night, I sent 2 photographs to the same cell phone
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`th
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`\
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`number to show the 3 vessels full of water with the following message: "Hello, good night! This is
`an emergency, please! Then I called to speak to Administration, but the phone was off at all times.
`
`I thought that, due to the rain, possibly the people of the Administration would be very busy
`and that for this reason they could not see my messages or answer my phone call. So, seeing that
`the problem was increasing with the leaks, I went to Maria, the Administrator's apartment around
`10:00 pm to announce the problem of the leak and hear from her a possible solution or what I
`should do. When I knocked on her door, her husband came out, nicknamed Nene, and I explained
`to him the problem of the leak in my house; I told him that I also wanted to speak with Maria and
`asked him to see my messages on the phone, but he told me that the leak was a problem that
`spread throughout the entire building where I live and that they were already aware of my
`messages. So, he told me that the next day, that is, Sunday, December 6, in the morning he would
`come to my house to see the condition of the leak. I took his word for it and on Sunday I was at
`home, waiting for him but he didn't come all day.
`
`I understand that we are going through a difficult time due to Covid 19, and the rainy and
`snowy weather, but this is no excuse to ignore my messages and my efforts so that the situation
`does not get worse. On Friday, December 18, I personally spoke with Nene and I explained my
`problem with the leaks again and asked him to help me find a solution. He answered me that the
`leak is a problem in the entire building where I live and that he was going to speak again with his
`wife Maria to find a solution for me, that he and Maria would call me that same day to give me
`instructions or a solution to the problem. . I never got your call.
`
`Yesterday, Sunday December 20, the water bellies that are in the lying exploded due to the
`thawing snow, dragging the paint, and debris from the roof. So I had to protect my mother who
`lives with me, remove some of our things from the room and asked for help so that a third person
`could come to help me. I went to Home Depot and it occurred to me to buy a corner piece, tape,
`rope, a meter and towels to dry the water to channel the leaks that wet my bed, my clothes, my
`drawers and my things that I have had in that room and remove the musty smell and mold that is
`damaging my personal things. I worked on this until 3:00 am in the morning. I must add that the
`leak is in the direction of the light bulb that is connected to three light bulbs that go to the living
`room; In conclusion, I cannot turn on the electricity in this part of the house to avoid a short
`circuit. Water and electricity do not mix. OMG!
`
`Today, Monday, Ja