DOCKET NO: UWY-CV23-6069106-S
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`: SUPERIOR COURT
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`RUPE, STEPHEN, ET AL
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`: JUDICIAL DISTRICT OF WATERBURY
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`V.
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`: AT WATERBURY
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`LAUDISI, JENNIFER, ET AL
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`: SEPTEMBER 5, 2024
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`DEFENDANTS’ MOTION FOR DISQUALIFICATION OF
`JUDICIAL AUTHORITIES AND TRANSFER
`Defendants Jennifer Laudisi and Jane Reed respectfully move
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`under Conn. Practice Book §§ 1-22; 1-23 and Conn. Gen. Stat. § 51-
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`183c to disqualify all judges who are or were assigned to the
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`Judicial District of Waterbury throughout the life of this case,
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`especially Judges John L. Cordani and Robert A. D’Andrea, from
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`presiding over any disputes arising from the now-terminated
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`landlord/tenant relationship between the parties to this case or
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`any litigation arising from such disputes (e.g., FDCPA), due in
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`part to an appearance of ex parte communications.
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`This case is only in Waterbury because Attorney Kolesnik
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`engaged in illegal forum shopping in violation of federal law, and
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`he has since benefitted from favorable rulings by a judge with
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`close personal ties to his family: Judge Cordani’s mother was a
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`librarian at the same private Catholic school where Attorney
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`Kolesnik’s father was on the school board and which his children
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`attended: Our Lady of Mt. Carmel.
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`Attorney Kolesnik has also benefited in this case from
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`avoidable delays by Judge Cordani and also Judge D’Andrea, who was
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`very recently assigned to the Litchfield Judicial District where
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`all other disputes arising from this same landlord/tenant
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`relationship are being litigated.
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`Defendants also move under Conn. Practice Book § 12-1 and
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`Conn. Gen. Stat § 51-347a for an order transferring this action,
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`including all pending motions, to a Housing Court Judge in Judicial
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`District of Torrington who is not disqualified by this motion. A
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`similar motion (Doc # 125.00) was previously denied by Judge
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`Cordani without explanation (Doc # 125.15).
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`APPLICABLE LAW
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`I. Rule 2.11 of the Code of Judicial Conduct Requires
`Disqualification Where There Is Actual Bias or Either an
`Appearance or Reasonable Question of Bias...................... 4
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`II. Rule 2.11 Does Not Draw Inferences in Favor of a Judge’s
`Honesty or Care as a Matter of Law............................. 5
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`III. Any Appearance, Reasonable Question, or Reasonable
`Perception of “Impropriety” Under Rule 1.2 Requires
`Disqualification as a Matter of Law............................ 6
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`A. Where the Judge Has a Relationship with Attorneys or
`Parties Before Them ................................... 7
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`B. Where the Judge or Court Staff Engage in Ex Parte
`Communications ........................................ 8
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`C. Where the Judge or Court Staff Act in a Manner that
`Coerces a Party into Settlement ....................... 9
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`D. Where the Judge Engages in Dilatory Practices or Causes
`Avoidable Delays, Resulting in Unnecessary Costs ...... 9
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`E. Where the Judge Declines to Enforce the Rules of
`Professional Conduct ................................. 10
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`APPLICATION OF FACTS
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`1. The Significant Family and Social Relationship Between Judge
`Cordani and Attorney Kolesnik................................. 11
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`2. Appearances of Impropriety are Unavoidable in Waterbury
`Because This Case is Only Here Due to Attorney Kolesnik’s
`Illegal Forum Shopping in Violation of State and Federal Law.. 13
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`3. Judge Cordani or Court Staff Gave Attorney Kolesnik Advance
`Notice of Judge Cordani’s Rulings Without Notifying Opposing
`Counsel....................................................... 16
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`4. It Appears Judge Cordani Issued Orders in Ex Parte
`Coordination with Counsel to Coerce Defendants into a Settlement
`Favoring Attorney Kolesnik.................................... 16
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`5. Waterbury Judges' Dilatory Practices and Avoidable Delay
`Favoring Attorney Kolesnik, Resulting in Unnecessary Costs to
`the Defendants................................................ 17
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`6. Current and Former Waterbury Judges Choose to Turn a Blind
`Eye to Ethics Violations by Attorney Kolesnik, Unnecessarily
`Increasing Defendants’ Costs.................................. 19
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`CONCLUSION.................................................... 20
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`CERTIFICATION................................................. 22
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`APPLICABLE LAW
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`Rule 2.11 (a) of the Code of Judicial Conduct provides that
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`a judge shall be disqualified from any proceeding “in which the
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`judge’s impartiality might reasonably be questioned,” including
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`where the “the judge has a personal bias or prejudice concerning
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`a party or a party’s lawyer.” The Code of Judicial Conduct defines
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`“impartial,” “impartiality,” and “impartially” to mean an “absence
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`of bias or prejudice in favor of, or against, particular parties
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`or classes of parties, as well as maintenance of an open mind in
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`considering issues that may come before a judge.”
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`I.
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`Rule 2.11 of the Code of Judicial Conduct
`Requires Disqualification Where There Is Actual
`Bias or Either an Appearance or Reasonable
`Question of Bias
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`Disqualification is required “even in the absence of actual
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`bias,” where a party shows either (a) a mere appearance of
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`partiality, or (b) a hypothetical person who does not know whether
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`the judge is impartial may reasonably question the court’s
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`impartiality. Ajadi v. Commissioner of Correction, 280 Conn. 514,
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`527-28, 911 A.2d 712 (2006); Sabatasso v. Hogan, 91 Conn. App.
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`808, 825, 882 A.2d 719, cert. denied, 276 Conn. 923, 888 A.2d
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`91(2005). As the Supreme Court has explained:
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`The question is not only whether the particular judge
`is, in fact, impartial but whether a reasonable person
`would question the judge’s impartiality on the basis of
`all the circumstances, because the appearance and the
`existence of impartiality are both essential elements of
`a fair exercise of judicial authority. Judicial
`decisions rendered under circumstances suggesting bias
`or favoritism tend to breed skepticism, undermine the
`integrity of the courts, and generally thwart the
`principles upon which our jurisprudential system is
`based. An appearance of bias may be just as damaging to
`public confidence in the administration of justice as
`the actual presence of bias.
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`Rosado v. Bridgeport Roman Catholic Diocesan Corp., 292
`Conn. 1, 20-21, 970 A.2d 656 (2009), cleaned up.
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`
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`II.
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`Rule 2.11 Does Not Draw Inferences in Favor of
`a Judge’s Honesty or Care as a Matter of Law
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`The law of disqualification rejects “drawing all inferences
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`favorable to the honesty and care of the judge” precisely because
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`Rule 2.11 applies equally to actual bias as it does the appearance
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`or reasonable question standards. Id. Doing otherwise because it
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`would make the two other, less stringent standards meaningless and
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`indistinguishable from the actual bias standard. Ibid.
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`III.
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`Any Appearance, Reasonable Question, or
`Reasonable Perception of “Impropriety” Under
`Rule 1.2 Requires Disqualification as a Matter
`of Law
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`Because Rules 1.2 and 2.11 of the Code of Judicial Conduct
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`are both intended to promote public confidence in the judiciary’s
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`administration of justice, conduct implicating Rule 1.2 is
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`necessarily relevant to any analysis of disqualification under
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`Rule 2.11. Code of Judicial Conduct, Rule 1.2, Comments (1), (3).
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`Rule 1.2 provides:
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`A judge shall act all times in a manner that promotes
`public confidence in the independence, integrity, and
`impartiality of the judiciary and shall avoid
`impropriety and the appearance of impropriety. The test
`for appearance of impropriety is whether the conduct
`would create in reasonable minds a perception that the
`judge violated this Code or engaged in other conduct
`that reflects adversely on the judge’s honesty,
`impartiality, temperament, or fitness to serve as a
`judge.
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`As they are used in the Code of Judicial Conduct, the word
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`“impropriety” includes conduct that undermines a judge’s
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`independence, integrity, or impartiality; “integrity” means the
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`probity, fairness, honesty, uprightness, and soundness of
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`character; and “independence” means a judge’s freedom from
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`influence or controls other than those established by law.
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`This is all relevant to disqualification under Rule 2.11
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`because a perception that the judge has engaged in “impropriety”
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`for one definition of that word under the Code (e.g., undermining
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`their independence) also creates an appearance, reasonable
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`question, or reasonable perception they also engaged in
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`“impropriety” under other definitions of that word, including
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`conduct that undermines the judge’s impartiality. This transitive
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`property is further evidenced by the Code’s definitions of
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`“independence” and “integrity” containing identical references to
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`the exact same Canons and Rules: Canons 1 and 4, and Rules 1.2,
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`3.1, 3.12, 3.13, and 4.2. Though the former should be updated to
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`also reference Rule 2.4.
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`A. Where the Judge Has a Relationship with Attorneys
`or Parties Before Them
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`Code of Judicial Conduct, Rule 2.4 (b) prohibits a judge from
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`permitting any “family, social, political, financial, or other
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`interests or relationships to influence the judge’s judicial
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`conduct or judgment.” The Comment to Rule 2.4 states “the integrity
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`of judicial decision making is undermined if it is based in whole
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`or in part on inappropriate outside influences.”
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`Presiding over a matter where it appears such family, social,
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`or other relationship is influencing the judge to suborn bias in
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`favor of a party or a party’s lawyer creates an appearance of
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`judicial impropriety and therefore requires disqualification as a
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`matter of law. Rules 1.2; 2.11 (a) (1), supra.
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`B. Where the Judge or Court Staff Engage in Ex Parte
`Communications
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`Code of Judicial Conduct, Rule 2.9 broadly prohibits a judge
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`from
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`initiating,
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`permitting,
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`or
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`even
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`considering
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`any
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`communications made to the judge outside the presence of the
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`parties or their lawyers concerning a pending or impending matter
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`unless “expressly authorized by law to do so.” Rule 2.9 (a) (5).
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`If a judge inadvertently receives such a communication bearing on
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`the substance of a pending matter, they must “make provision
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`promptly to notify the parties of the substance of the
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`communication and provide the parties with an opportunity to
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`respond.” Rule 2.9 (b).
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`Judges are responsible for making all reasonable efforts to
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`ensure Rule 2.9 is not violated by the judge or by court staff.
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`Rules 2.9 (d); 2.12.
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`The appearance that either the judge or court staff engaged
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`in such one-sided communication, especially without notifying the
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`other party, creates an appearance of judicial impropriety
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`requiring disqualification. Supra.
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`C. Where the Judge or Court Staff Act in a Manner that
`Coerces a Party into Settlement
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`Code of Judicial Conduct, Rule 2.6 (b) provides “A judge
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`shall… not act in a manner that coerces any party into settlement.”
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`The appearance that a judge has done so creates an appearance of
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`judicial impropriety requiring disqualification. Supra.
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`D. Where the Judge Engages in Dilatory Practices or
`Causes Avoidable Delays, Resulting in Unnecessary
`Costs
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`Code of Judicial Conduct, Rule 2.5 (a) provides “A judge shall
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`perform judicial and administrative duties competently and
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`diligently.” Comment (3) shows the rule is meant to encourage
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`“prompt disposition of the court’s business,” the expeditious
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`determination of matters under submission. Comment (4) provides:
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`In disposing of matters promptly and efficiently, a
`judge must demonstrate due regard for the rights of
`parties to be heard and to have issues resolved without
`unnecessary cost or delay. A judge should monitor and
`supervise cases in ways that reduce or eliminate
`dilatory practices, avoidable delays, and unnecessary
`costs.
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`As described below, Judge D’Andrea and Judge Cordani have both
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`engaged in dilatory practices in this case.
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`E. Where the Judge Declines to Enforce the Rules of
`Professional Conduct
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`Code of Judicial Conduct, Rule 2.15 (d) obligates any judge
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`“who receives information indicating a substantial likelihood that
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`a lawyer has committed a violation of the Rules of Professional
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`Conduct” to “take appropriate action.” The first comment to that
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`rule provides:
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`Taking appropriate action under the circumstance to
`address known misconduct is a judge’s obligation…
`Ignoring or denying known misconduct among one’s
`judicial colleagues or members of the legal profession
`undermines a judge’s responsibility to participate in
`efforts to ensure public respect for the justice system.
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`Therefore, a judge saying something to the effect of “if I enforce
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`one ethics rule, I have to enforce them all” as his reason to
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`decline taking up a sanctions motion based on the Rules of
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`Professional Conduct would create an appearance of judicial
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`impropriety requiring disqualification. Supra.
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`APPLICATION OF FACTS
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`
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`1. The Significant Family and Social Relationship
`Between Judge Cordani and Attorney Kolesnik
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`The online obituary for Judge Cordani’s mother (“Mrs.
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`Cordani”), Exhibit A,1 and the page on Our Lady of Mount Carmel
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`Church’s website dedicated to Attorney Kolesnik’s father, Exhibit
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`B,2 prove Judge Cordani’s mother was a librarian for many years at
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`the same private Catholic school where Attorney Kolesnik’s father
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`is a member of the school board and children attended as students.
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`At private Catholic schools such as Our Lady of Mount Carmel,
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`students, their parents, faculty, and board members tend to belong
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`to the same tight-knit and insular community due in part to (1)
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`the nature of private education being private, (2) the tendency of
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`nearly all the faculty, staff, and students’ parents being
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`registered parishioners of the associated Church, furthered by (3)
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`those schools’ tendency to offer tuition discounts in exchange for
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`parents’ agreement to register as parishioners and regularly
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`attend services at the associated Church. Afft of Attorney Paholke,
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`attached, ¶ 5.
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`1 Available online at https://www.chaseparkwaymemorial.com/obituary/susan-cordani
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`2 Available online at https://olmcwtby.com/page/robert-kolesnik
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`There is an undeniable appearance that the Cordanis and
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`Kolesniks are parishioners of the same Catholic Church in
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`Waterbury. It is unclear if Mrs. Cordani was the school librarian
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`at the same time that (a) Attorney Kolesnik’s father was on the
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`school board, or (b) any of Attorney Kolesnik’s children were
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`students there.
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`But if a reasonable mind even desires such information for
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`analysis of Rule 2.4 (b), or is tempted to proffer such
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`information, then disqualification is required because such desire
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`is the line of demarcation for the “appearance” or “reasonable
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`question” or “reasonable perception” standards discussed supra.
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`This relationship, when considered with the other issues
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`presented below, creates an appearance, reasonable question, or
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`reasonable perception that Judge Cordani shares significant
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`“family, social, political… or other interests or relationships”
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`with Opposing Counsel which are inappropriately influencing Judge
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`Cordani’s conduct in cases litigated by Attorneys named Robert S.
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`Kolesnik, Sr. or Jr. Disqualification is therefore required under
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`the Code of Judicial Conduct.
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`2. Appearances of Impropriety are Unavoidable in
`Waterbury Because This Case is Only Here Due to
`Attorney Kolesnik’s Illegal Forum Shopping in
`Violation of State and Federal Law
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`The record shows that Opposing Counsel has repeatedly tried
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`to bring the Plaintiffs’ case against these Defendants in the
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`Waterbury Court, despite the clear warning by Judge Spader, in
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`violation of a forum shopping (or perhaps venue shopping) statute,
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`and the venue selection laws of Connecticut.
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`Defendant’s previous motion to transfer this matter to the
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`judicial district of Litchfield in Torrington (Doc # 125.00), which
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`Judge Cordani denied without explanation (Doc # 125.15), explained
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`that all cases between the parties about their landlord/tenant
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`relationship had been entirely litigated in Torrington. That
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`motion even included a copy of a prior order from the Waterbury
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`Judicial District, wherein the Honorable Walter Michael Spader,
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`Jr. rightly thwarted Plaintiffs’ attempts at forum shopping by
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`transferring the case to Torrington sua sponte for nearly identical
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`reasons as one presented in the motion to transfer (Doc # 125.00):
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`The Litchfield Judicial District is the proper venue for
`this action under Section 51-345 (h) of the Connecticut
`General Statutes. That is the judicial district where
`the premises are located, and this case is a housing
`matter as defined by Section 47a-68 (6), (8), and (9).
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`The motion went on to argue that transfer is in the interests of
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`judicial economy because the same facts of this case are currently
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`being litigated in two other matters in Torrington, one of which
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`is Docket Number LLI-CV24-6037124-S, wherein Opposing Counsel is
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`a codefendant to the Plaintiffs here and is being sued for bringing
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`two cases (the instant matter and the prior case Judge Spader
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`transferred sua sponte to Torrington) in the wrong venue as per se
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`violations of the FDCPA’s prohibition against abusive forum
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`shopping. 15 U.S.C. § 1692i (a) (1) provides:
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`Any debt collector who brings any legal action on a debt
`against any consumer shall, in the case of an action to
`enforce an interest in real property securing the
`consumer’s obligation, bring such action only in a
`judicial district or similar legal entity in which such
`real property is located.
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`Attorneys qualify as “debt collectors” under the statute as a
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`matter of law. See, e.g., Gonzalez v. Law Office of Allen Robert
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`King, 195 F.Supp. 3. 118 (C.D. Cal. 2016). The FDCPA is applicable
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`in state courts under 15 U.S.C. § 1692k (d).
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`
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`Clearly, Attorney Kolesnik keeps bringing the Rupes’ cases in
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`this court because he sees Waterbury as a favorable place to
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`litigate. Perhaps it’s because of his close relationship with Judge
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`Cordani, or maybe he has friends among the court staff in this
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`Judicial District. Either way, Attorney Kolesnik brought this case
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`to Waterbury seeking unfair advantage, and he appears to have found
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`it.
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`At minimum, the discrepancy between Judge Spader’s prior sua
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`sponte order and Judge Cordani’s denial of Doc # 125.00 without
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`explanation creates a reasonable question or perception of such an
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`unfair advantage, especially in light of the personal relationship
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`between Attorney Kolesnik and the judge who authored Doc # 125.15
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`despite being presented Judge Spader’s sua sponte transfer order.
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`Transfer to the Litchfield Judicial District is further
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`warranted because the Plaintiffs’ claims in this case have the
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`potential to cause a chilling effect on the residents of Litchfield
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`to contact their health district authorities on matters of public
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`concern, avail themselves of governmental housing programs in
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`Litchfield, and on Litchfield tenants who seek enforcement or
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`protection of their rights in court. Memorandum of Law in Support
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`of Defendants’ Special Motion to Dismiss, doc # 123.00, pp. 8-20.
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`The proper venue for the adjudication of such issues is the
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`Judicial District of Litchfield.
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`The circumstances presented by this motion infra and supra
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`demonstrate an appearance, reasonable question, or reasonable
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`perception that that these issues will not be fairly adjudicated
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`in the Waterbury Judicial District, and that adjudication in
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`Litchfield by Judge D’Andrea (who now sits in the Litchfield
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`Judicial District) will not have an appearance of fairness as
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`required by the Code of Judicial Conduct.
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`3. Judge Cordani or Court Staff Gave Attorney
`Kolesnik Advance Notice of Judge Cordani’s
`Rulings Without Notifying Opposing Counsel
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`Paragraphs 8 through 29 of the attached affidavit present
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`circumstances creating an appearance, reasonable question, or
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`reasonable perception that Judge Cordani or court staff shared or
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`discussed Judge Cordani’s order Doc # 122.10 with Attorneys
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`Kolesnik and/or Plouffe without making any efforts to notify
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`Attorney Paholke as required by Rules 2.9 and 2.12.
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`Disqualification is therefore required under the Code of Judicial
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`Conduct.
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`4. It Appears Judge Cordani Issued Orders in Ex
`Parte Coordination with Counsel to Coerce
`Defendants into a Settlement Favoring Attorney
`Kolesnik
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`As presented in the attached affidavit, the timing of the
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`publication of the aforementioned Doc # 122.10 to the Superior
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`Court website in between two phone calls on July 25 where
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`settlement was being discussed between Attorneys Paholke and
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`Plouffe, combined with the ex parte communication and personal
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`relationship issues described above, create an appearance,
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`reasonable question, or reasonable perception that Judge Cordani
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`had crafted his order in Doc # 122.10 to coerce Defendants into a
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`settlement agreement favorable to Attorney Kolesnik by lending
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`post hoc credibility to a bluff made by Kolesnik’s Attorney,
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`described in paragraph 18 of the attached affidavit.
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`Disqualification is therefore required under the Code of Judicial
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`Conduct.
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`5. Waterbury Judges’ Dilatory Practices and
`Avoidable Delay Favoring Attorney Kolesnik,
`Resulting in Unnecessary Costs to the
`Defendants
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`A motion to dismiss this case was filed in November 2023
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`(Doc # 107.00) and rested on the papers. Judge D’Andrea told
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`counsel in a status conference that he would work quickly to
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`resolve the motion, even promising to spend the weekend on it.
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`When Attorney Kolesnik filed a surreply to that motion
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`(Doc # 117.00), Defendants filed an objection (Doc # 118.00) which
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`cited an opinion written by Judge D’Andrea explaining why
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`surreplies are disfavored and that arguments raised for the first
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`time in a surreply are “strictly prohibited” and considered
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`abandoned. Hunter v. Daimler Trucks North America, LLC, Docket
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`No.: UWY-CV18-6040217-S, 2024 Conn. Super. LEXIS 377, at **30, 39
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`(Super. Feb. 22, 2024).
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`Despite Defendants resting on the papers, Judge D’Andrea
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`delayed ruling on the November motion until after hearing, the
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`date of which was not scheduled until July, following several
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`months’-long delays3 in spite two caseflow requests: one in April
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`and second in May. See Doc # 107.10; 114.10; 119.00; 119.10;
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`120.00; 121.00.
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`But when the November 2023 motion was finally heard in July
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`2024, it was not heard by Judge D’Andrea, but instead by Judge
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`Cordani, who ruled in favor of Attorney Kolesnik (Doc # 107.30).
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`Judge Cordani wrote there “When considering a motion to dismiss,
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`the court considers… appropriate facts, affadavits, or testimony
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`considering jurisdictional facts.”
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`Defendants filed a new motion to dismiss one week after that
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`ruling which included a sworn affadavit and twenty-one (21)
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`exhibits proving that the jurisdictional facts provided in Judge
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`Cordani’s ruling were untrue as a matter of fact. (Doc # 122.20).
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`Judge Cordani denied that motion within 48 hours without even
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`waiting for an objection from the Plaintiffs in this matter. (Doc
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`# 122.10).
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`3 One of these delays was related to a stipulated order in January 2024 which
`Judge D’Andrea negotiated among the parties to accommodate for a death in the
`family of Defendants’ attorney. (Doc # 122.20). That attorney is grateful,
`but Rule 2.11 as a matter of law does not draw inferences in favor of a
`judge’s care, especially considering the specter of forum shopping hanging
`over this case and the other delays since that stipulated order. Supra;
`infra.
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`6. Current and Former Waterbury Judges Choose to
`Turn a Blind Eye to Ethics Violations by
`Attorney Kolesnik, Unnecessarily Increasing
`Defendants’ Costs
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`Judge Cordani’s apparently-rushed4 order denying the new
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`motion to dismiss (Doc # 122.10) alleged Defendants had no good
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`cause for filing the motion when they did, despite the motion
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`expressly stating it was filed to “challenge jurisdictional facts…
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`and clarify misapprehensions about the litigation history between
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`the parties resulting from oral argument in prior hearing(s).”
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`(Doc # 122.00).
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`Because Judge Cordani ruled in Attorney Kolesnik’s favor
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`without waiting for an objection or reply, Defendants were forced
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`to file an Appeal (Docket Number AC 47917) and a subsequent motion
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`(Doc # 128.00) more explicitly presenting Attorney Kolesnik’s
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`ethics violations, emphasis in original:
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`Throughout the litigation of this matter, and especially
`during the [oral argument for the first motion to
`dismiss, Attorney Kolesnik] made several false or
`misleading statements regarding the facts underlying
`their case; facts which that attorney personally
`witnessed. One such misleading suggestion is that the
`First Eviction was not resolved by a stipulation between
`the parties. Yet such a stipulation exists… [Attorney
`Kolesnik] led the court to believe during oral argument
`that [stipulation, attached there as] Exhibit M never
`existed, just like he tried with the newly-discovered
`TAHD records [he knowingly withheld in discovery].
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`4 See attached affidavit, ¶¶ 26-29.
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`19
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`Similarly, Judge D’Andrea repeatedly declined to take up a December
`
`2023 sanctions motion against Attorney Kolesnik (Doc # 122.00) for
`
`directly communicating with a represented opposing party after
`
`their attorney had specifically asked them not to in writing. See
`
`Docs # 122.00, 122.10, 122.15, 122.20, 122.25).
`
`Because Judge D’Andrea declined to take up the matter under
`
`his sanctions authority, Defendants were forced to bring suit for
`
`those same facts under the FDCPA in Docket Number LLI-CV24-6037124-
`
`S, which is in the Judicial District to which Judge D’Andrea is
`
`currently assigned.
`
`These circumstances demonstrate an appearance, reasonable
`
`question, or reasonable perception that Judges Cordani, D’Andrea,
`
`or any other current or former Waterbury judge will (1) take
`
`appropriate action when receiving information indicating a
`
`substantial likelihood that a lawyer has committed a violation of
`
`the Rules of Professional Conduct or (2) refrain from dilatory
`
`practices or avoid unnecessary delays which will impose
`
`unnecessary costs to the parties.
`
`CONCLUSION
`
`For the foregoing reasons, Defendants move for Judges John L.
`
`Cordani, Robert A D’Andrea, and any other Judges who have been or
`
`are assigned to the Judicial District of Waterbury throughout the
`
`20
`
`

`

`life of this case be disqualified from presiding over any disputes
`
`arising from the now-terminated landlord/tenant relationship
`
`between the parties to this case and any disputes arising from the
`
`litigation of such relationship. Defendants also move to transfer
`
`this matter to a Housing Court Judge within the Judicial District
`
`of Litchfield who is not disqualified by this motion.
`
`
`
`21
`
`

`

`CERTIFICATION
`
`I certify that a copy of this document was delivered
`electronically on September 5, 2024, to the following attorneys of
`record:
`
`Parties and/or attorneys served:
`
`Robert S. Kolesnik, Jr.,
`Kolesnik Law Firm
`49 Leavenworth St., Suite 200,
`Waterbury, CT 06702
`
`
`By:
`
`/s/ 440544
`
`
`
`
`
`Benjamin Paholke, Esq.
`Bona Fide Law, LLC
`P.O. Box 320231
`Hartford, CT 06132
`Tel. 959-203-2371
`LawyerBen@BonaFideLaw.net
`Juris # 440544
`
`
`
`22
`
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