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

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1 FORECLOSURE/MOTION FOR INTERIM COMMITTEE FEES AND EXPENSES AND/OR APPRAISAL FEES JD-CV-149 New01-15 STATE OF CONNECTICUT SUPERIOR COURT 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 Name of case (Plaintiff vs. Defendant) Connecticut Innovations, Inc. v. Andrade & Ashworth, Inc. et al Judicial District of I Middlesex Seller/Committee's Name Docket number MMX-CV Juris Number Paul Gozzi Seller/Committee's Address Telephone Number 129 Main Street, 2nd Floor, Old Saybrook, CT Date of Scheduled Sale I Reason Sale did not go forward 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 ~~~~ I~Dare _ ~V 08118/2015 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 Kahan, Kerensky & Capossela, LLP 45 Hartford Turnpike P.O. Box 3811 Vernon, CT *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

2 ";.. STATE OF CONNECTICUT DOCKETNO. MMX-CV S CONNECTICUT INNOVATIONS, INC. V. SUPERIORCOURT J.D. OF MIDDLESEX 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, That ofthis date, there are additional out-of-pocket expenses totaling $ (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, (a copy of which is attached hereto). Dated at Old Saybrook, Connecticut this 18 th day OIA"l1~j,!llr>,;J.,, ~ ;j /.~......~ v~./.- Ow Personally appeared Paul Gozzi who swore to the fact that the foregoing is true ancfac~tlrate -::::.. -E;. ~=. and to the best of his know/edge this 18 th day of A st, 15. -': - :: :3.\ 'c -, ;.;::-.. ',/.'- /~~.. --~---. '/,"~ "'-".....~.-'-"....~

3 Gozzi Law Offices, LLC 129 Main Street, 2 nd Floor Old Saybrook, CT Ph: Fax: August 18, 2015 Re: CT Innovations v. Andrade & Ashworth, et-al-mmx,.cv s99-s Services ; Review pleadings (including appraisal); letter to appraiser; complete Application for committee insurance and letter to Kronholm Insurance Services; s to and from title searcher; s to and from CT Sign (sign installer); s to and from NH Register/Middletown Press; enter ad language on judicial website Review proof of sign language; s to and from CT Sign & Post; s to and from NH Register/Middletown Press.8 TC w/nh Register/Middletown Press; check foreclosure ad on judicial website; review insurance binder; review title search; TC w/mr. C. Andrade (defendant) and memo to file 3.0 s 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; TC w/ c. 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 filing; review bank- appraisals, notice to bidders, agreement for sale TCs w/ Atty. Levine and Atty. Hannah re: bankruptcy ruptcy notice; TC w/ prospective bidder (G. Neri) Attendance at property re: standing orders/notice Preparation of Motion for Interim fees etc

4 21.1 Hours x $ Out of pocket expenses: Kronholm Ins. (committee ins.) Esposito & Associates (appraisal) CT Sign & Post Gina Sullivan (title search) NH Register/Middletown Press $4, $ $1, $ $ $ $2, Total Fees and Costs: $6,999.86

5 155 Oak StreetKTel P.O. BOX 6604 Fax Glastonbury. CT Kronholminsurance.com KRONHOLM IIStIAIU SIMB GOZZI LAW OFFICES, LLC PAUL GOZZI, ESQUIRE 129 MAIN STREET, 2ND FLOOR OLD SAYBROOK, CT DATE: July 2, 2015 ACCOUNT#: A GOZLAO-8 00 INVOICE#: PHONE: ( 86 0) (860) FAX FOR QUESTIONS, CALL: Karen M. Madore OA't!:)$.$U~D? TO EXPIR.:' ijpu Y#! Qw:m~j(# 8/16/15 8/16/16 C ~L (GOZLAO-8) KM(A).. DES a!ption.....amount ) COMMITTEE OF SALE lnew Policy ' ' * Total premium due 0.00 PAID IN FULL. THANK YOUl

6 Gozzi Law Offices, LLC 129 Main Street, 2 nd Floor Old Saybrook, CT paulqozzi@yahoo.com July 1, 2015 Kronholm Insurance Services Attn: Karen P.O. Box 6504 Glastonbury, (T Re:Foreciosure Sale Property address: 76 westbrook Industrial Park; Westbrook, cr Dear Karen: Enclosed, please find a completed application for committee liability insurance in the amount of $1,000, and our check in the amount of $ as payment for same. Please issue the policy with a starting date of July 1, If you could send methe binder and other information at your convenience, it would be appreciated. Thank you for your kind attention. Sincerely, ~L~ PAULGJ;~/--. PGjkk Enclosures.

7 ~I. ESPosito & Associates r:!ifrom:. Wlfham F. Esposito, Jr.!i :;::::;;;:os:to.& A$socia!es ReatEstate Appraisers 1674 Whi.lney Avenue. Suite 2 '! Hamden" CT TerephoneiNtmib'er: {203} 281~ TO: Attorney Paul Goui Gozzi Law Offices. LLC 129 Main Street. 2nd Floor Old Saybrook. CT Telephone:Nllmber:(86.0.) ' Aitemafe-Nulllber: Fa-number: E-PIail: IntemaIOrder#: LenderrCase#: C1ientFile:#: MafnFile# on form: 76WestbrooklndtlstrfalPk.2. otfjer File #: onform: CTlnnOliationsv.Andrade&Ashworth FederarIax Ii}: Employer 10: Lender. Attorney Paul GozziCRefit: Attorney Paul Gozzi Purchaser/Borrower: Andrade & Ashworth Incorporated Property Address: 76 Westbrook Industrial Park Road City: Wes.tbrook County: Mfddlesex State: CT Zip: tegaldescription: Volume: 29"8 Page: 1166 and Volume: 231 Page: 0449 Docket # MMX:-CVl ,,$ CT Innovations. Inc. vs. Andrade & Ashworth.1.riCOrporated', et al Appraisal SUBTOTAL 1, Check#:: Check#:: Check#:: Da:te: Date: Date: Description: Beseriplion: DeSCription: Thank You for Your Business. TOTALDUE $ FormNIV3 - "WinTOTAL" appraisal software by a la mode, inc ALAMODE

8 -r>; I. rnvoice 4046 THOMAS KEANE CT SIGN AND POST PO BOX 101 MIDDLEBURY, CT BILL TO: Paul Gozzi, Esq. 129 Main Street, 2 nd floor Old Saybrook, CT //2015 TOTAL DUE 76 Westbrook Industrial Park Rd, Westbrook, CT FORECLOSURE INSTALL $ DOCKET # MMX-CV S

9 /', r ". Gina M. Sullivan P.O. Box 423 Clinton, CT Invoice.INvoreE # 7/9/ i Paul Gozzi, Esquire 129 Main Street, 2nd Floor Old Saybrook, CT BIE:~TO.. SIiIJ;"'TO. ~.oue6ate... 8/8/20.15 ITEM DESCRIPTION AMOUNT full search 76 Westbrook Industrial Park Road, Westbrook (commercial) copies

10 '\t:l\:l!\ve:\ UE(;JSTER SHOREliNE =---Dmli3--- THE HE(;ISTERCITIZE.\ TIl( MiddlelownPn-,'Ss FarmingtonValJe);'l1mes.' ~Trader WEST HARTFORD NEWS ~~... u..&.l~u.~~. THE GRANBY NEWS ~ihenolphin THE LITCHFIELD COUN'IY TIMFS Post-Chronide RECEIPT New Haven Register 100 Ganda Drive New Haven, CT Phone: /02/15 Account: Name: Company: GOZZI LAW OFFICES, LLC Address: Telephone: Description: 129 MAIN STREET 2ND FLR OLD SAYBROOK, CT (860) LEGAL NOTICE FORECLOSURE Gross: $ Paid Amount: - $0.00 Amount Due: $ Date: 07/02115 Ad Date: 07/25/15 Class: 1220 Ad ID: Ad Taker: CRBCOLELLO Sales Person: Open (032301) Words: 59 Lines: 33 Agate Lines: 37 Column width: 1 Depth: Inserts: 4 Blind Box: Preprint Quantity: 0 Publication Middletown Press, middletownpress.corn LEGAL NOTICE FORECLOSURE AUCTION SALE Docket No.: MMX-CV S Case Name: Connecticut Innovations, Inc. v. Andrade & Ashworth, Inc., Et AI Property Address: 76 Westbrook Industrial Park, Westbrook, CT Property lype: Light Industrial Date of Sale: Saturday, August 15, 2015, 12:00 noon Committee: Paul Gozzi. Committee Phone: See Foredosure Sales at www';ud.ttgov for more det<j/led information ,7/25,8/8 We Appreciate Your Business! Thank YOU!

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