FORECLOSURE/MOTION FOR INTERIM COMMITTEE FEES AND …

FORECLOSURE/MOTION FOR INTERIM COMMITTEE FEES AND EXPENSES AND/OR APPRAISAL FEES

JD-CV-149 New01-15

STATE OF CONNECTICUT SUPERIOR COURT jud.

ADA NOTICE The Judicial Branch of the State of Connecticut complies with the Americans with Disabilities Act (ADA). If you need a reasonable accommodation in accordance with the ADA, contact a court clerk or an ADA contact person listed at jud.IADA.

Name of case (Plaintiff vs. Defendant) Connecticut Innovations, Inc. v. Andrade & Ashworth, Inc. et al Seller/Committee's Name

Judicial District of

I Middlesex

Docket number MMX-CV-14- 6012599-5 Juris Number

Paul Gozzi

304350

Seller/Committee's Address

Telephone Number

I 129 Main Street, 2nd Floor, Old Saybrook, CT 06475

Date of Scheduled Sale

Reason Sale did not go forward

860-339-5750

0811512015

Defendant/property owner filed a Chapter 11 bankruptcy petition on 8114[2015.

The Committee requests that the court order the following:

IZI Allow the Committee a reasonable fee for his or her services and reimbursement for his or her expenses as

listed in the attached affidavit;

IZI Allow a reasonable fee to the appraiser for his or her services

~V ~~~~

I~0D8a1re18/2015

_

Certification

I certify that a copy of this motion was or will immediately be mailed or delivered, electronically or non-electronically. to all counsel and self-represented parties of record, and that written consent for electronic delivery was received from all counsel and self-represented parties of record who were or will immediately be electronically served.

Date mailed or delivered 08118/2015

Names and Addresses of each individual to whom a copy of the motion was mailed or del!vered"

Carmody, Torrance, Sandak & Hennessey, LLP P.O. Box 1950 New Haven, CT 06509 Kahan, Kerensky & Capossela, LLP 45 Hartford Turnpike P.O. Box 3811 Vernon, CT 06066

*If needed, attach additional sheets with the name and address of each individual to whom a copy of the motion was mailed or delivered. Oral Argument is Not Requested Nor Required

STATE OF CONNECTICUT

DOCKETNO. MMX-CV-14-6012599-S

SUPERIORCOURT

CONNECTICUT INNOVATIONS, INC.

J.D. OF MIDDLESEX

V.

AT MIDDLETOWN

ANDRADE & ASHWORTH, INC. et al

AUGUST 18, 2015

AFFIDAVIT RE: COMMITTEE FEESAND COSTS

STATEOF CONNECTICUT COUNTY OF MIDDLESEX

ss. Old Saybrook

Personally appeared Paul Gozzi, who being sworn, does hereby depose and say as follows: 1. I am over the age of 18 years and believe in and understand the obligations of an oath. 2. I am the court appointed Committee for Sale in this action. 3. I have performed the legal services and incurred the costs as set forth in an itemized

statement dated August 18, 2015 and attached hereto. 4. That of this date, fees total $4,747.50. 5. That ofthis date, there are additional out-of-pocket expenses totaling $902.36 (copies

of said expenses/payments are attached hereto). 6. There is additionally a fee to the appraiser due and owing in the amount of $1,350.00

(a copy of which is attached hereto).

Dated at Old Saybrook, Connecticut this 18th day OIA"l1~j,!llr>

,;J.,,--- _

Personally appeared Paul Gozzi who swore to the fact that the foregoing and to the best of his know/edge this 18th day of A st, 15.

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Gozzi Law Offices, LLC 129 Main Street, 2nd Floor Old Saybrook, CT 06475 Ph: 860-339-5750 Fax: 860-339-5749

August 18, 2015

Re: CT Innovations v. Andrade & Ashworth, et-al-MMX,.CV-14-6012S99-S

Services

7-1-15

7-2-15

7-13-15

7-16-15 7-18-15 7-25-15 7-27-15 7-28-15 7-31;-15 8-5-15

8-6-15 8-9-15 8-13-15

8-14-15

8-16-15 8-18-15

Review pleadings (including appraisal); letter to appraiser; complete

Application for committee insurance and letter to Kronholm Insurance

Services; e-mails to and from title searcher; e-mails to and from CT Sign

(sign installer); e-mails to and from NH Register/Middletown Press; enter

ad language on judicial website

6.0

Review proof of sign language; e-mails to and from CT Sign & Post; e-mails

to and from NH Register/Middletown Press

.8

TC w/NH Register/Middletown Press; check foreclosure ad on judicial web-

site; review insurance binder; review title search; TC w/Mr. C. Andrade

(defendant) and memo to file

3.0

E-mails to and from CT Sign

.s

Trip to property (sign missing)

.5

Confirm NH Register/Middletown Press ad. Public

.3

Letter to property owner re: access

.2

TC w/appraiser

.2

TC w/Mr. Charles Andrade

.2

Review appraisal (Esposito & Associates); prepare and file return of appraiser;

c. TC w/ Tedeschi (CT. Innovation); TC w/ Atty. Levine

1.8

Preparation of Fact Sheet-Notice to Bidders and Sales Agreement

1.8

Respond to e-rnail of 8-7 from prospective bidder (Mat Field)

.4

TC w/ prospective bidder (Gwen Neri); prep for auction re: copies of

appraisals, notice to bidders, agreement for sale

1.2

TCs w/ Atty. Levine and Atty. Hannah re: bankruptcy filing; review bank-

ruptcy notice; TC w/ prospective bidder (G. Neri)

1.2

Attendance at property re: standing orders/notice Preparation of Motion for Interim fees etc.

2.0 1.0

21.1

21.1 Hours x $225.00 Out of pocket expenses:

Kronholm Ins. (committee ins.) Esposito & Associates (appraisal) CT Sign & Post Gina Sullivan (title search) NH Register/Middletown Press

Total Fees and Costs:

$4,747.50

$250.00 $1,350.00

$175.00 $291.00 $186.36 $2,252.36

$6,999.86

K

155 Oak Street

Tel 860.633.1440

P.O. BOX 6604

Fax 860.633.6699

Glastonbury. CT. 06033-6504



KRONHOLM

IIStIAIU SIMB

GOZZI LAW OFFICES, LLC

PAUL GOZZI, ESQUIRE

129 MAIN STREET, 2ND FLOOR

OLD SAYBROOK,

CT 06475

DATE: July 2, 2015 ACCOUNT#: A GOZLAO-8 00

INVOICE#: 086900 PHONE: ( 86 0 ) 339 -5750 (860) 339-5749 FAX

FOR QUESTIONS, CALL:

Karen M. Madore

OA't!:)$.$U~D? TO?EXPIR.:'?? ???ijpU?Y#!?Qw:m~j(#

8/16/15 8/16/16 C40194696604586 ~L (GOZLAO-8)

..

DES?a!PTioN

COMMITTEE OF SALE lNew Policy

* Total premium due

KM(A)

.????.?..A..MOUNT??)

250.00

-----'-. -- -------' --

0.00

PAID IN FULL. THANK YOUl

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