NOTICE OF APBLICATION ifo'R“PREJUD'GM'EN‘T"' o ~ 7" STATE OF CONNECTICUT %Q,c,g% ;
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`-REMEDY/ CLAIM FOR HEARING TO CONTEST - A T : 7 JUDICIAL BRANCH. (552
`APPLICATION OR CLAIM EXEMPTION oL " SUPERIOR COURT .
`JD:CV-53 .Rev. 1124 "~ - » . C - L o C www,jud. ct. gov
`C.G.S. § 52-278¢ : e . A
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`7 _ » _ i For information on ADA
`Instructlons to plamtlfflappllcant . . accommodations, contact
`1. Complete section I in connection with all prejudgment remedles EXCEPT ex parte prejudgment remedies and the Centralized ADA Office at
`submit to the Clerk along with your application and other required documents. 860-706-5310 or go to:r
`2. Upon rece/pt of srgned order for hearing from clerk, serve thls form on defendant(s) with other requtred documents. www.jud.ct.gov/ADA/
`
`Section I — Case lnformatlon (To be completed by plamtrff/appllcanfl
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`Court address .. : o
`[x] fudiclal (— Housing | 235 CHURCH STREET, NEW.HAVEN, CT 06510 COURT USE ONLY
`Has a temporary restraining order been requested? Amount, legal interest, or property in demand, excluswe CLPJRA
`[]Yes [x]No of interest and costs is (Select one of the foIlowmg)
`Name of case (First-named plaintiff v. First-named defendant) D Less than $2 500 “"mmm“l"“m NHI ’I,”I“"’
`PALLUOTTO, JONNA Et Al v = - =| []$2,500 THROUGH $14,999.99 e -
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`MONACK, ROBERT Et Al
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`[ | See attached formh JD-CV-67 for Continuafion of Parties
`Case type (From Judicial Branch code list) | Number counts
`Major: M Minor: 90
`Name and address of plaintiff/applicant (Person mak/ng application for prejudgment remedy) (Number, street, town and zip code)
`
`JONNA PALLUOTTO, 140 THOMPSON STREET, UNIT 8B, EAST HAVEN, CT 06512
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`Name(s), address(es) and telephone number(s} of defendant(s) against whom prejudgment remedy is sought (Number, street, town and zip code) (Attach additional sheets if necessary)
`Robert Monack, 216 Laurel Street. Apartment 214, East Haven, CT 06512
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`Name and address of any third person holding property of defendant who is to be made a gamlshee by process preventing dlssmatlon of such property
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`Lulaj, LLC, 10 ngh Street, Wallingford, CT 06492
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`Name and address of attoney, law firm or plaintiff if pro se {Number streel, town and zip code)
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`. o PATRICIA A. COFRANCESCO, ESQ. 89 KIMBERLY AVE., EAST HAVEN, CT 06512
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`For the plaintiff(s) E-mail address .Telephone number Juris number (if attomney or law firm)
`enter the pattycofffi‘glcescoc paclawoffices.com 2034676003 ) ) 300918
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`Section Il — Notice to defendah_t
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`- [x] $15,000 or more
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`(Select if applicable)
`[:] Claiming other relief in addition to or in lieu of money damages
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`You have rights specified in the Connecticut General Statutes, including Chapter 903a, that you may wish to exercise concerning this
`application for a prejudgment remedy. These rights include the nght to a hearing:
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`(1) to object to the proposed prejudgment remedy because you have a defense to or set-off
`against the action or a counterclaim against the plaintiff or because the amount sought in the
`application for the prejudgment remedy is unreasonably high or because payment of any
`judgment that may be rendered against you is covered by any insurance that may be available
`to you;
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`(2) to request that the plaintiff post a bond in accordance with section 52-278d of the General
`Statutes to secure you against any damages that may result from the prejudgment remedy;
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`(3) to request that you be allowed to substitute a bond for the prejudgment remedy sought; and
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`(4) to show that the property sought to be subjected to the prejudgment remedy is exempt from
`such a prejudgment remedy.
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`FOR COURT USE ONLY
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`You may request a hearing to contest the application for a prejudgment remedy, assert any
`exemption or make a request concerning the posting or substitution of a bond in connection with
`the prejudgment remedy. The hearing may be requested by any proper motion or by
`completing section Hl below and returning this form to the superior court at the Court
`Address listed above.
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`You have a right to appear and be heard at the hearing on the application to be held at the above
`court location on:
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`Date Time
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`Courtroom Docket number
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`PJR CV
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`' Page 10f 2 /}
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`N Instrucl; ns to defendant
`R B Complete sectlon IIIandsubmlt to the Clerk B N : WIENIS T e i
`B ,_‘2 I, you have not already fil Ied an Appearance {fonn JD CL 12) f /e an AppearaHCe along with thls form ER
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`Sectlon III — Defendant‘s clalm and request for hearmg (To be completed by defendant)
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`- COURT USE ONLY
`
`"1,.the defendant named below, request a hearing to contest the application for prejudgment remedy, .
`claim an exemption or request the posting or substitution of a bond. 1 claim: (Select the appropriate boxes) _ CLPJRHG®
`[j that’ the amount sought in the appllcatlon for prejudgment remedy is unreasonably high. o ||||]mmm’|mm|’|“|flw"Hm ’
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`|:] that any judgment that may be rendered is adequately secured by insurance.
`] a defense, counterclalm set-off, or exemption. ‘
`[] that I be allowed to substltute a bond for the prejudgment remedy.
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`[] that the plaintiff be required to post a bond to secure me against any damages that may result from the prejudgment remedy.
`
`Signed (Defendant) ’ ) E-mail address of defendant s Date signed
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`“Certification
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`| certify t a co y of thls document was or will |mmed|ately be mailed or delivered electronlcally or non- electronlcally on
`(date) ( ZS to all attorneys and self-represented parties of record and that written consent for electronic delivery was
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`received from all attorneys and self-represented parties of record who received or will immediately be receiving electronlc delivery.
`Name and address of each party and attorney that copy was or will be mailed or delivered to*
`
`" Litchfield Cavo, 82 Hopmeadow Street, Suite 210 Simsbury, CT 06089 .
`
`Robert_ Monack, 216-_Laure_l Street. Apartment 214, East Haven, CT 06512
`Melissa Monack ,140 Thomason Street, Unit 8A, East Haven, CT 06512
`- Lulaj, LLC, 10 High Street, Wallingford, CT 06492
`
`*If necessary[ atfach a/jfinflfijnal sheet or sheets with name and address which the copy was or will be mailed or delivered to.
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`Slgned (Signgtird of Print or ame of pgfson signing .- | Date signed .
`W\K}fl fiLARU\A DM OB 5 b qjm)u
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`Page 2 of 2
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`¥
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`v wy
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`" NNH-CV25-6152590-S
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`To the Superior Court for the Judicial District of New Haven at New Haven:
`
`1.
`
`Judicial District of New Haven
`SUPERIOR COURT
`
`FILED
`
`SEP 23 2025
`
`CHIEF CLERK’S OFFICE
`
`APPLICATION FOR PREJUDGMENT REMEDY
`
`The undersigned represents:
`
`SUPERIOR COURT
`
`JONNA PALLUOTTO, ET AL J.D. OF NEW HAVEN
`V. AT NEW HAVEN
`ROBERT MONACK, ET AL SEPTEMBER 9, 2025
`
`The plaintiffs, Jonna Palluotto -and Michael Giamettei (-)f. 140 Thompson Street, Umt 8B,
`
`East Haven, CT 06512, recently commenced the above-entitled matter inter-alia, against .
`
`the defendant, Lulaj, LLC, of 10 High Street, Wallingford, CT 06492, pursuant to a
`
`Motion to Cite in Party Defendant (DE#121.00) and First Amended Complaint. .Count
`
`Four of that First Amended Complaint, sounds in “Fraudulent Conveyance,” and it
`
`alleges that the defendant, Robert Monack conveyed the property that is the subject of
`
`this lawsuit to the defendant, Lulaj, LLC for less than adequate consideration in violation
`
`of the provisions of Conn. Gen. Stat. Sec. 52-552¢ “to hindér, delay or defraud the
`
`plaintiffs.”
`
`2. As grounds for the plaintiffs’ belief there is probable cause that a Judgment will be
`
`LAW OFFICES OF PATRICIA A. COFRANCESCO
`89 Kimberly Avenne - East Haven, Connectiout 06512
`Telephone (203) 467-6003 - Facsimile (203) 467-6004 - Juris No. 300918
`
`Stabe of Conn eatinut
`
`-
`
`Prap Dabe: 2025 -0
`
`Franessing Mumber
`25266280001 0001
`Dacket MRHCV25E"
`Raceipt# 0221237
`Tafal F180.00
`
`1
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`entered in their favor, all of the requisite elements for a fraudulent conveyance cause of
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`- action have been alleged, ie: less than adequate consideration when compared to other
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`comparable Units in the parties’ Condominium Association; the sale was not publicly
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`- advertised; did not represent an-arm’s length transaction given the parties’ prior - -
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`relationship; took place after the sfibj ect lawsuit was brought; and the net value of the
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`Condominium Unit represented a substantial asset to Robert Monack. .
`
`. Subsequently, and as recently as August 22, 2025, the defendant, Lulaj, LLC listed the
`
`- subject property for sale (See attached exhibit A). Said sale would dissipate a substantial
`
`asset of the defendant Lulaj, LLC that would be available to satisfy any Judgment
`
`rendered in favor of the plaintiffs Jonna Palluotto and Michael Giamettei
`
`. The Prejudgment remedy is for an attachment of real property known as 140 Thompson
`
`Street, Unit 8A, East Haven, CT 06513.
`
`. It is submitted that there is probable cause, that a Judgment will be rendered in this matter
`
`in favor of the plaintifl ’s inter-alia, agajnst Lulaj? LLC and to secure such J_udgment, the
`Applicants seck an order from this Court directing the following prejudgment remedies
`be issued:
`
`a.) To attach the subject real estate owned by the defendant, Lulaj, LLC, located
`
`at 140 Thompson Street, Unit 8 A, East Haven, CT 06512, part of Thompson
`
`LAW OFFICES OF PATRICIA A. COFRANCESCO
`89 Kimberly Avenye - East Haven, Connecticut 06512
`Teleyhone (203) 467-6003 - Facsimile (203) 467-6004 - Juris No. 300918
`
`
`
`
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`
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`Garden Condominiums, as describéd in the attached Schedul_e'A'to secure the
`sum on $75,000.00.
`
`b.) To attach the bank accounts and/or funds on deposit in the name of the
`defendant, Lulaj, LLC in afiy banksin the State of Connecticut, or eIsewhere, ~
`to secure the sum of $75,000.00.
`
`¢.). An Order requiring the defendant, Lulaj, LLC to deposit the.sum of
`$75,000.00 into Court.
`
`6. Moreover, said potential sale of the subject property furthers the fraud committed by thg
`defendants Monack and Lulaj, LLC. designed to deprive the plaintiffs of access to their
`
`assets to satisfy a Judgment rendered in their favor.
`
`THE PLAINTIFFS,
`JONNA PALLUOTTO
`‘ MIC GIAMETTEI
`
`By: Vp
`
`Patricia A. Cofrancesco, Esq.
`89 Kimberly Avenue
`
`East Haven, CT 06512
`Telephone: 203-467-6003
`Juris No.: 300918
`
`LAW OFFICES OF PATRICIA A. COFRANCESCO
`89 Kimherly Aveniie - East Haven, Connecticut 06512
`Telephone (203) 467-6003 - Facsimile (203) 467-6004 - Juris No. 300918
`
`
`
`
`
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`
`
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`NNH-CV25-6152590-S o : 'SUPERIOR COURT
`JONNA PALLUOTTO, ET AL : : J.D. OF NEW HAVEN
`
`V. , : AT NEW HAVEN
`
`ROBERT MONACK, ET AL SEPTEMBER 9, 2025
`
`SUMMONS
`TO A STATE MARSHAL OF THE COUNTY OF NEW HAVEN, GREETINGS:
`
`- By AUTHORITY OF THE STATE OF CONNEC_TICUT, You are hereby commanded to
`Summon the defendant, Lulaj, LLC, whose address is 10 High Street, Wallingford, CT 06492
`concerning the property known as 140 Thompson Street, Unit 8A, East Haven, CT 06512, more
`particularlydescribed in thé attached Exhibit B, and to serve atrue and aftested copy of the
`Application for Pre-Judgment Remedy, the Affidavit of Probable Cause, the Order of the Court
`on Application for Pre-Judgment Remedy, the Notice of Pre-Judgment Remedy/Claim for
`Hearing to Dissolve or Modify, and this Summons and the attached, Amended signed Complaint
`dated September 9, 2025 upon the Defendant, Lulaj, LLC, of 10 High Street, Wallingford, CT
`06492, c/o Agent for Se?rvice: Raymond Lemley, 4 Industrial Circle, Hamdgn, CT 06517 by
`
`leaving the same in the hands, of the said agent, Attorney Raymond Lemley.
`
`Dated at East Haven, Connecticut, this 9" day of September 20@ J{J(\ qfl
`(MNY]
`v
`
`Patricia A. Cofrancesco, Esq.
`89 Kimberly Avenue
`
`East Haven, CT 06512
`Phone: 203-467-6003
`
`Fax: 203-467-6004
`
`Juris No.: 300918
`
`LAW OFFICES OF PATRICIA A. COFRANCESCO
`89 Kimberly Avese - East Raven, Connectiout 06512
`Telephone (203) 467-6003 - Facsimile (203) 467-6004 - Juris No. 300918
`
`
`
`
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`
`
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`11133\)”[”“
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`1
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`NNH-CV25-6152590-S SUPERIOR COURT
`
`JONNA PALLUOTTO, ET AL J.D. OF NEW HAVEN
`V. AT NEW HAVEN
`ROBERT MONACK, ET AL SEPTEMBER 9, 2025
`
`AFFIDAVIT OF PROBABLE CAUSE
`
`The undersigned plaintiffs, being duly sworn, hereby depose and state the following:
`
`We are thoroughly familiar with the facts contained in the undersigned Amended
`Complaint and in the Application for Prejudgment Remedy in the above entitled matter,
`
`and the facts set forth in each are true to the best of our knowledge and belief.
`
`In our opinion, the foregoing facts are sufficient to show that there is probable cause that
`
`¢ rendered for the plaintiffs.
`
`Nfichael Giametti
`
`Subscribed and sworn to MM\ Goronrodor
`
`Before me on SW Qw25
`
`Notary Public
`
`NElLRICH LUCAS
`
`LAW OFFICES OF PATRICIA A. COFRANCESCO
`
`89 Klmberly Avenie - East Haven, Connectiont 06512
`
`' Jonna Palluotto
`
`Subscribed and sworn to
`Bef
`efore me on ) (
`Notary Public Cf' {O‘ ZS
`Denise Loe Greenteaf
`NOTARY PUBLIC
`
`State of Connecticut
`My Commlnlon Exphes 06/30/2030
`
`
`
`
`
`
`
`
`
`' ORDER
`The foregoing Motion, having been heard by the Court, is it hereby ORDERED:
`GRANTED / DENIED
`
`THE COURT
`
`By
`Judge
`
`LAW OFFICES OF PATRICIA A. COFRANCESCO
`89 Kimberly Avemie - East Haven, Connecticut 06512,
`Telephone (203) 467-6003 - Facsimile (203) 467-6004 - Juris No. 300918
`
`
`
`
`
`
`
`
`
`NNH-CV25-6152590-S - . SUPERIOR COURT
`
`JONNA PALLUOTTO, ET AL S J.D. OF NEW HAVEN
`V. o AT NEW HAVEN
`'ROBERT MONACK, ET AL s SEPTEMBER 9, 2025
`
`ORDER FOR HEARING AND NOTICE
`
`The above application having been presented to the Court, it is hereby ordered that a
`hearing thereon be help at the New Haven Superior Court, 235 Church Street, New Haven, CT
`06510 on at and that the plaintiffs give notice to the defendant, Lulaj,,
`
`~ LLC. of the pendency of the Application and of the time and place it will be heard by causing a
`true and attested copy of the Application, such Writ, Summons, Amended Complaint, Affidavit
`and Probable Cause of this Order to be served upon the defendant by some proper Officer on or
`
`before and that due return of such service be made to this Court.
`And it is further ordered that the defendant be and its are hereby restrained and enjoined
`
`from transferring, disposing of, injuring or concealing the property described in said Application
`
`until said Hearing and further Order of the Court.
`
`BY THE COURT
`
`Judge-Assistant Clerk
`
`LAW OFFICES OF PATRICIA A. COFRANCESCO
`89 Kimberly Avenne - East Haven, Connecticut 06512
`Telephone (203) 467-6003 - Facsimile (203) 467-6004 - Juris No. 300918
`
`
`
`
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`
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`
`
`NNH-CV25-6152590-S ' : SUPERIOR COURT
`JONNA PALLUOTTO, ET AL - : : J.D. OF NEW HAVEN
`V. o AT NEW HAVEN
`
`ROBERT MONACK, ET AL SEPTEMBER 9, 2025
`
`ORDER FOR PREJUDGMENT REMEDY
`
`Whereas, after due hearing at which the plaintiffs and defendant appeared and were fully
`heard, it is found that there is probable cause to sustain the validity of the plaintiffs’ claim and
`that the application should be granted. ' '
`
`Now therefore, it is hereby ordered that the plaintiff may attach to the value of
`
`$75,000.00 the following estate of the defendant, Lulaj, LLC located at 140 Thompson Street,
`Unit 8A, East Haven, CT 06512.
`
`BY THE COURT( J)
`
`Assistant Clerk
`
`LAW OFFICES OF PATRICIA A. COFRANCESCO
`89 Kimberly Avemie - East Haver, Connecticut 06512
`Telephone (203) 467-6003 - Facsimile (203) 467-6004 - Juris No. 300918
`
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`LAW OFFICES OF PATRICIA A. COFRANCESCO
`89 Kimberly Avemie - East Raven, Connecticut 06512
`Telephone (203) 467-6003 - Facsimile (203) 467-6004 - Juris No. 300918
`
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`»
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`€ Back ( East Haven,CT - X
`-Listed by Carrie Vass with Carbutti & Co., Realtors L :
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`Ry
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`$315,000 o
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`2 bed 1.5 bath 1,210 sgft
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`140 Thompson St Apt 8A, East Haven, CT 06513 View on map ©
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`Est.$2194/mo (Get p‘re-approved>
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`3o e
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`___Adda—com__m_ute A LA 2T
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`@ Tothomes IR &)
`Property type S
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`HOA fees
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`HOA
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`1Car - | ?
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`‘Garage
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`( ' Compareimy Home | ) ‘
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`Realtor.com checked: A few minutes ago
`
`17 days
`
`On Realtor.com
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`$260
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`_ Price per sqgft
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`1986
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`Year built
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`Listing last updated: Sep 6, 2025 at 10:10 AM (EDT)
`
`Source: SMARTMLS, MLS #24121057
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`‘(@) open houses
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`Contact agent for a private showing.
`
`(Scheduia ‘tour>
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`
`
`Welcome home to this desirable end-unit condo that combines
`comfort, convenience, and thoughtful updates. Offering 2 bedrooms
`plus... Show more
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`| &) Interior
`
`Bedrooms
`e Bedrooms:2
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`Primary Bedroom Level: Upper
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`Bedroom 1Level: Upper
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`Primary Bedroom Features: Hardwood Floor
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`Bedroom 1 Features: Hardwood Floor
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`Show more v
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`- Local Home Services
`
`Advertisement .
`
`| Monthly payment o L
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`¥ Veterans & military benefits
`Sponsored by ‘g‘ggfié 3{15
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`1 Property history -
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`+$155000 s $3816
`Since last sold in 2025 = 2025 taxes
`
`=+ 2 Sales I | 39 years old .
`e Since 1996 | | ?Builtin198_6 |
`
`Price history
`
`Today
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`Aug 22, 2025
`
`17 days on
`Realtor.com
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`Listed $315,000
`SMARTMLS +96.88%
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`$260/sqft
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`ST e ppligRecord (o TR
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`1996 o o o o o o L
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`Sold
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`Jul 1, 1996
`. Public Record
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`$75000 $62/sqft
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`-Showmore v - . . L o IR
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`Tax history
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`Total .
`
`o "~ Land Additions
`assessment , e
`
`. Year " Taxes -
`
`2025 $3816 $114100 - = - + $114100
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`2023 $3,560 $114,100 = - + $114,100
`
`2022 $3560 - $114100 - = -+ $114,00
`
`2021 $3,263 $95,260 = - + $95,260
`
`2020 $3,263 $95,260 = - + $95,260
`
`Show more v
`
`The price and tax history data displayed is obtained from public records and/or MLS feeds
`from the local jurisdiction. Contact your REALTOR® directly in order to obtain the most up-
`to-date information available.
`
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`
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`f g EnvirOnhéhtal risk o N o . v
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`et e 2 e e e i sy O T e
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`RealEstimatesM
`
`‘We're sorry. No estimates are currently available for this home. We
`recommend you work with a real estate professional to help you make
`informed financial decisions. ' :
`
`| Want to track your home's value?
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`| More about RealEstimates™ data
`
`Foxon market trends
`A neighborhood in New Haven, CT
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`
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`price/sqft median . -
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`_Sold price median . - Daysonmarket. | S
`B $315000 - 30 S e
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`Py
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`3
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`- . 1
`.. i
`R w
`i Y
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`1 . i P
`T L L L T
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`- u
`o s e
`$rom
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`e
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`e
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`n
`¥
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`PR,
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`Nearby home values
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`We're sorry, no nearby home values are currently available for this home.
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`LAW OFFICES OF PATRICIA A. COFRANCESCO
`89 Kimberly Avere - East Haven, Comnecticut 06512
`Telephone (203) 467-6003 - Facsimile (203) 467-6004 - Juris No. 300918
`
`10
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`NNH-CV25-6152590-S
`JONNA PALLUOTTO, ET AL
`V.
`
`ROBERT MONACK, ET AL
`
`- SUPERIOR COURT - -
`
`J.D. OF NEW HAVEN
`
`AT NEW HAVEN
`
`SEPTEMBER 9, 2025
`
`Property Description for 140 Thonipson Street, Unit 8B, Eést Haven, CT 06512
`
`LAW OFFICES OF PATRICIA A. COFRANCESCO
`89 Kimberly Avenne - East Raven, Connecticut 06512
`Telephone (203) 467-6003 - Facsimile (203) 467-6004 - Juris No. 300918
`
`11
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`SCHEDULE A
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`ALL THAT CERTAIN real property situated in the Town of East Haven, County of New
`Haven and State of Connecticut, being known and designated as BUILDING NO. 8
`UNIT A, THOMPSON GARDENS WEST, together with all appurtenances thereto,
`
`- being moreparticularly designated and described in a certain Declaration of
`Condominium by K & L Building Corp. dated November 15, 1985 and recorded in A
`Volume 360 at Page 758, as amended by Amendment dated April 21, 1986 and recorded
`in Volume 386 at Page 287, as further amended by Amendment dated August 1, 1986
`
`and recorded in Volume 371 at Page 949, as further amended by Amendment dated
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`March 18, 1987 and recorded in Volume 407 at Page 272, as further amended by
`Amendment dated May 20, 1987 and recorded in Volume 471 at Page 227, as further
`amended by Amendment dated March 10, 1988 and recorded in Volume 471 at Page
`227,as further amended by Amendment dated July-15, 1988 and recorded in Volume 477 -
`at Page 154, as further amended by Amendment dated October 31, 1988 and recorded in
`Volume 513 at Page 84, as further amended by Amendment dated December 27, 1988
`and recorded in Volume 520 at Page 289, as further amended by Amendment dated
`November 26, 2027 and recorded in Volume 1991 at Page 157, as further amended by
`Amendment dated September 11, 2013 and recorded in Volume 2342 at Page 253 of the
`East Haven Land Records, as amended from time to time. -
`
`LAW OFFICES OF PATRICIA A. COFRANCESCO
`89 Kimberly Avenme - East Raven, Connecticut 06512
`
`Telephone (203) 467-6003 - Facsimile (203) 467-6004 - Juris No. 300918 12
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